Representation by London Gateway Port Limited (London Gateway Port Limited)
- Date submitted
- 21 February 2023
- Submitted by
- Members of the public/businesses
Introduction and Background London Gateway Port Limited, LG Park Freehold Limited and LG Park Leasehold Limited (collectively hereinafter referred to as DPWLG) are the owners and operators of DP World London Gateway Port (the Port) and DP World London Gateway Logistics Park (the Logistics Park) on the north bank of the Thames Estuary in Stanford-le Hope, Essex. The Port is a Nationally Significant Infrastructure Project (NSIP) and makes a significant contribution to the national economy1. Once fully developed, the Port will comprise deep sea shipping and container handling facilities with an annual throughput that will equate to approximately 27% of the predicted national growth in such trade by 2030. The Logistics Park will provide up to approximately 830,000sq.m of vital commercial floorspace. Both are of national significance and importance. Representation DPWLG are generally supportive of additional river crossing highway capacity and increased network resilience for north/south routes (alternative to Dartford Crossing and M25 Junction 30). However, there are significant concerns over the real potential for ‘severe’ impact on the highway network2, which would in turn lead to significant impacts on the economic activity and future growth of the Port and Logistics Park3, in addition to impacts on the wider economy. DPWLG make the following representations: • Limited and wholly insufficient information has been submitted to show that the impact at the A13/A128 Orsett Cock junction and the A13/A1014 Manorway junction (the Junctions) have been properly assessed. Both are located along a critical route to the Port and Logistics Park3. The application, therefore, fails properly to assess congestion and capacity issues at these Junctions or consider whether and to what extent these impacts need to be mitigated4. • Congestion on the local highway network, due to the proposed LTC development, has the real potential to create significant adverse impacts at the Junctions5, which in turn would constrain the operation of the Port and Logistics Park3. The application does not consider the potential economic impact on the Port and Logistics Park and their essential contribution to the regional and national economy1. • S.3(6) of the Infrastructure Act 2015 establishes a requirement for both the Secretary of State and National Highways to comply with the Road Investment Strategy (RIS). In this regard we highlight that: - RIS2 (2020 – 2025) (Part 1, Section 3, Page 37) sets out proposals for changes to the geographic extent of the SRN including trunking of the A13/A1014 from the end of the trunked A13 through to London Gateway Port - A Performance Indicator for RIS2 relates to “delay on gateway (ports and airport) routes” . The target performance is 97% network availability: “for average delay we have set an ambition for performance at the end of RP2 to be no worse than at the end of RP1. Highways England will be required to demonstrate how it has acted to achieve this ambition.” - The end of the RIS2 period (2025) is in advance of the anticipated first operational use of the LTC (2030). It is therefore necessary to assess the impact on the route comprising the A13/A1014 from the end of the trunked A13 through to the Port and Logistics Park as part of the DCO examination. • There is a need for mitigation solutions at the Junctions6 to prevent accessibility and operational issues at the Port and Logistics Park7. • Impacts during closures of Dartford Crossing (e.g. high wind close the QE2 bridge) must be considered. In such circumstances the level of traffic re-routing via the A13/A128 and A13/A1014 junctions would be likely to be extremely significant. Conclusions The benefits of the LTC cannot be weighed against the significant adverse traffic impacts for the Port and Logistics Park (or as a result the national economy) as the traffic and economic impacts have not been properly assessed within the application8. Further transport assessment work and economic analysis is required to fully understand whether the adverse impacts of the proposed development outweigh its benefits9 and to gauge what, and to what extent, mitigation works would be required to obviate or minimise these impacts to acceptable levels so as not to prejudice Port and Logistics Park related activity contrary to the national interest. Without prejudice to DPWLG’s case that it is for the applicant to establish the acceptability of the scheme having regard to the impacts on its operations, DPWLG reserves the right to adduce any technical evidence that may be necessary properly to inform the decision-making process. Footnotes: 1 Paragraph 1.2 of NPS for National Networks confirms other NPS statements may be relevant to decisions on NSIPs. Paragraph 3.3.6 of National Policy Statement for Ports recognises the essential contribution to the national economy that international and domestic trade makes through the UK’s Ports. 2 Paragraph 111, NPPF. 3 Paragraph 2.16 of NPS for National Networks confirms traffic congestion constrains economic activity and growth, and furthermore the paragraph states that businesses make decisions about where to locate based on good transport connections. 4 Ibid. Paragraph 5.206 confirms the applicant’s assessment should include a proportionate assessment of the transport impacts on other networks as part of the application. 5 Ibid. Paragraph 5.212 confirms any assessment should consider local transport models. Manorway junction has not been assessed as part of the submission, despite pre-submission consultation highlighting this junction and congestion as a potential issue. Initial review of microsimulation assessment provided by LTC to Thurrock Council suggests that LATM is significantly over-estimating the capacity of these junctions and therefore the overall validity of the LATM is questioned. 6 Ibid.Paragraphs 5.216 – 5.217 confirms where development would worsen accessibility such impacts should be mitigated so far as reasonably possible. 7 Ibid.Paragraph 5.214 confirms if the applicant is willing to commit to transport planning obligations to mitigate transport impacts identified in the WebTAG transport assessment with attribution of costs calculated the development consent should not be withheld. 8 Ibid. Paragraph 4.3. 9 Ibid. Paragraph 1.2.