In response to Helius's recent press release regarding a further extension to the pre-consultation period and their intention to review all comments received to date as well as reviewing the siting, form and external appearance of the scheme we would like to request further and immediate clarification on exactly what Helius's intentions are at this stage.
We feel this is another example of a "woolly" and non committal press release that has the potential to be read and interpreted in a number of different ways. For something that is causing a lot of distress and anxiety to the local community we feel Helius could be showing a greater deal of concern over how their actions are affecting people's lives and all we ask is for a coherent and plain approach from them.
At the crux of our concerns are the fact that any major deviation to the siting or form of the current proposal are no longer a continuation of the proposals but a new proposal that should be subject to a new, independent IPC application and consultation period with it's own dedicated SOCC and project promotional period. If this is what Helius are proposing then they should call an end to the current proposal by indicating to the IPC they will not be taking this application forward.
If Helius then feel they have a different project for the same site, that could provide a real local benefit and be classed as positive to us as residents then by all means start the process again and win our backing by proving they listened to us and overcame our objections to their first proposal by coming up with an acceptable scheme for this location.
Of course if Helius are just attempting to confuse and distract from the current proposal yet again, then this course of action will be of no interest to them and effectively they will still be attempting to convince the public of this project's merits when it is clear to everyone the project has no local merits whatsoever and in fact will harm our community. By talking of still submitting an application on this current project this is the NSB Groups real fear and reason for our call for Helius to clarify in plain English their intentions now for all our sake.
After considering information that came to light over the 2 latest IPC held meetings explaining the process in more detail we have a number of concerns so far on the process and wish to make these known now in the hope that Helius can genuinely take these on board by abandoning the scheme in it's current proposal and if so choosing to re-consider another project either on the same site or within another Southampton site that at least they learn from what we feel are the mistakes made so far on this project and do not repeat them. If they wish to pursue this proposal in it's current plans then we ask for a new pre-application process that isn't hampered by misleading information, provides the basic project facts and information only and is properly promoted to all local groups and residents of Southampton who will be impacted as per their statutory requirements.
Our major concern with the adequacy of the pre-application is mainly concerned with the inability of Helius to accurately communicate what the exact proposal is and to provide an accurate representation of the proposed project either through the project website www.southamptonbiomasspower.co.uk or through the number of public exhibitions that have so far been held to clarify and explain the project and the non technical consultation document Helius released. We feel there has been a deliberate attempt to confuse what the proposal actually represents and this has been done in a manner designed to purposely bias public opinion either in favour of the project or for them to feel the project has no significant impact on them and therefore not offer any comment on the project. To clarify this to date, we as the public still do not know a) What the project will actually look like or even a range of options that would reflect potential final designs or b) The exact size of the proposal itself. We feel these are 2 of the most fundamental points for the many residents living in eye-shot of the proposal who will be presented with this view on a daily basis
The Planning Act 2008 paragraph 16 guidance as mentioned in Helius's Southampton Community Consultation Strategy pdf lists 5 points on what the public consultation should achieve and below we will elaborate on why we feel the process so far has failed to adequately fulfill these requirements.
The Statement of Community Consultation was implemented to govern the pre-application process in conjunction with Southampton City Council. As far as we are aware this report was published on a single date of 8th November 2008 in a single local newspaper publication. It relied on a normal resident purchasing the local paper and seeing the notice in this commercial paper and immediately recognising the importance of it. The release was a series of statements that collectively formed the SOCC that would govern the pre-application process and contained no identifiable title or scheme image to draw attention to the sheer scale and size of the project with the largest title/element being the Helius Energy logo and the scheme purely titled SOUTHAMPTON BIOMASS POWER which makes no reference to a large scale industrial planning application or inference that this concerns a Major Infrastructure Development . As such the majority of residents remained completely unaware of the project or proposal despite the statement even identifying residents of Millbrook and Freemantle living in the vicinity of the project as groups with a particular interest which seems at contrast to the aims of making all local interested parties aware as the crucial area of Shirley was omitted.
After a period of over 3 months from the initial single publication of the Community Consultation statement Helius held an update meeting with the IPC and SCC to update on project process. Helius proposed 2 public exhibitions for that week with again a single local advert placed in the Daily Echo that Monday advertising the events. Helius also reported the distribution of 14500 leaflets the previous week. Our concerns with these leaflets is how they were distributed and the content of the leaflets. A very large number of residents in the identified groups of interest have indicated they were not aware of receiving these leaflets. As a tri-folded leaflet the leaflet's main page on viewing looked more like a generic environmental groups info leaflet or an energy companies attempt to get you to switch supplier - in no way did it accurately portray the proposal of a major Infrastructure in Southampton and that this was something that had been identified as having an impact on local residents and therefore inviting them to have a chance to understand the proposal and an opportunity to respond and have their opinions considered by the applicant.
