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THERE 'S STILL TIME TO RESPOND! SAY CLEARLY WHETHER YOU OBJECT OR SUPPORT. 

SEND YOUR COMMENTS DIRECT TO: 

Matthew.Case@Oxfordshire.gov.uk

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Respond to the Consultation

Still a few days to contact Oxfordshire County Council

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Ask Michael Gove for a Public Inquiry

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Key Questions on The Oxford Flood Alleviation Scheme
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Does the two-stage channel provide little benefit and the scheme would work without it?

Will the irreplaceable MG4a grassland Hinksey Meadows be destroyed?

Has The Environment Agency only budgeted maintenance for 15 years? How would this undermine the scheme?

Does Construction mean 114 HGV vehicle movements a day on and off the A34 for 3-5 years?

Will construction result in a big increase in carbon emissions?

Will OFAS improve the landscape and 'enhance biodiversity' as the EA claims?

 
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Will Hinksey Meadow with its rare MG4a grassland be destroyed?


Hinksey Meadow is no ordinary meadow. Despite the pylons and the suburban location it is a crown jewel of meadowland. The short answer is sadly  yes -  its goodbye to a 1,000 year old landscape that was painted by JMW Turner. the grassland is so rare that there are only four square miles of this kind left in the UK, and Hinksey Meadow MG4a is of the rarest type, and, as the EA itself acknowledges, has never been translocated. Hinksey Meadow also constitutes one of the largest surviving individual parcels of MG4a.

The EA themselves admit that the scheme may dry out what remains of the meadow for part of the year and perhaps make it unsustainable: “Hinksey Meadow is towards the dry end of the tolerance of MG4 grassland and therefore the potential concern would be any changes that left the ground drier during early to mid- summer during the growing season” MG4 Grassland Mitigation Strategy, p.6).  The EA also plans riffles in Bulstake Stream to try to mitigate effects on meadow hydrology but cannot guarantee that these will be effective. 

 
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MG4a has 26 species versus around 15 species in the MG4 grassland with which the EA proposes to ‘replace’ it.   But the relevant 17.8ha field cited by the EA to the S.E. of Osney Mead is already publicly accessible and has been managed for years as good as good quality semi-improved grassland.  It would be dug up (or scarified to create 50% bare earth) and seeded with green hay taken from Hinksey Meadow.  Thus the proposed ‘additonal’ flower meadow neither replaces lost public space nor mitigates for the loss of MG4a. 

Floodplain meadow IS agricultural land. While not all floodplain has the invaluable MG4a, all floodplain meadows function in a cycle of haycutting and grazing, which creates a balanced system sustainable for hundreds of years.  OFA’s dismissal of the area’s biodiversity outside the MG4a area omits the fact that the floodplain meadows are surrounded by mature trees and established hedgerows.  The scheme as a whole is an area of high biodiversity: it’s West Oxford’s Port Meadow (though Port Meadow itself lacks the rare MG4a).  


 

What the Meadow Experts Say

OFA and the EA underestimate the length of time of to recover meadow and the difficulties of doing so. Their rosy picture is in direct contrast to the fears of the noted experts in the field with direct experience of managing meadows. 

Oxford Preservation Trust say: "We are putting our case together through the planning and compulsory purchase routes, as ever, not objecting to the overall scheme but to the destruction of Hinksey Meadows and the spoiling of Willow Walk and public enjoyment of the area. The OFAS newsletters and Oxford Flood Alliance emails are disheartening as they put such a positive spin on things and we have no doubt that Hinksey Meadows will be spoiled extensively, with the landscape and flora and fauna changed, infrastructure introduced and considerable problems of management in the future."

See: https://www.oxfordpreservation.org.uk/node/2145

Catriona Bass – Meadow Expert  http://www.longmeadwildlifesite.org.uk/thames-valley-wildflower-meadow-restoration-project.html


"Floodplain meadows are among our rarest habitats in the UK and the most botanically diverse. Hinksey Meadow is over 1000 years old. If it were an animal or a building bus-loads of tourists would be coming to see the 'last of its kind in the wild'. Recent research by the Floodplain Meadows Partnership at the Open University shows only a 25% succcess rate of floodplain meadow creation in the UK. Research from the Centre for Hydrology and Ecology predicts that it will take 150 years for the majority of species to colonise a new meadow. So the chances of replacing this unique habitat and as important part of our cultural heritage as the Ashmolean and Radcliffe Camera are very slim. There is no scientific evidence for the success of translocation of Floodplain Meadows. Floodplain meadows are one of the few habitats that combine biodiversity with food production."

