Get documents about "Strategic Rail Freight Interchange former Radlett Airfield_
Document Sample
HERTFORDSHIRE COUNTY COUNCIL Agenda No.
DEVELOPMENT CONTROL COMMITTEE
TUESDAY, 23 JUNE 2009, AT 10.00 A.M.
2
ST ALBANS DISTRICT
APPLICATION FOR RAIL FREIGHT INTERCHANGE: FORMER RADLETT
AIRFIELD, NORTH ORBITAL ROAD, ST. STEPHEN SADC/5/2009/0708
Report of the Director of Environment and Commercial Services
Author: Steve Bailes Tel: 01992 556293
Local Member: Aislinn Lee
(Adjoining Members: Caroline Clapper, Mike Ellis, Chris Brazier)
1. Purpose of Report
1.1 To inform the Development Control Committee of the above application
and provide the Committee with an opportunity to discuss the issues
raised prior to considering a formal response to St. Albans City and
District Council at the Development Control Committee meeting on 20
July 2009.
2. Summary
2.1 This application is to develop a strategic rail freight interchange facility
(SRFI) at the former Radlett Airfield south of St Albans. It is virtually
identical to that submitted in 2006 on which this committee commented
in October of that year. St Albans District City and District Council
subsequently refused the application which went to appeal in 2007.
2.2 The appeal was dismissed primarily on the grounds that the appellant
had not adequately demonstrated that no other sites would come
forward to meet the need for SRFIs and therefore had not
demonstrated that the harm to the Green Belt was outweighed by the
need for the development.
2.3 A new application has been submitted to which much of the October
2006 report to committee still applies.
2.4 Freight would be brought in by rail, mainly from the greater south east
region‟s container ports plus the Channel Tunnel, using a new link from
the Midland Main Line. It would be off loaded into warehousing (over 3
million square feet) and then processed, assembled and repackaged
before being moved out by road, largely to London markets. About half
the facility is anticipated to handle rail based freight and the other half
freight brought in by road.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 1
2.5 12 trains a day (24 in and out) are predicted when the facility is fully
operational generating 3,200 HGV movements a day (in and out). In
addition there would be 7,000 light vehicle movements daily (employee
cars and „white vans‟). The facility would operate 24 hours a day.
2.6 The main highway access would be to the north with a new signalised
roundabout on the A414 with a second access to the south via a new
bypass to Park Street/Frogmore to the A5183 north of the M25. The
two existing roundabouts on this section of the A414 would be
improved, with traffic lights installed at the Park Street roundabout and
the lights up rated at the London Colney roundabout. The bypass is
proposed as a benefit to provide mitigation to existing traffic problems
in Park Street and Frogmore.
2.7 Employment is forecast at nearly 3,400 employees; three quarters
being classified as „process plant and machine operatives‟. Nearly half
the staff (43%) is expected to live in London with a further 10% in
Luton. Hertfordshire is predicted to provide 40% of the workforce.
2.8 As part of the proposals, landscaping, tree planting and improvement
works to provide a country park on surrounding land is intended. This
is proposed as mitigation for the impact of the SRFI. It would not be a
country park in the normal sense of the term but the substantial areas
of countryside and former mineral workings from Moor Mill to Broad
Colney would be managed in the public interest and linked with rights
of way for public access.
2.9 Most of the development site has been worked for minerals and has
been restored at the lower, post extraction, level. It is currently being
used for agriculture (grazing) and woodland. The whole of the
application site is within the Green Belt.
2.10 The application is an outline application to cover siting, including local
impacts such as noise and air quality, landscaping, access (both road
and rail) and demand and the need for the facility. St Albans City and
District Council as the local planning authority will determine the
application. They intend to do so at a meeting of their Referrals
Committee on 20 July.
2.11 The County Council has been consulted as Highway Authority and on
ecological/ landscaping/country park issues. The new consultation was
received on 18th May 2009.
2.12 As Highway Authority, further work is ongoing on the transport
assessment, and the Committee will be more fully advised in the report
to the 20th July meeting.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 2
3. Recommendations
3.1 That the Committee note the content of this report with a view to
providing a formal response to St Albans City and District Council at
the Development Control Committee on 20th July 2009, particularly
taking into consideration the following:
i) whether the applicants have demonstrated sufficient need for the
development of this site.
ii) whether other aspects on which the County Council has been
consulted (except for highways matters) could be resolved with
the applicant through the imposition of planning conditions and
obligations on the lines discussed at the Public Inquiry.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 3
4. Background
4.1 This application is virtually identical to that submitted in 2006 on which
this committee commented in October 2006. Much of this report
therefore repeats that committee report in its description of the
proposal.
4.2 It is government, regional and County Council policy to seek to increase
the amount of freight carried by rail and water to reduce road freight
traffic. If freight is to be carried by rail, whether through the Channel
Tunnel, from container ports such as Felixstowe and Southampton, or
from other parts of the country, it has to be off loaded at sites for
onward transmission by road.
4.3 The East of England Plan (RSS 2008) promotes the efficient and
sustainable movement of freight through maximising the proportion of
freight carried by rail and water and encourages measures that provide
adequate rail freight capability and capacity on routes to the region‟s
major ports. Comparable policy is reiterated through the recently
published South East Plan (2009) and the existing London Plan (2006).
4.4 The former Strategic Rail Authority (SRA) considered the implications
of growing rail freight traffic. Their Strategic Rail Freight Interchange
Policy in March 2004 indicated that the required capacity „would be met
by three or four new strategic rail freight interchanges (SRFI)‟ in the
wider south east region around London (para 6.9).
4.5 These sites would enable rail borne containers to be offloaded,
unpacked and their contents repackaged (and assembled) for onward
transmission by road; a much bigger operation than the traditional
rail/road terminal. The site proposed in this application would also
handle a considerable proportion of road borne freight for redistribution.
4.6 The proposal for an SRFI at Radlett Airfield was to have been the first
such site in the south east but one has now been permitted at Howbury
Park near Bexley, Kent. There have also been proposals for two sites
near Maidstone, Kent; an application for one has recently been
refused. Barking and Dagenham Borough have also identified a
potential (though smaller) site for a strategic freight terminal in their site
specific allocations document.
4.7 There are a number of SRFIs operating in the Midlands, such as DIRFT
near Daventry, and one permitted at Alconbury (north of Cambridge)
but not developed. Peterborough Council is understood to be
considering whether to propose a site in their area through their
emerging core strategy. The SRFI proposed in the south east prior to
Radlett, at Colnbrook, Slough, just west of Heathrow, was refused after
an appeal in 2002.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 4
4.8 The requirements for an SRFI, particularly in terms of the size of site,
link to the railway and access to major roads and motorways (radial
routes and the M25), are such that there are relatively few areas in the
region which could potentially accommodate one. Development
company Helioslough have identified the former Radlett aerodrome
south of St. Albans as having this potential. After some years‟ work,
including pre-application public consultations in which local members
were consulted; they bought forward their original planning application
which was subsequently refused by the Secretary of State after a
Public Inquiry in October 2008.
4.9 There was some limited pre-consultation prior to 2009 application but
the applicant did not engage in discussions with County Council
officers prior to their submission to the City and District of St Albans.
