Response to the ‘Sites and Housing Development Plan Document, Proposed Submission Document’ Consultation, June-July 2011
From Dr Judith A Webb
Page 1 of 6: General comments on all Sites:
Sustainable Urban Drainage
SUDS [Sustainable Urban Drainage Systems] are put forward as mitigation in some of these proposed developments. Bearing in mind that ‘mitigation’ does not mean ‘putting things right’ but more like ‘making a bad situation less bad’ my strong feeling is that full SUDS should be an absolute requirement in ALL future developments (large and small) within the city. Problems occur all over the city with rainwater from hard surfacing overloading an old and inadequate-capacity sewage transport network; resulting in the regular upwelling of sewage into streets, parks and homes after a sudden rainstorm. Not to mention damage to any watercourse road-run-off water is directed to and lack of replenishment of aquifers.
Not only should every development have SUDS, there must be realisation and acceptance that all SUDS need regular maintenance (?annually) to a high standard to remove silting up and reduction in performance - as regards infiltration to ground water and reduction in damaging run-off. This fact is well known (see link below). SUDS that work perfectly for the first year and then slowly decline in performance so that by year 10 they are only half as permeable are no good. After all, every householder knows that they should check their guttering for sediment regularly (annually?) and knows that if this sediment is not all removed regularly, the result is a blocked down pipe and water overflowing the gutter and down house walls. At that point it is as if there was no gutter. This situation is exactly the same for SUDS; The sediment that fills gutters is dust from the air which rains down continually. In the same way that it fills gutters, it fills up soakaways and blocks the pores in permeable/pervious paving and asphalt. Maintenance of such SUDS involves jetting and sucking all the silt out. It requires specialist machinery, labour and presumably has a carbon footprint and is costly. It won’t get all the silt out at each session - at regular intervals the permeable surfaces will need to be replaced in order to work effectively. Developers will be long gone by then so who will pay for such essential maintenance?
There is much information on decline in performance, just search on the web for ‘clogging of permeable paving’, just a few quickly found:
http://www.north-herts.gov.uk/sfra_appendix_h_alternative_suds_techniques.pdf
‘The performance of permeable pavements will dramatically decrease over a period of time with the clogging of voids and this should be taken into consideration during the design process and maintenance.’
http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm?action=browse&Rbutton=detail&bmp=136&minmeasure=5
‘Studies of the long term surface permeability permeable pavements have found high infiltration rates initially, a decrease, and then a levelling off with time’
Page 2 of 6:
Due to clogging, the design life of some types of concrete interlocking paving may be as little as 20 years, and it may then need replacing, or the aggregate between pavers will need replacing.
I understand maintenance of all SUDS can be planning obligations or as a condition attached to planning permissions for development. OR will all new SUDS be adopted and maintained by a local authority? Which of the cash-strapped City or County Councils will be able to pay for expensive maintenance of all the SUDS in these new developments for the development’s lifetime?
SUDS without any maintenance are pretty worthless in my view. Permeable paving installed in the ‘Harberton Heights’ housing development adjacent to Milham Ford Nature park in New Marston was installed in 2008 and is already showing significant blocking between the pavers with extensive moss growth, in only just over 3 years. Thus it already cannot be functioning as it should.
A greenfield (if un-compacted) is the only self-sustaining, completely indefinitely renewable, cost-free water-infiltration surface a site can have. This is obvious to any gardener. Drainage spaces in a natural soil are continually being formed by live earthworms burrowing and the growth and death of plant roots which leave vertical channels as they rot. Yes the channels silt up, just as in permeable paving; but the crucially different feature is that new drainage channels are always forming by the continuing action of living things (plants, worms) in the soil. No living things means no new channels formed. This is the situation in any artificial, man-made, permeable surface.
Reference to all the above will occur regularly in the specific comments that follow. If I sound like a boring, broken record all the time it is because I feel very strongly that this is such an important issue.
Specific Site Comments:
Warren Crescent ( SP62)
As I have said before, this site shouldn’t even be considered at all at this stage for all the reasons I have given earlier (see previous submissions). I strongly object to its proposal for housing and it should be thrown out. New evidence indicates breeding of protected BAP reptiles within very few metres of the site boundary and an active badger sett just on the bank below the site boundary in the LNR plus breeding of BAP brown hairstreak butterflies on blackthorn immediately adjacent.
