Memorandum by Sefton Metropolitan Borough
Council (P 21)
OPPORTUNITIES AND DEVELOPMENT PROSPECTS AT
1.1 The Council's interest in and experience
of major port development stems from the fact that the main operational
area of the Port of Liverpool, including the Royal Seaforth Container
Terminal, lies within the Borough.
1.2 Over the past decade the Port has undergone
a period of rapid growth in trade, profitability and physical
development. There have undoubtedly been local economic development
and employment benefits arising from this. However, there is currently
a very strong perception in the communities adjacent to the Port,
shared by the Council Members representing these areas, that these
benefits have been outweighed by the adverse environmental impact
of Port-related activity.
1.3 These adverse impacts relate in particular
The noise, air pollution and safety
impacts of the large volumes of HGV movements generated on the
major road corridors through Bootle to the national motorway network.
All these corridors pass through residential areas experiencing
other forms of social and economic stress associated with inner
The environmental pollution arising
from port activity and related industries, especially as a result
of the recent growth of open storage of coal and scrap metal and
major food processing operations. This impacts particularly on
the residential neighbourhoods immediately adjacent to the Port
estate in the form of noise, dust, smells and visual intrusion.
The actual and potential threat to
coastal and estuarine habitats arising from Port operations. National
and international designations cover much of the Mersey Estuary,
and a proposed SSSI lies within the operational Port estate at
Seaforth. The protection of this site from Port development proposals
was a significant issue in the preparation of Sefton's UDP and
was eventually secured to the year 2000 through a Parliamentary
Undertaking by MDHC.
1.4 This perception of the balance between
the benefits and disbenefits of recent Port development has been
strongly influenced by the sharp decline in the traditional dock
employment that once provided jobs for many residents in the adjacent
communities. These communities experience some of the highest
unemployment rates in Merseyside. A recent long and bitter industrial
dispute has only served to polarise local sentiments.
1.5 This combination of circumstances has
coloured the Council's recent relationships with the Port authority,
the Mersey Docks and Harbour Company (MDHC). As indicated below,
the Council has been willing to support major development initiatives
that will assist the Port's contribution to regional and local
economic development. But it has not been re-assured by the Company's
approach to consultation and mitigation that it fully recognises
the impact of its operations on local communities.
1.6 On a positive note there is an increasing
number of examples of effective joint working between the Council
and MDHC on environmental management, transport policy, regeneration
projects, development planning and relations with the EU and regional
agencies. Reference is made to some of these in following paragraphs.
The current collaboration on the European Objective 1 programme
promises to be particularly productive.
1.7 The Council responded to the DETR invitation
to comment on the Outline Ports Policy paper in March 1999. Many
of the comments submitted then remain pertinent to the present
Inquiry, and the Council's response is appended to this Memorandum.
2. ECONOMIC CONTRIBUTION
2.1 The role of the Port of Liverpool as
a regional economic asset is recognised in the Regional Strategy
of the NWDA and in the draft Regional Planning Guidance for the
2.2 The Port's significance in the local
Merseyside and Sefton economy has been measured by a number of
studies. For example:
A study in 1996 by the University
of Liverpool, Department of Economics, concluded that the trading
activities of MDHC were associated with between 36,000 and 86,000
jobs in the Merseyside economy. Of these, up to 15,000 jobs were
classed as directly dependent.
A study recently completed to support
regeneration proposals for the Objective 1 programme concludes
that there is a cluster of some 200 businesses in the Bootle/North
Liverpool area which are directly or indirectly port related,
and which employ 3,000 to 3,500 people.
2.3 An important theme in Merseyside's Objective
1 Single Programming Document (SPD) for 2000-06 is to capitalise
on this asset to secure physical and economic regeneration and
environmental improvement. The Port hinterland is defined in the
SPD as one of the Strategic Spatial Development Areas (SSDA) which
will act as major drivers for economic development and employment
growth in the sub-region.
2.4 There is hard evidence on the ground
that the buoyant Port business can spin-off further development
and employment growth. For example, in 1995 Sefton Council, in
partnership with MDHC and with City Challenge and Objective 1
funding, approved a major expansion of the existing Freeport Zone.
This included a phased programme for the development of over 72,000
square metres of new warehousing. While the expectation was that
this would meet port-related needs for 10 years, two-thirds of
the warehousing was built and occupied within four years of development
2.5 The further opportunities arising from
the Port's dominant position in the rapidly growing Irish Sea
ferry trade is highlighted in Modern PortsA UK Policy (Case
Study 6, Annex 2).
