Representation by Gravesham Borough Council (Gravesham Borough Council)
- Date submitted
- 31 March 2021
- Submitted by
- Local authorities
Gravesham Borough Council in principle supports the London Resort Development Consent Order application on the basis that it will provide significant economic benefits, in particular employment and business opportunities, for local residents and businesses. Some of the impacts will be direct and others indirect, for example poverty and unemployment are among the greatest risk factors when it comes to health. At the same time, as with any large scale development proposal, the Council recognises that there will also be impacts that need to avoided, mitigated or compensated where relevant. The Council’s full views will be set out in the Local Impact Report and written representations at the appropriate time. In the interim, however, this response is intended to set out areas where the Council feels greater detail is needed or there are matters, including process considerations, that need development to assist the Examination Authority. The DCO application is set out using a Rochdale envelope for environmental appraisal purposes, with the much of the detail to be filled in at a later date. For most major infrastructure projects, the local example being the Lower Thames Crossing, the nature of what is being proposed is clear. However London Resort is a commercial leisure resort, to be delivered in two phases, which will change its content over time, and how it is managed could material change the impacts. There is therefore a need to establish: • Interconnections between the various elements of the project – i.e. what needs to be delivered when and what happens if parts are not delivered • Adequate control and monitoring mechanisms to ensure that what is delivered fits the assessed environmental impact and has a set of potential mitigation mechanisms if required • Hours of operation and other operational matters are subject to approval or review as they evolve to ensure the appropriate environmental standards are met A general review of the application has identified a number of areas where additional information and understanding is required. There are a number of references in the documentation to strategies or further work which are not currently available which lead to uncertainty. This should not be taken as implying the Borough Councils sees major issues that cannot be resolved or that further understanding of the proposals may clarify. Attention is also drawn to various Gravesham specific matters. For convenience the numbering and topics follow the Environmental Statement chapters: 7. Land use and socio-economic effects i. How local residents and businesses can maximise the benefits of the resort ii. Implications of additional jobs and visitors on housing needs and housing market pressures (with possible Green Belt implications) and the provision of all types of services iii. Works 23 or 25 provide for the relocation of Ebbsfleet car parking and potential impact on development in the Ebbsfleet Valley, which could therefore impact upon development quantities within Gravesham iv. Impacts on retail and leisure provision in Gravesham 8. Human Health i. The Council is keen to work with the applicant to further understand the health and wellbeing aspects of the project in its construction and operational phases. 9. Land transport i. Strategy for controlling on street car parking needs to be secured ii. Practical operation of the transport strategy especially on days above 85% percentile and the feasibility of enforcing some of the proposed measures needs to explored further iii. Steps to be taken to ensure the proposed modal split is achieved and the implications and alternative options if it is not iv. Ensure new development is fully accounted for in the transport modelling, including the implications of the Governments standard methodology for housing v. Further exploration of the possible impacts on local roads and junctions in Gravesham 10. River transport i. Implications for Gravesend to Tilbury Ferry from the new proposals ii. Potential noise and disturbance implications for riverside properties (existing and proposed) from Tilbury to resort ferry operations 11. Landscape and visual effects i. Scale and massing and implications for views of Gravesham residents (both those in Northfleet towards the site and those in Gravesend across the river to Tilbury) ii. Ensuring minimal light spillage from the site into nearby residential and nature conservation areas 12. Terrestrial and freshwater ecology and biodiversity i. SSSI (and nature conservation in general) compensation and mitigation package and how that balances with the socio-economic benefits 13. Marine ecology and biodiversity i. Implications for the marine conservation area and wider marine environment 14. Cultural heritage and archaeology i. The rich archaeological heritage of the area means that despite previous development and quarrying, major finds could still be made and allowance for this is needed in the construction timetable ii. The resort needs to celebrate the local heritage both within its boundaries and the wider localality 15. Noise and vibration i. Control of construction and operational noise, and the agreement of appropriate mitigation measures to be taken if agreed limits are breached 16. Air quality i. Control of construction and operational air quality, and the agreement of appropriate mitigation measures to be taken if agreed limits are breached 17. Water resources and flood risk i. Implications for flood risk in the flood cell that extends from the resort site east along Northfleet Riverside ii. Ensure water supply and demand proposals do not compromise integrity or supply for existing and future residents 18. Soils, hydrology and ground conditions i. The pulverised fuel ash (PFA) on Swanscombe Peninsula is highly alkaline and has significant implications in construction on workers, residents, wildlife and any structures upon it 19. Waste and materials i. The practical outworking of the waste strategy is unclear 20. Greenhouse gases and climate change i. Gravesham, having declared a climate emergency, would expect to see a carbon balance for those parts of the scheme in the Borough not just overall 21. Cumulative, in-combination and transboundary effects i. Ensure that the environmental and transport assessments take sufficient account of local development ii. Proper account is taken of wider development that will need to use the A2 as primary link in the strategic road network iii. Robust strategy to deal with both the implications of Lower Thames Crossing opening in 2029 and what happens if it is not built