EAST MIDLANDS GATEWAY STRATEGIC RAIL FREIGHT INTERCHANGE ORDER 201X INFRASTRUCTURE PLANNING (EXAMINATION PROCEDURE) RULES 2010 APPLICATION BY ROXHILL (KEGWORTH) LIMITED FOR AN ORDER GRANTING DEVELOPMENT CONSENT FOR THE EAST MIDLANDS GATEWAY RAIL FREIGHT INTERCHANGE Proposals Including Rail Freight Interchange, Warehousing and Highway Works on Land in the Vicinity of Junction 24 of the M1 Motorway to the North of East Midlands Airport, South of Lockington and Hemington and to the East of Castle Donington.

LOCAL IMPACT REPORT ON BEHALF OF DERBYSHIRE COUNTY COUNCIL PLANNING INSPECTORATE APPLICATION REFERENCE TR050002 Interested Party Reference Number EMG: SP031

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1 Introduction

1.1 This document is Derbyshire County Council’s (DCC) Local Impact Report (LIP) on the Development Consent Order (DCO) application by Roxhill (Kegworth) Limited (RKL) for the development of a strategic rail freight interchange (SRFI), warehousing and highway works on land in the vicinity of Junction 24 of the M1 motorway to the north of East Midlands Airport, south of Lockington and Hemington and to the east of Castle Donington. The scheme is known as the East Midlands Gateway (EMG). The LIR should be read in conjunction with DCC’s main Written Representations and Written Representations Summary, which have also been submitted on the DCO application. The LIR has been prepared in the context of the requirements of the National Policy Statement on National Networks (NPSNN) and is largely based on a review of information and evidence provided in the applicant’s Environment Statement and supplemented with DCC’s own evidence where necessary.

1.2 The LIR sets out both DCC’s elected County Council Member comments and

the technical comments of officers on the potential economic, environmental and social impacts of the EMG development proposals. DCC has responsibilities for major infrastructure planning and provision, particularly highways infrastructure and, under the Duty to Cooperate, works collaboratively with local authorities in Derbyshire and, where necessary, adjoining districts and borough councils on cross boundary planning policy matters, particularly relating to housing provision, transport infrastructure, education provision and environmental matters.

1.3 The proposed EMG scheme is located wholly within North West

Leicestershire District Council’s (NWLDC) administrative area. However, the application site is located a short distance away from the administrative area of DCC to the west, north-west and north. DCC’s administrative area covers the district and borough council areas of South Derbyshire District to the west of the EMG site and Erewash Borough to the north. Derby City Council (the City Council) is a unitary authority and its administrative area is located further afield to the north-west of the site. The site is located directly to the south-west of Junction 24 of the M1, where the motorway is joined by the A50. The M1 travels through Erewash Borough to the north of the site. The A50 travels in a westerly direction through South Derbyshire District to the north-west and directly to the south of the urban area of Derby further afield, where the A50 links with the A6 and A38 to provide direct access to the City. The EMG site is, therefore, easily accessible by road to these three local authority areas in Derbyshire, particularly South Derbyshire District and Erewash Borough.

1.4 Given the geographical proximity of the administrative area of Derbyshire to

the EMG site and its easy accessibility to and from the site, particularly by road and rail, it is considered that the EMG proposals are likely to have significant economic, environmental and social impact implications for Derbyshire. DCC has, therefore, made extensive Member and officer representations on the EMG proposals at both the pre-DCO application and

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submission DCO application stages. Details of these representations are set out in Section 2 of DCC’s Written Representations.

1.5 DCC’s officers have had extensive and on-going liaison and consultation with

the applicants and their consultants over the last two years or so about the potential highways impacts of the EMG scheme and its public transport and wider accessibility implications for Derbyshire. This liaison and consultation has particularly focussed on the transport evidence base to support the DCO application, especially the methodology and assumptions in the Transport Assessment (TA), and the development of the Public Transport Strategy (PTS) and Travel Plan (TP) for the proposals. DCC has been signatory to two Statements of Common Ground (SoCG) with the applicants on matters relating to the TA, PTS and TP. Further details are provided in Section 2 below.

1.6 The applicants have also engaged directly with DCC’s Members as part of

their wider public consultation on the proposals. Representatives of the applicants attended a meeting of the South Derbyshire Local Area Committee (LAC) on 11 June 2014 to explain the EMG proposals and answer Members’ questions.

1.7 DCC was consulted by Goodman Shepherd on a First Stage Consultation on

similar development proposals for a SRFI it is promoting on land to the south-west of the A38 / A50 interchange at Burnaston in South Derbyshire, known as the East Midlands Intermodal Park (EMIP). The scheme includes an intermodal terminal, which would include container handling equipment and storage facilities; up to 557,400 sq m (6 million sq ft) of units for the distribution industry; and new road access to the site from the A38 / A50 intersection to serve the new development. DCC provided its Member and officer technical comments on the EMIP scheme to Goodman Shepherd on 18 July 2014. A copy of these comments is included in Appendix 3 of DCC’s Written Representations.

1.8 DCC is particularly concerned about the potential cumulative economic,

environmental and social impacts of both the EMG and EMIP SRFI proposals on the County. This issue has been an important consideration in DCC’s assessment of each SRFI proposal.

1.9 Given the scale of the EMG proposals, they are likely to raise wide ranging

and complex national, regional and sub-regional planning policy implications. A detailed analysis of the EMG proposals in the context of the above is set out in Section 3 of DCC’s Written Representations.

1.10 The EMG proposals, however, raise a number of more detailed issues relating

to their economic, environmental and social impacts on Derbyshire, including their potential cumulative impacts. An assessment has been carried out in Section 2 below of these impacts.

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2 Detailed Local Impact Issues for Derbyshire

2.1 This section of the LIR provides an analysis of the more detailed economic, environmental and social impacts of the proposed EMG SRFI, as they relate to the administrative area of Derbyshire.

2.2 Sections 4 and 5 of the NPSNN, set out a range of assessment principles and

generic impacts, which need to be considered in the assessment of applications for all nationally significant infrastructure projects (NSIPs), including SRFI developments.

