Havering Friends of the Earth concerned over Council’s plans to build Data Centre on Green Belt land.

Today, Havering Friends of the Earth write in the Havering Daily in regards to the plans to build a data centre on green belt land.

Data Freeport Issues (filed: HFoE LBH)

We are very concerned indeed that London Borough of Havering (LBH) has decided to consider an application to build a Data Centre on Green Belt land, and that it is considering the application through a Local Development Order, rather than a full Planning Application. 

There are many aspects of the application that are worrying. Here are our main concerns, and we believe that there are many more which could be raised. Hence our asking for a full Planning Application:

1.The use of Green Belt Land:

We do not accept that the proposed Data Centre is an ‘exceptional’ case such as to justify the damage to the natural environment. It is acknowledged in the applicant’s presentation that there is a  SINC (site of interest for nature conservation) on the site it wants to occupy. This must be preserved, along with the green environment on the site. 

The benefits will be primarily to companies that handle large amounts of data. The promise of jobs is not likely to benefit local people, and we understand that most data centres outlive their usefulness in 9/10 years. Will the workers travel in by car? What is the environmental impact of thousands of workers on the site?

There is a considerable danger that allowing this development would set up a precedent in the area, and there is talk of linking up with other Freeport areas nearby. Green Belt should be protected and not allowed to be gradually taken away.

The Campaign for the Protection of Rural England (CPRE) is‘appalled’ that the council is looking on this scheme favourably. We believe other environmental groups will agree that it is not acceptable.

2. Freeports:

We are amazed that the council is seduced by having a freeport in the borough. These benefit companies that want to minimize taxes and reduce regulation. The current Conservative government is keen on them, but the Residents Association has not raised any concern about this. 

3. The nature of data centres and their impact on the environment: 

These enormous banks of computers (never mentioned as such in the application!) require a large amount of electricity – the figure of 600 MW is quoted – which it is said will come from the existing Ockenden substation. The source of this electricity is therefore fossil fuels – it is not renewable or sustainable.

It is disingenuous of the application to highlight the solar farm at Cranham (which we supported during its application) as this has nothing to do with the proposal for North Ockendon.

There is apparently a care home nearby – has the impact of noise from the plant been considered?

Bunds are, in our view, unsightly ways of hiding even more unsightly industrial buildings!

Usually such data centres require cooling, as the operation of the computers generates heat. Often such centres are built in countries such as Finland or Iceland to make cooling easier. It is said the heat will be used to grow produce, but there is no word of whether or how this will be sufficient to cool the plant.

It is extremely likely that the plant will produce carbon dioxide and contribute to global warming. Data centres worldwide are known to contribute measurable quantities of carbon dioxide. 

There will be banks of batteries (50,000 square metres!) -therefore impacting on the mining of heavy metals and lead, which has caused concern globally. Will there also be a back-up, as is often the case in data centres, of diesel? 

Conclusion:

In sum, given the complexity of the proposal, the enormous cost (£35 billion) and the fact that it will take years to put into operation, we do not accept that this application should be hurried through. We believe there should be a full Planning Application, so that the public can have time to understand the nature of this development. 

Page 1:

Site (432 acres open farmland) is in an area designated as Green Belt. 

Other on-site designations on parts of the site include Mineral Safeguarding, Flood Zones, Site of Importance for Nature Conservation [NB] and Archaeological Priority Zones.

Nearby: sporadic residential/commercial including a care home…. [noise]

Page 10:

Market gardening + gravel pits…

Cranham solar park… [not part of the scheme] 

Page 11.

Vision:

Deliver a world class data centre campus that supports the government’s digital strategy and ensures the UK remains a leader in the international digital economy and increases London’s data centre capacity by 50%, ensuring the UK businesses have access to appropriate digital infrastructure to grow. [waffle!]

• Deliver an exemplar green infrastructure project that aligns with the government’s Clean Growth Strategy and policy ambitions for a carbon neutral future. [how does a data centre do this?]

• Integrate on-site renewables and invest in infrastructure upgrades on site to facilitate the delivery of 1,100 MW of green renewable energy to the grid. [see below]

• Promote innovation in agriculture, meeting the Committee on Climate Change’s Net Zero UK land use policies including tree planting, the introduction of Agro-forestry and restoration of wetlands. [how much space for this and will it happen?]

• Use waste heat from the data centre campus to grow produce that requires humid growing conditions, dramatically reducing the carbon footprint generated by these products creating a sustainable reduced carbon mile food supply for London. [Is this the innovation in agriculture?!]

• Deliver a biodiverse landscape with a discovery and learning centre providing an amenity that increases wellbeing and the health of the community. [as above]

• Ensure the design is shaped to integrate the buildings into the surrounding landscape using a strategy of wooded bunding and ditches that in turn increases biodiversity on the site[bunds are unsightly!]