As I have explained before this site is well within the catchment of the SSSI North Fen springs therefore any suggestion that SUDS will be an acceptable mitigation of the effect of development will be not tolerable. The reason for saying this is that every drop of rainwater that currently falls in the Warren Crescent grassy areas is needed to replenish the groundwater to feed the SSSI springs on the West side of the fen. Climate change to less rainfall every year will in any case be starving the springs of water in the future (drought is already upon us) so they will unavoidably produce less water for the fen. Building on this site is avoidable, therefore it should not be done. Breaking up the concrete ex-garages and returning them to permeable greenfield will help supply water to the springs and assist in counteracting effects of climate change.
Page 3 of 6:
Previous planning permission was granted in ignorance of hydrological information and biodiversity information that is now available. Therefore it sets no precedent.
Apart from threats to biodiversity of development on this site I would like officers to consider the consequences of lack of water to the springs producing drying out of the considerable tonnage of peat that exists in the Lye Valley North fen and LNR area. Despite past peat cutting, a depth of more than a metre of peat exists over a large area of the whole valley bottom. Lack of spring water will result in drying which results in oxidation of the peat, liberating CO2. The site will become a serious CO2 emission source if the springs dry up. The City Council has a duty to try and reduce its carbon footprint as much as possible. I can roughly calculate the potential volume of C locked up in the peat at the moment and therefore the potential future emission if it is oxidised to CO2 upon peat drying. Is that of interest?
Churchill Hospital Site (SP 8)
Run-off from all roofs and paved and road areas in the Churchill site currently all enters the Boundary Brook. Due to the large Churchill site area, the water run-off volume must be a major contributor to the flash flooding and consequent erosion problems the brook is already experiencing, resulting in on-going damage to the Lye Valley SSSI South fen downstream. Part of the reason for this is the non-functioning of a water-interception device at the surface water outfall. Prior to entering the brook, run-off water from the Churchill site first enters a balancing/ attenuation/retention pond. Such a pond should function by filling up during a storm peak and then slowly releasing the water to the brook or into the ground after the event. However this water interception pond retains water at all times (more or less full) therefore has minimal capacity to attenuate the effects of storm water from the Churchill in a sudden heavy rainfall event. Thus, any rainwater from the Churchill site enters the brook suddenly at full, damaging, force – basically it skates over the top of the already full balancing pond.
Re-developments at the Churchill should take the opportunity to introduce full, high quality SUDS throughout, with a full programme of efficient maintenance for the lifetime of the buildings and paved/asphalt areas. This would increase infiltration at source and reduce the current peak run-offs to the brook and reduce the problems of the non-properly-functioning water-interception pond. Rainwater harvesting for use within the buildings (e.g. toilet flushing) would not be good because that water is then lost from the site to the sewers eventually. Much better would be rain-water harvesting for the purpose of infiltration into the ground to replenish aquifers locally.
A drastic reduction in the run-off volume on the west side of the site should be required. If space is in short supply, why can’t green roofs be part of the design plan?
In addition, the wooded corridor of the Boundary Brook is a LWS for its BAP priority habitat of wet woodland. This habitat depends on functioning, flowing, springs along the whole line of the brook from the Churchill site. More efficient infiltration as a result of re-development will be beneficial in feeding the springs and helping them combat the effects of coming climate change.
Page 4 of 6:
As regards re-developments on the East side of the Churchill site, this area is within the calculated catchment of the springs feeding the North Fen SSSI therefore the suggestion that SUDS will be an acceptable mitigation of the effect of development must be strongly challenged. The reason for saying this is that every drop of rainwater that currently falls in the Churchill area that is the calculated catchment is needed to replenish the groundwater to feed the SSSI springs on the West side of the fen. Predicted climate change to less rainfall every year will in any case eventually be starving the springs of water in the future (drought is already upon us) so they will unavoidably produce less water for the fen. The current re-inforced gravel surface over the car parking area just above the North fen seems to be working in that the springs on this side are still running. However it must be borne in mind that hydrologists advise me that there can be a significant time delay between changing a surface feature (i.e. installation of paving over greenfield) and seeing the effect of such a feature on the output of springs from the aquifer underneath. It could be 10 years or more before the FULL effect of changing a surface feature is reflected in a changed output of the springs from the aquifer underneath the feature.