 

Does the two-stage channel provide little benefit and the scheme would work without it?

How the EA's own data shows marginal benefits for the most expensive element of the scheme with a catastrophic environmental impact.

According to independent hydrologists, planners and economic analysts, the channel does not bring certainty and reliability: it will carry only about 15% of the flood flow and river levels are projected to rise by 30%.  Nor does it directly address ground water or surges. As the area will have been turned from long established flood meadows to a gravel floodplain, the hydrology is uncertain. The channel is passive and only begins taking water, which it may well move too slowly, once flooding begins. In other words it only starts to work when the risk is already high.  It neither provides enough storage nor enough flow to carry water and needs a re-think.

Independent analysis by Surveyor Tim O'Hara suggests that the channel provides only marginal improvement from flooding. 

  • The scheme is intended to provide flood protection: the EA's own figures show the number of dwellings with a great than 1% annual risk of flooding reduces from 1126 to 180. However the same figures show that the channel only accounts for 5.7% of the reduction (54 properties), which could be protected by more environmentally friendly and effective methods. 

 
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How are the figures interpreted to reach a 5.7% marginal benefit of the channel?

The 5.7% figure was obtained by analysis of the information presented within Table 6 of appendix Q. This shows the numbers of residential properties at risk of flood. That table is not as clear as it could be, but it has been  assumed that the figures in the columns are cumulative. 

On this basis there are 1126 residential properties with a 1.33% (or greater) annual risk of flooding for the option “Do minimum: temporarily defences for 25 years”.

  • Under the EA’s scheme this would fall to 180, therefore the scheme improves protection (to a less than 1.33% annual risk of flooding) for 946 residential properties (1126-180).

  • Under the option “ No Channel New Hinksey Meadow to Old Abingdon Road”, the number of properties with a 1.33% or greater annual risk of flood is 234.

  • Hence the channel only accounts for 54 of the 946 residential properties. Expressed as a percentage this is 5.7% (i.e. 54/946)

  • N.B. If you look at residential and non-residential properties combined, then the channel accounts for 81 (7.5% ) of the 1077 properties which have their risk reduced to 1.33% or less.  

  • However, one of the EA’s key objectives is to reduce (on the opening of the scheme) the annual risk of flooding to 1% or less for over a thousand properties.   Our analyst thinks this is one of the reasons for the channel, because without it they can’t get to those magic numbers.

  • If you use their 1% measure as the Oxford Flood Alliance does for a in 1 in a 100 flood event, then the channel accounts for 157 (i.e. 16.5%) of 952 residential properties with a 1% or less annual risk of flooding. 

  • For all properties the channel accounts for 216 (19.9%) the 1085%% properties with a 1% or less annual risk of flooding. 

  • So you can see it makes a difference on numbers depending on the level of flood risk one is prepared to accept.  

These calculations assume 1.33% annual risk of flooding to be a reasonable one.  Bear in mind that flooding has been a known risk in Oxford for many years.  Most of the “at risk” properties are and have been acquired or occupied with this knowledge. Therefore, whilst there will be some marginal increased improvement as a result of the scheme, is it reasonable to expect all of the risk to be removed?  Especially where each increment of risk reduction incurs progressively higher financial, environmental, and social cost?

There are some additional factors that the EA figures do not take into account. 

These additional marginal  gains of the channel can be nullified if there is increased development north of Oxford. Also the Schemes efficacy will reduce over time due to climate change and only works if maintained properly over the life of the scheme. The scheme is conceived as stand alone and since most of Oxford's flood waters come from upstream, the risks would be markedly reduced if there was a whole catchment solution. 

The 1% AEP (annual excellence probablitily) in a +30% climate change scenario expected in the 2080's is not assessed as this exceeds the design standard for the scheme and all scenarios would show extensive flooding across the area. 