2.3 Paragraphs 4.1 to 4.4 of the NPSNN, set out a number of key principles for

the assessment of NSIPs. Paragraph 4.2 indicates that, subject to the detailed policies and protections in the NPSNN, and the legal constraints of the Planning Act, there is a presumption in favour of granting development consent for national networks NSIPs projects. Paragraph 4.3 indicates that, in considering any proposed development, and in particular, when weighing its adverse impacts against its benefits, the Examining Authority and the SoS should take into account:

• Its potential benefits, including the facilitation of economic development, including job creation, housing and environmental improvement; and any long term or wider benefits; and

• Its potential adverse impacts, including any longer-term and cumulative adverse impacts, as well as any measures to avoid, reduce or compensate for any adverse impacts.

2.4 Paragraph 4.4, states that in the context of the above, environmental, safety, social and economic benefits and adverse impacts, should be considered at national, regional and local level.

2.5 In the context of paragraphs 4.1 to 4.4 of the NPSNN, there will be many

detailed and specific impacts which are directly related to the development of the application site itself and its immediate surroundings, generated by the construction and operational phases of the EMG scheme. In the context of Section 5 of the NPSNN, these impacts will particularly relate to air quality; carbon emissions; biodiversity and ecological conservation; waste management; civil aviation security; dust, odour, artificial light; flood risk; land stability; the historic environment; landscape and visual impacts; land use, open space and Green Infrastructure; noise and vibration; impacts on transport networks; and water quality and resources. These impacts will no doubt be assessed in more detail by NWLDC and Leicestershire County Council (LCC), within whose district and county the site is located.

2.6 However, there are a number of the above economic, environmental and

social impacts, which are likely to extend well beyond the site itself and its immediate surroundings and be likely to impact on the economy, environment and population of Derbyshire both directly and indirectly. These particular impacts on Derbyshire include:

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• Impacts on the strategic and local road network;

• Implications for public transport and wider accessibility to the site;

• Implications for Rail Freight;

• Economic Impacts, Job Creation Potential and Market Demand Issues;

• Landscape and Visual Impact Issues;

• Greenways and Public Rights of Way Issues;

• Impacts on Housing Provision;

• Impacts on Security at East Midlands Airport; and

• Cumulative Impact Implications.

2.7 An analysis of these impacts, in the context of the requirements of Sections 4 and 5 of the NPSNN, is included below

Impacts on the Strategic and Local Road Network

2.8 Although the site of the proposed EMG SRFI is located in North West Leicestershire District, the traffic impact from it will fall upon the roads of no less than six Highway Authorities. In addition to DCC, these include Nottinghamshire and Leicestershire County Council’s, Derby and Nottingham City Councils and the Highways Agency (HA). All six Highway Authorities have been working with the applicant and its consultants for over two years and have agreed jointly the TA methodology, its scope and inputs via a series of transport related documents and Technical Notes. As far as the potential impact of the EMG scheme upon Derbyshire’s roads is concerned, traffic impact would be principally upon the strategic road network, although it would eventually be dissipated over Derbyshire’s local road networks.

2.9 Prior to the submission of the DCO application to the Planning Inspectorate,

DCC signed a Transport SoCG with RKL (see Section 2 of DCC’s Written Representations). The SoCG set out DCC’s position that its officers had reviewed the traffic modelling evidence, TP and PTS submitted to it by the applicants and their consultants. Paragraph 3.2 of the SoCG indicated that, with the exception of the TP and PTS, the submitted TA and transport documentation covered all aspects of the development and had been prepared in accordance with all current Guidelines and Codes. Together they represented a fair and reasonable assessment of the development and included appropriate Assessment Methodology, Trip Generation and Traffic Assignment and concluded by defining an appropriate package of highway mitigation measures that were appropriate and acceptable to mitigate the impacts of the development.

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2.10 The purpose of the TA is to demonstrate that the proposed EMG scheme can

be satisfactorily accessed by all relevant travel modes and that the proposed highway mitigation measures are sufficient in scale to ensure that adverse impacts on the surrounding highway network as a result of the development will not occur. It also presents the strategies for maximising the use of public transport, walking and cycling by people travelling to and from the development

2.11 The development would increase the number, and alter the pattern of, traffic movements on the transport infrastructure surrounding the site, and the proposed highway works would also alter the conditions for existing users. The effects of the changes on non-motorised uses, would include pedestrians, equestrians, cyclists and drivers.

2.12 As part of the consideration of development, improvements to the highway network to accommodate the development traffic and improve the existing facilities have been proposed. The improvements are shown to provide betterment to the adjacent highway network, providing significant reduction in driver delay and improve journey times. Once fully operational, the proposals would remove over half a million long distance HGV movements per year from the national highway network. As noted above, as far as the potential impacts upon Derbyshire’s roads are concerned, traffic impact would be principally upon the strategic road network, although it would eventually be dissipated over Derbyshire’s local road network.

2.13 It is understandable that RKL has focused upon the progression of the

Section 278 Agreements with LCC and Highways Agency. The proposed access infrastructure is extensive and includes new motorway slip roads and over bridges together with a Kegworth bypass. There would be no actual highway construction works within Derbyshire, so RKL has not involved DCC’s Highway Authority in any Section 278 or S106 undertakings.

2.14 The EMG proposals have raised significant concerns with local residents in

South Derbyshire District, particularly in Melbourne, Kings Newton and Repton about the potential traffic congestion and highway safety implications associated with the construction and operation of the EMG scheme. There is a particular concern and perception by local residents that heavy goods vehicles accessing or leaving the EMG development would be likely to route onto local roads in Derbyshire, such as the A514 and B578 within and around those settlements (see comments below from Councillor Linda Chilton, County Council Member for Melbourne). Such concerns may have been heightened by the TA and supporting evidence with the DCO application, which shows heavy goods vehicles being routed across Swarkestone Causeway on the A514. However, this is largely an anomaly in the transport modelling rather than a prediction. Nevertheless, the Panel of Examining Inspectors and the applicant should be mindful of the concerns of local residents in South Derbyshire. Councillor Linda Chilton recommended that the Panel of Examining Inspectors should visit her electoral division on their accompanied site visits on 3 February 2015, to inspect the nature of the roads

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in the vicinity of Melbourne, Kings Newton, Stanton-by–Bridge and the Swarkstone Causeway. The Panel, however, chose not to visit these suggested sites and locations.

2.15 Swarkstone Causeway is a Scheduled Ancient Monument and is not suited to

the volume and nature of existing traffic using it. The South Derbyshire Local Plan Submission (SDLPS) recognises the traffic problems associated with the Swarkstone Causeway and in Policy INF4: Transport Infrastructure Improvement Schemes, indicates that South Derbyshire District Council (SDDC) will work with partners to deliver a number of transport schemes, including a Swarkstone Causeway Bypass. The development of a potential alternative highway route to the Causeway is identified in the Derbyshire Local Transport Plan (LTP 2011- 2026) as a potential major project.

