Here is a more comprehensive list of objections you might like to use:
Policy 8 . Promoting health and safe communities
Should result in access to high quality open spaces and opportunities for sport and recreation and anticipating and addressing natural hazards.
Restricts community access to the principal green spaces of West Oxford for 3-5+ years plus and reduces their extent thenceforth, giving less access to walking and cycling.
Relies on contractors to control pollution and hazards during construction. Adds to the traffic congestion on local roads which already suffer from excess vehicles and pollution.
Much of Seacourt Nature Reserve lost as a public amenity.
9. Promoting sustainable transport
Requires (para 113) that applications be supported by a transport statement or assessment ‘if they are likely to generate significant amounts of movement’.
The EA OFAS Planning Statement claims ‘There will be no transport impact from the proposals during operation’.
As they are planning 111 vehicle movements per day for 15 months of the three (+?) years of gravel digging this is a very dubious claim and presumable can only be ‘true’ because of their form of words, which must mean national level transport impact. They admit to ‘some impact on the local road network during construction from vehicles travelling to and from the site’ but say this is OK because they’ve submitted an outline Construction Traffic Management Plan in the Transport Assessment in Appendix M of the Environmental Statement.
None of this makes the scheme’s traffic without impact for local residents. The main workyard of the scheme is situated right up against South Hinksey village, necessitating noise and disruption (which the EA says it will try to control, but cannot in light of the number of vehicle movements and the scale of the digging out of the ancient floodplain meadows and earthwork construction).
Gravel and soil not used in the scheme, even though trucked around on the new access roads through the greenfield within the scheme, will still be taken out to the A34 and add to the already extreme congestion there.
-114 HGV movements per day from South Hinksey on and off the congested A34 near the Hinksey Hill Interchange (the A34 is a route of more than local significance)
-35 HGV movements per day from Seacourt Park and Ride onto the congested Botley Road plus contractors’ vehicles from the contruction area in the Seacourt Nature Road
- movement of construction vehicles across the busy Abingdon Road on the proposed haulage routes to the worksite on the southern border of Hinksey Park, ultimately causing futher congestion on the A34
-congestion at the south end of the scheme where the main construction access for the Hinksey Stream channel is via the Redbridge Park and Ride
12. Achieving well-designed places
Para 126 recognises that ‘good design is a key aspect of sustainable development, and creates better places to live and work, and helps make development acceptable to communities’.
Since EA claims, with some plausibility (since they’re not building a housing estate) to be preserving green belt and open spaces by creating a landscape infrastructure, this point probably too general to be useful in consultation The problem is a general one of principle i.e, that well-designed places are no substitute for established ecologies maintained with skill and respect.
However, the appalling visuals of the ‘motorway style’ bridge over Willow Walk (a large paved and railed vehicle bridge) in comparison with what exists (an informal, mature landscape with a pedestrian and cycle path through it) could be mentioned.
Para 127 ‘design should be developed with communities and reflect local aspirations and be grounded in understanding and evaluating each areas defining characteristics. Plans and policies should reflect these elements in their vision and expectations’.
West Oxford greenspace is a riverine landscape of ancient flood meadows characterised by mature crack willows. Changing this into wetlands (over 9 hectares of which will be offsite) and cutting down mature willows along Willow Walk and South Hinksey Stream does not observe these guidelines.
Para 130’ decisions should ensure development functions well and adds to overall quality of the area not just for the short term, but over the lifetime of the development’.
The fact that the EA claims this is a scheme for 100 years but budgets maintenance for only 10-15 and has no clear pathway for maintaining the scheme even for 20 years post construction does not comply.
13 Protecting green belt land.
states that the “Green Belt serves five purposes:
• to check the unrestricted sprawl of large built-up areas;
• to prevent neighbouring towns merging into one another;
• to assist in safeguarding the countryside from encroachment;
• to preserve the setting and special character of historic towns; and to assist in urban
regeneration, by encouraging the recycling of derelict and other urban land.”
EA has made a separate ‘Very Special Circumstances’ case in which other considerations outweigh harm. I see no point in arguing against this: it is better that the Green Belt have flood scheme than a housing scheme in it, especially as whole catchment planning hasn’t been undertaken and will be looked at again (statements vary) in 2028 or 2070. Focus should rather be on the channel which does unnecessarily large environmental damage within the scheme without commensurate benefit.
14 Meeting the Challenge of Climate Change, Flooding and Coastal Change
Again, the problem of the channel’s disproportionate cost and destructiveness and the absence of whole catchment planning is probably the strongest challenge against this.
The EA also claim under this heading to have met the principles involved by including measures to maintain and enhance biodiversity, landscape and recreation, three areas better challenged under separate headings.
15 Conserving and Enhancing the Natural Environment
Paragraph 180 of the NPPF states the principles:
a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;
b) development on land within or outside a Site of Special Scientific Interest, and which is likely to have an adverse effect on it (either individually or in combination with other developments), should not normally be permitted. The only exception is where the benefits of the development in the location proposed clearly outweigh both its likely impact on the features of the site that make it of special scientific interest, and any broader impacts on the national network of Sites of Special Scientific Interest;
c) development resulting in the loss or deterioration of irreplaceable habitats (such as ancient woodland and ancient or veteran trees) should be refused, unless there are wholly exceptional reasons (note 63 specifies ‘For example, infrastructure projects (including nationally significant infrastructure projects, orders under the Transport and Works Act and hybrid bills), where the public benefit would clearly outweigh the loss or deterioration of habitat’) and a suitable compensation strategy exists;
d) development whose primary objective is to conserve or enhance biodiversity should be supported; while opportunities to improve biodiversity in and around developments should be integrated as part of their design, especially where this can secure measurable net gains for biodiversity or enhance public access to nature where this is appropriate.
