Comments on the Barton Area Action Plan, Preferred Options Consultation Questionnaire document for 24 06 2011
From Judith A Webb
Whilst I have attended a drop in session and the stakeholder meeting regarding this development because I have interests in and support the New Marston Wildlife Group, the Oxford Urban Wildlife Group and the Rare Plants Group of the Ashmolean Natural History Society of Oxfordshire, I have not had time to discuss my concerns regarding wildlife potentially affected with any of these groups therefore I cannot officially represent their views here.
Thus the comments that follow represent my own personal views only.
This development may have far reaching effects in the area well beyond the development boundaries and it is very disappointing that the City Council has not addressed these issues mentioned below at this early stage. I feel the following points discussed are not mere details to be sorted out later, but are potentially very large issues that need to be considered at the earliest opportunity in the whole process, with robust solutions found before proceeding. I urge decision makers to think beyond the plans on paper and look seriously to how this site will actually function long into the future. Climate change predictions are available into the 2080s on the UKCIP website. Please make decisions based on modelling incorporating the very latest information available here to ensure account is taken of at least the next 70 years. Lack of time means I have not been able to quote references supporting many of my observations below. Much is based on my own personal ecological experience, but supporting references can be supplied in time for the next stage of this process towards the Land at Barton Development.
A. Potential damaging effects to city residents and to SSSI meadows in New Marston from the extra sewage from this development entering the existing sewage network
It is clear from Thames Water representatives at the Stakeholder meeting that sewage from this new development will have to travel to the STW at Sandford through the existing pipe network which travels under the New Marston area of the city. This area has a history of problems of sewage welling up in streets, gardens and valuable SSSI floodplain meadows habitats not far from the Cherwell River. This happens after heavy rainfall when the system gets overloaded. Climate change predictions state that such heavy rainfall events in the winter are predicted to increase in the future. 1000 new homes will produce a vast amount of extra sewage entering an already overloaded system. At the Stakeholder meeting on 16.06.2011 a Thames Water representative stated that the existing network had insufficient capacity and that peak flow output of sewage from the projected Barton Area development expected could be 40litres/second.
To solve previous sewage upwelling problems very expensive attenuation tanks were installed in the sewage network in the New Marston area to reduce the effect of peak flows. According to local residents, these have never worked properly. The SSSI meadow that has been previously affected by sewage outflow (it has a main sewer with several hatches running under it) is a hay meadow (No. 46Y, in the Natural England classification system). Residents in properties at the lower end of Ferry Road have suffered problems from this same sewer. Details of the problems in this area are not presented here due to lack of time, but can be assembled for the next round of consultation.
This new development presumably will require even bigger and more costly newer attenuation tanks in New Marston to deal with sewage upwelling problems. Is there a guarantee these will actually work for ever, or will this new development condemn local residents here to further misery and important SSSI meadow habitats to more damage? The next point is relevant to peak flows in this sewage system.
B. Sustainable Urban Drainage in this new development
I noted in the Stakeholder meeting on Thursday 16th June that it was stated that this whole development would have SUDS that would produce an equivalent state to ‘greenfield or better’. I take great issue with this statement. I think it is completely unrealistic, looking into the future of this site. What little research into the actual effectiveness of SUDS I have had time to carry out indicates to me that the very best SUDS reduce the run off from an area from 100% (i.e. with a completely impermeable surface) to about 20-30% with SUDS. Not to zero. The worst performing reduce the run-off from 100% to only 50%. Add to this that all SUDS eventually silt up, either quickly or slowly, depending on whether the water entering the system is carrying a lot of suspended clay or silt or not. So even if they perform quite well when newly installed, they will not perform that well in 10-15 years’ time when their pores are clogged-up. Another very important point is the fact that homeowners in the new development will be able, if they so wish, to completely impermeably pave over their back gardens without needing planning permission. Will no house extensions or infill development be ever allowed? Inevitably, over time, the run-off from this 1000 house site with tarmac roads will gradually increase and increase. One needs to look at the run-off this site will be producing 50, 100 years or more into the future to gauge the potential impact elsewhere of the run-off generated. Who will maintain the effectiveness of the SUDS on this site over that 100year and more timescale? How will increase in the impermeability of privately owned areas (e.g. by paving) be prevented, in the short and long term? How will the SUDS function with the increase in sudden, intense, rainfall events in the winter months predicted by the climate change models currently available on the UKCIP website? (see ‘changes in the wettest days in summer and winter’ – http://ukclimateprojections.defra.gov.uk/content/view/2069/500/. According to this, by 2080, assuming the medium CO2 emissions scenario, rainfall in the winter in the Oxford area could increase by as much as 30% in the winter).
