Roxhill’s ‘Northampton Gateway’ SRFI Development Proposal Our Case Against Part A A submission to the Planning Inspectorate on the Environmental and Social Impacts on local communities, of a proposed industrial development of 5 million Sq. ft. on 500 acres of open countryside. Prepared on behalf of local communities by the ‘Stop Roxhill Northampton Gateway’ Action Group PINS Reference: TRO50006 Unique Registration ID Number: 20011012 1 Table of Contents 1. ROXHILL PROPOSAL DESCRIPTION – AN OVERVIEW......................................................................... 3 2. EXECUTIVE SUMMARY....................................................................................................................... 4 3. PLANNING COMPLIANCE ................................................................................................................. 14 4. VALIDITY OF SITE SELECTION & ALTERNATIVE SITES ...................................................................... 27 5. RAIL ACCESS & CAPACITY ................................................................................................................ 30 6. AIR QUALITY .................................................................................................................................... 43 7. HEALTH IMPLICATIONS .................................................................................................................... 63 8. ENVIRONMENTAL ISSUES ................................................................................................................ 81 8.1 Ensuring the Accuracy & Objectivity of Environmental Impact Assessments (EIA’s) ............... 81 8.2 Landscape .................................................................................................................................. 84 8.3 Public Rights of Way .................................................................................................................. 88 8.4 Ecology ....................................................................................................................................... 91 8.5 Cultural Heritage........................................................................................................................ 95 8.6 Flooding, Sewerage & Ground Water ..................................................................................... 101 8.7 Noise Pollution ........................................................................................................................ 105 9. EMPLOYMENT................................................................................................................................ 110 10. PUBLIC OPINION .......................................................................................................................... 114 11. CRIME........................................................................................................................................... 126 12. SUMMARY OF KEY CONCLUSIONS & OBJECTIONS ...................................................................... 129 APPENDIX A - SRNG ACTION GROUP TEAM MEMBERS DETAILS .................................................. 132 APPENDIX B - GLOSSARY OF ABBREVIATIONS .............................................................................. 133 2 1. ROXHILL PROPOSAL DESCRIPTION – AN OVERVIEW The Roxhill Northampton Gateway (RNG) application is for the development of a Strategic Rail Freight Interchange (SRFI) together with landscaping, access and other supporting infrastructure works. It consists of: • An intermodal freight terminal including container storage and HGV parking, with new rail sidings within the site to serve individual buildings. • Capability to provide a ‘rapid rail freight’ facility as part of the intermodal freight terminal. • Up to 6,000,000 sq. ft / 557,418 sq. m. (gross internal area) of warehousing and ancillary buildings. • New road infrastructure and works to the existing road network, including provision of a new access and associated works to the A508, a new bypass to the village of Roade, and substantial improvements to Junction 15 of the M1. • Strategic landscaping and tree planting, including retained diverted public rights of way • Earthworks and demolition of existing structures on-site. • The relocation of an Aggregates Depot; this was added to the scope of their proposal after the last and final round of Roxhill Northampton Gateways (Roxhill NG’s) public consultation meetings late last year (c. Dec 2017). Reference: 1. https://infrastructure.planninginspectorate.gov.uk/projects/east-midlands/northampton- gateway-rail-freight-interchange/ 3 2. EXECUTIVE SUMMARY Introduction This submission paper to the Planning Inspectorate (PINS) is in direct response to Roxhills Northampton Gateways (Roxhill NG’s) Strategic Rail Freight Interchange (SRFI) proposal and has been compiled by multiple members of the Stop Roxhill Northampton Gateway Action Group (SRNG Action Group) who strongly object to Roxhill NG’s proposal. Details of the SRNG Action Groups Contact Details can be found in Appendix A. SRNG Action Group Objections – An Overview ES1 – A Strategic Proposal? Whilst the SRNG Action Group recognize the National Policy Statement for National Networks (NPSNN) policy requirement for the UK’s rail network to be expanded to cater for future growth in rail freight traffic and the need for the SRFI network capacity to be extended by the logistics industry to encourage more freight traffic, it is evident that Roxhill NG’s proposal is not aligned with the NPSNN policies. For example, Roxhills NG’s SRFI proposal does not: 1. Best serve the UK’s government driven objectives to expand the network of large SRFI’s across the regions especially in areas poorly served by such facilities at present. 2. Take into consideration that the NPSNN clearly states that existing operational SRFI’s and other intermodal Rail Freight Interchanges (RFI’s) are already predominantly situated in the Midlands and the North at this time. 3. Consider that the NPSNN also state that SRFI capacity needs to be provided at a wide range of locations to provide the flexibility required to match the changing needs of the market. The SRNG Action Group acknowledge that Roxhill NG’s proposal has been accepted as a strategic proposal for examination purposes by PINS, however, we challenge the unproven strategic nature of Roxhill NG’s proposal for the following/additional reasons: • Daventry International Rail Freight Terminal (DIRFT), only 18 miles from the Roxhill NG’s proposed SRFI site, already provides a SRFI (with more than adequate warehousing capacity) to serve the Midlands area for the foreseeable future. The historic take-up of space at DIRFT is less than 50,000m2 per annum. Unless a major change in buyer behaviour occurs or can be proven, DIRFT Phase III will provide capacity for over 15 years, therefore, granting consent for Roxhill NG’s SRFI proposal would risk the success of DIRFT by creating a situation whereby both sites would be competing for the same train paths. • Roxhill NG’s proposed site is situated halfway between major centres of production and consumption i.e. London and Birmingham. This contravenes the NPSNN policy to locate SRFI’s at major nodes. Planned investment in the Strategic Rail Network should target major freight flows from Felixstowe and Southampton to the West Midlands effectively bypassing Roxhill NG’s proposed SRFI location to the West and North. Only when paths are released by High Speed 2 (HS2) would there be any prospect of a significant modal shift from road to rail. The SRNG Action Group feel strongly that future and potential capacity should not be used as a justification for consent of Roxhill NG’s SRFI proposal as it cannot be accurately predicted or guaranteed. • Oversupply of SRFI’s in the region and undersupply in regions poorly served or currently lacking a SRFI would magnify regional economic imbalances and undermine national policy. 4 • Roxhill NG’s proposed SRFI site is too close to points of origin to permit economic rail freight for most users; a minimum viable rail freight range is 200 km and this is limited to bulk commodities which don’t require processing, sorting or repackaging. In addition, Roxhill NG’s SRFI proposal does not cater exclusively for such markets. • Realisation of drawbacks at Prologis Eurohub near Corby meant that its projected rail link was never laid. Indeed, the number of freight train movements in the UK has declined from approx. 416,000 train movements in 2003/04 to approx. 216,000 train movements in 2017/18 (source: http:// http://orr.gov.uk). Furthermore, recent reports confirm a decrease in the use of rail freight by 20% down to 0.4% growth from predictions of a 5% increase year on year. • Roxhill NG’s proposed SRFI site has an extensive history of bids and proposals to change its use from arable land to various industrial enterprises. All, thus far, have failed or were abandoned as respectively they contravene the Joint Core Strategy (JCS) and Local Planning processes. Roxhill are undoubtedly aware of these facts given that they were party to (some if not all) earlier/aborted proposals. They have stressed in their consultations that their proposed SRFI site lies within a ‘Golden Triangle’, but this term relates to road haulage only and not to road and rail – a fundamental misconception which Roxhill appear to have overlooked in their proposal. The aforementioned key points are reflected in the graphical maps directly below: RFI’s & SRFI’s in the