Essentially the council has passed everything back into the lap of Secretary of State Eric Pickles and is hoping that he will come up with improved substantive grounds as to why Colnbrook is a better place than Park Street to site a railfreight terminal to serve the north-west quadrant of London.

My niggling doubt is that we saw the Conservative-controlled county council refuse to stand up for local residents in the second public inquiry, leaving it to the District Council and to STRiFE.  That was a dereliction of duty of their part and must have played a part in allowing the Inspector to recommend approval of the project,  leading to the Secretary of State having to over-rule him, and so this most recent legal challenge by HelioSlough.

I hope the new Conservative-led district council administration, which is in St Albans but not of St Albans, is not wobbling in resolve to stand up for residents in the south of the district.

I spoke second and flagged up the potentially fatal flaw identified by David Parry and myself in the way that Helioslough’s traffic experts had calculated the likely HGV movements in and out of the terminal (see more below).  I then went on to comment that while the proposed terminal had forfeited any right to be described as strategic, St Albans’s strategic place in British history was assured and any destruction of the crucial southern approach to the city based on a “dodgy dossier” of highway evidence had to be weighed against that.

Other speakers included Eric Roberts and Peter Trevelyan of the Civic Society.  Eric in particular gave an absolutely bravura performance on the rail issues, drawing fully on his 27 year career as a railwayman.

The final witness of the morning was David Parry.  It is he of course who first identified the possible flaw in the HGV calculations because of a traffic generation formula based on warehousing comparative floorspace rather than comparative volume.  It is quite clear that we have struck a real nerve with Helioslough.  Their counsel seemed quite hurt at the press coverage we have achieved – well bless.

He went at David hammer and tongs, trying to get him to wobble, and emphasising that all highway forecasts are done in this way.  As David pointed out, that does not make them right and 20 metre high warehouses as proposed here are a relatively new phenomenon.  Their lawyer then said how did David know whether the part of the warehouse higher than 12 metres would be as intensively used as the lower 12 metres.  David, who runs his own architectural design practice, said that he did not design a three storey house on the basis that the top storey would not be used.

Rather than trying to beat up on witnesses who are not paid, who have to take time off work, and who don’t have massive resources at their disposal, it would be far better if Helioslough simply got a signed statement from their professional traffic advisers confirming that they did take into account the greater storage volume per square metre of floorspace at Radlett compared with other sites.

I suspect that is a question they don’t want to ask – I wonder why not…

For the first time for a long time, I feel slightly more optimistic about the final outcome.  St Albans District Council and STRiFE have done a magnificent job.  They and we have provided more than enough ammunition  – in the end it all depends  on the Inspector.

Finally the full text of my speech this morning follows -

I am Sandy Walkington, Liberal Democrat Parliamentary Candidate for St Albans Constituency.  I am an independent Communications Consultant.  I was previously a senior manager for Texaco, BT, and up until 2006 I was the Director of Public Affairs for Transport for London.  I have also been a member of the CBI National Council.

The St Albans constituency is bounded by the A1(M) in the east and the Grand Union Canal in the west.  The A414/A405 dual carriageway is effectively the spinal cord of the area defined by the parliamentary boundaries.  I live at the eastern end of this road and drive along it in both directions on a daily basis at all times of the day and evening, entering and exiting at all the major junctions.  So I am very familiar with its patterns of usage.

At the previous Inquiry I expressed my concern at the carrying capacity of the road infrastructure and whether it could cope with the predicted lorry movements put forward by the applicant.  My concerns were of course widely shared by others opposing the application but as we know the Inspector concluded that in his opinion the local road system would be able to handle the predicted lorry numbers.

