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Examples of Objections to Use

A selection of examples to use in your objection have been provided here.  If you use any objections from the list provided, please use your own words to avoid planners classing your reasons as duplications.

You may have your own, or may wish to add more to this list.  


If the planning officers see duplication, your objection may be not be considered or counted
Examples of Objections to Use 

1. Use of a Local Development Order

The whole application process is unsatisfactory. We do not believe that it is acceptable to use LDOs for development on Green Belt land, and the process seems to be leading to the application being subject to less scrutiny. (We are not sure whether this is due to the LDO process itself, or the council’s misuse of it, since the council has hardly any experience of LDOs – the only previous use of one was to put benches in the local market square!). Residents have had a great deal of difficulty in communicating with the council about the proposal, as the council’s view is that information will not be available until the Consultation stage, so residents have not had enough time to get to understand this complex proposal.

The way this process is being handled is contrary to local government guidance: ‘A fundamental component of delivering and developing a LDO is to ensure that there is effective engagement with all relevant stakeholders.’ (Guidance to councils on Preparing LDOs section 3.3).

We get the distinct impression that the council gave the go-ahead for this proposal first and then tried to think of justifications for it afterwards (other than the financial benefits to the borough). Council leaders rely almost entirely on officers when asked detailed questions about data centres, suggesting that it is the financial benefits that are uppermost in the councillors’ minds. Again, local government guidance says: ‘It is imperative that LPAs are clear from the outset what the issue, or opportunity, is that they are seeking to address in an area, or on a site, through the use of a LDO’ (our emphasis). Any ‘benefits’ will accrue to the borough and not to the local area. Residents feel they are ‘expendable’, and that the council leadership has no real knowledge of the existing ecology and biodiversity in North Ockendon, and no concern for the well-being of its residents.

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

The environmentalist George Monbiot has said we may use his name in support of our objections.

Given all these issues, and the complexity and novelty of the LDO process, we have contacted the Environmental Law Foundation, and a Barrister has started to advise us, pro bono, on the handling of this case.  

2. Protect Metropolitan Green Bent Land

The planned data centre is to be sited on 490 hectares (figures given vary) of Green Belt land in North Ockendon, which is still being used for agriculture (wheat, barley etc).  At the time of writing, we still do not know what the ‘Very Special Circumstances’ or 'exceptional circumstances' are, which have to be defined, to justify the destruction of Green Belt land.  (* see also footnote).

In another recent planning application (a Battery Electrical Storage Site in Cranham) a vague argument was used to say that ensuring a reliable provision of electricity was enough justification for building on Green Belt land. We are contesting this, through formal complaints. A similar argument may be used over the data centre, and we would reject it even more strongly (the data centre does not supply electricity!). Another argument that has been used is that data centres are ‘national infrastructure’ – we reject this as a justification for building data centres, and we do not accept that this point justifies building on Green Belt Land.

3. Purpose of the Green Belt

Green Belt land is supposed to be characterised by its ‘openness’, but the 12-15 buildings on the site will be very high (15, 21 metres) and each be enclosed by 16-metre fencing. It also exists to prevent ‘urban sprawl’ – and yet, in our area there are a number of developments that will increasingly encroach on the openness of the countryside (Lower Thames Crossing, housing developments etc –see above).

4. Unbalanced Benefits Information Peddled to the Public

When the Council leadership has described the benefits of the data centre (and the leadership is strongly in favour of it), they have put these in such a way that they would go to Havering, and not the local community. The leader has spoken of ‘The reputation of Havering’, and that this would be ‘a catalyst for other businesses.’ These ‘other businesses’ (and jobs – see above) would clearly not be in North Ockendon, which is a historic village.  How, then, is this a ‘Local Development’?

Substantial business rates are also cited as a benefit, given that Havering is short of money, and we suspect that this is the primary motivation of the council leadership. However, the developers are not able to use this (financial gain) as an argument in the planning application.

5. Incorrect Location for a Data Centre

We do not accept that the proposed Data Centre is an ‘exceptional’ case such as to justify the damage to the natural environment. The site is currently very open green space, and it is extensive, with crops, established hedges and old trees. There is a SINC (site of interest for nature conservation) on the site, several SINCs nearby, and it is next to a conservation area. This is the wrong site for such a development. We are not ‘luddites’ and we do not oppose data centres as such, but their siting and planning needs regulation.

