Representation by Tarmac Cement and Lime Ltd (Tarmac Cement and Lime Ltd)
- Date submitted
- 17 February 2023
- Submitted by
- Members of the public/businesses
Tarmac have significant operational plant and consents for development in both the Kent and Essex Areas affected by the LTC proposals. These facilities depend on the efficient delivery of construction materials and building products across the UK. A significant proportion of the deliveries that they make are necessarily by road and therefore additional delays on the network arising from the scheme will have a detrimental impact on those operations. Whilst the LTC proposals will improve network resilience for north/south routes (alternatives to Dartford Crossing and Junction 30 of the M25), Tarmac have significant concerns relating to the impacts the scheme will have on local roads and networks which are shown to experience significant or material increases in traffic flow (and hence delay) but have not been mitigated to any extent. By way of example a specific concern is the A228 corridor. Here the company operate a significant Asphalt and Concrete Plant (Ham Hill) and have planning consent in Snodland (Kent County Council Planning Reference: TM/98/785) for a new Cement Works. That consent was granted by the then GOSE following appeal in November 2001. Whilst the works themselves have not been commenced the consent itself has been implemented by virtue of the implementation of the site access roundabout and associated railway infrastructure. When fully operational the site has the capacity to produce circa 1.4 million tonnes of cement per year to service demand across the south east region. Whilst a significant proportion of this will be exported by rail, the overall traffic generation in peak hours is upto 82 HGV movements per hour. This will all be focused on the A228 and have not been included in the modelling work. Importantly, the Transport Assessment (TR010032/APP/7.9) confirms that there will modest adverse impacts in terms of driver delay on the A228 on this link. There is no mitigation to consider this. In absence of any formal mitigation to resolve this, it would have a material adverse impact on the operation of the site. The absence of a Transport Section in the ES means this impact has not been properly considered in the overall assessment of scheme impacts. This is a flaw in process. The proposed approach to review of strategic highway infrastructure (Examination Document TR010032/APP/7) is a wholly inadequate way to address these impacts and consideration of mitigation to deal with the issue is required prior to determination of the DCO.