I expect that actually there will be substantial surface run-off from this 1000 house development. The two routes from the site for this water will be the Bayswater Brook which will suffer as a result increased erosion further along its course, presumably through fields and entering the Cherwell near Sescut Farm. The other route for this run–off water from the site could be to enter the sewerage system and contribute to increased sewage volume after heavy rainfall events. This will contribute to the great problems in the pipe network as it passes under New Marston. Is it the case that the design of this development will mean there will be absolutely NO hard surface/roof rainwater run-off entering the sewage system after a heavy rainfall event in this development? This is what is required to ensure no problems in New Marston.
In addition, in my view, it is completely inappropriate to put a lot of the SUDS in the proposed linear nature park which is planned for alongside the Bayswater Brook. The two uses are incompatible. Swales, for example, take up a lot of space, can be pretty ugly, cannot be in places where people regularly walk (compression) and cannot be attractive water features as they need to be empty before a rainfall event to work.
C. Potential damage by increased public access - recreational pressure/vandalism to Sidlings Copse & College Pond SSSI
This SSSI is situated only 600m to the NW of the proposed development area and outside the city boundary in South Oxon District. A footpath runs directly from the development to and through the south western end of the site, College pond. County Policy is to actively encourage people to access countryside more in order to obtain the health benefits of walking.
This SSSI contains a number of different very fragile habitat types, ranging from ancient woodland to limestone grassland, acid grassland and calcareous valley fen. These are habitats that are not robust enough to stand much trampling and increased public access may present the following problems which may result in damage and loss of biodiversity and the rare species that are present:
1. Increased trampling and informal path formation in areas with no official footpaths. Loss of the trampled plant communities and soil compaction.
2. Arson. Destruction of deadwood that presents an important habitat for invertebrates. Burn damage to turf from picnic and barbeque fires.
3. Increased dog walking resulting in nutrient enrichment from dog faeces and urine. All habitats at this SSSI are low nutrient areas and such nutrient enrichment will change plant communities for the worse.
4. Increased dog walking to the site resulting in increased hazards to the BBOWT grazing stock which are ponies especially in the fen and sheep in the limestone grassland areas. If grazing has to stop due to dog attacks, there will be damaging changes to the plant communities of the grassland and the fen.
5. Disturbance to shy birds, mammals and reptiles – some from dogs. Increased public pressure may destroy the quiet conditions these need to breed successfully.
6. Actual digging up and removal of rare plants such as orchids present on site.
Obviously there will be discussion on minimising the potential damage with BBOWT, Natural England and South Oxon District Council. My suggestions for reduction of potential damages listed above are:
a. Divert the footpath going from the new development to Sidlings Copse & College Pond away/around the SSSI site so there is no access directly into the SSSI from the development direction.
b. Access to the footpath leading to Sidlings Copse and College Pond from the development edge only by stile, with restricted or no parking allowed at the point of access from the development. If there is parking, people will be encouraged to drive to this point and park to take numbers of dogs along this footpath. This already happens a lot in New Marston Meadows SSSI. Serious walkers will not be dissuaded.
As regards mitigation for any damage to this site. There can be no way to recreate habitat elsewhere that is of equivalent worth to the loss of ancient woodland or calcareous valley fen. Recreation of acid and calcareous species rich grassland may be possible, but an appropriate area may be difficult to find.
D. Standard of construction of all the new houses
I would hope that all new houses should be zero carbon i.e. not less than level 5 of the Code for Sustainable Homes to reduce the overall environmental impact of the construction. I would hope that these homes would incorporate good water conservation measures, such as grey water recycling. The reason for this is the projected shortfall in water availability in the South East in the future (See UKCIP09). Overall annual rainfall may decrease on average by 10%. Summer rainfall in the SE could decrease by as much 50%. There will be a huge demand for water for agriculture for irrigation, so the less demand new housing makes, the better.
E. Allotments (question 6 in the official questionnaire)
I think the whole of the area of allotment land should be retained in its entirety in its current location. It is unreasonable to move people from plots they have tended and improved for many years. Even if it is not all plots are cultivated at the moment, it will be filled up as there will be new takers of allotments from the new development. All residents need to be able to obtain the health benefits from growing their own food and accessing such productive green spaces.
F. Ruskin Fields Development (question 15 in the official questionnaire)
I think there should be no development of the Ruskin fields for several reasons. They should remain a green habitat for wildlife and essential wildlife corridor to prevent isolation and fragmentation of such remaining green sites as Dunstan Park. No development will also ensure they remain fully permeable allowing rainfall infiltration and thus there will be no increased run-off and potential damage to any watercourses leaving this site. At the moment I presume any run off from these fields enters a drainage system which feeds to the watercourses running through Marston to the Cherwell. These run past properties and through SSSI meadows.
