Representation by DP World London Gateway (DP World London Gateway)
- Date submitted
- 23 March 2021
- Submitted by
- Non-statutory organisations
This Relevant Representation is submitted on behalf of London Gateway Port Limited, LG Park Freehold Limited and LG Park Leasehold Limited (hereafter collectively referred to as DP World London Gateway (DPWLG)). Background Context DPWLG is the developer and operator of London Gateway (LG), which comprises the London Gateway Port (the Port) and London Gateway Logistics Park (the Park), located on the northern banks of the Thames Estuary in Stanford-le-Hope, Essex. LG provides a tri-modal transport interchange of national significance and forms part of the Thames Freeport, awarded Freeport status within the Chancellors Budget Statement of 3rd March 2021. With first operational use taking place in November 2013, the Port currently comprises three operational berths, whilst the Park currently provides 161,892sq.m of operational floorspace in eight buildings, with two further buildings currently under construction. The Port and Park are consented pursuant to the London Gateway Port Harbour Empowerment Order (HEO) which was made by the Secretary of State for Transport on the 2nd May 2008 and the London Gateway Logistics Park Local Development Order (LDO), made by Thurrock Council on the 7th November 2013 respectively. Once fully developed the Port will comprise six shipping berths providing additional deep sea shipping and container handling facilities with an annual throughput of 3.5 million TEU (twenty foot equivalent units). The adjacent Park will provide up to approximately 830,000sq.m of commercial floorspace. Policy Context As discussed within the National Policy Statement for Ports (NPSP) dated January 2012, ports such as London Gateway Port comprise an “an essential element in ensuring sustainable growth in the UK economy” (Paragraph 3.1.4). The NPSP also makes reference to “the need for unimpeded access” (Paragraph 1.1.2). DPWLG contend that the Ports NPS forms a material planning consideration in determining the Development Consent Order for the proposed development and that significant weight should be given to matters that have the potential to detrimentally impact upon access to LG. Material Issues The proposed Ferry Terminal and associated vehicle parking facility in Tilbury (defined in the TA as the ‘Essex Project’) has the potential to result in significant detrimental impact on highway routes critical to the operation of LG. Should the development proceed in isolation of other proposed schemes, such concerns relate predominantly to the operation of the M25/A13 grade separated roundabout junction (M25 Junction 30) and A13 links west of the A1089. Should however the development proceed in combination with the Lower Thames Crossing (LTC) we believe that significant detrimental impacts will result at the A13/A1014 junction (Manorway Interchange) and links of the A13 between the A1014 and A1089. In this regard we highlight that Manorway Interchange and the A1014 form the sole access route to LG for freight traffic (other more local roads all being subject to vehicle weight restrictions and unsuitable for freight traffic). Having reviewed the Applicant’s Transport Assessment (TA) (Document Reference APP-093), DPWLG are of the view that the potential impacts described above are not sufficiently assessed or mitigated, with peak traffic flows rates on the related parts of the network significantly understated. In particular, we note that, notwithstanding DPWLG’s response to the Applicants Statutory Consultation (letter dated 6th August 2020), LG is not recognised as Committed Development of relevance to traffic impacts. As a result, Manorway Interchange and links of the A13 east of the A1089 are not included within the study area and are not afforded due consideration.