East Midlands Freeport
Planning Application Ref 22/01339/LDO
Saturday 3rd September 2022
Local Development Order for Development at Ratcliffe on Soar Power Station / Ward Members’ Response – Leake Ward
This response to the consultation is from the three ward members for Leake Ward – Councillor Kevin Shaw, Councillor Carys Thomas and Councillor Lesley Way.
Overall we are supportive of redevelopment of this brown field site to form a high tech green technology hub but we have serious concerns on a number of grounds and we OBJECT to the overall proposal as it stands.
1. Decision-making for detailed proposals
The consultation gives the opportunity to comment on this. We believe that there should be the ability for decisions on certificates of compliance to be taken directly by elected Councillors in certain circumstance, for example a request to do so by the ward member, or ward members from multiple adjacent wards, and/or evidence or significant public opposition to a particular proposal for whatever reason. It is important that any contentious applications have the benefit of full public representation. The situations should be few and far between if the applications broadly comply with the LDO, and with the right mechanism should not result in great delays. Such applications could be referred to Planning Committee or perhaps to a specially convened working group under the Planning Committee comprising members of the LDF or the DevCo WP (as members of these groups maintain oversite of the initiative), but considered in public with speakers as for Planning Committee.
2. Impact of Significant Increased Traffic Levels on Villages and Country Roads
The Transport Assessment identifies significant projected increase in traffic along Dark Lane and through the two villages of West Leake and East Leake as well as other villages and country roads in the area.
The Environmental Impact Assessment includes the following statement.
Non-motorised users on Station Road and West Leake Road in East Leake; and Main Street in West Leake may be impacted as a result of increased traffic flows making road crossings more difficult. This results in a moderate adverse effect, which is considered significant.
Note that many impacts on local roads are identified in the transport assessment and are of concern to residents, but this is the only significant impact re transport and traffic raised in the Environmental Impact Assessment.
The traffic modelling is based on work for the East Midlands Gateway which did not have to consider traffic from the A6006/A46 needing to turn north/west to go to the Power Station. As the proposal stands, traffic approaching from the direction A60/A6006/A46 will leave the strategic road network somewhere between Costock, Rempstone and Zouch to head for the power station. It will travel along narrow winding country roads and through the villages, with huge negative impact on quality of life. Insufficient analysis has been done. No 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.
We request that additional analysis is undertaken before the LDO is approved, as follow :
Model the following junctions for am and pm peaks, and check accident records:
A60/Main Street/Wysall Lane - Costock crossroads
A60/A6006 Rempstone crossroads
A6006 Staggered junction Leake Lane/Loughborough Road
A6006/A6 at Hathern
East Leake T junction Gotham Road/Main Street
East Leake junction by the church Brookside/Main Street/Station Road
(Note that modelling should include housing developments completed and under way in East Leake plus the Defence and National Rehabilitation Centres.)
Determine the strategic preferred routes avoiding villages for journeys to and from the Power Staton site from the following roads:
A6006 (Rempstone to Hathern)
A60 (Nottingham to Loughborough).
Specify signage and improvements to the roads and junctions identified as strategic routes to improve traffic flows, encourage use of these routes, and remove delays at pinch points to make these routes more attractive.
Specify measures to protect the country roads and villages that will be impacted by traffic cutting though from the strategic routes, to mitigate the impacts and to make these routes less attractive. Measures could include: weight limits, speed limits, chicanes, road closures, one way systems, width reduction to create one way flows with priority signage, signage to designate “country lanes”, “cycle priority route”, “access only” etc.
3. Emphasis on travel by car and insufficient provision of public transport
Very little is being done in the plans to satisfy various policy requirements to promote methods of sustainable transport. Even after measures proposed the Transport Assessment concludes:
80.4% of people travelling to/from the Site would travel either as a car driver or passenger, and 15% would travel by public transport (13.6% by rail and 1.4% by bus).
This is simply not good enough and plans cannot be allowed to go forward on this basis. The car is king! The site plan has the appearance of a giant car park, and apart from anything else this is inefficient use of land. The premise is that there will be on-plot parking for each of the buildings. Journeys by car will be door to door and so encouraged. Public transport journeys however will be difficult and time consuming and so discouraged. At present there are proposals for two existing services to simply stop at the entrance to the site with travellers expected to change at the mobility hubs and catch the shuttle bus or borrow a bike or scooter. As things stand in the proposals, the balance of convenience is greatly in favour of travelling by car.