There also appears to have been only a limited review or updating of
the baseline information used in the current application from that as
was used in the original application in 2006 and inquiry in 2007.
5. The 2009 Application
5.1 The proposed development site is the former Radlett Airfield lying
between the M25 and the A414 North Orbital Road west of the Midland
Main Railway Line (MML) and east of Frogmore and Park Street on the
A5183 and the Abbey Rail line. Its most recent use was for the
extraction of minerals. (Appendix 1 shows a Map of the site and
surrounding area).
5.2 The planning application seeks permission for an SRFI comprising
„intermodal terminal and rail and road serviced distribution units‟
(331,665 m² B8 Warehousing including ancillary B1/B2 office
accommodation). These would be served by rail sidings linked to the
„slow up‟ line (the most easterly of the 4 tracks) of the Midland Main
Line by a track running through part of the old Harper Lane quarry and
passing through the existing embankment under the main line and
curving back southwards. About half the facility is anticipated to
handle rail based freight and the other half freight brought in by road.
5.3 Road access would be from a new signalised roundabout on the A414
North Orbital road near Hedges Farm. The farm house was originally
to be demolished but during the Inquiry the proposed roundabout was
relocated slightly and the building will now be retained. The new road
from the roundabout into the site would divide, with one road to serve
the site and one to continue along the edge of Frogmore to join the
A5183.
5.4 This road would form a Park Street/Frogmore Bypass which would
allow traffic calming measures in Frogmore and Park Street and reduce
car and lorry traffic through the villages. This is put forward by the
applicant as a positive benefit arising from the development. The
original proposal was to link to the A5183 at a realigned bridge over the
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 5
M25 but the new proposal, as discussed at the Inquiry, is to initially
have a signalised junction at the southern end of Frogmore with the
bridge to be constructed later.
5.5 The applicant forecasts that when fully developed the facility would
handle 12 trains a day (24 movements), about 1 train an hour. These
would largely arrive from the south via a cross London route though, a
rail connection for trains from the north could be added later.
5.6 This level of operation, the applicant estimates, would generate 3,200
HGV movements over a 24 hour period. 97% would use the new A414
access, 54% turning west to the Park Street roundabout and 43%
turning east to the London Colney roundabout. Measures are
proposed to ensure HGVs do not use the A5183 or turn onto Harper
Lane as a shorter route to Junction 22 on the M25.
5.7 Employment is forecast at about 3,385 on site employees (including
lorry drivers) (1 employee per 100 sq m of warehouse). 68% would be
warehouse staff and 74% classified as „process plant and machine
operatives‟.
5.8 Workers are expected to commute from within 30 minutes drive of the
facility, 40% from London and 10% from Luton with 15% from St
Albans District. Shift working would reduce the impact on peak hour
traffic and 35% of all employees are expected to travel to work by
modes other than the car. 7,000 light vehicle movements (employee
cars and vans carrying goods) into and out of the site are forecast for
the 24 hour period when the facility is fully developed.
5.9 Parking provision would be 1,665 car spaces and 617 HGV spaces.
5.10 The applicant has submitted a comprehensive Travel Plan with the
application setting out targets for non-car modes of travel for workers
and how these could be achieved.
5.11 The application is an outline application to cover siting, including local
impacts such as noise and air quality, landscaping, access (both road
and rail) and demand and the need for the facility. The development
site is 146 hectares of which 86 hectares are proposed for landscaping,
including large bunds between Frogmore and the new bypass to mask
the views and reduce noise from the development from this aspect.
5.12 The proposals indicate major land remodelling to reduce the visual
impact of the development from the surrounding area. As part of the
Inquiry process, the wider landscape impacts of the development were
also considered.
5.13 Most of the development area (known as Site 1) within the former
Radlett aerodrome and quarry has been worked for minerals and has
been restored generally at the lower, post extraction, level. The site is
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 6
currently being used for agriculture (grazing) and woodland. Rail
access to the development area will be via a spur from the Midland
Main Line (MML) which will pass through part of the Harper Lane
Quarry, located to the east of the MML and north of the M25 motorway
(Site 2). Site 2 has previously been worked for minerals and restored,
in part by landfill although the restoration quality at this site is not to the
same, modern standard as Site 1.
5.14 The application also includes 6 other parcels of land in the area (247
hectares) known as Sites 3-8. Of these, two to the north are river valley
areas (Sites 3 and 4) where there is no known history of mineral
extraction or landfill. The southern part of Site 6 at Smug Oak Lane
also has no known history of mineral working or landfill. The remainder
are all former mineral workings and landfills, one located to the west
(Site 5 at Moor Mill), one to the south-west (northern part of Site 6 at
Smug Oak Lane) and two located to the east (Site 7 on part of the
Harper Lane and Site 8 at Bell Lane). These former mineral workings
are now restored (though to varying standards) reflecting the age of the
different sites and the relevant planning requirements that applied at
the time for each. Several of these sites (Moor Mill, the northern part of
Smug Oak Lane and Bell Lane), have all previously been identified by
the County Council as well as by the Watling Chase Community Forest
as meriting possible re-restoration in all or part, to address known
problems with the current condition of the land.
5.15 The applicant proposes further landscaping and other works, including
earth mounding and substantial tree planting, within these areas to
provide publicly accessible open land and community forest. They
intend to create nearly 250 hectares for Country Park and recreation
uses with improved access to the countryside which is offered as a
benefit to the local area. The proposals do not however, include the full
re-restoration of the damaged areas at Moor Mill and Bell Lane but
conversely, do acknowledge the existing established scheme to re-
restore the land north of Smug Oak Lane, this having been granted
planning permission by the County Council under ref. 5/1811-04 in
March 2007. Though not yet implemented, the planning permission at
Smug Oak Lane remains extant and it is expected that the
development will begin either later this year or in early 2010. The
proposals for the former landfills may also be affected by potential
contaminated land issues that may arise and these in turn, could
impact upon the proposals. However, these are matters for the
Environment Agency and St Alban‟s Environmental Health‟s
Contaminated Land Officer to consider. Again, these matters were
considered during the inquiry and both the Inspector and Secretary of
State agreed that these could be addressed by conditions.
5.16 This would not be a Country Park in the normal sense of the term. It
would mean substantial areas of countryside and former mineral
workings from Moor Mill to Broad Colney, all within the Watling Chase
Community Forest, would be managed in the public interest and linked
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 7
with rights of way for public access. However, the details of how this is
to be achieved and responsibilities for future management were not
determined at the Inquiry, nor was it established with certainty whether
there might be a need to carry out other re-restoration or environmental
improvement works associated with the old mineral workings and
landfills until a more detailed site assessment has been carried out. It
was the Inspector‟s view however, that these matters could be
addressed by condition and the Secretary of State agreed.
5.17 The whole of the application site is within the Green Belt and within the
Watling Chase Community Forest. As a restored mineral working the
airfield would be defined as a green field site.
5.18 In summary, the proposal is for a major rail served warehouse
development on the former Radlett aerodrome site within the greenbelt
south of St Albans. Neighbouring areas would be planted and
landscaped to provide approximately 250 hectares of Country Park with
public access in the Watling Chase Community Forest area. The site
will provide significant employment opportunities, although only a small
proportion is expected to be sourced from the local area, and will
generate significant traffic flows on the existing highway network and
the proposed Park Street / Frogmore bypass.
