The Planning Inspectorate National Infrastructure Planning Temple Quay House 2 The Square Bristol BS1 6PN Emailed to: [email protected] FAO Mr Hefin Jones 25 July 2019 Dear Sir/Madam Location: Southampton to London Pipeline Project Proposal: Notification from Esso of acceptance of their DCO application (by the Planning Inspectorate) and deadline for registering as a Interested Party Following the Planning Inspectorate’s acceptance of an application for a Development Consent Order (DCO) for the Southampton to London Pipeline, Runnymede Borough Council requests to be registered as an Interested Party at the Examination. Runnymede Borough Council (RBC) is a host Borough and also landowner affected by the development. Chertsey Meads, a public open space owned by the Council is a key parcel of land required to be used to enable the pipeline to go under the River Thames. Runnymede Borough Council is not a unitary authority and therefore a number of matters, such as Highways, Transport and Archaeology fall within the remit of Surrey County Council (SCC). Esso’s discussions with SCC have not been shared with RBC and therefore RBC are now making enquiries as to SCC’s position. This letter provides a summary of the main aspects of the proposal which RBC is presently in a position to confirm that it agrees and/or disagrees, together with an appropriate explanation, in accordance with the Planning Inspectorate Advice Note 8.3. The response below is an initial response as the Council is currently reviewing the detailed documentation submitted with the DCO application and therefore the Council reserves the right to make further written representations during the examination should it be required. The issues raised will be the subject of detailed written representations and a Local Impact Report which will be submitted during the examination process. Having now recently received an initial draft RBC is actively engaged with Esso in compiling a Statement of Common Ground. RBC has engaged positively and proactively with Esso and this has gained momentum as resources have allowed. Throughout discussions, RBC has considered the impact of the project on communities that appear to be directly affected along with the wider impacts across the Borough. Whilst RBC notes that the proposed development will deliver a significant national benefit to the South East, the anticipated local impacts during construction must be addressed Runnymede Borough Council, Civic Centre, Station Road, Addlestone, Surrey, KT15 2AH Tel: 01932 838383 Fax: 01932 838384 DX 46350 Addlestone www.runnymede.gov.uk for which RBC consider greater clarity is needed and specifically details as to how impacts might be mitigated. The matters referred to in this representation are based upon the representation submitted in February 2019 in response to the route design consultation. The Examination Panel and therefore invited to consider both representations to be read together. For information purposes, the examination panel is advised that RBC received a draft Statement of Common Ground on Friday 5th July 2019. RBC disagrees with the proposed content and this is under active negotiation. RBC will continue to discuss its concerns and we are optimistic that there will be progress in reaching a final document that fairly addresses RBC’s current concerns. Compulsory acquisition of the land and rights in the DCO RBC object to the compulsory acquisition of the land and rights in the Order. RBC consider that the applicant has failed to take adequate steps to acquire the land and rights by negotiation, and that there can only be a compelling case for the acquisition of the rights if appropriate measures are provided to mitigate the adverse effects of the implementation of the scheme. Esso have not been forthcoming in identifying what mitigation and compensation is offered. Highways and Transportation • RBC are seeking the advice of SCC on traffic impacts from the construction of the project. This includes the impact of construction vehicles on the condition of highways within the Borough. We understand that SCC have concerns regarding the current proposed DCO which removes a number of powers currently held by SCC. RBC supports SCC in any objection raised on this point. RBC is not satisfied that the provisions in the DCO are sufficient to ensure that such works will be carried out without significant disruption to the local road network and inconvenience to residents. • RBC notes Articles 9, 10, 12 and 15 of the DCO contain extensive provisions permitting alterations to works in streets in the Borough. Although there is provision for approvals to be obtained from the highway authority, no provision is made for engagement with the Borough as to the manner and timing of the exercise of these powers. In particular, the Borough seeks provision to be made for consultation with the Borough prior to the temporary stopping up of streets and public rights of way in its administrative area, and prior to the exercise of the traffic regulation provisions in Article 15. • RBC anticipate a high level of activity in