Below is the Freemantle Councillors' submission to Helius as a formal response to their consultation on their planned biomass plant in the Western Docks.
We are writing as local councillors for the Freemantle Ward to put on record our formal objection to your plans for a Power Station proposed for the Western Docks.
Over recent weeks we have been inundated with correspondence from constituents objecting to the scheme and we have attended a number of packed local public meetings where residents were unanimously against the plans.
The proposed site is directly opposite a residential area. Roads like Lakelands Drive and Foundry Lane are just 125m from the site. Due to the site’s close proximity to housing the proposed power plant will undoubtedly have a serious detrimental impact on the lives of local residents. Anecdotally we have been advised that your plans are already beginning to blight the area with residents struggling to sell their properties or finding that their properties are being significantly devalued.
Cllr Moulton is a governor of the local school, Freemantle Academy. Hence we know first hand from many parents in the area how they are worried about the impact of the power station on their community. The worry is that families will not want to bring up children in an area over shadowed by an enormous power station and will start to move away or not move into the area. This will have a profound knock on effect on the school.
A number of residents have asked whether other sites in the Docks have been examined; bearing in mind that the docks are an expansive area with the majority of the area sited much further away from housing. We are not aware that any alternative sites have been considered.
The proposed scale of the plant is far too large and out of context with its surrounding structures. Indeed it will be the biggest building on the city skyline, dwarfing the terraced housing opposite. The chimney at 100m tall is three times the height of cranes in the docks. Its sheer size and mass is out of character with the area. It will dominate the view of those coming into the city by road or rail from the west, the residential areas across Southampton water bordering the New Forest and the 1.4m cruise ship passengers travelling up and down Southampton water. The new police building in Southern Road, that opened this year, was meant to be a landmark gateway building. However all people will see when approaching from the west will be the power station.
Some residents have suggested to us that if the power station was of a much smaller, perhaps more on the scale of the District Energy Scheme in the city centre then proposals for the site would be more acceptable. However, other concerns would need to be addressed. Observations have been made that perhaps the only reason you opted for such a large scale site of 100MW capacity was not because they planned to operate at this capacity, but felt that a more favourable result would entail if they bypassed the local planning process in order to submit to the IPC. Hence it is important that local views are not disenfranchised to effect an unfair advantage to the applicant.
Neighbouring the development is the premier shopping development of West Quay with the new £150m luxury shopping development of Watermark Westquay due to open in 2013. On the waterfront is the proposed £450m development of Royal Pier by Morgan Sindell. The economic revival of Southampton will be placed in jeopardy, as developers will struggle to find tenants to occupy these premier sites with a huge eyesore dominating the surrounding skyline. Southampton is one of the most deprived urban areas in the South East and is fundamental that inward investment is secured to enable job creation in the area. There are thousands of new jobs now in jeopardy.
The proposed design of the scheme is dreadful. It is functional and lacks any architectural merit. It is completely out of keeping with the Victorian terraced houses and docker cottages bordering the site or the nearby attractive 1934 Solent flour mill that greets workers and visitors entering Dock Gate 10 to the port along West Bay Road. It has been suggested that this might not be the final design. However, what guarantees are there that you will present a more appealing design and proceed to build this and not revert to the cheaper functional form already presented. Indeed can the design be changed if you get IPC approval with your current submission? What guarantees are there that you would not sell your planning approval to another company that might then proceed to develop something very different in appearance?
A major concern of residents is the adverse impact on air quality. The area already has very low air quality with all the nearby industry and traffic. The power station will further reduce the air quality. The aim should be to improve air quality. The suggestion that it might be within particular standards, if true, does not change the fact that the air quality will be worse and this will have a heath impact on local residents. One only has to walk around the area to see the build up of soot on cars and window ledges. The city centre location is densely packed being home to thousands of people and with the local Freemantle primary school being close by. One can imagine people with asthma and other health problems will be adversely affected. To the North East of the area are the central parks of Southampton Common, a site of Special Scientific Interest with a fragile habitat with the largest population of the internationally rare great crested newt.
