Representation by Frank Burgess
- Date submitted
- 13 June 2023
- Submitted by
- Members of the public/businesses
5th February 2022.Rev B 18th Feb 2022 Rev C 4th March 2023 Rev D 3rd June 2023Rev E 13/6/23 [Redacted] Summary. This proposal, to install a National Rail Freight Interchange, near J2 of the M69 near Hinckley appears to contain very little rail freight interchange. From the figures provided by Tritax only between 5% and 25% of the freight interchange will have any rail content, and my knowledge of the rail industry suggests this will be closer to 5%. The remaining 75% to 95% is unspecified, but would appear to be possibly a large distributing, warehousing and or manufacturing hub. It is very disturbing that no information is provided on need or details. To provide 8,000 jobs in the area plus a similar number of indirect jobs would appear, on the surface, to be positive, but given the current population and local rates of unemployment, it is unclear where these employees are to come from. If local, this would involve considerable extra housing plus associated infrastructure, which would both destroy Sapcote and Stoney Stanton as villages, and would change the character of the whole Hinckley area in an undemocratic way. Transport would involve adding a Western entrance at J2 of the M69 which would cause considerable extra traffic through Sapcote, which would be against the condition of the original build approval of the M69. It appears that despite original suggestions any Sapcote bypass is not even to be considered, although Tritax seem unwilling to discuss this. The B4469 to Hinckley would also have considerable increase in traffic, and we need only look back at the road closures when the Leicester to Nuneaton rail line was containerised causing bridge closures over several months to see some of the problems that would occur. To approve this proposed development, with such missing, and apparently misleading, information would be like signing a blank cheque and the results could be disastrous. As a minimum this should be resent back for further information, and the developers should provide full, accurate and verifiable details on all aspects, and not just a few favourable items for their benefits. Detailed Comments I have several comments, suggestions and objections to the proposed interchange listed below. I have grouped these as far as possible in the sequence of the feedback form as suggested by Tritax, and so not listed these in order of importance as everyone has differing priorities or logical flow. 1. I agree with the principle of transferring road traffic both to rail traffic, and also believe there is still a valid case for much more canal traffic. However this proposal when examined in detail transfers only a small minority of traffic, (5 to 25% -using calculation data provided at the consultation, more details in annex A ) using the hub off the road and onto rail, or from road to rail, and taking into account commuter traffic using the site even less, so even the title is very misleading. This hub will have a minimal help in this and the title of the project “Hinckley National Rail Freight Interchange” covers only a small part of the proposed activities and must have given a false impression to many local residents. 2. Transferring traffic to rail if done properly would be beneficial to climate change, as the coefficient of friction over well designed and maintained rail is about 0.25% as opposed to 2.24% for well designed and maintained road of 2.2% whilst near stationary. However, when in motion the gap is considerably reduced, and with extra interchanges will be virtually nullified. Placing the hub in a countryside environment away from major industrial sites will involve more road vehicle miles and pollution which will decrease any advantages even further as discussed further in section 3. 3. The location is very poor for several reasons: i) England is the onre of the few major countries, excluding City States, with a population density in excess of one thousand per square mile. With this, we are incapable of being self-sufficient in food production if required. I am of an age when, unfortunately, I have lived through food rationing, and it is not a situation I would like to repeat. We therefore need to avoid the use of greenfield land for purposes which could not easily be transferred to food production. This proposal would place many acres under concrete and tarmac and permanently prevent it from being used food production. ii) If such a hub is required, it should be as close to major industries as possible to reduce the road miles. Within the west midlands there are many brownfield sites which had both rail access and have, or could be, modified to have suitable rail access. These areas have large populations who require jobs with less commuting. With the number of personnel required to staff this hub appears to be considerably in excess of the available potential local workforce availability. In addition, with some 8,000 jobs, plus a similar number of ancillary jobs, the majority of which are unlikely to be filled by local residents will cause substantial communing (this is likely to be entirely by road, as no on-site passenger rail station is apparently planned). A look at the map of central England shows that it will not take much infilling, such as this to create one huge urban sprawl from Melton Mowbray/Grantham in the East to Shrewsbury in the West. This would be larger than the Greater London area, and to have it imposed on the population by stealth in undemocratic, non- environmentally friendly, and would cause huge social problems. The road/motorway network in the area is unsuited to this amount and type of increase in traffic. iii) In the local area, we currently have Hinckley, as a medium size town, with several largish villages on or close to the boarder, such as Burbage and Earl Shilton, with close to ten smaller villages within about 8km. I could go into the history or development, but with the development of this hub, and the related population, plus the current vogue for granting large developments, this is further evidence or making the area into an urban sprawl. Surely residents should have a major say in what sort of environment they live and not have that changed by unnecessary development. Infrastructure and services such as medical facilities, school, drainage capabilities would also need to be addressed, with these already being fully stretched if not overstretched. iv) The rail network does not seem to have spare capability to support the hub in a major way. Several years ago, Croft Quarry submitted a proposal