6. Planning Process
6.1 The application will be determined by St Albans City and District
Council as the local planning authority. They intend to do so within the
statutory 16 week period at a meeting of their Referrals Committee on
20 July 2009. The County‟s Development Control Committee is to
determine the County Council‟s response.
6.2 The County Council has been consulted as Highway Authority and on
environmental/ecological/landscaping/country park issues. Officers will
look again at these issues to consider whether circumstances have
changed since the original application but any response will need to
have regard to the Inspector‟s findings at the Inquiry.
6.3 For the previous application, the County Council was also consulted on
strategic planning issues including greenbelt. With the demise of the
County Structure Plan, strategic issues are now regional planning
matters. The East of England regional Assembly (EERA) have been
consulted on the current application.
6.4 Members will wish to consider whether the objections put forward by the
2006 DC Committee can be said to still apply. Those objections were
(Resolution of Committee):
That the planning application should be refused because:
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 8
a The application has been submitted in advance of a region wide
study of potential Strategic Rail Freight Interchange locations. It
would be premature to permit the development in advance of the
findings of the EERA commissioned Regional Freight Strategy and a
wider greater south east study by the Regional Planning Bodies (in
line with Department for Transport guidance)
b The applicant‟s Alternative Site Assessment is inadequate in being
limited to a small sector of the east and south east regions and
producing results which appear contradictory.
c) A Strategic Rail Freight Interchange site to the north of London, such
as Radlett, is not well placed to meet the forecast arisings of demand
and is unlikely to achieve the benefits intended from increasing rail
freight at the expense of road freight.
d) The „very special circumstances‟ that are required to warrant
permitting this development in the Green Belt have not been
demonstrated and the application should therefore be refused.
e) According to the applicant‟s Traffic Assessment, a fully operational
Strategic Rail Freight Interchange will increase traffic on the A414 by
over 10%. As the A414 is already near capacity, the County Council
is particularly concerned with the following aspects : -
1) The safety and congestion aspects of the location and design of
the new roundabout on the A414. The proposed roundabout is
not large enough to provide sufficient capacity for queuing traffic
creating unacceptable safety issues.
2) The increase in traffic on this section of the A414 will be
significant and the ability of the proposed traffic lights at the Park
Street and London Colney roundabouts to handle the extra traffic
is questioned.
3) The amount of traffic to be generated may have been under
estimated. There is no guarantee that the Strategic Rail Freight
Interchange will operate as currently envisaged. The proportion
of road based freight operations may increase beyond that
anticipated increasing the level of HGV traffic generation.
4) The impact, beneficial and adverse, of changing flows on the
A5183. The environmental benefits and disbenefits of the Park
Street Bypass are inadequately assessed.
f) The application site is poorly located to attract the necessary staff
and achieve the potential economic spin-off benefits from a Strategic
Rail Freight Interchange contrary to the expectations of Strategic Rail
Freight Interchange locational policy. It will not be of benefit to the
Hertfordshire economy and a location in a Regeneration Area would
be preferable.
g) The target non car mode share for journeys to work of 35% is
considered unachievable on the evidence presented given the
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 9
widespread residential location of the labour force and the lack of
detail on improvements to public transport services to the vicinity of
the site.
h) The proposals for country park and landscape and ecological
improvements intended to mitigate for the losses associated with the
development are unacceptable in scale, outcome and detail and the
process and funding of a long-term management regime is not
determined. No permission should be granted until these matters are
satisfactorily addressed.
i) The proposed measures to mitigate the landscape impact of the
development are not sufficient to compensate for the loss of this
greenfield site.
j) The loss of this area of Green Belt is unacceptable because of the
impact this would have on the Green Belt area south of St Albans
as a whole.
6.5 The present proposal is a new application and should be considered on
its merits. However, any response must take account of the Inspector‟s
findings and the weight he placed on those findings in balancing the
issues to arrive at his recommendation and consider whether there
have been any changes in policy or circumstances to warrant a
different view. The findings are considered in the following sections
dealing with the issues.
7. Land Ownership Information
7.1 The development site (Radlett Aerodrome) is now owned by the
County Council after Lafarge Aggregates transferred ownership of it to
the County Council in October 2006. It is leased back to Lafarge so the
restoration and aftercare of the mineral workings can be completed.
Most of the „country park‟ area to the west and east is owned by
Lafarge with Veralum Estates owning other surrounding areas.
7.2 The land is subject to a restrictive covenant, enforceable by Lafarge,
requiring no buildings to be erected and the land not to be used for
other than Green Belt uses (open space, agriculture etc). This
covenant could be changed with the agreement of Lafarge.
7.3 Landownership was not however relevant to determining the original
planning application nor should it be in this case.
8. Representations
8.1 For the previous application the County Council received a large
number of letters (over 125) objecting to the proposal and none in
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 10
favour. So far only a few have been received on the new application,
although this could be due to the short timescale.
9. Strategic Policy Background
9.1 The policy background to the provision of rail freight interchanges is set
out in the documents supporting the application. The desirability of
increasing the carriage of freight by rail to reduce road borne freight
and therefore road traffic is a feature of national (Sustainable
Distribution Policy 1999), and regional (East of England, South East
Regional Spatial Strategies and the London Plan) policy.
9.2 Development proposals must be in accordance with the development
plan unless material considerations indicate otherwise. The relevant
part of the development plan for the purposes of determining this
application is the East of England Regional Spatial Strategy (RSS).
The Hertfordshire County Structure Plan (adopted 1998) has no saved
policies which are relevant (Policy 30 supported an increase in the use
of rail at the expense of road with rail depots for freight to be supported
at suitable locations in the County) and the St Albans District Plan 1994
does not refer to rail freight issues, although other policies such as that
relating to Green Belt will apply.
9.3 Policy T10 of the RSS states:
Priority should be given to the efficient and sustainable movement of
freight, maximising the proportion of freight carried by rail and water
where those are the most efficient modes;
High priority should be given to measures to provide adequate
rail freight capability and capacity on routes to the region‟s major
ports of Bathside Bay (Harwich), Felixstowe, London (including
Tilbury) and London Gateway;
Provision should be made for at least one strategic rail freight
interchange at locations with good access to strategic rail routes
and the strategic highway network, unless more suitable
locations are identified within London or the South East for all
three to four interchanges required to serve the greater south
east;
In this it reflects national freight policy as set out for example in the
1998 Integrated Transport White Paper and the Sustainable
Distribution Strategy. These highlight the benefits of moving freight by
rail and the need for adequate facilities for the whole of the supply
chain.
9.4 The need for distribution facilities was considered by the Strategic Rail
Authority (SRA) in their SRFI Policy March 2004. It indicated that the
required rail freight capacity in London and South East, as determined
by their analysis, „would be met by three or four new SRFIs in the
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 11
region‟. The qualitative criteria to deliver this required capacity would
mean „that suitable sites are likely to be located where the key rail and
road radials intercept with the M25‟.
