Postscript on Seacourt P&R extension

Members of OFA steering group, along with Councillor Colin Cook, and Stephanie Ouzman (a member of MP Layla Moran’s staff), met with Council officers and their consultants WYG on 27 April 2018 to try to obtain answers to a series of questions about the proposed Seacourt P&R extension. Subsequent to the meeting there was a further email exchange and answers were provided to a number of outstanding points by the Council. We appreciate having had this opportunity for dialogue about the issues, and now feel we understand what is being proposed.

It’s clear from the response from the Council that the planning documents did not provide a clear reference to the use of an impermeable membrane at the site. It wasn’t spelled out in the application, and the documents give no details of the tanking and how this would work. This has now been explained to us.

We believe we should have been able to get answers, as of right, on points of issue like this through the planning consultation. The fact that we couldn’t was a failure of the process, and below the standards we have observed in other applications locally. The County (LLFA), Environment Agency and planning officer didn’t, in our view, fully understand what WYG were proposing – this is clear from correspondence with them during and subsequent to the planning process. Councillors, therefore, approved a proposal which had information gaps in it on flood risk, and which they couldn’t have fully understood. In our view this happened because the planning outcome had already been pre-determined, and our queries were ignored because the process was designed to secure a particular outcome. 

Now that we know what’s actually proposed, we don’t believe (as far as we can judge) that the development poses an immediate and direct flood risk to local properties, which is obviously a welcome outcome. But all development in Flood Zone 3B by its very nature creates a risk to the consistent and predictable functioning of floodplains. Hence planning policy, which incorporates learning outcomes from decades of previous developments in areas subject to flooding, prohibits such developments because the medium and long-term consequences can be unexpected and far-reaching. 

We believe the development is inconsistent with planning guidelines – building in the floodplain and Green Belt – but recognise the planning officer advised otherwise, and that Councillors agreed with his interpretation. We regret that the Secretary of State did not choose to examine this issue, and believe the Council’s decision sets an unfortunate planning precedent. We also remain unconvinced of the need case.

The car park extension will be an additional source of pollution during a flood, and there is no way to stop this. This is undesirable, and a negative environmental impact. The Seacourt P&R extension is just to the north of OFAS which has an ‘environmental vision’ aiming to improve freshwater habitat – a vision the Council signed up to. 

If the development goes ahead, we’ll be watching with interest to see how often if floods and how the local authority deals with this. At times of flooding the car park will be a potential source of risk to users and members of the public. We will also continue to be vigilant about further planning applications brought forward by the Council, as the process has left us feeling we can’t rely on the local planning authority, or members of Council planning committees, to safeguard the public interest. We hope public concerns will be better addressed should any similar situation arise in future.

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Representatives of OFA will be meeting with City Council officers and their consultants this afternoon to discuss our continuing serious concerns over the (now approved) Seacourt P&R extension. Cllr Colin Cook will also be there as will a representative for Layla Moran MP who is unable to attend in person: both strongly opposed the application.

There’s an article in today’s Oxford Mail

http://www.oxfordmail.co.uk/news/16188420.Flood_hit_Seacourt_Park_and_Ride_site_would_have_been___39_closed_for_three_weeks__39__this_year/

 

 

Objecting to Seacourt P&R extension – our latest comments

 

We remain strongly opposed to the planning application by Oxford City Council to extend its Seacourt Park and Ride into Oxford’s vital flood plain. There has been a nibble, nibble attrition of the flood plain over many years leading to worse flooding. That the City Council should itself be seeking to extend a car park into the flood plain that protects our city is quite extraordinary.

Here are our latest comments:

OFA comments on FRA Nov 2017 Final

OFA comment on PS Addendum Nov 2017 Final

Redbridge vs. Seacourt P&R from south + Maps

Letter to EA 30 November 2017_final

Lime stabilization considerations Nov17

Seacourt P&R – proposed extension

We are very strongly opposed to the proposed extension by Oxford City Council  of Seacourt Park and Ride on the Botley Road, which has been mentioned here before.

If you want to see our latest objections go to http://public.oxford.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=OFE2FHMFIAV00  where you can see not only ours but the serious objections from others too.

