Representation by C2E Partnership (C2E Partnership)
- Date submitted
- 31 March 2021
- Submitted by
- Members of the public/businesses
Relevant Representation from C2E Partnership – 31 March 2021 INTRODUCTION 1. This Relevant Representation has been prepared on behalf of the C2E Partnership and its contents do not prejudice any Relevant Representations submitted separately by members of the C2E Partnership. 2. The C2E Partnership was formed in 2016 as an informal group of authorities to promote an extension of the Elizabeth Line beyond its current planned terminus at Abbey Wood towards Ebbsfleet. It is comprised of stakeholders that represent local communities in the area including: • London Borough of Bexley • Dartford Borough Council • Gravesham Borough Council • Ebbsfleet Development Corporation • Kent County Council • The Greater London Authority • Thames Gateway Kent Partnership 3. The Partnership also works closely with public transport infrastructure providers, particularly Network Rail and Transport for London. 4. In 2019, Government allocated funding for the preparation of the Abbey Wood to Ebbsfleet Connectivity Study to assess and develop a range of different transport options (including both Elizabeth Line extensions and lower cost options) in order to support new housing and employment growth along the corridor. The C2E Partnership is responsible for the delivery of the Connectivity Study and has appointed consultants to take forward the technical work. ABBEY WOOD TO EBBSFLEET CONNECTIVITY STUDY 5. The London Borough of Bexley, and the boroughs of Dartford and Gravesham, supported by Kent County Council and the Greater London Authority, have plans to support more jobs, make their town centres more attractive and build more high-quality homes for their communities. 6. Improvements to the transport network in these boroughs aim to support these plans by: i. Making it much easier to travel by public transport to key locations along the route, including Ebbsfleet International, Dartford town centre, health and education facilities and many key employment locations within the area ii. Improving journey times and connections into central London, Canary Wharf and Heathrow Airport and within the local area iii. Attracting more investment and supporting plans for the development of new homes, jobs and leisure facilities, including new town centres at Belvedere and Ebbsfleet iv. Supporting and enhancing the quality of existing town centres in the area including Erith and Dartford v. Reducing reliance on the car, thereby reducing carbon emissions, improving air quality and health 7. The Connectivity Study has assessed the potential for different transport options to meet these aspirations. 8. In summer 2020, a longlist of potential options to improve the transport network in the study area was drawn up. This longlist was subject to high level assessment and sifted down to eight broad options for further consideration. 9. The eight options were then subject to further assessment in autumn 2020 and following a detailed appraisal process five options were selected for further development: i. three options involving different ways of extending the Elizabeth Line from Abbey Wood to Dartford and/or Northfleet/Ebbsfleet ii. one option to improve National Rail services (with no change to the Elizabeth Line) iii. one option to provide a new Bus Rapid Transit (BRT) service with no changes to rail services. 10. These schemes were subject to a public consultation in February 2021 (https://www.abbeywood2ebbsfleet.com/) and as part of this details of the schemes were shared with the developers of the London Resort. Comments were received from the London Resort Company Holdings Ltd (LRCH) (26 February 2021) which provided a summary as follows: “LRCH is proposing to develop a global entertainment resort on the Swanscombe Peninsula. It has developed a credible business plan supported by a robust transport strategy that draws upon many modes of travel. LRCH actively monitors the development of major transport infrastructure in the South East, including LTC and the extension of the Elizabeth Line to Ebbsfleet. LRCH actively supports the principle of increased investment in major transport infrastructure in and around the Swanscombe Peninsula and recognise the benefits these may bring to the area as a whole and the Resort, however it is not dependent upon the delivery of such measures for the successful implementation of its own transport strategy and operation of the Resort. LRCH’s preference is public sector investment to ensure the delivery of Options C1 [segregated Crossrail extension to Ebbsfleet] and Hybrid G1/G2 as both are required to deliver multi-modal transport improvements to the Ebbsfleet area that will ‘unlock’ the true extent of the economic dividend offered by the Resort and other planned and future development.” 11. The results of the consultation process are being incorporated into a further detailed appraisal of each scheme. The results of this appraisal process will enable three options to be identified for further analysis and the preparation of a Strategic Outline Business Case which is to be submitted to the Ministry of Housing, Communities and Local Government and the Department for Transport in autumn 2021. 12. All of the options currently being assessed have the potential to complement the delivery of the London Resort proposals. This means that there is the potential to maximise the benefits of investment in public transport services to meet the needs of London Resort and support the wider aspirations for growth and development in the Abbey Wood to Ebbsfleet Corridor. However, the impacts of this require full assessment to ensure there is no harm to existing communities and that the quality of the existing public transport services is not undermined. ? ISSUES FOR FURTHER CONSIDERATION 13. Following a review of the documents submitted as part of the DCO application we recommend that the following issues are further considered during the DCO process: i. Impact of London Resort on Rail Services. Para 1.3.5 of the Appendix TA-U Rail Strategy Plan [Document 6.2.9.1] shows that rail modelling work is ongoing and was not completed at the time of the submission of the DCO application. This suggests