Throughout the communications from Helius there are statements of the project details being fully available on the project website www.southamptonbiomasspower.com . We have 2 main concerns with the project website and it's role in providing an adequate pre-application.
1. We are concerned that although on the website, in the public domain, absolutely no effort has been made by Helius to promote this website to concerned groups - the web address was not in a prominent position within the single press publication of the SOCC.. As such you can have the best website in the world but without advertising or having a strategy in place to drive traffic to the website it is performing no function. We note even now there is very little external linking to the project website. This would indicate no efforts have been made to Internet market the proposal. Again for such a large scale project, that is crucial for public awareness there are a number of ways the project could have been promoted more eg paid for adverts on high traffic, local relevancy sites or through targeted social media marketing eg Facebook adverts to help ensure the project was properly promoted to all sections of the affected Southampton residents.
2. The website itself has no images of the proposed project or visual reference to a large scale Power station/Infrastructure building easily accessible. All project images are hidden away in the technical downloads. The images and slant of the whole website is to promote the idea of green energy not to plainly represent the project itself which surely should be the basic principle for the official project website as an information source to set out the proposal in full. Anyone visiting the website expecting to learn more specifics on the exact project could easily be misled in to a belief that this is not a large scale development. As such we feel the website falls short in informing people easily of the project itself.
As a result of what we can only guess were SCC concerns with the manner of the 1st consultations and leaflets a 2nd leaflet design was produced and distributed. This leaflet was put in a plain white envelope with the Helius logo, Southampton Biomass Power Public Exhibitions in bottom right corner and addressed to The Occupier and posted via Royal Mail normal post. If you had no idea of who Helius were the envelope easily appears as just a junk mail circular as it wasn't personally addresses or very clear that the envelope contained important information on a proposed power station that the council and Helius had deemed to potentially affect the household receiving the letter. As the only strategy for promoting the public event it seems woefully inadequate in raising the public awareness and yet again something very likely for people to not actually notice due to the "disguised nature" of the distribution. We feel it has only recently come to residents attention by our own efforts to raise awareness. Many of our core residents have put their own lives on hold to ensure the public are made aware of these plans and we think it is very fair to say we are the point of source for many of those now aware of these plans and we have achieved this through very basic marketing of Website, Hand Posted flyers and associated press from the few organised events we have held. Evidence in this exists by the difference in numbers who attended the recent IPC meetings with Southampton being capacity and Marchwoods (where we haven't focused our efforts) having less than 6 residents present! As such we feel as the official consultation period draws to a close people in affected areas are still unaware of the enormity of this proposal and how it could impact their lives and our city.
The Public Exhibitions themselves were not adequate in answering and presenting the results of the technical and non technical documents. The boards were carefully crafted representations from Helius attempting to distort the basic facts of the project and again purposely mislead or bias the general public.The exhibition also contained mis-leading and irrelevant information that could have caused confusion and mis-understanding to those that attended. Our main comments on the exhibitions themselves and why we feel they were not adequate are
The boards themselves were all designed and marketed with the slogan "SWITCHING ON THE GREEN LIGHT" across the bottom of every board. When Helius were questioned on the source of the Biomass which is crucial in determining the overall "greenness" the public were told this is commercially sensitive information. The whole green statement is based on a number of related factors and this project, in it's current format can not be classed as a green project especially when from the outset Helius have not attempted to build the project on a site that has an immediate call for a CHP plant, something widely stated as a crucial element of consideration - the project can be said to be greener than building an identical sized, brand new, fossil fueled powered plant but that is very different to a generic green project. When discussing carbon savings we asked for information on the carbon footprint of the 3 year construction period and were informed they weren't required to calculate this - again for what could consist of more than 10% of the operational life of the plant the carbon cost of this period seems crucial in deciding the projects greenness and therefore justifying the Helius green credentials.
The board with regards Biomass and the generating process very over simplified the process and as the plant proposal was for majority of wood to be imported should have shown the increased proportion on import biomass over domestically sourced. Again we have the issue of the electricity being produced as being Green Electricity - This is Helius's take and something without taking into account the full project not a statement that can be made with full conviction - there is evidence available that shows converting current fossil fuel plants to run on biomass is significantly greener than new Biomass - also in terms of CO2 gas burning is a cleaner energy source albeit it uses an exhaustible fossil fuel. In terms of fairness it would be better that these exhibitions stick to the basic facts of the proposal ie Electricity Generated with known colour scheme of yellow zig zag rather than an un substantiated green zig zag attempting to persuade the public of the green benefits of the project.
