21st December
2009
Dear Mr Rider,
Application 08/01665/FUL
We have reviewed the additional
information submitted by National Grid (NG) and our comments are below. The
text in italics and marked ‘NG Letter’ is taken from NG’s letter to you dated 8th December
2009.
1. Landscaping
The Inspectors reported that
“we feel strongly that the
details of this proposal, in particular the quality of the landscaping, would
fall far short of what should be expected from this statutory undertaker for
this PRI development in a sensitive rural landscape” 1
Given this verdict, we do not
understand why NG have perpetuated the wholesale shortcomings of the Appeal Site
in their latest plans. Apart from issues around the unacceptability of an
industrial site in open countryside, their proposal – both as originally stated
and as currently amended - remains dependent on the same urban approach which
they used at the Appeal Site, and which the Inspectors criticised because it
was clear that there had been no involvement by a landscape architect: 2
You will also be aware that the
Inspectors heavily criticised the use of bunds at the
Appeal Site, saying
“Indeed, the mounds themselves
would be alien and intrusive features in the landscape and do little to help to
assimilate the industrial development” 3
NG now propose the use of even
larger bunds. Combined with a poor choice of tree
and shrub species, and
technically difficult - if not unachievable - ways of trying to
secure rapid establishment for
screening purposes, these current proposals will
accentuate the intrusion of this
large installation into the countryside rather than
mitigate its impact.
NG have paid lip service to
countryside conservation objectives by their simplistic
and wholly inadequate approach
to dealing with the special character of the Application Site. Comparison of
the detailed plans for Tirley with those rejected for the Appeal Site shows the
presentation of an almost identical approach which will result in a grossly
intrusive and alien feature in the local landscape which will be evident for
very many years. This industrial development would never merge into the local
scene and would always remain an eyesore.
2. Lighting: Telescopic lighting standards
“The possibility of using
telescopic lighting columns has been considered. Whilst such lighting
arrangements can be employed in other locations, we would not be able to use standard
units (incorporating electric motor drive units) in a controlled gas site.”
NG
Letter
NG claim that they would not be
able to use ‘standard’ units (incorporating electric motor drive units) but
they do not give a reason. However, they do not totally exclude the possibility
of using telescopic lighting columns. In the absence of a proper explanation,
we do not consider that our comments have been addressed.
3. Hedgerow
The view is being advanced by NG
that the hedgerow will afford a visual barrier through which drivers using the
B4213 would find it difficult, if not impossible, to see the proposed PRI. NG
say:
“The view [of the lighting
columns] would be transitory, as the relocated hedge and proposed roadside
mound with planting would close these views for most drivers using the road.”
NG
Letter
We dispute this statement.
3.a) NG limit their statement to
lighting columns. There will also be 12 exhaust flues and these will not only
be higher than the lighting columns but will also have a larger diameter, and
consequently will be more visible, and intrusive, than the lighting columns.
3.b) For approximately six
months of the year the hedgerow is without leaf and consists only of a random
criss-cross of twigs and branches. When a person standing on the road looks at
- and through - this patchwork, his eyes focus on the twigs in the foreground and he is less aware of the
background. However, when a driver moves along the road in a car, his eyes and
brain function differently. The twigs and branches move past him at a speed
which his eyes do not have the capacity to resolve and he therefore focuses on
the background. Although at no time does he have a whole and uninterrupted view
of the background, the speed of the interruption is so fast and so varied that
his brain extrapolates and interpolates the missing data and he is left with an
apparently near-uninterrupted of the background.
(This phenomenon is similar to
flashing a series of cards, each of which has a picture which is taken slightly
later in time to its predecessor; the effect is to show movement4. In the case of the hedgerow, a
better parallel would be where each card shows a picture of the background, but
with each picture being slightly incomplete in a different way from every other
picture. The effect for the viewer – the driver – is the removal of the
hedgerow as an effective visual barrier.)
3.c) The construction of a bund
1 metre high for a short length to the west of the entrance to the site from
the B4213 will be largely irrelevant in summer when the hedgerow is in leaf
and, in winter, when the hedgerow does not offer an effective visual barrier,
will serve to bring closer to the public the artificiality of the construction.
Given that the height is only 1m - and that for just 50 metres (or 2 seconds
for the passing motorist) it is unlikely to be high enough to achieve its primary
purpose of preventing views into the PRI .
