Thurrock Flexible Generation Plant

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.

Thurrock Flexible Generation Plant

Received 18 August 2020
From Essex County Council

Representation

Environment and Green Infrastructure Essex County Council currently provides advice on green infrastructure (GI) schemes for major developments in Essex. Although this proposed development is located in neighbouring Thurrock Borough, we remain keen to highlight the importance of protecting and enhancing GI, accessibility and biodiversity net gain wherever possible. Loss of saltmarsh and intertidal mudflat habitats in the footprint of causeway construction is considered to be a significant adverse effect, albeit at a very local scale, due to the vulnerability and high value of these habitat types. It is proposed that these will be mitigated by new saltmarsh habitat creation, which is welcomed. Similarly, the potential significant adverse effect of loss of grassland habitat on the main development site would be more than fully compensated for (with net biodiversity gain) by habitat creation. Unfortunately, the application is not supported by an illustrative detailed landscape/GI plan for the main site, whereas these have been provided for associated development areas. Therefore, we would recommend that this is provided so that an appropriate judgement can be made on the GI proposals. Through the right design the proposal could blend, enhance and contribute to landscape character. GI must not be seen in isolation from ‘grey’ infrastructure, but as a means to improve its performance and benefits and create new linkages in the surrounding areas to enhance and develop the existing GI networks for the area. For instance, the use of GI as part of the sustainable design would have multiple benefits. For example, green roof or walls on storage buildings would provide invertebrate habitats, reduce surface water runoff and provide aesthetics. The Development Zone Plan (Doc no: 10872-0005-53) identifies Habitat Creation and enhancement areas (Zone F) and a temporary PRoW diversion of Footpath 200 (Zone I). This along with the Illustrative Landscape Plans, outlines the landscape enhancements areas proposed. Moving forward, detailed landscape plans for all GI assets will need to be submitted. We would expect these to include a landscape for all soft landscape assets, including, naturalises solutions for attenuation ponds, buffering and proposed trees, plants and seed mixes. This should be in line with British Standards and include details of planting works such as preparation, implementation, materials (i.e. soils and mulch), any protection measures that will be put in place (i.e. rabbit guards) and any management regimes (including watering schedules) to support establishment. This should be accompanied by a schedule, with details of quantity, species and size/type (bare root, container etc). Hard landscape details such as surface materials and boundary treatments must also be included. We support the proposed recommendation for a Landscape and Ecology Management Plan for the mitigation and management of the landscape, including the protection of existing retained trees and hedgerows. We would recommend that long-term management of GI elements (and ecological management) both within and off-site is secured via appropriate legal agreements. ECC have previously suggested that a Landscape Mitigation Fund be set up and funded from the various major developments within the area and used to fund landscape mitigation projects and enable management measures/projects to be undertaken. Climate and Energy Climate change is now recognised and rated as the greatest risk/challenge facing society. In response Essex County Council has established the Essex Climate Commission to develop a proactive and deliverable strategy for achieving more resilient and adaptable places in line with Government objectives. Across Essex, more than half of districts and boroughs have declared a Climate Emergency, where urgent action needs to be taken on the causes, impacts and mitigation of climate change, including Thurrock Borough in October 2019. As a neighbouring local authority to Thurrock Borough where this proposed development is located, from a climate and energy perspective, we would like to highlight that in principle, whilst we appreciate the calculation of net negative GHG emissions, the proposal of large scale gas fired energy generation can further add to the detrimental impacts of climate change through the use of fossil fuels and is contrary to the aspirations of a greener Essex. This level of investment, whilst proposed to replace inefficient small scale gas fired energy generation sites, would reduce requirements and investment in renewable energy generation projects that would have a much greater environmental impact alongside battery storage. However, having reviewed the submitted information if the Planning Inspectorate is minded to approve the application, as a minimum we would recommend that there should be mitigation during the operational phase in order to reduce net emissions and use of the safeguarded land for carbon capture readiness from the start of operation. Minerals & Waste Planning ECC is the host Minerals and Waste Planning Authority in the two tier administrative area of Essex, and is a neighbouring authority in the context of this application. The Essex Minerals Local Plan - Adopted July 2014 (MLP) concerns the administrative area of Essex only, and seeks to ensure the sustainable use of minerals across the county. The Essex and Southend on Sea Waste Local Plan - Adopted October 2017 (WLP) concerns the administrative areas of both Essex and Southend on Sea. Thurrock Council is a unitary authority and is its own Minerals and Waste Planning Authority. Thurrock Council are the appropriate contact for minerals and waste issues in the administrative area of Thurrock, including the application of policies, details regarding existing and pending planning permissions, any site information and capacity data. Nonetheless, given the scale of this substantial application, there are potentially a number of minerals and waste implications for the administrative area of Essex arising out of this application, particularly cumulatively with other programmed significant infrastructure projects in proximity. Therefore there are a number of issues that Essex County Council (ECC) in its capacity as the Minerals and Waste Planning Authority for a neighbouring county would expect this development to address. It is noted that the Environmental Statement is silent on mineral and waste matters. Both should be scoped into the Statement or addressed via other means. Minerals ECC would expect the scope of the Environmental Statement to include an assessment of the amount of aggregate needed to implement the proposed development and how this need would be phased over the construction period. The assessment should also set out the likely market areas which will supply the necessary aggregates for the development. This should cover a suitably wide geographic area and have regard to the potential for marine aggregate to be landed via the River Thames, as well as terrestrial sources. Supply considerations should be provided in the context of the current level of permitted reserves as well as the annual rate of mineral provision in relevant areas, as sourced from the latest Local Aggregate Assessments. Waste It does not seem as though waste matters associated with construction have been addressed beyond noting that ‘It is not possible to predict decommissioning and waste management methods several decades hence with certainty’. This is agreed but an assessment of waste arising from the construction of the development currently being applied for would be possible. ECC supports the application of the Waste Hierarchy and the Sustainable Management of the excavated materials and waste arisings, including recycling and potential re-use/after-uses. ECC would expect this information to be included within a Materials Balance. Any such audit and waste management strategy should identify the composition and volumes of waste arising on a phased basis during the construction phase, which aligns with the phased delivery of the proposals. These should be assessed in the context of relevant known and indicative local waste management capacity across each delivery phase unless the waste arising is clearly less than existing capacities. Synergies could be identified such as those between Construction, Demolition and Excavation waste arising and the need to restore any void space created through mineral extraction, thereby reducing the need for long distance transportation and therefore helping achieve the aims of the ‘proximity principle’ in line with the National Planning Policy for Waste.