The Project Information board (and website project page) state 450 construction jobs. This is massively increased from original SOCC of 250 jobs and other previous documents. We feel this increase was in response to concerns about no immediate benefit to Southampton residents and is an attempt to make the proposal carry more weight in showing a local community benefit through the extra jobs the project will create. We pointed out this discrepancy only to be told it wasn't important and only an indicated peak employment number - we disagree with this Helius view and feel it hasn't helped with producing a coherent and consistent application for people to comment on. This board also states potential heat supply. This matches the SOCC statement but appears in total contradiction to the original project plan as discussed with the IPC on 7th September 2010 where the true intentions of the company are to make this CHP ready but they have no interest in ensuring this is taken up, relying on 3rd party take up. As this is a major consideration into the efficiency of the plant and therefore it's lean towards "greenness" it is only fair to say Helius are not attempting to build the most efficient Biomass station as commercially their model can run on pure electricity generation alone - understanding this is one of the reasons for our major objections to this project being so pre-dominantly promoted as green as CHP is by far a more environmentally friendly and efficient system! Our worry is the average public person will not understand this and therefore the Helius consultation is flawed as it is presenting an unfair view of the actual project they propose to construct and operate.
In the visual board there seems to be inaccuracy in the super-imposed "what it could look like views". When asking the visual expert on what steps were taken to ensure scale they could not answer and could only state they believed they were all scale accurate. For something so crucial as getting the visual impact as accurate as possible it would seem that this should have been one of the most crucial elements yet we got 3 boards of scale outlines, 2 of full cgi generated images and 1 board with 6 smaller images of possibly not to scale artist impressions of the real world impact. As part of a fair exhibition and to help the layperson understand the project accurate artistic drawings or scale models should have been presented for people to judge. As a group we have managed to have a scale model machine precision created to represent the scheme - why have Helius neglected to do this themselves to accurately reflect and demonstrate their proposal to help people fully understand it when the visual impact is such a large issue? When questioning Paul Brighton on the visual design we were told the images were all worst case scenario. When questioned further about what could be done size wise to reduce the visual impact we were told that all the finished designs would be "roughly the same size as the plan" - this appears to be a complete contradiction to the official press release that implies a scaling down of the project size. Also we can't stress enough the visual impact on both residents and visitors to our city as this site is adjacent to one of the main gateways to the city and visible from surrounding national and historic locations - for these reasons it is crucial we are presented with a much clearer idea of the visual proposal at the start of the projects life to be able to effectively consider and respond to the application.
The air quality slide was the complete opposite of the generating slide in that it went in to a lot of technical detail and presented the information in a manner the average person just didn't understand. When detailed questioning of the process behind the calculations were given we were told the full results were within her (the air quality experts) report to Helius - yet this document has not been made public yet so we are unable to see the extent of the report. We questioned as to why the 5 results displayed were chosen and we were not given any answer. We questioned why the figures for the square where the proposal was for, weren't included on the board again she didn't know why they had chosen the squares they had but did say her report had the details for all the squares. We also asked whether any of the 5 results reflected the square with the biggest impact from the plant and discovered this square was in the Shirely high street area and wasn't included on the board as one of the highlighted squares. As other slides are designed to show worst case scenarios why did the crucial air quality slide neglect to show the immediate site impact and the worst case example from the emissions modeling? We are also waiting for information from DEFRA to clarify how the modeling was done as we have possible concerns over the modeling used due to recent reports (non verified) that indicate modeling accuracy may be underestimating the actual figures - http://uk-air.defra..gov.uk/reports/cat05/1103041401_110303_Draft_NOx_NO2_trends_report.pdf - a report found on the website the air quality lady gave us for information on how her figures were calculated. Reading through notes from previous IPC/SCC/HELIUS meetings it appears other concerns have been raised on whether this modeling has been EA approved - as such we may have figures on air quality that won't last the process and as they form such a major part should be impartially and accurately collated in advance of any planning proposal.
Noise level slide was again fairly technical - what it didn't show was any comparison with current noise levels in the area or the operating noise levels of a similar size and purpose biomass plant. As such it is just a theoretical report and something that causes confusion to the average person. It seems the board omits any of the level of detailed needed to put the data in context. Our concern is if there is nothing to hide why not show the current level and the actual impact on the residents - this is our expectations of this consultation process if we are to be able to comment accurately on the proposal on how it may affect us.
The peak vehicular flows board was again very technical with numbers at odd angles, which made them hard to see and more importantly understand. The tags on the board (and still on the website download) were mis-leading as they give the impression of an AM and PM period of many hours when in fact they were figures for single hours eg 8-9pm and 4-5pm. When this was discovered the technical guy was happy for us to provide a sticker to add this information - however the web download hasn't been amended despite the traffic expert agreeing the board could have been better worded to make it clearer. Again this is another example of Helius attempting to mis-lead and lesson the potential impact of their project. Our concern is anyone judging the project, without the ability to clarify exactly what this information needs with the specialist would seriously be likely to mis-understand the information on this board.
