Representation by Greater North Kent (Greater North Kent)
- Date submitted
- 23 February 2023
- Submitted by
- Members of the public/businesses
Greater North Kent (GNK) is an alliance of, and collective voice for, the North Kent districts of Dartford, Gravesham, Maidstone and Swale together with Medway Unitary Authority and Kent County Council. This Relevant Representation is submitted separately from, and without prejudice to, individual submissions by GNK partner authorities. Within GNK there is a diversity of views about the merits of the LTC proposals, but agreement on some key principles and on certain issues that need to be tested thoroughly through the public examination of the DCO. In terms of key principles, GNK partners agree: • The need for an additional Thames crossing to relieve the traffic pressure and associated congestion at the existing Dartford Crossing, and to strengthen the resilience of the strategic roads network. • That wherever a new crossing is located, any negative environmental and community impacts should be adequately mitigated, and where mitigation is not feasible that appropriate compensatory measures should be implemented. • That any socio-economic benefits generated by both the construction and operation of a new crossing, including employment, skills training and supply chain opportunities should be targeted towards the areas most directly and negatively impacted by the development. • That the LTC should not be viewed in isolation, but considered holistically and supported by investment in other parts of the strategic and major roads network in Kent that are not currently fit for purpose and would be adversely affected by increased traffic attributable to the LTC. • That the design of the LTC needs to be based on a realistic understanding, agreed with the relevant local authorities, of anticipated growth and development across North Kent and other neighbouring authorities within the next 15-25 years. • That wherever a new crossing is located, its legacy should be that it supports the UK’s progress towards net zero carbon by 2050, delivers a net gain in biodiversity, and enhances local economic opportunities. The issues that GNK would want to see thoroughly tested at examination include, but are not restricted to, the following. • Green Belt: whether the scheme demonstrates very special circumstances to justify the significant damage to the openness of the Green Belt between the Gravesend and Medway urban areas. • Environmental Impacts: whether the impacts have been thoroughly and objectively assessed, and whether proposed mitigation and compensation measures adequately address impacts such as the losses of Ancient Woodland, risks posed to the Thames Estuary and Marshes SPA, and increases in nitrogen deposition, noise and pollution affecting air quality and residential amenity. • Landscape impacts: whether the impacts have been thoroughly and objectively assessed, and whether proposed mitigation and compensation measures adequately address impacts such as the setting of the AONB and the loss of landscape features such as between M2 Junction 1 and the proposed A2 junction with the LTC. • Implications of and for emerging local plans: across North Kent, local plans are in various stages of development, some very advanced. All plans are seeking to provide for sustainable growth, taking into account central Government housing targets, as well as provision for employment, commercial and other development. In its approach to traffic modelling (the Lower Thames Area Model, LTAM) National Highways’ assumptions seriously understate realistic forecasts of growth over the period between now and the early years of operation of the LTC. This in turn shapes National Highways’ intervention in local plan processes with far-reaching implications for future development in North Kent both generally and in specific locations. • Traffic modelling: whether the proposals adequately take into account, and address, the impacts on local and major roads and junctions including A229 (Blue Bell Hill, with M20 Junction 6 and M2 Junction 3), A228 (Rochester Road and M2 Junction 2), A289 (with M2 Junction 1), B255 and A2260, and on the capacity of the A2/M2 itself. • Socio-economic impacts: whether the assessment and distribution of benefits attributed to the LTC, particularly in the immediate locality and for North Kent more generally, is robust. • Construction: whether measures to mitigate disturbance and disruption to residents and businesses during the five and a half years of construction are adequate; and whether proposals to secure employment, training and supply chain opportunities for local residents and businesses are robust and deliverable. • Traffic monitoring: whether the proposals for monitoring impact of the LTC should commence earlier to include the construction phase and to reflect changes that have happened since the base year for the LTAM. Greater North Kent will be working with its partners and neighbouring authorities where appropriate to coordinate engagement with the DCO process.