Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

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 outcomes.

  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 development.

  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 region"

    —  "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 sustainability."

  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 Strategy chapter.

  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 designations;

    —  tourism.

  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 EU—and to do this in a more sustainable manner through increased use of short sea and rail transport."

  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.


  3.01  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 future developments.

  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 Objective 1)

    —  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.


  4.01  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 and uncertainties.


  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.


  6.01  A range of potential social consequences arises from SAC designation. These are mainly associated with:

    —  loss of trade by local businesses—especially the ports and related operations—leading 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 include:

    —  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 growth;

    —  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 Nature.

  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.

January 2001


  1.  Regional Economic Strategy— regstrat.asp.

  2.  Humber Trade Zone Initiative: Aims, Objectives and Strategies (July 2000).

  3.  Regional Planning Guidance— regstrat.asp.

  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 Humber.

  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 for Development.

  9.  Enviros (September 2000) Developing a Programme to Accelerate Sustainability in the Humberside Region, UK.

  10.  South Humber Bank Industrial Area Development Brief 1999.

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