Felixstowe South reconfiguration inspector's report
Mr L Meyer
7.30 Woolverstone is on the west side of the River Orwell. The centre of Woolverstone is approximately 2.5km from the nearest point of the A14, and approximately 3km from the Orwell Bridge. At these distances from any trunk road or motorway, traffic noise levels will be low. Nevertheless, in a down wind direction from the road, and especially at night, it is to be expected that noise from the trunk road would be audible in Woolverstone. The fact that road noise is audible does not imply unacceptability.
7.31 The level of noise in Woolverstone from A14 traffic, including that from the traffic on the Orwell Bridge, will vary from day to day depending on wind direction, speed and temperature. On a cold morning, particularly under clear skies with little wind, atmospheric conditions will often enhance sound propagation effects, and give rise to higher than normally received noise levels from distant roads.
7.32 Although the proposed reconfiguration scheme would add further traffic to the A14, the number of additional HGV movements would not significantly increase the overall traffic noise levels. The increase in noise levels in this area as a result of extra traffic from the reconfiguration scheme compared with the "no development" scenario would be less than 1dB. There would thus be no significant increase in background noise levels at Woolverstone as a result of traffic associated with the reconfiguration scheme. According to the Department for Transport's "Transport Analysis Guidance", for freely flowing traffic a difference of about 3dB is required before there is a perceivable change in the noise level. No mitigation measure is therefore considered warranted in relation to Woolverstone as a consequence of noise associated with the proposed Felixstowe South Reconfiguration.
Written expressions of opposition or concern
The need for the development
7.33 Capacity constraints at UK ports - and at Felixstowe in particular - have already resulted in substantial business being transferred to ports in mainland Europe. The provision of adequate port capacity in UK is necessary for both direct import/export and also for transhipment. This is a necessary requirement for sustained economic growth at the rate desired and forecast by the Government. If no major port expansion project is approved, the UK's major ports would run out of capacity at some time in 2009. Demand for trade greater than the ports could supply would spell disaster for the country. A huge amount of trade would be lost, and the country's Gross Domestic Product would be very significantly and adversely affected. On the other hand, if all major pending projects were approved, the utilisation of container port capacity would be 108.2% by 2020 in the high case outlined at paragraphs 3.109 to 3.111 above; in the base case it would be 102% in 2020; and even in the low case it would be 87.85% in 2020, when average capacity utilisation of 85% is the maximum which should be aimed for in order to maintain flexibility to meet changes in seasonal demand. There is therefore no case for suggesting that a decision should not be taken on the Felixstowe applications in advance of the outcome of the applications at Bathside Bay or anywhere else.
7.34 "Modern Ports" (Document CD/HP/55) contains no requirement that a port should be fully developed before any expansion is permitted. The presumption in favour of making the best use of existing and former operational land and infrastructure where possible is stated at various points in the White Paper, and is clearly best practice. But that is in effect what the Promoters seek to do at Felixstowe.
7.35 Nor is there any requirement for alternative solutions to be considered under the Habitats Directive or the Conservation (Natural Habitats etc) Regulations 1994 in this case, because no adverse effect on the integrity of a European Site is predicted as a result of the Felixstowe South Reconfiguration.
7.36 Deepening the existing berths at the Trinity Terminal is not possible because it would involve an overstressing of the piles and the quay wall. It could not in any event take place without first developing additional berth capacity to which business could be transferred.
7.37 Additional deep water capacity could be created at Hunterston and at Scapa Flow, but these are distant from the major deep sea routes of north Europe, and it is at least questionable whether sufficient labour would be readily available to staff them. Even if the largest vessels called at those ports, and smaller vessels were then used to feed containers to other ports in UK, this would not provide an economic solution to the needs of the country.
The effect on existing amenities and infrastructure
7.38 The Section 106 Agreement makes provision for the replacement and enhancement of the existing dock viewing area.
7.39 The area which would be affected by the proposed reclamation from the Harwich Haven cannot be considered a prime fishing water. Most of the area has a reduced diversity biotope, as it has previously been affected by dredging and shipping activity. Only a small area of shore currently exists from which angling can take place. The new viewing area would be suitable for shore based angling.