9.5 With the demise of the SRA the Department of Transport (DfT) took
responsibility for rail freight. The DfT determined that much of the
interchange policy was still relevant though it has not been adopted
formally as Government policy. The DfT Guide for Producing Regional
Transport Strategies (RTS) makes clear that „adequate and suitably
located facilities for inter-modal freight interchanges (i.e. facilities for
transfer between road vehicles and rail, sea, inland waterways and
airfreight) are vital to fulfilling national policy objectives in relation to
freight transport.‟
9.6 The DfT Guide goes on the say that the Regional Planning Bodies
(EERA etc.) „should consider the best approach to assessing issues
and options for freight interchanges as part of the background analysis
for the Road Transport Strategy. As a result of necessary analysis
(and, where appropriate, appraisal of proposals) the regionally
important locations for inter-modal freight interchanges should be
identified and safeguarded in the RTS. The RTS should make clear
where regional and national needs have to be accommodated within
local development and transport plans.‟
9.7 This policy background informed the East of England Regional Spatial
Strategy (RSS) and Regional Transport Strategy (RTS). The Panel
Inspector recommended a freight policy (T10) including the statement
that; “provision will be made for at least one strategic rail freight
interchange within the East of England, at a location with good access
to the strategic rail routes and highway network”.
9.8 The regional planning process has not however identified specific sites
and locations as anticipated by the DfT nor has it addressed whether
the interchange already permitted at Alconbury meets the region‟s
requirements.
9.9 The South East RSS has a similar policy (Policy T13) which requires
the Regional Authority to work with other stakeholders „to identify broad
locations within the region for up to three intermodal interchange
facilities‟.
9.10 However, the Regional Assemblies, the Mayor of London and the DfT
have not jointly commissioned research to identify the most appropriate
approach to dealing with the freight needs of the capital and wider
south east. As a consequence there remains no technical work
available to the development plan processes in London and the two
regions on the most appropriate approach to SRI provision in the south
east. The East of England Freight Strategy published in 2008
supports the development of additional rail freight and intermodal
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 12
terminal facilities in the region but does not specify where these should
be.
9.11 In 2006, county officers were of the view that, in line with DfT RTS
guidance, the most suitable locations for strategic rail interchanges to
serve the capital and the wider south east region should be explored by
robust technical studies taken forward collaboratively by the
assemblies and the DfT, covering the entire periphery of the capital. In
the absence of this technical work and the findings tested and taken
forward by responsible bodies (regional assemblies and relevant
district/borough councils) through the relevant aspects of the
development plan (regional spatial strategies and local development
frameworks) the original application was considered by the local
authorities to be premature.
9.12 The Inspector took the view (paragraph 16.112 of his report) that this
argument only holds good if there is a reasonable prospect that such a
study is likely to be undertaken and its findings accepted. He
concluded (16.114) that refusal on prematurity grounds should not be
supported and the Secretary of State (SoS) agreed (SoS40).
9.13 Since the Inquiry any work on a possible interregional study has been
delayed to ensure that the regional review of logistics is consistent with
the government‟s review of national transport policy through the
„Delivering a Sustainable Transport‟ (DaSTS) process initiated in 2008.
However, the London Assembly is now expected to carry out further
investigative work into freight transportation in and around the London
area as part of the forthcoming review of the London plan.
9.14 It is expected that EERA will support such work although it is still
uncertain whether or not a technical study at an interregional level will
emerge. Such a study would enable other potential sites, such as in
the ThamesGateway eg Shellhaven in Thurrock, to be considered in an
East region context.
9.15 Furthermore, any application for an SRFI the size of that proposed at
Radlett would under the Planning Act 2008, be considered „nationally
significant infrastructure‟. Under the new consent regime not yet in
force, it would be determined by the Planning Commission under the
relevant National Planning Statement (NPS). It is expected that a NPS
for freight (National Networks) will be published for consultation in the
Autumn which would influence the location of such developments
across the United Kingdom. There could therefore still be an element
of prematurity to the Helioslough proposal.
9.16 In the absence of a regional study of potential locations the applicant
has chosen to concentrate the search for a site in the „north west‟
sector between the M4/Great Western Main Line and the A1(M)/East
Coast Main Line (see section 11).
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 13
9.17 The northern sector around London is arguably not the area most
suited to meet the demand that the applicant has identified. Freight
arising from Southampton and the Channel Tunnel bound for London
would be better catered for in the west where the rail journey is shorter
and does not involve cross-London routes and similarly freight from the
Haven Ports and the Thames would be better catered for in the east for
the same reasons. However, the applicant claims a site in this sector
would be particularly well placed to serve the north west London
market.
9.18 The policy aspect is extremely important in regards to Green Belt policy
as well as rail freight policy. The application site is located within the
Green Belt so the applicant has to demonstrate that „very special
circumstances‟ exist to warrant overturning Green Belt policy to permit
the development. The applicant has sought to do so quoting the
general rail freight policies and the SRA‟s conclusions regarding the
need for new capacity together with the analysis of sites which showed
that were an SRFI to be located close to the M25 around London it is
highly likely it would have to be in the Green Belt.
9.19 As would be expected, harm to the Green Belt formed an important
element of the Inquiry. There is no dispute that the development would
constitute inappropriate development and it is up to the applicant to
demonstrate that harm to the Green Belt is clearly outweighed by very
special circumstances that justify granting planning permission (16.1).
9.20 The Inspector concluded that the need for SRFIs to serve London and
the South East was capable of being such a consideration (16.202) and
the Secretary of State agreed (SoS 58). However, the Inspector and
the SoS were not convinced from the applicant‟s „Alternative Sites
Assessment‟ that they had adequately demonstrated that no other site
would come forward to meet the need for further SRFIs and the
Inspector considered this failing to be critical.
9.21 The same concerns were raised at the Public Inquiry for the SFRI at
Howbury Park in Kent. However, both the Inspector and the SoS
concluded in that instance that the alternative site assessments
satisfactorily showed that there were no other suitable sites within that
(southern) area of search. The application was subsequently approved
as exceptional circumstances existed, warranting greenbelt release.
9.22 National and regional transport policy identifies the importance of
facilitating an increase in rail borne freight. In particular, it identifies the
need for three to four strategic rail freight interchanges to serve London
and the South East. Given SFRI requirements, suitable sites in the
south east are limited and the majority are located in the metropolitan
green belt. The Inspector at the 2007 Public Inquiry concluded that the
need for an SFRI is an exceptional circumstance that could out weigh
the harm to the green belt and the Secretary of State agreed. The
same approach was taken at the inquiry into the SFRI in Bexley.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 14
Studies on rail freight opportunities may be taken through the London
Plan review and include areas on the London periphery.
10. Operational Factors
10.1 The proposed Radlett Airfield site does meet some of the criteria
referred to by the SRA in that it is well located in relation to the M25
and radial routes to serve London markets. In rail operational terms it
is not ideal in that the Midland Main Line (MML) is not a major freight
route and freight trains to Radlett from the ports, the Channel Tunnel or
origins elsewhere in the UK would require access from cross London
routes such as the North London line.
10.2 The Inspector was not convinced this was of great weight (16.70).
However, it does mean trains accessing the site from the West Coast
Line (the main freight line from Scotland and the north), would have a
time consuming detour. If the main demand is from the Haven and
Thames ports access is easier but there is some question as to
whether rail would be a favoured mode for such a relatively short
journey.
