91% of responses to OFAS consultation object

OFAS Third Party Comments

Updated on 1^st June 2022 V1

1

I strongly object to this planning application and urge you to reject it in its current form due to the channel. Oxford does have a problem with flooding but I am very concerned about the channel element of this proposal. Constructing a 200m wide channel between the Botley Road and the Old Abingdon Road is an environmentally destructive proposal and does not appear to be good value for money.

I want to see the implementation of an alternative option, such as a no-channel plan with the clearing of the existing streams given the opportunity to be assessed properly. The proposed scheme does not follow the National Planning Policy paragraph 180 which states that if biodiversity is significantly harmed by a development, then the scheme must be mitigated, or turned down. The mitigation theory would involve either avoiding impact (no channel) or mitigating impact (a smaller channel/piped water).

THE CHANNEL

The section of the scheme with the most environmental, health and social costs is the channel. The Environment Agency’s figures show that the overall scheme reduces at risk houses from 1126 to 180 in a once in 100 years flood. However, it also shows that the channel accounts for 5.7% of this reduction. The number of houses that would benefit from the channel is therefore relatively small. Independent reports put the figure at 54 houses. Compared to the very large economic and environmental costs made to protect them this is a small number. Prioritisation is being given to a few households over the impact on a much greater number of people and the significant loss of rare habitat.

85% of the proposed measures are not dependent on the channel. Improved flow at the A34 bridge, the embankments and bunds, for example. I strongly believe that there should be an incremental approach, managing and monitoring results at each stage of the scheme. Flood alleviation without the channel would cost less in monetary, environmental and social terms and it would therefore be vastly preferable both to current residents and future generations.

The channel is a very large project and does not appear to have other working examples to prove that it would efficiently cope with increasing future flood levels. Independent hydrologists and planners do not accept that the channel would bring certainty to the end of flooding in the area. Turning an ancient flood meadow into a gravel plain is not guaranteed success on a functional level and would certainly destroy the existing habitat for ever.

HINKSEY MEADOWS

My main concern is the environmental damage that will be caused by the channel: the destruction of a rare grassland and its biodiversity. At a government level we are constantly, and quite rightly, made aware of the need to preserve our shrinking biodiversity and rare habitats, and to decrease our carbon levels. This proposal is in complete contrast to this policy.

Hinksey Meadows are an extremely rare and precious habitat. It is MG4a grassland and there are only 4 square miles of this habitat left in England and Wales. It is vital that this is preserved and cared for. It has been managed for 1,000 years the channel would destroy 2 hectares this grassland. The Environment Agency say that the remaining 5 hectares may well dry out and loss its unique conditions.

The UK has lost 97% of its meadows in the last 100 years and it is crucial that the remaining 3% is preserved. There are only 4 square miles of MG4a grassland left in England and Wales and Hinksey Meadows forms part of that.

The Environment Agency plans to sow seeds taken from Hinksey Meadow elsewhere to mitigate the damage done by digging the channel. However, the Environmental Statement states that it is doubtful it will be successful and “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”.

Research from the Centre for Hydrology and Ecology states that it will take 150 years for the majority of species to colonise a new meadow so, even if reseeding were successful, we would not see the proper results for many generations.

Destruction of Hinksey Meadows is as bad, if not worse, than destroying Port Meadow. Hinksey Meadows are home to the rare Creeping Marshwort which is listed as Endangered in the Red Data Book and is only found in Oxford. It is also found on Port Meadow which is treasured as an Oxford landmark but is not classed as rare MG4a grassland.

The Environment Agency plans to replace the MG4a grassland with the proposed new wetland is not acceptable. It is much easier to create a new wetland than recreate an ancient floodplain and is not an acceptable substitute.

Protected species such as amphibians, bats and otters would be affected ‘negatively’, as listed in Table 8.5 of the Environment Statement. To have these animals so close to the centre of our city is something we should treasure and protect.

TREES

The scheme would result in the loss of at least 2,000 trees in the area (Table 7.5 of the Environment Statement).

Our County Council’s Director of Environment and Place stated that their updated policy on trees “would put an emphasis on the ‘presumption in favour of trees’ because of the host of benefits they provide to the climate, the environment and the places where people live”.

The Environment Agency proposes to replace the lost trees but the trees that will be felled are mature. The replacement whips will take decades to have the equivalent biodiversity and carbon-fixing benefits as the mature trees. The scheme would destroy also most of the Kendall Copse Community Woodland which was planted by local people.

CARBON

“Oxfordshire will make climate action a top priority in all decision making” states Oxfordshire’s Climate Declaration. This is contradicted by this scheme. The Environmental Report states that the proposed scheme will generate almost 20,000 tonnes of carbon over its lifetime, which goes against the aim of having a net-zero carbon Oxfordshire by 2050.

The carbon storage capacity of meadows and soil is an area of new and ongoing research. The Open University’s Floodplain Meadow Alliance recognises flood meadows “value as areas for flood storage” and writes that in the UK 95% of sequestered carbon is held in the soil: digging up soil always releases carbon. Species-rich flood meadows, where carbon has been held for centuries, hold the most carbon after peat.

The Environment Agency plans to dig up 700,000 tons of soil from the floodplain meadows for its channel. The soil disturbance and the displacement of gravel and soil, the loss of trees and hedgerows will have a huge carbon cost that is not in line with the Oxfordshire Climate Action Declaration.

TRAFFIC LEVELS

Not everyone in Oxford chooses to own a car but we are all affected by traffic. The Abingdon Road already has heavy congestion and the frequency of queueing cars is much worse since the Westgate Centre was built.

Congestion at the Kennington end of the city would probably be unavoidable in any version of the scheme. However, excavation of the channel would be responsible for the great majority of the increased traffic levels.