2.6 It follows from the introductory comments
above, that a high priority in the future SSDA regeneration programme
will be measures to ensure that new employment is accessible to
local residents in the adjacent urban priority areas. This will
be achieved through targeted training programmes developed in
partnership with business, training agencies and community organisations.
Targeted public transport measures will improve physical accessibility.
2.7 One particularly interesting aspect
of these initiatives is the development of the concept of a "cluster"
of Port-related businesses. The essence of a cluster is that the
value of the whole exceeds the sum of its parts. The cluster is
characterised by horizontal competition and vertical co-operation.
Competition is essential to maintain the efficiency of the cluster
against competing clusters. Co-operation is essential to gain
synergy between firms. The cluster idea is increasingly being
embraced as a tool for economic development (Planning for Clusters,
DETR, June 2000). The port-related cluster of 200 firms in Sefton
is a sub-set of a Merseyside cluster related to the five other
dock areas in the sub-regionincluding Birkenhead (MDHC).
Tranmere Oil Terminal (MDHC), Garston (ABP), Eastham/Manchester
Ship Canal (Peel Holdings) and the Cammell Laird shipyard.
2.8 The realisation of this sub-regional
potentialunder the proposed title of "MerseyPort"
will require co-operation between a number of interests including
three port operators. Whilst it is not yet clear how far this
initiative will progress it may be of interest in view of the
specific reference to co-operation between ports in the terms
of reference of this Inquiry.
2.9 This wider economic role of ports is
not mentioned in Modern PortsA UK Policy. Apart from its
economic and physical developmental aspects, it raises issues
relevant to port management and external relations and to employment
and training. The coverage of the latter is particularly narrowly
focussed on dock work, whereas a modern port and it related cluster
of businesses generates a much wider range of employment opportunities
and skill needs. Port operators and government agencies need to
be aware of and plan for this potential.
3. PORTS POLICY
3.1 There are a number of helpful general
comments and proposals in Modern PortsA UK Policy. However,
the Council would wish to see some more specific measures emerging
along the lines set out in its March 1999 response (see Annex
The Council wishes to add to and reinforce these comments as follows.
Environmental management and safety
3.2 In paragraphs 5(d)-(h) of its March
1999 response, the Council made specific recommendations for the
strengthening of existing pollution control and public safety
regulations. These address specific port-related problems that
arise from the location of a wide variety of open storage, processing
and manufacturing activities within the dock estate, particularly
involving food products, coal and scrap metal.
3.3 The Council wishes to stress its belief
that an IPPC approach to regulating the combined effects of various
dock estate tenants, under a single Authorisation Regime issued
to the Dock Company, would assist all parties. This would set
estate boundary noise and pollution levels within which the estate
landlord could regulate its tenants by way of tenancy conditions
supported by an environmental management system. Such an approach
would ensure consistent regulatory control at all major ports.
It could help set acceptable environmental criteria to justify
the relocation of residents as part of community-led regeneration
3.4 In recent major development proposals
MDHC has been prepared to enter into agreements recognising the
need for environmental management of the impact of Port activities.
These have been in relation to specific proposals. The general
relevance of standard environmental management accreditation procedures
(EMAS, for example) would be worth exploring, and could be a requirement
of the Port Authority itself in relation to firms operating within
the dock Estate. The Council would therefore support the ideas
set out in 2.5.14 of Modern Ports.
3.5 The Council notes the initiatives by
the Health and Safety Commission referred to in paragraphs 4.1.11
and 4.1.20 and would welcome any proposals which would be likely
to improve the safety of residents living close to the Port. The
important criterion is that regulatory measures should address
the port estate as an integrated operation rather than a number
of separate businesses.
Planning and other regulatory controls over development
3.6 Paragraph 2.4.24 of Modern Ports suggests
that local planning authorities "believe that the existing
system of permitted development rights is broadly satisfactory".
Later paragraphs under the heading "Better Regulation"
refer to the powers devolved by Parliament to harbour authorities,
and the obligation that these should be used "openly and
3.7 It has to be said that these statements
do not adequately reflect Sefton Council's recent experience in
its dealings with the MDHC. Inadequate consultation with the community
has been one of the most divisive issues in this Council's recent
relationships with the Company. This is dealt with further below.
3.8 From the Council's perspective as planning
authority, the present system of permitted development rights
is far from satisfactory. From the way these rights have been
exercised the perception is that the GDO gives the Company the
right to implement development with little or no consultation.
On those occasions where consultation has taken place, there is
little evidence that representations from the Council or the local
community have been welcomed by the Company. It has required intense
local pressure to secure change.