That is why the proof of evidence presented by my friend and colleague David Parry and particularly the appendix to his proof is so important.  He suggests that the agreed forecasts for lorry traffic appear to be based on a wrongly founded calculation.  He has noted that the likely traffic generation figures for Radlett have been generated by extrapolation from actual vehicle movements at Daventry International Railfreight Terminal (DIRFT) in 2005 and at Magna Park in an undated survey.  I accept that all the parties involved in highway matters appear to have accepted the calculation, but there seems to be something very odd about the quoted formula.

As Mr Parry has noted, they state that they have used recorded HGV movements associated with the warehousing floorspace in square metres at Daventry and Magna Park to derive the forecasts for vehicle movements into Radlett by comparing the proposed warehousing floorspace in this application.  But  on the face of it the fact that the proposed Radlett warehousing is designed to accommodate considerably more storage volume per square metre of floorspace than is the case at DIRFT and Magna Park has been simply ignored.   The Radlett warehousing with a planned height of 20 metres is 50 percent higher than the older 12 metre high warehousing at DIRFT and Magna Park.  In addition warehousing of the height proposed at Radlett requires automated rail guided loading and unloading systems rather than conventional fork lift truck stacking.  This allows internal storage stacks to be placed in a much denser configuration than in older warehouses.  The combination of both gives Radlett a far greater storage capacity per square metre of floorspace than at the comparator sites used to generate the forecast.

The only conclusion that I can draw as a layman in these matters is that either  Helioslough is committing deliberately and as a matter of ;policy to under-utilise its built storage space (which seems unlikely in the real world of competition) and/or to they are committing to only have low turnover  warehouse operations as tenants (which also seems unlikely).  Or they have contrived – quite possibly accidentally –  to underestimate by a very considerable margin the likely HGV traffic into and out of the site.

I have additionally had sight of the statement submitted to the Inquiry by Mr Chris Brown of STRiFE.  I note that he has taken forward Mr Parry’s insight and has produced a very useful table which inter alia compares forecast lorry movements per cubic metre of storage at Radlett versus those predicted per cubic metre of storage for Kent International Gateway and Colnbrook.  His table of figures starkly illustrates that there does indeed seem to be something very amiss with the forecasts for lorry movements at Radlett, where lorry numbers are predicted to be half the number per cubic metre of storage as at the other sites.  In short the sums do not add up.

The previous Inspector’s conclusions were not based on there being huge surplus capacity on the local road network.  He simply concluded that the additional lorry numbers were manageable.  But if in fact the actual daily figure for HGV movements in and out of the site is up to or even greater than 6,000 compared with the figure of just over 3,000 on which the Inspector’s conclusion was based, there must be a good chance that we will have reached a tipping point where the roads local to the Park Street site will be overwhelmed and the concerns of the Highways Agency about the impact on key strategic junctions will be further magnified.  All the assumptions about highway capacity must be re-examined from scratch.  Moreover such a huge increase in HGV movements without a commensurate increase in train traffic will make Radlett far more obviously a road to road distribution site with a few sidings attached rather than a genuine railfreight interchange.  It seems to me to open up a whole series of questions which must be answered.

Turning to the rail element of the application, I agree with the other parties to the Inquiry about the impact on commuters, which has already been well rehearsed at this Inquiry.  When I worked at Transport for London I was closely involved in the early negotiations to create TfL’s ambitious new London Overground programme.  This is taking over elements of the surface rail system and is designed to introduce more frequent metro style services to encourage ridership on these under-used lines.  I can certainly confirm on the basis of numerous discussions in that role the huge conflict in North London between the existing demands for freight paths and the ambitions for increased commuter rail into and across the metropolis.

I also agree with other witnesses on the implications of the known restrictions of rail access and loading gauge.  A maximum W9 gauge and rail connections only to and from the south fatally undermine this site’s pretensions to be a Strategic Railfreight Terminal – and if it is not strategic, then the destruction of Green Belt and impact on local infrastructure cannot be justified.