From Judith A Webb
Whilst I have attended a drop in session and the stakeholder meeting regarding this development because I have interests in and support the New Marston Wildlife Group, the Oxford Urban Wildlife Group and the Rare Plants Group of the Ashmolean Natural History Society of Oxfordshire, I have not had time to discuss my concerns regarding wildlife potentially affected with any of these groups therefore I cannot officially represent their views here.
Thus the comments that follow represent my own personal views only.
This development may have far reaching effects in the area well beyond the development boundaries and it is very disappointing that the City Council has not addressed these issues mentioned below at this early stage. I feel the following points discussed are not mere details to be sorted out later, but are potentially very large issues that need to be considered at the earliest opportunity in the whole process, with robust solutions found before proceeding. I urge decision makers to think beyond the plans on paper and look seriously to how this site will actually function long into the future. Climate change predictions are available into the 2080s on the UKCIP website. Please make decisions based on modelling incorporating the very latest information available here to ensure account is taken of at least the next 70 years. Lack of time means I have not been able to quote references supporting many of my observations below. Much is based on my own personal ecological experience, but supporting references can be supplied in time for the next stage of this process towards the Land at Barton Development.
A. Potential damaging effects to city residents and to SSSI meadows in New Marston from the extra sewage from this development entering the existing sewage network
It is clear from Thames Water representatives at the Stakeholder meeting that sewage from this new development will have to travel to the STW at Sandford through the existing pipe network which travels under the New Marston area of the city. This area has a history of problems of sewage welling up in streets, gardens and valuable SSSI floodplain meadows habitats not far from the Cherwell River. This happens after heavy rainfall when the system gets overloaded. Climate change predictions state that such heavy rainfall events in the winter are predicted to increase in the future. 1000 new homes will produce a vast amount of extra sewage entering an already overloaded system. At the Stakeholder meeting on 16.06.2011 a Thames Water representative stated that the existing network had insufficient capacity and that peak flow output of sewage from the projected Barton Area development expected could be 40litres/second.
To solve previous sewage upwelling problems very expensive attenuation tanks were installed in the sewage network in the New Marston area to reduce the effect of peak flows. According to local residents, these have never worked properly. The SSSI meadow that has been previously affected by sewage outflow (it has a main sewer with several hatches running under it) is a hay meadow (No. 46Y, in the Natural England classification system). Residents in properties at the lower end of Ferry Road have suffered problems from this same sewer. Details of the problems in this area are not presented here due to lack of time, but can be assembled for the next round of consultation.
This new development presumably will require even bigger and more costly newer attenuation tanks in New Marston to deal with sewage upwelling problems. Is there a guarantee these will actually work for ever, or will this new development condemn local residents here to further misery and important SSSI meadow habitats to more damage? The next point is relevant to peak flows in this sewage system.
B. Sustainable Urban Drainage in this new development
I noted in the Stakeholder meeting on Thursday 16th June that it was stated that this whole development would have SUDS that would produce an equivalent state to ‘greenfield or better’. I take great issue with this statement. I think it is completely unrealistic, looking into the future of this site. What little research into the actual effectiveness of SUDS I have had time to carry out indicates to me that the very best SUDS reduce the run off from an area from 100% (i.e. with a completely impermeable surface) to about 20-30% with SUDS. Not to zero. The worst performing reduce the run-off from 100% to only 50%. Add to this that all SUDS eventually silt up, either quickly or slowly, depending on whether the water entering the system is carrying a lot of suspended clay or silt or not. So even if they perform quite well when newly installed, they will not perform that well in 10-15 years’ time when their pores are clogged-up. Another very important point is the fact that homeowners in the new development will be able, if they so wish, to completely impermeably pave over their back gardens without needing planning permission. Will no house extensions or infill development be ever allowed? Inevitably, over time, the run-off from this 1000 house site with tarmac roads will gradually increase and increase. One needs to look at the run-off this site will be producing 50, 100 years or more into the future to gauge the potential impact elsewhere of the run-off generated. Who will maintain the effectiveness of the SUDS on this site over that 100year and more timescale? How will increase in the impermeability of privately owned areas (e.g. by paving) be prevented, in the short and long term? How will the SUDS function with the increase in sudden, intense, rainfall events in the winter months predicted by the climate change models currently available on the UKCIP website? (see ‘changes in the wettest days in summer and winter’ – http://ukclimateprojections.defra.gov.uk/content/view/2069/500/. According to this, by 2080, assuming the medium CO2 emissions scenario, rainfall in the winter in the Oxford area could increase by as much as 30% in the winter).
