CONSULTATION ON THE GOVERNMENT’S NATIONAL POLICY FRAMEWORK (NPPF).
Members will be aware of the likely destructive effect of the Coalition Government’s proposals for a new National Planning Policy Framework. Much has already been said about it in the media. The National Trust, CPRE and many other respected organisations concerned with protected our rural landscape are strongly against these proposals. We have until 17th October to register our concerns and, importantly, to ask our local Councillors to write in on our behalf. These proposals make radical changes to planning policy. The Government, mistakenly, sees that the only way to achieve economic growth, and the need to build a vast number of new houses, is to scrap the tried and tested Planning Policy Statements (PPS) and Guidance. Instead, whilst greater control is being passed down to Local Authorities, the proposed framework for each Authority is in future to presume in favour of any sustainable development, irrespective of whether this is on green field sites. There is no clear understanding of what is and is not “sustainable.” Although there will be protection for designated Areas of Outstanding Natural Beauty, the less protected, but still sensitive, areas of our countryside will now be at serious risk.
The existing planning framework, evolved over many years experience, is there to strike the right balance between the demands for new housing, and the interests of developers on the one hand, and the need to protect our countryside, on the other. Under the New Framework there will no longer be a presumption in favour of building first on available brown field sites, nor of office development in town centres. There are other serious concerns. I see these proposals, unless radically amended, as a real threat to the picturesque villages and countryside in this lovely part of North East Essex. Development must continue to be strictly controlled on green field sites.
The draft NPPF can be found on: http://www.communities.gov.uk/publications/planningandbuilding/draftframework. Those interested can access the views of both CPRE and the National Trust through their respective web sites: www.cpre.org.uk, and www.nationaltrust.org.uk. Those who wish to write in, or ask their Councillors to, should do so before 17.10.2011, sending responses to Alan C Scott, Department for Communities and Local Government-National Planning Policy Framework, Zone 1/H6, Eland House, Bressenden Place, London SW1E 5DU; or by e-mail to: planningframework@communities.gsi.gov.uk.
Charles Aldous. 8.11.2011.
STOP the INCINERATOR on Rivenhall Airfield
New Planning Application on Rivenhall Airfield (Gravel Extraction)
A new planning application has just been submitted for Rivenhall Airfield. This time, Gent Fairhead/Golder are seeking to dig up the proposed waste site and a large area of adjacent land to the west for sand and gravel extraction.
This is now the 4th planning application to largely destroy what remains of the former WW2 airfield and the woodland and other habitats it supports in the area around the hangar and the listed Woodhouse Farm complex.
We have not yet had time to go through all the application documents but will do so as soon as we can and will then issue some notes on suggested responses to the application consultation.
As with the previous airfield applications to the County Council, matters are complicated by Essex County Council's outdated methods of public engagement. We know about their restricted access to public participation in their planning meetings, but in addition, they still have no facility for viewing planning application files on-line, despite many other councils having offered this facility for several years now.
The paper files will be available at various locations including council offices and libraries as normal.
You may recall that in 2009, the heavy duty legal and planning team employed by Gent Fairhead dismissed local objections to the waste site/incinerator and said they wanted to get on and build the plant straight away. Well nearly 2 years later, they have not done so and the new application for sand an gravel appears to suggest they may not build the waste site, at least in the forseeable future.
That is obviously good news for all of us concerned about the consequences of burning 1000 tonnes of waste a day, but the new application proposal appears to pose pretty much the same threats to the airfield as the "eRCF" in terms of habitat impacts. It will involve the destruction of much of the TPO woodland, old buildings that support bat populations, open ground areas that support a wide range of birds, etc. And the applicants state they want to clear the site later this year.
Back in 2009 we were told that if the waste site was to be built, sands and gravel beneath it would need to be excavated as a consequence and permission was given for the waste site on the basis that those sands and gravels cannot be dug without a firm assurance the waste site would go ahead. Now we are being told that the sand and gravel should be excavated alone.
Our initial position is that this is a completely unacceptable proposal that should require an entirely different "need case". There are plenty of other sites that can be dug for sand and gravel in Essex - two of which the landowner has already put forward to the north of the old runway. Furthermore, the proposed sand and gravel site, called "A2" could be dug with a modest boundary change on its eastern side that would leave the hangar/TPO woodland/Woodhouse Farm area intact. There is simpy no "need" to destroy it.
All in all, it looks like the goalposts are being moved yet again in what is now a nearly 20 year planning battle. Our intention is to fight on to try and secure the long term protection for the most valued part of the old airfield, whilst recognising that some sand and gravel extraction on other areas may go ahead - with restoration to farmland and woodland. And of course with no major waste site.
James Abbott (James Abbott
(James Abbott is a Councillor and spearheaded the original objection)
Could this latest application be a way of starting the waste project? Dig a hole large enough to hold the incinerator, then reapply for Planning Permission!
Response to National Grid.
The following observations are made by the Colne Stour Countryside Association to National Grid’s consultation on its approach to undergrounding new electricity transmission lines.
National Grid’s policy on undergrounding should be governed by a set of clearly defined principles, which not only have public support, but which are objectively reasonable. By this we mean that the reasonableness of any decision taken by National Grid whether or not to underground in any specific situation must be capable of being objectively tested by both objectors and the relevant Planning Authority.
It is not acceptable for National Grid just to say that any such decision will be made on a “case by case” basis, having “identified alternative options” and “undertaken a thorough appraisal process to consider the technical, economic, social and environmental effects of the options”. This is not acceptable for a regulated monopoly. Nor is it sufficient for National Grid just to rely on the general guidance in the National Policy Statements.
There must be a set of objective criteria, openly laid down, governing the specific issue of whether or not to underground. Objectors must be able to readily determine whether the National Grid’s decision was correct or not, without first having to expend considerable time and resources investigating the matter for themselves. Equally, when it comes to the planning application itself, the reasonableness or not of National Grid’s decision must be capable of being determined by the relevant adjudicating Authority by reference to detailed principles laid down by National Grid; for otherwise how can the Authority decide whether National Grid have acted in a fair, transparent and consistent way? Although decisions on whether or not to underground will vary according to such matters as topography, National Grid should always be seen to act fairly, transparently and consistently.
National Grid should therefore be required to commit to a set of publicly defined principles, to be universally applied, on whether or not to undergrounding transmission lines.
2. Importantly, these principles must include a fair and publicly acceptable methodology for evaluating in all cases the environmental benefit of avoiding overhead transmission lines; so that any decision not only takes account of the additional costs of undergrounding, but also assesses its long term visual amenity benefits. This must therefore take account not just of the effect on the number of people living in the vicinity but also of the non-use value placed on attractive landscape by those not living there. To do this, these principles could, for example, require National Grid to apply the Treasury Green Book on Appraisal and Evaluation in Central Government when assessing the detriment to visual amenity from overhead transmission.
3. More fundamentally, National Grid’s whole approach is wrong. As understood National Grid simply identify a need for additional transmission capacity from point A to B, and having done this then consider, when the precise route is chosen, to what extent, if any, to underground.
Now that:-
• The Government and the “industry” are actively looking at alternative integrated and radial transmission systems for transmitting electricity from the new series of coastal and off shore generators and between the UK and Europe.
• There are already and will continue to be major technical advances in transmission, (including gas insulated underground cabling), which will fast become increasingly less costly.
• IET are proposing to produce an independent report later this year on the cost of undergrounding, including, presumably, the use of new technology.
National Grid should not only defer finalising its future undergrounding policies until at least IET have reported, but should first come forward with proposals for a long term fully integrated strategic plan for coast and offshore transmission. National Grid should tailor its undergrounding policy to this plan. Only then can one see to what extent further on shore transmission will be truly necessary.
Charles Aldous QC. (Chairman). 4th July 2011.
Horkesley Park.
For those who were unable to attend the Planning Council hearing on Thursday 26th May, the vote of the Committee was 11 to 1 against the proposal; a resounding victory for the “No” campaign. In one sense the outcome was not surprising once we had seen the Planning Officer’s report comprehensively recommending refusal. The hall was packed, with people being turned away for lack of room. Each side was allocated 36 minutes, with no speaker allowed more than three minutes. I was allotted one of the three minute slots to speak "against" on behalf of the Colne Stour Countryside Association. Not only did the local parishes and conservation groups speak against, but so also did the Suffolk Preservation Society, CPR Essex and importantly the Dedham Vale AONB and Stour Valley Project responsible for the Borough’s management plan for the Vale. Quite apart from seeing this as in reality an unnecessary out of town retail park, it became clear, when Council members spoke, that they had been hugely impressed by their site visit. They were persuaded that the proposals would cause serious harm to the AONB, not least as a result of a huge increase in traffic along the protected lanes and through Nayland and its despoiling effect on Horkesley Church. Rest assured this will not be the end. The Applicants, having invested so much money in this application, will be unlikely to just accept the decision and leave it there. For the present, a considerable vote of thanks must go to Will Pavry and the Stour Valley Action Group for their steadfast opposition to what would have been a wholly unnecessary development in this most beautiful countryside.
Charles Aldous 2nd June 2011.
Horkesley Park.
Councillor ...............
Colchester Borough Council
PO Box 884
Town Hall Colchester CO1 1FR
October 22nd 2010
Dear Councillor
Horkesley Park Heritage and Conservation Centre: Application No 090231
I am sure you will be aware that the Horkesley Park Application will be coming before Council for decision in the near future.