7.40 The Section 106 Agreement makes provision for a terminal for the foot ferry at Felixstowe.
7.41 The use of mitigation planting to screen the reconfigured Terminal would not adequately address the matter of impact in wider views. The quayside cranes would be in the order of 113 metres high, and it is principally the upper portions of these cranes which would be apparent in wider views. Clearly, trees would not address the impact on these views.
7.42 Existing lower cranes are already apparent in a number of distant views from Felixstowe. The proposed reconfiguration represents an intensification of the Port's presence in local and wider views rather than a new feature. The cranes are and would continue to be distanced from the main residential and commercial areas of the town, and this reduces the potential adverse effects of such elements. Changing the colour of the cranes would not result in any substantial alteration in impact; camouflage painting would be inappropriate and ineffective.
The effect on safety and the free flow of traffic
7.43 The issues of the capacity and safety of the Dock Spur Roundabout, with or without the improvements which would come with approval of the reconfiguration scheme, have been considered at paragraph 7.11 and 7.21 to 7.28 above.
7.44 Only a small proportion of jobs arising indirectly from the Promoters' proposals would be located at the Port. The FQP and the green travel plan would, however, seek to encourage movement outside peak hours.
7.45 The Highways Agency is satisfied that the operation of the A14 would be "no worse" with the carrying out of the proposed development.
7.46 As regards the issues raised by the Brightwell, Foxhall and Purdis Farm Group Parish Council, the Felixstowe South Reconfiguration scheme traffic impacts are not material at the Seven Hills Interchange. There is no need for mitigation works there arising from the development proposals. In relation to the A14 links, the Highways Agency does not require physical works to mitigate the impact of the reconfiguration scheme; matters are being addressed by means of the FQP and the FTMP required by the Section 106 Agreement. At the inquiry, the Highways Agency confirmed that it is extremely rare for the A14 to be completely closed.
7.47 As regards provision for cyclists, the proposed Travel Plan would include a wide range of initiatives to improve accessibility. There is a number of cycling facilities amongst the measures proposed, including improved crossing facilities at Walton Avenue/Ferry Lane to facilitate cycle usage from north of the Port to Trinity Container Terminal (via Dock Gate 2), and an upgraded cycle route from Peewit Hill to the reconfigured Landguard Terminal (via Dock Gate 1).
7.48 The SRA and the Promoters formed a Joint Study Group to assess the impacts of the reconfiguration proposal on the rail network. The results of that assessment are reported in Document CD/HP/124. The Group concluded that a dual section between Derby Road and Westerfield, as advocated by Mr BS Rose (Document ID/107), would be in an unfavourable location to achieve maximum capacity on the Felixstowe Branch Line.
The impact on ecology and conservation
7.49 One area of peacock worms would be on the edge of the proposed new dredged channel, but the bed near to the Landguard Point is not likely to be affected by the development.
Impact on amenity
7.50 The assessment that the impact of operational noise would demonstrate no significant increase over present levels is accepted by the independent expert retained by the District Council. The noise barrier proposed for Adastral Close would protect the properties there from both operational and traffic noise.
7.51 As regards piling noise during construction, the use of a shroud would be effective in reducing noise levels when the lower part of the shroud could be lowered into the water. That is possible only for about 85% of the hard driving period. Should the scheme proceed, the civil engineering contractor appointed would be required to investigate effective means of providing an acoustic curtain for as much as possible of the piling period, but the exact arrangements could only be finalised when the final design and detailed working methods were known. Any noise reduction proposals put forward by the contractor would be agreed with the District Council as part of an Agreement under Section 61 of the Control of Pollution Act 1974 before piling works were allowed to take place.
7.52 Further afield, traffic noise levels are already high for properties adjacent to the A14 on the north side of Trimley St Mary and Trimley St Martin. Increasing traffic would cause increasing traffic noise levels from the A14 in those locations, but only a fraction of that noise could be attributable to the reconfiguration scheme. The Promoters recognise, however, that much of the noise which is currently experienced by residents adjacent to the A14 is associated with HGV traffic serving the Port. Whilst maintaining that traffic associated with the reconfiguration scheme would do little to exacerbate the current level of road traffic noise, the Promoters have therefore offered to fund the installation of noise barriers for the areas most affected by traffic noise in Trimley St Mary and Trimley St Martin.
