Rail Central (Strategic Rail Freight Interchange)

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Rail Central (Strategic Rail Freight Interchange)

Received 03 December 2018
From Dr Andrew Gough

Representation

Objection to Rail Central TR050004
Alternative sites exist that are better able to take advantage of investments made in other infrastructure schemes, such as the development of port-centric logistics and specific investments in increasing rail freight capacity.
Planned investment in the Strategic Rail Network targets the major freight flows from Felixstowe and Southampton to the West Midlands, effectively bypassing Rail Central to the West and North. Only when paths are released by HS2 would there be any real prospect of significant modal shift.
The mere prospect of future capacity should not be used as justification for consent as it cannot be guaranteed. The application is therefore premature.
Deficiencies in the Assessment of Alternative Sites result in significant non-compliance with planning legislation. Deficiencies in the socio-economic case highlight non-alignment with NPSNN policies on availability of labour.
The proposed scale of the development is in excess of that needed in Northamptonshire, according to Network Rail’s own forecasts. Market demand for Rail Central is primarily driven by a shortage of high-quality, large-footprint buildings, not by any proven desire to enact modal shift.
The design of Rail Central is inappropriate for its intended use as an SRFI. Comparison with the design approaches of consented schemes such as DIRFT III and East Midlands Gateway show that a substantial revision of the Rail Central masterplan will be required to meet market expectations for rail-served buildings.
The proposal contravenes NPS 4.86 as it is in extremely close proximity to residential areas. No amount of earthworks or landscaping can provide satisfactory mitigation.
The proposal contravenes NPS 2.45 and 2.56 in that it is not located in close proximity to conurbations, major centres of population, nor near the markets it claims it will serve.
Brownfield sites have been ignored as viable alternatives, contrary to NPS 5.186.
In my opinion, Prologis’ assessment that the Northampton Loop could only support a sub-regional facility remains extant. Furthermore, Prologis’ assessment that the Highgate facility could “work with” DIRFT III is also correct. We are effectively being asked to approve “DIRFT IV”.
The historic take-up of space at DIRFT is less than 50,000m2 per annum. Unless a major change in buyer behaviour can be proven, DIRFT III will provide capacity for over 15 years.
Granting development consent to Rail Central would risk the environmental success of DIRFT by creating a situation whereby both sites competed for the same train paths.
Priority should be given to filling gaps in the national network of SRFIs, through schemes that provide new routes to the deep-water ports from locations North of the A14 / M6 corridor, such as Hinckley NRFI and West Midlands Interchange.
A combination of the already-consented capacity at East Midlands Gateway, DIRFT III and the proposed Hinckley National Rail Freight Interchange would provide an optimum network solution, sufficient to meet both market needs and national policy objectives in the medium term.
I am not convinced that Rail Central has made the case for a SRFI development of national importance, in this location, at this time.