Comments of Councillor Linda Chilton

2.16 County Councillor Linda Chilton, in her capacity as Local Member for

Melbourne, expressed her concerns about the likely highways impacts of the EMG in both DCC’s responses on the pre-DCO application and DCC application consultations. Councillor Chilton’s comments were that:

RKL’s development proposal would seem to make sense, seeing as we have

the East Midlands Airport, Junction 24 of the M1 and rail track already in existence. I can see this logic, but my concern would be the likelihood of two rail freight terminals within a short distance of each other and basically running on the same highway - A50. I am already concerned and have made my comments known to my Parish Council of the knock on effect from the EMG terminal (there is already an action group in Kegworth against this www.J24actiongroup.org). Mainly the added volume of traffic going through a twisty rural road, noise nuisance and the requirement of yet more homes to house the new workforce, which cannot yet be determined as presumably, a number will be existing inhabitants. Melbourne and Kings Newton are already affected by large volumes of traffic because of its proximity to Castle Donington / Racetrack and the EMA.

I would ask that a point be made as to the need for two terminals. This is two

authorities seeking infrastructure projects and as yet, no final decision on availability of Fire & Rescue and, my favourite subject, the reliability of Swarkestone Causeway even though it has a 7.5 tonne limit.

2.17 A statement by Councillor Chilton was also submitted to the Panel of

Examining Inspectors on 22 January 2015, setting out her reasons why she considered it necessary for the Panel to visit sites and locations in her electoral division to appreciate her concerns and those of her constituents about the likely impacts of the EMG scheme on congestion and highway safety in the area around Melbourne, Kings Newton, Stanton by Bridge and Swarkstone Causeway. The statement indicated that:

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Vehicles are expected to access the proposed site via the A50 / A453 (from the M42 and M1 junctions). This will put the rural roads around my South Derbyshire Division of Melbourne at risk.

It is more than a possibility that HGV’s will travel past the East Midlands Airport (A453 southbound), junctions to Castle Donington, Diseworth / Long Whatton in North West Leicestershire, which shows a 7.5 weight limit ahead, junction at Isley Walton then turn right towards Melbourne where again, there is a 7.5 weight limit sign a couple of miles down. On reaching the edge of Melbourne proper, turning right through Main Street, Kings Newton (B587) a narrow winding country road, especially the bend by Jawbone Lane, will lead to the A514 (the main arterial route from Derby City to Swadlincote, South Derbyshire) culminating in vehicles trying to cross over the River Trent via Swarkestone Causeway / Bridge; an ancient monument with a 7.5 tonne weight limit, very winding and in a couple of places not 5.5 metres wide and therefore not suitable for the type of transport that would be necessary if needing the use of a freight terminal. Once on this A514 there is no turning point for HGVs. We have had a number of issues over this.

Once over the River Trent the A514 travels towards Derby and one mile on there is Junction 3 (known as the Bonnie Prince roundabout) of the A50. Turning west leads to the proposed freight terminal at Eggington / Burnaston only a few miles down and turning East returns to Castle Donington, Lockington, Hemington and M1/M42 junctions.

Many truckers travelling from Swadlincote (South Derbyshire) usually travel via the A453 (not A/M42) as they know they cannot travel over the Causeway. Foreign truckers especially, have unsuitable satnavs which lead them down into residential areas and towards the Causeway where they risk crossing or have great trouble in trying to turn around.

The area will, no doubt, change dramatically with housing applications (those in train already causing alarm) to house the new workforce – 7,000 predicted using the Developer’s formula. We are not in a position to sustain the knock on / cumulative effects of two freight terminals on our roads

Major incidents (re: aircraft / terrorist acts on infrastructure) will pose a problem for local roads. Has this issue been considered?

In all, I would urge the Inspectorate to take half an hour of their time to travel this route to get a full picture of the area and road standards, with a view to requesting necessary strictures before any plans are passed.

Implications for Public Transport and Wider Accessibility to the Site

Public Transport Strategy

2.18 DCC’s Public Transport officers have been liaising with the applicant’s transport and infrastructure consultants for some time regarding the public

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transport implications for Derbyshire of the proposed EMG SRFI and particularly, the PTS, which has been submitted in support of the DCO application. The funding pot for the PTS has also been central to those discussions. DCC’s officers have also recently met with Trent Barton, one of the main bus service operators involved in current discussions about servicing the EMG SRFI proposal. Also, at the East Midlands Airport Transport Forum held recently, it has become evident that the other large employer in the area, Marks and Spencer (M&S), is dovetailing its staff public transport and travel plans with East Midlands Airport to provide an area wide improvement, and they would be happy for RKL to share in their success to mutual benefit. The applicant’s PTS has been reviewed in the evolving context of the above.

2.19 Of the proposed bus service enhancements identified in the PTS, it is clear

that the one with the most relevance to Derbyshire, the my15 extension, has been identified as the one with the best business case and therefore achievable with a relatively small proportion of the funding pot. DCC’s officer’s recent discussions with Trent Barton has confirmed that extension of the my15 service to EMA is something that Trent Barton has already been looking at with East Midlands Airport, as part of the Airport’s Surface Action Plan, and that Trent Barton consider this as already being near to commercial viability. In terms of the costs and revenues assumed by the consultants, DCC’s officers have assessed this and confirm that it is possible for the extension to the EMG SRFI to be implemented with two extra buses. Importantly, it is also possible (just) to serve the Airport with the same resource, given the assumptions on overall generated revenues dependant on this.

2.20 Armed with this additional information, DCC’s officers are now much more

comfortable that the key public transport enhancement affecting Derbyshire is deliverable within the funding pot proposed.

2.21 The position is less clear, however, on the other key proposed enhancements

(Coalville and Nottingham A453 service) and it is notable that the figures in Table 4.1 show that there is an expectation that there will still be a significant operating deficit on these services in year 7, which implies an on-going loss for these beyond the funding period. Whilst this is not really a concern for DCC, it does confirm that the bulk of the funding pot is likely to go into propping up these other services. Nevertheless, DCC’s officers would much rather be in a position of having the public transport enhancement which is most likely to succeed commercially and therefore least likely to have a call on DCC to fund at the end of the seven years.

