Dear Mr Duxbury
Objection to planning application 09/00909/REM – Land off
Gavray Drive, Bicester
I write to register my objection to the above application for
approval of the drainage scheme for residential development at Land North of
Gavray Drive, Bicester. I may write with more detailed reasons for objection
shortly, but in order to assist the consultation process that has now commenced,
and to provide the applicant with an opportunity to provide further information,
I summarise the main grounds for concern below:
1)
The surface water drainage scheme for this development
is the subject of a planning condition imposed by the Secretary of State. That
condition requires details of “...attenuation, storage and on-site balancing
arrangements, reflecting current best practice for sustainable urban
drainage...”. The scheme that has been submitted for approval relies on off-site
balancing and has more in common with conventional 1980’s designs than in any
way representing best practice for modern sustainable urban drainage. There is
ample space on this site for sustainable drainage features to be incorporated
and no justification has been provided for deviating from the terms of the
outline consent, and the requirements of the Secretary of State. The applicant
has not asked for the condition to be varied.
2)
The ‘elephant in the room’ with this application is that
in order for this submitted drainage scheme to function, large volumes of inert
fill will need to be imported to the site to raise land levels - by in excess of
1.5 metres in some places. This issue has only come to light in piecemeal
fashion and the applicant has consistently declined (e.g. see my letter of
24th October last year - attached) to provide proper details on the
volumes of fill material required, their type and source, their route of
importation to the site, the numbers of lorry movements that will be involved
and how attendant issues of traffic, noise, dust and nuisance to neighbours will
be addressed. These are important material considerations for the determination
process, and for the sake of due process all of those consulted need to be
furnished with such details in order for their responses to be made on a
properly informed basis.
3)
Although it is the duty of the applicant to provide this
information, their consistent refusal to do so has necessitated third party
observers such as myself having to try and back-calculate and second-guess the
full implications of this drainage strategy from levels drawings presented in
previously submitted masterplan documents. The applicant has not challenged the
resulting (probably conservative) estimates of 50-55,000 cubic metres of
material being imported to the site for this purpose. This figure translates to
an additional heavy lorry travelling along Gavray Drive every couple of minutes
for every working day over 3-4 months – over and above the other construction
traffic that the development will generate. These are not insignificant
considerations and are matters upon which I am sure local residents in
particular would feel the need to be appraised.
4)
As is recognised by CDC, the land filling / raising
issue was not addressed in the Environmental Impact Assessment that
accompanied the outline application and neither was it examined at the public
inquiry that led to it being granted outline consent. This is despite the
applicant confirming that they were aware at the pre-application stage that land
filling and raising would be necessary to create building platforms on the site
that could drain by gravity. There has been a failure of regulatory process
here, with decision makers and a broad spectrum of stakeholders being denied the
opportunity they should have had to weigh important matters into their
consideration of the overall scheme and to balance their responses accordingly.
This is still not remedied in the current consultation, as there is scant or no
information on the land-raising in the information presented in the current
application. Directing the applicants to undertake a properly scoped EIA of the
drainage proposals provides an opportunity for this failure to be addressed,
quite apart from ensuring the full environmental consequences of this submission
are examined properly and not overlooked, ignored or subjected to obfuscation.
5)
Given the above, I am extremely puzzled and indeed
concerned as to how CDC have felt able to arrive at a screening opinion that
Environmental Impact Assessment is not required for this application in the
absence of any quantitative detail on the land filling aspect. The magnitude of
land-filling, with its attendant lorry movements and possible implications for
traffic, noise, dust and human health, not to mention the overall sustainability
questions over the type of drainage solution being proposed, are all matters
relevant to assessing the likelihood of significant environmental effects
arising from this proposal. The rationale given in the screening opinion is a
source of further concern but I do not intend to address it here, but I do
question how CDC felt able to make a screening judgment at all without important
and highly relevant matters of detail to hand and invite them to re-consider
their approach on this.
Best regards
Dominic Woodfield MIEEM
CEnv
Director
Bioscan (UK) Ltd
The Old Parlour
Little
Baldon Farm
Oxford
OX44 9PU
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