3.9 The view of the local community and
their elected representatives is, therefore, that the Company
exercises its planning rights in its own interests alone. Based
on this experience, the Council believes that there must be an
element of compulsion in the duty to consult, either on individual
proposals or on a forward plan or programme of action.
3.10 Harbour Revision Orders can encompass
significant change with substantial environmental consequences.
Any proposals for simplifying the regulatory regime must redress
the balance between the rights of the Harbour authority and those
of the local communities on whom they impact. Consideration should
be given to the Human Rights aspects of the current permitted
development and harbour revision order regimes.
Protection of Natural Heritage
3.11 Port authorities are regarded as "relevant
authorities" for the purposes of The Habitats Regulations
and therefore will have direct responsibilities for securing compliance
with the Habitats Directive, including co-operation in the drawing-up
of schemes of management for sites within or adjacent to their
jurisdiction. In the case of MDHC this includes the Mersey Estuary
European Marine Site as well as the Alt and Ribble Estuary European
Marine site. Other Mersey Ports (eg ABP) will have similar responsibilities,
and have very recently been circulated with a package of information
from English Nature detailing their roles.
3.12 The implications of the Habitats Directive
for Ports have been explored in detail by Graham Rabbits of ABP.
While some aspects of his work remain controversial, his overall
approach is commended as a way forward for discussion among those
agencies involved in developing schemes of management for European
sites close to operational ports. It would help considerably if
port authorities with responsibilities for the same site (as in
the case of the Mersey) could adopt a uniform approach, and take
note of the work undertaken by ABP. Modern Ports (paragraphs 2.5.12-14)
does not deal adequately with this important role of Port Authorities.
It is mentioned only in passing in 2.5.23. It is essential Ports
recognise their role and co-operate with other agencies in carrying
out the requirements of the Directive.
3.13 The Directive will impact on the Ports'
own development proposals, and should be mentioned in section
3.2.8 of "Modern Ports". The ABP work on this is highly
relevant. It is also important that Government clarify for Port
Authorities the full implications of the Habitats Directive with
regard to offshore responsibilities.
3.14 The Council has observed with interest
the relationship between MDHC and Lancashire Wildlife Trust in
the management of a nature reserve within the Dock ESTATE
(THE Seaforth Reserve). The reserve
has recently been notified as a Site of Special Scientific Interest
by English Nature. Although the future of the reserve has been
highly insecure due to the long-term development proposals of
the Company, the support of LWT by the Company should be regarded
as an example of best practice.
Coastal Zone Management
3.15 This Council has a long-established
Coast Management Scheme. The partnership under which the scheme
works is currently under review and the Council would welcome
the involvement and co-operation of MDHC because of its importance
for the management and the economy of the coast.
3.16 The council also participates in the
Mersey Strategy and would stress that more active involvement
of the Port Authorities in the Strategy would be of considerable
benefit. Co-operation in coast and estuary management initiatives
would help Ports carry out their duties under the Habitats Directive
noted above, for example. The presence of Ports as active partners
would add weight to the Strategy and would help raise awareness
of the economic role of the Ports and the estuary on which they
are situated. In this respect the Council would strongly endorse
the statement under this heading in Modern Ports (paragraphs 2.5.25-28).
3.17 It should be noted that the Mersey
Strategy is currently co-operating with French, Dutch and Irish
port cities in an Interreg IIc project reviewing environmental
issues raised by the presence of major ports in coastal cities.
It is likely a short submission will be made to the Inquiry by
the Mersey Strategy.
Oil Pollution response
3.18 The Mersey Ports have worked with local
oil companies in developing a local contingency plan for dealing
with pollution incidents. From this Council's perspective, while
it is indeed important to have national plans in place to deal
with major incidents, there is equally a need for effective local
contingency plans to cope with the continuing large number of
minor incidents. Many of these "local" incidents are
in fact large enough to affect local beaches and the local tourism
economy. It is also essential that these plans take into account
the correct practices for remediating oil spills in areas of high
nature conservation vale. Section 4.5 of Modern Ports does not
stress sufficiently the need for the co-operation of a number
of agencies in dealing with a local incident in a large estuary,
and the need for effective local contingency plans to be developed
Port Waste and Marine Pollution
3.19 The effect of marine litter on the
Sefton and Merseyside coastline is significant, and puts a large
burden of cost on the Council to maintain its popular beaches
in reasonable condition. The effectiveness of the Ports' waste
reception arrangements are therefore of great concern. The Council
accepts however that this is only part of the equation, and that
further action needs to be taken under the MARPOL Convention.
The council would strongly support the identification of the Eastern
Irish Sea as an area of special control under this convention.
