The Millbrook Power (Gas Fired Power Station) Order

Comments on Relevant Representations – Submitted at Deadline 2

Planning Act 2008 The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: EN010068 Document Reference: N/A Regulation Number: N/A Author: Millbrook Power Limited

Revision Date Description 0 April 2018 Examination Version

Millbrook Power Limited

Applicant's Comments on Relevant Representations

Deadline 2 - 17 April 2018

Project Ref: 40334 | Rev: 01 | Date: April 2018

Office Address: 33 Bowling Green Lane, London, EC1R 0BJ T: +44 (0)20 3824 6600 E: [email protected] Comments on Relevant Representations Millbrook Power Project

Contents

1 SUMMARY ...... 1 2 REP-001 ELAINE RANDALL ...... 2 3 REP-002 WYNNS LIMITED ...... 4 4 REP-003 LOUISE WARD ...... 5 5 REP-004 TRACEY DOWERS ...... 6 6 REP-005 KEN WORF ...... 7 7 REP-006 CLIVE BAKER ...... 9 8 REP-007 THE COAL AUTHORITY ...... 10 9 REP-008 ANGLIAN WATER SERVICES LTD ...... 11 10 REP-009 NATIONAL GRID ...... 12 11 REP-010 CIVIL AVIATION AUTHORITY ...... 13 12 REP-011 MINISTRY OF DEFENCE ...... 15 13 REP-012 BEDFORD BOROUGH COUNCIL ...... 16 14 REP-013 ENVIRONMENT AGENCY ...... 17 15 REP-014 NETWORK RAIL ...... 19 16 REP-015 HOGAN LOVELLS INTERNATIONAL LLP ON BEHALF OF COVANTA ROOKERY SOUTH LIMITED ...... 21 17 REP-016 JEREMY RAMSDEN ...... 22 18 REP-017 CENTRAL BEDFORDSHIRE COUNCIL ...... 25 19 REP-018 HISTORIC ENGLAND ...... 28 20 REP-019 MARSTON MORETEYNE PARISH COUNCIL ...... 29 21 REP-020 NATURAL ENGLAND ...... 31

Appendix A Additional Correspondence with Environment Agency ...... 33 Appendix B Correspondence with Network Rail ...... 34 Appendix C Additional supporting illustrative material submitted to Historic England35 Appendix D Meeting Minutes and further air quality information submitted to Marston Moreteyne Parish Council ...... 36

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Comments on Relevant Representations Millbrook Power Project

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Comments on Relevant Representations Millbrook Power Project

1 SUMMARY

The Applicant, Millbrook Power Limited, is applying to the Secretary of State (SoS) under the Planning Act 2008 (PA 2008) for development consent to construct, operate and maintain an Open Cycle Gas Turbine (OCGT) gas fired peaking power generating station, fuelled by natural gas with a rated electrical output of up to 299 Megawatts (MW) (the Millbrook Power Project).

The Development Consent Order (DCO) Application for the Millbrook Power Project (the Project) was submitted by the Applicant to the SoS in October 2017. It was formally accepted to progress to examination in November 2017. Following acceptance, the Applicant consulted on the accepted Application pursuant to Section 56 of the PA 2008. The consultation period ran from 29 November 2017 to 19 January 2018. In response to the consultation period, a total of 20 Relevant Representations (RRs) have been made.

The 20 RRs received during the consultation period are from the following groups:

° 2 local planning authorities (Rep 012, Rep 017);

° 7 members of the public/business (Rep 001, Rep 002, Rep 003, Rep 004, Rep 005, Rep 006, Rep 016);

° 1 other organisation (Rep 015);

° 9 prescribed consultees (Rep 007, Rep 008, Rep 009, Rep 010, Rep 011, Rep 013, Rep 014, Rep 018, Rep 020); and

° 1 parish council (Rep 019).

Representations from the Borough Council of Wellingborough (Examination Library Reference AS-001), Public Health England (Examination Library Reference AS-002) and the Health and Safety Executive (HSE) (Examination Library Reference AS-003), were also submitted. The Applicant notes that:

a. the Borough Council of Wellingborough has confirmed that it has no objections to the Project.

b. Public Health England has chosen not to register its interest in the Project; and

c. the HSE has confirmed that it will not be submitting a relevant representation in respect of the Project.

This document sets out the Applicant’s response to each of the RRs. This document has been prepared in order to assist both Interested Parties and the Examining Authority by clarifying the position of the Applicant in relation to the points raised in the RRs.

A glossary of key terms was submitted as part of the original submission documents [APP- 004].

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2 REP-001 ELAINE RANDALL

Summary of Relevant Representation

The respondent states that an outline of the principal submission she intends to make will be in respect of air quality and whether the Project constitutes sustainable development.

Applicant’s Comments

The Applicant notes the comments made by the respondent and provides the following information:

Air Quality

An air quality assessment, including air dispersion modelling, has been undertaken to assess any potential air quality effects resulting from the Project on identified human receptors within 10 km of the Project Site and ecological receptors within 2 km of the Project Site. These receptors include properties at South Pillinge Farm, Stewartby and Houghton Conquest and Rookery Clay Pit County Wildlife Site. The air quality assessment considered all stages of the Project including construction, operation, maintenance and decommissioning of the Project.