There will be approximately 200 HGV movements a day around the A34 for 3-5 years as they move 455,000 cubic metres of gravel, build roads on the site and build the channel. There will be an average of 144 HGV movements a day at South Hinksey, 36 HGV movements a day on the Botley Road, 14 movements a day on the Abingdon Road. An HGV will join the A34 multiple times an hour.

Contractors' vehicles will add more traffic. The Environment Statement estimates there will be about 100 construction workers and this will inevitably add to the congestion.

A 40mph limit on the A34 between North Hinksey and south of South Hinksey is being proposed by the Environment Agency because the traffic is expected to be so bad around South Hinksey. This will have an impact on people far beyond Oxford. I am doubtful that a temporary 20mph road joining Kennington and the Old Abingdon Road will cope with increased levels of traffic.

The A34 is already a very crowded road and any incident leads to very long tailbacks and this affects traffic on the Abingdon Road. I question whether this is an acceptable price to pay in order to reduce flooding in around 50 houses.

POLLUTION

The project is expected to last 3-5 years and during this time there will be dust, pollution and noise for local people. Oxford’s pollution rates are already 718,000 tonnes per year above recommended limits and the council should be working to reduce levels, not add to them.

Sand and gravel extraction will be a particular problem, causing dust and health-related problems. These issues will be particularly acute for villagers in South Hinksey and North Hinksey, villages whose residents will have little benefit from the channel. The A34 by Yarnells Lane is already an area above the legal limits for vehicle emissions.

NATIONAL PLANNING POLICY

The channel does not appear to future-proof enough properties to justify its cost. The cost of this scheme will be 122 million to 154 million for this project. However, this does not take into consideration recent inflation of building costs. The channel will cost 23 million which is 25% of this sum, yet will give only 5% of the benefits.

I would urge the Environment Agency to consider any no-channel alternatives. Or piped alternatives. Or first-stage only channels.

The National Planning Policy Framework paragraph 180 states: “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”.

This National Planning Policy should be followed. I do not believe that permission should be given for this scheme to go ahead in its entirety and less expensive, less harmful options should be implemented first.

ACCESS TO GREEN SPACE

The proposed scheme would restrict public access to almost all of this publicly-accessible open space for ever. This is a severe impact because access to green space is increasingly considered crucial to well-being.

Along with greatly increased numbers of walkers, I have particularly enjoyed the space during the last 2 years. Seacourt Nature Reserve was visited by almost 100 people on an average day in February 2018, according to the Environment Agency’s data. Many more visit during spring and summer. As compensation, the Environment Agency is suggesting public access to Jewson’s Field but this is already accessible to the public and is therefore not compensation.

ONGOING MANAGEMENT

At the moment the Environment Agency is not clearing the streams. They should do this instead of building a destructive and ineffective channel. The streams in the area are blocked because of the number of trees that have come down. Clearing these trees and the existing culverts is probably the easiest and most cost-efficient way of reducing flooding.

Without mowing, grazing or cutting back of encroaching trees and plants, vegetation will accumulate, reducing the effectiveness of the channel over time. The Full Business Case of 2019 does include costings for maintenance but only for the first 10 years after construction.

The Environment Agency has many demands on its funds, which have been reduced, and struggles to cope with incidents such as sewage spills into the Thames. Whether it will be able to manage the channel properly is questionable.

Who will take on management of the channel after the Environment Agency? Environmental groups may not have the financial capability to meet this task. Maintenance of the channel and the surrounding proposed wetland is a considerable challenge. If not properly maintained it will silt up and the effectiveness of the channel will be diminished.

GREEN BELT

The proposed scheme is in the Green Belt. The National Planning Policy says in paragraph 137: “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”

The National Planning Policy paragraph 138 states the Green Belt is “to preserve the setting and special character of historic towns”. The proposed scheme will destroy an area that is very valuable to local people and the iconic landscape of Oxford will be changed forever with more fences and less trees.

What is the point of having a National Planning Policy Framework if it is so ignored?

A NATIONAL ISSUE

National-level issues are raised by this scheme and therefore should be decided by a national planning inspector or Parliament rather than through a local planning application.

It would reduce traffic speeds on part of the A34 national trunk road with implications beyond Oxfordshire.

Destruction of nationally-rare MG4a grassland

It is a very poor use of public funds

I want the Environment Agency to properly consider a no-channel approach, a piped option or a channel for a much smaller section - options that they have made no significant attempt to consider. I very much hope that this proposal will be turned down in its current form because of its damaging channel element.

2

The proposed flood alleviation channel has at least the following problems:

1. It will be totally destructive of a significant percentage of Hinksey Meadow, which itself represents a significant proportion of the remaining water meadow of its type in the entire country. Among many other plants, this meadow is home to the Snake’s Head Fritillary, a plant officially classified as “vulnerable”.
2. The loss of trees (2-4000 depending on whose estimates one prefers) 3. The loss of miles of hedgerows and the attendant loss of biodiversity, both flora and fauna. The suggestion that the consequences of this and item 2 above will be diminished or even eradicated by a replanting scheme, is disingenuous at best. It will take at least 40 years for the current level of biodiversity to be restored (and possibly much longer) 4. The loss of ca. 250 acres of agricultural land 5. Major traffic disruption on the A34 6. The vast majority of reduction in flood risk will come from maintenance/improvement of existing flood defences at a cost that is miniscule by comparison 7. It is understood that an alternative scheme is available which has significantly lower environmental impact and is also cheaper 8. The loss of a major local amenity, some on a short term basis (a few years) and some permanently

3

I am objecting due to the loss of Willow Walk as a safe commuting route for school children (primary and secondary) and walkers/cyclists as well as being a popular running and dog walking route during the construction work. Botley Road is not a safe or quick alternative for these users, and will leave many switching to cars instead, at an environmental and economic cost. We will lose our community connections to Grandpont and Osney and beyond during this period, and it will encourage bad transport habits that will be hard to shake off.