Page 12:

Total Proposed Development Area 390,000 sqm 

Data Centre 330,000 sqm 

Electrical substations, distribution and infrastructure equipment; TBC [why TBC, and how is this green?]

An Information and/or learning space TBC [why TBC?]

Indoor Agricultural facilities 40,000 sqm 

Green Energy Power Generation Technology 50,000 sqm [how significant? And what?]

Battery Storage 50,000 sqm 

Nature Reserve 280 acres/ 113 hectares. [check what this means…]

[NB: no mention of cooling required].

Page 13:

The proposed development includes for 330,000 square metres of data centre floorspace which is considered as a Class B8 (storage and distribution) use. The primary function of the development is to support cloud computing services and the storage of data. 

The development would be Europe’s largest single data centre campus and an infrastructure development of national importance. It will increase London’s existing data centre capacity by more than 50%, ensuring the UK remains internationally competitive. 

The specification of the design and quality of the proposed development is proposed to be very high. The data centre buildings will be sensitively designed into the ground and the landscape, softened by extensive new planting and green infrastructure, with significant benefits to biodiversity. It will also embrace a number of innovate sustainable solutions, such as the repurposing of data centre heat to warm indoor agricultural facilities. 

Thanks to a £113m investment in the grid infrastructure at Warley development is proposed to operate on a Carbon Neutral basis with Carbon Negative infrastructure designed and installed to feed into the grid in the future as green technology advances. [ Does this make sense? What is meant by carbon negative infrastructure and isn’t this for the future?] It is intended to be an exemplar for the future of data centre design and operation of global significance to the future of the planet, showcasing the UK as a world leader in reducing carbon emissions. The Carbon Neutral and Carbon Negative attributes are anticipated to be able to facilitate further inward investment and job creation whilst being a significant contributor to the UK plc’s target to achieve zero emissions by 2050.

Page 14:

Horticulture 

The development proposals will result in up to 40,000 square metres of indoor heated or non-heated horticulture within the southern confines of the site, close to the proposed access off of Fen Lane. 

Battery Storage or Grid Balancing Infrastructure 

The development proposals include for the provision of up to 50,000 square metres of battery storage or grid balancing infrastructure across the site to support Greater London and UK’s electrical network at peak periods, support renewable energy technology on and off site together with the achieving the development future Zero carbon targets. [unclear how this works aren’t the batteries there for computer banks?]

Hard and Soft Landscaping:

Hard landscaping within the built area will be as locally sourced, low carbon as reasonably possible and provide SUDS features such as permeable paving. All build zones will be required to meet a detailed soft landscaping standard or guidance to enhance the biodiversity of the wider site nature reserve and where possible complement or enhance new biodiversity corridors proposed as part of the wider site master plan and infrastructure. 

Parkland/Ecology Park:

The proposed development seeks to incorporate a Nature Reserve no less than 113 hectares (280 acres). [check significance?] This Nature Reserve would be for use as parkland and to provide enhanced biodiversity / habitat to compensate for the proposed development. It is intended that this Nature Reserve would include the provision of a mixture of wetland, wet grassland, wet woodland, woodland, ponds and open grassland. [ How, from farmland?] A network of foot and cycle paths would be provided, whilst a discovery centre is also proposed. 

Green Energy:

The development provides for up to 50,000 square metres of green energy power generation technology such as gas or hydrogen generators, fuel cell, battery storage, green micro grid or other technology to achieve on site renewable energy and future Zero carbon targets. [battery storage = green? ‘such as’ is vague, and ‘on site renewable energy’ is also imprecise – how much of the site or of the energy?] 

Highways & Engineering Works 

The proposed development will include new on and off siteroad infrastructure to support the proposed development, whilst engineering works will include (but are not limited to) the creation of an open swale and SUDS pond and biodiversity features. [as above – SUDS are not innovative]Cut and fill levelling is proposed locally to each build zone to provide suitable development platforms where required, excess soil will be reused on site for raised woodland landscaped bunding to the build zone parameter. The raised bunding will assist to reduce or remove visibility of the proposed buildings from proposed the proposed nature reserve along with the wider area and heritage assists. [as above, bunding is unsightly]

Page 16: 600 MW power supply from the Warley Substation… [as above – green?!]

Page 18: £5.3 billion investment – jobs etc. 

Construction phase 2023 – 2027… 

GVA investment [?} 

From DCD: (November 15, 2022 By Peter Judge):

Environmental group CPRE has promised to fight proposals to build a 600MW data center campus on East London’s green belt in Havering. The Campaign to Protect Rural England (CPRE) says it is “appalled” at the scheme, 

if the center becomes part of Thames Freeport, a new economic zone where normal tax and customs laws do not apply.

