Representation by Prologis UK Limited (Prologis UK Limited)
- Date submitted
- 23 June 2023
- Submitted by
- Members of the public/businesses
We hereby submit a Relevant Representation on behalf of Prologis UK Limited (“Prologis”; “our client”) with respect to the Application for a Development Consent Order (“DCO”) in connection with the proposed expansion of London Luton Airport (hereafter: “the Proposed DCO”, ref. TR020001) and to register as an Interested Party. Prologis and its interest in the Proposed DCO It is considered that it will be helpful to provide some background information on Prologis and their interest in the Proposed DCO. As the leading global real estate provider of industrial and logistics buildings, Prologis understands the benefits that major transport infrastructure projects – such as the Proposed DCO – can bring to global supply chains and local communities alike. Prologis is therefore supportive of the principle of the application, and hopeful that it will be approved. However, our client, Prologis, has a responsibility to protect the assets that it owns and manages on behalf of its current and future tenants, especially those whose operations hinge on the efficient movement and delivery of goods and therefore require excellent and unimpeded connectivity and accessibility to the strategic transport network, (as secured under the hybrid permission referred to below). Prologis is the landowner of Prologis Park Luton, LU1 3HJ (“the site”). In May 2023, Luton Borough Council (“Luton BC”) granted hybrid planning permission (ref. 22/01334/HYBEIA, “the Permission”) for the comprehensive, employment-led redevelopment of the site to provide up to 34,250 sqm of modern industrial and logistics floorspace, an on-site training facility (“the Hub”), and all associated infrastructure works, access arrangements, internal road network, parking, and hard and soft landscaping. The Permission is anticipated to generate up to 540 direct on-site employment opportunities once fully operational. Our client is in the process of dealing with the pre-commencement conditions and once these issues are discharged intends to commence with the construction works of the first development phase in 2024. It is important to note that the principal access to the site is located off Windmill Road, which connects to Kimpton Road via a three-arm mini-roundabout adjacent to the north-east corner of the site. As part of a wider package of off-site highways interventions required to accommodate the expanding airport capacity, the Proposed DCO seeks to convert the existing mini-roundabout into a three-arm signalised junction (identified as ‘Work No. 6(e)a’ of the Proposed DCO). The Proposed DCO, any associated changes to the traffic flow (along Windmill Road and surrounding road network) resulting from the proposed works, and required works to the Windmill Road/Kimpton Road and the mini roundabout at Osbourne Road all have the potential to (significantly) affect the day-to-day operations of Prologis’ future tenants. The fact that the site benefits from hybrid planning permission means that the scheme is a committed development and will need to be included as part of the DCO assessment to be undertaken. Our client therefore needs to ensure that the assessment of the highways and transport impacts of the Proposed DCO as well as the detailed highway interventions, and with this any mitigation measures proposed, are thoroughly planned, robust and do not lead to adverse impacts on the road network, potentially affecting both the delivery of the Permission and the site’s future operation. As such, our client’s advisors have reviewed the relevant documentation of the Proposed DCO and set out some initial, high-level issues, concerns and recommendations below (which may be expanded upon as part of any future Written Representations). Outline of Key (Material) Issues, Concerns & Recommendations In accordance with section 104(2) of the Planning Act 2008 (“the Act”), the Secretary of State (“SoS”) is required to have regard to any relevant National Policy Statement (“NPS”) where it has effect, amongst other matters, when deciding whether or not to grant a DCO. Whilst it is acknowledged that the Airports National Policy Statement (“ANPS”) (2018) only has ‘effect’ in relation to the delivery of additional airport capacity at Heathrow Airport, Paragraph 1.41 of the ANPS makes clear that the contents of the ANPS will be both an important and relevant consideration under section 105 of the Act in the determination of an application for development consent for any other airport development, particularly where it relates to London or the South East of England. Paragraph 5.5 of the ANPS states that “the Government’s objective for surface access is to ensure that access to the airport by road, rail and public transport is high quality, efficient and reliable for passengers, freight operators and airport workers who use transport on a daily basis”. It is therefore of utmost importance for the Applicant (and Examining Authority) to ensure that passengers, airport workers, and freight operators – a category highly likely to include future tenants of the site – or indeed other future road users are fully protected against any potentially adverse impacts resulting from the Proposed DCO. Having reviewed the Proposed DCO and its supporting documents, our client wishes to reiterate that it is fully supportive of the principle of the proposed development, but would like to raise the following key issues, concerns and recommendations with regards to potential transport impacts on its asset and/or other Interested Parties with an interest/landholding in the area: 1. Walking and cycling improvement proposals must properly connect with those on the ground and serve the areas of need, such as designated employment sites including the site; 2. The proposed works to Windmill Road/Kimpton Road Phase 1 (Drawing No. LLADCO-3C-ARP-SFA-HWM-DR-CE-006/P01) shows a signal arrangement at Kimpton Road and a mini roundabout at Osborne Road. Our client’s transport consultant, WSP, would comment thus: • Kimpton Road is close to the main access serving the site (an area currently occupied by BWI Group) and to manage the anticipated traffic flows in Phases 1 and 2 of the Permission - while mitigating any new issues of blocking back as a result of the signals at red - it is recommended that the Designer/Applicant consider the implementation of signals at the existing access into the site combined with the adjacent signals to form a single coordinated junction; • Whilst it is understood that the signal design is at a preliminary stage, the locating of offside primary and secondary signals will need further consideration; and • The proposed northern kerb realignments at the Osborne Road mini roundabout do not appear to achieve anything in terms of utility at the junction. It is understood that the model used will probably report higher capacity as a result of the very slight realignment, but the reality is likely to be somewhat different and lead to nothing more than inconvenience and disruption to our client, their future tenants and the public while construction takes place. Moreover, these apparently unnecessary works give rise to a negative environmental impact in terms of wasted materials and carbon spend. We would wish to understand more about these works before giving our support to this element of the Proposed DCO. Conclusion As set out above, although supportive of the principle of the Proposed DCO, our client seeks to ensure that all of its transport-related impacts are thoroughly assessed and robustly mitigated against. At present, it is considered that this element of the Proposed DCO may require a further review and/or coordination with surrounding landowners and Local Highway Authority, and Prologis therefore urges the Examining Authority to consider the content of this Relevant Representation at Examination stage. Our client is further willing to arrange direct discussions with those parties to ensure the proposed detailed highway interventions are comprehensively planned and implemented. A full Written Representation may be formally submitted when the Examination commences. Please ensure that our client/we are contacted on any further updates on the Proposed DCO.