Some analysis suggests that a 1 in 100 year flood event could become 1 in 12 years. 

If this is correct then, a whole re-design and re-think is necessary.

This also means the EA cannot really claim that OFAS is guaranteed for 100 years if projections aren't robust beyond 60 years. 

 

Does the Channel Make Economic Sense?

The short answer is not much. The ‘incremental value’ (iBCR) of a scheme must be above 1 to be worth building. In economic terms, not having a channel (iBCR) makes much more sense than having one and having no channel through Hinksey Meadow makes as much sense as the proposed scheme. This assumes that the proposed scheme costs ‘only’ £122M (previous assessments have put it at £154 million, the difference having been taken on by National Rail to construct the culverts at Kennington Bridge). But there has been little adjustment for increased construction costs which have increased markedly in the last three years.
It is also worth bearing in mind that splitting the scheme into its 'Elements' and doing a cost-benefit analysis on each element could indicate that the channel is not value for money.  The channel generates just under 5% of the benefits for just over a quarter of the cost of the scheme.

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Has The Environment Agency only budgeted maintenance for 10 -15 years? And how would this undermine the scheme?

OFAS claims that costs, including maintenance for 100 years, are costed and form part of the overall economic analysis, and specific funding sources have been identified for the first 10 years. No construction project is required to specify exactly where maintenance costs will be met from fifty or a hundred years from now. That’s impossible. Any alternative proposal would face the same issue. 

This last point is true: and it’s one reason why the claim from the EA that this is a flood scheme for 100 years is so disingenuous.  

By the EA’s own admission the scheme will reduce in effectiveness over time and needs a whole catchment solution.  But whole catchment solutions, originally dismissed in the twentieth-century planning of the scheme, will not be addressed by the EA until 2028 or 2070 (different time frames have been given on different occasions). 

The EA has also lost 2/3rds of its funding, which is why it chases big schemes and has no money for investigations of “minor” sewage outfalls (only 5,082 last year from Thames Water). So, whether it will be able to maintain control of the invasive species such as Himalayan balsam (which are more likely to colonise disturbed earth), is not clear.

For a  proportion of the scheme, stewardship of flood defences reverts to private landowners and Guardian investigations have shown that the majority aren’t maintained for lack of funding and expertise.   https://www.theguardian.com/environment/2021/oct/31/revealed-a-third-of-england-vital-flood-defences-are-in-private-hands

Big channels were a twentieth-century solution in vogue at the EA before the gravity of climate crisis was fully realised.  Now, and especially in the light of the recent UN Code Red for Humanity warning and the International Climate Crisis Protocols report no. 3 (reporting that carbon emissions must peak in 2025 or catastrophic 3 degree warming will be unavoidable) the true value of flood plains is better understood.    Far less destructive measures, involving  whole catchment solutions, regenerative farming and land management and the retention of the extraordinary power of floodplain meadows to hold water and sequester carbon, are required.  The EA scheme is irreversible: if the hard-to-predict knock-on effects of climate catastrophe reveal further problems with the channel than those already analysed by independent experts, there is no way back to the irreplaceable floodplain meadows.  

Conclusion: it is true that maintenance has only been budgeted for 15 years and the inability to guarantee core funding for a critical part of the scheme greatly imperils it’s effectiveness. The current situation for the EA securing ongoing funding for maintenance is not hopeful. 

 

Does Construction mean 114 HGV vehicle movements a day on and off the A34 for 3-5 years?

OFAS say that construction of the channel is expected to take 3 years. Movement of soil from the site will take place mainly in a 15-month period spread over two summers. The EA is proposing to bring forward a separate planning application to use rail to move a significant amounts of material which will substantially reduce road use.

Calculations of the movements off-site have varied throughout the scheme’s life. The claim that a rail link is being considered was made in the previous application of 2018, and its status is not guaranteed in the current scheme (if it involves a separate, future planning application, its relation to the costing of the scheme, its timing, and the maintenance questions remains opaque). Movements of heavy lorries will continue throughout the construction period within the scheme’s area.  

The high number of maintenance roads (which will also have to be constructed) is telling. OFAS will inevitably cause a huge increase in traffic movements in an already congested part of the city. South Hinksey will become a building compound for the life of the project.