7.53 An emission survey on all locomotive types using the Trimley Line would not be a practical proposition.
7.54 The benchmarks used for the assessment of air quality impacts are the Government's current and future health based air quality objectives, as laid down in its Air Quality Strategy. The carrying out of the proposed development would not lead to any of these standards being exceeded.
7.55 As regards lighting, the Port of Felixstowe is required to be adequately illuminated at night to comply with the Docks Regulations 1988 and in order to allow staff to move about the Port and carry out their duties safely. The whole estuary is surrounded by urban development, port area lighting and street lighting installations. The proposed lighting scheme would result in a very considerable reduction in interference by lighting with the properties nearest to the reconfiguration scheme. The Promoters have also reached agreement with the District Council that, as lighting units in the rest of the Port area reach the end of their useful life and are replaced, they shall be replaced with a luminaire or lighting unit of a modern design specification. These would be low cut off zero upward light units to minimise upward light and obtrusive light from the installations. The operational requirements and the requirement for uniformity of lighting within the Port necessitate the slight tilting of luminaires to provide the appropriate level of illumination to comply with the Docks Regulations 1988.
Impact on the built heritage
7.56 The impact of the proposals on the built heritage has been considered by the County Council, the District Council and English Heritage. In the event, all three parties are satisfied with the proposals of the Promoters and have withdrawn any objection to them.
7.57 At present, the very existence of the Landguard Fort is threatened by the sea. The reconfiguration scheme brings with it the opportunity to provide against a 1 in 200 year flood, a substantial benefit to the Fort. The Fort would also benefit by the provision of an enhanced entrance and approach following the realignment of the Port boundary. Container stacking would be controlled in the area closest to the Fort, and plug in points for RTGs would be located in such a way as to ensure that RTGs would be parked away from the Fort.
7.58 Other buildings which are neither listed nor scheduled, but are of some interest because of past associations, have to be demolished. Each would be recorded to an appropriate level. In addition, so far as Shed 22 is concerned, an extended opportunity would be provided during which English Heritage would seek to arrange for its relocation. If that proved to be possible, then the building would be dismantled with a contribution paid by the Promoters towards its relocation. It would, in any event, be fully recorded.
Impact on coastal protection, erosion, flood risk and surface drainage
7.59 All the concerns originally identified by the Environment Agency and by English Nature have been dealt with to the satisfaction of those bodies. The Section 106 Agreement ensures that mitigation would be in place to deal with all coastal protection and erosion issues which might arise should the reconfiguration scheme proceed. A satisfactory flood risk assessment has been submitted and agreed in Document SCG/11. The proposed works would result in a standard of protection of 1 in 200 years.
Adequacy of the Environmental Statement
7.60 The ES is intended to help in the assessment of a proposal. It does not have to, and is not intended to embrace every last scrap of information. Its purpose is to identify and assess the main effects which the development is likely to have on the environment.
7.61 As regards the extent of the air quality assessment in relation to traffic impacts, it was decided early in the scoping process that the traffic assessment would extend as far as the Copdock Interchange, and the air quality impacts were modelled for the same study area. Representatives of the Suffolk Air Quality Management Group were formally consulted at the scoping stage, and have been involved since that time. Subsequently, the County Council requested that the District Council should be the ongoing point of contact on air quality matters. That request was honoured. Further receptor locations were added to the study at the request of the District Council, but there was no request for an extension of the scope of the study beyond the Copdock Interchange. Air quality impacts are the subject of Document SCG/14, to which the County Council and the District Council are parties.
Water supply and aquifers
7.62 The Promoters have carried out an examination of the issue. There are three aquifers in the area. The Promoters conclude that they are, or are likely to be, contaminated by sea water or by agricultural fertilisers leading to high saline and nitrate levels, or are above the level of the proposals and are, therefore, immune from dock-generated pollution or are subject to a combination of these factors. In any event it appears extremely unlikely that these aquifers would be used for drinking water extraction.