Representation by PD Port Services Limited (PD Port Services Limited)
- Date submitted
- 4 December 2023
- Submitted by
- Members of the public/businesses
Written representation of PD Port Services Limited in Response to the S56 Notice 1. INTRODUCTION 1.1 PD Port Services Limited (“PDPS”) have received the S56 Notice in relation to the development consent application made by Associated British Ports (the “Applicant”) for the Immingham Green Energy Terminal Development Consent Order (the “Project”). 1.2 PDPS own and occupy a site adjacent to the Project boundary, access of which is on Laporte Road. 1.3 PDPS’s site provides extensive warehousing with over 64,000 sqft of bonded covered warehousing and large open storage areas. We offer various services including devanning, reloading and pick and pack for a diverse range of cargo from metals and constructions materials to forest produces, agribulks etc. We are currently handling steel and bulk products and receive and load cargo constantly throughout the day from the Dock and beyond. 1.4 The works proposed to be authorised by the Project for which application has been made would be constructed adjacent to PDPS’s property and the Project’s construction and operation could potentially adversely affect PDPS’s operations. 1.5 As part of the Project, the Applicant seeks temporary access and stopping up as well as a permanent speed limit change on Laporte Road. 1.6 PDPS supports the Applicant’s project in principle but is concerned to ensure that the construction and operation of the proposed works do not adversely affect its operations. PDPS is seeking to work positively with the Applicant which it considers should seek to minimise impacts on surrounding businesses. 2. ISSUES 2.1 PDPS’s concerns with the Application are detailed below. Vehicle Route 2.2 PDPS access the dock by turning left out of the site onto Laporte Road and then right onto the dock. 100% of the inward cargo including containers, bulk tippers and steel up to 28m long use this route. Cargo vehicles often carry weights of 44 tonnes, and special cargo loads can be over and above that. 2.3 The Applicant is proposing a permanent reduction to the speed limit on Laporte Road and a temporary closure of Laporte Road as part of Work No. 4. 2.4 The Applicant’s Environmental Statement Chapter 11: Traffic and Transport states as follows: 2.4.1 There would be some localised highway works to Kings Road, Queens Road and Laporte Road associated with culvert works, utilities connections and protective works and the creation of site entrances. These works would be undertaken using powers included within the draft DCO. Liaison would be undertaken with NELC for all works in the highway. Any road closures (for example for the construction of Work No. 4 on Laporte Road) would be managed and agreed with the Local Highway Authority, with suitable diversion routes being available, e.g. via Kiln Lane. No significant disruption is expected. All construction traffic would be routed via the Strategic Road Network with no construction traffic routed through the town of Immingham. No adverse traffic effects are expected on the town of Immingham. 2.5 Whilst PDPS do not have any objection to the reduced speed limit, any closure of Laporte Road will have a significant impact on PDPS’s operations and will require a 3 mile detour which may encourage customers to find an alternative provider. It is therefore disputed that “No significant disruption” is expected arise from the development. Temporary Access off Laporte Road 2.6 As part of Work No. 9, a temporary construction and laydown area is proposed, including a road access from Laporte Road and the temporary alteration of the layout of the road. The new access (labelled as ‘P’ on Works Plan Sheet 4) is located opposite the entrance to PDPS’s site. 2.7 It is assumed that the temporary access will be in place throughout the construction period for the Project, which is a significant amount of time. PDPS will require comfort that the access will not interfere with their current access. In particular it is unclear what traffic will be generated at this location and how this will be managed so as not to interfere with PDPS’s operations. Proposed Culvert 2.8 As part of Work No. 4, an underground culvert is proposed under Laporte Road. It is unclear from the available documentation what works will take place on the highway to enable those works to be carried out. 2.9 PDPS is concerned with the effect that any such works might have on the strength of Laporte Road; any weight restrictions would be particularly problematic. As previously stated, vehicles accessing the PDPS site can weight in the region of 44 tonnes and occasionally over this in the case of special loads. PDPS require comfort that there will be no weight restrictions imposed on Laporte Road. COMAH status/restrictions 2.10 PDPS understand that the Project will be assigned COMAH status in respect to hazardous substances. 2.11 Although PDPS’s site has not been identified by the Applicant as a receptor in its Environmental Statement Chapter 22: Major Accidents and Disasters, PDPS is concerned that the proposed COMAH status of the site may led to restrictions on the use of its own property (such as types of products we can store, possibly restrictions on future development). 2.12 PDPS will require confirmation that the operation of the Project as COMAH site will not impact on PDPS’s operations or restrict the use of our site. 3. OBJECTION 3.1 For these reasons, PDPS must currently OBJECT to the DCO application.