The excavation of 455,000 cubic metres of soil and gravel, the felling of 2,000+ trees and miles of hedgerow will mean:

  • 240 HGV movements a day on the A34

  • 40 mph speed limit on sections of the A34 

  • massive queues at Hinksey Hill

All of this pollution and carbon release must be factored in to assess the true carbon cost of the project.

 

Will construction result in a big increase in carbon emissions?

The ES Non-technical summary for the scheme says: The whole life carbon dioxide emissions over the project life are estimated at 19,558 tonnes and the operational carbon is 4.65% of this (i.e. 909 tonnes) based on the proposed maintenance regime. To put this into context, a 2019 Oxford City Council report stated that carbon dioxide emissions from the city in 2017-2018 were 718,362 tonnes per year. The emissions due to the Scheme including operation for 100 years would be equivalent to the direct emissions from the city for less than 10 days. However this assessment only measures one element of the true carbon cost of the project. 

A great deal is left out here. The operational carbon of the scheme is one issue, the construction carbon is another and the loss of the carbon sequestration of ancient flood meadows and mature trees, hedgerows and grasslands is another. 

There is ongoing research into the carbon storage capacity of meadows and soil. The Open University’s Floodplain Meadow Alliance, and the FMA researches the carbon holding properties of flood meadows.  In the UK 95% of sequestered carbon is held in the soil: digging up soil always releases carbon into the atmosphere.

Species-rich flood meadows, where carbon has been held for centuries, hold the most carbon after peat, as the FMA research has shown.  The EA plans to dig up 700,000 tons of soil from the floodplain meadows for its channel, yet offers no costing of these emissions.   

Conclusion: The EA and OFA are only counting carbon cost in a limited scenario that doesn’t represent the true carbon cost. Failure to take the full carbon cost into account vastly underestimates the full carbon cost. The soil disturbance and the displacement of gravel and soil, the loss of trees and hedgerows  will have a huge carbon cost. 

 

Will OFAS improve the landscape and 'enhance biodiversity' as the EA claims?

The most contentious claim and the one with most obvious consequences for residents is that the EA is improving the landscape and bringing ‘enhanced bio-diversity’.

Not only will access to the scheme’s area be compromised for 3-5 years, but most of Seacourt Nature Park will be permanently lost, as will Kennington Copse. 

There is no mention of the overall loss of thousands of trees, and the loss of trees’ capacity for water retention during floods. 

Not only MG4a grassland will be lost but so will the willows on the east side of Seacourt Stream, facing North Hinksey Lane. Loss of about one-third of the willows on Willow Walk, not replaced (Landscape and Habitat Management Plan Sheet 1 of 7).  Crack willows take up to 45 years to reach maturity and properly maintained can host up to 450 different species of insects, birds, small mammals etc.  Each lost tree is an eco-system in its own right.  Planting young trees cannot replace mature trees for decades (the EA now admits that its drawings of its new landscapes only represent the scheme many years on). 

Mitigation strategies are not as good as they sound!

Under the Environment Act 2021 the scheme must provide at least 10% biodiversity net gain. But despite the alleged environment-friendly nature of the scheme, it only provides the net gain if: 

•           Approx. 9.2ha of wet woodland is created off-site 

•           4-5km of hedges are planted off-site 

•           Approx. 730m of ditches are provided off-site (Environmental Statement App. S Biodiversity Metric, pp. 5-7). 

See: https://wickedleeks.riverford.co.uk/news/climate-change-net-zero-biodiversity/soil-carbon-and-biodiversity-credits-solution-or-scam

Replacing an ancient floodplain with a new wetland ( a much easier habitat to create) is not a net gain. We have lost 95% of meadows since WW2.  Maintaining wetland also poses large challenges. If not properly maintained it will silt up, diminishing the channel's efficacy even more. 

This landscape cannot be replaced in this iconic location. 

We await more detailed analysis of the Biodiversity Net Gain. The previous withdrawn application was found to  contain serious flaws in its calculations when assessed by outside experts. 