Regarding this East side of the Churchill site within the North fen catchment it seems sensible to suggest major buildings and hard surfacings (even if ‘permeable’) are kept well away from it. Perhaps it could remain permeable gravel with most of the parking here, or green grassy areas with water interception features such as natural ponds and swales (– soft SUDS) or green areas with attractive gardens for the enjoyment and mental health of patients and people visiting the hospital.
I have also a concern over possible infiltration of pollutants into the aquifer feeding the springs for the North fen SSSI. The Churchill Hospital has a very poor record in the past over pollutant-control in surface run-off entering the Boundary Brook. A couple of years ago it was pollution of diesel oil from a leak in underground storage tanks and in spring-summer 2011 it was substantial pollution from an unknown source (suspected to be Ethylene Glycol, anti-freeze) from the Churchill which entered the brook (contact the EA for records). Water quality in the North Fen aquifer must be absolutely protected from incidents such as this and redevelopment on the Churchill site should locate any potential pollution source well away from the sensitive fen catchment zone. There is no way a pollution of the aquifer can be un-done or remediated once it has occurred and remember there is a potentially long time delay between any event and observable effect in the fen.
Wolvercote Paper Mill (SP193)
I see that 66.9% of the site is within Flood zone 3a but zone 2 for the sequential test and that development proposals must incorporate sustainable drainage.
My main feeling is that development (especially housing) in this flood risk area is highly inadvisable in the first place. If there is a development there must be full SUDS and they must have a planning obligation for efficient regular maintenance to ensure they work at full efficiency forever. If the SUDS decline to a low permeability (as they will with no maintenance) then significant run-off from the site could build up and cause flooding problems elsewhere or overload the sewage removal network.
Page 5 of 6:
Duke’s meadow is mentioned as part of the site. This area has currently low floristic diversity, but due to position relative to river excellent opportunity for enhancement of floristic diversity by using green hay from nearby sites to increase the area of high quality floodplain meadow. The Floodplain Meadows Study Group of the ANHSO could be approached for advice on this as they are also involved in monitoring the nearby SAC meadows.
The development site will be very noisy as adjacent to A34 (which will only get busier). Also the air pollution from this road must be considered. Therefore the areas nearest the A34 must surely be unsuitable for housing, better for just employment. That means the housing might well all be located much nearer Port Meadow – relevance to next point.
I see the plan is to create of public open space on the site to encourage people not to walk dogs on the SAC Port Meadow. I expect this strategy to have only a little effect with regard to this stated aim. You have only to look at the behaviour of dog walkers. The paper mill site is only 5 mins from Port meadow and people already come a much greater distance in cars with their dogs specifically to let them off the lead on Port Meadow to run free in its attractive large open area. Also the paper mill site is only a few minutes walk to the footpath that leads under the A34 directly across Pixey Mead SSSI &SAC haymeadow. There will be increased public pressure on this sensitive haymeadow for walking recreation. My experience of direct observation of New Marston Meadow meadows SSSI (haymeadows) for the last 12 years has shown that ever-increasing public usage of the haymeadows for informal recreation has meant a big increase in arson (fires and barbeques) plus some public treating the haymeadows not as a farm crop or a respected wildlife area but just as a public recreation park – general trampling in some areas. The making of new unofficial footpaths has resulting in much loss of hay and detrimental change in the flora - consequent flora biodiversity losses. Development needs to consider how to stop this happening to Pixey mead.
Finally, one needs also to consider the cumulative effect of not just this papermill development but the possible development of employment and housing on the Northern Gateway site nearby with regard to public recreation pressure (especially dog pressure) on the SAC and car pressure on the narrow, congested Godstow road, not to mention the full-to-capacity Wolvercote Roundabout – a nightmare to navigate already at peak times. How will developers solve any of these off-site problems?
Warnford Hospital site (SP61)
As the proposal is to relocate new hospital buildings on the greenfield site of a sports pitch, there will be an unavoidable loss of a fully permeable surface. Maximum infiltration of roof and paved area water should be carried out by full SUDS in the whole re-development area. These need to be regularly maintained as part of the planning obligation to ensure maximum efficiency during the lifetime of the site. It is particularly important that NO site run-off water be directed into the drainage network which discharges into the Boundary Brook. This brook is currently experiencing severe erosion from flash flooding with consequent damage to the Lye Valley SSSI downstream. There must be no increase in discharges to this brook; in fact reduction in discharges is desirable.
