Northampton Gateway Rail Freight Interchange

The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.

Northampton Gateway Rail Freight Interchange

Received 11 July 2018
From Northampton Rail Users Group

Representation

NRUG object on the basis of the adverse effects this proposal will have on passenger services.

The assertion of plentiful capacity on the WCML with no restriction to freight and no interference to passenger traffic by freight is not supported by a number of studies, including the NSPNN and freight RUS. Capacity restrictions DIRFT to Wembley, and at Northampton, are well documented.

Roxhill suggest that capacity will be released on the WCML when all the intercity trains are moved to HS-2. This will not be the case: the WCML will continue to host a significant number of intercity services, as the ES for the revamp works at Euston makes clear.

None of the strategic freight corridors shown in the NSPNN and Freight RUS include the WCML south of DIRFT. As this proposed development is not located on any of the identified strategic freight routes, in policy terms it can not be said to be strategic.

The Northamptonshire Rail Capacity Study, as prepared by SLCRail and presented to Northamptonshire Enterprise Partnership (now integrated into SEMLEP) identifies a 32% market growth for Northampton passenger traffic by 2023 and a 106% growth to 2043, ie doubling the current usage in the next 25 years, bringing the WCML back to its current capacity constraints within 25 years, even with HS-2.

A number of flaws exist in the ES, including failure to comply with the EIA regulations, and not having performed a sufficiently robust cumulative assessment.

It is a requirement to assess the effects the proposed development has on “people”, which in this case incudes rail passengers, both in construction and operation. This omission is a fundamental non-compliance with EIA regulations.

The required changes to the track layout at Northampton station are impractical following the building of the new station. The quoted train speeds MK to Rugby illustrate the specific adverse interference to passenger service speed caused by freight.

The transport assessment is flawed and assigns significant beneficial effects where the correct finding would be significantly adverse. Contrary to the position taken by Roxhill, major local effects are commonly identified and assessed in EIAs. The dilution of effects by averaging over a larger area and dismissing significant effects because they are localised does not comply with EIA regulations. The chapter as whole fails to establish the criteria for significance, “material impact” is not the EIA criteria. In EIA methodology, mitigation of adverse effects does not produce major significant benefits as proposed.

Part of the proposed development is to build a new road that takes the 1856 HGV movements per day, and 12,200 light vehicle movements per day created by the development. Roxhill then suggest the effects of this new road and this high traffic level to be “permanent beneficial” of “major significance”. This is not is a beneficial environmental effect, it is a significant adverse one.

The wrong basis is used for cumulative assessment, resulting in underestimating the effects on habitats.

The interpretation of WHO guidelines on noise is wrong.