The scope of the air dispersion modelling was discussed and agreed with the Environment Agency (EA), and the modelling meets the EA’s requirements (including permit modelling requirements, the cumulative effects with the Covanta RRF Project and best available techniques (BAT) requirements).

The air quality assessment and its findings are set out in Chapter 6 of the ES [APP-033]

The assessment concludes that: “the Project will not result in any likely significant environmental effects in relation to air quality either as a standalone project or cumulatively with other projects, having regard to the design and proposed operation of the Project and embedded mitigation” (Section 6.11, Chapter 6 of the ES, Document Reference 6.1 [APP- 033]).

The Applicant will comply with a Construction Environmental Management Plan (CEMP), which includes embedded mitigation measures such as dust mitigation, i.e. dampening down or covering of stock piles/excavations during periods of dry and windy weather. The final CEMP will be approved by the relevant planning authority and will be in accordance with the Outline CEMP (Revision 1, submitted at Deadline 2).

Sustainability

There is a considerable national need for this type of project, acknowledged at all levels of government policy. National planning policy supports the need for new electricity infrastructure due to the current ageing and inevitable closure of older coal fired power plants and the likely increase in demand for electricity over the coming decades.

The Government's policies in relation to Nationally Significant Infrastructure Projects (NSIPs) are set out in National Policy Statements (NPSs). NPS EN-1 (the overarching energy NPS) states at paragraph 3.6.3 that "gas will continue to play an important role in the electricity sector - providing vital flexibility to support an increasing amount of low-carbon generation and to maintain security of supply ".

Gas is a reliable fuel source. It is acknowledged by the Government as being essential to a low- carbon economy and to underpin the country’s energy security.

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As set out in paragraph 6.2.55 of the Planning Statement [APP- 056] Paragraph 4.5.3 of NPS EN-1 seeks that proposals are “ sustainable and, having regard to regulatory and other constraints, are as attractive, durable and adaptable (including taking account of natural hazards such as flooding) as they can be ”. Further, Paragraph 4.5.3 of NPS EN-1 states that “ Whilst the applicant may not have any or very limited choice in the physical appearance of some energy infrastructure, there may be opportunities for the applicant to demonstrate good design in terms of siting relative to existing landscape character, landform and vegetation .”

Paragraph 6.2.56 of the Planning Statement goes on to state that In accordance with paragraph 4.5.3 of NPS EN-1, and as set out in the Design and Access Statement [APP-057], as far as is reasonably practical, the Power Generation Plant will use materials which can be disposed of sustainably (e.g. easily re-usable or recyclable) when the plant has reached the end of its life (having due regard to durability and safety). The technology chosen has an inherently low requirement for process water. As set out within the Outline Landscaping Plans [APP-045], the design of landscape planting will enhance the area’s biodiversity through the retention of existing woodland; the planting of belts of trees to increase the amount of woodland in the area; the reinstatement of planting where possible and appropriate; and careful management of soils during construction works to facilitate plant growth, to be implemented as part of the Construction Environmental Management Plan (CEMP) (Revision 1, submitted at Deadline 2).

As set out within the Design and Access Statement [APP-045] and the ES [APP-038], the Project has been designed in accordance with good design principles. The Project is considered to constitute sustainable development, by virtue of its contribution to a low-carbon future and its contribution to the local and national economy, and should therefore be considered favourably in accordance with the provisions of paragraph 14 of the National Planning Policy Framework (NPPF).

As stated in paragraph 6.3.13 of the Planning Statement, Paragraph 93 of the NPPF acknowledges that planning plays a key role in supporting the delivery of low carbon energy and therefore achieving the economic, social and environmental dimensions of sustainable development. Paragraph 97 of the NPPF advises that, in order to increase the use and supply of low carbon energy, there should be a positive strategy to promoting energy from renewable and low carbon sources, whilst ensuring that adverse impacts are addressed satisfactorily.

Paragraph 6.3.14 of the ES goes on to state that the Project seeks to develop low carbon energy infrastructure and should therefore be considered positively in accordance with the provisions of paragraphs 93 and 97 of the NPPF.

Paragraph 6.3.66 of the Planning Statement sets out Policy CP21 of the Bedford Core Strategy and Rural Issues Plan (adopted 2008) which advises that all new development should, inter alia, be of the highest design quality, fully consider the wider context and address sustainable design principles. Policy CP24 states that ‘the Marston Vale will be the focus for landscape enhancement and restoration and the council will continue to support the Forest of Marston Vale.’ New development should protect and where appropriate enhance the quality and character of the landscape.

Paragraph 6.3.67 of the Planning Statement goes on to state that in accordance with the provisions of Policy CP21 and CP24, MPL has sought to adopt good design principles from the outset of the Project such that the development is sensitive to its setting. As illustrated in the Design and Access Statement [APP-045], the indicative form, scale, massing and landscaping has been designed so that the Power Generation Plant blends in with its surroundings minimising visual intrusion from key viewpoints.

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3 REP-002 WYNNS LIMITED

Summary of Relevant Representation

The respondent states that it is a "specialist consultant dealing in the movement of out of gauge project cargo and Abnormal Indi