Memorandum by Yorkshire Forward (P 32)|
1.01 While Yorkshire Forward has a wide
concern with the development of economic opportunities at major
ports, in this submission we wish specifically to address aspects
of the Sub-committee's second bullet point, namely "what
problems and opportunities currently face such ports, particularly
with respect to cooperation with each other, safety, the environment,
and regulation"particularly referring to environment
and regulation and the proper management of the process of negotiation
between government agencies and stakeholders to achieve sustainable
1.02 Our immediate interest relates to the
current consultation process on the EU Habitats Directive: Natura
2000, on the selection of potential Special Areas of Conservation
(SAC). We wish to ensure that the economic viability of the region
is maintained by the possibly adverse impacts of SAC designation
on Humber Estuary ports, and other local industry and businesses,
being taken properly into account.
1.03 Yorkshire Forward, and our partners
in the Humber Trade Zone (HTZ) including the four local authorities
and the Humber Forum, has reviewed the proposals for SAC designation
of the Humber Estuary put forward by English Nature (EN). EN's
consultation letter of 15 September 2000 (attached in hard copy
bundle) states that the first phase in the selection and submission
of candidate SACs may only take account of scientific criteria.
We further understand that the Habitats Directive acknowledges
the need to take account of economic, social, cultural and regional
issues in the context of the general objective of sustainable
1.04 A separate consultation exercise on
the SAC designation was carried out by the Department for Environment,
Transport and the Regions, to meet Ministers' expressed wish to
be aware of the possible consequences on selected sites of economic,
social and cultural requirements, and regional and local characteristics.
1.05 We understand that ABP (Associated
British Ports) who are partners in the HTZ are submitting evidence
to the Sub-committee Inquiry which deals inter alia with questions
about the scientific basis on which EN have approached the consultation
and aspects of the interpretation of the Port of Bristol case.
Yorkshire Forward confines its interest in this submission to
the Sub-committee to the non-scientific issues.
1.06 Yorkshire Forward's concern is that
there is a lack of clarity about whether the Commission or Member
States expect to take economic and social factors into account
in determining SAC designations, particularly after the recent
ruling on the Port of Bristol case in the European Court. This
memorandum of evidence, therefore, seeks to draw the Sub-committee's
attention to some of the procedural, practical and perceived implications
of the SAC designation and the process leading to it. We hope
this will assist the Sub-committee in forming a view about the
potential implications of environmental designations on development
prospects at major ports and on where modifications may be sought
to maintain economic and environmental opportunities and concerns
in sustainable balance.
2.01 The Regional Economic Strategy (RES)
for Yorkshire and the Humber identifies the Humber Estuary as
an area with major growth potential, which will make a "vital
contribution to the strategic economic development and regeneration
of the region." Improving access to the area through sustainable
transport, including increased use of the waterways and rail,
is an important element in the Strategy.
2.02 Regional Planning Guidance (RPG) already
provides a framework to encourage sustainable development in the
context of the government's four central objectives. Both the
RES and RPG have been subjected to independent sustainability
appraisals which conclude that:
"the RES lays a good basis for
moving towards a more sustainable future . . .It recognises the
importance of environmental quality as a foundation for a successful
"the draft RPG provides an appropriate
framework for delivering sustainable development in the region
. . .The draft RPG as a whole makes a significant move towards
The Humber Estuary Management Scheme (HEMS),
which takes account of environmental sensitivities, also recognises
the environmental significance of the Humber.
2.03 A specific initiative, the Humber Trade
Zone (HTZ), has been established by Yorkshire Forward, together
with our local partners, to address the lack of employment opportunities
in the area and the serious social and economic deprivation. A
copy of the HTZ Initiative Executive Summary is included. These
structural weaknesses in the local economy have been recognised
by the EU Structural Funds Objective 2 designation.
2.04 The aim of the HTZ Initiative is to:
"exploit the current and potential assets
of the Humber ports and estuary for the greater wealth of the
UK whilst ensuring that the benefits of this exploitation are
specifically captured in the Humber sub-region and the wider Yorkshire
and Humber region."
In other words, the objective is to place the
Humber at the centre of the sub-regional economy.
2.05 The Panel Report on draft RPG, which
was issued in October 2000, emphasises the importance of the HTZ
through policy revision. It recommends that the HTZ be identified
as one of three regionally significant locations in the Spatial
The Panel response also recommends clearer guidance
for Local Authorities at the sub-regional level, to assist in
the preparation of development plans. Suggestions for guidance
includes details on:
role of the Humber Trade Zone;
importance of the deep water resources
of the Humber, and as a gateway to the Region;
importance of maritime Heritage and
marine archaeology, as well as international nature conservation
2.06 The importance of the Humber is also
recognised through the North European Trade Axis, which is a £2,250,000
European project. The NETA corridor is a trans-national initiative
linking Ireland, Northern England, the Netherlands and Germany.