to use the Leicester/Nuneaton line to use for removing most of the stones, and this was rejected due to insufficient capacity on the line. I am aware of subsequent signalling improvements on the line, but also with the containerisation upgrades and the extra traffic caused already by this, I have serious doubts whether the 16 trains per day suggested could be catered for, and even with the minimum of 4 suggested would I think would cause problems. This would be made worse by the length and speed of the trains involved, and by trains coming from the Hinckley direction of leaving in the Leicester direction having to cross the track. See also annex A. 4. The proposals are for up to 850,000m2 of floorspace etc. and the potential uses of such has not been very well defined. This raises several queries: - i) From the limited information I found available it appears there are:-nine large buildings; several smaller buildings; space for around 6,000 cars for workers and visitors (no obvious cycle racks despite recent government initiatives to promote cycling); an H.G.V. fuelling point, and a number of rail sidings. It is interesting that with the coming of electric vehicles as the “norm” within the next decade that car/L.G.V. charging points are not apparently being considered. ii) There is no obvious H.G.V./trailer or container parking; or cranes for transfer of containers between trucks, trains or storage. iii) It also appears that there are to be 8,000 workers, probably about a quarter of whom will be office based. Where these offices will be, unless they are integral in the large buildings. There is also no mention of working from home or how this would affect the proposal. iv) Infrastructure for such an operation, such as catering does not seem to be mentioned. v) I am unable to work out the primary uses of the large buildings. Perhaps someone can enlighten me:- Is it for some or all of the following: -a) To store containers in, probably for security, or possibly for weather reasons, although the difficulties in moving these can only be imagined; b) To unload and sort out containers into individual consignments such as the DPD depot off the A5 near Hinckley. If it is anything even remotely similar, this should have been obvious at the consultation; c) To rent out as general office and or warehouse space; d) A mini-nuclear power station, which would be a suitable local site to help power electric locomotives, or charge vehicles, as well as power plant for the grid; e) As manufacturing site(s); or f) Something else – in which case what? vi) Without considerably more information I must object to taking this green field site out of the current use. 5. The Environmental Information Report seems to need several footpaths and bridlepaths to be moved or deleted, although information is not easy to obtain, surely by this stage of the proposal accurate information should be present rather that vague statements that can be altered to suit factions at their wish. To concrete over such large areas has to be negative, although I was pleased to see that solar panels were proposed. See also sections 3 ii) and 3 iii). I have several comments, suggestions and observations to the road improvements proposed:- i) When the M69 was approved, one condition was that J2 should only be accessible to and the Leicester (M1) direction. This was to protect the residents of Sapcote from an unacceptable level of traffic, noise and pollution, and the residents believed this to be set in stone. When this HNRFI proposal first came out, a Sapcote by-pass was suggested, but this now seems to have been abandoned. It feels as if the residents of Sapcote have been abandoned, and that with a very few cosmetic changes, which may even make things worse, that we should lie down and accept this. When the original condition was given, this must be honoured, or the rule of law and democracy is a complete and utter farce, and it is things such as this which can cause revolutions. The Sapcote bypass must be present and complete before and permission for such a development can be even considered. The “patches” proposed such as speed limits and extra constraints are not worth considering. There are already chicanes in the village, and the visibility in the centre prevent any extra “Zebra” crossings. When a weight limit to be rigidly enforced was suggested this was not taken seriously by the Tritax personnel at the meeting despite the considerable potential increase of H.G.V. traffic to the car auctions at Bruntingthorpe, and to the industrial sites near Broughton Astley. This is in addition to the extra traffic on the B4469 which would be caused by traffic from Broughton Astley, Cosby etc. using Sapote as a rat run to the M69 going west. We would also have the extra traffic from 8,000 employees, a considerable number of who would travel through Sapcote, and given the amount of shift work likely much of this would result in night time noise. This extra would significantly increase both congestion and pollution. A further issue is that in Sapcote we already have a problem with the bollards in the centre being knocked down by H.G.V.s on a regular basis, and although this proposal may try to discourage H.G.V. drivers using the B4469 through Sapcote we have severe doubts how successful this would be and how and if it would even be enforced. More recently the increase of length limit of H.G.V.s would make this situation even worse, and result in significant damage to infrastructure and property in the centre of Sapcote. Ii) It appears that compulsory purchase orders have been made on several properties in the centre of Sapcote, including some modern properties. Factual information on why these were issued, and whether the proposal is involved in these orders does not seem to be forthcoming which I find disturbing. What absolute assurances have we that the centre of the village is not to be altered by stealth? iii) am pleased that my comment on a new route to the A47 seems to have been adopted, although how much of this is due to me, probably very little! I would however suggest this be dual carriageway right through to the A47, as there is likely to be considerable truck traffic to industrial areas around Desford, Peckleton, the New Parks area of Leicester, etc. 6. Highway Issues. i) The M1/M69 junction is already overloaded and dangerous. To add a thousand or considerably more H.G.V.s as well as many L.G.V.s and cars is irresponsible unless and until major changed are in place. These need to include: - The repositioning of the slip road from the M69 to the M1 where lanes merge at the same time as slow uphill traffic enters