The proposed project site sits within the outer boundary of Thames Freeport, which was announced in the UK Government’s 2021 budget, and intended to promote the “leveling up” of deprived areas in Essex, East of London. Havering Council has applied to have the project included within the Freeport zone, which would enable the council to keep 100 percent of the business rates levied on it, reports Mellor.

Digital Reef has also offered the council a one-off £9 million payment if construction starts by 2024 – a date which, Newsquest’s Josh Mellor points out, can only be achieved if the council gets the planning process accelerated through a Local Development Order (LDO) which must be approved by a central government minister.

A decision has been reached by Officers to explore the proposal through the lens of a LDO. This is not to say that a LDO will be made, because that decision can only be reached at the end of a detailed process which fully considers all of the material planning issues. Rather, the decision which has been taken results in efforts now being channelled into a particular process.

Notes on Local Development Order (LDO):

3.4 Making a LDO removes the need for a planning application to be made by a developer or landowner. In effect, the ‘permission’ is granted upfront by the making of the Order. A LDO is usually time limited, although it can be permanent. 

3.5 A LDO can apply to specific site or to a wider geography. It can also apply to a specific type or types of development. The benefit of a LDO is that provides certainty to a developer or landowner by defining what development is acceptable on a site and therefore, what can take place on a site without planning permission being required. LPAs can use LDOs to enable growth by positively and proactively shaping development in their area. LDOs can play an important role in incentivising development by simplifying the planning process and making the investment more attractive. 

3.6 It is important to note that a making a LDO does not obviate the need to meet the requirements of environmental legislation. The LPA is responsible for making sure that requirements under the Environment Impact Assessment Regulations and Habitats Regulations are satisfied. 

3.7 It is also important to note that in the same way conditions can be attached to a planning permission to make sure a development is acceptable in planning terms, conditions can be attached to a LDO. Conditions could cover the type(s) and scale(s) of the development permitted, require compliance with design criteria (such as a design code) or require actions to be undertaken prior to development, such as highways improvements. Attaching conditions ensures that the Order is robust and comprehensive as possible. 

3.8 A Section 106 Obligation cannot be required under aLDO, as the LDO constitutes the grant of planning permission. However, this does not prevent an obligation being offered by the developer and negotiated with the LPA, including in order to satisfy a condition of the LDO. Development may still be liable for Community Infrastructure Levy (CIL) monies depending on the land use permitted and the CIL charging schedules in place. 

3.9 Where development within the site of the LDO falls outside the scope of the Order, or the conditions attached to it, a planning application would need to be submitted in the normal way. 

What is the process for making a LDO? 

3.10 A simple summary of the process is outlined below: 

Stage 1 – LDO Preparation: the LPA prepares a draft of the Order and a statement of reasons which includes the description of the development to be permitted and a definition of the area it effects, together with the case for making the Order plus other supporting documents. 

Stage 2 – LDO Consultation and Publicity: the LPA consult on the Order. Consultation is undertaken with those that would have been notified/engaged with had a planning application been submitted. This includes local residents and statutory consultees. A site and press notice would be published. The draft Order, statement of reasons and other supporting documents would be made available for review online and in key, in person, locations. 

Stage 3 – Consideration of Representations: Following a review of the representations received, the LPA considers whether any revision is needed to the draft LDO and as a consequence, any re-consultation is needed. 

Stage 4 – LDO Adoption: the LDO is formally made by the LPA through a resolution to do so. The LDO (and all of its documentation) is sent to the Secretary of State and placed on the Planning Register. 

What is the role of Strategic Planning Committee in the LDO process? 

3.11 The Committee has an important role in the consideration and ultimate making of any LDO for this particular project. It is proposed to report to SPC at key milestones to seek agreement to progress to the next stage. 

3.12 The intended reporting intervals are as follows 

(SPC nos. 1 and 2 reflect the introductory briefing to the project on 20th April and the LDO process briefing on 8th June). 

Dates for these meetings are to be confirmed as the project progresses: 

SPC 3 Decision to be sought: agreement to begin informal consultation. Informal consultation would take place under the umbrella of Stage 1 described at paragraph 3.9 above. [? 3.10]

SPC 4 Briefing: Initial feedback on informal consultation 

SPC 5 Decision to be sought: agreement to begin formal consultation, as per Stage 2 at paragraph 3.9 [? 3.10] above. 

SPC 6 Briefing and Decision: feedback on formal consultation responses and decision on whether any modifications to the draft Order, and any re-consultation, is required. This falls under Stage 3 as described by paragraph 3.9 above. [? 3.10]

SPC 7 Decision to be sought: making of the LDO, as per Stage 4. 

3.13 For a report to be presented at the SPC 3 milestone, there is a considerable amount of further work needed. In seeking the Committee’s agreement to begin informal consultation, it will be important for Officers to be broadly comfortable that there is justification for pursuing matters via the LDO process. This will enable the recommendation to begin informal consultation to be made to the Committee.

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