4

I am concerned that the woodland known as Kendal copse on both sides of the Kennington Road to the north of Kennington village will be destroyed by the works to the railway bridge . This woodland was planted by the community in the 1990's and is just beginning to look mature, there is a diversity of trees, hedgerows and wildlife biodiversity in the two areas either side of the road into Kennington. Destruction of these trees in the context of climate change makes no sense at all. Please do not destroy this young woodland planted by children of our community!

5

I object to this planning application in the strongest terms. I am very opposed to the construction of the channel between the Botley Road and the Old Abingdon Road.

The construction of a channel appears to be the most destructive part of the proposed scheme. I would accept flood alleviation plans apart from the channel and would like alternative plans to be adopted.

A step-by-step approach, clearing existing streams, clearing culverts and maintaining the current flood meadow would be a far better approach in terms of financial expenditure and environmental cost. The proposed scheme does not follow the NPP paragraph 180 which states that if biodiversity is significantly harmed by a development, then the scheme must be mitigated, or turned down. The mitigation theory would involve either no channel (avoiding impact) or a smaller channel/piped water (mitigating impact).

INCREASED TRAFFIC

My main concern is the greatly increased levels in traffic and pollution in South Oxford. I live close to the Abingdon Road and use the road network around Kennington and the A34 at least once a day for work and for supporting an elderly parent. The traffic will severely impact my life for years. We already experience extremely heavy traffic in the Abingdon Road, which has got much worse since the building of the Westgate Centre.

The scheme would have an unacceptable impact on traffic levels. Congestion around the A34 and Kennington is inevitable with any form of construction work but the excavation of the channel would make the traffic levels considerably worse than if no channel is built.

The traffic on the Abingdon Road is frequently so congested that the vehicles are at a standstill. The pollution levels are noticeable, particularly in the summer. The Oxford Flood Alleviation scheme will inevitably lead to increased traffic and pollution but the channel aspect of the scheme will add considerably to the issue.

There will be an average of 144 HGV movements a day at South Hinksey. There will be 36 HGV movements a day on the Botley Road. There will be 14 movements a day at the Abingdon Road. This is approximately 200 HGV movements a day around the A34 for 3-5 years as they move 455,000 cubic metres of gravel, build roads on the site and build the channel.

Furthermore, the contractors' vehicles will add more traffic. The Environment Statement estimates will be about 100 construction workers and this will inevitably add to the congestion caused by the HGVs.

The traffic from the South Hinksey site is expected to be so bad that the Environment Agency is suggesting a 40mph limit on the A34 between North Hinksey and South Hinksey. This will have an impact on people far beyond Oxford.

The A34 is already a very crowded road and any incident leads to very long tailbacks. The Abingdon Road is often at a standstill because of an incident on the A34 or the ring road.

POLLUTION

The project is expected to last 3-5 years and during this time there will be dust, pollution and noise for local people. Sand and gravel extraction will be a particular problem, causing dust and health-related problems. These issues will be particularly acute for villagers in South Hinksey and North Hinksey.

Oxford’s pollution rates are already 718,000 tonnes per year above recommended limits and the council should be working to reduce levels, not add to them.

The A34 by Yarnells Lane is already an area above the legal limits for vehicle emissions. The issue will be made worse by increased traffic.

REMOVAL OF TREES

The scheme would result in the loss of 2,000 trees in the area (Table 7.5 of the Environment Statement). It would destroy most of the Kendall Copse Community Woodland which was planted by local people and is valued.

The Oxfordshire County Council’s Cabinet recently updated their tree policy. The County Council’s Director of Environment and Place states “it would put an emphasis on the ‘presumption in favour of trees’ because of the host of benefits they provide to the climate, the environment and the places where people live”.

The Environment Agency proposes to replace the lost trees but the replacement trees will be whips which will take decades to have the equivalent biodiversity and visual benefits. Willow trees are a particularly important source of early pollen for the insects as they emerge after winter.

LOSS OF HINKSEY MEADOW RARE GRASSLAND

I am also concerned about the environmental damage that will be caused by the channel - the destruction of a rare grassland and its biodiversity. In recent years we have learnt a lot about importance of biodiversity, habitat conservation and reducing carbon release and this proposal seems to ignore current developments in research. There are only 4 square miles of rare MG4a grassland left in the UK. Hinksey Meadows is MG4a grassland and it is vital that this is preserved and cared for. It has been managed for 1,000 years and once it has gone it is can never be replaced.

The UK has lost 97% of its meadows in the last 100 years and it is crucial that the remaining 3% is preserved. But only a fraction of that is MG4a grassland. MG4a meadow has 26 species of plant. It cannot be adequately replaced by MG4 grassland which has only 15 species. Therefore, reseeding the area with wildflower seed is not an adequate replacement for the lost meadow.

Creeping Marshwort is listed as an endangered species and is only found in Oxford. It grows in Hinksey Meadows in the field south of Willow Walk. It is also found on Port Meadow, which is a site of international nature conservation importance. However, Port Meadow is not rare MG4a grassland.

The Environment Agency plans to sow seeds taken from Hinksey Meadow elsewhere to mitigate the damage done by digging the channel. However, the Environmental Statement 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”.

By the Environment Agency’s own admission reseeding is unlikely to be successful. Even if the reseeding is successful, we will not see the benefits in our lifetime. Research from the Centre for Hydrology and Ecology predicts that it will take 150 years for the majority of species to colonize a new meadow.

Replacing the MG4a grassland with a new wetland is not acceptable. It is much easier to create a new wetland than recreate an ancient floodplain and therefore cannot be counted as a net gain.

There will be further damage to wildlife, some of them endangered species. Amphibians, bats and otters would be affected ‘negatively’, as listed in Table 8.5 of the Environment Statement.

POOR USE OF PUBLIC FUNDS

I am concerned that the channel aspect of the scheme covers so few properties. I do not think it will justify its cost. Spending 23 million of public money on a channel that will alleviate flooding in 54 houses in a 1:100 year flood is not acceptable, especially as it may not work as flood threat levels change in the coming decades, probably for the worse.