The implications of such designations are not dealt with in Section
4.6 of Modern Ports. The Council would strongly support the work
of the Marine Pollution Advisory Group in its view that UK waters
should be declared a special area in terms of marine environmental
3.20 The Port of Liverpool has a direct
rail connection via the Bootle freight line from the Seaforth
inter-modal terminal to the West Coast Main Line at Edge Hill,
Liverpool. The MDHC have taken a positive approach to the movement
of freight by rail, and some two million tonnes is now carried
by rail to UK and European destinations. This includes significant
volumes of coal.
3.21 This rail traffic could be significantly
increased by integrated land use and transportation planning.
Following a Merseyside-wide Freight Study, proposals to encourage
the greatest possible shift from road to rail are included in
the Merseyside Local Transport Plan and in our emerging regeneration
plans and Unitary Development Plan reviews. However, the success
of these measures is ultimately dependent on the success of Government
policy to promote and invest in rail freight.
3.22 As a member of the Piggyback Consortium
and its successor, the Rail Freight Group, the Council has lobbied
for the enhancement of the freight railway gauge to encourage
more long-haul traffic onto rail through "piggyback"
(the W11 gauge) or at least to capture the growing number of high
cube 9'6" containers (the W10 gauge). We have costed the
gauge enhancement and track renewal work required in Merseyside
and are promoting this through the Objective 1 programme and through
the Strategic Rail Authority.
3.23 The Council is, therefore, generally
happy with the content of Section 2.6 of Modern Ports in this
respect. The Government's commitment in Transport 2010: The Ten
Year Plan, and the role of the SRA in delivering this, represents
a significant advance on the previous Railtrack Network Management
Statements. We are particularly encouraged by the priority the
SRA is attaching to upgrading Port rail connections, and would
welcome an early commitment to the proposals outlined above when
it publishes its long-awaited Freight Strategy.
3.24 However, the full environmental benefits
of rail freight for port communities will only be realised if
the operating companies also invest in new locomotives and rolling
stock which produce less noise and fumes.
3.25 It is accepted that the railways will
generally only be competitive with road haulage over long distances
(generally over 200km). The Council recognises that a sustainable
transport strategy for a growing port must include investment
in the strategic highway network. This must address not just the
congestion issues referred to in paragraph 2.6.16 of Modern Ports
but also the environmental impact of HGV traffic on the local
community. For example, plans to improve strategic road access
to the port must take into account the fact that the two main
routes pass through residential communities and close to numerous
primary and secondary schools. The evidence of a possible link
between high levels of child respiratory illness and road traffic
in these communities is a further cause of concern. Solutions
to both the congestion and environmental problems will not come
cheaply: they will involve major capital investment and innovative
traffic management. Most importantly, they will require an effective
partnership involving the Council and local community, the Highways
Agency, the road haulage industry and the MDHC.
The Port and the Community
3.26 It is appropriate that the Council's
evidence should conclude on this most important subject. Paragraph
3.1.2 of Modern Ports says that, "ports should add value
to their communities and to the wider economy". The Council
endorses that statement.
3.27 In paragraph 3.1.5 it goes on to say
that, "shareholders increasingly look not only at financial
performance but also at companies' relationships with local communities
and the environmental impact of their operations". It will
be clear from earlier comments that, in the Council's experience,
this interest has not always been evident in the MDHC's past approach
to major development proposals. Ports are businesses operating
in a highly competitive environment. From the community perspective,
the overriding concern is to maximise throughput and activity
and minimise costs.
3.28 Whilst the Council is interested in
the initiative proposed by the Government, in paragraph 3.1.5,
to develop good practice guidance and standards for accountability,
it is sceptical that an entirely voluntary code will suffice.
However, the Council would welcome the opportunity to contribute.
The joint groups referred to should include elected representatives
from local government. It is not clear where community relations
and environmental awareness would lie within the four areas of
3.29 In paragraph 5(i) of its March 1999
response the Council referred to the need locally for improved
liaison between the regulatory bodies, the Port and its neighbours,
including the local community.
3.30 Despite the concerns expressed in this
evidence, the Council agrees with the comments in paragraph 3.1.6,
and in particular that "there is scope for a new productive
relationship between ports and their local authorities".
For example, the Council's recent experience is that the MDHC's
active involvement in regeneration partnerships can be very productive.
The Company is currently represented at Board Director level on
the Steering Group that is preparing the Objective 1 SSDA strategy
referred to above. The Council is hopeful, therefore, that with
the Company's co-operation it will be possible to build on these
positive developments to ensure that mutual understanding and
openness become the norm in all aspects of the relationship.
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