2.22 Therefore, in the context of the above, DCC’s officers consider that the

proposed budget for the PTS is acceptable, subject to making the following additional points:

• The budget forecasts (understandably) recognise the potential revenue generation from serving East Midlands Airport and M&S on the back of serving the EMG SRFI. This confirms the importance of the need for EMG’s promoters to work closely with East Midlands Airport, which also

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has a strong track record in delivering successful public transport provision. It is therefore essential that the proposed Sustainable Transport Working Group works in partnership with East Midlands Airport and the inclusion of East Midlands Airport and operators in the Working Group is essential;

• It is important that there is some flexibility to how the funding pot is ultimately spent. If the business case is strong to extend the current my15 service then there may also be a strong case to extend the service beyond the current 0500-2300 hours of operation and make it a 24/7 service, as with the current Nottingham and Derby / Leicester Skylink services. This may be a more productive use of the funding pot than the other proposed enhancements;

• DCC’s officers still have some concerns over the proposed shuttle bus service which would serve the individual units on the site (funded separately) and the proposals for the interchange, but it is considered that these are primarily issues for LCC to ensure that they are fit for purpose.

Travel Plan

2.23 In its comments that were submitted to the Planning Inspectorate on 6 November 2014 on the DCO application, it was indicted that DCC’s Officers had reviewed the TP submitted with the DCO application and had raised a number of issues and concerns, particularly that:

• Travel Plan lifetime - Whilst the seven years proposed was generous (greater than the normal 5 year lifespan), officers felt it was important to ensure the plan was active throughout the initial occupation and operation phase, plus at least one additional year. Whilst this may coincide with the proposed development timetable, it would not make sense for it to ‘peter out’ before the development was fully built out and operational; and

• Targets. These should include a 10% gross SOV reduction between 2016 and 2023.

2.24 Following the submission of the above comments, further information and clarification on the TP was submitted to DCC in January 2015 by the applicant’s consultants. This additional information and clarification satisfactorily addressed DCC’s previous concerns on the TP relating to its Lifespan, for which the TP indicates would have a lifetime of 10 years; and the reduction in SOV target, which would be reduced by 10%.

2.25 Given the satisfactory resolution of the issues and concerns raised above on both the PTS and TP, on 19 January 2015, DCC’s Strategic Director of Economy, Transport and the Environment (ETE) signed an Addendum to the original SoCG of 21 July 2015, which indicated that further work carried out by the applicant’s consultants had satisfactorily addressed DCC’s previous concerns of these matters (see details in Section 2 of DCC’s Written Representations).

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Implications for Rail Freight

2.26 The EMG SFRI site is one of the top two intermodal freight sites in the East Midlands, as derived from the results of the East Midlands Rail Freight Study (EMRFS) prepared for the East Midlands Development Agency (EMDA) at DCC’s suggestion in 2008/09. The other top site is at Burnaston in Derbyshire, the subject of separate proposals for the EMIP SRFI. DCC’s officers have liaised with contacts in the rail freight industry to discuss whether the establishment of a cluster of SRFIs in one regional location presents difficulties. The answer is the contrary, in that it is normal elsewhere, and drives access and operating costs down. For example, in the West Midlands, there are four SRFIs including the Birch Coppice, Hams Hall, Lawley Street and Prologis Coventry sites, which are all located reasonably close together.

2.27 In terms of the site detail, DCC’s officers were consulted by RKL’s rail freight

consultant at the pre-application stage. From that consultation, it was made clear that the proposed EMG SRFI development scheme, if approved, would be for the site to grow its operations slowly from an initial 4 trains per day. The Castle Donington freight line is being upgraded to be part of Network Rail’s Strategic Freight Network (along with the Midland Main line, Erewash and Cross Country routes locally), and so able to take 9ft 6in high maritime shipping containers to inland ports such as the proposed EMG site. The proposal, and the connecting rail infrastructure at Castle Donington, has Network Rail’s approval. It is being configured in the context of longer term planning issues around capacity on routes and junctions. The question of how to increase freight traffic so that it does not conflict with passenger proposals such as speeding up Nottingham-Birmingham trains by using the Castle Donington route to avoid Derby, however, is unclear without significant capacity enhancement measures. Economic Impacts, Job Creation Potential and Market Demand Issues;

2.28 DCC’s officers have reviewed the applicant’s evidence and supporting information relating to the economic impacts and job creation potential of the EMG scheme in Chapter 4 of the ES: Social and Economic Impacts. Overall, it is considered that the methodology, assumptions and data sources used in the assessment in the ES are robust and reliable These data sources particularly include the 2011 Census, Nomis, Office for National Statistics (ONS), Department of Communities and Local Government (DCLG) English Indices of Deprivation, Prologis Technical Note and the Homes and Community Agency’s (HCA) Employment Density Guide.

2.29 It is noted that Section 4.6.3 of the ES defines and Area of Influence (AOI) for

the EMG scheme, which covers 16 local authority areas. Five of these local authority areas fall within Derbyshire, including Amber Valley Borough, Bolsover District, Derby City, Erewash Borough and South Derbyshire District. The local authority areas of Amber Valley, Bolsover and Erewash are easily accessible by road to and from the EMG site via the M1 to the north and its junctions 25 (A52), 26 (A610), 28 (A38), 29 (A617) and 29A. Derby is easily accessible via the A50 and its junctions with the A6 and A38 to the north-

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west. South Derbyshire is easily accessible via the A453 and A50 with its junction with the A514.

2.30 Overall, therefore, the AOI defined by the applicants is considered to be

robust as far as it relates to Derbyshire and its local authorities. These local authority areas, especially those in closest geographical proximity to the EMG site of Derby City, Erewash Borough and South Derbyshire District would be particularly likely, therefore, to benefit from the economic impacts of the development, particularly in terms of its job creation potential and associated expenditure spin-off benefits.

2.31 Sections 4.9.1 to 4.9.20 of the ES, provide an assessment of the likely numbers of jobs that would be created at the EMG scheme once it is operational and during its construction phase. It is considered that the two main evidence base studies to support the assessment of the direct employment generating potential of the EMG scheme provide a robust basis for the assessment namely the Prologis Technical Note and Homes and Communities Agency (HCA) Employment Density Guide. The Prologis Technical Note is based on empirical data from occupiers of 28 B8 units with a total of 5.65 million sq m of floorspace. This research found that B8 occupiers typically accommodate 1 employee per 77 sq m of floorspace. The HCA study, of large scale high bay warehousing B8 uses, found that such uses typically accommodate 1 full-time equivalent employee per 80 sq m of floorspace.

