Representation by Medway Council (Medway Council)
- Date submitted
- 27 January 2023
- Submitted by
- Local authorities
This Relevant Representation outlines the main issues for the Medway unitary authority area relevant to the proposed Lower Thames Crossing (LTC). It is understood that the Relevant Representation will be used by the Examining Authority to carry out an initial assessment before the Preliminary Meeting. Medway Council anticipates making further written representations during the Examination that will expand on this Relevant Representation. The following matters are agreed: Need for the proposed LTC • Medway Council supports the need for the project. Nitrogen deposition • A landscape scale compensation approach, rather than a series of scattered sites, is more likely to deliver multiple benefits. • Compensatory land should be publicly accessible, where appropriate. • National speed limit enforcement between M2 junctions 3 and 4 is being considered by the project team to reduce nitrogen deposition. Consideration of reducing the speed limit, which could have unintended consequences for the local road network, is understood to have been ruled out by the project team. The following matters are under discussion or not agreed: Growth assumptions • It is understood that the project team’s transport model was built following the Department for Transport’s (DfT) Transport Analysis Guidance. • Growth within the transport model is capped in line with DfT traffic forecasts and adjusted locally to account for developments with planning status (as of 30 September 2021). This comprises the Core Scenario which forms the basis of other assessments. • The DfT traffic forecasts represent growth assumptions that are lower than Medway’s development needs and this presents challenges for local plan-making. • Medway Council is reviewing the Uncertainty Log of developments set out within the Combined Modelling and Appraisal Report (Appendix C, Annex A). Air quality • Medway Council is concerned about: the number of receptors modelled in Medway; the absence of any analysis in respect of PM2.5; the need for air quality modelling during construction; and the indicative predictions that exceedance of air quality objectives would occur at receptor locations adjacent to the M2 and the A228 in Medway. Materials, assets and waste • Medway Council is reviewing application documents relating to materials, assets and waste relevant to matters set out in our Statement of Common Ground. Local highway mitigations • National Highways is not committing to any direct additional funding for mitigation of effects on the wider network through the Development Consent Order. • Instead, National Highways refer to existing investment processes and collaborative work with local authorities. • This provides little certainty that local impacts can and will be mitigated. Local highway monitoring and management • Medway Council is reviewing the list of monitoring locations within the Wider Network Impact Monitoring and Management Plan. Toll charging • During a 28 July 2020 briefing from the project team, Medway Council members called for a resident and business discount scheme to be extended to Medway. • It is understood that this would be a decision for the Secretary of State following any decision to grant development consent, and that the DfT may require a consultation.