10.3 Network Rail were of the view that there should be sufficient capacity
on the MML for the forecast 12 trains (24 in and out) every 24 hours.
With one per hour on average this should not disrupt local services in
the Inspector‟s view (16.65). The rail operator (First Capital Connect)
were concerned as to the impact on their services and with work
starting on ThamesLink and have again expressed concern regarding
the new application. The Inspector was satisfied that in the longer term
freight capacity of the London crossings on which Radlett would rely
was likely to be available (16.71).
10.4 The MML only has a freight gauge of 8 between London and Radlett
(and gauge 7 north of Radlett) while major freight lines such as the
West Coast Main Line and Great Eastern Main Line have a gauge of
10. This limits the size of container and wagons which can be handled
and therefore the potential of the facility.
10.5 The applicant intends to improve the gauge between London and the
site but the details of the work that would be required and the source of
funding remain matters to be determined. The Inspector recommended
a condition be imposed that only a part of the development (175,000
sqm) should be occupied before the Gauge 10 works are completed.
Network Rail has recently announced a long term aim to increase the
gauge of the MML north of Radlett (Strategic Freight Network: The
Longer-Term Vision May 2009) but this is not programmed.
10.6 The authorities were concerned that potential rail operation problems in
the future could mean that the facility would fail to realise the levels of
train borne freight predicted and will then have to attract increased
levels of road borne freight, therefore taking on the characteristics of a
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 15
typical, if very large, distribution warehouse depot. The potential for the
development to act as a road to road interchange was an issue
considered at some length at the Inquiry but the Inspector was of the
view that having invested in the rail infrastructure the operators would
ensure the facilities were used and road hauliers would look for
cheaper premises elsewhere (16.153). However, there remain some
uncertainties as to the true level of demand in the long term.
10.7 The limitations of the Midland Main Line to provide the required rail
freight capacity without unacceptable disruption to other services were
discussed at the 2007 Inquiry. The inspector dismissed the concerns
including those that the facility could become increasingly road based
but it is understood that First Capital Connect are still concerned and St
Albans have appointed consultants to review rail issues.
11. Alternative Sites
11.1 Demonstration that there is no alternative site that could come forward
to meet the need, with less harm to environmental and most
importantly, Green Belt interests than the proposed site is essential if
the planning permission is to be granted. Having failed to convince the
Inspector with the original study of alternative sites the applicant has
carried out a further study to address the flaws highlighted at the
Inquiry.
11.2 The applicant has continued to limit this study to his chosen M4 – A1(M)
sector (the East Coast Mainline to the Great Western Main Line
including the Midland Main Line and the West Coast Main Line). There
is no policy basis for this. The Inspector accepted it was reasonable to
limit the study to this sector given the intention to serve the north west
London market (16.125) but there is still a lack of detailed data on
forecast demand.
11.3 The key assessment criteria for arriving at a long list of sites were
5 km of any railway line (was 2 km previously)
5 km of a motorway junction or „A‟ road
Minimum of 40 ha of developable land
Between the A1(M) and M4 within 32 km of an M25 junction.
11.4 72 sites (from 118) were shortlisted and of these 4 sites plus Radlett met
the applicant‟s operational and other criteria. One of these sites is that
at Colnbrook, Slough which was refused permission in 2002 but where
it is understood a developer remains interested in bringing it forward.
The site is not included in Slough Borough‟s Core Strategy but the
strategy sets out criteria for such a development.
11.5 Two of the shortlisted sites are north of Luton at Sundon and Hartington
and their absence from the original final list was queried at the Inquiry.
The fourth site is west of Maidenhead in the Berkshire Green Belt and
seems to serve to show how few sites to the north and west of London
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 16
there are for consideration for such a massive development as an
SRFI.
11.6 The alternative sites assessment was subject to detailed analysis at the
Inquiry and the new study warrants a similar level of study. With one
SRFI in the south (permitted in Bexley) and potentially one in the east
(Thames Gateway could be seen as meeting demand noted in RSS
policy T10) there would remain a (SRA) policy requirement for one or
two more. How such requirement is met should depend on up to date
analysis of the market demand and an inter-regional study in the light
of a National Policy Statement.
11.7 The alternative site assessment is essential if development in the green
belt is to be justified. The Inspector did not accept the previous
assessment and the applicant sought to address the failings. The new
alternative site assessment study is still limited to the north west sector
and shortlists four sites as alternatives to Radlett. Not all of these sites
were short listed in the 2006 study, however there is still some concern
over the current methodology and it is currently being assessed by
consultants retained by St Albans City and District Council. It is
anticipated that the outcome of this work will help inform the county‟s
response.
12. Economy and Employment
12.1 An SRFI requires a large work force and the SRA in their 2004 policy
refer to the presence of an available and economic workforce as an
„increasingly important determining (locational) factor‟ in the effective
siting of such facilities. „When major distribution facilities can employ
well in excess of 1,000 people, the economics of access to a reliable
and skilled workforce, employable at economical cost, is of high
importance‟ (Paras 4.26 and 4.27 SRA SRFI Policy March 2004).
12.2 The Policy document goes on to comment on the potential for locating
further employment uses near to an SRFI. In this respect it says SRFIs
should be seen not simply as rail specific activities „but a key element
of spatial planning for employment development‟. The Park Street, St
Albans area is clearly not an area for major employment growth nor
does it offer a workforce to service one.
12.3 The applicant estimates that when the proposed facility is fully
operational the level of on site employment generated will be „about‟
3,385 jobs. This is based on a job to floorspace to ratio of 1 to 100
sqm which is probably a reasonable basis for this type of forecast.
12.4 68% of the total would be classified as warehouse staff, 11%
administration or support staff, 7% managerial and 13% drivers. 74%
of workers (2500) would be classified as “process, plant and machine
operatives”.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 17
12.5 This is a large number of relatively low skilled jobs which would be
welcome in many parts of the country including those areas in need of
regeneration elsewhere in the East of England. However, in this part of
Hertfordshire with its low unemployment rate even in recession (2.1%
in St Albans April 09) and high skill levels (3.67% of workers in St.
Albans District are process, plant and machine operatives compared
with 8.42% in England – 2001 Census). Such numbers cannot be
sourced locally to Radlett or in the surrounding area.
12.6 The applicant recognises this and suggests staff would be drawn from
the area within 30 minutes drive time of the site. This wide area
extends across north London and up to Luton and has a total (2001)
population of 2.8 million with 64,000 unemployed and 79,000 process,
plant and machine operatives. With this labour pool, therefore, the
applicant‟s claim that the Radlett facility would have no problem
attracting the 3,385 staff required.
12.7 At the Inquiry 34% of workers (1,164) were estimated to come from
Barnet, Brent, Enfield and Harrow, 10% (331) from other parts of
London and 10% (350) from Luton. Just 14% (477) were estimated to
live in St Albans town, Park Street/Bricket Wood/Colney Street and
London Colney, with nearly 6% (194) in Watford.
