RWE npower Plc. The Economy Tuesday 19 th July 2011

Transcription

1 RWE npower Plc Statement on the soundness of the Economy Chapter of the South Oxfordshire Proposed Core Strategy and information on the availability of Didcot A Power Station for employment related development. The Economy Tuesday 19 th July 2011

2 Didcot Power Station 1. RWE npower Plc owns and operates Didcot Power Station which is located North West of Didcot Parkway railway station. The site consists of 2 power stations known as Didcot A and Didcot B. 2. Didcot A Power Station is a coal fired power station and Didcot B is gas fired. The attached plan ref: MAP/DIDC/114/A indicates the operational boundaries for each power station. 3. The Large Combustion Plant Directive is a European Directive introduced in 2001 to further control emissions of sulphur dioxide, oxides of nitrogen and dust from large combustion plants. Existing plant like Didcot A Power Station can either choose to comply with the Directive by fitting additional abatement equipment or opt-out. RWE npower has taken the decision to opt Didcot A out and consequently, in accordance with the Directive, the power station will cease operations by the end of 2015 at the latest. 4. Following closure of Didcot A Power Station it will be decommissioned and demolished. It is RWE npower s view that decommissioning and demolition will take approximately 2-3 years. 5. It is RWE npower s intention to retain part of the Didcot A Power Station site for future operational development. However, a large proportion of the site will also be declared surplus to operational requirements. The site area of Didcot A Power Station is approximately 212 acres. It is probable that more than 100 acres of land will be released for alternative development uses. 6. The vast majority of Didcot A Power Station is located within the Vale of White Horse District However, the site boundary for Didcot A Power Station abuts South Oxfordshire s District boundary and the site access road falls within South Oxfordshire. South Oxfordshire Core Strategy 7. RWE npower is generally supportive of the spatial visions and objectives for Didcot which are set out in Part 3 of the Proposed Submission Core Strategy. However, it is RWE npower s view that the employment objective for Didcot, namely to provide new jobs for South Oxfordshire s Didcot residents at Harwell Science & Innovation Centre and Milton Park, is unsound. 8. Paragraph 4.52 of Planning Policy Statement 12 sets the test for soundness stating that To be sound a core strategy should be JUSTIFIED, EFFECTIVE and consistent with NATIONAL POLICY PPS12 defines Justified as founded on a robust and credible

3 evidence base and the most appropriate strategy when considered against the reasonable alternatives. 9. In terms of effectiveness PPS12 states that a core strategy should be deliverable and flexible. 10. Dealing with each soundness test in turn RWE npower comments as follows: Justified 11. RWE npower has previously submitted representations to the Submission Core Strategy Consultation (attached) to state that in its view the document is unsound on the basis that Didcot A Power Station has been omitted as a preferred location for new employment development. 12. As RWE npower has only recently announced its intention to declare more than 100 acres of land at Didcot A Power Station surplus to operational requirements, its previous omission from the Core Strategy is understandable. 13. However, the Council is now in a position to amend its spatial vision and objectives for Didcot in light of this new evidence. 14. Paragraph 4.37 of Planning Policy Statement 12 states that it is essential that core strategies are based on thorough evidence and that the evidence base should contain two elements: Participation Evidence of the views of the local community; and others who have a stake in the future of the area. Research/ Fact finding: Evidence that the choices made by the plan are backed up by the background facts. 15. In addition, Paragraph 4.37 states that evidence gathered should be proportionate to the job being undertaken by the plan, relevant to the place in question and as up-to-date as practical having regard to what may have changed since the evidence was collected 16. Clearly the evidence base for Didcot has now changed and the Core Strategy should be amended to reflect this fact. 17. Didcot A Power Station is a significant previously developed site within the existing settlement of Didcot. In contrast to Harwell Science and Innovation Centre and Milton Park, it is a short distance from Didcot Parkway railway station, the town centre and a large proportion of the town s residential developments. It is RWE npower s view that Didcot A Power Station should be considered as a preferred location for South Oxfordshire s employment development requirements.

