Planning objection to Partingdale Lane sub station
LONDON ASSEMBLY LABOUR
Andrew Dismore AM
London Assembly Member for Barnet and Camden
City Hall
The Queen’s Walk
London
SE1 2AA
09/10/2020
Objection to planning application for land adjacent to the National Grid Sub-station Ref: 20/4241/FUL
Dear Sir or Madam,
I am writing to object to the above application in my capacity as London Assembly Member for Barnet and Camden.
This development will encroach on previously undeveloped Green Belt land, to the west of the transformer site, and is not being built within the footprint of the transformer site. It is to have the same capacity of 50 MW (1.1.1, 6.2.13) as the proposed gas peaking plant, hinting that the two developments are linked, but there is nowhere in this application which states that it is a replacement.
There are repeated references to the use of storage in conjunction with renewable energy, yet there are no plans for any renewable energy sources on or near the site. Appendix G in 20/4241/FUL gives examples of gas peaking and battery applications in Green Belts. In Rochford Essex, an application for a 49.99MW gas-fired generating facility was accompanied by a separate application for a battery storage facility.
This proposal proves that major applications are made incrementally. In this way individual applications can comply with thresholds and the full impact is not apparent in the first wave of opposition. As it is, there is also a proposal for a gas pipeline along Burtonhole Lane (19/6641/FUL).
Paragraph 1.2.4 states that the batteries are for storage for use in periods of peak demand, thereby hinting that 19/6641/FUL is not a proposal for a peaking plant, which is an alternative to batteries, but for a medium scale power station.
Mill Hill has had a substantial increase in new housing built without pre-planned infrastructure, using up all brownfield sites, such as the old Mill Hill East gas works now replaced by the Lidbury Square estate. Then as an afterthought, the increased requirement for electricity is a justification for using Green Belt land. Any power requirements should have been built on the gas works site.
Paragraph 20 of the NPPF states the importance of an overall strategy (6.2.67) and there does not appear to be one. ‘Overall demand for electricity is likely to double by 2050’ (4.3.10) implies no behavioural changes to decrease consumption, together with an increased population. It is unclear how this is compatible with zero carbon emissions.
The long-term plans stretch to 2050 (4.4.2) so why will the development only last 25 years and then be dismantled? If requirement for electricity is to double by 2050, then how is it that this plant will be decommissioned (3.8.6) and the land returned to Green Belt? It is likely that the Green Belt with a ‘Major Development’ on it (see section 4 here) will be used for an even bigger installation.
By making two separate applications, 19/6641/FUL and 20/4241/FUL, the proposers avoid the need for Environmental Impact Assessments.
The B.S.F area: applied for 0.49 hectare compared to threshold of 0.5 hectare.
Gas ‘peaking’ plant: applied for 49.9 MW compared to threshold of 50 MW.
Both these capacities are curiously close to the thresholds? Are there any guarantees that these facilities not only will not exceed their permitted limits, but cannot?
Together with 19/6641/FUL this becomes a major development of more than 1 hectare.
https://www.legislation.gov.uk/uksi/2015/595/pdfs/uksi_20150595_en.pdf
Such a major development requires more scrutiny.
The batteries are 13.7 m long, 3.1 m wide and 2.9 m high (3.2.1), visually more ‘solid’ than the pylons in the sub-station. However, the field in which it will be located is surrounded by deciduous vegetation, which offers far less visual shielding in winter.
There are ventilation and cooling units at either end of each unit (3.2.1). If Hillview Road is affected by noise and vibration (5.7.3) then so will Burtonhole Lane.
There are no restrictions on noise output specified here (5.7.5) and no noise control methods in this specification, but possibly ‘in the final design’(5.7.6). A full analysis of noise is essential, and must take into account the noise from the gas-fired power station proposed.
The battery system together with the power station is anything but low-carbon (4.3.10). These two proposals need to be looked at together; to claim that one part of the system (e.g. car seats in a petrol-driven vehicle) is low-carbon is misleading.