We remain absolutely committed to securing the rejection of this Application and very much hope that the Council will follow the recommendations of their own Consultants, Nathaniel Lichfield and Partners and reject it. Nathaniel Lichfield conclude that:
“7.17 Our analysis of the Horkesley Park proposals suggest the attraction is not of regional significance, does not meet the exceptional circumstances where major development would be permitted in the open countryside.
7.18 In our view the amount of retail and other enabling development proposed is excessive and dominates the proposals. The scheme will be a retail led scheme. There is no guarantee the tourist attractions will be delivered or maintained.
7.19 The benefits of the tourist elements of the scheme in our view do not out-weigh the disbenefits of major development in the open countryside.”
There can be no doubt that they are recommending rejection by the Council and it is difficult to see how any other decision could be reached by the Planning Committee.
The Applicant sent in a document refuting the findings of Nathaniel Lichfield which we contested in our letter to the Council of August 31st 2010.
We have set out our reasons for rejection many times and in great detail in our response to the Council of April 17th 2009. To repeat our main objections:
Horkesley Park would cause irreparable damage to the peace and tranquillity of the Dedham Vale AONB through the impact of an additional projected 485,000 visitors annually.
It is contrary to national and local planning policy.
It is a retail development with over 75% of projected revenues coming from the garden centre, restaurants, food sales and other merchandising.
Whatever the Traffic authorities say to the contrary, the impact of cars associated with 485,000 visitors on local lanes and villages would be quite unacceptable.
No account has been taken of the impact of additional traffic on the Protected lane of Fishponds Hill.
The countryside is free for all to access through the myriad of footpaths, bridleways and public areas that exist in the Dedham Vale. Why should people be asked to pay for something that is already freely available?
There is no demonstrated need for the development. All the elements of the plan are available elsewhere in the region.
There is no ‘heritage’ asset at Horkesley Park that could possibly justify the development.
We have demonstrated that it is almost certainly not commercially viable as proposed. We have demonstrated that visitor number projections and revenue generation are in all probability grossly exaggerated and will not be obtained.
The Applicant’s claims for job creation numbers must therefore be set aside and must not be treated as a reason for overriding all other planning considerations.
The Council has received 1307 well reasoned letters and e-mails of objection compared with only 445 letters and e-mails of support.
Organisations to object include Dedham Vale AONB and Stour Valley Joint Advisory Committee, Dedham Vale Society, CPR Essex, Suffolk Preservation Society, English Heritage, Natural England, National Trust, Gainsborough’s House Museum, Colne Stour Association, Soil Association, Nayland with Wissington Conservation Society, Essex Ramblers, Babergh District Council, Parish Councils of Great Horkesley, Little Horkesley, Nayland with Wissington, Boxted, Stoke-by-Nayland, Leavenheath, Alphamstone and Lamarsh.
The Applicant still claims that their petition of 22000 signatures obtained before the application was submitted from their Suffolk Punch road show should be counted. In our view this is manifest nonsense as these signatures only showed support for the Suffolk Punch and cannot have had anything to do with the Horkesley Park application as submitted and cannot legitimately be counted as support.
We very much hope we can count on your support to have this Application rejected when it does finally come before the Planning Committee for determination.
Yours sincerely,
Will Pavry
Chairman, Stour Valley Action Group
www.stourvalleyactiongroup.org.uk
Newsletter October 2010
Dear Member,
Status of Horkesley Park Application No 090231
We believe that the whole Horkesley Park will in all likelihood come to a head within the next few months– but then we have been saying that since last December!
We have been in regular touch with the Colchester Borough Council Planning Officers and they advise us that they are now bringing all the documentation together and expect it to come before the Planning Committee of the Council in the near future.
Now we need you! When this happens, we must have maximum attendance from you all at the Council meeting to demonstrate our absolute opposition to this desecration of the countryside.
We do not know what the Planning Officers’ recommendation to Councillors will be, but must presume that they will take note of the strong grounds for rejection from their own consultants, Nathaniel Lichfield and Partners (NLP) and their own Spatial Policy team who also recommended rejection.
To remind you of activities over the last ten months:
In December 2009, CBC commissioned a report into certain aspects of the Application from NLP. They responded in March 2010 but the report was not made publicly available until July 2010. The Report was very unfavourable to Buntings and a summary of their findings is given in our Newsletter of July 2010 which is on the SVAG website under www.stourvalleyactiongroup.org.uk.
Buntings produced a 406 page response to the NLP report dated July 13th 2010 seeking to contest its conclusions.
SVAG wrote a detailed response to the Buntings’ document and in support of the NLP Report. Our letter was dated August 31st 2010 and is available in full on our web site above.
Essex Highways finally concluded their response on traffic issues in their letter of July 6th 2010. They raised no objection but imposed very onerous public transport requirements which would seriously affect the financial viability of the Application. They made no comment on the status of the Fishponds Hill Protected Lane. We contested this in our letter of July 27th 2010 which has been acknowledged and a response is awaited.
Suffolk Highways originally recommended rejection in their letter of April 2009. They changed their position in their letter of May 2010 and we wrote and contested this.
There has been a steady stream of letters in the local press from many of our members which have been most helpful.
SVAG’s position regarding the Horkesley Park Application is fully set out in our letter to Colchester Borough Council of April 17th 2009. The Application must be rejected because:
Horkesley Park would cause irreparable damage to the peace and tranquillity of the Dedham Vale AONB through the impact of an additional projected 485,000 visitors annually.
It is contrary to national and local planning policy.
It is a retail development with over 75% of projected revenues coming from the garden centre, restaurants, food sales and other merchandising.
Whatever the Traffic authorities say to the contrary, the impact of cars associated with 485,000 visitors on local lanes and villages would be quite unacceptable.
The countryside is free for all to access through the myriad of footpaths, bridleways and public areas that exist in the Dedham Vale. Why should people be asked to pay for something that is already freely available?
There is no demonstrated need for the development. All the elements of the plan are available elsewhere in the region.
There is no ‘heritage’ asset at Horkesley Park that could possibly justify the development.
We have demonstrated that it is almost certainly not commercially viable as proposed. Any claims for job creation numbers must therefore be set aside.
The Council has received 1307 well reasoned letters and e-mails of objection compared with only 445 letters and e-mails of support. Organisations to object include Dedham Vale AONB and Stour Valley Joint Advisory Committee, Dedham Vale Society, CPR Essex, Suffolk Preservation Society, English Heritage, Natural England, National Trust, Gainsborough’s House Museum, Colne Stour Association, Soil Association, Nayland with Wissington Conservation Society, Essex Ramblers, Babergh District Council, Parish Councils of Great Horkesley, Little Horkesley, Nayland with Wissington, Boxted, Stoke-by-Nayland, Leavenheath, Alphamstone and Lamarsh.
Buntings still claim that their petition of 22000 signature obtained before the application was submitted from their Suffolk Punch road show should be counted. Our view is that this is manifest nonsense as these signatures only showed support for the Suffolk Punch and cannot have had anything to do with the Horkesley Park application as submitted. We have made strong representations to the Council on this issue.
Horkesley Park must be rejected. We need you support at the Planning Committee hearing and will advise you as soon as we know the date.
Will Pavry
Chairman, Stour Valley Action Group
Keep in touch with developments on : www.stourvalleyactiongroup.org.uk
SVAG, P.O. Box 6587, Great Horkesley, Colchester, Essex CO6 4TN
National Grid Press Release


National Grid’s plans for erecting a new line between Bramford and Twinstead.
Your Association has been working assiduously for many months, in conjunction with other interested groups, in opposing National Grid's proposals. A steering group has been formed, comprising, Stour Valley Underground, Colne Stour Countryside Association, Dedham Vale Society and Bury Not Blight (Hintlesham). We have been joined recently by The Suffolk Preservation Society and CPRE Essex, which adds considerable influence. Amongst the issues, we have been researching and promoting economically viable and practical alternatives that will not disfigure our historic landscape. We have attended meetings with local MP's and, importantly, both Suffolk and Essex County Councils, as well as with the Infrastructure Planning Commission.
The battle has been joined at Government and at Parliamentary level and much of the legal framework surrounding the development of the Electricity Transmission Network is currently under Governmental Review.
Due in no small part to local protest, National Grid’s own timetable for consultation has been substantially delayed, with as yet no date set for the next phase, although expected in the early New Year.
More crucially for those Parishes in Suffolk not affected by existing proposals, over the last few weeks, plans for additional transmission infrastructure have been revealed, due to Scottish Power’s plan to build the East Anglia One wind farm off the Suffolk coast. This is an imminent development, with power lines proposed in a broad ‘envelope’ covering the Deben, Orwell and Stour estuaries, through to Bramford.
Scottish Power says it hopes that some lines can be placed underground, but this is only an aspiration and not a guarantee. It is also only the First Phase of this development, with two more phases to follow, one of which includes a connection at Lowestoft along with related Pylons. Requests have been made to those Parishes to become engaged now before it is too late.
Even though not the reason for National Grid's existing proposals, if these new power lines are to come on shore through to Bramford, this will inevitably reinforce National Grid's determination to erect these further lines through to Twinstead.
There are alternatives. Reconductoring the existing 400 Kv line, already planned, will add substantially to capacity. There is spare capacity in other available lines down to London. Power from the wind farms can be taken undersea to Bradwell, where again there will be spare capacity even after the new nuclear station has been built there. Moreover, although the subjects of a newly commissioned Government study yet to report, undergrounding is thought to be much less expensive than National Grid has been claiming. Do please access regularly Stour Valley Underground’s website at info@stourvalleyunderground.org.uk. for up to date information on developments. We must all be very grateful for the enormous amount of work they have devoted to this.