2.32 The applicant’s approach in the ES is to use the lower figure in the Prologis

study, which is a robust approach and would provide for a more conservative estimate of the job creation potential of the EMG scheme. Applying the 1 job per 77 sq m ratio to the proposed 560,000 sq m B8 floorspace uses in the EMG scheme, would generate the capacity for the scheme to provide 7,272 new jobs. It is noted in paragraph 4.9.2 of the ES, however, that the applicant acknowledges that this figure could be higher or lower. The Prologis study also indicated that 88% of employees in the 28 B8 units surveyed were employed on a full-time basis, with the remaining 12% working part-time. On that basis, it would appear a reasonable assumption that the EMG scheme could generate 6,400 full-time jobs and 872 part-time jobs. This job creation potential of the proposed scheme is welcomed and supported, particularly as a significant number of these new jobs would be accessible to residents in Derbyshire, particularly those five local authorities included in the AOI.

2.33 Further evidence in Section 4.8 of the ES indicates that a significant number

of new jobs could also be created during the construction phase of the scheme, creating 688 jobs in each year of the 5 year construction phase. DCC has no particular comments on the robustness of the analysis provided in the ES, except to make the point that large development projects of the scale proposed would typically be constructed by national-based construction companies using their existing labour, rather than employing local labour. It is questionable, therefore, whether the proposed development would be likely to create the number of construction based jobs locally being suggested by the applicants in it ES.

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2.34 In terms of the types of jobs likely to be created, the Prologis study would

again appear to provide a sound basis for the assessment, which indicates that the EMG scheme would be likely to create 3,120 warehousing jobs, 759 drivers jobs, 897 administrative and support jobs, 644 managerial jobs and 1,852 other jobs in IT, customer services, sales and engineering support. Whilst these jobs are welcomed and supported the majority are not in the higher skills sector which the Derby, Derbyshire, Nottingham and Nottinghamshire Local Enterprise Partnership (D2N2 LEP) is particularly keen to promote in Derbyshire and Nottinghamshire.

2.35 The likely significant job creation potential of SRFI schemes is accepted by

Government. Paragraph 2.52 of the NPSNN, sets out the Government’s view that SRFIs can provide considerable benefits for the local economy. For example, because many of the on-site functions of major distribution operations are relatively labour intensive, this can create many new job opportunities and contribute to the enhancement of people’s skills and use of technology, with wider long-term benefits to the economy.

2.36 Overall, the job creation potential of the proposed scheme is welcomed and

supported, particularly as a significant number of these new jobs would be accessible to residents in Derbyshire, particularly those five local authorities included in the AOI, where there is a readily available pool of labour with the types of skills required to the fill the likely jobs created at the EMG scheme. It is important, therefore, that the job creation potential of the site is maximised for the residents of Derbyshire and that labour from the local area around the site is recruited as far as possible, particularly by positive recruitment initiatives and advertising in local job centres in Derbyshire. A number of proposed initiatives are set out in Section 4.10 of the ES to maximise the recruitment and training benefits of the EMG scheme. These include:

• Use of labour agreements to maximise the proportion of local construction workers;

• A recruitment / training programme for construction workers with a focus on the job centres in locations where employment deprivation has been identified;

• Provision of skills training in construction with the Work Programme Initiative;

• Local procurement of products and services; and

• The establishment of an Employment and Skills Group to coordinate the extent and type of external workforce training provision required and how it will be delivered.

2.37 All of the above initiatives are welcomed and supported. However, no mention is made is the ES of apprenticeships, which should also form an important part of any recruitment strategy for the EMG scheme.

2.38 At the meeting of the South Derbyshire Local Area Committee (LAC) on 11

June 2014 referred to in Section 2 of DCC’s Written above, DCC’s Members raised concerns about the robustness of the estimation of the number of jobs

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likely to be created on the site and the nature of those jobs. Members expressed their concerns that many of the jobs created on the site could be low paid and on a non-contracted hours basis, which would not be the types of jobs that were needed in the area. Evidence provided in the applicant’s ES would appear to address some of the concerns raised by Members. Notwithstanding the above, the job creation potential of the EMG is an important issue for DCC. The Panel of Examining Inspectors is requested to carefully assess this issue in their assessment of the proposed development. The scale of employment generated by the proposed development will also have important implications for the scale of any necessary housing development required in the area to accommodate the proposed workforce at the site. It is important, therefore, that a thorough and robust assessment is carried out of this issue by the Panel.

Market Demand Issues 2.39 DCC’s officers have reviewed the Market Report submitted in support of the

application. While much of the report is concerned with national scale economic policy and economic evidence issues, it is considered that the report contains sufficient evidence to help support a view on the market demand for the scheme in a more sub-regional context.

2.40 The Market Report contains fairly robust evidence on why the scale and location of the EMG scheme is seen as meeting market demand - particularly in light of the interplay between policy, market drivers, scale and rail accessibility. It is considered that Paragraphs 2.10, 3.6, 3.11 and 3.15, 5.7, 5.44 and the entirety of Section 7 provides a good context for the proposal. In this context, DCC’s Officers consider that the statements provided in the Market Report are realistic. Landscape and Visual Impact Issues

2.41 DCC’s Landscape Officers have reviewed the information supporting the application relating to the potential landscape and visual impacts of the proposed EMG scheme, particularly the ES, which includes a Landscape and Visual Impact Assessment (LVIA), Planning Statement and a Design and Access Statement (DAS).

2.42 Direct impacts of the EMG scheme on the landscape of Derbyshire are likely

to be extremely limited. The LVIA identifies a number of locations within Derbyshire, predominantly to the north of the site, that have formed part of the assessment of likely effects. These include communities at Shardlow and Great Wilne in excess of 3km from the site, Draycott and Breaston approximately 6-7km from the site, Spondon and Risley 9km away, and Sawley and Long Eaton 4-5 km from the site. In all cases, the LVIA predicts the visual effects to be minor adverse during the construction phase reducing to negligible / minor adverse effects after 15 years. DCC’s officers generally concur with these judgements given the distance over which the site will be seen, the fact that the site is likely to be part of a wider vista, and the extent of intervening vegetation and existing settlement, often restricting the viewer to a

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partial or glimpsed view of the site. Although this is a major development scheme, DCC’s officers are satisfied that it will not be particularly visually prominent from any location within Derbyshire.