Page 6 of 6:
Nuffield Orthopaedic Centre (SP38)
In any new developments at this site Maximum infiltration of roof and paved area water should be carried out by full SUDS which are regularly maintained to ensure maximum efficiency during the lifetime of the site. It is particularly important that NO MORE site run-off water be directed into the drainage network which discharges into the top of the Lye Brook. This brook is currently experiencing severe erosion from flash-flooding with consequent damage to the Lye Valley SSSI downstream. There must be no increase in discharges to this brook, in fact, reduction in discharges is desirable.
Oxford Brookes Gipsy Lane Campus (SP41)
IF any surface run-off from this site currently enters the network of surface drains reaching the Boundary Brook, any rebuilding or replacement of courtyards and paved areas has the potential to increase the brook’s problems. If that case applies, any redevelopment should incorporate full SUDS which are regularly maintained to ensure maximum efficiency during the lifetime of the site and no increased run off to the brook.
Government Buildings site (SP19)
An important green wildlife corridor exists alongside the pedestrian and cycle way of Cuckoo Lane. Previous large developments (student halls, Islamic centre) all along Marston Road have successively broken, fragmented and severed the green corridor between Headington Hill and Marston meadows making it very difficult for wildlife to move in this part of the city. This point is mentioned in the text B2.48 but not in the context of wildlife and nothing about it appears in the final policy. I strongly feel the policy should actually state that this wildlife corridor of green vegetation should be as wide as possible and be specially protected. Protection of green wildlife corridors is supposed to be something that the City is very keen on. Not much sign of any of that kind of thinking in this area in the developments to date.
Government Buildings (SP 19) and Harcourt House (SP20)
Developments at these sites should take special care to have full SUDS as part of their planning obligation. No roof/ paved or tarmac surface water should enter the already overloaded sewage network running through Marston to reduce problems of sewer overloading to residents in Oxford city further along the pipe work on its way to the Thames. All SUDS should be fully and efficiently maintained for the lifetimes of the buildings.
From Dr Judith A Webb
Page 1 of 6: General comments on all Sites:
Sustainable Urban Drainage
SUDS [Sustainable Urban Drainage Systems] are put forward as mitigation in some of these proposed developments. Bearing in mind that ‘mitigation’ does not mean ‘putting things right’ but more like ‘making a bad situation less bad’ my strong feeling is that full SUDS should be an absolute requirement in ALL future developments (large and small) within the city. Problems occur all over the city with rainwater from hard surfacing overloading an old and inadequate-capacity sewage transport network; resulting in the regular upwelling of sewage into streets, parks and homes after a sudden rainstorm. Not to mention damage to any watercourse road-run-off water is directed to and lack of replenishment of aquifers.
Not only should every development have SUDS, there must be realisation and acceptance that all SUDS need regular maintenance (?annually) to a high standard to remove silting up and reduction in performance - as regards infiltration to ground water and reduction in damaging run-off. This fact is well known (see link below). SUDS that work perfectly for the first year and then slowly decline in performance so that by year 10 they are only half as permeable are no good. After all, every householder knows that they should check their guttering for sediment regularly (annually?) and knows that if this sediment is not all removed regularly, the result is a blocked down pipe and water overflowing the gutter and down house walls. At that point it is as if there was no gutter. This situation is exactly the same for SUDS; The sediment that fills gutters is dust from the air which rains down continually. In the same way that it fills gutters, it fills up soakaways and blocks the pores in permeable/pervious paving and asphalt. Maintenance of such SUDS involves jetting and sucking all the silt out. It requires specialist machinery, labour and presumably has a carbon footprint and is costly. It won’t get all the silt out at each session - at regular intervals the permeable surfaces will need to be replaced in order to work effectively. Developers will be long gone by then so who will pay for such essential maintenance?