The UK section comprises the Trans-Pennine axis, which includes
the Humber ports. One of the key objectives of NETA is to:
"Enhance significantly trade and prosperity
along this west-east corridor as both an alternative to the traditional
north-south orientation of the EUand to do this in a more
sustainable manner through increased use of short sea and rail
2.07 The Humber Estuary is of strategic
importance to the region being a major trade route, with about
12 per cent of total UK trade passing through Kingston-upon-Hull,
Grimsby and Immingham and the associated Trent ports further inland.
It is forecast that imports and exports will grow by approximately
40 per cent in the next ten years within the Humber Trade Zone.
The Humber Ports and related activities are estimated to support
about 40,000 jobs in the area.
2.08 We are concerned that the SAC designation,
as currently envisaged, may impose severe constraints on the HTZ
initiative particularly in relation to key components such as
the urgent need to created employment opportunities, better utilisation
of the Humber Ports, improved communications and infrastructure
and the provision of serviced land.
2.09 We recognise that the SAC designation
could bring some benefits to the area eg in terms of enhanced
environmental image and a potential increase in eco-tourism and
related businesses. It would also provide an opportunity to demonstrate
how local industry and commerce can work effectively side-by-side
with nature conservation. However, these benefits are likely to
be small in comparison with the potential negative impacts on
the economic and social fabric of the area.
3. EXISTING BUSINESS
3.01 The proposed SAC designation for the
Humber Estuary is considerably more extensive in its coverage
than the existing Special Protection Areas and Sites of Special
Scientific Interest. In geographic terms, only the areas immediately
outside the docks at Grimsby, Immingham and Kingston-upon-Hull
are excluded from the SAC, otherwise the whole of the Humber Estuary
is included. In addition, the SACs are broader in terms of including
priority habitats for a wider species of birds, flora and fauna.
3.02 SAC designation requires all unimplemented
planning permissions relating to the designated area to be reviewed
and more detailed Environmental Impact Assessments to be undertaken
in many cases. This would place a major burden on the planning
process in the area and on existing operations, as well as constraining
The cost and delay implicit in these requirements
could conflict with the strategic RES objectives:
To grow the region's businesses in
the key economic sectors to create a radical improvement in their
competitiveness and contribution to the region's wealth. (Strategic
To achieve higher business birth
and survival rates to create radical improvement in the number
of new, competitive business that last. (Strategic Objective 2).
3.03 The SAC designation is of particular
concern to existing businesses in the Humber ports and to the
port operators themselves. The smaller port-related operations
are deeply concerned about its impact on their future development
plans and are worried about lack of resources to undertake the
Appropriate Assessments required under the Habitats Directive
or to implement possible mitigation measures.
3.04 It is believed that the Humber is the
only major North West European port that faces a situation where
European Marine Site designations include the navigational channels
or any major working port area. The designation would, therefore,
place the Humber ports at a competitive disadvantage compared
to other comparable ports in the UK and on the Continent. Furthermore.
It will impact on the potential expansion plans of the existing
ports with the danger that new terminals may be located in sub-optimal
locations resulting in more road transport. The port operators
are already working proactively with environmental design specialists
to ensure best practical outcomes.
3.05 The impact on the other business sectors
in the area could be significant. For example, there are over
100 chemical companies in the Humber sub-region employing more
than 10,000 people with a gross value added (GVA) of about £800
million per annum. There is a significant concentration of such
companies on the South Humber bank and close to the Port of Hull.
The existing operations and future development of these companies
would be affected by the SAC designation where discharges are
made into the Humber estuary and river system. These companies
are operating in highly competitive global markets and any additional
costs and/or time delays would place them at a competitive disadvantage
when site rationalisation and/or development is being considered
by their multi-national parents. It would also affect smaller,
speciality chemical companies, which have limited resources and
time to address such issues.
3.06 Overall, the ports and the chemicals
and related industries are the major drivers of the local economy
and there would be serious consequences if the future of these
sectors were jeopardised by the introduction of the SAC designation
without modification to reflect the economic realities of the
Humber. A critical element of the HTZ is the expansion of the
Humber's existing businesses, an element that is already undermined
by the perception of the impact of SAC designation and the lack
of assurances about its practical implementation.
4. INWARD INVESTMENT
4.01 The attraction of strategic inward
investment to the HTZ area is a major objective of the RES, to
address the structural weaknesses of the sub-regional economy.
A wide range of target sectors have been identified in the recent
pilot study "Developing a Programme to Accelerate Sustainability
in the Humberside Region", including chemicals, food, timber
products, paper, metals and glass. This builds on the existing
infrastructure and logistical strengths of the area, including
the port facilities, as well as proposed new developments such
as the refinery, CHP plant and the Humber Bundle. In the chemicals
sector, for example, a number of strategic investment targets
have been identified which could create 2,400 jobs and £800
million per year in gross output.
4.02 A wide range of industrial sites have
been identified for development to stimulate inward investment,
including over 1,000 hectares on the South Bank. It is estimated
that this could result in the creation of over 28,000 jobs overall.