12.8 The Inspector accepted that very few of the workers would live close to
the site but did not see that as a critical factor in the SRA‟s list of key
factors for SRFIs (16.100). However, it does mean that any potential
role an SRFI could play in the regeneration of an area would not be
realised if that SRFI were located at Radlett. Ideally the 3-4 SRFIs
would have been located to achieve regeneration where it is needed
and where workers could access the site through sustainable modes of
transport. The SoS agreed with the Inspector (SoS 39), that the site
performed badly with regard to “proximity to workforce”. However, she
agreed that the proximity to the workforce is an important, rather than a
critical factor to the location of an SRFI, although she did acknowledge
that no one at the inquiry had challenged the workforce issue per se.
12.9 The proposal will therefore generate significant employment
opportunities but, due to the nature of the work and the location of the
site, less than half of these are expected to be taken by Hertfordshire
residents and only a small proportion would be local to the
development. The SRFI would not contribute to regeneration and
would make sustainable travel to work difficult to achieve.
13. Highways and Transport Issues
13.1 Traffic generation, and the impact it will have on what are seen to be
already congested local roads, is a matter of particular concern to the
County Council as Highway Authority. The Highways Agency (HA) is
responsible for the motorways and the newly reclassified section of the
A414 which was formerly the M10 and the County Council the A414
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 18
and A405 and the roundabouts as well as the other local roads. The
applicant‟s Transport Assessment report (TA) was considered at the
Inquiry, and questioned by a County Council witness, but has been
reproduced with little change for the new application.
13.2 The principal access to the site would be from the A414 with a new
signalised roundabout constructed near to Hedges Farm. The A414 is
a primary route, „detrunked‟ in 2003, but still the highest level in the
county strategic route network. The County‟s Local Transport Plan
(LTP) has a presumption against new access points on the primary
route network. Technically the new junction would impede the free flow
of traffic but the Inspector took the view that that there was no practical
alternative to a direct link onto the strategic road network and minimal
weight should be given to this objection (16.76).
13.3 Traffic generation will result from the HGVs moving the freight from,
and to, the facility, the employee‟s cars and a range of „white vans‟ both
carrying freight and servicing the site. The main access will be from
the new roundabout on the A414 with a lesser access largely for cars
and vans to the south to the A5183, the link between them forming a
bypass to Park Street and Frogmore.
13.4 The applicant estimates that when the facility is fully operational traffic
generation will be:
Traffic Generation (vehicles)
Light HGVs Total
Vehicles
AM Peak (0800-0900) 494 202 696
PM Peak (1700-1800) 491 185 676
24 Hour AADT 7,057 3,197 10,254
13.5 The figure for HGVs is based on operations (in 2005) at the DIRFT site
in Daventry, a successful rail based freight interchange, and at Magna
Park, a major road based distribution centre. The estimates for Radlett
assume that about half the facility is used for rail based freight and the
other half for road based (road in, road out) freight. Of the forecast
3,197 HGV movements 1,126 are estimated as rail related and 2,071
road related. There is no certainty the facility will be half rail and half
road and any increase in the proportion of road based freight will cause
a disproportionate increase in HGV movements.
13.6 It is also quite possible the operation could seek to expand in the
future. This would require a new planning permission but this might be
difficult to refuse once the proposed development is in place.
Expansion would inevitably increase forecast traffic generation. The
Inspector chose not to recommend any condition being imposed on a
potential permission which would place a limit on the number of
vehicles using the site.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 19
13.7 The figure for light vehicles includes both employee cars and white
vans. The Travel Plan submitted anticipates 65% of employees would
travel by car, with an intention to reduce this to 50%, and a maximum
demand for 1665 parking spaces. 3,000 workers a day would therefore
generate 2,000 employee car journeys (4000 in and out) the majority
arriving and leaving when the shifts change (06.00, 14.00 and 22.00
hours).
13.8 The County Council at Inquiry raised serious doubts as to whether the
site could achieve a car mode share as low at 65% (see below section
14). Whatever the figure, the majority of employee traffic will be
travelling well outside of the peaks when it would have less of an
impact on local roads, but would still be a considerable increase on
existing traffic flows.
13.9 The majority of the traffic is predicted to use the A414 access, 97% of
the HGVs and 67% of the light vehicles. If this were a constant
proportion the flows onto/from the A414 would be:
Light HGV’s Total Existing
Vehicles (2004) Flows
AM 331 196 527 4372
PM 329 179 508 4528
24 Hrs 4728 3101 7829 55830
13.10 The A414 is already an extremely busy road with flows on this section
some of the highest non-motorway flows in the county. The applicant
shows that with a fully operational SRFI the traffic would add around
12% to existing (2004) flows on the road. Typically a traffic increase of
5% is considered to be a material increase.
13.11 The TA states that between 2004 and 2008 there has been little
change in traffic flows on the major roads in the area. The implications
of the opening of M1 widening scheme and the previous congestion
caused by the roadworks still needs to be assessed in discussion with
the HA. Since the Inquiry, Butterfly World has been opened (alongside
the Gardens of the Rose) and with an access to the A405 near the
Noke roundabout. The potential impact of visitor traffic particularly in
the evening peak when added to the forecast development traffic
needs to be assessed.
13.12 The increase in development traffic will affect the operation of the Park
Street and London Colney roundabouts. A great deal of time at the
Inquiry was spent discussing potential mitigation of the capacity
problems at these roundabouts. The Inspector concluded that limited
improvements to these roundabouts including introducing traffic lights
onto the 3 major arms of the Park Street roundabout and improving
those on the London Colney roundabout (to upgrade the system) would
be adequate to ensure congestion would be no worse with
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 20
development than without (16.81). These improvements would be
required by condition/Section 106 obligations.
13.13 In this conclusion the Inspector appears to have relied heavily on the
views of the Highways Agency (HA) rather than the concerns of the
County Council. The HA have issued a Holding Objection to the new
application (as they did for the previous one) subject to further
technical work being undertaken and as Highway Authority the County
Council will be in discussion with the HA regarding traffic conditions
and any changed circumstances since the Inquiry. Of particular
concern is Junction 21A on the M25, the forecast level of traffic in the
area without the SRFI (including any impact from the newly opened
Butterfly World) and the increase in levels of traffic accidents at the
Tippendell Lane roundabout on the A405 (the roundabout has now
been identified as a Hazardous Site). All aspects are being
reconsidered (a process which will probably extend beyond July).
13.14 Of course when the M25 is congested or closed by an accident
additional traffic will use the A414 and other local roads. The Inspector
accepted rat-running is of concern locally but took the view it would
exist as a result of congestion with or without development (16.82).
13.15 An important element of the proposal is the bypass for Park Street and
Frogmore. This is put forward as a positive benefit of the development
as it will reduce traffic, including the existing heavy goods traffic,
through the villages and allow traffic calming measures to enhance the
local environment. Some of these benefits, the reduction in road noise
for instance, are used by the applicant as a trade-off for the impacts of
the development, for instance the increase in noise levels at some
dwellings.
13.16 The bypass as proposed would extend from the A414 at the new
access roundabout to join the A5183 at the southern end of Frogmore
with two links, the main access for the A5183 south being signalised.
In time the applicant proposes to replace the signalised link with a new
realigned bridge over the M25. However, the cost and the need to
agree the details with the HA must make such a future improvement
somewhat uncertain and the extent of the works that it would fund
needs to be assessed.
