Representation by Department for Transport (Department for Transport)
- Date submitted
- 31 March 2021
- Submitted by
- Other statutory consultees
The Department acknowledges the national significance of the London Resort Company Holdings (“LRCH”) development proposal. The Secretary of State for Transport owns various property interests that have been included within LRCH’s proposed Development Consent Order (“the DCO”) red line boundary. he Group Property team at Department for Transport (“The Department”) have not been consulted at all regarding the potential acquisition or impact of the proposals to their property interests.?The Department on behalf of Secretary of State for Transport can therefore not support the DCO application as it stands on the basis of lack of information and consultation in relation to its property interests. The Department requests to be registered as an Interested Party to ensure proper consultation is undertaken going forward. The Department is aware however that LRCH has consulted with the Ebbsfleet Development Corporation (EDC) who is the freeholder of much of the land in question and HS1 Ltd, the concession holder and Department’s sub-lessee. The Department, as both long lessee and freeholder of land and infrastructure within the DCO red line boundary, should also have been consulted in a similar manner in relation to its property interests to date. The Department has evidence that EDC sent an email to LRCH requesting contact is made with Department and providing specific contact details on 29 June 2020, but no contact was made. The Department recognises there are a number of complexities which need to be thoroughly considered, mitigated and addressed throughout the lifecycle of the development proposed. Land ownership / property interest concerns The proposed DCO has captured numerous land interests as a category 2 interest (where The Secretary of State for Transport is party to an option agreement). In addition, the Secretary for State for Transport also has category 1 interests (long lessee or freehold) in plots 292, 293, 294, 295, 296, 297, 298, 302, 303, 304, 305, 306, 311, 312 313, 314, 316. It is unclear within the “book of reference” precisely what is intended by LRCH concerning the proposed acquisition of and impact on the Department’s property interests. Inclusion of the phrase “except those owned by the Crown” is used in relation to the plots (listed above). Further clarity is needed on this urgently. There is an option agreement which gives LRCH rights to acquire land for access to the resort, however the proposed DCO appears to be seeking land and rights outside that agreement. Urgent clarity is needed as to how LRCH propose to acquire these and by what means. Furthermore, there is extremely limited information relating to the proposed Multi Storey Car Park or the acquisition of the land on which LRCH propose this is built. Much more information is required in relation to the additional traffic created by the London Resort and its impact on highway capacity. Operational concerns Having not been directly consulted to date by LRCH there is a large number of potential operational issues that we do not have full information on and which raise significant concerns to Department. The existing railway infrastructure, which LRCH itself intends will become one of the main transport links into the Resort, is HS1. HS1 is a high-speed railway, connecting Ebbsfleet International Station to London St Pancras in the North and to the Channel Tunnel in the South. Ebbsfleet International Station is served by both domestic and international rail services. As infrastructure owner, the Department is concerned with maintaining the efficient and effective operation of critical rail services now and into the future, as well as protecting the long-term value of the concession for taxpayers. HS1 is operated as a concession, managed by High Speed 1 Ltd a self-funded infrastructure management company. The Department also has a contract with London South Eastern Railway (LSER) to operate the domestic passenger rail services along the HS1 network as well as the South East of the National Rail network. The Department recognises that there will be a number of direct impacts on HS1, the concession and service provision arising from the LRCH proposals, including (but not limited to): Timetable and service demand. Additional London-Ebbsfleet services will be required to accommodate increased numbers of passengers travelling to and from the Resort. Natural growth. LRCH will introduce a new “leisure” user profile, which will significantly modify the demand strategy which is based on growing commuter traffic. St. Pancras and Ebbsfleet International stations. The proposals will necessitate modifications to existing station facilities such as platforms, ticketing and access facilities in complex environments, including heritage considerations. Ultimately, increased demand could necessitate station expansion and future rail use will need to be safeguarded. Provision of rolling stock. There are costs associated with any extra trains required, as well as the wider impact on operations, stabling and maintenance of additional fleet, all of which will require detailed further analysis. HS1 railway infrastructure. Additional utilisation of railway assets (such as track, signalling etc) would require LRCH contributions to a structure of charges specific to HS1 concession. The Department understands that the HS1 issues mentioned above are being explored further in a joint independent capacity study commissioned by HS1 Ltd/LRCH. The Department has observed three meetings relating to this study where the consultants responsible for the work (Steer Group) have presented some initial findings, but to date there remain many uncertainties and no final conclusions. We note the report is due to be completed in mid-April 2021. In addition, HS1 services are not the only means of travel to the proposed resort and passengers may also choose to use the National Rail network; as such, changes to station infrastructure (such as Swanscombe and Northfleet) and service provision along this network may also be required. As its stands there has been no consultation with the Department on this element. The Department would welcome the involvement of all railway stakeholders and a collaborative approach to exploring feasibility. In conclusion, feasibility studies, as well as more detailed analysis of wider Department interests, commercial and financial consequences for HS1 will be essential to provide confidence that the proposals do not have a negative impact on the successful and safe operation of the railway as LRCH progress their proposed development. Please register the Department as an Interested Party so we can be kept informed of relevant information and hearings that might affects its position.