Much of this development is adjoining or close to the proposed
SAC areas and within the 2 km zone. Current thinking indicates
that the South Bank offers the only potential location for appropriate
deep-water port activity essential for present and forthcoming
generations of bulk carriers.
4.03 All these developments would be affected
by the SAC designation, particularly in terms of the delays and
costs involved in undertaking the Appropriate Assessments. The
market for such investments is very competitive. There is real
concern that the HTZ area would be placed at a significant disadvantage
compared with competing locations in the UK and Europe. This is
critical in the light of the very tight timescales to attract
mobile investment and the extent to which investors quickly and
decisively screen out locations that are associated with risks
5. WIDER ENVIRONMENTAL
5.01 The impact of the SAC designation of
the Humber on the wider environment should also be taken into
consideration. The Humber is the most important port on the east
coast of the UK for traffic from the heart of England to designations
in Northern Europe and the Baltic. If further development of the
port is limited by the SAC designation, the amount of north-south
road traffic between the Humber and the East coast and channel
ports will grow. This will increase pressure on roads such as
the A1 and the M1, which are already running near to capacity.
5.02 The increased road traffic will also
cause carbon dioxide and other emissions to rise which will adversely
affect the greenhouse gas emission reduction targets set by the
RES and the Government. In addition, road congestion in other
parts of the country eg the southeast will worsen.
6. SOCIAL CONSEQUENCES
6.01 A range of potential social consequences
arises from SAC designation. These are mainly associated with:
loss of trade by local businessesespecially
the ports and related operationsleading to increased unemployment
and social exclusion;
not realising the full development
potential of the area resulting in a failure to create as many
new jobs (direct and indirect) as planned with the consequent
impacts on the social and cultural activities in the area;
the social costs of redeployment
of staff elsewhere in the UK due to loss of trade/business and
even site closures;
long term outward migration if the
economy is affected by its peripheral location.
7.01 Sustainable transport is a key policy
area in Regional Planning Guidance for Yorkshire and the Humber.
The policy to encourage the use of sustainable alternatives to
road freight (particularly rail and water) is identified as having
a major positive long-term impact in the RPG sustainability appraisal.
The European Commission is also taking steps to encourage inland
transport by water to reduce stress on land infrastructure. The
SAC designation could lead to restrictions in the implementation
of sustainable transport initiatives especially associated with
river traffic. This is important to this Region since a large
number of freight waterways are linked into the Humber.
7.02 Yorkshire Forward, at Government's
request, has recently identified the six economic transport priorities
for the Region, endorsed by the Regional Chamber. These priorities
utilisation of the potential of the
Humber ports and the Regions waterways to complement the Humber
Trade Zone as a specific area of integrated, sustainable economic
development of the Transpennine Link
to provide a viable trade and passenger link from Ireland, across
the north of England to Rotterdam and the rest of Europe, with
reduced journey times and increased capacity. It provides a key
alternative to the congested and difficult links via the South
East as well as tackling inter/intra regional constraints across
the Pennines and to the important Humber ports.
7.03 The Trans European Network initiative,
which aims to stimulate sustainable growth and competitiveness
within the Single Market with improvements in infrastructure,
should also be taken into account. One of the objectives in the
UK is to take pressure off north-south routes by stimulating more
west-east traffic and to increase intermodal transport methods
eg including rail and waterways. The Humber estuary and ports
provide a key link into Europe in this context.
8.01 There are real concerns regarding the
implementation of SAC designation, particularly in the selection
of schemes for assessment and the scope and content of an Appropriate
Assessment that, we understand, will be decided on a case-by-case
basis. This raises issues concerning the transparency of the process
and the relationships between the local authorities and English
8.02 The Humber Estuary experience suggests
that a more informed and open dialogue is required between stakeholders,
such as those represented within the partnership of the HTZ, and
the DETR, English Nature and the Environment Agency.
9.01 Yorkshire Forward would be pleased
to explore the issues raised in this memorandum in oral evidence
to the Sub-committee. We would also be pleased to assist in facilitating
a visit by the Sub-committee to the Humber ports.
1. Regional Economic Strategyhttp://www.rayh.gov.uk/regbod/regbod
2. Humber Trade Zone Initiative: Aims, Objectives
and Strategies (July 2000).
3. Regional Planning Guidancehttp://www.rayh.gov.uk/regbod/regbod
4. ECOTEC Research Consulting in association
with Land Use Consultants (October 1999) Sustainability Appraisal
of the Regional Economic Strategy for Yorkshire and Humber.
5. ECOTEC Research Consulting in association
with Land Use Consultants (October 1999) Sustainability Appraisal
of the Draft Regional Planning Guidance for Yorkshire and the
6. Environment Agency (September 2000) The
Humber Estuary Shoreline Management Plan.
7. DTZ Pieda Consulting (August 2000) Humber
Estuary Property Market Study.
8. Ecoscope Applied Ecologists (October
2000) Ecoscope Report, SAC/SPA Review of Legislation and Implications
9. Enviros (September 2000) Developing a
Programme to Accelerate Sustainability in the Humberside Region,
10. South Humber Bank Industrial Area Development