delivering housing within the Borough at the same time proposed for the construction of the Pipeline. This anticipated development coincides with other developments taking place in Surrey Heath and Woking and the Council has recognised that there will be a cumulative impact on the A320 corridor. The Council has published a study developing a package of mitigation measures which address and \ or minimise the impact of the growth to enable the delivery of the developments. The Council is actively pursuing a funding bid with the Housing Infrastructure Fund which includes details of the capacity issues on the A320. • The information provided in Esso’s Environmental Statement (ES) is generalised and non- location specific. RBC seek assurance that the construction of the Pipeline will not result in any significant impacts (ref. capacity and congestions) on the transport network in accordance with paragraph 108 of the NPPF, particularly when viewed against the background identified in the A320 corridor study. • Officers request that the Code of Construction Practice (CoCP) sets out how the local authority will be kept informed of when and where works are taking place. • Employees travelling to the site by car and the impact on the availability of on street parking where there are no public car parks available, is expected to be covered in the CoCP including 2 details of where residents should be directed in the event of a complaint. Similar parking considerations relate to residents of streets which are temporarily severed. The condition of the highways is expected to deteriorate as a result of additional HGV traffic and as a result of overrunning of the carriageway edges and verges. The applicant is required to conduct road condition surveys to identify where construction traffic has caused damage and the applicant will be expected to rectify this. Flooding and Drainage Runnymede has historically suffered several flood events and RBC welcome the approach taken by Esso to follow good practice guidance. However, RBC will be seeking the views of the EA and LLFA as to whether the measures proposed are appropriate e.g. soil stockpiling within floodzone 3, as suggested by the Applicant. Furthermore, RBC will seek advice on whether the identified risk is accurate and any proposed mitigation proportionate. The Chertsey Meads, owned by the Council, which is said to be critically required to enable the pipe to be laid across the River Thames, is vulnerable to flooding. Verbally RBC has been advised construction works on the Meads would take place in the summer at a time when seasonal flood risk is low. This has other implications (discussed below). RBC requires clarification as to how these impacts will be mitigated. Green Belt (Saved policy GB1) RBC understands that the impact of the Project on the Green Belt will be temporary during the construction period only. As limited details are available on the construction plan RBC reserve the right to comment further on the impact as more information becomes available. Ecology and Nature Conservation • The proposed route crosses or is adjacent to Areas of Landscape Importance (Saved Local Plan policy NE8); Local Sites of Nature Conservation Importance; Queenwood Golf Course. SNCI (south of Stonehill Road) and Chertsey Meads. SNCI. In addition, Emerging Policy EE9: Biodiversity. Geodiversity and nature Conservation states that the Council will seek net gains in biodiversity, through creation/expansion, restoration, enhancement and management of habitats and features to improve the status of priority habitats and species. • The proposed route crosses several Biodiversity Opportunity Areas (BOAs) including but not limited to Chertsey Meads and Foxhills Golf Course. Emerging policy EE11 Green Infrastructure sets out that the Council seeks to avoid further fragmentation of Green Infrastructure and would seek development to contribute to Green Infrastructure assets. Runnymede considers that the applicant should commit to restoring and enhancing those BOAS affected by the Pipeline construction. Where this is the Council requestsa financial contribution to offset the impact to Chertsey Meads which is within the Council’s ownership. • Officers encourage the applicant to commence a dialogue with Surrey Wildlife Trust regarding these issues. Officers anticipate that in managing the impacts, the Construction Code of Practice (CoCP) and Ecological Management Plan will set out the approach and Officerswelcome early site of this in relation to Chertsey Meads specifically. • The Meads is a Site of Nature Conservation Importance, the eastern half being a Local Nature Reserve.It is also protected as a Queen Elizabeth II Field via the "Fields in Trust" organisation. It is one of the very few River Thames flood plain meadows left in the lower reaches of the river. The site supports an ecosystem which includes many species of wild flowers and grasses which characterise such flood plains as well as many increasingly rare plants due to the serious loss of river flood plain habitat resulting from their drainage and 3 development.