The power station will operate 24 hours a day and local residents will be subject to continuous noise pollution. It is not necessarily the operating noise of the facility itself but the conveyors carrying the fuel source onto the site and loading into the burners. To site it further away from houses would help alleviate its impact. This is then an argument for looking for an alternative site and/or downscaling the power station so that it doesn’t impact on the community. There is already considerable noise pollution and over many years we have had complaints from neighbours who are affected by it.
If a power station is to be built in the docks, then all the materials should be shipped through the docks and not brought by road. When one considers that a single lorry movement equates to 30 tonnes of load then when the proposal is for 800,000 tonne capacity, then the road impact could be enormous if limits were not put in place. There are no such guarantees in the current submissions we have seen. The Millbrook roundabout and Millbrook Road West are already very congested. The link road into the city is recognised as one of the key roads in the country yet it remains the responsibility of the Council to maintain something that it can ill-afford. The new City Depot being built off Dock Gate 4 will add further traffic pressure to the area. This route is the main entry point into the city for tens of thousands of daily shoppers to West Quay and IKEA, commuters and visiting football fans. Your plans include no measures to mitigate the impact of traffic on the community. There are no suggestions to have a separate docks road off the M271. Measures like this would help should you bring materials by lorry.
The feeling in the community is that your consultation has been flawed. Your staff have been unable to provide good quality answers to residents’ questions at drop in sessions. Very people recall receiving leaflets from you and the design of the leaflets did not attract the eye. Indeed we understand that many fliers were distributed via the free weekly Southampton Advertiser and hence any literature will have been mistaken for the usual marketing leaflets and binned. It was only when pictures of the proposed design came to light in the online consultation document that residents began to become aware of the proposal and appreciate the enormous impact it would have on the community. Letters from you have been restricted to residents associations, councillors, MPs and the like and limited effort has been made to directly engage the residents who live near by.
You have suggested in a recent press release that following the public response to your scheme that you would look again at the size of the scheme. However no detail has been forthcoming. If you intend to make material changes then you should restart the consultation. If the changes are not material then clearly they won’t address the concerns that residents have. From discussions with Southampton City Council planners they have grave concerns about the lack of detail in your submission. Despite numerous requests for more detailed specifications to expand on "not significant" they have yet to receive adequate responses. This lack of open and honest engagement is deeply concerning.
We have considerable doubts that wood bio mass on this scale is sustainable. The amount of fuel proposed is enormous in comparison to the UK output of wood. Indeed from research we understand that there is no spare capacity to meet the plant’s proposed requirements. Inevitably the vast quantity of wood will be sourced from abroad. Hence the so called green credentials of this technology are dubious to say the least. The impact on carbon emissions of transporting it from around the world will be considerable. A more locally sustainable, smaller, power station using waste wood and local coppicing would surely be more environmentally friendly. What guarantees can you provide that all your wood will come from an accredited source, indefinitely? What steps have you taken to secure viable quantities of fuel?
Will food be the only fuel source or might other material be burned? What guarantees can you make in this regard? What will be the impact of burning non-virgin wood which has been treated with chemicals (paint and varnish)? Has an assessment been made of burning these complex chemical compounds?
Heat and CO2
No provision has been made to recycle the heat produced from the burning of the fuel. Nor has thought been given to the release of the CO2. Hence these by-products of the combustion are being wasted. Combined heat and power plants are now common place in large glass house nurseries around the UK such as Thanet in Kent and Isle of Wight, where the green credentials of burning fuel are well known and documented with heat used to warm the glasshouses and CO2 provided to the plants.
Whilst this is by no means an exhaustive list of arguments to oppose this application, we do consider that the concerns we have raised are real and warrant that this application be rejected. The first area that must be considered is the adequacy of consultation. We consider that this first stage has not been satisfied and you should be required to return the drawing board.
Once the construction phase has ceased, which no doubt be undertaken by specialist workers from outside the city there will only be 40 jobs created by operating the plant. Hence there will be limited economic benefit to the city outside of the income earned by ABP for leasing the site and cheap power source provided. For such a major multi-million pound development, you have not offered any planning monies to benefit the local community, facilities or infrastructure improvements to the key arterial M271/Millbrook Road route into the city. This is incredibly surprising and demonstrates a complete disregard for your corporate social responsibility.
Councillors for Freemantle Ward