I expect that actually there will be substantial surface run-off from this 1000 house development. The two routes from the site for this water will be the Bayswater Brook which will suffer as a result increased erosion further along its course, presumably through fields and entering the Cherwell near Sescut Farm. The other route for this run–off water from the site could be to enter the sewerage system and contribute to increased sewage volume after heavy rainfall events. This will contribute to the great problems in the pipe network as it passes under New Marston. Is it the case that the design of this development will mean there will be absolutely NO hard surface/roof rainwater run-off entering the sewage system after a heavy rainfall event in this development? This is what is required to ensure no problems in New Marston.
In addition, in my view, it is completely inappropriate to put a lot of the SUDS in the proposed linear nature park which is planned for alongside the Bayswater Brook. The two uses are incompatible. Swales, for example, take up a lot of space, can be pretty ugly, cannot be in places where people regularly walk (compression) and cannot be attractive water features as they need to be empty before a rainfall event to work.
C. Potential damage by increased public access - recreational pressure/vandalism to Sidlings Copse & College Pond SSSI
This SSSI is situated only 600m to the NW of the proposed development area and outside the city boundary in South Oxon District. A footpath runs directly from the development to and through the south western end of the site, College pond. County Policy is to actively encourage people to access countryside more in order to obtain the health benefits of walking.
This SSSI contains a number of different very fragile habitat types, ranging from ancient woodland to limestone grassland, acid grassland and calcareous valley fen. These are habitats that are not robust enough to stand much trampling and increased public access may present the following problems which may result in damage and loss of biodiversity and the rare species that are present:
1. Increased trampling and informal path formation in areas with no official footpaths. Loss of the trampled plant communities and soil compaction.
2. Arson. Destruction of deadwood that presents an important habitat for invertebrates. Burn damage to turf from picnic and barbeque fires.
3. Increased dog walking resulting in nutrient enrichment from dog faeces and urine. All habitats at this SSSI are low nutrient areas and such nutrient enrichment will change plant communities for the worse.
4. Increased dog walking to the site resulting in increased hazards to the BBOWT grazing stock which are ponies especially in the fen and sheep in the limestone grassland areas. If grazing has to stop due to dog attacks, there will be damaging changes to the plant communities of the grassland and the fen.
5. Disturbance to shy birds, mammals and reptiles – some from dogs. Increased public pressure may destroy the quiet conditions these need to breed successfully.
6. Actual digging up and removal of rare plants such as orchids present on site.
Obviously there will be discussion on minimising the potential damage with BBOWT, Natural England and South Oxon District Council. My suggestions for reduction of potential damages listed above are:
a. Divert the footpath going from the new development to Sidlings Copse & College Pond away/around the SSSI site so there is no access directly into the SSSI from the development direction.
b. Access to the footpath leading to Sidlings Copse and College Pond from the development edge only by stile, with restricted or no parking allowed at the point of access from the development. If there is parking, people will be encouraged to drive to this point and park to take numbers of dogs along this footpath. This already happens a lot in New Marston Meadows SSSI. Serious walkers will not be dissuaded.
As regards mitigation for any damage to this site. There can be no way to recreate habitat elsewhere that is of equivalent worth to the loss of ancient woodland or calcareous valley fen. Recreation of acid and calcareous species rich grassland may be possible, but an appropriate area may be difficult to find.
D. Standard of construction of all the new houses
I would hope that all new houses should be zero carbon i.e. not less than level 5 of the Code for Sustainable Homes to reduce the overall environmental impact of the construction. I would hope that these homes would incorporate good water conservation measures, such as grey water recycling. The reason for this is the projected shortfall in water availability in the South East in the future (See UKCIP09). Overall annual rainfall may decrease on average by 10%. Summer rainfall in the SE could decrease by as much 50%. There will be a huge demand for water for agriculture for irrigation, so the less demand new housing makes, the better.
E. Allotments (question 6 in the official questionnaire)
I think the whole of the area of allotment land should be retained in its entirety in its current location. It is unreasonable to move people from plots they have tended and improved for many years. Even if it is not all plots are cultivated at the moment, it will be filled up as there will be new takers of allotments from the new development. All residents need to be able to obtain the health benefits from growing their own food and accessing such productive green spaces.
F. Ruskin Fields Development (question 15 in the official questionnaire)
I think there should be no development of the Ruskin fields for several reasons. They should remain a green habitat for wildlife and essential wildlife corridor to prevent isolation and fragmentation of such remaining green sites as Dunstan Park. No development will also ensure they remain fully permeable allowing rainfall infiltration and thus there will be no increased run-off and potential damage to any watercourses leaving this site. At the moment I presume any run off from these fields enters a drainage system which feeds to the watercourses running through Marston to the Cherwell. These run past properties and through SSSI meadows.