Representation by Greater North Kent Partnership (Greater North Kent Partnership)
- Date submitted
- 31 March 2021
- Submitted by
- Local authorities
This relevant representation is submitted on behalf of the Greater North Kent Partnership (GNKP). GNKP is a partnership of local authorities in North Kent, comprising Dartford, Gravesham, Maidstone and Swale borough councils and Medway unitary authority. The contents of this submission are completely without prejudice to any Relevant Representations submitted jointly or separately by the local authorities included in the Partnership. This submission reflects areas of the Resort proposals that will be of particular interest for GNKP – including economy, transport and infrastructure, skills and environment – pursuing aspects of the work of its predecessor, the Thames Gateway Kent Partnership, which is formally wound up on 31 March 2021. Although the DCO application is accompanied by a large volume of documentation that was not available at the time of statutory public consultation in autumn 2020, considerably more information needs to be provided and additional assessment carried out for the impacts of the proposals to be fully understood. GNKP’s more detailed representations are likely to include the following issues. Transport and infrastructure • The sustainability of the transport strategy, approach to mode share and contribution towards the achievement of net zero carbon. In particular, we do not consider that the transport strategy gives sufficient detail about or attention to rail travel as an integral component of the strategy. The projections of peak journeys by visitors and staff do not compute with the overall projections of mode share and visitor numbers or staff headcount. • Approach to traffic modelling: the application documents provide insufficient clarity about modelling to inform assessment of the highways impacts. This will need to be updated to reflect revisions by Highways England of the Lower Thames Area Model developed for the proposed Lower Thames Crossing, with a clearer assessment of the interrelationship with the Lower Thames Crossing and its impact on Resort-related travel patterns and behaviours. • How peak day transport pressures – i.e. beyond the “85th percentile day” used for modelling purposes – will be actively managed. There is insufficient detail on this. • The approach to rail and in particular the potential use by staff and visitors of North Kent Rail Lines which directly connect the Resort to Central London, as well as providing access from stations both westwards into London and eastwards to Medway and beyond. This includes the implications for rail interchanges (including Swanscombe Station in particular) as well as for services. The absence of well developed proposals for enhancing access to the Resort from Swanscombe Station is especially disappointing. • Potential synergies with, and implications for, the connectivity options being explored in the Abbey Wood to Ebbsfleet Connectivity Study sponsored by the Ministry of Housing and Local Government, including potential extension of Crossrail services. A separate submission is being made by the C2E Partnership specifically addressing this. • The implications (e.g. of the proposed Ebbsfleet Multi Storey Car park (Work No.23)) for the objective to create a pedestrian link between Northfleet Station and Ebbsfleet International Station to improve connections between the North Kent Line train service and the Ebbsfleet international services and HS1. This link would also be critical to the successful delivery of a Crossrail extension to Ebbsfleet as Crossrail trains would have to stop at Northfleet. • The implications of additional Resort-related journeys on HS1 rail network capacity at both peak and non-peak times. • The assumptions underpinning proposals for access via the River Thames, and how the envisaged river-based mode share might be achieved. Environment and sustainability • More scrutiny is needed of impacts of the development, the scale of benefits that enhancements might deliver, and the adequacy of mitigations proposed. More specific and explicit commitments are needed regarding mitigation measures and compensation. This has become more significant with the notification of the Swanscombe Peninsula as an SSSI, subject to confirmation. • Impacts on neighbouring communities both during construction and operation of the Resort including noise, light pollution and air quality impacts. • The approach to energy strategy, zero carbon and use of offsite mitigation measures to offset carbon emissions. There is a lack of detail about the offsite measures proposed, but the significant dependence upon them indicates that the benefits of those mitigations will not be enjoyed by the local communities impacted by the Resort. • There is a deliberate lack of precision about the design of development beyond the Gate One payline: more detail is needed for the impacts to be fully understood and assessed. Socio-economic • The implications for wider ambitions for Ebbsfleet Garden City, and particularly the proposed commercial centre around Ebbsfleet International Station. • The implications for the North Kent Enterprise Zone sites at Northfleet Rise, which has been included within the DCO Order limits (#40 in Appendix 6.2.21.1), and Northfleet Embankment West which lies within 200m of the DCO Order limit (#39 in Appendix 6.2.21.1). The application shows no recognition of the enduring enterprise zone designation of these sites and associated development aspirations. • The approach to securing employment opportunities at all levels for a locally-based workforce, both to minimise longer-distance work-related travel and to contribute qualitatively to the North Kent jobs market. • The impact on businesses displaced by the Resort. • The impact on local housing markets and associated infrastructure requirements. • The impact of development in front of the Resort pay-line on existing food, beverage and retail centres across Kent and Medway. • The impact on visitor accommodation supply and demand across Kent and Medway.