Could members who live in Parishes even remotely affected by these threats, ask their Parish Council to give serious consideration to these developments, and engage with the IPC (see address below) their County Council and all relevant organisations to appraise them of local opinion.I would ask that you get your Parish Council to pass a resolution to support the proposal to block all new overhead transmission lines and remove existing transmission and distribution lines where ever possible.
As I say, developments in underground cabling and the potential for an offshore grid offer fresh hope.
We have already made a difference, but if we are to succeed in this fight, we need as much support as possible. I hope that you will appreciate the importance of a unified stance.
Charles Aldous (Chairman)
1st December 2010.
Contacts;
Sheila Twidle/David Cliff
Infrastructure Planning Commission,
Temple Quay House,
Temple Quay,
Bristol, BS1 6PN
Update to National Grid’s proposals for new overhead lines from Bramford to Twinstead..
On behalf of the Association I have been liaising closely with Stour Valley Underground, Dedham Vale Society and Bury not Blight, all of whom, like us, oppose any pylons, whatever the corridor. I was deputed to speak on behalf of all four organisations at a recent meeting in Hadleigh, chaired by the Infrastrure Planning Commission, to air our criticisms of National Grid's consultataion process. I spoke from a jointly prepared paper, on which all four organisations worked closely together. Set out below is the final version of the paper which has been sent to the IPC following the meeting. I hope readers will see that your Association has been taking active steps on your behalf to do all that we can to try and stop the pylons happening. Charles Aldous. 24th June 2010."
Submission by Stour Valley Underground, Colne Stour Countryside Association, Dedham Vale Society and Bury Not Blight.
(22nd June 2010)
1. All four Associations have consistently opposed any overhead pylons; contending that National Grid (“NG”) has not engaged in any real consultation on other possible alternatives.
2. There is a statutory obligation on NG to undertake a fair and constructive public consultation. NG is required to provide the public with sufficient information to enable them to determine whether NG’s case is sound.
3. This requires NG to fairly explain in sufficient detail how and why it has come to reject alternative proposals that are environmentally preferable, when it must have known that there would be very considerable objection to the 4 overland routes. Consultation involves enabling the public to properly understand and question their rejection, if necessary, with the benefit of independent expert scrutiny. Indeed paragraph 74 of the Guidance on pre-application consultation recognises this, by providing that it may be necessary for the promoter following the consultation process to proceed with options significantly different from those consulted (emphasis added). This shows that NG must engage in a proper open minded consultation with the public on other possible solutions. By the “public” one means ordinary, concerned, non-specialist members of the public. So far it has not.
Need for additional line not proven
4. When the public consultation started, the public was led to understand that the new 400 kV pylons were essential to accommodate the additional capacity from the new nuclear power station at Sizewell, the two gas stations at South Holland (awaiting consents - due 31/10 2014) and Kings Lynn B. (consents approved delivery 31/10 2014). Much was made of the input from Sizewell C, (David Mercer to Tim Yeo, 4 December: “The proposed Bramford to Twinstead 400 kV overhead line has a high power rating to cater for the major new generation projects in East Anglia including Sizewell C”). The potential input from the offshore wind farms was also mentioned, implying that this would add to the region’s on-shore transmission requirement (see further below). In short the main emphasis was on the need for additional capacity, principally because of the two new gas stations and Sizewell. This is what the public fairly understood the proposals to be predicated on.
5. What then happened? We were then able to discover that there were two elements to NG’s proposals; upgrading or reconductoring the existing lines and, separately, construction of a new 400 Kv line. Significantly, it now appears that upgrading the existing line will provide more than enough capacity for the 2 gas power stations. Reconductoring will add 2.2 GW (NG’s written answer to David Holland) to the existing system and yet maximum output from the new stations is rated at less than 1 GW each (984 MW and 840 MW). Reconductoring can go ahead under the authority already held by NG.
6. As for Sizewell C, the anticipated date for the new nuclear station coming on line has slipped by four years and may slip much further. The original date for the first Sizewell reactor was 2016, and hence NG was saying that the new Bramford - Twinstead connection had to be complete by the same date. Recently, we have been told that EDF have chosen to slip the commercial load date of the first Sizewell reactor to 2020, and the second to 2021. Given the coalition government’s reluctance to subsidise nuclear power, there is reason to question whether Sizewell C will ever happen.
7. If reconductored the existing lines will provide adequate capacity for the new gas powered stations and as Sizewell C’s power is not expected before 2020/21 at the very earliest, there is no urgency for the construction of the proposed line. This is important, as it will now allow NG to factor in the impact of changing Government plans which currently include Smart Grid and Undersea Grid implementation commitments, both of which may have a major impact on the case for any new pylon line. Indeed The Offshore Valuation Group’s most recent report presses the need for such a North Sea Grid. Given the rapid rate of change in the power industry, it would be irresponsible to press ahead precipitously with the inevitable danger of creating redundant assets, i.e. erecting these hugely despoiling pylons, which in only a few years may be shown to have been unnecessary.
8. Returning to NG’s failure to present the public with the real issues and allow the public to question NG’s rejection of, or require it to consider, other solutions. In the light of the slippage at Sizewell and having revealed that there will be more than sufficient capacity from reconductoring the existing lines, there has been a change in the presentation of NG’s case. Whilst public literature continues to talk about increased generation capacity, in recent meetings with councillors NG has emphasized the importance of the second overhead line to meet the current SQSS security criteria. So far as we are aware, the security issue didn’t feature until meeting with NG on 15th February, 2 weeks before closure of consultation. It is likely that many members of the public concerned about this issue are still unaware of this.
9. In very basic terms, SQSS - the Great Britain Security and Quality of Supply Standard - ensures power can be re-directed in the event of failure of one part of the transmission network - or a “double circuit outage condition” (N-2). Assumptions are made about the likelihood of this happening and the grid is modeled accordingly. This quality standard is being reviewed by the energy industry’s SQSS Review Group. Acknowledging that “we need to be more proactive in the future in terms of keeping the industry appraised of progress”, on 30 March 2010 the Group published an open letter setting out its proposals for progressing its review. It accepts that much more work remains to be done and proposes a phased approach. The letter states that the SQSS “underpins the case for development of the transmission network” and looks towards the implications of new ‘SMARTer’ technology. Urgency in this review work has already been requested by the House of Commons Energy and Climate Change Select Committee[1].
10. Despite the critical importance of the security review, the public is only being supplied with limited information and is being expected to take NG’s interpretation of the review on trust. However given the review being undertaken by the SQSS Review Group, current academic studies relating to SQSS and the widespread interest in now transferring assessment from a deterministic to probabilistic basis, there needs to be explicit consideration and consultation into whether there is any need for a new line from Bramford to Twinstead on security grounds. The public is entitled to this opportunity.
11. Given the Sizewell delay there may well be other strategies to deal with both the security and transient instability issues on the existing circuits e.g:
i) temporarily re-routing the power along the upgraded lines (or via possible NG suggested new lines) which may be constructed to connect from the Wash area to the South going circuits that run through Eaton Socon;
ii) as expressed to us by an NG engineer, by placing a switching station at the Twinstead Tee so as to allow the two circuits going south to have their full capacity potential realised. Currently the circuit from Pelham to the Tee, then going south is highly underutilised.
Impression was clearly given at the recent meeting that NG has not looked at other possible solutions to the security issue if one takes Sizewell C out of the equation[2]. All of the grid enhancement scenarios referenced in the Optioneering Report are predicated on the additional load from Sizewell C. This security and stability issue is just the sort of issue (which has only really featured very late on) where the public is entitled to be afforded a proper opportunity to get to the bottom of before any decision is taken on the preferred corridor. Is any new line of pylons really necessary just to meet security requirements? We believe we will be able to show the answer is no.
Wind Farms
12. The impression conveyed by NG concerning wind farms is misleading. In general, transmission systems designed to accept wind generation will require little reinforcement. Wind energy when brought directly ashore is a substitute to fossil fuel generation (a fuel saver) not a contributor to overall capacity.
13. At the same time, NG has recently admitted that even if the new 400 kV line were erected this will not be sufficient to accommodate the proposed Round 3 wind farms if their output were brought directly ashore. A third high voltage overhead line across South Suffolk would be unthinkable even to NG. NG will therefore have to sooner or later (we say “sooner”) come forward with an alternative solution, namely, the undersea grid. We now know that the Coalition Government are likely to press for the implementation of these wind farms urgently and have recently committed to connecting them to an undersea grid (see e.g. section 10 of the Coalition Agreement). This again shows the untimeliness of the current proposals and that sensible decision making is near impossible at this point with such important matters unresolved.
14. Although the optioneering report (issue date 06/11/2010 - after consultation had started) ruled out an undersea alternative on cost and technical grounds, NG conceded at our meeting on the 15th February that it was not as comprehensive as it could have been. However, this report was prior to NG realising that the Round 3 wind farms are unlikely to be accommodated by any new 400 Kv overhead line. This means that an East Coast – London undersea connection must now be a very realistic possibility. The consultation period must allow for a proper understanding of what NG will have to do for Round 3. If there is in any event to be an undersea grid for the wind farms, this can also take account of Sizewell C, if it ever happens. There is now more than sufficient time for NG to come forward with a solution fit for the 21st century.
15. In short, security/transient instability has now become the only immediate reason for NG claiming there is any pressing need for these pylons. We believe that, if given a proper opportunity to examine this, the public will be able to show this is unnecessary.
Environmental issues not evaluated
16. Obviously pylons have a significant and detrimental impact on the areas through which they pass. If this were not so, the whole consultation would be redundant.