Costings state expenditure to be between 122 million and 154 million for this project, although this does not take into consideration recent inflation of building costs. The channel will cost 25% of this sum, yet will give only 5% of the benefits.

I would urge the Environment Agency to consider any no-channel alternatives. Or piped alternatives. Or first-stage only channels. The National Planning Policy Framework paragraph 180 states:

“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”.

I do not believe that permission should be given for this scheme to go ahead in its entirety and less expensive, less harmful options should be implemented first.

CARBON

Climate action, according to the Oxfordshire County Council, will be a top priority in all decision making. The Environmental Report states that the proposed scheme will generate almost 20,000 tonnes of carbon over its lifetime, which goes against the aim of having a net-zero carbon Oxfordshire by 2050.

Flood meadows and soil in general are an important aspect of carbon storage. The Open University’s Floodplain Meadow Alliance writes of flood meadows: “We recognise their value as areas for flood storage and they act as sources of seed for the restoration of meadows across the country. They are a small reminder of a traditional, rural landscape and have a critical role to play in the conservation of our natural heritage.”

The FMA also researches the carbon-holding properties of flood meadows. In the UK 95% of sequestered carbon is held in the soil: digging up soil always releases carbon. Species-rich flood meadows, where carbon has been held for centuries, hold the most carbon after peat, according to FMA research.

The Environment Agency plans to dig up 700,000 tonnes of soil from the floodplain meadows for its channel. The soil disturbance and the displacement of gravel and soil, the loss of trees and hedgerows will have a huge carbon cost.

LOSS OF RECREATIONAL SPACE

Hinksey Meadows are a greatly valued part of life in South Oxford and there have been greatly increased numbers of walkers enjoying the space during the last 2 years.

The Environment Agency’s data counted almost 100 people visiting the Seacourt Nature Reserve on an average day in February 2018 and many more will visit during spring and summer. The proposed scheme would restrict public access to almost all of this area of publicly-owned and publicly-accessible open space for ever.

MANAGEMENT OF THE CHANNEL

The Environmental Statement includes a management plan (Appendix I) but no costings about ongoing maintenance of the scheme. Without mowing, grazing or cutting back of encroaching trees and plants, vegetation will accumulate, reducing the effectiveness of the channel over time. The Full Business Case of 2019 budgets for the first 10 years after construction but not beyond.

We see sewage spills into the Thames and other rivers and the Environment Agency has had its funding cut, so whether it will be able to maintain the channel and control of the invasive species such as Himalayan Balsam is doubtful.

Wetland needs proper and ongoing management. If the proposed wetland is not properly maintained it will silt up, diminishing the effectiveness of the channel.

The Environment Agency should clear the streams, instead of proposing a destructive channel. The streams in the area are blocked because of the number of trees that have come down. Clearing these trees and the existing culverts is probably the easiest and most cost-efficient way of reducing flooding. This would be a far cheaper option.

LOSS OF LAND IN THE GREEN BELT

During construction, open fields would become construction compounds and access tracks. During operation, the current landscape would have fewer trees and hedgerows, with more views of the A34 from the paths through the area.

The proposed scheme is in the Green Belt. One of the purposes of Green Belts (NPPF paragraph 138) is to preserve the setting and special character of historic towns. The proposed scheme would absolutely not do this for its 3 to 5 year construction period.

The National Planning Policy Framework says in paragraph 137 “The government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.”

In paragraph 138 of the NPP it says the Green Belt is “to preserve the setting and special character of historic towns”. The proposed scheme will not do this for the duration of the scheme and will destroy an area that is very valuable to local people. The iconic landscape of Oxford will be changed forever with more fences and less trees.

A NATIONAL ISSUE

The scheme raises national-level issues. This proposal should be considered by a national inspector or Parliament rather than through a planning application.

It would reduce traffic speeds on part of the A34 national trunk road from 60mph to 40mph. It would destroy 1% of the remaining area of nationally-rare MG4a grassland and could lead to the loss of another 5% by drying out the area. It is a very poor use of at least 125 million of public funds, with 23 million spent on a controversial channel. For these reasons the proposal needs inspection at a national level.

In conclusion I sincerely hope that this proposal will be turned down because of its damaging channel element which will bring traffic misery to Oxford for years and destroy a nationally-rare ancient flood meadow.

5

Oxford does need a flood alleviation protection scheme, but not this one.

My main objection is the huge damage caused to the environment by the proposed 5km channel. This channel requires the felling of thousands of trees (which in themselves help with flood protection), the destruction of a rare wild flower meadow, restricted access to fields and massive soil extraction. All of which runs contrary to the Council’s policy of conservation and protection of green spaces.

The channel only provides a small percentage of the flood reduction in the proposed scheme, the major part being obtained by the building of flood walls, gates and culverts. It would therefore make sense to strengthen and expand the latter, whilst investigating alternatives, such as a pumped pipeline, for the former.

6

I am very concerned about this proposal but understand the need to alleviate flooding in general but feel this may be too large a proposal given the time elapsed from initial discussion to now in light of latest IPCCC report, the environmental impact on our local area and the compromise over the ecological impact which will take decades to repair.

This may not be the best of the use of the last remaining land in this area, it seems an awful lot of work and destruction to try and create something that may or may not work. Once again, I am not against the flood prevention, just this flood prevention scheme

The physical impact will be enormous, we are so privileged in West Oxford to live so close to nature which offsets the increasing post pandemic traffic of the Botley Road and this vital asset should be maintained at all costs.

The dust, noise and smell will make for very unpleasant living in this area but for what gain? Surely in 2022, climate change must be high up on the agenda? If not, I despair.

I am no expert but I do know that once this projects starts, there will be no going back.

