Representation by Tonbridge and Malling Borough Council (Tonbridge and Malling Borough Council)
- Date submitted
- 23 February 2023
- Submitted by
- Local authorities
Tonbridge & Malling Borough Council (TMBC) continues to support the Lower Thames Crossing Project, as we recognise that the existing Dartford Crossing is operating over capacity and there are limited alternative options to cross the River Thames. It is a much-needed nationally significant infrastructure project that will help to improve the resilience of the strategic road network, as well as offer the potential for local and regional economic benefits. We however remain concerned about the impacts of the project on the local road network in particular. The following is an outline of the main issues that are relevant to Tonbridge & Malling, that are not agreed or under discussion at this time as included in our published Statement of Common Ground. Traffic Modelling • TMBC has concern that the growth associated with the government’s standard method for assessing housing need (15,941 dwellings in Tonbridge & Malling 2021-2040) is taken into account by the Lower Thames Area Model core scenario. The modelling undertaken does not give sufficient consideration to anticipated future growth. TMBC has previously requested modelling of alternative scenarios and is further reviewing the application with regard to this matter. Wider Highway Network Impacts • TMBC has concern regarding the impact of increased traffic on local roads as a consequence of LTC and requests funding to provide mitigation. The new crossing will have implications on the M2 Junction 3, the A229 Bluebell Hill, M20 Junction 4, the A228, A20 and Rochester Road within Tonbridge and Malling borough. • The A229 at Bluebell Hill which connects M2 Junction 3 with M20 Junction 6 needs improving to accommodate the additional LTC traffic alongside Local Plan growth and is the subject of a Large Local Major scheme bid to the Department of Transport, which TMBC supports. This project has not yet secured funding. EIA Methodology • TMBC is seeking clarification about how the DCO application treats the included Alternative Scenarios, given that other aspects of the DCO application are understood to be dependent on the outputs from the Core Scenario. We are reviewing the application in this regard. Air Quality • TMBC has concern regarding the operational air quality implications of increasing traffic within the M20 Air Quality Management Area and on the A228 and A229 between the M2 and M20, in particular the impacts of nitrogen oxides and particulates upon local air quality. TMBC is reviewing the application with regard to this matter. • TMBC has declared a climate emergency and is aiming for our borough to become carbon neutral, we are therefore concerned about increasing carbon emissions from road transport. Clarification is required as to whether the assumed rates of decarbonisation have been approved by the Department for Transport. Nitrogen Deposition • The requirement for nitrogen deposition compensation land is a cause for concern given the potential wider ecology impact of LTC on the Kent Downs AONB, the North Downs woodlands Special Area of Conservation. Notwithstanding our concern, TMBC welcomes the compensatory habitats. Well managed compensatory tree planting is a good option to capture nitrogen, reduce noise and store carbon. • TMBC is reviewing the application with regard to this matter, including. o Site selection methodology and rational as to how the sites including Bluebell Hill were chosen. o Detail of site management including tree and other planting, stewardship and access.