Representation by Essex County Council (Essex County Council)
- Date submitted
- 23 February 2023
- Submitted by
- Local authorities
Essex County Council’s Relevant Representation The Lower Thames Crossing (LTC) scheme as proposed represent a huge step change for how vehicles can cross the Thames, giving an alternative to the current Dartford Crossing and providing a direct link between Junction 29 on the M25 and the M2 in Kent with two lanes being proposed southbound and three northbound. The connection will be made by tunnel under the River close to the village on East Tilbury in Thurrock, a Unitary Council. Nevertheless some of the route will be formed in Essex where the M25 intersects with the A127 at Junction 29, and the impacts this proposal will have on the free flow of vehicles and trade across the River is hugely significant and considered, for the most part, to be beneficial, and is supported by Essex County Council (ECC) Highways and Transportation As a Highways and Transportation project the service area within ECC continues to review the DCO application documents, as will be appreciated there is a lot of information contained within the application. Clearly in reviewing the DCO application, and other information that has been provided we will continue to have questions, and hence will continue to request clarifications or more detail on certain points as necessary. Engagement on this DCO submission has been proactive and positive, made so by the applicant entering into a Planning Performance Agreement for both pre and post submission work, with post submission discussions on going. This has engaged us to properly engage and produce a comprehensive Statement of Common Ground with the applicant at this time. From a transportation perspective we agree in principle with the aims and objectives of the project and fully support the need for a further crossing of the Thames. The current crossing arrangements are acting as a break on the movement of people, goods and services and as such restricting economic development at a regional and national level. We do however have concerns and in general these concerns which we will raise throughout the DCO and at hearings. These concerns should not come as any surprise to the applicant as they have been a common thread through responses made to all statutory and non-statutory consultations. Our concerns are as follows: • M25 Junction 29: The proposed east to south slip lane, i.e. A127 westbound to M25 southbound, raises issues for both us and Brentwood. The original proposal severed access to the proposed Brentwood Enterprise Park, a main employment site for Brentwood. We acknowledge that progress has been made in resolving this issue. We await a formal plan to confirm access arrangements will be completed to all parties’ satisfaction. • Reduction of lanes southbound: We do not support the change which came in one of the design changes whereby the southbound section from J29 has been reduced from three to two lanes. We assume is driven by cost pressures. National Highways have rejected any discussion on this matter. We accept that the modelling shows the that three lanes are not currently required but all other data shows that three lanes will be required eventually. We believe that it is short sighted to not at least provide passive provision at this stage, increasing the number of lanes in the future, which will almost certainly be required, will be a costly and disruptive process. • Sustainability & role of public transport: As stated whilst the project provides necessary additional capacity crossing the Thames the lack of public transport provision is a missed opportunity. The project must engage with bus operators and larger businesses about ensuring that the many newly generated trips between north Kent and South Essex can be managed by bus services. In terms of cycling, thought should be given to how cyclists can get through the tunnel and all cycling infrastructure must be designed to LTN 1/20 standards. There has been an improvement in the limited cycle facilities that the project is implementing with LTC accepting the need to try and meet LTN 1/20 standards but no noticeable change in the position for public transport. • Construction traffic plans: There are concerns over the suitability of some routes shown – Beredens Lane as one specific example. We await updated construction management plans, but the routes used must be fit for purpose. Beredens Lane, as a rural single-track road is not. • Orsett Cock Junction: Whilst this junction is within the Thurrock area, we share the concerns expressed by Thurrock on the future operations of this critical junction noting that the modelling indicates serious issues regarding the operation of the junction from completion of the project. We are currently reviewing this in detail but will require further assurances from National Highways on plans for this junction. • Link to the Port of Tilbury: Although located in Thurrock, we opposed to the removal of the connection to the Port. We request some form of assurance that this will be revisited in a future round of the Roads Investment Strategy. We understand that the revised plans released as part of the next consultation exercise will show a change in this area. • ECC network: We have conducted a review of the traffic data and models. This has shown some areas of concern with increased traffic levels impacting on our network and some areas and junctions that will start to operate over capacity. National Highways have been clear that no mitigation outside of the red line boundary will be considered, this is an unacceptable position to take. We request that appropriate forms of mitigation are formally looked and implemented, through the DCO if feasible interventions are found to be available. Junctions within ECC cordon impacted by LTC The table below shows change in ratio of flow to capacity (RFC) between the Do Something and Do Minimum scenarios which has been calculated to identify locations where the forecast junction performance deterioration is most pronounced in terms of junction performance. The following criteria has been applied to identify junctions where operational performance worsens: • one of the arms both exceeds a RFC of 85% and • this RFC has increased by more than 5% compared to the Do Minimum scenario. ? The junctions with the highest forecast change in RFC for the Do something compared to the Do Minimum model in the AM and PM peaks are: JUNCTION AM RFC % DM) B1007 Stock Road Southbound to Ingatestone Road junction 100% (82%) Wigley Bush Lane Northbound to Weald Road 101% (74%) A13 westbound merge from A176 junction 135% (118%) M25 Southbound off slip to A12 100% (91%) M25 Southbound off slip to A12 96% (75%) A176 Roundacre Northbound to Upper Mayne roundabout 96% (85%) Downham Road Southbound to Dowsetts Lane / Hawkswood Road junction 101% (91%) PM RFC % (DM) A13 Westbound merge from A132 junction 104% (90%) A13 Westbound merge from A176 junction 104% (66%) A12 Eastbound merge from A1023 junction 100% (88%) ECC remains in discussions with the applicant on the above matters. Environmental concerns From a wider environmental perspective discussion on a number of topics are on going but at this time the following area raised: • ECC remains concerned that the socio economic impacts of the development and the benefits that could be raised by skilling the local labour force current lack opportunity for Essex residents. • ECC is keen to understand and maximise the legacy of skills, training, employment, directly and indirectly (e.g. through wellbeing from employment). The legacy aspect of the original draft Strategy was perceived to lack emphasis. • ECC has requests clarification of NH’s plans for archaeological investigation work at the site of Hole Farm. This is in recognition of the expansion of the proposed order limits to include this site for environmental mitigation purposes and open space. • ECC requested a comprehensive and coherent cycling network linking south Essex authority areas as part of the Project, or the ability to pursue these via designated funds, in its response to the 2021 Community Impacts Consultation. • The use of Bereden’s Lane and the linking rural highway network for traffic associated with the construction of the scheme is located within the Green Belt where the impact on the environment and on local amenity is considered wholly unacceptable.