Advice to Dr Barbara Lees
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- From
- Dr Barbara Lees
- Date advice given
- 18 November 2019
- Enquiry type
Dear Sir/Madam, I understand that you are the Examining Authority for National Infrastructure Planning and as such recommend projects that are submitted to the National Infrastructure Planning in relation to Rail Freight Interchange applications. I am interested to know what factors you take into consideration when arriving at a decision to recommend or not, if there is a specific framework you follow and in particular whether these include local conditions. My questions arise specifically in relation to an application due to be submitted to the Inspectorate in Q4 2019 by db Symmetry for the proposed Hinckley National Railfreight interchange. Do you consider the following factors: Number of existing Railfreight terminals in the immediate vicinity - in this area there are already 3 rail freight terminals within proximity of this site in operation or being constructed, Daventry International Railfreight Terminal , ‘DIRFT’, (18 miles away), Associated British Port Authority already operate freight along this line from Felixstowe which it delivers to its centrally placed Hams Hall Railfreight Terminal, 24 miles from this site, very close to the automotive industry and East Midlands Gateway Railfreight Interchange (28 miles away). There are 3 others which are either in pre- application, decision or pre- examination stage within a 35 mile radius, namely East Midlands Intermodal Park, Northampton Gateway Railfreight Interchange and Rail Central (Strategic Railfreight Interchange). In addition to this the the construction of DIRFT stage 3 approved in 2014 on a brown field site appears to be progressing very slowly which might suggest demand for this facility is not great. I believe, as the law stands, there is no legal requirement for either a minimum amount or any rail freight to actually be processed at these sites which seems a loophole in the plans of this nature. Rail network factors - use of a dual track cross country line carrying passengers from Leicester to Birmingham with a recent proposal to improve and extend these services to Coventry and Nottingham- can this reliably also service a further Railfreight terminal in addition to the terminals at Hams Hall, East Midlands and DIRFT? There is a level crossing on the line at Narborough which already causes traffic congestion in the area. Warehouses - why is it necessary to have warehouses if this is simply a railfreight terminal - surely goods should be delivered directly to the end point or as close as is possible. They are not planning to start building the railfreight terminal for 4-5 years and then only with a limited train service. Will you examine the need for an area of 327.59 acres of farmland to be covered by 14 warehouses providing 5077 car parking and 1013 lorry parking spaces resulting in increased traffic in an area where there are empty warehouses advertised by junction 20 and 21 of the M1, at Magna Park and junction 2 of the M6. The new Coventry and Warwickshire Gateway Park, which is currently being developed, together with Hams Hall Ralfreight Terminal are in optimal locations to service the Midlands automotive industry directly and indeed formed part of the planning application for the former. As the development consists largely of warehouses one would normally expect local people to have some input via the normal planning application route. Both Blaby District and Hinckley and Bosworth Borough Councils and our local MP’s Mr Alberto Costa and Mr David Tredinnick have all spoken out against this development in this locarion in addition to the large number of local people and others who visit Burbage Common and oppose this development. Location - on over 400 acres of agricultural farmland crossed by footpaths, bridleways and a public road all giving access to the immediately adjacent Burbage Common and wood - a SSSI and ancient woodland. This farmland also provides a habitat for many ground nesting birds such as skylarks, pheasants, lapwings and partridge, tree sparrows, buzzards and other bird, insect and animal species inhabit the dense hedgerows and old oak and ash trees growing there. These green spaces containing a number of small ponds provide much needed wildlife corridors to support animals such as brown hares, badgers, foxes, bats, insects, amphibians, reptiles and other small mammals as well as an area where people can walk and ride their horses - the benefits of which to both physical and mental wellbeing are well known. The loss of this green field space and footpaths to warehousing and proposed replacement access paths to the Common through an industrial site will expose people and animals to constant 24 hour a day noise, air and light pollution. This 24 hour exposure has been shown to disrupt Circadian rhythms causing physiological changes and has been shown to be detrimental to both people and wildlife. Employment- the levels of unemployment in Blaby and Hinckley and Bosworth are both below the national average at 3.8% according to Nomis so presumably people will have to travel by car to work, causing further congestion and pollution. On one recruitment site alone there are 225 warehouse jobs advertised within 10 miles of Hinckley today. There is also a growing trend for automation of warehouses which will eventually remove any temporary increase in employment that maybe produced. In conclusion I sincerely hope that if this plan is submitted to you that the local situation in relation to the above factors and the long term future health and well-being of both people and wildlife is seriously considered before Burbage Common and the surrounding environment is damaged irrevocably. The bypassing of the local authorities and local population by this submission to the Planning Inspectorate through the thinly disguised application for a rail freight terminal is regrettable and seems a loophole for more warehouse development in an inappropriate place. Yours Sincerely Dr Barbara Lees
Advice given
Dr Lees, Thank you for your email. Examining Authorities are appointed after the submission of an application, if the application is accepted for examination. As you note in your letter the application for Hinckley National Rail Freight Interchange has not yet been submitted to the Planning Inspectorate. Section 104 of the Planning Act 2008 indicates what factors the Secretary of State must have regard to in deciding applications where a national policy statement has effect. Until the applications are submitted, your first point of contact should be the developer. I would therefore encourage you to contact DB Symmetry (Hinckley) Limited directly. It is important that the developer is made aware of your comments at the pre-application stage of the process, to enable them to consider these points before finalising their proposals and submitting the applications to the Planning Inspectorate. If you would like more information about the Planning Act 2008 process, please see “Advice Note Eight: Overview of the nationally significant infrastructure planning process for members of the public and others” which can be found along with other advice notes, here: https://infrastructure.planninginspectorate.gov.uk/legislation-and-advice/advice-notes/ I hope you find this information to be useful. Yours faithfully, Liam