Representation by Kent County Council (Kent County Council)
- Date submitted
- 14 June 2024
- Submitted by
- Members of the public/businesses
Submitted via online form only. Dear Sir / Madam Re: Application by Cory Environmental Holdings Limited (CEHL) for an Order Granting Development Consent for the Construction and Operation of Carbon Capture Plant, Storage and Marine Export Terminal – Relevant Representation Submission Following the Planning Inspectorate’s acceptance of the application for a Development Consent Order (DCO) for the Cory Decarbonisation Project, Kent County Council (hereby referred as the ‘County Council’) requests to be registered as an Interested Party at the Examination. This letter provides a summary of the main aspects of the proposal which the County Council agrees and/or disagrees with, together with an appropriate explanation, in accordance with Planning Inspectorate Advice Note 8.3. In summary, an outline of the principal submissions which the County Council intends to make in relation to the application will concern: • Highways and Transportation – as Local Highway Authority for Kent Highways and Transportation Landside Transport Environmental Statement Chapter With regards to the ‘Policy and Guidance’ in section 18.2 of the Landside Transport Environmental Statement (ES) Chapter, please note that the Dartford Local Plan 2024 to 2037 was adopted on 22nd April 2024. The applicant has provided further information as to why the proposed jetty cannot be used to transport construction materials. However, the County Council would continue to encourage the applicant to consider how to utilise the jetty for at least part of the construction works, given how constrained the local road network is along the A206 Thames Road / Bob Dunn Way, through which a significant proportion of construction-related traffic will be routed. The highway links within the Study Area which have been assessed include, but are not limited to, A2016 Bronze Age Way, A206 Thames Road and A206 Bob Dunn Way. It is noted and agreed that Automatic Traffic Counts (ATCs) 13-16 have been undertaken on the part of the road network for which the County Council is the Local Highway Authority. Given the level of peak hour trips anticipated along the A206, and the known congestion issues in this area, the County Council questions the lack of any Manual Classified Counts (MCCs) at the A206 Thames Road / A206 Bob Dunn Way / A2026 Burnham Road junction or the A282 J1a. The traffic impact at these junctions should be set out. Table 18-16 shows the staff trip distribution. This is based on the previous Riverside 1 and 2 assessments. As previously requested, the accuracy of the distribution and subsequent assignment onto the road network should be checked against more recent data sources, such as the 2021 census. Furthermore, the County Council would request the inclusion of the percentage of staff trips expected to use the A206 towards J1a of the M25. Table 18-7 shows the worst case peak daily construction traffic attraction. This shows 489 daily two-way traffic movements on the A206. The equivalent figure for the operational phase is 30, which is considerably lower. The County Council’s concerns regarding the application relate to the potential construction impacts, rather than the operational impacts. A percentage impact assessment has been undertaken and is presented in Table 18-21. It is assumed that this is for daily, rather than, peak hour traffic movements. This shows a maximum impact of 1.8% on the A206 Bob Dunn Way. However, this should be viewed in the context of the existing heavy traffic flows on the A206 and even this magnitude of impact may add to congestion and delay. Transport Assessment Table 6-3 of the Transport Assessment shows the HGV construction trip attraction across the peak hours. It shows a peak of between 0700 to 0900, which coincides with the morning peak period of the network. Consideration should be given to minimising / removing HGV movements during network peak hours. The A282 J1a already experiences significant congestion at peak times and there is a working group consisting of the County Council, Dartford Borough Council, National Highways and the London Borough of Bexley, aiming to design a scheme to ensure the junction operates within capacity. The group is seeking financial contributions from developments which have a significant impact on the junction. However, the A282 J1a is not referred to in the assessment. Table 6-5 shows construction trip attraction at junctions where MCCs were undertaken. Given that the results of the ATCs for the A206 Bob Dunn Way show an increase of 230 two-way movements during the AM peak hour and 229 during the PM peak hour, and the known congestion in this area, the impacts on the A206 Thames Road / A206 Bob Dunn Way / A2026 Burnham Road junction and the A282 J1a should be provided to the County Council for review. This should include the peak hour of the A206 which may be different to that in Bexley. Junction capacity assessments are undertaken in section 7 of the Transport Assessment. No assessment has been undertaken for the performance of the junction of the A206 Thames Road / A206 Bob Dunn Way / A2026 Burnham Road, nor the A282 J1a. Given the forecast increase in traffic movements through these junctions, capacity assessments should be undertaken to assess their performance. Without this, the County Council has not been provided with sufficient evidence to demonstrate that the proposal will have an acceptable impact on the local road network in Kent. As set out above, the County Council has serious concerns about the peak hour impacts on the junction of the A206 Thames Road / A206 Bob Dunn Way / A2026 Burnham Road, and A282 J1a. However, it is noted that whilst the assessment is based on staff arriving/departing during the peak hours, realistically, “the daily construction operating hours are from 07:00-19:00”. In addition, no staff trips are predicted to use the A2026 Burnham Road and the County Council questions whether this is realistic given that the site may attract construction workers from Dartford. Further information should be set out to demonstrate what the realistic trip generation is likely to be at the two junctions above. Given the congestion and sensitivity of this particular area of Dartford, the applicant should consider a planning requirement to restrict peak hour traffic movements, to give comfort to the County Council that the impact would not be significant. Framework Construction Traffic Management Plan It is noted that the Transport Assessment proposes a Construction Traffic Management Plan (CTMP) to mitigate the construction impacts. A Framework Construction Traffic Management Plan (FCTMP) has been submitted for review. Although this is a Framework for the development of a full CTMP upon the appointment of a contractor, the key principles should be clearly established in the document. It is considered that additional detail is needed at this stage in order for the County Council to agree that it could successfully mitigate the potential impact on the local road network in Kent. The potential for HGVs to route along the A2026 Burnham Road through Dartford town centre is a particular concern and it is unsuitable to accommodate a significant increase in HGV movements. Overall, the information provided in the FCTMP on construction vehicle routes and access is minimal. No routing plans or any other figures / location plans are provided within the FCTMP. Routing plans should be provided within the FCTMP showing the route to/from the site, including to/from the M25 i.e. using the A206 Bob Dunn Way, with no HGVs to route through Dartford town centre. Information should be provided regarding restrictions (e.g. for local roads) and how these will be monitored. In the ‘Implementing, Monitoring and Updating’ section, the FCTMP lists data that will be collected through the full CTMP including vehicle movements, non-compliance, accidents and workforce travel patterns. Reference to a robust monitoring system should be made and this should be detailed in the full CTMP and developed in consultation with the County Council as one of the local highway authorities. It is suggested that a Traffic Management Forum is established to ensure regular liaison with key stakeholders such as the County Council. The purpose of the Traffic Management Forum would be to evaluate the performance of the CTMP and to implement corrective measures should the monitoring identify any traffic management issues. Further details should be provided regarding the Construction Workforce Travel Plan, particularly given the potential for a significant quantum of car trips associated with the 1,000 construction workers. It should contain a robust set of measures to discourage vehicular travel and promote sustainable transport modes. Waste Management The County Council as Waste Disposal Authority would welcome engagement from applicant regarding future opportunities for this project and the County Council. The County Council would welcome further opportunities to engage with the applicant throughout the progression of the proposal. If you require further information or clarification on any matter in this letter, then please do not hesitate to contact the County Council. Yours faithfully, Stephanie Holt-Castle Director – Growth and Communities