East Midlands Freeport
Planning Application Ref 22/01339/LDO
Monday 5th September 2022
West Leake Parish Meeting response to 22/01330/LDO by Tom Barton.
The Parish Meeting does not oppose the re-development of the Power Station site but does object to the development of the open Green Belt land south of the A453. It also has grave concerns about certain aspects of the application and would like confirmation that the Parish will be actively involved in the condition setting and monitor of the development. The Parish believes that the Ward member councillors should have the ability to make decisions on the certificates of compliance on the planning conditions and the Borough Council should allow full public consultation on any potentially contentious issues.
The Parish Meeting feel that this application is being “rushed” through the planning process, in order to satisfy the Government Freeport initiative for occupation by Autumn 2026, rather than having detailed consultation on the impact of the scheme. This is the largest potential development the area has ever seen and makes East Midland Gateway (EMG) look small in comparison. EMG took 10 years of planning, a public inquiry and years of consultation with the local communities before it was granted permission.
The Parish Meeting has concerns about the robustness of the information provided within the application. For example, concern has been raised about the figures used in the Transport Assessment and the quality of that assessment. Leicestershire County Council Highways have raised their objection to the scheme based on the figures failing to meet the basic tests of the NPPF. Surely, with the likelihood of the Power Station remaining in use for some considerable time to come then a more detailed analysis of the impacts of the development can be assessed.
The Parish Meeting is also concerned that, in light of recent announcements on the likelihood of the coal fired power station being required to stay open for a few more years, the granting of the LDO may allow for part development of the site and, in particular, the land south of the A453. This land should not be developed as its green open space.
The Parish Meeting has reservations on the Community Involvement in the proposed development. The villages of West Leake and East Leake are “significantly” affected by the proposal and had no exhibitions yet the villages of Thrumpton and Gotham, which do not seem in the application to be “significantly” affected have had Public Exhibitions.
The Visual Impact
The site is less than 2 miles from the centre of the Conservation village of West Leake and less than 1 mile from the parish boundary.
The factory south of the A453 is planned to be up to 40m in height. The only screening to the south of the site is a small belt of existing trees up to 12m high. The highest building at EMG is 30m high. A 40m high building is totally unacceptable. Also, the density of the developed land as a proportion of this site’s total area is unacceptable.
The screening of the site north of the A453 is minimal and should be dramatically increased in the application.
The Environmental Impact
This Green Belt application shows little thought for the environment. For instance, all the buildings should have solar panels on the roof. There should also be systems for retaining and reusing all rainwater falling on the site.
The site south of the A453 is all green open space except for the small areas of the site being currently used for the ash pits. This site provides a huge number of habitat units.
The proposal will lead to over 25 acres of mature woodland being lost and 2.5 miles of hedgerow being destroyed. The small areas for biodiversity proposed are insignificant to the established areas to be built on. Only about 50% of the habitat units being lost are to be redistributed around the site, after development, with the rest being “off-site”. This is unacceptable and the development should have the required 10% bio-diversity net gain on site. This is an opportunity for the Borough to make this site an exemplar in bio-diversity- if they really do want biodiversity. The site is huge and whilst the developer will want to maximise every piece of land for building the Council have an opportunity to show that they are really serious about the environment and make a real contribution by controlling the environmental impact.
The Borough’s own Ecology and Sustainability Officer concludes that the plans within the Environmental impact assessment are broad in character and more detailed reports will be required in the future- who is going to “test” these reports.
This is the biggest concern for West Leake Parish Meeting. The Transport Assessment identifies “significant” increases in traffic to the lanes surrounding West Leake with little or no mitigation. This is totally unacceptable.
The Transport Assessment states that the increases in traffic directly resulting from the development will make Main Street, West Leake “difficult to cross safely” and the adverse traffic impact on Main Street and Dark Lane as being “significant”.
No other roads in the area have this “significant” level of impact- not even the A453,M1,A50,A6 or side roads closer to the site.
The various reports do not make it clear how many people are expected to work on site- this varies from 3000 up to potentially 15,000 creating, potentially, an additional 27,000 vehicle movements per day. This is based on the predicted 80% of workers travelling by car. This is an outrageous amount of car dependency. The plans show parking for 6000 cars and so we are not sure all the figures are accurate and that they should be independently tested.
Furthermore, the documents submitted by ARUP Transport Assessment is based on significantly lower staffing levels. The stated increase in vehicle movements along Dark Lane and Main Street, West Leake and into East Leake estimate at an increase of 30%+ is therefore underestimated and could be at least 3 times these figures. In light of these discrepancies is the Transport Assessment flawed?
There are more children living in West Leake now than ever in the last 50 years. There are numerous places in the village where there are no footpaths at the sides of the roads and where road crossing is frequently required.
The Parish Meeting would like the local authorities to consider the closing of Dark Lane to through traffic. Whilst signposting, speed control measures and gateway schemes can deter and control the speed of traffic, the modern use of sat-navs will mean that vast numbers of traffic will use this lane for access to the development from the south as it will be the shortest route. Already there is traffic using Dark Lane from the A6006 to the A453 in order to have a more direct route rather than using the main roads.
Dark Lane is a narrow country lane and totally unsuitable of taking more volume.
The accident record for the New Kingston Crossroads (Dark Lane/West Leake Lane/Kegworth Road junction) has been totally missed out of the Transport Assessment. It is a dangerous crossroads and whilst some mitigation is mentioned it is minimal considering the volume that will use the junction. Precedent for shutting roads has been set before in the area where there is new development and safety issues. For instance, Rempstone Lane to A6006 south-east of East Leake and Gravelly Hollow cut through from Calverton to the A614.
Dark Lane does not have footpaths at the side of it and is used extensively by horse rider and pedestrians linking into the Midshire Way. Similarly, the West Leake Road to East Leake has no footpaths at the side of it for pedestrians and it too is predicted to have a “significant” and “adverse traffic impact”. Increases in traffic will be to the massive detriment of other road users- this again is unacceptable.
The plans show very little to mitigate these traffic impacts. A holistic solution to the far-reaching environmental and human effects of the increased traffic is not shown. There is total disregard for the effect on the minor roads around the site rather than a truly sustainable and integrated scheme.
Further away from the site, insufficient analysis has been done. Little mitigation is proposed. Some of the junctions that will be impacted are already known to be operating close to or over-capacity, but no modelling has been done for these junctions. For instance, A6006/Travells Hill, West Leake Road/Main Street, East Leake, Gotham Road/Main Street, East Leake. The Parish Meeting back the proposals made by the Ward Members for further analysis of the road network particularly to the south of the site.
Once the LDO is approved there will be little opportunity to avoid the adverse impact of traffic on the vulnerability of West Leake. Therefore, the LDO must have conditions attached to it that require a solution for mitigating the identified impacts prior to any development starting. The local parishes must also be involved in these solutions.
The application is woefully lacking in showing how an integrated transport plan could work. The requirement for a permanent foot link to the railway station at Parkway, the provision of a bus link to the tram stop at Clifton, a bus to link to the airport, extension of the tram and linking into the bus routes around Loughborough, North West Leicestershire and Erewash, are just some examples that could be incorporated. A forecast of 1.4% of workers using bus is far too low to be acceptable.
The Parish Meeting also believes that more analysis needs to be carried out on where the potential 15,000 workers (if that is the correct predicted number) are going to come from. With employment levels very high in the East Midlands, just how far are the 80% car users going to come travel and should even wider modelling take place.