If that doesn’t take you there direct go via https://www.oxford.gov.uk/info/20066/planning_applications  click ‘View and comment on planning applications’, twice, and then search for Seacourt or 16/02745/CT3.

Seacourt P&R in the Oxford Mail; smart signs, plus risk to life

This article in the Oxford Mail talks about the possibility of  ‘smart signs’ – electronic boards – on the ring road, to alert drivers to where there are empty park and ride spaces around Oxford. This could obviate the (claimed) need to increase the number of spaces at Seacourt, instead pointing drivers to (say) nearby Redbridge. According to an earlier report in the Oxford Mail there is apparently so much spare capacity at Redbridge that the City Council proposes to remove 270 parking spaces, and is quoted in the newspaper as saying that the loss of these spaces would be ‘marginal’.

It seems to us to be inconsistent for the City Council to argue that removing 270 spaces at Redbridge is perfectly ok, while at the same time arguing a burning need to build new spaces at Seacourt – in the floodplain, on Green Belt land, contrary to local and national planning guidance and, as far as the present application goes, creating a potential risk to life (see towards the end of the first newspaper article and our previous post). Never mind the cost, which has already risen from about £2million to over £4 million.

 

Seacourt P&R – Key Point 4: Oxford City’s Planning Strategy

cs2

Within Oxford City Council’s main strategic planning document, the Core Strategy, Core Strategy 2 (CS2, see above) states:

‘Greenfield land will not be allocated for development if any part of the development would be on Flood Zone 3b.’ 

Our comment: The proposed site for the new car park is greenfield, and in functional Flood Zone 3b.

CS2 also says that ‘development will only be permitted on greenfield land if it is specifically allocated for that use in the [Oxford City Council’s] Local Development Framework’.

Our comment: This site is not so allocated.

Core Strategy 11 (CS11) says:

‘Planning permission will not be granted for any development in the functional flood plain (Flood Zone 3b) except water-compatible uses and essential infrastructure.’

Our comment: The proposed site is neither ‘water-compatible’ (a category intended for developments such as marinas), nor ‘essential infrastructure’ (which includes projects such as water treatment works, or roads which have to pass through a floodplain).

In our view the position could not be clearer – this proposal is, in fact, precisely the kind of development that the Council’s own strategic planning policy is there to prevent.

Seacourt P&R planning application vs. proposals for Redbridge P&R – comment

We have made further comments (our fourth) on the Seacourt P&R planning application to the Planning Officer today, 19 December 2016:

Planning Application 16/02745/CT3

We wrote to you earlier with regard to the validity of the so called ‘sequential test’ carried out for the Seacourt P&R extension. In addition to our previous argument about the existence of an option of negotiating with the landlord to erect decking on the current site, we have further grounds for objection to the ‘sequential test’.

The City Council Executive Board papers for 15 December 2016 include proposals for removing 270 parking spaces at Redbridge to accommodate a new waste transfer facility. It appears there is excess capacity at Redbridge P&R. The analysis of occupancy of Redbridge and Seacourt P&Rs included in the Executive Board papers, show that there is existing spare capacity at Redbridge, and but for the planned waste facility this could relieve Seacourt during the week. There is also capacity at both car parks sufficient to adsorb expected increases in weekend traffic once the Westend development completes.

The Planning Statement for the Seacourt extention makes no mention of the surplus capacity available at Redbridge. The review of Redbridge in the ‘sequential test’ simple says that there is limited scope to ‘expand’ Redbridge. This is deeply misleading. There is clearly scope to redirect surplus traffic from Seacourt to Redbridge, which might be achieved at no cost simply by use of differential pricing – i.e. making Seacourt more expensive. In the Seacourt application we’re told Seacourt has to expand because there isn’t an option at Redbridge. But the Redbridge proposal is using the possible expansion of Seacourt to justify closing parts of Redbridge. So the need to expand Seacourt is at least in part being created by the Council’s wish to re-purpose part of the Redbridge site. This is clearly an unacceptable justification for the Seacourt extending into the floodplain on Green Belt land.