During the pandemic, the population enjoyed their environment, indeed this was an unexpected bonus to come out of this period, the quiet, the birdsong and the once in a lifetime of being able to walk down the Botley Road safely

The landscaping and restoration scheme cannot replace ancient meadows which has been created over hundreds of years and indeed, if goes ahead the maintenance of this project is only guaranteed for 10 years

7

While I understand the need for a flood alleviation plan, there must be a way of achieving this that does not result in the destruction of ancient meadow with fantastic biodiversity and many mature trees. This area is valued by so many local residents, please let is stay for posterity.

8

I wish to oppose the proposed flood alleviation scheme in its current form, both as a local resident, and as an expert with an international track record of research on water issues and river management. My comments address three key areas: the extremely negative local impacts of the scheme; the flawed nature of the scheme and its outdated engineering approach; and the wider problems of excessive growth and development that the proposed scheme supports.

While I think there is broad agreement locally about the need for improving flood management in Oxford, and certainly some scope for making better use of riparian meadows, wetland areas, etc. to mitigate flooding more effectively, there is, as far as I can see, no need for the extremely destructive flood channel that is being proposed. This provides very little gain in terms of the flood scheme as a whole, and it has major short and long-term costs. All of these costs contravene the local Planning Framework that the Council is theoretically bound to uphold, as well as the National Planning Policy Framework, which basically requires a ‘do least harm’ approach to all infrastructural developments. The proposed major flood channel presents some major problems:

In razing much of Hinksey Meadow and Kennington Pit, it will destroy an important wildlife area, with high levels of biodiversity, which will not be readily recovered for many years, if at all.

It will replace these well-established areas of biodiversity with a massively over-engineered environment, greatly diminishing its capacities to support wildlife, as well as its value as a recreational amenity. (Contravenes Policy 15./conserving and enhancing the natural environment, protecting green belt land, achieving well-designed places).

It will deprive West Oxford residents of this recreational area entirely for 3-5 years, with concomitant impacts on local health and well-being. (Contravenes policy to ensure safe and healthy communities).

It will entail years of intensive engineering work, noise, air pollution and disruption, which will have a severe impact on the residents of South Hinksey and related areas of West Oxford, much reducing the quality of their lives, and creating a variety of impacts detrimental to their health. This is particularly important in an area in which the Council has already failed, for many years, to address severe air pollution and traffic issues. (Contravenes policy to ensure safe and healthy communities).

It will produce, for a similar period, major traffic disruption in West Oxford, with the constant movement of large trucks and materials, in an area already struggling to manage excessive traffic flows. (Contravenes policy to ensure safe and healthy communities).

It will contribute to the over-development of West Oxford and to the unnecessary expansion of its urban areas. (Contravenes policies to protect green belt land, achieve well-designed places, and ensure safe and healthy communities).

It does not demonstrate value for money: it will cost a great deal of public money for very little (and possibly rather short term) gains and will not add effectively to flood alleviation. (Contravenes Policy 6. and Policy 14./meeting the challenge of climate change and flooding)

The cursory consultation period does not provide sufficient time and opportunity for busy local residents to engage with and respond to this complex issue which will affect their lives for many years to come. It should be extended, and greater efforts should be made to listen to the views of local people. (contravenes policy commitment to high quality communications).

The proposed flood alleviation scheme also appears to be part of a broader policy - which Oxford residents have not voted for at all - to impose an intensive growth plan upon the city at the cost of its green belt. Although Oxford has almost zero unemployment, this plan intends to create 25,000 new jobs, thus massively increasing the population of a city in which it is already a challenge to provide affordable housing for younger people. While promoting expensive housing and industrial development in green areas all around Oxford, the Council has simultaneously refused to support the use of brownfield sites to create more affordable housing, or to enable the repurposing the many commercial buildings that lie empty all around the city centre, which (with some sensible rebalancing to make this more viable than the currently favoured ‘new build’ approach) have much potential to address the housing, traffic and pollution issues that Oxford faces, and to meet National Policy objectives to ‘ensure the vitality of town centres’ and ‘conserve and enhance the historic environment’. The proposed flood scheme also needs to be reconsidered, not in isolation, but as part of a larger plan for the overdevelopment of much of West Oxford, which may provide commercial gains to influential local developers, but will have major negative impacts on the resident communities in this area, and on its material capacities to support a healthy, biodiverse environment.

My final point is concerned with river management. Many countries are now moving forward to take a holistic approach to river catchment management, recognising that maintaining steady and manageable flows of water (and good water quality) can only be achieved by engaging systematically with the whole of the catchment area. This entails employing ‘soft engineering’ or ‘green engineering’ that works collaboratively with the riparian landscape all along the river to contain and release water more steadily. This generally means a more thoughtful approach to agricultural land use throughout the catchment area, enhancing upriver wetlands, meadows and woodlands, ensuring the adequate control of sewage and agricultural run-off, and refraining from expanding urban/concreted areas to the extent that the catchment’s diverse habitats cannot mitigate water flows sufficiently. Many parts of Britain seem to be lagging far behind in this progressive shift, and remain wedded to highly localised and disruptive ‘hard engineering’ schemes, such as the one being proposed here, that - ultimately - cannot possibly deal with an entire river in flood. This shortsighted approach, which suggests a focus on local commercial development rather than seeking socially and environmentally sensitive long-term water management, can only produce detrimental outcomes. The agencies responsible for these decisions need to do some serious catching up, both in understanding more enlightened ways to approach water management, and in questioning whether creating urban growth at all costs is really what we need.

I hope that these comments are helpful in encouraging a positive rethink of this planning proposal.

9

I am writing to SUPPORT the Oxford Flood Alleviation Scheme planning application.

I have confidence that the plans developed by the EA over the last 10 years will SIGNIFICANTLY REDUCE flood risk for several thousand properties in south and west Oxford.

The plans are clearly sympathetic to environmental and wildlife issues, and appear likely to INCREASE BIODIVERSITY in the areas around the new flood relief channel.