17. All four overland corridors are very similar. Many communities would be seriously affected by more than one corridor. All four will follow closely similar routes cross the same Stour Valley and through to Twinstead. The public are entitled to have the benefit of (and comment on) a suitable and sufficient environmental assessment of the impact of pylons during stage 1 consultation. This is essential in not just enabling the public to comment on which corridor would be environmentally less harmful but, more importantly, to comment on whether there should be any overland route at all. Environmental assessment is not only a stage 2 alignment issue (as NG contend).
18. NG offers detailed information on environmental issues only at stage 2. This is in inverse relation to the importance of environmental factors, where overwhelmingly the most important ones arise at stage 1.
19. Furthermore NG has not provided the public with a “thought through” position on which parts to underground, that is capable of objective scrutiny and testing. NG appears to consider that a sufficient case against undergrounding is made by quoting cost differences or cost ratios between pylons and undergrounding. This simply fails to address the issue. The question is not whether undergrounding (or other environmentally friendly options) cost more. The question is whether the cost savings of pylons exceeds their environmental detriment[3].
20. The only reference in NG’s consultation material to environmentally-friendly options is to state their policy of considering undergrounding in AONBs[4]”.
21. This does not mean that undergrounding will definitely be done throughout the AONB should the chosen route go through it, since an underground option did not even feature in the stage 1 consultation. It appears it is intended to mean that undergrounding is precluded outside the AONB. But this is not the case, since undergrounding took place outside the AONB in the recent Yorkshire case.
22. Even if it was clear that NG policy is to consider undergrounding only in the AONB,
a. no justification has been offered for this[5];
b. no rationale or process has been offered for the decision as to whether to underground within the AONB.
23. The cost difference between pylons and undergrounding is not so large as to mean it is incredible that environmental considerations outweigh it:
a. The cost of undergrounding all pylons in National Parks would be a few ££ per year per household. It is not obvious that this is excessive;
b. The excess cost of the proposed offshore wind power, against the same wind power capacity onshore, represents at least 10 times the cost of undergrounding in National Parks. The reason for generating offshore rather than onshore is environmental, and the generic environmental objections to on-shore wind farms are closely analogous to those to pylons (namely that both are arrays of huge industrial structures, alien to their surroundings).
c. Undergrounding of high voltage transmission is done without question in conurbations.
24. On the process for deciding whether to underground and to what extent, NG’s position appears to be that it is for NG to decide unilaterally. It may be that this position is distorted by regulatory considerations. We have been given to understand that if NG volunteer undergrounding, Ofgem is liable to exclude the cost from NG’s regulatory asset base, whereas if undergrounding flows from a decision by some other authority (eg a planning inspector) NG are entitled to have the cost added to their regulatory asset base. This may explain why NG has not been open either on the process for evaluating environmental considerations against cost (Who decides), or on the methodology (How environmental considerations are weighed against cost). But it does not make the consultation any more satisfactory. The public should know at stage 1 which, if any parts, NG intend to underground and the reasoning applied.
25. It seems clear that public willingness to pay to avoid environmental detriment is relevant to these decisions. We asked NG for any information they possessed on the subject but have received no reply. Assessing public willingness to pay, and incorporating it in the decision-making process, is well established in other areas eg transport safety. There is no good reason for not applying such techniques in this area.
26. In summary:
a. The essence of this issue is the conflict between cost and environmental detriment;
b. NG have excluded all environmentally-friendly options from the consultation;
c. NG have provided no tenable justification for this;
d. NG have put forward no methodology or process for evaluating the environmental detriment avoided by alternatives to pylons and assessing it against the additional cost;
e. NG have put forward no methodology or process for evaluating the different environmental detriments associated with the different route corridors, and assessing them against the different costs;
f. For NG to contend that the decision as to the trade off between cost and environmental detriment is theirs, unilaterally and without offering justification, is to defy the consultation process and indeed the subsequent IPC process;
g. It is reasonable to believe that on proper comparisons, and considering similar trade-offs in related fields of energy policy, and using relevant techniques of environmental cost-benefit analysis, the decision would be against pylons.
27. NG should now seek, and publish, advice on how best to enable the alternatives, including environmentally-friendly alternatives to be evaluated at stage 1, so as to ensure thereby that the public can fairly consider and comment on whether NG’s decision to reject these alternatives is sound. NG must ensure that there is a process and methodology which enables the broad environmental factors which operate at a regional and national level (ie excluding fine detail such as local habitats and individual listed buildings, but taking account of large-scale features such as AONBs) can be weighed against cost factors, so as to enable independent appraisal of the reasonableness of its decisions.
28. This work should include assessment of public willingness to pay to avoid environmental detriment. It is not for the public to have to commission this work.
Failure to provide relevant information in adequate time
29. In all of its consultation documents National Grid states that stage 1 was designed to consider route corridors; alignment was for stage 2. But for the villagers of Burstall and Hintlesham in particular the exact alignment from the Bramford sub-station is a major determinant in evaluating relative merits of the 4 corridors.
30. However, very late in the consultation period NG announced details of a new 2C corridor which requires towers in two new parishes (Sproughton and Copdock) never previously included in the consultation. This has resulted in confusion leading to division within the community and insufficient time to discuss all three corridor 2 options and present opinions before the relevant parish and district council meetings.
31. Effective consultation has also been limited due to the continued omission of relevant EDF power lines from NG’s publishedmaps.This includes the map in the latest newsletter. NG staff have been told about this repeatedly.
Failure to comment on conflicting evidence of the cost of undergrounding:
32. Europacable (Federation of European Associations of Cable Manufacturers) presentation of June 2009 points to significantly lower costs (ratios around half those suggested by NG).
33. NG’s answer has been that lower cost examples are based on lower transmission capacities. However, it appears this has never been checked (David Mercer in a letter to Tim Yeo MP dated 4th December 2009 said “I know some of your consultants have quoted lower cost ratios from overseas but, although I cannot be certain without checking the details, it is likely these are lower rated or lower voltage cable systems”). No further clarification has been provided.
34. So far NG have failed to provide any accurate costed figure for undergrounding the entire length from Bramford to Twinstead.
Conclusion
35. To summarise, we are requiring the consultation process to be put back so as:
a. to enable the public to obtain a better understanding of what will have to happen with the North Sea wind farms;
b. to enable both NG and the public to have a better understanding of the implications of the introduction of Smart Grid technology and the commitment to an East Coast Undersea Grid;
c. to enable the public to examine the transmission security issue and require NG to examine other possible security solutions not yet looked at;
d. to require NG to produce and apply a satisfactory process and methodology for taking the relevant environmental factors into account before deciding on whether any of the corridors should be selected; and
e. to provide for finalisation of the National Policy Statements.
It would be a calamity if these pylons were to go ahead only to see that they were unnecessary in four or five years time.
[1] That report also noted that there are “some concerns that the existing regulatory framework is driving the case for transmission investment presented by the industry at the expense of other more cost-effective options that seek better to utilise the existing network infrastructure. The current fundamental review of the Security and Quality of Supply Standards (SQSS) therefore presents a major opportunity to address these issues.”
[2] Indeed, the simplest solution to security problems arising after connecting King’s Lynn & South Holland may be to connect and manage, i.e. to temporarily switch off some or all of the power being generated there (since thereby the system reverts to what it is now). NG appeared at the 14 June meeting to recognize that this is technically viable, but quoted commercial obstacles (depriving the generators in question of revenue). Such objections can be overcome, by paying suitable compensation. The questions then are, (i) does the Net Present Value of the likely such compensation exceed the NPV of the second Bramford – Twinstead pylon line? (ii) if it does, does the difference in NPVs exceed the environmental detriment of the pylon line? It seems clear NG have not considered this.
[3] It should also be noted that the cost differences are unaffected by the status of the land in question, whether AONB or not. To concede that undergrounding is considered in the AONB – see following paragraph - is to concede that in some circumstances the excess cost of undergrounding is justified.
[4] And similar “severely constrained areas” such as conurbations or estuaries, but none of those apply in the present Bramford – Twinstead case
[5] For example, NG has not acknowledged that the incremental cost of undergrounding might be materially cheaper when extended beyond the AONB, nor that environmental benefits outside the AONB might be as great or greater than inside it.
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Response by the Colne-Stour Countryside Association to National Grid’s proposals for new overhead lines from Bramford to Twinstead..
1. The Colne-Stour Countryside Association (“The Association”) is a long established association, with over 600 members and 23 affiliated parishes, formed to protect the countryside abounding the mid and upper Colne and Stour Valleys. This includes the area either side of the Stour Valley immediately South of Sudbury, sometimes known as “Gainsborough country”, which will be severely damaged if National Grid’s proposals were to go through.
2. The Association strongly opposes all four overland proposals, each of which cuts through the very picturesque and undulating countryside leading across the river valley, through to The Hennies and Twinstead. An area which has been the inspiration for artists such as Gainsborough and which must continue to be protected for future generations.
3. A decision has already been taken by the Dedham Vale AONB and Stour Valley Project (funded by Natural England and the Local Authorities) to apply to have a large part of this area, already a Special Landscape Area, included in the Dedham Vale Area of Outstanding Natural Beauty. The Association strongly supports this. These “untouched” rolling valleys are becoming increasingly scarce. All four corridors go through the proposed extension.
4. The environmental damage caused by large pylons and overhead cables is severe. The countryside will be scarred. Houses will be blighted. What was a beautiful landscape is then lost forever. As has been stated many times, the fact that there are existing lines passing through these valleys cannot be seen as a reason to further damage this landscape.