There is much information on decline in performance, just search on the web for ‘clogging of permeable paving’, just a few quickly found:
http://www.north-herts.gov.uk/sfra_appendix_h_alternative_suds_techniques.pdf
‘The performance of permeable pavements will dramatically decrease over a period of time with the clogging of voids and this should be taken into consideration during the design process and maintenance.’
http://cfpub.epa.gov/npdes/stormwater/menuofbmps/index.cfm?action=browse&Rbutton=detail&bmp=136&minmeasure=5
‘Studies of the long term surface permeability permeable pavements have found high infiltration rates initially, a decrease, and then a levelling off with time’
Page 2 of 6:
Due to clogging, the design life of some types of concrete interlocking paving may be as little as 20 years, and it may then need replacing, or the aggregate between pavers will need replacing.
I understand maintenance of all SUDS can be planning obligations or as a condition attached to planning permissions for development. OR will all new SUDS be adopted and maintained by a local authority? Which of the cash-strapped City or County Councils will be able to pay for expensive maintenance of all the SUDS in these new developments for the development’s lifetime?
SUDS without any maintenance are pretty worthless in my view. Permeable paving installed in the ‘Harberton Heights’ housing development adjacent to Milham Ford Nature park in New Marston was installed in 2008 and is already showing significant blocking between the pavers with extensive moss growth, in only just over 3 years. Thus it already cannot be functioning as it should.
A greenfield (if un-compacted) is the only self-sustaining, completely indefinitely renewable, cost-free water-infiltration surface a site can have. This is obvious to any gardener. Drainage spaces in a natural soil are continually being formed by live earthworms burrowing and the growth and death of plant roots which leave vertical channels as they rot. Yes the channels silt up, just as in permeable paving; but the crucially different feature is that new drainage channels are always forming by the continuing action of living things (plants, worms) in the soil. No living things means no new channels formed. This is the situation in any artificial, man-made, permeable surface.
Reference to all the above will occur regularly in the specific comments that follow. If I sound like a boring, broken record all the time it is because I feel very strongly that this is such an important issue.
Specific Site Comments:
Warren Crescent ( SP62)
As I have said before, this site shouldn’t even be considered at all at this stage for all the reasons I have given earlier (see previous submissions). I strongly object to its proposal for housing and it should be thrown out. New evidence indicates breeding of protected BAP reptiles within very few metres of the site boundary and an active badger sett just on the bank below the site boundary in the LNR plus breeding of BAP brown hairstreak butterflies on blackthorn immediately adjacent.
As I have explained before this site is well within the catchment of the SSSI North Fen springs therefore any suggestion that SUDS will be an acceptable mitigation of the effect of development will be not tolerable. The reason for saying this is that every drop of rainwater that currently falls in the Warren Crescent grassy areas is needed to replenish the groundwater to feed the SSSI springs on the West side of the fen. Climate change to less rainfall every year will in any case be starving the springs of water in the future (drought is already upon us) so they will unavoidably produce less water for the fen. Building on this site is avoidable, therefore it should not be done. Breaking up the concrete ex-garages and returning them to permeable greenfield will help supply water to the springs and assist in counteracting effects of climate change.
Page 3 of 6:
Previous planning permission was granted in ignorance of hydrological information and biodiversity information that is now available. Therefore it sets no precedent.
Apart from threats to biodiversity of development on this site I would like officers to consider the consequences of lack of water to the springs producing drying out of the considerable tonnage of peat that exists in the Lye Valley North fen and LNR area. Despite past peat cutting, a depth of more than a metre of peat exists over a large area of the whole valley bottom. Lack of spring water will result in drying which results in oxidation of the peat, liberating CO2. The site will become a serious CO2 emission source if the springs dry up. The City Council has a duty to try and reduce its carbon footprint as much as possible. I can roughly calculate the potential volume of C locked up in the peat at the moment and therefore the potential future emission if it is oxidised to CO2 upon peat drying. Is that of interest?
Churchill Hospital Site (SP 8)
Run-off from all roofs and paved and road areas in the Churchill site currently all enters the Boundary Brook. Due to the large Churchill site area, the water run-off volume must be a major contributor to the flash flooding and consequent erosion problems the brook is already experiencing, resulting in on-going damage to the Lye Valley SSSI South fen downstream. Part of the reason for this is the non-functioning of a water-interception device at the surface water outfall. Prior to entering the brook, run-off water from the Churchill site first enters a balancing/ attenuation/retention pond. Such a pond should function by filling up during a storm peak and then slowly releasing the water to the brook or into the ground after the event. However this water interception pond retains water at all times (more or less full) therefore has minimal capacity to attenuate the effects of storm water from the Churchill in a sudden heavy rainfall event. Thus, any rainwater from the Churchill site enters the brook suddenly at full, damaging, force – basically it skates over the top of the already full balancing pond.