Points a and c are the most pertinent: the EA claims it is mitigating against the destruction of MG4a grassland, mature trees and ancient floodplain meadow landscapes and securing measurable net gains for biodiversity/enhancing public access to nature where appropriate.
This is what it recognises and claims:
The nature conservation importance of the study area is reflected in the designation of international
(e.g. Oxford Meadows Special Area of Conservation) and national conservation sites as well as local
sites of wildlife value, some of which support nationally rare habitats (such as MG4a grassland
communities; a National Vegetation Classification) and species including the protected Snakeshead
fritillary and nationally scarce Creeping Marshwort. The scheme and associated working areas are
located within and adjacent to various Local Wildlife Sites, Sites of Local Importance for Nature
Conservation (Oxford City) and Conservation Target Areas (e.g. Oxford Meadows and Farmoor, and
Thames and Cherwell at Oxford), in addition to areas of high ecological value such as Hinksey
We have therefore designed a fully integrated multi-beneficial scheme, which not only protects people
and property from flooding but also protects and enhances biodiversity (delivering a net gain in
habitats), enhances existing meadow landscapes and provides some new amenity features for the local
community. This recognises the quality of the natural capital of the application area.
Much of the mitigation is offsite.
(from Riki): Under the Environment Act 2021 the scheme must provide at least 10% biodiversity net gain. This is only deliverable if the EA provides offsite
c. 9.2 ha of wet woodland
4-5 km of hedgerows
Approx. 730m of ditches are provided off-site (Environmental Statement, Appendix 5, Biodiversity Metric, pp.5-7).
The EA is insufficiently clear about the time taken to equal existing biodiversity. Saplings planted offsite cannot develop to maturity within the projected time of the scheme’s maintenance budget (10-15 years only secured). Crack willows need 45 years. Newly planted hedgerows and tree groups take years to develop into fully fledged ecosystems and to replace the vita mycelium networks that link trees growing in groups.
Maintenance problems: The proposed replacement of ancient floodland by wetland does not allow for the fact that if maintenance does not extend beyond 10-15 years, the wetland and the ‘new ‘natural’ channel’ could clog up and not only impede mitigation, but diminish flood protection.
Mitigation is claimed through the provision of land that is already open to the public, e.g land behind the Botley Rd shopping malls and the grassland proposed SE of Osney Mead, which has long been managed as good quality semi-improved grassland, but would be dug up or scarified and seeded with green hay from Hinksey Meadow
Loss of 1.3 ha of the nationally rare MG4a grassland is calculated separately. EA admits this grassland has a high chance of not successfully relocating: MG4 Grassland Mitigation Strategy, pp. 6, 8.). [in fact the most authoritative research papers show it has never been and is unlikely to be translocatable as it takes so many hundreds of years to develop its systems and high levels of biodiversity, see e.g. McDonald ].
Wildlife: EA claims to be creating a new corridor for wild life through the scheme. Actually it’s disrupting an existing one. Its plans assess badger impact at Kennington but not at Seacourt and Jewson’s Field. Otters are dismissed as ‘a mobile species’ that can move themselves out of the way during the scheme. ‘Best safeguards’ are promised for minimising adverse effects on fish.
Individual plans here are very complex and defy digestion by the public within the consultation period.
For instance, the Bat Mitigation Scheme (Environmental Statement Appendix D-13
IMSE500177-CH12-XX-00-RP-EN-0711 maps gives detailed plans for 20 areas within the scheme. Its larger scale maps and surveys show 12 species of bats nesting not only in trees throughout the scheme, but in bridges (Kennington, Willow Walk packhorse bridge, Southern bypass bridge, Botley Rd Bridge, and shows bats as prevalent along watercourses and ditches in most areas. It twenty subplans show in vivid detail all the mature and other trees to be cut down. However assessing the adequacy of the mitigation would require particular bat expertise. It is generally clear that there will be a big impact on bats, but not easy to understand the implications without expert advice.
16 Conserving and Enhancing the Historic Environment
There are Scheduled culverts within the area and other features. The only one named in their OFAS Planning Statement is the unscheduled but nationally important medieval causeway under the Old Abingdon Rd. Historic England has said that the scheme would cause ‘less harm than substantial harm.’
I cannot see how to object here without specialist expert advice and have written to an archeology colleague familiar with West Oxford.
17 Facilitating the Use of Sustainable Minerals
Gravels in the area are not designated as a Mineral Strategic Resource Area or Mineral Safeguarding Area in the Oxfs Local Minerals and Waste Plan for 2017 say the EA. But site constraints, proximity of residents etc make ‘winning’ the gravels not an option to be easily followed. They conclude gravel is a by-product, not the object of their scheme. They looked at having HS2 use the gravel, but decided the quantitites were insufficient. All the same, the Materials Management Plan (pp. 10-11) estimates 900c.m per day need to be transported each day in a minimum of 111 vehicle movements, with the longest journey being 280 miles round trip, shorter trips being transporting material from one area of the scheme to another. They are looking at a range of sites (in other schemes and in private companies) north and south and along the A34 and A40 in Oxfordshire and elsewhere to which the spoil can be taken.
Again the general point of the vast amount of excavation and traffic carrying spoil generated by the channel seems to be the chief objection here, but probably better made under one of the earlier headings.