The 32 page one hour closing submission from the OPT spent a great deal of time making the same pointa as the Ferry Hinksey Trust and OFEG about the biased approach of the EA in modelling Alternatives that would not require a channel through Hinksey Meadow.
The conclusion was this:
The Trust has been at pains to emphasise that it takes very seriously the step of appearing at a public inquiry into a scheme that has been proposed to alleviate flooding in Oxford. As the scheme developed, the Trust made all reasonable attempts to discuss its concerns with the EA, despite its frustration with how the EA failed to give due consideration to the value of the MG4 grassland when developing options for the scheme. But even after considering the EA evidence with sedulous care, it cannot support this scheme in its current form.
It remains unconvinced that the EA has carried out anything like adequate analysis of the potential indirect effects on the retained MG4, or of mitigation and compensation proposals. It has not properly explored alternatives to the loss of the MG4, because it has taken an unjustifiably reductive approach to the scope of its options appraisal; and it has embedded an unfair methodology for comparing alternatives to the Scheme. It has not done enough to show, using its term, that the loss of MG4 grassland at Hinksey Meadow is “unavoidable”. As a result, the EA has squandered the opportunity properly to balance the importance of the grassland against the requirement for flood alleviation. The EA is promoting a scheme which has an impediment to implementation and is in any case contrary to planning policy. It has failed to demonstrate a compelling case for the Order.
The Trust therefore asks the Inspector to recommend to the Secretary of State that this Order not be confirmed, and asks the Secretary of State not to confirm this Order.
The full submission can be seen here
https://www.hwa.uk.com/site/wp-content/uploads/2023/08/OFAS-Closing-OPT.pdf