Some disruption during the building of the new infrastructure is inevitable, especially for residents of South Hinksey (such as myself); the proposals appear to have taken some steps to mitigate this. I trust that the planners will disregard the inevitable nimbyist objections that will be voiced as a result of such temporary disruption.

However, the issue of ACCESS TO SOUTH HINKSEY is important, given that, uniquely, there is only one single road access to the village (for vehicles), and that most pedestrian and cycle access to the village is also via a single route (the Devil’s Backbone).

The increase in traffic (not least potentially lorries) using the South Hinksey / A34 junction will be SUBSTANTIAL. The junction has very short slip roads, and the resultant INCREASED RISK OF ACCIDENT should be mitigated. The fortuitous proximity of not only a railway, but RAILWAY SIDINGS means that REMOVAL OF SPOIL BY RAIL should most definitely be encouraged.

The proposal includes measures to ensure that pedestrian access between South Hinksey and South Oxford (via a diverted Devil’s Backbone) remains possible throughout. Planners should ensure that this extends to CYCLE / PUSHCHAIR access along this route. Indeed, as part of the proposal, I would encourage the long-term creation of a LEGAL CYCLING ROUTE along the Devil’s Backbone, to reflect the reality of current informal practice.

The proposal appears to involve the REMOVAL OF THE PUBLIC FOOTPATH between South Hinksey and Old Abingdon Road (near to Redbridge Hollow). Clearly the current route cannot be maintained, but I see no reason why an ALTERNATIVE ROUTE, running to the west of the new relief channel, cannot be created, to maintain existing pedestrian access between South Hinksey and Old Abingdon Road.

10

I strongly object to the destruction of a valuable natural habitat and a much loved community resource. This scheme is ill conceived, and has a multitude of irrevocable costs. It should be rejected, and the meadows properly protected.

11

I am deeply opposed to the proposed drainage channel.

Having researched the predicted benefits of the drainage scheme to the local community, versus the considerable negative environmental and social impact it will have, I believe it would be a terrible mistake to proceed as detailed in the planning application.

12

It seems that all experts not directly connected with the EA think that the channel is ineffective, grossly expensive and destructive of valuable, irreplaceable ancient meadows.

The EA is operating under very difficult conditions, because, like all such services it is under financed and overstretched. It cannot even cope with the sewage in the rivers. Under this stress, it should draw on other expertise.

The pretence that planting some trees to replace what will be destroyed will replicate what is lost is farcical. Already the new trees planted along the river by the Osney Mead industrial estate are dying.

The Willow Walk and the Monks' Path will be destroyed. What is rural about Hinksey will be destroyed, and, at best, nondescript urban park will replace it - no doubt to be built on later.

13

I live in South Hinksey and will be directly affected by the OFAS. I think the scheme is flawed and I am very concerned about this planning application, especially the excavation of the new channel.

South Hinksey is a tranquil village which will be at the epicentre of this huge project for up to five years. The entire community will be affected by unacceptable levels of noise, dust, pollution and the disruption associated with the influx of contractors, movement of trucks and operation of heavy machinery, 6 days per week. The location of the construction compound so close to people’s homes is entirely inappropriate. The prospect is already causing distress to some residents and there could be mental health impacts if we are unable to enjoy the amenity of our gardens for months at a time, especially in the summer. I do not think the scale and implications of the scheme have been sufficiently spelled out to the community and I think the Environment Agency should have provided more candid public briefings to keep people informed.

The proposal to remove hundreds of thousands of tons of spoil via the A34 is horrifying and dangerous. The roadbridge over the A34 at South Hinksey is already in poor condition, narrow and with sharp bends - and completely unsuitable for intense use by large lorries, for which it was never intended. The potential removal of spoil by rail is not a panacea because vast quantities of material will still have to be transported the length of the scheme and loaded at the sidings, with all the associated noise, dust etc.

Objections to the location of the construction compound and the use of the South Hinksey junction to the A34 were raised four years ago when the previous planning application was submitted, yet it appears that nothing has been done to address these issues.

Many residents of South Hinksey are also concerned about the temporary re-routing of the Devil’s Backbone path and whether it will remain passable in bad weather. This is a lifeline for the village, a vital pedestrian/cycle route used to access schools, shops, doctors, places of work, the community centre etc, as well as for recreation.

The permanent impact of the flood scheme on Hinksey Meadows and the fields between South and North Hinksey is particularly upsetting. This is a beautiful landscape of environmental and historic significance. The manipulation of the current network of streams, the felling of trees and removal of rare grassland is heart-breaking. I am sceptical that the area will continue to be grazed, because fences will have to be removed. I note that the planning application says the scheme will require “little active management and maintenance over 100 years” and fear this means that these precious fields will be allowed to degenerate into an unattractive wasteland (as can be seen from other local fields which are not regularly mown/grazed or otherwise managed). The local environment will take years to recover from construction works on this scale and the lovely scenery which makes up one of the iconic views of Oxford will be changed for ever.

The stated aim of the scheme is to “create more space for floodwater within the western flood plain”. I do not understand the logic of doing this, without a corresponding substantial improvement in the outflow of water at the well-known “pinch point” in the Old Abingdon Rd area. I am also concerned that the scheme could exacerbate South Hinksey’s long-standing problems with flooding from groundwater and overflowing sewers and storm drains during periods of heavy rainfall, because all this effluent could back-up in the village.

It is also suggested that the scheme is partly intended to facilitate the future development of Osney Mead, and if so there should be greater transparency about this.

This scheme will be very costly and instrusive. I would much prefer to see efforts directed towards the clearance and improvement of existing water courses and drainage channels (those around South Hinksey are not properly maintained and have become clogged with vegetation), plus investment in temporary flood defences.

14

The area impacted by this scheme is a beautiful, quiet oasis of nature close to central Oxford. My family and I often cycle through the fields along the path of this proposed scheme, enjoying and wondering at how such a rural and natural environment, with abundant wildlife can exist so close to the city.

