Representation by Runwood Properties Limited (Runwood Properties Limited)
- Date submitted
- 23 February 2023
- Submitted by
- Members of the public/businesses
OUTLINE OF MAIN POINTS OF OBJECTION TO LOWER THAMES CROSSING 1. Unacceptable impacts on Whitecroft Care Home, Stanford Road, Orsett, Thurrock, and its residents and employees, due to the magnitude of the proposed works, their duration (both during construction and during operation), their proximity, and the Applicant’s inability to provide effective mitigation of the impacts. 2. Whitecroft Care Home, which specialises in the care of elderly persons with dementia and other cognitive impairments, provides long-term (and in many cases ‘end of life’) residential accommodation serving the local community, and plays a key role in the social welfare and healthcare provision for Thurrock and surrounding areas. It also provides local employment. If the Lower Thames Crossing (LTC) proceeds, Whitecroft will become an ‘island’ isolated within and surrounded by significant construction activity for some 5+ years, including the construction of three new bridges on Stanford Road, the raising of Stanford Road, the construction of a new bridge for the A13 westbound slip road to the A1089 southbound, the construction and operation of the Stanford Road Compound and the Brentwood Road Compound (incorporating the Brentwood Road Utility Logistics Hub), the construction and operation of haul roads/construction access roads and turning areas, the excavation of cuttings and the creation of embankments for the LTC and the various supporting slip roads, the construction of all of the new and improved highways, including highways lighting, the dismantling and re-erection of overhead power lines, excavations and installations for utilities pipelines and underground cables, the construction of a large mitigation bund to the immediate west of Whitecroft, the undertaking of 24 hour, night-time, and weekend construction activity for extended periods, and (post-construction) the retention and operation of the changed highway network for an assumed 60 year period. 3. This scale of detrimental change in such close proximity to a care home accommodating vulnerable persons is an unacceptable juxtaposition of incompatible uses which renders the Whitecroft incapable of effective continued operation and imposes what for most of its residents would be a ‘life sentence’ of unacceptable noise, dust, emissions, vibration, light intrusion, and disturbance, as a result of the construction of the LTC and associated works, including the operation of construction plant, machinery, and vehicles. Continued operation of the Whitecroft would be at serious risk if the LTC is approved and its closure is reasonably foreseeable. To that extent, the operational impacts of the LTC are secondary to the construction impacts, but if the Whitecroft did survive the construction of the LTC, its future as a care home would not be sustainable in the longer term with the LTC in place. 4. Deficiencies in the Applicant’s assessment of the impacts of constructing and operating the LTC include (but are not limited to): • inconsistencies in the Application material about the physical characteristics of the proposed works (in particular between APP-017, APP-035, and APP-044 as regards the heights of the bridge and slip road for the A13 westbound to the A1089 in the vicinity of the slip road for the A13 westbound to the LTC southbound to the north of Whitecroft, and similarly for the heights of the bridge and slip road for the A13 westbound to the LTC northbound in the vicinity of the slip road for the A13 westbound to the LTC southbound to the north of Whitecroft); • inconsistencies in the Application material as regards the assessment of heritage impacts at Whitecroft (in particular between AS-045 and APP-549); • wrongly assessing the residential community at the Whitecroft as a single residential receptor in the baseline assessment in APP-382 to inform the landscape and visual appraisal in APP-145; • omissions from the Application material, including a failure to undertake a construction vibration assessment at or in the vicinity of Whitecroft, a failure to provide detailed assessment results (including the assessed facades and calculated ‘with mitigation’ levels) for the construction noise assessment at Whitecroft (CN85); a failure to undertake noise and vibration assessments for Whitecroft reflecting the vulnerabilities of the residents and greater susceptibility to impact from noise/vibration than the general population; failure to demonstrate that proposed Best Practical Means (BPM) construction practices will achieve effective mitigation of construction noise impacts; failure to explain or evidence the local terrain modelling used for the air quality assessment; failure to adequately assess or explain the extent of heritage harm to the significance of the Grade II listed Whitecroft Farm House by reason of the extent of the proposed works; masking (and so under-estimating) health and equalities impacts by assessment at ward level rather than at site/institution level; failure to assess how emergency services access to Whitecroft will be maintained during the weekend and night-time closures of Stanford Road that are proposed; omission of Whitecroft as an existing business in the Population & Human Health Chapter of the Environmental Statement (APP-151); failure to assess the social, health, community, and economic consequences of the likely closure of Whitecroft, especially as regards the provision of care home placements for the local communities of Thurrock; and • consequential failure to accurately or adequately assess the cumulative intra-project impacts of the proposed works on Whitecroft and its residents and employees by reason of the preceding deficiencies. This is a particular failure with regard to the health impacts of the construction and operation of the LTC on the vulnerable residential community at the Whitecroft. 5. The failures in the assessment process as reported in the Application material mean that the impacts of the proposed works on Whitecroft and its residents and employees have not been properly assessed and the Applicant has failed to identify or address the unacceptable juxtaposition that would result from imposing the LTC on Whitecroft. The mitigation hierarchy expects adverse impacts to be avoided, reduced, mitigated, or compensated for. Avoidance is not an option if the LTC is to proceed. Given that effective mitigation for the unacceptable impacts has not been demonstrated to be a practical proposition, the Applicant needs to put forward proposals for the relocation of Whitecroft Care Home to an alternative site as a compensatory measure if the LTC is to proceed. 6. In addition, the deficiencies in the Applicant’s assessment mean that the Applicant has not discharged its Public Sector Equality Duty (PSED) in relation to the persons with protected characteristics resident at the Whitecroft and nor, on the basis of the Application material, will the Secretary of State be in a position to satisfy the PSED.