Wednesday, August 01, 2012

My Written Submission to Helius

I have just made my written submission to Helius. The deadline for responses to Helius about their proposed power station is the 3rd August. All resident comments have to be in before or on 3rd August and need to be sumbitted to

Below is the submission sent by myself and Cllr Parnell:

Dear Sir

We are writing as local councillors for the Freemantle Ward to put on record to you our formal objection to your revised plans for a Power Station proposed for the Western Docks. We have also made representations to the City Council at the Planning and Rights of Way meeting held on 24th July.

We believe that your pre application consultation has been inadequate and flawed from start to finish. Your initial announcement was first made to the media rather than to the City Council and its elected representatives, appearing in the Southern Daily Echo on 6th March 2012.

You failed to act upon the recommendations of the City Council’s Planning and Rights of Way panel, which in their meeting on 17th July made several requests. They asked that you extend the area in which you hold consultation meetings to Shirley and Old Redbridge, You failed to do this. You also failed to produce proper information on fire safety should your scheme be built. This is again despite being asked to do this at the Planning and Rights of Way meeting and despite there actually being a huge fire at the time of the meeting at a scrap metal storage site literally next to where you propose building a wood burning power station. The fire was so significant it was visible for miles and nearby neighbourhoods were thick with smoke. The blaze took Hampshire Fire and Rescue Service a day to put out. In light of this and also in light of the fact that there was a fire at a biomass power station recently in Tilbury, to then not provide full information on fire safety is totally unacceptable. This is a significant public concern which you have chosen not to address.

Your consultation has centred on trying to encourage residents to choose between one of three designs. This is clearly an attempt to present your scheme as a fait accompli rather than directing the public debate on to the issue of whether power station on this site is welcome or not. We have attended all of the public meetings held in Southampton and we have had this complaint made to us by residents repeatedly. Indeed Paul Brighton of Helius, at the planning meeting on 24th July, tried to make the point that one design appeared to date to be the most favoured of the three. This is a serious distortion of the true state of public opinion.

Finally we feel that the photographs of the proposed development that you have supplied do not properly reflect how the development might look if built. You have moved the buildings and site location slightly compared with your previous scheme that you consulted on in 2011. However you have not changed the locations from where you have taken photographs. This is most starkly illustrated by the photograph showing the bottom of Foundry Lane. In last year’s consultation this looked down on the huge boiler house and caused enormous upset amongst local people. You have moved the boiler house now to near the end of Regents Park Road but continue to use a photograph of the bottom of Foundry Lane rather than providing a similar view from the bottom of Regents Park Road. We feel that this is a deliberate attempt not show how large the site would look from this location.

We therefore feel that your consultation has not been open or honest and it appears to us that you have tried to pay lip service to public consultation rather than really try to engage with local people and stakeholders.

The proposed site is directly opposite a residential area. Roads in Freemantle are a mere 250m 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.
The draft Hampshire Minerals and Waste Plan specifically says that the site you have chosen for your proposed scheme is not suitable for very large developments, namely category 4 and 6 developments. Your scheme therefore directly breaches one of the council’s core planning policy documents. We would like to endorse the objection made by the City Council’s Planning and Rights of Way panel which objected to your scheme at its meeting on 24th July citing this as a key reason for objecting.

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. 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 last 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 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 you planned to operate at this capacity, but felt that a more favourable result would entail if you bypassed the local planning process in order to submit to the Planning Inspectorate. Hence it is important that local views are not disenfranchised to effect an unfair advantage to the applicant.
We would like to endorse the objections cited by the City Council’s Planning and Rights of Way panel which objected to your scheme at its meeting on 24th July citing the size and scale of the proposed development as unacceptable.

Economic Impact
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 designs of the scheme are dreadful. They are functional and lack any architectural merit. They are 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.

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 is Southampton Common, a site of Special Scientific Interest with a fragile habitat with the largest population of the internationally rare great crested newt. You have made reference to the possible need for mitigation measures on the Common in your Technical Document. However I cannot find any details of what these are. Would you please provide further details regarding this?


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. 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. 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 has recently been built off Dock Gate 4 this has added 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.

Fuel Source
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?

Heat and CO2
No firm 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.

Community Benefit
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. Given the specialist nature of your operation it is unlikely that most of the people employed will actually live in Southampton. 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.

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.

Yours faithfully

Jeremy Moulton
Brian Parnell
Councillors for Freemantle Ward

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