5. National Grid has failed to conduct a proper consultation as required by the Planning Act 2008. The Guidance on pre-application consultation, which National Grid has a statutory obligation to have regard to, was not genuinely followed.
6. Paragraph 16 states that National Grid was required before the proposals were finalised, to ensure the local authorities and other relevant organisations can
•“put forward their own ideas and feel confident that there is a process for considering ideas,
• have an active role in developing proposals and options to ensure local knowledge and perspectives are taken into account,
• comment on and influence formal proposals.
7. Paragraph 18 states that “it is important, therefore, that an effective process is in place for further information sharing, in both directions, to the benefit of both communities and promoters.”
8. Paragraph 19 states “it is important that, where possible, communities are able to participate early, when proposals and options are being developed. People need to know that their participation can make a difference.”
9. It is believed that no genuine attempt has been made to allow the local communities to put forward their own ideas and help develop the appropriate options to be put out for consultation; options, which, unlike the four proposals, would have complied with both the East of England and Local Authority Plans as well as the Holford Rules for protecting the landscape in AONBs and Special Landscape Areas.
10. Instead of which, National Grid decided for itself to reject any alternatives to overland pylons, primarily on cost grounds, and simply presented the four very similar options (all carrying similar cost), as a fait accompli.It is believed that no attempt was made, for example, to engage with the local organisations on the possibility of a more direct and hence shorter underground tunnel route, or on how to assess the true environmental impact of each of the four overland routes and gauge the public’s preference for more costly but environmentally preferable alternatives.
11. It is unclear how far National Grid has properly addressed the environmental impact, other than by considering narrow issues such as the likely effect on tourism. As with the submissions from the Dedham Vale Society, the essential issue is the right balance to be struck between financial cost and the environmental benefit, in its widest sense. There has been no attempt by National Grid to address this, other than by ruling out more expensive alternatives on cost. It is suspected that National Grid have no developed principles by which to assess the social benefits of less environmentally damaging alternatives and balance these against their higher cost. There has been no
attempt to research the public’s willingness to pay to avoid overhead pylons in Special Landscape Areas. Again as the Dedham Vale Society’s Response shows, the additional cost per household of undergrounding in tunnel the whole length from Bramford to Twinstead is trivial (2p per month). Even if all high-voltage transmission in the National Parks were put underground over a 14 year period it would only add 50p per year to household bills.
12. It is questioned whether before deciding on the four overland routes, National Grid ever undertook any detailed cost breakdown on the alternative of taking power under sea direct to Bradwell or the Thames estuary.
13. There is no longer any urgency for a new 400kV line between Bramford and Twinstead if the planned replacement of conductors on existing lines goes ahead. This alone will provide a 30% increase in capacity, more than enough for the planned power stations at Kings Lynn and New Holland.
14. The likely date for the start of transmission from the new nuclear power station at Sizewell and the off shore wind farms has slipped substantially since National Grid initiated this application and will not now be before the 2020s. Moreover, the additional 400kV line from Bramford to Twinstead will likely be inadequate to accommodate the total output once the future east coast nuclear power plants and all anticipated wind farms come on stream in the next15 to 20 years.
15. There is now sufficient time to thoroughly investigate more substantial environmentally acceptable proposals fit for the 21st century, which will satisfy the demand in the London area, and, crucially, accommodate future electricity generation through to 2030 and beyond (including the next anticipated batch of Round 3 wind farms). This investigation should not only include the possibility of different connection points for future East coast offshore wind generation nearer to the point of greatest demand; connection points which would obviate any need for an additional Bramford to Twinstead line; but also the adoption of new transmission and storage technologies already under development, as set out in the ENSG Electricity Transmission Report “A Vision for 2020”.
16. Specifically, it will allow time for a thorough investigation into new cable technology for under sea high-voltage direct current (HVDC) transmission.
17. Furthermore, as the Addendum to the ENSG Report states, it will probably be necessary to construct a further 400kV double circuit route between Walpole and the Eaton- Socon overhead transmission route. If further investigation to provide a long term UK solution shows that this will happen in any event, the additional 400kV line between Bramford and Twinstead may turn out to be unnecessary on this ground alone.
18. For the above reasons and those advanced by other opposing organisations, including Dedham Vale AONB and Stour Valley Project, The Dedham Vale Society and Stour Valley Underground, National Grid should not be permitted to proceed with any of the four overland routes.
Charles Aldous (Chairman) 26th February 2010.
To Robin Clarke,
OPM,
25b Gray’s Inn Road,
London WC1 8WG.
RESPONSE TO CONSULTATION ON NATIONAL POLICY STATEMENTS EN-1 & EN-5.
This response represents the views of the Colne-Stour Countryside Association; a long standing Association formed to protect the countryside of North Essex/South Suffolk, including the upper Stour Valley, seriously affected by the National Grid’s Bramford to Twinstead Overground Power Line Project.
The following comments address particular concerns with the draft Policy Statements EN-I and EN-5, which should be reflected in the final version before it is formally approved.
As a general comment, the regulatory framework is tilted too strongly to an acceptance of overhead pylons as the most efficient and economic system for electricity transmission. The suitability and cost of electricity transmission proposals should be looked at on a whole life cost/ benefit, calculated across the full working lifetime of the proposed installation. It should not be determined, as at present, on a short term view, largely on their upfront capital cost.
Although it may have a cost element, protection of the environment for future generations is becoming increasingly important. Damage to the landscape from large scale pylons can be severe and permanent. There is insufficient emphasis on the need, in appropriate cases, for National Grid to prefer what may in financial terms be a more expensive solution, but is one (a) which has significant environmental benefits, (b) which, if the public were surveyed, would show that they demand it and (c) which will have a minimal effect on tariffs, if looked at as cost to the end user.
NATIONAL POLICY STATEMENT EN-1.
Section 3.3.22:
It is recognised that interconnection to Europe on the East coast will become increasingly important to the United Kingdom. New East coast transmission proposals for nuclear and off shore wind farms should anticipate this and may, as a consequence of increased sub sea transmission to centres of demand, lessen the need for some new on land infrastructure there.
Part 4.
Section 4.1.1.
Given the importance of subsections (ii) to (v), this section should make it clear that subsection (i) is subject to these, by inserting- “(subject to subsections ii to v)”- after “operate” in the 3rd line.
Section 4.1,5
We suggest the words from “directly related” be revised. Otherwise it may not permit the IPC, in an appropriate case where there will be serious environmental detriment, to require money to be made available by way of a Section 106 payment for e.g. undergrounding non National Grid cables in areas to be affected by the newly erected pylons. There will be other examples where the Section 106 payment will be appropriate, but arguably not “directly related to the proposed development”.
Further Section.
There also needs to be a section entitling the IPC to require the applicant to reconsider the need or timing for the development and, if necessary re-engage with the generator, if, by the time the matter comes before it, circumstances have materially changed, for example deferring the need for the grid connection or making alternative connection points which are as or more suitable.
Section 4.1.6
As drafted this section unfairly impedes objectors by making it too difficult for them to contend that the applicant’s assessment methods are flawed and there are less objectionable but viable alternatives which have, as a consequence of the flawed assessment, been rejected (e.g. tunnelling, sub sea cabling or alternative routing). It is likely that such objections will rightly be at the core of many disputed applications.
Section 4.13
This section should advocate a precautionary approach to the installation of High Voltage AC lines, whilst the evidence may be inconclusive. The Statement should adopt prevailing European standards and rule out such overhead power lines passing within 200 metres of dwellings and twice this distance of schools. Childhood leukaemia is a risk which must not be run.
Section 4.24
If, rightly, the IPC has to reach its own judgment on whether or not to allow development within Areas of Outstanding Natural Beauty, and other scenically important parts, consideration needs to be given to whether it should be entitled to commission public surveys (at the expense of the applicant) to properly assess the public interest. Without this, its knowledge may be seriously deficient on an issue of huge importance to many.
NATIONAL POLICY STATEMENT EN-5.
Section 2.1.1
It is important to make clear that the “need” which has been demonstrated is a need for transmitting electricity from the relevant generators to where demand will be; and not necessarily a need for transmission in the manner and by the route specified by the applicant. As drafted the Section may arguably require the IPC to start by assuming that a need for transmission into the Grid at the point and by the method specified by the applicant has been shown. This is not acceptable and should be made clear to avoid misunderstanding.
Section 2.3.3
The two bullet points are expressed in the alternative. As drafted, the first bullet point, precludes the IPC from also taking account of “reasonably anticipated future requirements” when considering whether the infrastructure project should be considered in isolation. This is wrong. Where it is reasonably clear that there will in the not too distant future be requirements for additional transmission in the proximity, the IPC should be entitled to require that the project is environmentally designed to accommodate both.
Section 2.3.5
To avoid argument that, as drafted, this subsection gives primacy to National Grid’s solution, there needs to be a second sentence to the effect that the IPC can require National Grid (1) to demonstrate that the solution also takes sufficient account of environmental and social costs, and (2) to calculate the project cost over the working life of the transmission equipment to be used.
Section 2.7.4
Rewrite the bullet points to emphasise that siting of pylons only applies where overhead lines are the most suitable, so as to recognise that there have been significant advances in undergrounding and sub sea cabling.
Section 2.7.7
As drafted, this is an oversimplification. The cost of laying cables underground is not only reducing, but when looked at on a whole life basis is often not materially disproportionate.
