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Back button | Home | News | FORP Objection to Saltaire hydropower scheme in Roberts Park
Added to website: 23 April 2015
FRIENDS of ROBERTS PARK OBJECTION TO 15/00040/FUL CONSTRUCTION OF A HYDROPOWER SCHEME IN A HERITAGE PARK

Download this OBJECTION document as an Acrobat file

MEETING: Wed 29 April, Shipley Town Hall 10.00am
Please note: There is a meeting to discuss the planning application for the hydro-electric scheme proposed for Roberts Park, Saltaire, arranged by Bradford Council. It takes place on Wednesday 29 April 2015 at Shipley Town Hall Shipley at 10.00am. More info on meeting >

Updates and related info:
1. Letter: 20 April 2015: The Heritage Lottery Fund does not grant approval to this scheme.

2. The Council seek approval at the meeting on 29 April 2015. Local Planning Authority received 53 objections, including one from the Member of Parliament, and 20 supporting comments, including two from Shipley Ward councillors. (More detail >)

INTRODUCTION

1.1 This objection to the hydro scheme is made on behalf of the Friends of Roberts Park, a group that not only loves the park but whose members have made a significant contribution to its operation and its great success.

1.2 In principle, the Friends are supportive of green energy projects and recognise the work that has been put into the re-design of the hydro which is much better than the original.

1.3 However, the National Planning Policy Framework [NPPF] requires that
Where a proposed development will lead to substantial harm to or total loss of significance of a designated heritage asset, local planning authorities should refuse consent, unless it can be demonstrated that the substantial harm or loss is necessary to achieve substantial public benefits that outweigh that harm or loss...

1.4 Harm will be done to Roberts Park - and the applicant agrees with us:
It is acknowledged that the propose
d development may have an adverse impact on the park…
[Planning Statement]

1.5 But unlike the applicant, we believe that the harm that will be done to Roberts Park will not be outweighed by the benefits the hydro scheme claims to deliver.

2
THE SCHEME DOES NOT OFFER SUBSTANTIAL BENEFITS

2.1.1 Bradford Council’s website states that The turbine would harness power from the flow of the River Aire at Saltaire Weir to generate approximately 339,000 KWh [=339MWh] a year of electricity.

2.1.2 This is a misleading half-truth. The turbine may get close to that figure in the early years but its productivity will decline significantly. This decline is documented in the 2012 Council-commissioned feasibility study by JBA Consulting. The study said that the mean estimated net energy for the 2050’s is 244 MWh per year.

2.1.3 Declining performance is not confined to Saltaire. It is the reality for many installations:
Changing regional weather patterns are likely to affect the hydrologic cycle that underpins hydropower generation. In some regions, a decline in rainfall levels and a rise in temperature, leading to increased water loss, could result in reduced or more intermittent ability to generate electricity. [Climate Change: Implications for the Energy Sector. Key Findings from the Intergovernmental Panel on Climate Change. Fifth Assessment Report June 2014] This decline is already being experienced in the UK: Hydro generation [in 2013] decreased by 10.7 per cent on 2012 as a result of lower rainfall. [Dept of Energy and Climate Change press notice Ref 2014/016 27 March 2014]

2.1.4 It is notable that the application makes no reference whatsoever to the declining performance of the installation. Why not?

2.2.1 But whilst the starting figure of 339MWh sounds impressive, in reality it is very modest:
· 339MWh equates to the total energy usage of between 17 and 20 typical houses.
· 244MWh equates to the total energy usage of only 12 to 15 houses.
[www.ofgem.gov.uk]1

2.3.1 However, we are told in the applicant’s Design and Access Statement and in its Heritage Statement that:
The proposals will make a significant contribution towards the Council's energy targets of [sic] generating 20% of energy needs by renewable energy sources.

2.3.2 This sounds positive but does not appear to be true. In a letter from Bradford’s Chief Executive to local MP Philip Davies, the CE stated that
1 Why is this so different from the Council website’s claim that “around 339,000 kWh of electricity a year [is] enough for up to 100 homes”? Because electricity only accounts for ~22% of household energy usage. [www.ofgem.gov.uk]
The Saltaire hydro scheme would meet 0.5% of [the Council’s] current energy consumption and this would be 2.5% of the Councils [sic] agreed 20% by 2020 target. [Tony Reeves, CE BDMC, 28 August 2012 (ref CE/TR/KS/11095)]

3
THE SCHEME WILL HARM ROBERTS PARK

3.1.1 Contrary to what is said or implied in several of the applicant’s documents, the hydro scheme’s location is Roberts Park. The Noise Impact Assessment states that
The land is immediately south of Roberts Park…
It is not, as the 1870 map in the same document makes clear.

3.1.2 In addition, Roberts Park is within, and a significant part of, the Saltaire World Heritage Site.

3.2.1 Nonetheless, the applicant claims that building a turbine is not unreasonable because
All the principle [sic] landscape features of the Grade II* Registered Roberts Park are located outside of the area of the proposed development.

