Representation by Uniper (Uniper)
- Date submitted
- 23 February 2023
- Submitted by
- Members of the public/businesses
The representation has been prepared by Stantec who are working on behalf of Uniper in relation to the MedwayOne development at the former Kingsnorth Power Station on the Hoo Peninsular in Medway. The proposals for MedwayOne are for a commercial development of up to 315,000 sqm (GIA) of floorspace, planning reference MC/21/0979. As of November 2022, it has been granted a “resolution to approve” subject to completion of the S106 and Conditions. Uniper is concerned that the MedwayOne development has been purposely excluded from the Uncertainty Log used to inform the future year trip matrices in the LTAM, as stated in paragraph 5.7.20 of the Transport Assessment. This exclusion is despite MedwayOne meeting the criteria set out in TAG Unit M4 for inclusion in the Uncertainty Log. The application for MedwayOne was submitted and validated in April 2021 and the Uncertainty Log for the LTAM was put together in September 2021, meaning MedwayOne was a live application when the modelling was undertaken and therefore should have been classified as ‘more than likely’ and thus included in the Uncertainty Log. The only justification given for the exclusion was that ‘the development proposals do not include necessary highway interventions that would maintain the integrity of the road network’. At this time, National Highways had not made it known to Uniper that they had major concerns about the integrity of the Strategic Highway Network. In their consultation response dated 04 May 2021, only minor concerns had been raised in relation to M2 J2. The more major concerns relating to M2 J1 were not brought to Uniper’s attention until August/September 2022. Not only had the MedwayOne application been submitted at the time the Uncertainty Log was put together, but MedwayOne is an allocated site in the Medway Local Plan and has been since 2003. Therefore, the rationale for excluding it from the Uncertainty Log is unclear and arguably unjustified. Uniper is concerned that the impact of variety of “known” development schemes have not been considered in the context of the LTC, specifically in relation to M2 J1, in particular: • Extant Allocated employments site(s) since 2003 • MedwayOne submitted Application • Emerging Hoo Development Framework This is particularly important given the changes that are proposed as part of the LTC to M2 J1, and it is therefore highly questionable whether the full impacts of the LTC on M2 J1 have been considered. Uniper also has concerns about the exclusion of the Hoo Development Framework, which MedwayOne is part of, from the LTAM. This is for up to 10,000 homes, employment growth and supporting infrastructure. It is acknowledged that, in accordance with TAG Unit M4, the Hoo Development Framework does not necessarily need to be included in the LTAM Core Scenario due to its current planning status. However, given that Homes England awarded Medway Council circa £170M+ via the Housing Infrastructure Fund (HIF) in 2019 to “unlock significant growth on the Hoo Peninsula”, it seems perverse that a Government funded major infrastructure project (the LTC) should have failed to have regard to this “known” Government funded project in Medway. Given the anticipated level of direct impacts of the Hoo Development Framework and the LTC will have on M2 J1, it is highly questionable as to why alternative scenarios have not been undertaken to consider the potential impacts. Given the above information, Uniper question the soundness of the modelling undertaken by National Highways and the reasoning for excluding their development from the modelling. Uniper wishes to take part in the Examination process and would like to be included in any future consultations.