The first time round, the EA calculated the increase in biodiversity at  plus 40 units. Both Dr Tim King and the The Buckingham, Berkshire and Oxfordshire Wildlife Trust (BBOWT) independently calculated it and found that the true figure was minus 140 units, in view of the environmental devastation that it  would cause.

 

Is the channel an essential part of the scheme and there will be no flood alleviation measures without it? 

Sometimes the impression is created that we have to accept the channel or we jeopardise having no flood alleviation measures at all. 
However, 85% of the measures can be introduced and aren't dependent on the channel. The relief of the pinch points at the A43 bridge for example will go ahead and are not tied to the channel. Neither are the bunds and embankments. There is a strong argument for an incremental approach and a "maintain and monitor" strategy. If after implementing 
The Environment Agency is a statutory body and one of their objectives is flood relief. They also have to balance care for the environment and responding to climate change. They would be failing in their duties if they don't work to develop a scheme that balances these key objectives and is acceptable to

 

Do Your Part

THERE 'S STILL TIME TO RESPOND! SAY CLEARLY WHETHER YOU OBJECT OR SUPPORT. 

SEND YOUR COMMENTS DIRECT TO: 

Matthew.Case@Oxfordshire.gov.uk

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Respond to the Consultation

Deadline 9 May!

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Sign the Petition to Save Hinksey Meadows!

Ask Michael Gove for a Public Inquiry

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Check out our Take Action Page for more links

More information and resources

 

FAQ - The Importance of Debate and Diverse Views

How to evaluate the evidence and why we need constant scrutiny

The Oxford Flood and Environment Group was set up to provide independent advice and analysis on the Oxford Flood Alleviation Scheme. We believe that open debate is the best way to establish trust in institutions in all levels of society.

The Oxford Flood Alliance (OFA) who are partners in the scheme has responded to some of the criticisms and assessments of the Oxford Flood Alleviation Scheme by independent experts. While we don’t doubt their sincerity and commitment and the work they have done in the past, it’s important to understand the context of their statements.

It's often assumed that the Oxford Flood Alliance is an independent body representing residents and conveying their concerns to the Environment Agency. But Oxford Flood Alliance is not an independent community organisation but a partner in the Oxford Flood Alleviation Scheme and therefore has limited critical distance. 

OFA declined the invitation to attend the public meeting of 19th Nov 2021 to gather more information and independent analyses of the EA’s scheme. This was because it “is a member of the Sponsoring Group for [the EA’s scheme] and as such does not have a separate opinion on the scheme.”  The Environment Agency also lists OFA as one of the scheme’s partners. 

     So OFA didn’t engage with residents’ concerns and independent analyses on that occasion, despite its apparent remit to provide a voice to residents and convey this to the EA. We believe that ongoing citizen involvement in the development of large infrastructure projects is critical in improving their design, cost and effectiveness, particularly when these schemes may not be as effective as purported.

The EA claims to have undertaken full consultation, and OFA seems to feel that residents shouldn’t still have questions and anxieties about the scheme but should "trust the EA". 

This is even though knowledge on flood management is changing all the time and that key elements of the scheme, especially the channel and the EA’ s claims about biodiversity have been questioned by experts from the scheme’s first version onwards. The public meeting convened in November 2021 was organised to provide up to date and leading-edge input from a range of experts and encourage residents to review and take account of these in their consideration of the proposed scheme. The EA were invited to provide a speaker and attend but declined to do so. 

The meeting had an open-ended agenda and a questioning perspective on the scheme. It was organised to raise awareness about the proposed design, its impact and the robustness of the assumptions in the modelling.  The fact that 100 locals turned up, and many more accessed the information online and continue to do so, is an indication that OFA may not be filling its purported role or viewed as the only necessary source of information by engaged citizens.

There have been issues with the manner of consultation. The current application became publicly available on 7th April 2022 and offers a consultation period for public comment till 9th May: four weeks and four days over the Easter and school holidays. The application has an 88-page summary outline and over 300 documents. The Environmental Report alone is over 300 pages.  The timing, short period and presentation of immense amounts of data render the process challenging to say the least. The time pressure runs the risk of this looking like a consultation in name only. That is unless you think ‘trusting the EA’ is the only role of a local citizen.