13.17 The existing road through Frogmore and Park Street would be traffic
calmed to discourage through traffic. The applicant has offered
£300,000 as a contribution to fund traffic calming and associated
townscape works on this section of the A5183. Such a contribution
was discussed at the Inquiry but not agreed by the County Council.
13.18 The County highway authority witness strongly questioned the
applicant‟s forecasts of the reduction in traffic levels through Frogmore
and Park Street and the Inspector agreed there was doubt as to the
level of reduction (16.75). He was though satisfied this would not have
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 21
wider traffic implications (16.186). He (16.23) and the SoS were
satisfied that the bypass in removing some through traffic would be
beneficial to the Frogmore and Park Street Conservation Area (SoS
28) and that it should be counted as a benefit of the development.
13.19 Existing flows on the A5183 south of Radlett village are about 10,000
per (16 hour) day. Congestion is particularly bad at Elstree in peak
hours. The majority of the forecast SRFI traffic using the southern
access (33% of the light vehicles, employees and vans, 2,350 per 24
day) would travel outside the peak hours but a 10% increase in peak
hour traffic through Elstree is anticipated. The Inspector took the view
that congestion already existed at Elstree and measures will, in any
event, be needed to provide relief there so limited weight should be
accorded to this matter (16.86).
13.20 The applicant has offered no mitigation for Elstree and at present there
are no measures proposed by the local authorities to deal with
congestion there and any resulting air quality issues. While the
Inspector placed limited weight on this issue in balancing all the issues
in the overall decision on the development it remains a matter of
concern.
13.21 Prior to the Inquiry officers were of the view that:
The design of the new roundabout on A414 will be inadequate in
terms of congestion and safety to acceptably handle the forecast
traffic generation.
Traffic queues at the 2 existing roundabouts even with the
proposed traffic lights will increase to the detriment of existing
users.
The forecast traffic levels of the SRFI could be underestimating
the potential impact and changes to the assumed
origin/destinations which could further affect the predicted
impacts on traffic flows.
The benefits in terms of traffic reduction and traffic calming
measures of the Park Street/Frogmore Bypass may be
overestimated as the level of local and remaining through traffic
is likely to be greater than predicted.
There will be environmental implications for Radlett and Elstree
villages on the A5183 arising from the increase in traffic
associated with this development and these should have been
addressed by the applicant.
These were the reasons for refusal submitted to St Albans DC and on
which an officer of the County Council gave evidence.
13.22 Despite the case being strongly argued, these views were not accepted
or were given limited weight by the Inspector in determining whether
permission should be granted and the Secretary of State agreed.
Officers will now review the position along with the HA but unless
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 22
circumstances can be shown to have changed significantly since the
Inquiry there does not currently appear to be justification for the refusal
of this application on highway grounds.
14. Employee Access
14.1 The applicant recognises that to meet the PPG13 transport policy
requirements appropriate arrangements will have to be made to
provide good access to the development for employees by non-car
mode. These measures will include contributions to infrastructure
improvements and measures to encourage employees to travel by
sustainable means with funding secured through planning obligations.
14.2 The site is not well served by existing passenger transport services at
present with limited bus services through Park Street and Park Street
railway station on the Abbey Line branch having a constrained
timetable. However, with the majority of workers on a shift system the
applicant envisages a big role for shuttle buses (from St Albans and
Radlett railway stations and from locations in London) and car sharing.
The current proposals for shuttle buses to link the site with local rail
stations are not favoured by the County Council‟s Passenger Transport
Unit as they are a private service and would not serve the wider
community. The County Council will require the shuttle services to be
introduced as a scheduled service however; this could be addressed by
conditions and obligations.
14.3 As part of these measures the applicant (section 7 Helioslough‟s
Planning Policy Report) is now offering Hertfordshire County Council
£150,000 for improvements to Park Street Station and £200,000 as a
contribution to the passing loop on the Abbey Line as well as £450,000
to provide and improve footways, bridleways and cycleways in the
vicinity of the site. These obligations and conditions will need to be
considered in detail, however the Inspector concluded that the current
proposals for the provision of alternative transport to the car was
acceptable, and would not warrant refusal of the application (16.103 –
16.108). The Secretary of State agreed (SoS39).
14.4 The applicant‟s Travel Plan has an initial target of 35% of employees
travelling by sustainable means, 65% as car drivers. At the Inquiry the
County Council queried whether such a level of sustainable travel could
be achieved given the wide area from which employees would be
drawn and the lack of any direct passenger services from these areas.
14.5 The Inspector shared this concern but took the view that with a limit on
car park spaces tied to figure of 65% car drivers together with the
monitoring and controls contained in the Travel Plan there was real
incentive for employers to work towards reducing car usage. He
concluded that while the site‟s sustainability credentials are poor it
would not be reasonable to refuse permission on account of
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 23
sustainability concerns relating to the workforce‟s likely pattern of travel
to work (16.194).
14.6 It might be argued the new PPS1 supplement and its sustainability
objectives were not considered by the Inspector at the previous inquiry
and this could change the weight he gave to the issue. The Inspector
did though note the site‟s sustainability credentials were poor and it is
questionable whether the supplement makes those credentials worse
than was recognised at the time.
14.7 It might be noted that one improvement which would increase
accessibility would be the provision of a new station at Napsbury. The
developer has ruled this out of his proposals but has stated that his
application would not prevent a new station being built.
14.8 Employee access was considered at the Inquiry and concerns were
raised about the proposal‟s ability to meet sustainable transport
objectives. In her decision letter, the Secretary of Stated agreed this
would not be reasonable to refuse permission on this ground (SoS 39).
Despite the best intentions of the proposed Travel Plan there must be
doubt as to how such a widely spread workforce can be served in a
sustainable way, but these doubts were given limited weight in the
previous decision.
15. Landscape Ecology and Country Park Recreation
15.1 The impact on the landscape and landscape character of this huge
development is a matter for the District Council. The applicant accepts
there would be a deleterious impact on the landscape and the
Secretary of State agreed with the Inspector that the current landscape
value of the development site is „high‟ and the impact „significant
adverse‟ (16.14 & SoS 25), with a substantial impact on the openness
of the greenbelt and significant encroachment into the countryside
(SoS20).
15.2 The development site has no ecological designation and the Inspector
took Natural England‟s advice that there were no legally protected
species found on the site in concluding that the harm resultant from the
proposed development to the underlying ecological interest would not
be significant (16.179). There are however elements of ecological
importance (for example the breeding site for waders) which the
Inspector may have under valued and where adequate compensation
in the form of alternative sites has not been assured.
15.3 Over half of the total application area is dedicated to providing publicly
accessible open space and other areas of community forest. The
indicative proposals include new areas of woodland and managed
countryside, a Country Park visitors centre and picnic areas,
improvements to existing footpaths and provision of new ones, nature
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 24
trails and cycle routes, equestrian facilities, playing pitches and
enhancement and creation of new habitats.
15.4 Much of the proposed Country Park area is agricultural grazing land
with established footpaths and bridleways already allowing public
access to the countryside and some of the proposed landscaping
shown is already in existence. However, significant areas of woodland
would be planted which would accord with the aims of the Watling
Chase Community Forest.
