Representation by Dover District Council (Dover District Council)
- Date submitted
- 23 February 2023
- Submitted by
- Local authorities
1.1 Dover District Council (DDC) supports the need for the Project and the objectives set, however, does not intend to comment on the detailed alignment and the local study area impacts. 1.2 DDC cannot emphasis enough the that the Port of Dover is one of the largest international gateways serving the UK and is of strategic importance for goods and tourist connections to Europe; yet the impact on the strategic road network (SRN) and on port traffic has not been taken into detailed consideration. Although the impact on the SRN (A2 and A20) has been modelled and tested, with the significance of these routes to the Port having been acknowledged, there are no road upgrades being proposed within the district. 1.3 Significant concerns are raised that part of the A2 - Lydden to Dover is single carriageway creating a bottleneck effect for increased movements caused by the LTC. DDC have continually requested that the A2 needs to be upgraded to a dual carriageway. 1.4 The SRN junctions within DDC on the A2 are already overcapacity at Whitfield and Duke of York roundabouts, this has been acknowledged by NH and traffic modelling has confirmed this. The local plan and developments have been significantly held up over recent years due to needing to find a junction mitigation scheme to offset further increases in capacity on these junctions. Initial modelling identified a potential 10% increase at these junctions as a result of the LTC, this is significant and should not be screened out of the project assessment. 1.5 In the submission documents any upgrades to the SRN (A2) are identified for consideration under RIS3 proposals. There is currently no guarantee that the upgrades needed will be forthcoming as a RIS3 scheme and this is of strategic importance. DDC require any RIS3 scheme to be implemented alongside the LTC and need to ensure that the A2 upgrades are implemented. 1.6 A strategic and linked up approach between different highway projects is required. The importance of this has been raised with Ministers by the Leader of DDC, along with wide coverage in the national press in relation to traffic problems associated with the Port (Operation Brock/TAP and demand for ferry crossings over holiday periods, with problems expected to worsen). LTC proposals will add to these existing problems, affect the district and have a serve impact on the local economy. 1.7 The resilience of the network is critical to the district, operation of the port and SNR. The fragility of the SRN network serving Dover cannot be underestimated and there is a need to future proof this network to serve the UK and the strategic port. 1.8 DDC are disappointed that the impacts of the LTC on the Dover SRN have not been fully identified and that NH have failed to provide any of the required solutions or possible funding for the highway improvements needed. 1.9 DDC fears that there would be an impact on the local community and the environment with congested roads and poor air quality. There is evidence that congested roads leads to freight being unable to reach their destination in a timely manner and will have a negative impact on commercial business for the Port and the UK economy as a whole. 1.10 DDC request improvements to the SRN to ensure that the LTC does not hinder DDC’s housing growth agenda due to overcapacity at key junctions. 1.11 The concerns raised would therefore be likely to result in an unacceptable impact on highway safety and the residual cumulative impacts on the road network would be severe, with no mitigation identified or considered as part of this DCO, contrary to paragraphs 110 and 111 of the NPPF and local Development Plan policies. 1.12 The Inspector’s are therefore respectfully requested to consider these matters in the process.