HELIOSLOUGH has completely failed to show the former Handley Page airfield is the only suitable site for a railfreght terminal, the council's barrister Mattthew Reed has told the inquiry.

Continuing his opening statement this morning, he mounted a detailed assault on the company's alternative sites assessment, likely to be crucial as the first appeal failed largely through failings in the first assessment.

Mr Reed said: “The appellant has failed, again, to provide an adequate alternatives assessment.

“It has restricted its search to the north-west sector.

“In any event, even if this was correct, the assessment was wholly inadequate.

“If the occupiers of SRFI warehousing distribute on a regional basisd comprising London and the South-East, there is no benefit in lorrry mileage terms in being in one part of London rather than another, so long as the site is reasonably close to London.”

The first inspector accepted the company's approach of looking at the north-west sector of the M25 only, but Mr Reed argued there was no market-based evidence to support this.

He continued: “If all, or the majority, of those who will be occupying the premisses intend to distribute on a regional basis to London and the South-East, there is simply no basis for the restriction.

“The appellant's evidence is entirely lacking that the units will be occupied primarily by those distributing to the north-west sector.

“On the other hand, there is a considerable amount of evidence inidicating that the north-west sector in not the primary distribution area of those likely to be occupying an SRFI.”

Reffering to a survey of potential occupiers which supports his argument, he said: “It issuggested [by Helioslough] that the number if responses was inisignificant.

“But the companies themselves were significant concerns who distribute, in total, millions of miles.

“Absolutely no rebbutal evidence was provided by the appellant.

“The evidence establishes quite clearly that the search assessment should have been undertaken on a much wider basis.”

Mr Reed went on to analyse the assessment in detail, claiming there at least two sites in the north-west sector, Colnebrook near Slough and Littlewick Green near Maidenhead, providing clear alternatives.