Dear
Mr Rider,
NATIONAL GRID
plc – Proposed construction of PRI and associated works east of
Flat Farm (“the Site”); Application Number 08/01665/FUL
Thank
you for meeting us on 18th
August. CAPRI values the opportunity of meeting
you as the Officer dealing with this application; we are most
grateful for the opportunity that this gives us for an exchange of
views.
Further
to that meeting we now comment on the additional information
submitted by National Grid (“NG”) in response to your letter of
27th May;
our comments are categorised as follows:
•
Lighting
•
Extent of
landscaping
o
Hard landscaping
o
Soft landscaping
•
Hedgerow
translocation
•
Alternative
site
1.
LIGHTING
We
have studied the plans submitted by NG. Whilst both the number and
height of maintenance lighting standards have been reduced, we are
nevertheless mindful that at the Public Inquiry great concern was
expressed about the nuisance that bright lighting during the hours of
darkness would cause to local residents and to passing traffic. We
have the following concerns:
1.a
From the latest details submitted, it would appear that all the
lights will be on the same circuit, with the result that if lighting
is required at the Site all lights will be turned on even though the
illumination is required for only part of the Site. We suggest that
there should be separate circuits for different parts of the Site so
that either illumination can be provided for the whole Site or only
that part of the Site where lighting is required.
1.b
All the proposed maintenance lighting standards will be 8 metres
high and will be very visible during daylight hours when they achieve
no useful purpose. This will constitute an unnecessary visual
intrusion which it would be easy to avoid if the standards were
telescopic, being raised only when it was necessary to turn on the
lights. We understand that this possibility has not been investigated
by NG.
2.
EXTENT OF LANDSCAPING
Although
the proposed land take for the Site has been increased, the
additional land will provide no improvement for the reasons below.
2.a.
Hard Landscaping
The
latest proposal provides for bunding to be constructed to a different
configuration, and over a larger area, than initially proposed,
thereby enabling some gradients to be less steep. However, the
maximum height of the bunds remains unchanged.
The
effects of this are twofold:
(i)
as demonstrated by the submitted plans, there will continue to be
uninterrupted views – especially from the B4213 - into the centre
of the installation, and
(ii)
the bunds by their very nature will constitute an alien intrusion
into the
rural
landscape, which is currently open land sloping gently down from
south to north.
2.b
Soft landscaping
The
new proposal remains wholly inadequate because:
(i)
all the trees chosen are deciduous and cannot provide any screening
for half the year;
the
species chosen will take a long time - perhaps 20 years – before
they screen even the buildings, and they will never screen the
vent stacks and the lighting standards;
establishing
trees on bunds is a notoriously difficult and lengthy process. In
summary, the latest proposals do not in any way make this
intrusive installation less harmful to the rural character of the
countryside.
3.
HEDGEROW TRANSLOCATION
The
hedgerow is old and has been allowed to become mature without being
laid for many years, if at all. As a result, it will have developed
an extensive fibrous root structure with the roots extending outwards
for considerable distances. Translocation is very likely to involve
cutting into this root structure relatively close to the stems of the
plants and this will reduce the ability of the plants to survive. In
the face of what we believe will be a high failure rate, we maintain
that the proposal is misguided and that translocation of this hedge
is doomed to fail.
4.
ALTERNATIVE SITE
In
their site selection process, NG identified Site 16 (‘the
Alternative”) as a potential alternative to the Site. From
inspection, it would appear that the Alternative would be much less
disruptive to the visual appearance and amenity of the immediate area
because:
4.a.
it lies within the slopes of a secluded valley which would provide
immediate landscaping advantages;
4.b.
Downend Coppice is an existing substantial woodland to the immediate
north and would provide very effective screening of the Site from the
north;
4.c.
it cannot be seen from the main road (A438);
4.d.
it lies within a less densely populated area than the Site;
4.e.
according to NG, the nearest dwelling to the Site is 525m away, a
distance
which
is greater than is the case at the application site.
COST
NG
claim that they have made an extensive search for suitable
alternative sites. Whilst it is true that they have conducted a
search, it is apparent that their intention has always been to find a
site immediately adjacent to the pipeline. Environmental
considerations are obviously of much less concern to NG than
providing the PRI at as low a cost as possible; this is evident from
their selection of the first application site (at Corse) which was
manifestly unsuitable and was rejected as such on appeal.
Applications
are required to be considered on their merits and their cost is not a
planning consideration. This application has no merits at all and a
grant of permission would be unjustified. Alternatives to the Site,
suitable and feasible, do exist; the fact that they would be more
expensive than the Site is irrelevant to consideration of this
application.
Ever
since 1st July 1948 – when planning control first became effective
– there have been planning policies designed to protect the
countryside from development unless justified by particular
circumstances; these policies are incorporated in the development
plan. There are no such circumstances relating to the application and
accordingly there is no valid reason which would justify a departure
from the development plan.
CONCLUSION
In
their letter of decision dated 20th December 2007 relating to the
previous appeal, the Secretaries of State
‘concluded
that the harmful and intrusive impact that the appeal proposal would
have on the rural landscape is not outweighed by the important and
urgent national need. Overall, the Secretaries of State consider that
the proposal would not accord with development plan policy. They do
not consider that there are any material considerations, when
considered whether jointly or severally, to lead them to determine
the proposal otherwise than in accordance with the development plan’
and
for that reason they dismissed the appeal.
CAPRI
submits that the reasons cited by the Secretaries of State apply
equally to the present application and that the application should
accordingly be refused.
Yours
sincerely,
Peter
McMurtrie
Chairman