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 enquiries@southamptonbiomasspower.com.

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 24^th July.

Consultation
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 6^th 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 17^th 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 24^th 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.

Location
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 24^th July citing this as a key reason for objecting.

 

Size
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 24^th 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.

Design
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.

Pollution
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?

Noise

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.

Traffic
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

Freemantle Councillors Formally Object to Biomass Plant

Below is the Freemantle Councillors' submission to Helius as a formal response to their consultation on their planned biomass plant in the Western Docks.

Dear Sir

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.

Location

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.

Size

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.

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.

Design

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?

Pollution

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.

Noise

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.

Traffic

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.

Consultation

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.

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?

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.

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. 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.

Yours faithfully

Jeremy Moulton
Brian Parnell
Michael Ball
Councillors for Freemantle Ward

Greenpeace Welcomes the Conservative Energy Vision for Southampton

A week after Southampton's new Conservative Council Administration launched its green energy for the city, Greenpeace is teaming up with the City Council and energy company Utilicom to promote sustainable power and energy.

Tomorrow night the DeVere Grand Harbour will play host to over a hundred councillors, MPs and environmental experts who will be meeting to discuss how combined heat and power (CHP)schemes such as one in Southampton can be used to cut carbon emissions.

Councillor Gavin Dick (pictured above), Conservative Environment Cabinet Member said Councillor will be speaking at the event, promoting the work of Southampton City Council and encouraging others to back Southampton's green energy vision. He said: "Southampton is leading the way on sustainable energy thanks to the city`s CHP network, and we are delighted to be able to promote this success in the hope that other local authorities and businesses will learn from our own experiences."

Click HERE for Southampton City Council's press release on the subject.

Click HERE for coverage on environmental website Tenbees.

Plans Unveiled To Make Southampton Britain's Greenest City

At Springhill School, the new Conservative Council Administration today launched its integrated energy vision for Southampton.

The vision will see the expansion of energy efficient combined heat and power (CHP) technology throughout the city and better use of renewable energy such as biomass.

The biggest change will be to require as part of the planning process, large-scale developments in the city (such as new schools and colleges and large scale residential developments) to incorporate district energy such as CHP . These large developments will then act as hubs to link in smaller developments and existing dwellings.

At the moment, the city's CHP network already supplies around 40 businesses including the West Quay shopping centre, The Quays Swimming Complex and Southampton Solent University, while similar small-scale CHP plants are in use at Southampton General Hospital and Southampton University.

Planning development costs for households wanting to put up solar panels or install small-scale wind turbine generators will also be abolished.

No To New College Development Plans

I have written and formally objected to Linden Homes' plans to develop the former New College / La Sante Union site.

Linden have submitted 7 planning applications which include proposals for 200+ flats.

I wrote objecting to Linden's plans when they first came to light at their presentation to residents back in February. Click HERE for details of my letter to Linden and HERE for their reply.

I have objected on a number of grounds:

1. Firstly the design is totally out of keeping with the character of the local area, which is designated a conservation area.

2. Secondly I am concerned that only minimal efforts have been made to make the proposed development environmentally sound and sustainable. I would very much like to see any development on the site link into the city's combined heat and power station and was disappointed that Linden rejected this idea.

3. Thirdly I am concerned that there are too many flats and not enough family housing.

4. Finally inadequte parking will lead to increased parking pressure on the surrounding area.

Click HERE for the recent Daily Echo story on this.

New College Development Plans

Last night I went to a roadshow organised by Linden Homes about their Plans for developing the former New College Site (La Sainte Union) on the Avenue / corner of Archers Road. Their plans are for large numbers of flats, a few houses, some commercial offices and some sheltered housing.

I met a number of local residents and spoke with Linden Homes and their architects. No formal planning application has been submitted yet and so the plans are still in draft form.

However based on what I have seen so far I have some concerns.

1. Traffic Congestion. Archers Road is terribly congested already. A new development will mean many more vehicles coming and going. Planning permission was recently granted for large numbers of flats the other side of Archers Road on the old nurses / social services site. The proposed new development for New College has 2 points of access on to Archers Road.

2. Parking. If insufficient parking is provided it will mean more cars clogging up the surrounding streets. I was pleased to see that the developer is considering underground parking under the flats and 3 story townhouses with a garage on the bottom level. I would like to see the maximum amount of parking if the development does go ahead.

3. Design. The site is in the Avenue Conservation Area and it borders another conservation area. The developers are looking to protect some of the old buildings however the new buildings that they propose are of a very contemporary design (think Ocean Village). In my mind a development that is in keeping means that the new buildings look similar to existing ones rather than looking completely different.

4. Combined Heat and Power. There is CHP plans in the city centre (the big red building near Toys R US). This is gas turbine power station (previously a geo thermal power station) that heats most of Northern Above Bar. It is considerably more efficient the normal means of providing heat and power and therefore more environmental. A lot of new housing developments in the city centre have linked into the CHP network. Apparently Linden don't intend to use CHP for this development. I have asked why as it seems worthy of proper consideration.

I have mentioned all the above points to Linden Homes and will follow it up with a letter to them.

There is another Roadshow this morning at New College, for those that didn't get a chance to have a look yesterday.