6. Detrimental Impacts on Wildlife

There is extensive wildlife in the area – badgers, foxes, 60-70 different species of birds, and frogs and newts in the ponds, etc. We are preparing lists of species that are important, rare, or vulnerable, but will be threatened by building an enormous data centre. Extensive building works going on for 8-10 years (the developer’s estimate) will disrupt wildlife, and once driven away it is unlikely to return. 

7. Misleading Representation of the connected EcoPark

It is proposed, in ‘mitigation’ that there will be an ‘ecology park.’ This will cover an area which is existing green belt land, but which is inaccessible by public transport. The environmental damage from cars – supposing people will want to travel out to the site to see the ‘park’, which we consider unlikely! – will be very damaging.

8. Ecology Mitigation Flaws Does Not Protect Nature

Part of the ‘park’ describes land around the perimeter of the buildings, which will have been grassed over after the construction phase and turned into paths. Is it really likely that people will want to take a stroll around 21-metre-high buildings?! It is said that whips will be planted as ‘screening’, but these, of course, will take many years to grow into mature trees. This also shows a complete lack of understanding of ecology and the workings of ecosystems.  Ecosystems are built up over sometimes hundreds of years, and cannot be replaced in a matter of weeks. Destroying established hedges would also cause irreparable harm to wildlife and biodiversity. The claim of 100% net biodiversity gain, which Digital Reef maintains, is unreal. (Current government guidance on these issues is, we believe, harmful to the protection of nature.)

9. A Precedent Will Be Set to Destroy More Green Belt

Such a huge development on Green Belt land would set a precedent and could lead to other industrial developments in the area. North Ockendon is the only part of London that sits outside the M25 – it is quiet and very green (see above).

10. Too Close to Other Environmentally Detrimental Sites/Works

The site is not that far from the Lower Thames Crossing development, and there are proposals for battery storage buildings in the area. It is downwind from Launders Lane where there is a serious air pollution problem. Altogether, these developments could be seen as urban sprawl, which – again – destroys the green belt.

There are also major developments very close, across the border into Essex.  These Authorities do not take these into account in their considerations.

11. Impacts on Local Roads and Travel

Constructing the data centre will take, we are told, 8-10 years. The impact on the local area of hundreds of workers travelling to and from the site, not to mention dust and fumes from building works, will have a harmful effect on local residents. Local roads are narrow, and traffic already has difficulty when a large vehicle is involved.

12. Jobs and the Local Economy

The claim that the proposed centre would create 2,800 jobs is misleading, as most of these will be construction workers during the 10-year (!) construction period. When the centre is operational, only a small number of staff (approximately 100, divided between management, security and operational) will be required, and we question how many of these jobs will be suitable for local people.

The vast majority of those construction workers will be from outside of the area, with a need for additional rental accommodation, potentially pushing up local rents for local people.

13. Visual impact Will Be Detrimental To The Surrounding Area

The plan is for fifteen warehouse-sized buildings up to 21 metres tall, surrounded by 6 metre tall security fences. There will also be generators, cables etc. There will be extra equipment on the roofs of the buildings. It is said that bunds (earth mounds, covered in grass) will be used for screening, but bunds are unsightly, and there is no way they would hide 21-metre tall buildings! The bunds will also be planted with whips, which will take many years to be effective as any kind of visual barrier.

14. Noise Pollution

Data centres produce a constant 24-hour hum, which has been known to cause stress and damage to health in the US. Noise regulations are probably not sufficient to deal with this as they only refer to decibel levels (I believe_, and to ‘vibration’, not ‘humming’. The documents will need careful scrutiny on this point.

15. Benefits for Big Corporate, Not Local People

The benefits will be primarily to companies (Amazon, Google et al) 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. What will happen to the electronics/computers etc then? Also, once the land has been built on, will it still count as green belt?

16. Dangers of Development Links with Freeport and Finances

There has been mention of linking up with ‘freeports’ or even that this centre will be classified as a freeport. Freeports are notorious for being free of environmental and financial regulations and are designed primarily to increase the generation of money and profit. Even if this is no longer argued, it indicates to us the underlying motives of the council.