Section 2.7.8
Again this is an oversimplification. Maintenance and repair costs of both overhead cables and underground tunnels over their full lifetime need careful evaluation, particularly when including costs of repairing overhead cables from storm damage, snow etc. The sentence relating to uprating is wrong. So far as overhead lines, uprating can only be done when the original pylons are at less than full potential. The comparison with underground appears to relate to buried cables, not tunnels.
Section 2.7.9
This section relates to out of date methods and needs rewriting to take account of new technologies and best practice.
Section 2.7.10
As drafted this section leans too heavily in favour of overhead lines in every case and puts too heavy an onus on the objector. It is not just the upfront costs which are relevant, but the costs calculated over their whole working life. The section should be more neutral, so as to require the IPC, in appropriate cases where serious visual intrusion and environmental damage is obvious, to be satisfied that overhead cables are the most suitable. Also, the section should not state that undergrounding carries extra social and environmental costs. It is in fact large scale pylons traversing the landscape which can cause serious environmental and social cost.
Section 2.9
As stated above, a precautionary approach should be taken to siting overhead cables. This is a continuing worry both to scientists and to very many ordinary people. It seriously blights some properties because of it. Once erected, these cables are unlikely ever to be removed, if further research reveals a clear connection with human health. The risk should not be taken.
These comments are designed to improve the drafting and make the ground rules more even between applicants and objectors. We ask that these comments be given the most careful consideration
Charles Aldous QC. (Chairman). 17th February 2010
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National Grid’s proposals for new pylons from Bramford to Twinstead.
This is possibly one of the greatest threats to our part of the Stour Valley. Below you will see a plan of the 4 alternative routes proposed by the National Grid for new power lines to accommodate additional electricity coming from new nuclear reactors at Sizewell, further gas power stations at Kings Lynn and New Holland and offshore wind farms. If allowed, this will have a devastating effect on the area east of Twinstead, including the beautiful valleys through from Lamarsh and the Hennys. Even the proposed corridors 1&2 along the route of the existing pylons will involve in a second set of large 400KV pylons, possibly replacing the smaller 132KV pylons.
Readers should access the National Grid’s website for more detail on their proposals at www.nationalgrid.com/uk/Electricity/MajorProjects/BramfordTwinstead.
There is already strong opposition from a large number of groups and organisations, including the Dedham Vale Society and the Dedham Vale AONB and Stour Valley Project. The East Anglian Daily Times is covering the issue extensively and spear heading a campaign to stop the pylons. As many as possible should register their opposition online by going on to the EADT website at www.eadt.co.uk and typing in “pylons”. The position being taken by your Association is to join with others to do what it can to try and pressure the National Grid to put as much as possible underground, including if feasible the existing power lines across the more beautiful parts of our area. This is being strenuously resisted by the National Grid who maintain that to put power lines underground can cost up to 17 times as much as overhead lines, (i.e. £30 to £40 million per mile compared with around £2.4 million per mile for overhead lines), as well as carrying with it greater maintenance problems. These assertions need to be tested. More to the point is the cost of undergrounding relative to the revenue which will be earned. It is likely that the National Grid will be attempting to negotiate with individual landowners in advance for access and wayleaves for overhead lines. It is important that landowners resist and stand out for the greater prize of having the lines laid underground.
Stour Valley Underground (SVU) has been established principally to represent those living in the area within Lamarsh, Alphamstone, Middleton, the Hennys and Twinstead. Much work has already been done by them. They have an excellent website which should be visited at http://stourvalleyunderground.org.uk/.It is a sad fact that the existing pylons, which have already created such a scar on the landscape, make the argument that the new pylons will destroy the area that much more difficult. However were all power lines to be put underground, there is a strong case for this area qualifying for AONB status. This aspect should be pursued further in conjunction with the Dedham Vale AONB and Stour Valley Project.
For those wishing to delve deeper there are useful websites to access, including the anti pylon campaigners, Revolt, at www.revolt.co.uk/new/FAQs.php; and information on the Governments new planning authority at http://business.timesonline.co.uk/tol/business/industry_sectors/utilities/article68566130.ece
Charles Aldous
23.10.2009

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Latest Update and comments from Charles Aldous - Chairman CSCA
Many of you will have already attended one of the National Grid’s presentations. If you have not, do please go to one of the remaining meetings and inform yourself. It will only take about 30 - 45 minutes. Presentations are scheduled at Wickham St Pauls Village Hall on 5th January 2010 (12noon to 9pm.); Assington Village Hall on 15th January (12noon to 9pm); and Castle Hedingham Memorial Hall on 11th February (12noon to 9pm). If none of these is convenient, further meetings are listed on the National Grid, Twinstead to Bramford website.
We must accept that there is a need for further capacity in the National Grid, particularly for the supply of electricity to London and other parts of southern England, and that this will have to come from the two new gas power stations at Kings Lynn and New Holland and, probably, a new nuclear station at Sizewell. There is also the electricity from the wind farms
The first consultation stage to decide on one of the four identified corridors (shown on the plan attached to the earlier article) expires on the 28th February. It is not entirely clear how National Grid chose only these four corridors, ruling out other possible more direct routes into the National Grid and/or undersea cables from Sizewell. It is almost certain that, with minor constraints, they were selected as the cheapest, at least if looked at over a short time frame, under which the National Grid operates. For those living near Twinstead, if corridor two is chosen, National Grid intends to acquire and replace EDF’s 132 K-V line with huge 46.5 m pylons, which will create a need for a new large unsightly substation in your area.
By arranging for stage one of the consultation process to decide on which of four selected corridors to take forward, National Grid hope to have forestalled any debate on other possible routes to access the grid, and in the process have caused conflict between parishes. It is most unfortunate that there are some parishes who see their prime objective as ensuring National Grid select one of the other routes away from their area, with insufficient regard to the effect of overland cables across this beautiful part of Suffolk and North Essex.
Your Association’s position is to campaign for under grounding and not engage in trying to persuade the National Grid to prefer one route to any other. We are giving unqualified support to Stour Valley Underground, formed to represent the communities between Twinstead and Lamarsh/Middleton. SVU are campaigning for under grounding, without differentiating between routes. They have undertaken a huge amount of work for the cause. I urge members to visit their web site, where you will find a lot of information on such matters as the vital need of protecting these lovely valleys and, importantly, the feasibility, benefits and cost of under grounding.
Clearly what is needed is to pull together all those taking a similar position, whilst harnessing the work and expertise of SVU, so that we can speak with greater force and better organise opposition. Your Association will be liaising with the Dedham Vale Society, which takes a similar stance, and would like to see existing cables put underground as well. If corridor 1 or 2 is chosen. National Grid will possibly have to put the cables underground where they pass through part of the Dedham Vale AONB, as there may be requirements for under grounding in any Area of Outstanding Natural Beauty. We will be urging for, and supporting, an application to extend the existing AONB up towards Sudbury, if this is possible. This would impose a greater duty on National Grid to preserve the Stour valley.
National Grid claim that under grounding costs up to 17 times more than overland cabling. SVU has looked into this in other European countries, where power cables are consistently put underground, and where the cost may be as little as 6 times above ground.
It has been urged on us, from many quarters, that numbers do count. Please do not assume that others have the matter in hand and will look after your interests. Do sign the SVU petition (see below for their website) and also write to as many interested parties as possible, the National Grid, your MP and County and local Councillors.
www.stourvalleyunderground.org.uk Just click here and you will go straight into their website.
The address for the National Grid is: - “Freepost, Bramford, RRKX/EBGK/XXHT, Bramford to Twinstead 400KV overhead line project, Consultation Response, PO Box 5689, London WIA 4FG”.
Charles Aldous 7th December 2009
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Horkesley Park Heritage and Conservation Centre
At long last we have access to the Report obtained by CBC from Nathaniel Lichfield and Partners, which seems to recommend that this application to create a Heritage Park at Horkesley is unsuitable and outside CBC's Planning requirements for a countryside development. Please read the summary of the Report prepared by Will Pavry of Stour Valley Action Group. (Click here)
Below is what we originally wrote on this matter
At the end of February Bunting and Son resubmitted their planning application for the Horkesley Park Heritage and Conservation Centre. In many important respects the proposal has not changed. If allowed, they are forecasting 450,000 visitors in the opening year, planning for substantial café and restaurant facilities and over 48,000 sq. ft of covered garden centre, food experience and ancillary buildings, all open 364 days of the year. You can see the proposals on line at www.colchester.gov.uk/planning. Many of those objectors who have studied the proposals see them as in reality a retail scheme dressed up as a Heritage and Conservation Centre.
Along with the Dedham Vale Society, your Association is strongly opposed to the Horkesley Park proposals. If permitted they will seriously damage the character of the Dedham Vale, an important area of outstanding natural beauty. It’s unspoilt character and tranquillity will be destroyed forever. There will be a huge amount of extra traffic, leading in the summer months to congestion in the local villages and country lanes. If the purpose were really to enable people to visit and enjoy the countryside, they can do this already for free (not at a cost of up to £10.95 pp and with the footpaths fenced off to prevent access into the proposed countryside park!)
Even though objection is being spearheaded by the Stour Valley Action Group (which we support), we would ask you, and as many others as you can persuade, to write to:
John Davies,
Principal Planning Officer,
Colchester Borough Council,
PO Box 889,
Town Hall,
Colchester
CO1 1FL.
Or e-mail to: planning.sevices@colchester.gov.ukApplication
No. 090231 must be quoted and your address given on any letter or e-mail, which must be received by the 17th April. NUMBERS REALLY DO MATTER- IT IS VITAL THAT AS MANY LETTERS/E-MAILS AS POSSIBLE ARE SENT.Though a matter entirely for you, points to take may include: -• If allowed, the development will have a serious adverse effect on the Dedham Vale AONB, permanently destroying the peace and tranquillity of this unique part of East Anglian countryside.