that it is not currently possible to determine the impact of the London Resort on the rail network. This information should be issued so that the potential for the improvements being developed by the C2E Partnership can be considered and the impacts of LRCH on rail services and the rail interchanges can be assessed. This may require a further model run(s) to determine this impact. We note that the Land Transport report [Document 6.1.9] has not considered the potential impact of the C2E Partnership proposals as part of the development of the strategy except to say there is no impact on the safeguarding proposals (see paragraph 9.371). There has also been no consideration of the project peak flows arising from London Resort (which is important given the scale of the workforce) and how this might impact on the C2E options. Given the size of the potential change to the corridor related to the C2E proposals, we consider the potential for different scheme options to support the delivery of London Resort should be considered in more depth and whether the proposed transport strategy for the London Resort maximises the potential for access by public transport for visitors and staff. ii. Ferry Proposals. The London Resort proposes that 25% of car passengers should travel via a new ferry between London Resort and Tilbury (see paragraph 9.235 of 6.1.9). Other visitors would be expected to travel by ferry from central London. The DCO documents states that seven new 400-seat ferries (page 5 of Appendix TA-W document 6.2.9.1) would be required to deliver this service together with a likely need for additional piers. There would also be considerable ongoing operating costs to deliver the ferry service. This will require considerable capital and operating cost investment by London Resort and we note that there does not appear to be any commitment to this in the draft Development Consent Order (DCO). We recommend that the level of this investment should be identified and then the potential to invest a similar (or lower) level of money in public transport services on the south side of the River Thames should be considered to determine if it could yield enhanced public transport services for visitors and staff to the London Resort and also provide significant support to the development and growth aspirations for the Abbey Wood to Ebbsfleet corridor. More details of the ticketing strategy should also be provided to understand the attractiveness of a ferry service from central London compared to using the rail network to reach London Resort. It is noted that there is a reliance on ferry services to meet a proportion of the target modal share which in itself presents a risk to the public transport network if the ferry service is not secured or protected or is disrupted. iii. Swanscombe rail station. This station lies on the southern boundary of the development site and we consider that the potential to use this station more actively as part of the transport strategy for London Resort should be considered in more detail. Again, the peak flows of visitors and workers are likely to have an important impact on the station and these have not been fully assessed. Potential changes could include upgrading access arrangements at the station. This would complement proposals to improve the frequency of rail services to the station as part of the C2E proposals. It is disappointing given its proximity to the Resort that Swanscombe Station is not included within the DCO Order limits so that innovative solutions could have been considered. iv. Impact of London Resort on bus services, including Fastrack. We consider that further work should be completed to consider how the bus service proposals proposed as part of the C2E partnership could complement the arrangements proposed for London Resort. Further assessment needs to be undertaken of the Resort proposals on the existing bus services (including Fastrack) and the interchanges served by the buses, with a sensitivity test carried out of how the C2E proposals might create further impacts. This could lead to synergies from bus service enhancements which serve the needs of staff and visitors to London Resort and residents and employees in the Abbey Wood to Ebbsfleet Corridor. This assessment should consider the potential to build on the success of Fastrack and identify the need for further infrastructure and / or operational requirements and the potential sources of funding which would be required. v. Impact on the link between Northfleet Station and Ebbsfleet Station. We also consider that the Ebbsfleet Multi Storey Car park (Work No.23) could prejudice the objective to create a pedestrian link between Northfleet Station and Ebbsfleet International Station. This link provides a connection between the North Kent Line train service and the Ebbsfleet international services and HS1. The pedestrian link is critical to the successful delivery of a Crossrail extension to Ebbsfleet as Crossrail trains would have to stop at Northfleet. vi. Potential for Tax Increment Financing (TIF), e.g. via a London Resort ‘Enterprise Zone’. Upgrading the public transport network to improve the sustainability of the Resort will require funding, at a time of significant fiscal pressure. The proposed Resort, an NSIP, is a standalone investment that is likely to pay a significant amount annually in business rates. There are precedents in the use of an Enterprise Zone as a TIF mechanism, alongside established developer contribution mechanisms such as s106, in order to help fund the public transport improvements needed to unlock major national infrastructure projects (such as Battersea Power Station redevelopment). These public transport network improvements will be needed early in the implementation of London Resort, so an appropriate financing structure will need to develop to fund the improvements ahead of the business rates accruing. vii. Safeguarding. The safeguarding and future proofing measures required for an extension of Crossrail should be secured through the DCO and they are not included at present. viii. Transport targets. The modal shift aspirations expressed by the applicant are not secured through the DCO and have not been subjected to any sensitivity testing on the wider public transport network.