15.5 The Inspector noted that the „country park‟ proposals attracted
considerable criticism and that they would not deliver a „country park‟ in
the sense the term is generally understood. The six areas of land are
not contiguous and there would be only limited visitor facilities and
parking. Notwithstanding this he had no doubt the proposals including
the new footpaths would be beneficial to the countryside (16.146) and
the SoS agreed (SoS 46).
15.6 Despite the considerations at the Inquiry a number of issues previously
raised have not been satisfactorily dealt with in the new application.
These include
Inappropriate tree planting is suggested on grasslands of
importance.
Public access is suggested for areas of ecological importance
which will increase disturbance in sensitive areas.
Mitigation proposals for birds displaced from the development
site are inadequate.
The future management systems for the Country Park and of the
ecological areas (and translocations) have not been clarified.
However, these issues could be dealt with by condition and obligation if
the applicant and the other landowners were to agree.
15.7 In addition, the physical improvements intended for the Moor Mill (site
5) and Bell Lane (site 8) as parts of the Country Park are not clear. If
these areas are to be made suitable for increased public access
including the provision of recreational facilities such as sports pitches
and allied development, they may need improvement through
landraising. New earth mounding is also proposed for Sites 2 and 7.
15.8 The quality and source (from the development site or elsewhere) of any
material that may be required for this earth mounding or other
landraising has not yet been identified although the applicant refers to
the possibility of surplus soils arising from the airfield. It would however
involve major movement of material which would add to the initial
vehicular movements anticipated as part of the construction process.
As a result, there is no certainty whether the works on these areas,
especially on Moor Mill and Bell Lane, could go ahead acceptably.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 25
15.9 One existing bridleway crosses the north end of the site which would
have to cross the bypass/access road. The Ramblers Association had
applied for a footpath across the development site to be designated on
the definitive map but the Inspector was satisfied these issues could be
settled (16. 32 & 35).
15.10 Concern was expressed at the Inquiry that the increased traffic would
increase the hazards for walkers and horse riders on the surrounding
roads. Contributions to improve major road crossings were requested
but the inspector thought this unreasonable (16.96)and the Secretary
Of State agreed (SoS36 & 37). It is the Rights of Way officer‟s opinion
that these issues are unlikely to merit further argument.
15.11 While the original proposals were considered unacceptable by the
authorities it was recognised that environmental benefits could be
obtained from suitably revised proposals. There is potential for
improving past restoration, tree planting, public access, recreation,
ecological and other environmental benefits but are critically subject to
an adequate long-term management regime and funding. Such
improvements to the proposals have been insufficiently set out in the
current proposals and would still need to be agreed with the developer
or imposed by condition and obligation. However, it was the Inspector‟s
view that these matters could be addressed by condition and the
Secretary of State agreed. It is unlikely therefore, that further
contention could be raised on these grounds at this time unless new
information comes to light that was not available at the inquiry.
16. Other Issues
16.1 The application raises a number of issues, such as those regarding
visual amenity, impact on landscape character, tree loss, noise, air
pollution and light pollution. These are matters for the District Council
but were all considered at the Inquiry.
16.2 A further issue which arises from RSS Policy ENG1 is the use of
decentralised/renewable energy on such a large development. The
applicants have not addressed this in simply reproducing their previous
application but District Council should now require the provision of at
least 10% of the required energy for the site to be from „decentralised
and renewable or low-carbon sources‟ to meet the requirement of the
policy.
16.3 If permission were granted there would be a need for detailed section
106 agreements on a wide range of issues ranging from public
transport provision to country park management. A number of these
are included in the present application having been recommended by
the Inspector. In addition as part of any detailed permission there
would be local sustainability issues such as disposal of waste, grey
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 26
water and so on and now sustainable energy generating proposals to
meet the requirements of Policy ENG1 of the RSS.
17. Conclusions
17.1 It is national, regional and county policy to support the increase in the
carriage of freight by rail in order to reduce the amount carried by road.
If freight is to be carried by rail it normally has to be off loaded at an
interchange site to be delivered to its final destination by road (or in
some cases by rail).
17.2 The SRA in March 2004 determined there would be a need for three to
four strategic regional freight interchanges around London. This policy
has been accepted by the Department for Transport but there has been
no study into potential locations for such development. The MML is
not a major freight line but the section from the site to London could be
brought up to Gauge 10 standard.
17.3 Specific support for this location through the development plan process
has not emerged through any regional or national technical work. The
regional assemblies around London, together with the Mayor of London
and the DfT are the responsible bodies for undertaking appropriate
technical work and coming to conclusions on how best to meet the
SRFI needs of the wider south east. Those conclusions should be then
tested through the development plan process, regional spatial
strategies, the London Plan and Local Development Frameworks.
17.4 This process has not taken place though it maybe in the future and in
regard to a National Policy Statement. However, the criteria for SRFIs,
proximity to a main rail line and to major roads and motorways, mean
there are few suitable sites in the wider south east region. All will have
some disadvantages and most are likely to be within the Green Belt.
17.5 As a consequence the present proposal could be considered to lack
support through due planning process but it must be recognised that an
almost identical proposal has gone through the full rigour of the Public
Inquiry process. The Inspector concluded, and the Secretary of State
agreed, that in terms of general planning policy the proposal was
acceptable.
17.6 The reasons for refusal put forward by this committee in 2006 were
fully considered at the Inquiry and none were seen as warranting
refusal of planning permission in the Inspector‟s balance of the benefits
and disbenefits. On those aspects of most immediate relevance to the
County Council, notably transport and ecological/ country park issues,
officers will have to carry out more detailed analysis to see whether
circumstances have changed sufficiently to justify questioning the
Inspector‟s conclusions.
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 27
17.7 The previous application for the Radlett SRFI proposal apparently
failed because of perceived failings in the study of alternative sites.
The applicant has therefore carried out a further study for the M4 to
A1(M) sector as part of the present application. St Albans DC has
appointed consultants to analyse this study and determine whether the
demand in this area is sufficient to ensure any development does
attract rail freight rather than road based operations.
17.8 The proposal is for a large scale development which members may feel
is totally out of character with this part of Hertfordshire. However, in
commenting on the application the Committee must have regard to the
findings of the 2007 Inquiry. Officers will need more time to look at the
specific matters of County Council responsibility and if there prove to
be issues which are considered to be unresolved the committee will be
informed.
17.9 It is therefore recommended that the Committee note the content of this
report with a view to providing a formal response to St Albans City and
District Council at the Development Control Committee on 20th July
2009, particularly taking into consideration the following:
i) whether the applicants have demonstrated sufficient need for the
development of this site.
ii) whether other aspects on which the County Council has been
consulted (except for highways matters) could be resolved with
the applicant through the imposition of planning conditions and
obligations on the lines discussed at the Public Inquiry.
18. Financial Implications
18.1 There are none arising from this report.
19. Background Papers
Planning Application SADC/5/2009/0708 and related documentation
Inspector‟s Report June 2008
http://www.stalbans.gov.uk/Images/Rail_Freight_Interchange_St_Albans_204
5747_tcm15-6594.pdf
Secretary of State Letter 1 October 2008
http://www.stalbans.gov.uk/Images/Secretary_of_state_decision_Radlett_Rail
_Freight_Interchange_tcm15-6593.pdf
79e01858-01e8-4d87-9c95-98be51bf9c72.doc 28