2.43 The proposal is supported by an extensive landscape strategy and illustrative

masterplan, which appears to be wholly appropriate to the site context as set out in the LVIA. Mitigation proposals include the retention of existing woodlands where possible, extensive land-raising, bunding and large-scale woodland planting. There are opportunities for ecological enhancements through the use of sustainable surface water drainage ponds, associated wetland margins and new hedgerows.

2.44 As a consequence of the design proposals for the development of the site and

the proposed mitigation, overall it is anticipated that there would unlikely to be any significant landscape or visual impacts generated by the proposed development with respect to sensitive locations within Derbyshire. Greenways and Public Rights of Way Issues

2.45 DCC’s Greenway Strategy – South Derbyshire District, proposes a strategic

network of multi-user routes, or Greenways, for walkers, cyclists, horseriders and those with mobility difficulties, across the district of South Derbyshire. Greenways provide sustainable transport links to facilities, services, work, schools, places of interest and to the countryside.

2.46 The plan in Appendix 11 of DCC’s Written Representations shows a proposed network of Greenways (shown by the red arrows), which firstly link Castle Donington to SUSTRANS’ National Cycle Network (NCN) Route 6 at Wilson (this is an existing route shown by blue arrows). NCN Route 6 is a long distance cycleway and destinations include Watford, Milton Keynes, Leicester, Derby, Nottingham, Sheffield and Manchester. The proposed Greenway between Castle Donington and Wilson is predominantly in Leicestershire. The second route links Castle Donington to the Trent and Mersey Canal. This will involve constructing a bridge over the River Trent in the vicinity of King’s Mills. This will then connect to a proposed Greenway on the Trent and Mersey Canal, linking SUSTRANS’ NCN Route 6 south of Derby, to the Trent Valley Way leading to Nottingham.

2.47 It is considered important that the design of the EMG SRFI facilitates the

provision of links to the wider Greenway Network around the site as far as possible, particularly falling within Derbyshire to maximise the wider accessibility of the proposals by walking and cycling.

Impacts on Housing Provision

2.48 The provision of new housing to meet the needs of new large-scale employment generating uses is an important issue for DCC. The NPPF highlights the importance of the relationship between new housing provision and economic development and job creation in providing for sustainable patterns of development. Under the Duty to Cooperate, over the last few

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years, DCC has been working with all the local planning authorities in Derbyshire to help them assemble the evidence base on future housing provision needs and employment land requirements to inform the spatial strategies being incorporated in their Local Plans / Core Strategies. The provision of the necessary infrastructure to support new housing and employment growth is also a key concern and responsibility for DCC.

2.49 Should the EMG DCO application be granted consent by the Secretary of

State (SoS), the potential creation of over 7,000 jobs on the site once the scheme was operational, could have significant implications for future housing provision requirements both in North West Leicestershire District and the wider area, including in Derbyshire, particularly in Derby City, Erewash Borough and South Derbyshire, which are within close geographical proximity to the site and easily accessible to and from the site by the national and strategic road network.

2.50 The Panel of Examining Inspectors and the Secretary of State may wish to

examine the local plans of neighbouring district councils in Derby City, Erewash Borough and South Derbyshire relating to housing provision because the EMG proposals could have significant implications for future housing requirements in each of these areas. A summary of the current housing provision issues in the local plans of these local authorities is provided below.

2.51 The three local authorities of South Derbyshire District Council (SDDC), Derby

City Council (the City Council), and Erewash Borough Council (EBC), have all recently carried out reviews of their previously adopted local plans. SDDC’s replacement Local Plan / Core Strategy was subject to an Examination in Public (EIP) between November and December 2014. The City Council is currently preparing its Pre-Submission Local Plan, which is likely to be published in the summer of 2015. EBC adopted its replacement Core Strategy / Local Plan in 2014. Given that these Local Plans have either been adopted or are at an advanced or relatively advanced stage, and that a decision on the EMG DCO application by the SoS is not likely until 2016, if the DCO application is approved it is likely that the potential implications of the EMG will need to be considered in any future reviews of these Local Plans / Core Strategies.

South Derbyshire Local Plan 2.52 The South Derbyshire Local Plan (SDLP) was adopted in 1998 and its

policies, particularly for housing growth, were set in the context of conformity with the (then) Derbyshire Structure Plan (DSP) (1990). The majority of the policies in the SDLP were saved by the Secretary of State in 2009, pending adoption of a replacement Local Plan / Core Strategy for the District.

2.53 Since 2009, SDDC has been working collaboratively with the City Council and

Amber Valley Borough Council (AVBC), to prepare replacement Local Plan / Core Strategies for their areas, which together form the Derby HMA. It is a long established principle in strategic planning policy making for the area that

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Derby City will not be able to meet its own future housing needs within the administrative area of the City and that its future needs will have to be partly met in the adjoining areas of South Derbyshire District and Amber Valley Borough, particularly as sustainable urban extensions to the City.

2.54 The SDSLP was submitted to the SoS by SDDC in August 2014 and was subject to an EIP between November and December 2014. The SDSLP, as submitted, sets out the District’s proposed future housing requirement for 13,454 dwellings between 2008 and 2028. This was South Derbyshire’s proportion of an overall housing requirement for the Derby Housing Market Area (HMA) of 35,354 dwellings between 2008 and 2028 (see further comment below)

2.55 SDSLP Policy S1: Sustainable Growth Strategy, seeks to ensure that South Derbyshire’s objectively assessed housing needs (OAHNs) are met alongside providing additional housing to ensure that Derby City’s needs are also met. To meet this objective, Policy S1 indicates that 10,903 dwellings will be provided to meet South Derbyshire’s needs and 2,551 dwellings would be provided to meet the needs of Derby City.

2.56 Policy S4: Housing Strategy, indicates that sites will be allocated in the Part 1 Plan to accommodate at least 12,404 dwellings to meet this requirement, with the balance to be identified in the Local Plan Part 2 (600 dwellings) and 450 dwellings assumed to be likely to be provided as windfalls. The District Council will also maintain a five year rolling land supply of specific deliverable sites.