3.d) The hedgerow along
virtually the whole of the north side of the B4213 is high and has been left
untended for many years. The owner of the hedgerow will be free to lay or
otherwise reduce the height of the hedge at any time and there could then be an
uninterrupted view of the lighting columns and vent stacks of the PRI.
4. Site Option 16
4.a) Economic and efficient
“However, as the Inspectors made
clear in their report on the Corse PRI appeal, regard must be had to National
Grid's statutory obligation to develop its gas transport infrastructure in an
economic and efficient manner. The additional costs of alternative schemes are
therefore a material planning consideration.”
NG
Letter
NG appear to suggest that the
statutory duty laid upon them to construct an infrastructure in an economic and
efficient manner requires that they exclude Site 16 as a possible choice.
It should be remembered that the
Inspectors severely criticised NG for failing to examine the land beyond a
radius of 1 km from the Appeal Site. It follows from this that the Inspectors
did not consider that the additional cost inherent in building a PRI
at up to 10km from the AGI was
necessarily a bar to siting a PRI at Site 16 or indeed at any location within
that 10km circle. It follows from this that a full and proper evaluation should
be made of the Site 16 option and that the additional cost implicit in the
selection of Site 16 is not a material consideration.
4.b) Proximity to AGI
“the Inspectors acknowledged
that the consideration of alternatives has to be made in the context of certain
constraints, including the technical objective of locating the PRI and the AGI
as close together as possible.”
NG
Letter
This is not a valid argument for
excluding the possibility of Site 16. Whilst technically it may be desirable to
co-locate these two facilities, the Inspectors severely criticised NG for not
examining the possibility of locating the PRI up to 10 kms distant from the AGI5; that is, separating them by as
much as 10km. If the Inspectors had accepted the argument that the two
facilities should be located as close to each other as possible, they would not
have required NG to examine this enlarged area, nor indeed would they have had
an argument for refusing the appeal because the enlarged area had not been
researched.
5. Need to consider
alternatives
Site 16
“It is evident that the current
proposals have addressed the concerns expressed by the Inspectors and that the
need for the development outweighs any harm that may be caused. In those
circumstances, it is unnecessary to determine whether there is any better
alternative to the application proposals.”
NG
Letter
It is for the reasons cited by
NG that they have undertaken no proper evaluation of Site 16. Their reluctance
to consider this Site, first evidenced by the surprise of their representatives
when they were invited to walk to the Site during the site visit undertaken by
the Planning Officers and CAPRI, and further confirmed by the limited assessment
which they have since produced, is obvious. NG, having determined that there is
no need to consider Site 16 as a candidate site because the choice of that site
would breach their ‘economic and efficient’ duty, have given it no proper
consideration.
The current proposals do not
address the concerns of the Inspectors and, as we have previously stated, the
proposal does not comply with either the relevant local or national planning
policies.
5. Land area
We wish also to bring to your
attention the fact that NG have issued a Compulsory Purchase Order for an area
of land greatly in excess of that required for the PRI or its associated
landscaping. Some additional land may be needed during the construction phase
for the temporary storage of tools and equipment, but NG have declined to give an
assurance that that additional land would be returned to the original owner
when construction was complete.
We are accordingly concerned
that NG may therefore view this site as being suitable
for further but as yet
unannounced development.
6. Conclusion
We conclude by repeating our
previous claim that, whatever minor cosmetic improvements are made to the
proposal, granting permission to build a PRI at this location would be wholly
unjustified because it is the wrong location, and is an industrial installation
which is contrary to the Development Plan.
Yours sincerely,
P. M. McMurtrie
Chairman
1 Inspectors’
Report, para 8.111
2 Inspectors’
Report, para 8.62
3 Inspectors’
Report, para 8.59
4 Pictures
appearing at a rate of 16 per second give an impression of relatively fluid
motion.. A ¼ inch diameter twig would interrupt the view of a passing motorist
for approximately 1/4,000 of a second – that is, would effectively be
invisible.
5 “We accept that
finding a suitable alternative site for the PRI would not be an easy task but
we have sympathy with the argument that the consideration of an area of search
that looks at only 1% of the potential area does not signify a serious and
concerted effort and it should be given little credence. “
Inspectors’
Report, para 8.69