I write regarding Natural England’s lack of objection to the Oxford Flood Alleviation Scheme (https://myeplanning.oxfordshire.gov.uk/Document/Download?module=PLA&recordNumber=10517&planId=65770&imageId=577&isPlan=False&fileName=Consultation%20Response - Natural%20England.pdf). I am appalled that Natural England is willing for such a very environmentally harmful and inefficient scheme to go ahead in its present form, given the serious impact it would have on biodiversity, and its non-adherence to the mitigation hierarchy.
1. The proposed scheme would have significant and irreversible impacts on Hinksey Meadow, which is a rare MG4a meadow which requires specific water levels and management. It would destroy 1.33ha of MG4a meadow, and threaten the remaining 7.2-7.7ha of MG4a meadow. There are currently only 194.5ha of MG4a meadow left in England and Wales. Although the Environment Agency proposes to try to replace this loss by sowing seeds from Hinksey Meadow elsewhere, the environmental statement itself states that "This habitat will not fully replace the unimproved grassland lost, because part of its value comes from having been managed in the same way for hundreds of years" (p.182). Essentially this is the loss of an irreplaceable habitat and should be refused, since there are not ‘wholly exceptional’ reasons for taking it forward (NPPF para. 180c).
2. The proposed scheme would have significant and irreversible impacts on two Local Wildlife Sites: Hinksey Meadow and Kennington Pit. Policy C7(iii) of the Oxfordshire Minerals and Waste Local Plan notes that “Development shall ensure that no significant harm would be caused to… Local Wildlife Sites… except where the need for and benefits of the development in that location clearly outweigh the harm”. The benefits of a channel are minor - they represent about 5.7% of the homes protected by the scheme - compared to the harm to these sites.
3. The scheme would negatively affect the rare creeping marshwort growing in the field south of Willow Walk. Creeping marshwort is listed as Endangered in the Red Data Book. It is found only in Oxford, and is one of two reasons why Port Meadow is a site of international nature conservation importance.
4. The scheme would destroy thousands of mature trees. Although the Environment Agency proposes to ‘replace’ these trees, the lost trees would be mature, whilst the replacements would be whips that will take many years to have equivalent biodiversity, landscape and carbon fixing benefits.
5. The scheme would destroy most of the Kendall Copse community woodland, which was planted by local people.
6. It would affect protected species. Table 8.5 of the environmental statement concludes: amphibians ‘moderate negative’, bats ‘moderate negative’, otters ‘moderate negative’,
7. It seems to struggle to achieve the biodiversity net gain required by the Environment Act 2021, despite the much-vaunted biodiversity benefits of the new wetland habitats. The Environment Agency have not yet responded to a Freedom of Information request about their biodiversity net gain calculations. However the calculations of Sec. 8.4.3 of the environmental statement suggest that a net gain can only be shown if significant assumptions, not consistent with the precautionary principle, are made about replacing existing meadows with MG4 meadows, even though this replacement will be only partially effective at best. Replacement hedges and wet woodlands would have to be provided off site, despite the large size of the area that would be taken up by the scheme.
8. Furthermore biodiversity net gain should only be a last resort, after avoidance and mitigation, but this is not being done by the scheme. The scheme makes an effort at mitigation in terms of narrowing the channel in some areas, but makes no attempt to avoid (no channel).
I am horrified that Natural England (“We help to protect and restore our natural world”) makes no attempt to require the Environment Agency to consider less damaging alternatives that would follow the mitigation hierarchy (including for biodiversity net gain) and reduce the impacts above. The Environment Agency seems stuck on providing a wide, harmful, inefficient channel, even though alternatives to this exist, including a phased ‘monitor and manage’ approach (everything except the channel at first and then a channel only if this does not work) and a pumped pipeline which would take up much less land and work better in terms of flood alleviation.
I urge you to reconsider Natural England’s response to this destructive and inefficient scheme; to object to it in its current form; to require the Environment Agency to properly follow the mitigation hierarchy required in the National Planning Policy Framework and Environment Act 2021; and to call for the Environment Agency to actively consider alternatives that do not involve a channel. Yours sincerely,
Dr. Riki Therivel