Given the existence of sufficient capacity to deal with any increased weekend traffic related to the Westend, the arguments for the extension, contained in 3.20 of the Planning Statement, appear extremely general. Is this really the best justification the Council can offer for breaching its own core strategy, national policy on Green Belt, and guidance on development in the floodplain? The justification for this move appears to rely wholly on longer term projections about potential increases in traffic resulting from a growth in the city and county during the next 15 years. Such needs should be addressed through a strategic planning process.

We understand that the Council has to increasingly rely on the revenue it earns, and perhaps the real, unstated reason why this proposal has come forward is financial. But even this doesn’t make sense. The capital cost has now doubled from the original budget to £4.1m. Extra income from the extension, assuming rates increase from £2 to £3 a day, is projected at £160,000 a year according to the Executive Board papers. Even assuming this revenue is achievable the investment would take more than 26 years to pay back, and that is without discounting for the cost of capital. If, as we believe is likely, the site floods regularly, has to be closed part of the year, and faces significant maintenance costs, the payback period will be much longer.

This scheme is a nonsense and should not proceed.

Application by Oxford City Council to extend Seacourt Park & Ride

Application by Oxford City Council to extend Seacourt Park & Ride  (Oxford City Planning application no. 16/02745/CT3).

We are strongly opposed to this application to build a car park extension right in the Oxford floodplain.

Our key points are:

Inappropriate development in the floodplain – contrary to Oxford City Council Core Strategy, CS2 – this is a greenfield site. It is also contrary to City Council Core Strategy 11 – it is neither ‘essential infrastructure’ nor ‘a water compatible structure’.

Not consistent with national planning policy framework (NPPF) guidelines.

Inappropriate development in the Green Belt.

A planning application for a similar scheme on the same site was rejected by the Secretary of State in 1999. Planning law has become tighter since.

County Transport Strategy envisages new P&R sites at Cumnor and Eynsham over the next few years; the present proposal is at variance with that. Traffic coming off the A34 and A420 may face increased delays in reaching the P&R.

Flood-risk assessment flawed:

  • fails to note the serious floods since 2008
  • does not properly consider the frequency with which this low lying site actually floods, which is often (it’s functional floodplain)
  • permeable pavement recommended only slows run-off when flood event are so low risk it’s irrelevant. As soon as a significant flood event starts to develop the car park will be under water.

Emergency evacuation plan is inadequate and lacks detail. The site is at high risk of flooding, being 0.5-1 m lower than the existing car park. There is a significant risk to vehicles and people during a flood event: any emergency plan has to be very robust. Extra resources could be needed from already stretched emergency services. In a 1 in 100 flood the water would be 2m deep.

The ground is subject to movement and would require further investigation to see if remediable stabilisation would even work.

The site itself may be damaged by prolonged or severe flooding, even with surfaces broken and swept away. The fences proposed for the perimeter of the 2 ha site, and structures on the site, would be very vulnerable in a large scale flood.

The proposed permeable surface will be impaired by silt and other debris: it will require cleaning which may or may not restore its permeability. After prolonged flooding such paving may even have to be replaced (in early 2014 this site would have been under a significant depth of water for several months).

If fences, structures on the site, and cars were swept away they could end up blocking the nearby Seacourt which is a vital flood channel.

The proposal does not take proper account of the latest plans for the Oxford Flood Alleviation Scheme in this area.

The rationale for this extension being needed is that the present car park cannot be given a decking storey because of a covenant on the land. No such covenant has been produced by the applicant and we cannot find one. What there is is a lease agreement, with could potentially be varied by negotiation with the landlord, which could make this whole scheme unnecessary.

Oxford is at risk of flooding. The principle of not building on greenfield sites in the floodplain must be adhered to.

These reasons are set out in more detail in the following documents submitted to the planning authority, Oxford City Council (links download pdfs).

  1. Our initial objections (28 Nov 2016)
  2. Further points (5 Dec 2016)
  3. Address to Council (5 Dec 2016)

We are working hard to get our message across to the decision makers and to other people who may wish to comment. If you agree with us that this development should not be allowed to go ahead please do say so via the Oxford City planning website or speak to your local City Councillor.