The Green Belt
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THURROCK FLEXIBLE GENERATION PLANT Land south west of Station Road near Tilbury, Essex PLANNING STATEMENT OF CASE Application document A8.3 APFP Regs ref. 5(2)(q) OXF10872 A8.3 Statement of Case and Green Belt Statement 26 February 2020 rpsgroup.com A8.3 STATEMENT OF CASE AND GREEN BELT STATEMENT Document status Version Purpose of document Authored by Reviewed by Approved by Review date 1 Draft for internal comment C Lecointe 13.12.19 2 Draft for internal comment C Lecointe 24.01.20 3 Draft for internal comment C Lecointe T Dearing C Lecointe 26.02.20 Approval for issue Chris Lecointe 26 February 2020 © Copyright RPS Group Plc. All rights reserved. The report has been prepared for the exclusive use of our client and unless otherwise agreed in writing by RPS Group Plc, any of its subsidiaries, or a related entity (collectively 'RPS'), no other party may use, make use of, or rely on the contents of this report. The report has been compiled using the resources agreed with the client and in accordance with the scope of work agreed with the client. No liability is accepted by RPS for any use of this report, other than the purpose for which it was prepared. The report does not account for any changes relating to the subject matter of the report, or any legislative or regulatory changes that have occurred since the report was produced and that may affect the report. RPS does not accept any responsibility or liability for loss whatsoever to any third party caused by, related to or arising out of any use or reliance on the report. RPS accepts no responsibility for any documents or information supplied to RPS by others and no legal liability arising from the use by others of opinions or data contained in this report. It is expressly stated that no independent verification of any documents or information supplied by others has been made. RPS has used reasonable skill, care and diligence in compiling this report and no warranty is provided as to the report’s accuracy. No part of this report may be copied or reproduced, by any means, without the prior written consent of RPS. Prepared by: Prepared for: RPS Thurrock Power Christopher Lecointe Andrew Troup Operational Director Director 20 Western Avenue 1st Floor Milton Park 145 Kensington Church Street Abingdon, Oxfordshire OX14 4SH London W8 7LP T +44 1235 821 888 E [email protected] OXF10872 | A8.3 Statement of Case and Green Belt Statement | | 26 February 2020 rpsgroup.com Page i A8.3 STATEMENT OF CASE AND GREEN BELT STATEMENT EXECUTIVE SUMMARY This planning Statement of Case (SoC) has been prepared by RPS to support Thurrock Power’s (the Applicant) application for a Development Consent Order made pursuant to the Planning Act 2008 (as amended). The Application proposes to build a Flexible Generation Plant comprising gas reciprocating engines with electrical output totalling 600 MW; batteries with electrical output of 150 MW; gas and electricity connections; the creation of access roads and a causeway; and creation of habitat and exchange Common Land. This mix of energy and other infrastructure, therefore, straddles several of the National Policy Statement’s but where relevant, it is compliant and receives the support of Government policy in all material respects (NPS EN-1 and EN-2). In addition, while it is not a renewable energy project in its own right, it is designed to support the delivery of power from renewable sources and provides additional resilience in the National Grid network, as well as additional security of our electrical supply. Under the National Planning Policy Framework (NPPF) the development is also considered to be low carbon. The definition on page 70 of low carbon technologies is “those that can help reduce emissions (compared to conventional use of fossil fuels)”. The applicant submits that on the basis that the proposed development is necessary to suppose the greater deployment of intermittent renewable generation and can meet peak power demands in a more efficient, lower-carbon way than conventional gas-fired power stations, it can be considered low carbon. The application site is positioned within the administrative boundary of Thurrock Council, a unitary authority. The development plan for the area does not include any adopted ‘Site Specific Allocations Document’ (or similar), nor does it therefore conclusively determine where the authority intends to make strategic allocations or adjust their current Green Belt boundary to cater for new development although this is likely. These matters will be addressed and defined in the emerging local plan for Thurrock. The emerging local plan has only reached its ‘issues and options’ stage and so little policy direction is currently available. In policy terms, while the local development plan does not yet specifically allocate land for the energy infrastructure now proposed, there are a number of policy goals and objectives which are capable of being met by allowing this development (discussed later). This plan also contains a number of generic development management type polices which in all material respects are met by the proposed development. The application site does fall within the existing Metropolitan Green Belt where the Overarching National Policy Statement for Energy (NPS EN-1) sets out that there is a general presumption against inappropriate development. NPS EN-1 places the onus on the Applicant to identify whether the proposed project is inappropriate and whether very special circumstances can be demonstrated to outweigh harm to the Green Belt. The Green Belt balance requires an assessment of whether the harm by reason of inappropriateness, and any other harm, would be outweighed by other considerations to amount to the very special circumstances required to justify the proposal. The Applicant has prepared a detailed Green Belt Statement report, and this is attached as Appendix 1 to this Statement of Case. This has identified the level of harm associated with the project’s impacts on the Green Belt’s openness, including the test against the five purposes set out within Paragraph 134 of the NPPF. The Applicant has then set out the need for this type of flexible energy generation, to support both the growth in renewable energy generation and maintain the security of electricity supply. This need is driven by the increased integration of intermittent renewables, coupled with the decommissioning of both coal and gas fired power stations. While the need for this type of flexible generation is across the UK, there is a very specific need for additional generation capacity on the 275kV electricity network around London and the south east. The Applicant has demonstrated that all other suitable, available and viable points of connection into the 275kV network would also require development within the Green Belt. OXF10872 | A8.3 Statement of Case and Green Belt Statement | | 26 February 2020 rpsgroup.com Page ii A8.3 STATEMENT OF CASE AND GREEN BELT STATEMENT The Applicant has demonstrated that there would be some reduction in the openness of the Green Belt, although limited conflict with the purposes of including land within the Green Belt. While substantial weight must be given to this identified Green Belt harm, in this case there are significant benefits and very specific locational needs that outweigh the identified harm, sufficient to demonstrate that very special circumstances exist and that the proposed development is acceptable in Green Belt terms. It is considered, therefore, that this green belt assessment, the degree of compliance with other national and local plan policy, when balanced with other material considerations, leads to an overwhelming degree of policy support for the development proposed by Thurrock Power. Accordingly, in accordance with the provisions of the Planning Act 2008 and the NPSs, it is concluded that the proposed development is acceptable in planning terms and there is no reason why the draft Development Consent Order should not be granted. OXF10872 | A8.3 Statement of Case and Green Belt Statement | | 26 February 2020 rpsgroup.com Page iii A8.3 STATEMENT OF CASE AND GREEN BELT STATEMENT Contents EXECUTIVE SUMMARY .................................................................................................................................... 2 1 INTRODUCTION ...................................................................................................................................... 1 Purpose of this Report .............................................................................................................................. 1 2 SITE AND PROJECT DESCRIPTION ..................................................................................................... 2 3 PLANNING POLICY CONTEXT .............................................................................................................. 5 Introduction ............................................................................................................................................... 5 Relevant Legislation and the Decision Making Framework ..................................................................... 5 Relevant National Policy .......................................................................................................................... 7 Development Plan Documents ...............................................................................................................18 Other Material Considerations ................................................................................................................22