The IPC application board failed to provide details of the IPC meetings to explain the process - surely as part of a public consultation and in explaining the IPC role this information would have been relevant and useful to visitors - far more than the SWITCHING ON THE GREEN LIGHT STATEMENT. Our feeling is Helius are attempting to just do the bare minimum to comply with current regulations to put through their commercial project due to the governments slant towards encouraging these projects - this is their right but we feel they have fallen short of this bare minimum mark and have actually crossed into the realms of less than minimum and actually attempting to mislead the public on the true extent and potential impact of this project in the hope the proposal goes through un-opposed.
There was also a picture book of various power stations across the world. This had no relevance to Helius's proposal as none of the stations pictured were their ones and as such it had no place amongst their public exhibition except to confuse the public into thinking Helius are a more established company or that this proposal was similar to some of the other ones built.
We then have one of the most major issues in our opinion. After the first day of public consultations Helius released a press release to the local media. This talks of reducing the size of the buildings. As this is one of the most crucial elements of the process if the building size is to be significantly reduced then it would mute this proposal/application void and would need a new project and new pre-application procedure due to the substantial change in design and the implications of that substantial deviation from the original plans.
If we are just discussing modifying the outside element or external design then again this seems to contradict the press release and will only confuse people to what this application actually is and the affect it could have on them. Either way Helius have not provided a fair and accurate pre-consultation by press releases that have confused and possibly misled the public. Certain residents are of the belief the plant is being down scaled as could be taken from the official press release, yet this can't be achieved under the current application.
The statement on air quality is misleading in the press release. It doesn't state the air quality reports have not been verified and agreed with by the EA, HSE or SCC (An issue highlighted in the 8th February meeting between the IPC, Helius and SCC) so to infer the impact is negligible is attempting to influence public opinion before the evidence is there in black and white as CERC's work may not meet the requirements of the EA/HSE with regard it's report on the air quality. To state the wood source as sustainable when no details of the source of the proposed wood or details of contracts of obligations entered by Helius are present there is no way of judging the woods sustainability therefore this statement is misleading. As a recent statement by The Secretary of State in relation to the legal challenge to Helius/Bristol City Council by Coedbach action team there is no legal standard or agreed legal definition of what sustainability means in terms of biomass fuel sourcing - in light of their involvement in this case to keep quoting sustainably sourced seems to be contradictory when there is no measure to judge this sustainability against and as such it becomes a meaningless statement. There is no legal framework that would allow the UK to enforce a standard of sustainability on EU member states or third countries.. In light of this any talk of sustainability is confusing the process and in our opinion attempting to mislead the public - What affect could potentially occur in the future if certain third countries sources were deemed un-sustainable and Helius had to source from UK only (something that makes a good argument for a green project over just a commercial venture). We feel this press release was a deliberate attempt to pacify and reduce any Southampton residents interest in the project by attempting to dismiss our concerns and publicly raised issues on the subject. As such it was not the right time for such a release and has clouded the issue with the general public to the point we feel this pre-application can no longer proceed having not met the requirements of the SOCC or planning act in adequately consulting with the public.
There are still other issues with the pre-application process so far including the Daily Echo adverts - All adverts have been placed on a Monday. The daily echo charges advertisers different rates that vary due to increased circulation days due to supplements and content within the paper - this is freely available information on the advertisers rate card. Thursday is the most expensive day for advertising as the paper has its largest circulation figures due mainly to the jobs section and the interest in Southampton residents for this job information. As part of any adequate campaign to alert the population of a large city this singular approach to marketing seems very unlikely to achieve it's goals of raising awareness. As a commercial company that obviously invested a large budget in the project planning it seems completely disproportionate to the amount then spent to advertise the project and achieve the local awareness required for a fair and adequate public consultation. Our expectations would be for a prolonged campaign to increase exposure or at the very minimum to choose to advertise on the highest circulation day of the paper.
The public meetings have been inadequately advertised and there is still a feeling that the majority of residents are unaware of the plans and how they could be affected. If the area of highest pollution from the chimney fall out has since found to be in Shirley then surely the businesses and residents of this area need to be added to the core group that need to be informed of the scheme in advance. Looking at the SCC website we found figures of Freemantle ward population of about 14,100, Millbrook ward population of about 15,500, Redbridge population of around 14,500 and Shirley ward population of around 13,900. These areas alone account for around 59000 people so 14500 leaflets, designed to go unnoticed and a single/couple of echo adverts alone seem a poor attempt at communicating with the public especially with mis-leading information and a lack of depth and transparency around the important information the residents are requesting in association with this proposal.
In conclusion this project should be immediately stopped and fully re-thought in light of the feedback received so far by Helius on public feelings. At the very least the project needs to be fairly and accurately portrayed to all the people it will affect as part of any adequate planning application and we feel this needs to be reflected in the SOCC and Helius's actions in fulfilling their obligation to explain their project accurately and to the detail required by those that it will affect.