• A predicted first year attendance of 485,000 with a turnover of £13.4 million represents an inappropriate development as defined in the Colchester Borough Council Core Strategy Document.
• The income for the first year includes £2.8 million from food and restaurant sales and £7.3 million from “gifts”. This is in reality a retail outlet. Such out of town retail facilities are excluded by the national guidelines (contained in PPS6).
• The road infrastructure is wholly unsuitable. It is highly doubtful whether the access off the A12 will be completed within the timescale. Quite apart from the undesirability of attracting such a large number of vehicles off the A12 along the A134, it is inevitable that there will be a very large and unacceptable increase in traffic coming from other directions through the local villages and country lanes.
• At peak times the traffic on the A134 will be intolerable. Many drivers currently using the A134 will also develop “rat runs” through these lanes to avoid the congestion, adding further to the unsustainable traffic levelsThis list is not exhaustive.
Do make your own points. If you need further information, visit the Stour Valley Action Group site at www.stourvalleyactiongroup.org.uk.
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Letter to Colchester Borough Council
HORKESLEY PARK HERITAGE AND CONSERVATION CENTRE.
COL/09/090231
The Colne-Stour Countryside Association strongly objects to the planning application to create what amounts to a Theme Park and substantial Retail Centre in the Dedham Vale Area of Outstanding Natural Beauty.
This Association has over 600 members and 23 affiliated councils. Its remit includes safeguarding the countryside against inappropriate development in the upper Stour Valley, extending east as far as Little Horkesley.
In summary the proposal:
• Contravenes planning policy, including both Government Policy Statements and the Colchester Borough Council’s Local Plan.
• Permanently damages the Dedham Vale AONB.
• Has a detrimental effect on local jobs and business.
• Causes serious and unwanted traffic congestion on the A134 and surrounding country lanes.
A key principle of National Planning Policy is to strictly control any new development in open countryside. Areas of Outstanding Natural Beauty are to have the highest status of protection (PPS7para 21). The proposed Theme Park and Retail Centre is clearly a major development for this particular area. It has to be subject to the most rigorous examination, (PPS7 para 22). Colchester Borough Council Planning policy is to protect…. The Dedham Vale Area of Outstanding Natural Beauty (Objective 5.4). The Council’s duty is to protect the Dedham Vale as a “peaceful area” in which [the] villages lie undisturbed by major development and heavily trafficked roads (Para 5.7).
“C02. Development in…. the Dedham Vale Area of Outstanding Natural Beauty will be subject to special scrutiny. Where such development could have an adverse impact….on the area, it will be acceptable only where an overriding national need for development in that particular location can be demonstrated.”
There is no such overriding need. The Dedham Vale Management Strategy specifies that the area is for quiet informal recreation, emphasising the need for only quiet informal public access in keeping with maintaining the tranquillity of the valley.
Planning Policy Statements make it clear that protection of AONBs must take precedence over recreation, with the views of the local community given great weight.
Proposals which contravene the principle of “sustainable tourism” must be rejected. This proposal does. If allowed, the AONB will be overwhelmed by tourism (18,000 per week in the summer months!). Local business within the AONB will be seriously affected, as the Retail Statement concedes.
Damage to the Dedham Vale AONB.
The whole site is within or should be considered as if it were within the AONB. Even that part just outside it will have a direct impact on the proposed major development within it; and should therefore under planning law be treated as a single proposal effectively within the AONB.
The Vale is unique, with its spectacular unspoilt farmed landscape, uncongested country lanes and small villages, with their local stores and public houses. As the Council for The Protection of Rural England have established, this area is now one of the very few tranquil areas left in South East England. The Planning Authorities have an obligation to protect it and ensure that it remains as it is, and is not suddenly “swamped” by a theme park, projected to be as large as Woburn Safari Park, with restaurants to seat 787 and a huge, unnecessary, Retail Centre.
Under the proposal the many public footpaths, which currently enable walkers wonderful unrestricted views across the vale, are to be “boxed” in to prevent access to the park without paying. This is not protecting or preserving the AONB!
There is no overriding need for this development. There are already numerous garden centres and farm shops in the vicinity, with regular Farmers Markets being held locally. The local public houses, which need supporting, provide all the meals required. A visit to, for example, Wyevale Garden Centre at Braintree will reveal how extensive this is.
This is in reality an application for a major 46,000 sq ft retail project, using the countryside park as the inducement, and should be treated as such. Seventy-five percent of the overall projected revenue is to come from merchandising, food and drink, with sixty seven percent coming from Merchandise Revenue alone. The Retail Centre is projected to earn £5.65million per year.
The benefits offered to conservation are limited. For example, there are several others in East Anglia who are already involved in breeding and conserving the Suffolk Punch, and many local farm parks in the region supporting rare breeds.
Detrimental effect on local jobs and business.
The proposal is likely to have a marked adverse effect on local employment. Although the restaurants and retail centre will need staff, many will be part time and low paid, coming in from outside the immediate area. The proposal recognises that more jobs will be lost in the local communities than gained, implicitly because of its detrimental effect on local business within the AONB. Government policy makes it clear that the effect on employment and business within the AONB is a vital factor.
Traffic congestion.
With the projected visitor numbers of 485,000 in the first year, peaking at 77,000 per month in the summer (or 18,000 per week), there will be major traffic problems; not just along the A134, where vehicles will be backing up to turn into or exit the site. Many will use other routes. Those coming from the South West will come across country. There will be an inevitable unacceptable overload of cars and lorries using the quiet narrow country lanes, which are required to be protected under the AONB designation. At peak times traffic along the A 134 will be incessant, making it very difficult and dangerous for local drivers to access it from side roads.
The B1068 from Higham to Stoke-by-Nayland and the B1087 from Stoke-by-Nayland to Nayland, both highly scenic and extremely narrow roads, will be choked with traffic. This is likely to be an almost insoluble problem in Nayland where the B1087 slims into a narrow throat before meeting Nayland High St.
Why, one asks, should those living and carrying on business in the AONB and the surrounding area have to suffer this?
The views of those living in the area should be listened to. This is in substance an attempt to obtain planning permission for a merchandising, food and drink centre in an AONB under the umbrella of a heritage and conservation park.
Charles Aldous QC. (Chairman) 9th April 2009.
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Fly Tipping - Keep Our Beautiful Countryside Tidy
Fly tipping is a disgusting habit and likely to become an increasing problem in an economic downturn, particularly if Council’s start charging for dumping. Although a boring subject to write about, it is important that our supporters know that we can make a real difference. All three District Councils in our area have Departments which deal with complaints, and will arrange for the removal of refuse dumped on public property and if possible bring offenders to book. Even where it is dumped on private property, and as such is the legal responsibility of the owner to remove, the Council will send out experienced investigators to try and identify those responsible and prosecute. They have designated departments there to help. At Colchester Borough Council, you can contact Shane Taylor on 01206- 282 838. For Braintree DC telephone the call centre on 01376- 552 525 and ask to be put through to “Environment”. Likewise with Babergh DC, call the department responsible on 01473 825 890. So please do what you can to ensure our countryside is kept tidy. A word of caution, anyone using a non-licensed waste carrier who then dumps the waste will themselves be liable to be prosecuted.
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Wind Turbines
The Association fully supports the Government’s aims of reducing carbon emissions through the promotion of renewable energy sources. Wind turbines have a part to play but it is important that we appreciate their limitations.
Modern turbines are over twice the height of electricity pylons and therefore have a huge impact on the UK’s rather small scale landscape. Once built, wind turbines require high voltage power lines to connect them to the grid as well as service roads, greatly increasing their impact on the countryside.
Furthermore wind turbines are not particularly efficient and on average operate at only about 27% of installed capacity. Because the wind only blows intermittently and the demand for electricity is constant, they will all have to be backed up by fossil fuel or nuclear capacity.
Present installed capacity of wind farms in the UK is about 2.5 GW or 3% of the country’s total power capacity. Nuclear power on the other hand supplies approximately 20% of the country’s energy and modern nuclear reactors do not carry the risks associated with the old Chernobyl type reactor. We believe that there will have to be a significant increase in the nuclear programme if the UK is to avoid power shortages.
The Association will only support the building of new wind farms on coastal and other exceptionally windy sites. We will oppose the erection of random wind turbines in the villages of the Colne and Stour valleys as these are likely to provide very little economic benefit at the cost of serious damage to the landscape given that they can only ever supply a small percentage of this country’s energy requirements.
For the above reasons, will any member who hears of an application to erect a wind turbine in our area please contact the Association’s local representative or a member of the Committee so that appropriate action can be taken
Wind Farms.
Apologies for repeating what I have said before, but there is an increasing likelihood of applications for unsightly and intrusive wind farms in our area, which will permanently scar our countryside. Except in the higher areas of the UK where the wind is stronger and more reliable, wind farms should be sited off shore. As I reported earlier, in the lower areas of Southern Britain, on shore wind power is insufficient. For example, in the coldest months of the year when energy demand is at its highest, on shore wind farms in East Anglia will produce a minimal amount of electricity. However due to very substantial Government inducements, such wind farms can still be profitable to landowners, even when operating at these very low inefficient levels. Ultimately it is us, the taxpayer, who has to subsidise this. Please be alert. If anyone hears of a threat to install any large scale wind turbine in their area, don’t assume that others will be “on the case.” Do please take action yourself; lobby your Parish Council, write to your local councillor, and as importantly contact your local CSCA representative.