2.57 Policy H1: Settlement Hierarchy, indicates that the location of new residential development will be determined in accordance with a Settlement Hierarchy. This Settlement Hierarchy includes ‘Urban Areas’ as a top tier, where residential development will be permitted of a scale up to and including strategic sites as extensions to the urban area of Derby and Swadlincote. Other tiers of the hierarchy include ‘Key Service Villages’ and ‘Local Service Villages’, where smaller scales of housing growth will be permitted.

2.58 Policies H2 to H18 identify a range of strategic housing sites to meet the

requirement set out in Policy S4 for 12,404 dwellings to be provided in Part 1 of the Plan. 17 strategic sites are allocated on the south and south-eastern edges of the urban area of Derby, in and around Swadlincote, and some of the larger Key Services Villages to help meet the requirement of 12,404 dwellings

2.59 An EIP of the SDSLP was help before a Local Plan Inspector between

November and December 2014. The Inspector has recently published her preliminary findings on the EIP, in which she has identified further work to be carried out by SDDC and the other Derby HMA authorities (see below) to address a number of soundness concerns, particularly relating the OAHNs of the Derby HMA and its apportionment between the three authorities, and the District Council’s five year housing land supply needs. Of particular importance, however, is that following the joint EIP session with the Local

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Plan Inspector who presided over the Amber Valley Local Plan EIP in March and April 2014 on the issue of the OAHNs of the Derby HMA, both Inspectors have agreed and recommended that the OAHN requirement for the Derby HMA should be 33,388 dwellings for a rebased plan period of 2011 to 2028.

2.60 In the context of the above, it is SDDC’s position that the District would

provide 12,341 dwellings towards the 33,388 dwelling HMA requirement for the re-based plan period. The Inspector, however, has expressed some concern about the respective proposed apportionments for housing provision between the three HMA authorities to meet the OAHN figure of 33,388 dwellings across the HMA and recommended that further work is carried out to address this issue. AVBC published Further Proposed Changes to its Local Plan Part 1 Core Strategy Submission in October 2014, in which it set out its proposed housing provision requirement of 9,651 dwellings between 2011 and 2028. The City Council’s position is that it is capacity constrained and that around 11,000 dwellings would be provided in the City. In this context, the three HHA authorities have identified land for around 33,000 dwellings with a remaining requirement of land for about 400 dwellings yet to be identified and agreed between the authorities. The four HMA authorities, including DCC, signed a Statement of Continued Joint Working (SoCJW) in November 2014, which committed the four authorities to work together to identify sufficient land to meet the residual 400 dwelling requirement across the HMA.

Derby City Local Plan

2.61 The exiting City of Derby Local Plan (CDLP) was adopted in 2006 and set out

the City’s future housing requirements in the context of the (then) Derby and Derbyshire Joint Structure Plan (DDJSP) up to 2011. Most of the policies in the Plan were saved by the SoS in 2009 for a further period pending the adopted of a replacement Local Plan for the City.

2.62 As noted above, since 2009, the City Council has been working collaboratively with SDDC and AVBC to prepare replacement Local Plan / Core Strategies for their areas, which together form the Derby HMA. It is a long established principle in strategic planning policy making for the area that Derby City will not be able to meet its own future housing needs within the administrative area of the City and that its future needs will have to be partly met in the adjoining areas of South Derbyshire District and Amber Valley Borough, particularly as sustainable urban extensions to the City.

2.63 The Derby City Preferred Growth Strategy (DCPGS) was published in 2012

and indicated that there was likely to be a need for 33,700 new dwellings in the Derby HMA between 2008 and 2028 with 19,230 dwellings required to be provided in the Derby Urban Area of which 12,000 dwellings should be provided in Derby City. The PGS identified a range of preferred strategic housing sites on the southern and south-eastern fringes of the City to meet the additional housing requirement.

2.64 As noted above, the housing needs of Derby City are intrinsically linked with those of South Derbyshire District and Amber Valley Borough. The Inspector

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for the SDSLP EIP has recently published her preliminary findings on the issue of the OAHNs of the Derby HMA, for which she has recommended a housing provision figure of 33,388 dwellings over the period 2011 to 2028. Derby City’s current position is that it would be able to meet 11,000 dwellings of that requirement. The Local Plan Inspector has required the three HMA authorities to carry out further work on the apportionment of these 33,388 new dwellings across the HMA. The outcome of this further work will inform the publication of the City Council’s Pre-Submission Local Plan / Core Strategy, which is likely to be published in the summer of 2015. Erewash Borough Local Plan

2.65 The Erewash Borough Core Strategy Local Plan (EBCSLP) was adopted on 6 March 2014. The EBCSLP, alongside a number of saved policies of the former Erewash Borough Local Plan (EBLP), now forms the development plan for the Borough.

2.66 EBCSLP Policy 2: The Spatial Strategy, sets out the Borough’s future housing requirements for 6,200 new dwellings between 2011 and 2028. Policy 2 sets out the broad spatial distribution of these 6,200 dwellings with approximately 4,500 homes provided in or adjoining the Ilkeston Urban area including approximately 2,000 homes at the Stanton Regeneration site; approximately 1,450 dwellings in or adjoining Long Eaton urban area; and approximately 300 dwellings within the rural settlement boundaries. Evidence on the Potential Future Housing Requirements Related to Large-Scale Employment Generating Schemes

Derbyshire Structure Plan – Secretary of State’s Proposed Modifications Relating to Development of Toyota Car Manufacturing Plant at Burnaston in South Derbyshire

2.67 Evidence on the likely relationship between large-scale employment generating developments and their associated housing requirements is very limited. The only reasonably comparable example in Derbyshire to the EMG scheme is the Toyota car plant at Burnaston in South Derbyshire.

2.68 The Toyota car plant was in the planning stages when the 1990 DSP was

being prepared by DCC. The Toyota development was granted planning permission subsequent to the DSP being submitted to the SoS in February 1989 for examination. During the DSP examination, DCC had proposed that housing provision in the local authority areas of Amber Valley, Derby City and South Derbyshire should be increased by about 2,100 dwellings in total, over and above the housing provision put forward in the Submission DSP, to account for the likely job creation potential of the car plant and the need to house some of its new workforce. DCC’s view was that the Toyota plant would generate 3,000 new jobs on site plus 2,000 off site jobs and a possible 6,000 spin-off jobs created by companies wishing to take advantage of the new opportunities that may arise.