I am dismayed that it will be subject to what looks like an enormous disruption, with a huge amount of digging and earth removal, to alleviate floods for which smaller scale works may achieve a similar end.

15

The two major features of this proposal which attract comment are:

1) the vast over-engineering, including the construction of a motorway flyover bridge taking what’s left of Willow Walk over the drainage channel, where a modest timber rainbow bridge would suffice for walkers and cyclists, though admittedly it would not carry a landing aircraft nearly so well as the EA’s proposal. This is so ridiculous that I can say no more.

2) the wanton environmental destruction sits uncomfortably beneath the name of the Government Agency proposing it. To plan includes the felling of a minimum of 4000 mature trees, 6000 seems the more probable estimate. How will the planned “forest” of 4000 tree saplings compensate for the loss of 4000 mature trees, 3 miles of hedgerow, and the loss of birds, mammals and insects that depend on them? Experience tells us that most of them will die within two years. Never mind whose fault it is; it just happens - every time. The benefit from what are left, even if they were 4000, would not be felt for 50 years. Climate change science tells it will all be too late by then.

What will happen to nesting birds and the bats, insects and other creatures that depend on the trees the Environment Agency wants to cut down? Is it that OFAS believes the cost in bio-diversity (and of carbon absorption) is a cost worth paying, and that the only choice for people living in West Oxford is either their houses or their environment?

The EA has made no arrangements with environment management organisations for the care and growth of the saplings beyond the life of the scheme, what guarantees do they offer that the trees will be looked after for the necessary decades to reach maturity and become capable of supporting fuller bio-diversity?

Table 8.8 of the Environmental Statement admits that the OFAS would result in the loss of 3.1ha of Hinksey Meadow, of which 1.33ha is rare MG4a grassland (about 1% of all the remaining MG4a grassland in England and Wales). Appendix C-5 of the ES explains that the OFAS would probably dry out the rest of Hinksey Meadow to the point where the plants that make it a rare MG4a grassland would no longer be able to survive. In other words, the OFAS would indirectly affect the whole of Hinksey Meadow.

The OFAS proposes to create new sites of MG4 grassland, but the ES notes that “Habitat creation and translocation are not a substitute for in situ conservation of this kind of habitats, the latter approach always being preferable where possible”. And alternative schemes have been proposed which show that it IS possible. It is possible to avoid ALL of this environmental destruction.

In summary, the proposal is an engineer’s vanity project that seems to owe its thinking to the 1960s when engineers (and planners) just didn’t care about the environment. They cannot bring themselves even to consider twenty-first-century alternatives and twenty-first-century attitudes to the environment and its destruction and the terrible cost of their proposals in the context of climate change.

I object.

16

I realise flooding us an issue but the floodplain you plan to impact is litterally irreplaceable. Part of the reason for the flooding ua due to the vast number of houses being built without a plan for drainage or sewage. Please respect one of the last specialist flood plains filled with biodiversity that we need to support. Equally the floodplain naturally helps with drainage so please resist any tampering.

17

Dear applicant,

to my understanding the current plan is not feasible, as South Hinksey does not have the necessary infrastructure to support heavy machinery and vehicles to pass through. Many of the village buildings are under heritage protection and the risk of damage to these buildings is relatively high in your proposal.

Furthermore, the meadows serve both as a recreational space for many people in Oxford as well as are rich in biodiversity.

I do understand the need for flooding mitigation, but would propose to use the train tracks close by for this purpose and to focus more on deepening and widening the small river which is parallel to electric road.

18

I object to the proposed Oxford Flood Alleviation Scheme because in my opinion there are serious technical weaknesses in the scheme that affect the reduction in flooding that will be achieved and the value for money that will be provided by the scheme.

I believe that Oxford requires a Flood Alleviation Scheme and the purpose of this objection is to highlight the technical weaknesses and support the development of an improved flood alleviation scheme for Oxford.

My objection is based on my technical expertise as a flood management specialist and my concerns for the city in which I live. I am a citizen of Oxford and have worked as a flood specialist for over 30 years.

My objection is outlined below. Further information can be provided if required including specific references to information on the scheme provided by the Applicant in the documents on the planning portal, referred to herein as ‘the documents’.

The documents give a very extensive description of the physical aspects of the scheme but provide very little technical information about the design approach adopted for the scheme and the constraints that affect the design.

The proposed scheme

The purpose of the proposed scheme is to reduce flood risk in the Oxford area. The scheme includes a new channel for the conveyance of flood water and some new walls and banks that provide protection against flooding.

The flood channel is small

The purpose of a flood channel is to carry a proportion of flood water so that the amount of flood water that causes flooding is reduced and, as a result, the flood water levels are reduced.

If the flood water levels are reduced, the water levels at individual properties will be reduced. As a result, properties will flood less frequently.

The proposed flood channel has a small capacity compared with the total flood flow. The capacity of the channel is less than 20% of the total flood flow in a large flood. As a result, the reduction in flood levels is small and the flood benefit is also small. However the flood channel requires a lot of work and impacts on large areas of land.

There is one other major flood relief channel on the Thames, the Jubilee River at Maidenhead. This has a capacity of about 40% of the total flood flow in a large flood, more than twice the proportion of the flow for the Oxford scheme.

My first concern is that the benefit of the flood channel is small but the work required to build it and the amount of land affected are both very large. Construction of the flood channel will cause a lot of disruption and does not seem to be an efficient use of public money.

Seepage of flood water can occur under the proposed walls and banks The small reduction in flood water levels provided by the proposed flood channel is recognised by the Applicant, and flood walls and banks have been introduced to protect vulnerable areas.

The floodplains in the Oxford area contain gravel and are permeable. This means that water can flow under the ground and cause flooding when river levels are high. This has caused flooding in the past in several areas including the Abingdon Road area.

When a flood occurs with the walls and banks in place, water will flow under the walls and banks and cause flooding.