Re-developments at the Churchill should take the opportunity to introduce full, high quality SUDS throughout, with a full programme of efficient maintenance for the lifetime of the buildings and paved/asphalt areas. This would increase infiltration at source and reduce the current peak run-offs to the brook and reduce the problems of the non-properly-functioning water-interception pond. Rainwater harvesting for use within the buildings (e.g. toilet flushing) would not be good because that water is then lost from the site to the sewers eventually. Much better would be rain-water harvesting for the purpose of infiltration into the ground to replenish aquifers locally.
A drastic reduction in the run-off volume on the west side of the site should be required. If space is in short supply, why can’t green roofs be part of the design plan?
In addition, the wooded corridor of the Boundary Brook is a LWS for its BAP priority habitat of wet woodland. This habitat depends on functioning, flowing, springs along the whole line of the brook from the Churchill site. More efficient infiltration as a result of re-development will be beneficial in feeding the springs and helping them combat the effects of coming climate change.
Page 4 of 6:
As regards re-developments on the East side of the Churchill site, this area is within the calculated catchment of the springs feeding the North Fen SSSI therefore the suggestion that SUDS will be an acceptable mitigation of the effect of development must be strongly challenged. The reason for saying this is that every drop of rainwater that currently falls in the Churchill area that is the calculated catchment is needed to replenish the groundwater to feed the SSSI springs on the West side of the fen. Predicted climate change to less rainfall every year will in any case eventually be starving the springs of water in the future (drought is already upon us) so they will unavoidably produce less water for the fen. The current re-inforced gravel surface over the car parking area just above the North fen seems to be working in that the springs on this side are still running. However it must be borne in mind that hydrologists advise me that there can be a significant time delay between changing a surface feature (i.e. installation of paving over greenfield) and seeing the effect of such a feature on the output of springs from the aquifer underneath. It could be 10 years or more before the FULL effect of changing a surface feature is reflected in a changed output of the springs from the aquifer underneath the feature.
Regarding this East side of the Churchill site within the North fen catchment it seems sensible to suggest major buildings and hard surfacings (even if ‘permeable’) are kept well away from it. Perhaps it could remain permeable gravel with most of the parking here, or green grassy areas with water interception features such as natural ponds and swales (– soft SUDS) or green areas with attractive gardens for the enjoyment and mental health of patients and people visiting the hospital.
I have also a concern over possible infiltration of pollutants into the aquifer feeding the springs for the North fen SSSI. The Churchill Hospital has a very poor record in the past over pollutant-control in surface run-off entering the Boundary Brook. A couple of years ago it was pollution of diesel oil from a leak in underground storage tanks and in spring-summer 2011 it was substantial pollution from an unknown source (suspected to be Ethylene Glycol, anti-freeze) from the Churchill which entered the brook (contact the EA for records). Water quality in the North Fen aquifer must be absolutely protected from incidents such as this and redevelopment on the Churchill site should locate any potential pollution source well away from the sensitive fen catchment zone. There is no way a pollution of the aquifer can be un-done or remediated once it has occurred and remember there is a potentially long time delay between any event and observable effect in the fen.
Wolvercote Paper Mill (SP193)
I see that 66.9% of the site is within Flood zone 3a but zone 2 for the sequential test and that development proposals must incorporate sustainable drainage.
My main feeling is that development (especially housing) in this flood risk area is highly inadvisable in the first place. If there is a development there must be full SUDS and they must have a planning obligation for efficient regular maintenance to ensure they work at full efficiency forever. If the SUDS decline to a low permeability (as they will with no maintenance) then significant run-off from the site could build up and cause flooding problems elsewhere or overload the sewage removal network.
Page 5 of 6:
Duke’s meadow is mentioned as part of the site. This area has currently low floristic diversity, but due to position relative to river excellent opportunity for enhancement of floristic diversity by using green hay from nearby sites to increase the area of high quality floodplain meadow. The Floodplain Meadows Study Group of the ANHSO could be approached for advice on this as they are also involved in monitoring the nearby SAC meadows.