3.2.2 This statement is highly misleading: English Heritage does not specify ‘principal landscape features’.
[http://list.english-heritage.org.uk/resultsingle.aspx?uid=1001226]

3.2.3 And if only the obvious stand-out features of Roberts Park are protected, may we look forward to a wind farm on the green space adjoining the cricket pitch?

3.3.1 The harm that will be done to Roberts Park may be summarised as follows:

  • an area of parkland will be turned over to industrial usage
  • during construction, the park and the nearby play area will be very noisy and in turmoil for ~6 months
  • industrial noise will become a permanent feature of the park
  • maintenance of the turbine and the river itself will require the use of large plant, involving ongoing disruption and noise. The 2012 feasibility study said that “The design should include for access by long reach excavator to the intake”. The area above the intake will be designed to accept excavators “working from the bank
  • mature trees will be lost.

3.3.2 Noise is of especial concern to us. This is a park after all, yet the application entirely ignores the ongoing adverse impact on park visitors.

3.3.3 The Noise Impact Assessment does acknowledge that the site’s residential neighbours may well suffer adverse impact during the 23 week construction phase:
a significant effect may occur for nearest noise sensitive premises [sic] during piling and pile extraction…
It is recommended that a temporary noise barrier is installed for the duration of the construction works, where practicable, between the construction area and nearest noise sensitive locations.
But it fails to mention the people most affected. Since the nearest noise sensitive location is the very well-used footbridge and park path, the effect on local pedestrians and visitors will be even worse.

3.3.4 Figure 7 in the Noise Impact Assessment shows that the location of greatest ongoing noise will be at the hydro itself:

Note that this location is:

  • within the park
  • immediately adjacent to that busy footbridge and the most used of the park’s entrances, and
  • where visitors love to stop and take the iconic view.

3.3.5 Those most impacted by construction noise will be park visitors and local pedestrians. Those most impacted by ongoing noise will be park visitors and local pedestrians. This represents harm, and it contravenes Bradford planning policy which states that:
Development will be permitted provided that it does not have an adverse effect on
• The surrounding environment; or
• The occupants of adjoining land.

3.4.1 It also represents an example of the NPPF’s “substantial harm to… a designated heritage asset”. But the harm to heritage goes beyond noise.

3.4.2 Firstly, Titus Salt’s urban plan which dedicated the Aire’s north bank to recreation will be compromised. This plan was fundamental to UNESCO’s inscription of Saltaire as a World Heritage Site:
Its textile mills, public buildings and workers' housing are built in a harmonious style of high architectural standards and the urban plan survives intact, giving a vivid impression of Victorian philanthropic paternalism.
[Quoted on the Saltaire Village website]

3.4.3 Secondly, Sir James Roberts “carried on Sir Titus Salt's ideals”
[http //www.victorianweb.org] when he presented the park to the people of Bradford. In his Deed of Gift, Sir James required – and Bradford’s Corporation accepted – that
The Corporation will at all times hereafter keep the said Park for the purpose only of a Public Park and Recreation Ground….

3.4.4 The Deed’s restrictions do not only apply to the land. The river was, and is, protected. Bradford agreed that:
The Corporation will not at any time hereafter do or permit to be done on the plot of land hereby conveyed anything which may in any way interrupt or interfere with the usual flow of water in the said River Aire past the adjoining land of the Settler on the South and East sides of the hereditaments hereby conveyed.

3.4.5 If Bradford Council is allowed to build this hydro, it will represent an unacceptable breach of trust with those who created and generously gifted a magnificent heritage asset. It represents “substantial harm to… a designated heritage asset”.

4
THE SCHEME MAY WELL HARM THE RIVER

4.1.1 The Friends are seriously concerned at the impact on fish stocks and angling predicted by the Aire Rivers Trust and Saltaire Angling Association.

4.1.2 We will leave them to make the case, but if their assertion is correct, this would contravene policy NE12 and NE13 of the Replacement Unitary Development Plan 2005 which requires the retention of landscape and wildlife features and wildlife corridors.


CONCLUSION

5.1.1 The Friends of Roberts Park believe that the building of the proposed hydro fails to offer benefits sufficient to justify the harm to Roberts Park and the World Heritage Site of which it is part.

5.1.2 The application is therefore inconsistent with the National Planning Policy Framework and should be rejected.

5.1.3 As we have shown, other planning rules and guidance will also be breached, giving further reasons for rejection.

5.2.1 However, if the planning panel decide to approve the scheme, we ask that they place a condition that a higher standard of noise mitigation be incorporated at the outset. We have been advised that water-cooling of the fans would reduce noise further – and given the sensitive location of the turbine in a popular, heritage park, this does not seem an unreasonable requirement.

Lesley Brook
Chair
Friends of Roberts Park
15 February 2014

See also: THE REQUEST FOR A REVIEW
The Friends of Roberts Park request a review of the decision by the Commission to make the Order dated 20 November 2014 to the Roberts Park (formerly Saltaire Park) charity 238159. See document >

 

   

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