From: on behalf of DC Secretaries
Subject: FW: 09/00909/REM - Land North of Gavray Drive, Bicester

Attachments: Bicesterlet14.doc
 

 
 


From: Dominic Woodfield [Sent: 23 July 2009 13:57
To: Bob Duxbury
Cc: Planning
Subject: 09/00909/REM - Land North of Gavray Drive, Bicester

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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