Paragraphs 4.3.10- 4.3.20 read like ‘greenwash’, i.e. standardised text, full of buzzwords like ‘smart’, ‘flexible’, ‘clean energy’, ‘low-carbon’ to make the installation sound environmentally acceptable.
There is no allowance for foul drainage/ sewage (3.6.1). Any run-off that is polluted with battery or cleaning chemicals, will be discharged to the water table untreated.
The access roads will have to include Partingdale Lane and Burtonhole Lane. The latter is a footpath and bridleway and is unsuited to heavy vehicles. The Ridgeway is already over-burdened with the heavy lorries associated with the construction of the Ridgeway Views and Millbrook Park estates.
In the Arboricultural Assessment of 20/4241/FUL individual trees are classified as high quality (4 out of 8), medium quality or low quality/unsuitable for retention. All the groups of trees are in the lower two categories. The set-aside habitat (Planning Drawing 2701-01-004b) is a small area immediately around the batteries.
Removal of ‘8 semi-mature trees to the east of the site …. considered to be of low ecological value ‘(3.5.2) is proposed.’
The large group of trees between the field and the public bridleway which is Burtonhole Lane, is called G4. ‘Some trees within the G4 grouping would been (sic) to be removed to accommodate the access road, however there are no trees of veteran or ancient status here (5.6.4). By this categorisation, the developers have deemed it unnecessary to replace these trees (NPPF 175c which is quoted) and the much-mentioned screening provided by vegetation will be inadequate.
It is admitted that this is a Site of Importance for Nature Conservation and a site of Metropolitan Importance M127 (5.2.2). Section 5.2 tries to devalue the area as a justification for building on it. The site is said to be ‘of limited ecological value and has no functional habitat’ (5.2.3).
East of the site is Burtonhole Lane which is an old green lane now a public footpath and bridleway. It is a Grade II Site of Borough Importance for Nature Conservation (5.5.2) and is an area of biodiversity which will be harmed by having installations on either side of it.
It is repeated (5.2.3 and 6.2.66) that the ‘grassland is for equestrian grazing and is therefore of little ecological value’. On the contrary, horses perform an important role in maintaining habitat, restoring plant diversity and pollinator populations.
The removal of this grazing area is therefore a double loss. Any wild animals there at present will be disturbed by the noise levels and intrusion into their habitat.
The ecological assessment in section 5 (e.g. 5.2.6 and 5.3.5) clearly contradicts the preliminary ecological appraisal made in 19/6641/FUL.
Section 5 mentions that the closest nature reserve is Totteridge Fields which is 2.2 km away Darlands Nature Reserve has been strangely omitted. It is only 700m away. Paragraph 5.2.4 reads ‘No aquatic habitat is present within the Site or surrounding land, and no ponds are present within 250m of the Site’, yet Folly Brook is 150m away and Darlands Lake is 750m away.
The proposal contributes incrementally to degradation of the Green Belt. The actual ‘merging of neighbouring towns’ (6.2.13) does not occur until the Green Belt is almost eroded, so the argument that ‘the proposal would not result in any material merging of neighbouring towns‘ is spurious.
It is acknowledged that the site is considered to be ‘inappropriate development’ in Green Belt. As is usual in these cases, ‘Special Circumstances’ are claimed.
The battery facility should be associated with a renewable energy installation if the proposal is to be plausible. If not part of the gas peaking plant, the batteries should be sited totally within the existing transformer site.
Alternatively it could be sited in a brownfield location, with constraints on noise and air pollution if close to residential areas. ‘Recycling of derelict and urban land’ (6.2.13 point e) is appropriate in this case as the technology of transmission of electricity over large distances is well established.
Contrary to the statement in (7.1.4) I conclude that the Battery Storage Facility, particularly in conjunction with the gas peaking plant, will be responsible for damage to ecology, will increase flood risk and surface water drainage, and cause noise and air pollution. It will be seriously detrimental to the Green Belt and its accessibility to local residents.
For all these reasons I object to this scheme.
Yours sincerely,
Andrew Dismore AM
London Assembly Member for Barnet and Camden
City Hall
The Queen’s Walk
London
SE1 2AA