The Applicant is aware of this groundwater problem and has included some short ‘trench sheeters’ under the walls and banks to reduce the groundwater flow. The ‘trench sheeters’ consist of short steel piles that are driven into the ground. They link together to form a steel wall in the ground.

The reason that the trench sheeters are short is that the groundwater flows are important for environmental reasons and must not be stopped. Seepage of flood water under the walls and banks will therefore occur during a flood.

I do not know how much flooding will occur from groundwater flows under the walls and banks during a flood event and no information is provided in the documents. I understand that pumps will be provided to deal with this problem but no details are given regarding their location and size.

My second concern is that flooding will take place behind the walls and banks during a flood, caused by seepage under the walls and banks. This could be a large source of flooding with the scheme in place which could require significant works (and costs) to mitigate.

Is the flood channel needed?

It is possible that the Applicant has information on the groundwater flows and is satisfied that the walls and banks will perform satisfactorily. If this is the case, it may be better to make the walls and banks slightly higher and leave the flood channel out of the scheme. This could save money and require less land.

The document entitled “Oxford FAS - Western Conveyance Channel Review”, dated 26 Jan 2022, considers options for removing the flood channel but does not include options for combining the removal of the flood channel with raising the walls and banks.

My third concern is that, if the walls and banks can provide an effective method of flood protection, why bother with the flood channel as it is not very effective at reducing flood risk?

Constraints imposed on the scheme

The documents do not explain the constraints that have been imposed on the design of the scheme. One constraint appears to be the need to avoid increasing the flood level downstream of Sandford Lock. This places severe restrictions on what can be achieved in Oxford because any reductions in the volume of flood water in the Oxford area cannot be passed downstream. This means that the flood water must be stored in the Oxford area even though the purpose of the scheme is to reduce flooding in Oxford.

An alternative would be to allow a small increase in flood levels downstream and provide (small) flood mitigation measures at any locations that are affected. This approach is adopted for the proposed River Thames Scheme, which will provide new flood channels to reduce flood risk between Windsor and Sunbury. In this case the downstream weirs at Molesey and Teddington will be modified to compensate for the effect of the scheme on downstream flood levels.

My fourth concern is that there are constraints that severely limit the effectiveness of the scheme to reduce flooding. If these constraints could be relaxed it would be possible to develop a more effective scheme and a more efficient use of public money.

Effectiveness of the scheme

Some information is given on the effectiveness of the scheme in the Flood Risk Assessment, including the following:

The annual frequency of flooding in the Botley Road area will reduce from 5% (1 in 20-year) to 2% (1 in 50-year); The annual frequency of flooding in the Abingdon Road area will reduce from 2% (1 in 50-year) to 1.33% (1 in 75-year); The annual frequency of flooding at Osney Island will reduce from 10% (1 in 10-year) to 5% (1 in 20-year). In this case it will still be necessary to deploy the temporary flood defences.

These changes are significant but there will still be significant flood risks in Oxford. There is a risk that the benefits of the scheme perceived by the people of Oxford will be greater than the actual benefits. This could lead to a severe backlash if flooding occurs after the scheme is completed.

My fifth concern is whether the people of Oxford understand the benefits that the scheme will provide and the limitations of the scheme. Many properties will still flood, but less frequently.

Climate change

The information on the effectiveness of the scheme referred to above is based on present day conditions and does not consider climate change.

It is projected that flood flows will increase as a result of climate change. The present-day flood that has a 1% chance of occurring in any year (the ‘100-year’ flood) has a flow of 218 cubic metres of water per second on the Thames upstream of Oxford and a flow of 291 cubic metres of water per second on the Thames at Sandford. The difference is mainly due to the inflow from the Cherwell.

The maximum capacity of the flood channel is understood to be about 40 cubic metres of water per second. This is about 18% of the 1% annual chance flood flow in the Thames upstream of Oxford and 14% of the 1% annual chance flood flow in the Thames at Sandford.

It is projected that the 1% annual chance flood flow will increase by more than 18% during the next 60 years due to climate change. This means that the reduction in flows in the Thames and other existing streams due to the scheme will be eliminated over the next 60 years based on current climate change projections. This will reduce the effectiveness of the scheme although the proposed walls and banks will continue to provide flood protection.

My sixth concern is that climate change will reduce the benefits of the scheme and there does not appear to be a plan in place to mitigate this effect.

19

Whilst an Oxford Flood Alleviation Scheme makes perfect sense in the light of climate change and its concomitant effects on the environment, the Environment Agency’s planning application has one serious flaw: namely, the proposed 5km channel from north of Botley Road to south of Abingdon Road. The EA itself acknowledges that the channel is the most disruptive, costly and damaging part of the scheme, yet has apparently not considered a pumped pipeline alternative which would offer more immediate flood protection and into the future.

Disruption to local residents and traffic systems aside, it is the threat to the natural world - trees, woodland, hedgerows, grassland, nature reserves - that should be the paramount consideration in weighing up the pros and cons of the channel option; otherwise, the losses are in danger of outweighing the gains. New housing estates are already robbing Kennington and Radley of vital green areas that we would do well to preserve; once a natural habitat for flora and fauna is lost, the damage is already done, often irreparably.

We would therefore ask you to reconsider at least the 5km channel and look more carefully at alternatives such as a pumped pipeline. Oxford needs and deserves a flood alleviation scheme that takes the natural - not just the human - environment fully into account.

Finally, the A34 is already notorious for traffic jams and accidents, and the Hinksey Hill interchange for its long queues. If these existing problems are further exacerbated, there will be a considerable outcry, especially as that junction is the only route for local pet owners to reach the one veterinary surgery in the area, which is on Hinksey Hill itself.

20

As a resident of Duke street I’d like to show my support for the project. The area needs a flood defence approach and I believe this will be a good approach to reduce our exposure to flooding events.

21

I agree that some flood protection is needed but the scheme proposed is o