in a middle lane from Leicester, and with the L.F.E. service exit only 1km. away; and The congestion at the roundabout with a considerable higher number of long H.G.V.s which already block the roundabout on a regular basis, so major alterations to this, or a replacement flyover system. ii) The B4669 road from the M69 roundabout to Hinckley and Burbage is already overloaded, particularly at peak times sometimes to the point of gridlock in the Burbage/Hinckley area. This results in considerable delays and roadside air pollution. With the small number of bridges across the rail line in Hinckley this is difficult to avoid, but to add a large amount of extra traffic, both commuters to and from the site, and some H.G.V. and L.G.V. traffic would result iii) Sapcote bypass already mentioned in 5 i). iv) The traffic projections are based on computer modelling if the information provided at the consultation is correct. The computer part of the modelling is likely to be accurate, but no information has been given on the criteria on which this modelling was based, and whether this modelling is based on absolute facts or whether statistical analysis, has been used, and if so whether this conforms to the statistical and experimental accuracy B.S. and I.S.O. standards. 7. To support a lorry park is no problem, provided it is with the proviso that there is no residential area in the immediate vicinity. Refuelling facilities is obviously an essential requirement. I am not sure what is meant by welfare requirements. Toilets are essential, and a secured compound, as are catering, but it needs to be made clear if this is for H.G.V. staff only; for all staff, or to also include the general public. Other welfare facilities could be for on-site medical facilities, with trained first-aiders, with a possible on-site nurse. Possibly some type of hostel accommodation could be included to discourage breaking of taco rules for safety. I would hope that some de-fib units would be available at well signed positions. 8. The proposed landscaping facilities I suspect are included purely for drainage and to avoid site flooding reasons. They do not appear to improve the overall aspect of the area significantly. 9. Additional Factors: i) The figures given per day are for between 4 and 16 trains, presumably each having up to 50 forty -foot containers which is between 200 and 800 containers per day. On the figures given this is up to ten container trains from Felixstowe, four from Liverpool and two from Southampton, although Immingham appears to have not been mentioned. I would ask for full information from Network Rail, to ensure that the paths for these are available. How this is split between import and export trains is not mentioned. We are currently in a partial shutdown due to Covid, and in an unknown situation with post E.U. world trade. I am asking for a realistic likely future breakdown of arrival/departure point for Felixstowe, which is probably reaching saturation, Immingham, which was been mentioned, Teesside and Tyneside, with the various rail connections and feasibility of these. ii) As this is supposed to be primarily a railhub, although this seems to be very much a minority activity, surely to improve the track, possibly to 3 or 4 track on some or all of the Leicester to Nuneaton line should have been considered. Can any such consideration, if it happened, be made public? iii) In addition to 4,000 H.G.V. movements per day, and the staff commuting, some 2,000 L.G.V. movements were suggested, although no information was given as to what this would be. If this is to be a “white van” site such as D.P.D., then we need information before any formal proposals are published. If this is to be a warehousing or distribution site, for instance for supermarkets, builders merchants, etc., then this need to be made absolutely clear up front. Without such information given in a clear and unambiguous way then no decisions can sensibly be made. iv) Air pollution near the site will be increased both from trucks and locomotives. The prevailing wind is from the west so this increase is likely to be of particular interest to Sapcote and Stomey Stanton. Are figures of such pollution to be made available to the public? v) The time frame and disruption likely to be caused by the construction phase has not been mentioned as far as I can establish. What levels of road closures, extra traffic, noise, etc. are likely to be present? vi) At the consultation, one aspect was the shortage of H.G.V. drivers. This is currently true, but no mention has been made of the availability of freight train drivers (E.W.S.). I believe these are also in short supply, and with training times for freight train drivers longer than those of H.G.V. no advantage in this aspect of transferring from road to rail would result. vii) There are 5 existing RFI sites within 20 miles of the proposed site, Birch Coppice, Hams Hall, East Midlands, Drift, and Prologis Park. In addition, West Midlands, Northants Gateway and the Proposed Intermodal sites are within 30 miles of the proposed site. This will result in the majority of national R.F.I. sites within a small local area. Such sites should consider contingency plans for emergencies, such as natural, economic, political and defence, and a major emergency in any of these could severely affect the supply chain for the whole country. In the Japanese tsunami apart from the economic and health problems, a considerable proportion of world supplies was affected, particularly with the current vague in the manufacturing industry for “Just in time”, for which readily available alternative routes and sources are essential. Whilst we would hope that a tsunami is unlikely in the U.K., then other issues such as related the Covid, international politics, defence, etc. could happen. Surely these sites need to be spread around the country, so that in the event of any area being unavailable for any reason, the load can temporarily spread around other areas. Annex A. The number of trains per day mentioned is between 4 and 16. Each of these is approximately 50 containers of 40 ft, or a larger number of 20 ft containers. This is between 200 and 800 containers. If these are to be then shipped out by truck, with 4000 truck loads per days it means that only between 5% and 20% of the site will be based on rail use (hardly an accurate name for a rail freight interchange). How will the remaining 5% to 95% (or possibly higher if the L.G.V. traffic is considered) of the site be used? Is it likely to be similar to the areas off the A5 near Lutterworth and Rugby/Daventry? Are we to have definitive information on this? F.B.