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National Grid
5th September 2008
Dear Sirs,
As promised at our meeting with you on Tuesday 19th August, I now write to express the views of
CAPRI.
1. CAPRI agreed to participate in the consultation process in the genuine belief that such process would be fair and thorough; that we might be able to make a useful contribution to the process and in the hope that constructive discussion might achieve a reasonable solution to the problem of identifying a suitable site for the PRI.
2. After I had received from you the Stage Three Assessment, the Third Stage Schedule of Data
('matrix') and the accompanying map, I - accompanied by the other officers of CAPRI and planning
officers from Tewkesbury Borough Council and the Forest of Dean District Council - inspected on
18th. August a number of the “representative locations” identified in that Schedule. I do not know why the phrase “representative locations” was used in the Assessment: my understanding was that the purpose of the search was to identify potential sites for a PRI - which is the phrase used in Fact Sheet 7 - and not “representative locations” - whatever that may mean. What is the purpose of including the word “representative” and what are the characteristics which made each location “representative” and of what?
During that inspection we were all astonished by the inclusion of some of those locations - e.g.
locations 1 and 22 - which were manifestly inappropriate given that they are on high ground. These two were so inappropriate that their inclusion calls into question both the purpose of the Assessment and Schedule as well as their credibility.
3. Before the meeting with you on 19th. August, I expected – and I believe that this expectation was shared by all the planning officers involved – that discussion would focus on a short-list of possible locations chosen from the 23 candidate sites identified in your Third Stage Schedule of Data. I had assumed that those 23 locations would be subjected to both discussion at the meeting and possible further investigation and perhaps inspection on the ground.
4. It was therefore with great concern that on 18th. August, the day before the meeting arranged with you, I received a copy of your Fact Sheet 7. I assume it had been prepared carefully so I have no reason to believe that it does not set out your position accurately. It claims (page 3, column 1) that you have consulted “at each stage” of the siting evaluation with CAPRI and four planning authorities and (page 2 column 3) that this “narrowed the ...sites... to two”. That claim is completely untrue because:-
(a) instructions must have ben given by you for the preparation of the Fact Sheet in mid-July or
thereabouts long before CAPRI received copies of the Assessment, Schedule or map so there had been no discussion whatever with CAPRI.
(b) it implies that CAPRI endorses the selection of the two locations identified in the Fact Sheet and any member of the public reading that Sheet would reasonably assume that was so - which I presume was the reason for so saying. I therefore request that you correct this grossly misleading claim by writing a letter, in terms previously agreed by CAPRI, to all those to whom you issued the Fact Sheet, and by making a suitable announcement in the local press.
(c) there have been four meetings which were held on 25th January, 14th April. 2nd May and 22nd July before the meeting on 19th August. At the first of those there was a discussion about the methodology to be used in the search for possible alternative locations: you invited comments and I wrote to you on 10th. March with the comments of CAPRI. At the other three meetings there was no consultation at all about possible locations because the awaited data was not available: those meetings were used by you to report the progress made in the search you were conducting: they were therefore briefing meetings - not consultations - and this is evident from the minutes. I would remind you of Minute 5 of the meeting held on 2nd. May where, in answer to my question, you confirmed that no decision had then been taken about preferred site options.
5. The Fact Sheet invites the community to express a preference between the two locations at Corse and Tirley which you alone have chosen and no opportunity is offered to the public to propose or express a view about other possible locations. It is therefore clear that when instructions were given by you for the preparation of the Fact Sheet you had already decided that the PRI would be located at either Corse or Tirley and it therefore follows that the whole consultation process has been a pointless sham.
6. I note from the Schedule you have supplied that Corse and Tirley are the cheapest options available to you and I conclude that cost is for you the determining factor and impact on the environment is not a significant consideration. Your approach therefore vitiates the purpose of consultation.
7. In view of the points made above, I am forced to question whether your search for alternatives – as recommended by the Inspectors – was a genuine endeavour or whether it was a search for something which you had already decided not to find. At the Inquiry last year, CAPRI strongly suggested that connecting the new 1200mm pipe to the NTS should be made at Wormington where it could be accommodated within the existing site and obviate the need for a PRI at either Corse or Tirley. This would have undeniable visual advantages as well as offering much better opportunities for adequate security.
8. At the first meeting, on 25th January, Mr Reynolds of the Forest of Dean District Council said that if a planning application for a PRI were submitted to that Council he would expect it to be accompanied by a detailed evaluation showing that a connection at Wormington had been thoroughly investigated. The Minutes of that meeting record this and state that “NG will consider this matter and make its position clear”. However all you have done is to reject such a connection solely on the ground of cost but you have provided no justification for that basis of rejection nor any evaluation of the benefit such as concentrating various elements of the NTS in one place.
9. You stated at the meeting on 19th. August that you are under strong commercial pressure to complete the PRI in order to allow the early flow of gas through the pipeline at the design pressure. I am aware that because of your failure to obtain planning permission from the Forest of Dean District Council in October 2006 and the subsequent failure to obtain permission on appeal, the construction of the PRI is now substantially behind the schedule which you originally envisaged and to which I understand you are contractually bound. This may well be a factor which has played upon, and distorted, your judgement and I now strongly suspect that the exercise which you have purported to undertake with us and the representatives of local planning authorities may have been from the start - or became so after its initiation when the reality of the commercial pressures upon you became apparent - no more than a sop to satisfy a quasi-legal requirement imposed upon you against your will.
10. Your "consultation" with CAPRI is probably characterised by your "consultation" with the public. Commencing your exhibitions in the last week of the school holiday season suggests that you did not want many members of the public to attend. However, in spite of the criticisms set out above, I and my fellow officers are prepared to attend further "consultation" meetings provided that they are held genuinely to discuss possibilities and are not simply forums where you tell those who attend what you have already decided to do.
Yours sincerely,
Peter M. McMurtrie
Chairman, CAPRI
Copied to:
Forest of Dean District Council
Tewkesbury Borough Council
Malvern Hills District Council
Herefordshire County Council
Chief Executive, National Grid
To see what they replied, click here
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