Parking provision should be redesigned to redress the balance in favour of sustainable travel. On- plot parking could be reduced to just disabled and shared car spaces, with the majority of spaces situated around the edge of the site near the mobility hubs. Multi story car parks here instead of flat parking throughout the site would keep the parking footprint compact and allow land to be used for green space and biodiversity gain instead. Having the various buildings closer together rather than separated by huge car parks would help build community among employees. This approach could also retain more land for business use in the future.
This will be a major employment centre situated in Rushcliffe but no analysis has been undertaken of public transport routes from the major residential areas in Rushcliffe such as West Bridgford, Ruddington, East Leake, Keyworth and Cotgrave. (Bingham and Radcliffe on Trent have the rail link.) This is a piece of work that should be added, by Rushcliffe if not by the applicant, so that additional public transport provision can be designed to benefit the residents of Rushcliffe as well as other surrounding areas.
As things stand, from the tram park and ride, it will be necessary to catch the Skylink, then the site shuttle bus. From East Leake (in our ward) the number 1 to the tram stop, then Skylink, then the site shuttle bus.
One option considered but which seems to have been discarded was for the site shuttle bus to be extended to the tram stop. This would reduce the number of changes for public transport users and make the public transport option significantly more attractive. It could be a public bus service rather than a free site bus. It might even be possible to consider running the shuttle bus along the reserved tram access route. The option of extending the shuttle bus service to EMG seems to still be under active consideration, but extending it to connect with the tram is surely more important?
An option from East Leake suggested by a resident would be to run the no 1 service from Gotham via Kegworth Road/West Leake Lane and the A453 to the crusader roundabout, stopping on West Leake Lane at the Southern part of the development, rather than through Fairham. The shuttle bus could be used from here to access the northern part of the site. This option is worth considering, preferably by adding extra buses via this route and/or perhaps running alternate buses via the two different routes. Bus stops would be needed on West Leake Lane. Any increase of journey time on the no 1 would be an unwelcome side-effect of this and could be a disincentive to travel by bus to Nottingham in general. However it is noted that increased journey time is also anticipated on the route when it has to pass through Fairham. The various options would need to be assessed.
4. Lack of Cycle Routes
Consideration is being given to cycle routes along the A453 and elsewhere, but there is only a cursory mention of a cycle route to Gotham, possibly to be extended to East Leake. There is certainly no firm undertaking from the applicant or from NCC to take this forward. This is not under consideration to receive funding from the development, despite the significant grants available towards transport. This needs to be rectified. In terms of distance, cycle journeys from within our ward are certainly very viable, but the winding roads with fast traffic are not conducive to cycling and will become even more unsuitable with the extra traffic proposed unless steps are taken to reduce it (see section above). The country lanes concerned need to be targeted as active travel routes and protected so that cycling is given priority on them and is safe. The alternative is to provide dedicated off road cycle routes and plans for this need to be worked up, rather than written off as a vague aspiration.
Although it is not far from the Number 1 bus stop in Clifton to Skylink at the tram park and ride, if the number 1 went into the site and out again, closer links to the tram and Skylink or shuttle bus may encourage this route. In fact, why not develop the park and ride site into a transport hub similar to a bus station making it easier to change?
We also recognise that with a few improvements the extensive bridleway network could form part of a sign-posted and promoted route and be part of the cycling solution for some people, at least in the summer months, and we ask that this is considered. The bridleways are already are used for recreational cycling. Many stretches are suitably surfaced already. With negotiation, the new access road within the proposed solar farm development 22/00319/FUL (if approved) could form part of the route.
5. Solar panels on roofs
There is no requirement for the buildings to have solar panels on their roofs, but this should be included. It is important to use such vast floorspace for this purpose and set an example here, given the “green” aspirations for the site. Placing them on the ground instead is not a solution – the area designated can instead be used for biodiversity improvements and habitat creation. Solar farms can be underplanted but typically these areas are enclosed preventing mammal movement and the vegetation is species poor and strictly controlled, often using pesticides. We realise that there is talk of green roofs, but that is not a requirement either, and even if it were, the area of land assigned for solar panels would provide greater capacity for carbon capture.