17. Data Centres Contribute To Global Warming

Data centres contribute to global warming by producing CO2. In fact, globally, they already produce more CO2 than aircraft do, and it is anticipated that the number of data centres will increase significantly (possibly by a factor of 3) in the next 10 years, so this problem will only get worse.

18. Electricity Consumption

A data centre can consume as much electricity as 50,000 homes.

However, a 600mw data centre uses enough to power 375,000 homes or 2.4million electric cars annually*

It is unlikely that the proposed data centre will get all its electricity from a renewable source, given the massive amount it will use. Claims that the data centre will be ‘green’ are misleading. It is not clear whether the grid can support this demand. Increasingly, nationwide, there is conflict between supplying data centres with electricity, and supplying homes.

19. Cooling The Data Centre

Air conditioning is essential in these centres as they produce a lot of heat. It is likely that 40% of the electricity used will be for air conditioning. Back-up generators will be needed in case the electricity supply breaks down – will these be diesel, and therefore polluting?

20. Water Usage

Most data centres use vast quantities of water for cooling. There are already complaints in this country, and across the world, that data centres are causing water shortages. It is unclear where this data centre will acquire water. Local residents already complain of not having an adequate supply!

21. Water Supply and Demand

How will the demand for water, and the necessary output of water once it has been used for cooling, impact on the river Mardyke, and the fen country (one of the few such areas in London) which is nearby? Recently we have been told the cooling will be done chemically, and this raises safety and pollution issues.

22. Flooding

The whole area is low-lying, and much of it is subject to flooding. With the building of a large number of large warehouse-type structures, the ground will lose its ability to absorb rainwater (and we will be getting more rain in future because of global warming!), leading to run-off and flooding problems. The very low-lying land to the east of the area (where the ‘ecology park’ will be?) is the only Fen land in London and is ecologically extremely valuable.

23. Loss of Farmland versus Smaller Vertical Greenhouses

Given the huge amount of heat that will be generated, (and data centres are often built in countries such as Finland or Iceland to make cooling easier) it is said the heat will be used to grow produce such as aubergines and avocados, but there is no word of whether or how this will be sufficient to cool the plant. We do not see how a greenhouse can produce enough crops to replace four farms currently producing wheat. We have not been able to find out what kind of financial incentives the current landowners have been offered, but we know that some of the largest and wealthiest companies in the world (Amazon, Google etc) are likely to be the clients to whom the space is offered when the centre is built…  

 

24. Battery Storage Risks

There will be 50,000 square meters of batteries.  We have seen explosions and fires at similar sites (near Heathrow) – there must be a danger of fire in a data centre that stores batteries. Batteries and computers use rare metals – so what implications are there for the mining of rare metals, lead etc? It is claimed that the site will produce green energy, but we are not at all convinced of this

25. Lifetime of a Data Centre and Waste

It is also likely that the centre will only have a lifetime of 10-15 years. Thereafter a large quantity of electronic waste will have to be dealt with, and this is already proving problematic around the world.

26. Property Values

Residents are already concerned about loss of value to their property, on top of the likely impact of noise, dust and security lights. However, this may not be justifiable as an objection, apparently…

27. Havering Residents' Association Reneged on Protecting the Green Belt

Residents are particularly upset that the council is led by the Residents’ Association which promised (e.g. in the 5-year plan for Havering) ‘protecting and enhancing the Green Belt and Havering’s open spaces and ecological assets.’

28. No Ward Councillor Engagement

The three local councillors – Havering Residents’ Association, Upminster Ward – have been totally uncooperative in responding to residents’ requests for meetings (see above also). The councillors are falling back on the line we have heard over and over, that ‘there is no information available until the LDO is published’.

29. Listed Building Destruction - LDO

Development should not interfere with listed buildings. There was a Grade II listed building on the site, but it was allowed to deteriorate over the years. We now find that it was de-listed in 2022, at about the time Digital Reef first proposed this development. We are highly suspicious that this is not just a coincidence and will continue to try to get to the bottom of it.

30. Development Credentials and Expertise

We have serious doubts about the developer Digital Reef, and we are not convinced that they know what they are doing, especially given recent issues over preliminary ‘survey’ work (digging and drilling) which took place without the developer informing the LPA, and which was illegally close to active badger setts. We also find it extraordinary that the Local Planning Authority says it has no need to look into the financial viability – or even the probity – of the prospective developer!

* Source: International Energy Agency

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