But if the proposed Freight Terminal has forfeited any right to be described as strategic, the strategic place of the city of St Albans in the history of this island is certainly assured.  Other witnesses have stressed the risk to an irreplaceable view of national significance from the Midland Main Line.  My own still memorable first sight of St Albans was across the flat expanse of the Park Street site – then empty runways – to the city on the hill with its remarkably preserved skyline of Cathedral, Clock Tower and St Peter’s Church.  St Albans stood out as distinct and separate from the outer London sprawl.  It is impossible to put a value on this kind of view – and it is not just the view from the south towards the Abbey and St Albans’s historic conservation area which will be irreparably compromised by the inappropriate bulk and massing of the proposed warehouses.  The crucial view southwards when exiting from the Abbey’s west end will be changed for ever by the sight of these huge warehouses in the distance.

Further along the M25 to the east, historic Waltham Abbey has been lost in a clutter of tin sheds with only occasional glimpses of the abbey tower.  This is the church where King Harold was reputed to have been buried after his death at Hastings.

St Albans is immeasurably more important than Waltham Abbey in historical terms.  We are talking of a city which has played a significant role in some of the greatest milestones of our nation’s history – the Roman invasion and Boudicca; the conversion of this island to Christianity and the great story of Alban, Britain’s first Christian martyr and strong contender to be the United Kingdom’s patron saint; the drafting of Magna Carta; key moments in the Peasants Revolt; two great battles in the Wars of the Roses; the foundation of modern scientific enquiry with Francis Bacon.  What will future generations think of us if we wilfully allow great slabs of warehousing to dominate the southern approach of this truly historic city and create the visual coalescence with other communities which Green Belt policy is precisely supposed to prevent?

St Albans is special.  As the internationally respected American architect and planner Andres Duany  (a huge admirer of this city) said in a recent talk in this very chamber, there are few enough places in the world which are genuinely special and we have to work ceaselessly to stop them being vandalised and reduced to conformity with other less special places.  We appear to have a dodgy dossier of highway forecasts.  It is a foundation of this application.  Until we get a full and proper explanation of the apparent discrepancies the appeal should be rejected and the applicant instructed to come back with an accurate forecast of lorry movements.  Otherwise we will have the unnecessary destruction of the southern approach to this great city, a complete breakdown of the highway infrastructure as up to double the predicted number of lorries access the site, and future generations will simply rub their eyes at our carelessness with history.

I joined the demonstration organised by STRiFE beforehand and then we all crowded into the council chamber to hear the opening submissions – so many of us that the council’s head of legal services joined other council staff in pulling out more chairs so everyone could sit.

In his opening remarks the Inspector, Mr Mead, specifically referred to a letter I had written to him at the end of last week.  In this letter I had asked him to consider an adjournment of the whole Inquiry.  I had not made an external song and dance about this request.  It was not a stunt.

But following Hertfordshire County Council’s recent abject decision not to oppose the Helioslough application on highway grounds, my old Liberal Democrat friend and colleague David Parry decided to review all the highways data.  He then phoned me up and asked me to come over to see if I agreed with his discovery of what looks to be very dodgy arithmetic in the calculations used by Helioslough’s “experts” to predict likely lorry movements in and out of the terminal.

This is of crucial importance since up until now all sides have accepted the Helioslough lorry movement forecast.  The discussion at the last Inquiry was simply whether the local road network could cope with this additional volume of traffic.  The Council, STRiFE and other objectors all argued it could not, the Inspector eventually ruled that the road network could cope.  But if the number of lorry movements has in fact been hugely under-predicted by Helioslough, then the Inspector was basing his decision on false data, all bets are off and the whole basis of the application should be re-reviewed.

When David says something about planning, it is always worth listening to what he has to say.  When he was a member of St Albans District Council, he was chairman of the planning committee (the then equivalent of Planning Portfolio Holder) and he led the successful campaign against the then Conservative government’s wish to see massive retail development on the “golden triangle” formed within the crossing of M1, M25 and A405.  David now runs a local design practice.  He knows his stuff.