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2.69 The Government Panel who examined the DSP in September 1989, however, considered that housing provision in the three local authority areas proposed by DCC was over cautious and recommended that a total of 3,000 new houses should be included in the DSP to meet the housing requirements likely to be associated with the jobs created by the car plant. The SoS agreed with the Panel and in January 1990, the SoS published his Proposed Modifications to the DSP, in which he recommended that housing provision within the three local authority areas should be increased by a total of 3,000 dwellings between 1987 and 2001, comprising 200 additional dwellings in Amber Valley Borough, 700 in Derby City and 2,100 in South Derbyshire (see Appendix 12 of DCC’s Written Representations).

2.70 Although the decision of the SoS on the Toyota development is dated, it does

give some background context to the consideration of this issue in the DCO examination of the EMG development proposals. It gives a clear demonstration that the SoS has, in the past, accepted that large-scale employment uses generate significant requirements for new housing development to accommodate the workforce likely to be generated by such proposals.

2.71 The Panel of Examining Inspectors and the SoS, are requested to carefully

examine the job creation potential of the proposed EMG development. If the SoS is minded to approve the EMG DCO application, his conclusions on the job creation potential of the site could have important implications for the local planning authorities in the surrounding area and the preparation of their future Local Plans, particularly relating to the need to identify sufficient land in their Local Plans to provide the necessary additional housing to accommodate some of the likely workforce employed at the EMG site. It is important that the local authorities have a robust employment figure for the site so that they can plan appropriately for the housing needs associated with the SRFI development. Security Implications

2.72 The proposed EMG development is located on land directly to the north of East Midlands Airport, with the southern boundary of the site situated only a short distance from the main take-off and landing runway.

2.73 Sections 4.74 to 4.78 of the NPSNN, indicates that national security

considerations are an important aspect of the assessment of NSIPs and that security considerations apply across all such infrastructure projects.

2.74 Paragraph 4.74 of the NPSNN, indicates that the DfT acts as Sector Sponsor

Department for national networks and in this capacity has lead responsibility for security matters in that sector and for directing the security approach to be taken. It notes that the Department works closely with Government agencies, including the Centre for the Protection of National Infrastructure (CPNI) to reduce the vulnerability of the most critical infrastructure assets in the sector to terrorism and other national security threats.

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2.75 Paragraph 4.75 of the NPSNN goes on the add that it is the Government’s policy to ensure that, where possible, proportionate protective security measures are designed into new infrastructure projects at an early stage in the project development.

2.76 The proposed EMG scheme would provide for a large-scale development in

very close proximity to East Midlands Airport, one of the country’s main regional airports. It would be likely to employ over 7,000 people and generate large volumes of trips to and from the site by road and rail so that a large number of people would be on the EMG site at any given time. This could pose a significant security risk to the airport making it more vulnerable to breaches of security.

2.77 It is very important therefore that the issue of security is thoroughly assessed

by the Panel of Examining Inspectors in its assessment of the EMG application proposals and that appropriate mitigation measures are considered to ensure that the EMG proposals do not have an adverse impact on security of the airport. This is an important consideration for DCC as the north-eastern part of South Derbyshire District is in close proximity to the airport, particularly the electoral division of Melbourne, which is represented by Councillor Linda Chilton. Councillor Chilton is very concerned about the issue of security at East Midlands Airport and how the proposed EMG development could heighten the security risk to the airport. Cumulative Impact Implications

2.78 On 27 May 2014, DCC was consulted by Goodman Shepherd on a First

Stage Consultation on its development proposals for a SRFI that it is promoting on land to the south-west of the A38 / A50 interchange at Burnaston in South Derbyshire, known as the EMIP. The scheme includes an intermodal terminal, which would include container handling equipment and storage facilities; up to 557,400 sq m (6 million sq ft) of units for the distribution industry; and new road access to the site from the A38 / A50 intersection to serve the new development. As noted above in Section 1, DCC provided its Member and officer technical comments on the EMIP development to Goodman Shepherd on 18 July 2014. These comments expressed broad support, in principle, for the proposed EMIP scheme but expressed concern about the proposed cumulative economic, environmental and social impact implications of both the EMG and EMIP on Derbyshire, should both schemes be approved by the Secretary of State.

2.79 The applicant’s ES for the EMG scheme has been reviewed in this context. It

is disappointing that the ES and other supporting information submitted by the applicant does not consider or assess the potential cumulative environmental, economic and social impacts of the EMG scheme with the EMIP scheme. The applicant’s ES indicates that four committed development proposals in the immediate vicinity of the EMG site have been assessed in terms of cumulative impacts which include:

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• Land adjoining 90 Ashby Road, Kegworth: Residential Development (outline) of up to 110 dwellings;

• Park Lane, Castle Donington : Residential development of 275 dwellings;

• East Midlands Distribution Centre, Castle Donington: 2.5 m sq ft of warehousing and distribution development;

• Land north and south of Park Lane, Castle Donington: residential development (outline) of up to 895 dwellings and employment uses, including new western relief road linking Back Lane to Hill Top.

2.80 Although the applicant’s approach to consider the cumulative impacts of the

proposed EMG scheme is understandable, in that only committed schemes have been considered, it is likely that by the time the SoS considers the recommendations of the Panel of Examining Inspectors on the EMG DCO application towards the end of 2015, a DCO application is likely to have been submitted by Goodman Shepherd to the Planning Inspectorate for the EMIP SRFI at Burnaston in South Derbyshire. At some stage, therefore, in his assessment of the EMG scheme, the SoS is likely to have to consider the potential cumulative impact implications of both the EMG scheme and the EMIP scheme, as this is likely to be a material consideration in the assessment of the EMG DCO application.

2.81 As noted in Section 2 above, on 12 January 2015, DCC attended the

Preliminary Meeting of the Panel of Examining Inspectors with the applicants and other Interested Parties. DCC was invited to the meeting and it was attended by County Councillor Linda Chilton, and DCC’s officers - Steve Buffery (Planning) and Geoff Blissett (Highways). The Panel invited questions from Interested Parties on the proposed examination timetable and its process and procedures.

2.82 Steve Buffery indicated to the Panel that DCC had particular concerns about

the potential cumulative impact implications of the EMG scheme with proposals for the EMIP at Burnaston in South Derbyshire. He asked the Panel to clarify its approach to how it was intending to deal with the cumulative impacts implications of both schemes through the DCO examination process.

2.83 Overall, therefore, DCC considers that the cumulative impact implications of

the EMG and EMIP schemes are a material consideration in the EMG DCO examination and that this issue should be considered by the Panel of Examining Inspectors.