​There has also been limited communication about the planning application and the deadline. Did you get a leaflet through your door as an affected resident to say the scheme had gone in? Have you seen any posters informing people about the scheme? Hinksey and Osney Environment Group has reported that they have only seen two in difficult to access locations.  Would you  have known about it before the consultation period expires if you weren’t signed up to OFA? Given the magnitude of the scheme there is a strong argument that affected residents should have been sent a letter or received a leaflet particularly as the consultation period has run over Easter and bank holidays. 


We believe that open, transparent information AND DEBATE is the foundation of an effective local democracy whatever the complexity of the issues.

So, in the interest of making informed decisions, below is a list of Frequently Asked Questions and additional information to what the Oxford Flood Alliance has labelled ‘myths’.

The Need for Questioning and Scrutiny

The Oxford Flood Alliance has a close working partnership built up over many years and grounded in personal relationships. They feel we should trust the Environment Agency on this basis. However, while we don't doubt there are many individuals within the organisation who work with integrity and commitment, there is ample evidence reported in the national press of institutional and organisational pressures on the Environment Agency.

Below are links to reports in The Guardian that outline a culture where whistle-blowers are silenced.
https://www.theguardian.com/environment/2022/jan/29/it-is-desperate-how-environment-agency-staff-were-silenced-as-pollution-worsened

https://www.theguardian.com/environment/2022/jan/20/environment-agency-cuts-staff-blow-whistle

This article reports on how the EA has downgraded reports on pollution including waste dumping and sewage spillage. It says that the EA has lost so much of its funding, it is not always able to carry out its routine monitoring and maintenance nor prosecute offenders.

https://www.theguardian.com/environment/2022/mar/02/environment-agency-england-downgrading-prosecutions-serious-pollution-leaked-report

Fish Legal, an organisation defending anglers against polluters, has initiated several legal actions against the Environment Agency for failure to monitor pollution in rivers. 

https://fishlegal.net/2021/10/06/environment-agency-climb-down-after-fish-legal-pressure/

https://fishlegal.net/2022/03/01/fish-legal-begins-legal-action-against-environment-agency/

Another issue is that the Oxford Flood Alleviation Scheme is comprised of a consortium who may all have different agendas. These include:

  • Environment Agency

  • Oxfordshire County Council

  • Oxford City Council

  • Vale of White Horse District Council

  • Thames Water

  • Thames Regional Flood and Coastal Committee

  • Oxford Flood Alliance

  • Oxfordshire Local Enterprise Partnership

  • University of Oxford

  • National Highways

​These bodies have different objectives and interests. For example, Oxford City Council, Oxford Local Enterprise Partnership and the University of Oxford are particularly interested in developing Osney Mead Industrial Estate. Sometimes the agendas of these organisations are at odds. The Oxford Flood Alliance has been critical of the extension of the Seacourt Park and Ride on Botley Rd by the City Council. However, despite their concerns about the extension leading to further flooding problems, the Council proceeded to build the extension. This has flooded on several occasions and is currently not fully operational.

See:

https://oxfordfloodalliance.org.uk/2021/01/06/seacourt-car-park-safety-concerns/

OFA is the only community organisation in the consortium and describes itself as follows (extract from their website): https://oxfordfloodalliance.org.uk/about/

“How is OFA run?

We have a steering group.  

We have a mailing list, and we hold an Annual Public Meeting.

We work in partnership with flood-managing agencies, and we have recognised a number of particularly helpful individuals as Flood Stars.”

The last public meeting organised by OFA was in 2018 (which according to their minutes had a low attendance). Interestingly, the new ‘flood star’ appointed at that meeting was Colin Cook, A local Labour city councillor.


There has been no public meeting organised by OFA in the last four years and not on the current proposals. Why not? Does the voice of local residents not matter? Or do we simply need to read articles about ‘Trusting the EA’ and have no opportunity to discuss their proposals?

Flooding and hydrology are complex matters, which is why we need ongoing scrutiny and to hold institutions to account. OFA may think it is fulfilling this role as a community-based organisation but this does not preclude other groups and interested citizens from examining the claims and data.

Please see below for a list of questions where the answers are not as straightforward as those who are partners in the scheme would have you believe. We encourage people to seek information across as many sources as possible.