Representation by Amazon UK Services Limited (Amazon UK Services Limited )
- Date submitted
- 30 March 2021
- Submitted by
- Members of the public/businesses
Amazon welcome the opportunity to engage in the London Resort Examination process as an Interested Party. The London Resort is proposed near existing and future Amazon fulfilment centres, at Tilbury and at the former Littlebrook Power Station. The latter of which is due to become operational in August 2021. Full consideration must be given to existing and committed sites/uses to ensure the potential impact of the proposed London Resort development has been fully assessed. The primary concern of this representation is related to transport impact. As outlined below, there are areas where it is considered that the transport case for the proposed development is not sufficiently robust and needs further clarification to ensure there are no detrimental impacts on existing/committed uses. PEP Transport Consultants have undertaken an initial review of the documentation available and provide initial comments below. We respectfully reserve the right to add to, or amend the transport points or expand further on matters below in future written representations. • The limited number of comparable developments in the Transport Assessment means that visitor forecasts could be subject to a range of error. Rather than relying on single value forecasts, sensitivity testing should have been undertaken based on a range, as well as demonstrating that use of 85th%ile visitor rates was appropriate. The basis for using 85th%ile rates is not clear and is not accepted methodology in the United Kingdom. • The extent of information on testing and effect appears limited in scope given the scale of the London Resort scheme. Consideration of what information should have been provided but has not is as important as what has been provided. Examples include a lack of firm commitment to improved bus services and mitigation works at the ASDA (Tilbury) roundabout which could include traffic signals. • The lack of firm commitment to new or improved services in the Bus Strategy Plan could prejudice achieving assumed non-car travel levels. The London Resort Transport Assessment does not consider the impact on Fast Track or other bus services in terms of delay because of traffic congestion. • The traffic analysis including micro-simulation testing does not consider or report on the possible impacts of diversion of traffic onto other routes as a result of Resort traffic. This is one of the issues with the nearby Bluewater shopping centre. The diversion onto local roads would have an adverse effect on the reliability of buses from the east of Amazon’s former Littlebrook Power Station and would impact on traffic conditions, with Amazon staff from the site relying on these routes and services. • Traffic testing is unsatisfactory in general and especially in respect of the ASDA (Tilbury) roundabout as examining only standard commuter peaks misses both peak Resort activity periods and potential combined base and resort combinations. From work undertaken by PEP at the ASDA roundabout is known that the hours tested for the Resort are not the actual peak traffic periods. • Testing only standard commuter traffic peaks is not good practice for critical junctions. Given that the Resort will be a seven-day week operation and that Amazon operates in the same periods, flows should be examined at other times on weekdays and also Saturdays and Sundays. In addition, a review of the ASDA (Tilbury) roundabout traffic data used shows that the base flows used are incorrect and need to be reviewed. • The Resort has indicated that, other than for on-site hotel residents, there will be no visitors before 10.00. Given the peak hour restrictions at both Amazon sites, it is suggested that the London Resort should accept a condition not to open facilities prior to 10.00 other than for the on-site hotels. • In addressing parking demand, the difference in 85th%ile and peak day accumulation appears less than in visitor numbers. Car parking management appears to rely on an advanced booking system. The potential for off-site parking is considered on the Kent side, but not for Tilbury. Even with a booking system, the Tilbury car park would be disproportionately attractive for visitors from the north and east, especially given issues with the Thames Dartford Crossings and A2 junctions. The forecast parking accumulation for the Resort as a whole and hence the Tilbury parking, needs detailed examination. • The proposed Tilbury car park raises serious traffic concerns for Amazon’s Tilbury site given the non-standard peak timing of Amazon and future Resort traffic. The results given in the Transport Assessment are of little value. Identification and testing of actual likely overall peak periods are required to correctly consider the impact on the network. • Given the proximity of the Resort to the Dartford Crossing and the highway capacity issues in this area identified by Highways England, a robust assessment of traffic associated with the proposed Resort is needed to identify whether there is a need to implement highway improvements, including at locations already identified for improvement by Highways England, or whether highway restrictions are required.