Walkways and those massive areas of car parking could also be covered with raised roofs with solar panels, affording shelter from the elements and encouraging active travel around the site, as well as generating electricity. For a site professing a vision of “A Smart, Green, Resilient Industrial Park focused on Energy Generation and Advanced Manufacturing” such initiatives should be built in from the start.
6. The Southern Site, Phasing, Logistics uses
Only part of the area south of the A453, viz the ash tips, can be regarded as brownfield and once the ash is removed these areas could readily be restored to countryside. It seems unlikely that this site would have been approved for development if it were not in combination with the power station site. There is concern about the height and imposing nature of the buildings proposed here and loss of fields and areas of woodland. We add our voices asking for the built area to be reduced, the building height to be reduced, the appearance broken up, screening to be added, and existing valued habitats and countryside to be preserved.
We are concerned that the possibility of the power station being retained for longer than originally planned will lead to this area alone being developed initially, which will make the visual impact even more pronounced.
We note that the area for B8 use (logistics, storage and distribution) is “limited to a maximum of 180,000 m2 GFA on the Northern Area”. We fear this may come under pressure if the planned phasing has to be revised. Applications for B8 use on the Southern Site should be refused, not least because this will introduce additional heavy traffic via this access. Indeed the introduction of logistics uses should be controlled in general to maintain the intended proportions so that it does not dominate the site at the outset. Even if areas come forward later than planned, the vision for the site must not be diluted as it comes on stream.
If coal-fired power generation continues presumably there will be an ongoing requirement for an ash tip – where will this go if the southern site is cleared and developed?
We note comments from NCC about ensuring that the ash, now a valuable commodity, is fully exploited and not simply used for levelling the ground etc.
There is little in the plans about using the buildings themselves to create wildlife habitats and provide biodiversity. Opportunities are being lost here – bird and bat nesting sites, green walls and other gains should be required. Green roofs in combination with solar panels perhaps. The areas of car parking could include more than a few trees, and the surfacing could be eco-friendly.
Page 13 para 3.3 of the LDO provides a hierarchy for delivery of Biodiversity Net Gain units, and will make it far too easy to avoid providing the benefits on site. That is the first option in the hierarchy and the only option that is really acceptable. The overall site could perhaps identify a series of projects that individual plot holders can buy into as part of their contribution? Provision off site in the immediate local area (options 2.1 and 2.2) is the only alternative that should be considered, and only in exceptional circumstances where the gain truly cannot be made on site. Fuelling the dubious industry of BNG providers is not acceptable. The fish pass at Thrumpton Weir (option 3) is no doubt a worthy cause but it is not a BNG. Option 4 – a payment to Rushcliffe is utterly insupportable – it will either be used for other purposes which would be a betrayal of the environment, or simply join the vast sum of developer contributions banked by Rushcliffe that cannot be spent for the intended purpose. BNG should be taken seriously and this section needs to be strengthened considerably.
8. Conditions and Overall site management responsibilities
There appears to be some opportunity for responsibilities to comply with conditions to fall in the crack between the land owner, overall site operator and applicant/operators of individual plots. All conditions need to clearly set out who is responsible for satisfying them. Similarly, a site wide management plan should be approved as part of this applicant (or as a condition attached to it), and individual plot site management responsibilities also clearly laid out and approved.
Responsibilities of other agencies such as Rushcliffe and Highways for any aspects of managing the site also need to be clearly defined and delineated. We have seen with housing developments how this can be problematic and this site is more complex.
9. Positive planning for Heat Energy from the Incinerator
The incinerator application promises on site direct heat as well as electricity generation. We note NCC comments about the importance of the infrastructure for this heat distribution network to be designed in from the start and we support their proposed condition.
10. Maximising advantages of the rail link
Much has been made of the presence of the rail link into the site when justifying development here, but there is little in the documentation to ensure that this is fully exploited. In the same way that there are travel plans about journeys to work we would like to see conditions so that the site planning overall and individual businesses taking up occupancy are actively considering how the rail link can be used to move freight of all kinds, including waste to be processed by the incinerator, raw materials, and manufactured goods. This will be key to reducing heavy traffic, but needs active consideration at this stage to make it happen, as any additional infrastructure will need to be in place before the individual plots are developed.