So this is what I wrote to the Inspector once I was confident that Helioslough had a case to answer:

Dear Mr Mead
As Liberal Democrat parliamentary candidate for St Albans, I have registered my wish to speak during the days reserved for members of the public in order to express my reasoned opposition to the proposed freight terminal on the former Radlett Aerodrome.
In preparing my statement of evidence I have been reading the material submitted by others and particularly that from Mr David Parry, chairman of the St Stephens Liberal Democrats.  As a result of reading his statement, I am writing to you without delay formally to request an adjournment of proceedings since he would appear to have exposed a fundamental flaw in the calculation used to generate lorry movements into and out of the Radlett site.
He has noted that the likely traffic generation figures for Radlett have been generated by extrapolation from actual vehicle movements at Daventry International Railfreight Terminal (DIRFT) in 2005 and at Magna Park in an undated survey.  Indeed all the parties have accepted the calculation.
But if you examine the reasoning, it is the relative square footage of the warehousing at Daventry and Magna Park which is used to compare with the proposed square footage at Radlett in order to calculate vehicle movements from Radlett.
However the Radlett warehousing is proposed to be 20 metres tall with a likely internal storage height of 18 metres whereas DIRFT and Magna Park both consist of warehousing mostly of no more than 12 metre internal storage height.  So already we have fifty percent more storage volume for the same internal square footage.
18 metre high storage stacks require automated rail guided loading and unloading systems, which in fact mean that the stacks are much closer together than in conventional warehouses using standalone forklift trucks.  So not only will Radlett have higher stacks than at DIRFT, they will also be closer together.  On this basis Radlett could have double the volume of storage for the same floor area.
This makes all the predictions of lorry movements totally understated.  Assuming Radlett is in line with modern norms in terms of turnover, we have to presume up to twice the number of lorry movements as predicted in the Helioslough submission.
Since these were the figures used in the previous Inquiry – without argument I admit – this implies that the Inspector’s decision that the local road network could cope was based on false information.  The local roads will be overwhelmed and the balance of movement between road and rail will be radically altered making it far more obviously a road distribution site.
I agree it is extraordinary that nobody has noticed this before.  I am only a layman in these matters.  But I do note that all data about warehousing talks in square footage rather than volume – it just seems to be taken for granted.  The elephant has been in the corner and nobody has noticed it – until now.
Mr Parry will be talking to his evidence on Public Day.  I will also be referring to these matters.  But the flaw seems so profound that I am formally writing to ask for an adjournment to give all parties the opportunity to re-examine the data.
I look forward to your prompt response.

The Inquiry Programme Office had contacted me on Friday to say that the Inspector had asked that the letter be circulated to all the parties, that is Helioslough, St Albans District Council and STRiFE.  STRiFE certainly received it and they believe there is a real issue which Helioslough must address.

Martin Kingston QC, lead counsel for Helioslough, said he knew nothing of my letter and was clearly taken aback.  Well he knows now.

Today the Inspector told us that he was not going to adjourn the Inquiry at this stage but that my letter clearly raised issues which will need to be addressed.

There are of course many other reasons for opposing this awful proposal and I will be rehearsing many of them when I give evidence at the Public Day on December 3rd.  But we just could have dropped a depth charge into the whole process.  Lets hope so.

The big new news is the opposition of the Association of Train Operating Companies (ATOC) to the proposal. They have produced a devastating analysis to show how it is virtually impossible to combine the increased demand for passenger train slots following the completion of the Thameslink 2000 upgrade and the paths required for slow moving extra long freight trains entering and exiting the proposed freight terminal. It makes it almost impossible to see how Helioslough could achieve their claimed 50:50 modal split between rail and road.

It really is nothing more than a glorified road terminal with some sidings attached. The council made the right decision tonight. The whole thing will go to appeal with yet more expense on lawyers and experts. At the end I hope we will have put a stake through the heart of this wretched proposal.