4 18. Failure to consider Didcot A Power Station as a suitable location for employment development is contrary to advice in paragraph 4.37 and 4.52 of PPS12 on the grounds that: South Oxfordshire s Core Strategy has not been formulated using the most up-to-date evidence; and, The employment strategy is, deficient as it is not the most appropriate strategy when considered against the reasonable alternatives. As the evidence now shows that Didcot A Power Station will be available for development during the plan period the site should be considered as a suitable and preferred location for employment development. The planning policy support for this approach is set out later in this statement. Effective 19. It is RWE npower s view that the proposed employment strategy for Didcot as set out in the South Oxfordshire Core Strategy is ineffective. 20. Paragraph 2.3 of the South Oxfordshire Core Strategy states that The plans for growth in the surrounding areas will impact on this district. It is therefore important that the policies in this core strategy are coherent with neighbouring authorities plans for growth. This is consistent with the approach set out in paragraph 4.45 of PPS The need for cohesion is paramount given the fact that Didcot is split by 2 local planning authorities. South Oxfordshire s Core Strategy requires land within the Vale of White Horse district to deliver a significant proportion of its employment growth (table 4.1 of the Core Strategy). 22. However, the Vale of White Horse Core Strategy is at an early stage of preparation. In these circumstances the South Oxfordshire Core Strategy can only make general assumptions about appropriate locations for future employment growth. Clearly, the assumption that Harwell Science & Innovation Park and Milton Park are the most appropriate locations for South Oxfordshire employment growth will have to be tested when the Vale of White Horse Core Strategy reaches its examination stage. 23. In advance of the adoption of the Vale of White Horse Core Strategy it is impossible to say that further employment growth will be delivered at Harwell Science & Innovation Park and Milton Park. Consequently, uncertainty remains about whether South Oxfordshire s employment strategy is deliverable. 24. Paragraph 4.46 of PPS12 recognises that a strategy is unlikely to be effective if it cannot deal with changing circumstances. The paragraph states further that it may not always be possible to have maximum certainty about the deliverability of the strategy. In these cases the

5 core strategy should show what alternative strategies have been prepared to handle this uncertainty and what would trigger their use. 25. It is RWE npower s view that it is unsound to propose Harwell Science & Innovation Park and Milton Park as preferred locations for employment development in advance of the adoption of the Vale of White Horse Core Strategy. In accordance with paragraph 4.46 of PPS12 South Oxfordshire s employment strategy should retain flexibility to take account of the fact that the Vale of White Horse employment strategy is yet to be properly formulated and examined. 26. As South Oxfordshire Council is now aware that a significant proportion of Didcot A Power Station is to be made available for redevelopment, the employment strategy should be amended to state that it is a preferred location for employment development. This will provide the employment strategy with more flexibility, thereby ensuring a better chance of deliverability. It is RWE npower s view that the employment strategy detailed in The Economy Chapter will be effective if Didcot A Power Station is identified as a preferred location for employment development. Consistent with National Policy 27. As Didcot Power Station is not listed as a preferred location for employment development in the Economy Chapter, South Oxfordshire s Core Strategy is inconsistent with National Planning Policy. 28. Planning Policy Statement 4 Planning for Sustainable Economic Growth (PPS4) sets out a number of key objectives to achieve the delivery of sustainable economic growth. In particular paragraph 10 lists the need to build prosperous communities by improving the economic performance of cities, towns and deliver more sustainable patterns of development by reducing the need to travel. 29. Policy EC2 (d) of PPS4 states that local planning authorities make the most efficient and effective use of land, prioritising previously developed land. which is suitable for re-use. Policy EC2 (d) also lists as an important consideration, access to a locally available workforce. 30. Policy EC2 (e) states that local planning authorities should seek to locate developments which generate substantial transport movements in locations that are accessible (including by rail). The Government s objective of minimising the need to travel and encouraging sustainable methods of transport is reiterated in PPG13 (Transport). 31. Didcot A Power Station is located within Didcot. It is a previously developed site with good access to Didcot Parkway railway station and other public transport links. As the site is within Didcot itself, it also has access to a substantial locally available workforce.

6 32. As the Economy Chapter does not allocate Didcot A Power Station as a preferred location for employment development the South Oxfordshire Core Strategy is contrary to National Planning Policy. Strategic Development Site 33. It is RWE npower s view that when the Vale of White Horse Core Strategy is prepared, there is a strong possibility that Didcot A Power Station will be allocated as a strategic development site. 34. Paragraph 4.6 of PPS12 states that Core Strategies may allocate strategic sites for development. These should be those sites considered central to achievement of the Strategy. Paragraph 4.7 goes on to state The Core strategy looks to the long term. It may be beneficial to delivery of its objectives for details of key sites to be included in it, where these sites are central to the achievement of the strategy and where investment requires a long lead in. 35. It is accepted that Didcot A Power Station falls outside of South Oxfordshire s jurisdiction. Consequently, it may be unjustified to describe it as a strategic development site in the Core Strategy at this stage. However, the Core Strategy should acknowledge that a major previously developed site within Didcot will be available for development within the Plan period. Conclusion 36. A large area of Didcot A Power Station will be declared surplus to operational requirements and be made available for redevelopment by the end of 2015, at the latest. 37. In light of the availability of Didcot A Power Station for redevelopment, the assumption that employment growth will be delivered solely at Harwell Science & innovation Park and Milton Park is flawed. Consequently, The Economy Chapter of the South Oxfordshire Core Strategy is currently unsound using the JUSTIFIED, EFFECTIVE and NATIONAL POLICY tests set out in PPS To remedy this situation the employment strategy in the South Oxfordshire Core Strategy should be amended to indicate that Didcot A Power Station is a preferred location for new employment development.