The development site will be very noisy as adjacent to A34 (which will only get busier). Also the air pollution from this road must be considered. Therefore the areas nearest the A34 must surely be unsuitable for housing, better for just employment. That means the housing might well all be located much nearer Port Meadow – relevance to next point.
I see the plan is to create of public open space on the site to encourage people not to walk dogs on the SAC Port Meadow. I expect this strategy to have only a little effect with regard to this stated aim. You have only to look at the behaviour of dog walkers. The paper mill site is only 5 mins from Port meadow and people already come a much greater distance in cars with their dogs specifically to let them off the lead on Port Meadow to run free in its attractive large open area. Also the paper mill site is only a few minutes walk to the footpath that leads under the A34 directly across Pixey Mead SSSI &SAC haymeadow. There will be increased public pressure on this sensitive haymeadow for walking recreation. My experience of direct observation of New Marston Meadow meadows SSSI (haymeadows) for the last 12 years has shown that ever-increasing public usage of the haymeadows for informal recreation has meant a big increase in arson (fires and barbeques) plus some public treating the haymeadows not as a farm crop or a respected wildlife area but just as a public recreation park – general trampling in some areas. The making of new unofficial footpaths has resulting in much loss of hay and detrimental change in the flora - consequent flora biodiversity losses. Development needs to consider how to stop this happening to Pixey mead.
Finally, one needs also to consider the cumulative effect of not just this papermill development but the possible development of employment and housing on the Northern Gateway site nearby with regard to public recreation pressure (especially dog pressure) on the SAC and car pressure on the narrow, congested Godstow road, not to mention the full-to-capacity Wolvercote Roundabout – a nightmare to navigate already at peak times. How will developers solve any of these off-site problems?
Warnford Hospital site (SP61)
As the proposal is to relocate new hospital buildings on the greenfield site of a sports pitch, there will be an unavoidable loss of a fully permeable surface. Maximum infiltration of roof and paved area water should be carried out by full SUDS in the whole re-development area. These need to be regularly maintained as part of the planning obligation to ensure maximum efficiency during the lifetime of the site. It is particularly important that NO site run-off water be directed into the drainage network which discharges into the Boundary Brook. This brook is currently experiencing severe erosion from flash flooding with consequent damage to the Lye Valley SSSI downstream. There must be no increase in discharges to this brook; in fact reduction in discharges is desirable.
Page 6 of 6:
Nuffield Orthopaedic Centre (SP38)
In any new developments at this site Maximum infiltration of roof and paved area water should be carried out by full SUDS which are regularly maintained to ensure maximum efficiency during the lifetime of the site. It is particularly important that NO MORE site run-off water be directed into the drainage network which discharges into the top of the Lye Brook. This brook is currently experiencing severe erosion from flash-flooding with consequent damage to the Lye Valley SSSI downstream. There must be no increase in discharges to this brook, in fact, reduction in discharges is desirable.
Oxford Brookes Gipsy Lane Campus (SP41)
IF any surface run-off from this site currently enters the network of surface drains reaching the Boundary Brook, any rebuilding or replacement of courtyards and paved areas has the potential to increase the brook’s problems. If that case applies, any redevelopment should incorporate full SUDS which are regularly maintained to ensure maximum efficiency during the lifetime of the site and no increased run off to the brook.
Government Buildings site (SP19)
An important green wildlife corridor exists alongside the pedestrian and cycle way of Cuckoo Lane. Previous large developments (student halls, Islamic centre) all along Marston Road have successively broken, fragmented and severed the green corridor between Headington Hill and Marston meadows making it very difficult for wildlife to move in this part of the city. This point is mentioned in the text B2.48 but not in the context of wildlife and nothing about it appears in the final policy. I strongly feel the policy should actually state that this wildlife corridor of green vegetation should be as wide as possible and be specially protected. Protection of green wildlife corridors is supposed to be something that the City is very keen on. Not much sign of any of that kind of thinking in this area in the developments to date.
Government Buildings (SP 19) and Harcourt House (SP20)
Developments at these sites should take special care to have full SUDS as part of their planning obligation. No roof/ paved or tarmac surface water should enter the already overloaded sewage network running through Marston to reduce problems of sewer overloading to residents in Oxford city further along the pipe work on its way to the Thames. All SUDS should be fully and efficiently maintained for the lifetimes of the buildings.