Charles Aldous (Chairman).22.04.2010
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Pylons
Your Association is implacably opposed to all the proposed routes suggested by National Grid and we contend that the consultation process is seriously flawed as NG has not complied with its statutory obligations under Section 47 of the Planning Act 2008 and the pre consultation guidance which is designed to ensure that all reasonably feasible options have been fairly put to the Local Authorities so that they can decide which should go out for community consultation. NG would have us believe that there are only four options whereas there are other alternatives that have not been given a hearing. (Undersea and Underground)
If you have not already done so, we urgently need you to write to The National Grid at the address given below, as well as to your County and District Councillor and MP, incorporating some or all of the bullet points listed below, together with you own objections. Individual letters count. Please write your letter in your own words.
• NG has not given the Local Authorities the chance to assess any alternatives other than the four proposed routes.
• NG has not consulted on an undersea cable to the Thames.
• NG has not consulted on a more direct underground tunnel route.
• NG have not have not considered the true lifetime costs of the above alternatives (including environmental and social benefits).They have merely dismissed them on short term expense grounds.
• NG has not shown that once the existing line is upgraded, the urgency to deliver more electricity to the Twinstead interchange, by alternative means, is delayed.
• NG has not disclosed that, even if another line were built, this would be insufficient to take the electricity to be generated by another Nuclear Reactor at Sizewell, together with electricity from an anticipated further round of Wind Farms. (Are they going to suggest yet another line of pylons?)
• NG has not taken into account the Special Landscape importance of the upper Stour Valley towards Twinstead, exemplified by the decision to apply for an extension of the Dedham Vale AONB up as far as Sudbury.
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Council for the Protection of Rural England. Essex Branch
CPREssex, the Campaign to Protect Rural Essex, exists to protect the beauty,tranquillity and diversity of rural Essex by encouraging the sustainable use of land and other resources.
CPREssex is pleased to support the Colne-Stour Countryside Association in its effective and determined campaign against National Grid’s intrusive and environmentally damaging pylon extension proposals.
In a wide range of environmentally sensitive areas, dedicated CPREssex activists, with the support of a highly regarded and very influential national office, are working hard to ensure that the effects of economic growth do not result in irreversible damage to our countryside.
Landscapes such as those of the Colne and Stour Valleys, good schools and housing, a true sense of social cohesion and belonging, strong local roots, commutability and increasing prosperity attract more and more people to live here. Our incomers are welcome but increase the pressure for housing development and airport expansion, whilst putting a further strain on increasingly overstretched resources such as utilities, roads, water, schools and hospitals. CPREssex is pleased to be able to support the CSCA in its effective and determined campaign against National Grid’s intrusive and environmentally damaging pylon extension proposals.
CPRE welcomes the abolition of the system of imposing regional housing quotas. However, our concern is that a policy vacuum has been created which could result in a period of unconstrained greenfield housing development at the expense of the regeneration of towns and cities. We are urging adequate consultation and debate about the forthcoming Localism Bill, which among many other things may permit village developments by local housing trusts without planning permission. We are particularly concerned that there may be inappropriate incentives to build new houses when there are so many empty properties in need of renovation. The tax incentives strongly favour VAT free greenfield housing, rather than more challenging but less remunerative brownfield housing development. When it comes to renovating the existing housing stock, VAT is almost always applicable, resulting in a 17.5% subsidy for greenfield house developers, rising to 20% from next year.
In a wide range of environmentally sensitive areas, dedicated local CPREssex activists, with the support of a highly regarded and very influential national office, are working hard to ensure that the effects of economic growth do not result in irreversible damage to our countryside. As well as housing sprawl and new pylons, CPRE are active opponents of, for example, airport expansion, spending on road building at the expense of investing in public transport, fly tipping,invasive onshore wind turbines and wind farms, and inappropriate mineral extraction and waste disposal.In each of these areas we have vigilant and expert volunteers.
What’s good for our countryside is good for our towns and cities. The more attractive we can make our towns and cities, the less pressure there will be on our rural communities, and the greater the chance that our children will eventually be able to afford to buy homes in the communities they have grown up in.
Please have a look at our CPREssex website www.cpressex.org.uk or ring us on 01376 572023 if you would like to learn more about what we do. We are a completely independent organisation and we don’t get a penny of government funding, which means we can speak our minds frankly and without fear. We passionately believe our countryside deserves nothing less.By joining CPRE you can make the Colne-Stour Countryside Association’s voice heard nationally and regionally as well as locally.
Tom Holme, CPREssex Chairman
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Localism Bill threatens massive new house building on greenfield farmland?
Under the previous Government, regional house building quotas were imposed via the East of England Regional Assembly. There was some environmental consultation, but the main driver was the perceived requirement for continuing economic growth.
The East of England Regional Assembly was abolished and replaced by the East of England Development Agency. The new Government promptly abolished the East of England Development Agency.
A reformed planning system will be contained in the forthcoming Decentralisation and Localism Bill. The stated aim of the reforms is to shift power away from central government and put local communities in charge of planning.
Whilst the decision to abolish imposed Government housing quotas is welcome, there are growing fears that the current absence of clear replacement planning policies has created a vacuum which will result in unconstrained greenfield housing development at the expense of the regeneration of our towns and cities.
The Campaign to Protect Rural England, CPRE, exists to promote the beauty, diversity and tranquillity of the countryside by the sustainable use of land and other resources. CPRE and its Essex county branch CPREssex are urging the Government to make protection and enhancement of the natural environment a key objective of the forthcoming Bill, and in particular those elements of the Bill which focus on planning reform.
A robust planning system has done much in recent years to protect greenfield land throughout the county of Essex from unnecessary and inappropriate development. CPREssex is asking the Government for a planning system which delivers long term gains, rather than a short term deregulation of house building to the detriment of the Essex countryside.
We cannot see how the Coalition Government hopes that the Decentralisation and Localism Bill will fulfil its pledge to be the 'greenest government ever’. There are certain specific likely environmental dangers which CPRE have identified and which we are campaigning to be taken account of.
A “Community Right to Build” envisages housing development without planning permission where it is favoured by the majority in a community. We are calling for this to be regulated to ensure that local communities are not unfairly pressurised by developers.
We are concerned that the payment of incentives for building new housing through local plans is monitored and safeguarded, to ensure transparent disclosure and environmental protection.
The proposed Local Enterprise Partnerships (LEPs) entail alliances between councils and business interests. There seems to be no provision for environmental protection in LEPs: we are seeking to rectify this.
CPREssex recognises the need for housing, but we advocate a genuinely sustainable approach to its provision, rather than an ill considered dash for development with potentially catastrophic environmental consequences for the county of Essex.
Nationally and locally, we are doing our utmost to engage with our elected representatives about our concerns in the process of consultation and debate about the forthcoming Bill.
Tom Holme Chairman CPREssex
The Localism Bill
The main speaker at the CPRE lecture on Thursday 10 February was Greg Clark, the Minister for Decentralisation with ultimate responsibility for the Localism Bill. The panel comprised CPRE’s Chief Executive Shaun Spiers, Professor Patsy Healey of Newcastle University, a planning expert, and Debbie Tripley of the Environmental Law Foundation.
Although there are positives in the Bill, I fear the Government has got the substance of this crucial bit of legislation utterly wrong, and that we are sleepwalking towards the environmental catastrophe of a development free for all.
The Minister reinforced the Government’s pro growth and development stance. They want to “unlock the right kind of development” and “require development to be sustainable”: these are words which seem to invite greenfield development.
The Government believes that if a Neighbourhood Plan is agreed by a community, there need not be a third party right of appeal. The Minister gave assurances that financial support and advice will be available to assist local groups making Neighbourhood Plans, which must not “frustrate a pressing need for homes.”
Patsy Healey responded that checks and balances are required to stop “the big barons running amok.” We need discussion and debate rather than exhortation. Developers must buy into collaborative planning.
Debbie Tripley responded that Community Plans can be ignored by local authorities and that Community Groups comprising a minimum of three people, only two of which need to live in the area, can be hijacked by developer.
Shaun Spiers highlighted CPRE’s three main areas of concern:
1 The framework of the new system
Local Enterprise Partnerships with no regard for environmental protection.
Development incentives which reward the numbers of houses built.
2 How can development possibly be “sustainable” if:
The planning system is perceived as an impediment to economic growth?
Economic objectives override social and environmental objectives?
3 There must be a third party right of appeal in Neighbourhood Plans. Rebalancing the planning system to favour development is wrong.
This Bill in its present form will perpetuate the importance accorded to the pursuit of economic growth in planning decisions. In a country with finite resources of undamaged countryside, and particularly so here in Essex, this can only accelerate environmental degradation with a hugely adverse and unsustainable outcome.
The Localism Bill has been through two readings and will have gone through the report stage in March. CPRE has serious concerns about the reality of this Bill beneath its headline claims of a new dawn of local emancipation. It is now time to make our views known more forcefully.
What have CPREssex done to date?
1 We organised Westminster Essex MPs’ planning briefings in July 2010 and March 2011 with participants from CPRE’s National Office and CPREssex.
2 We wrote to Essex MPs about our specific areas of concern last October, and sent them CPRE’s Charter for Planning Reform last November.
3 In our individual capacities, CPREssex members have written to our own MPs expressing our concerns.
Please:
* Publicise the environmental threat of the Localism Bill, for example by circulating this email.
* Commit as much of your time as you can spare towards this crucial campaign.
* Ask people to join CPRE and to join us in our campaigning.
Thank you
Tom Holme
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