Representation by Maidstone Borough Council (Maidstone Borough Council )
- Date submitted
- 24 February 2023
- Submitted by
- Local authorities
Maidstone Borough Council (MBC) has regularly engaged with National Highways throughout the pre-application stage of the Lower Thames Crossing Development Consent Order (DCO). This includes participation in engagement activities such as technical briefing sessions and the submission of responses to formal public consultations, as reflected in the National Highways Lower Thames Crossing Consultation Reports. MBC has also worked jointly with National Highways on the preparation of a Statement of Common Ground (SoCG). However, whilst the latest draft SoCG was signed by the Council’s executive in October 2022 a countersignature from National Highways has not been forthcoming. National Highways have informed MBC that the SoCG was not signed in time for it to be submitted at the DCO application stage. MBC would like to point out that there was insufficient time provided for it to agree the wording of the SoCG and to obtain sign-off under its Cabinet system within the timescales provided by National Highways. MBC made this clear to National Highways at that time. In light of the above, MBC understands that the SoCG has not been included with the submission documents for the DCO application and it is not currently in the Examination Library. MBC therefore wishes to make the following representations which reflect its key areas of interest and concern with respect to the project. In particular, MBC would like to call attention to matters concerning air quality. It is the Council’s understanding that evidence on air quality impacts of the project, including modelling and consideration of mitigations in Maidstone borough, is in fact ongoing. The lack of evidence provided by National Highways in this regard has meant that MBC is, at present, severely constrained in its ability to assess and respond to air quality impacts and mitigations arising from the project as part of its Local Plan Review, which itself is currently undergoing Examination in Public. Need for project MBC strongly agrees that the Lower Thames Crossing is required in order to provide a greater long-term capacity and resilience on the Strategic Road Network (SRN), and to alleviate capacity issues in the area surrounding the Dartford Crossing. MBC acknowledge that without the project, the current issues surrounding the Dartford Crossing will only be set to worsen; negatively impacting upon those residents and businesses of Maidstone borough who currently rely upon the Dartford Crossing to cross the River Thames. Route corridor and alignment MBC has previously expressed a preference in favour of the Eastern Southern link as opposed to the Western Southern link, on the corridor south of the River Thames in Kent. Notwithstanding this preference, MBC acknowledge that the Eastern Southern link would have greater environmental impacts, including more significant intrusion into the Area of Outstanding Natural Beauty (AONB), and is satisfied with the additional appraisal work undertaken by National Highways concluding that the Western Southern link is, on balance, more appropriate. MBC in principle support is, however, subject to caveat over concerns related to the impact of the Project on the local road network (LRN). Charging regime Maidstone Borough Council will confirm its position with respect to the proposed charging regime for the Project in due course. Traffic and modelling MBC has previously raised concerns that the traffic model does not fully account for the level of growth that is likely to occur in Maidstone and the wider Kent area over the long-term. MBC acknowledge that the model takes account of development pipeline activity, but also wishes to stress that assumptions of “near certain” or “more than likely” housing and employment development input into the traffic model are only a snapshot in time. MBC remains concerned that the predicted uplift on housing figures within Maidstone’s Local Plan Review, and other authorities’ local plans, will go beyond what has currently been modelled and therefore likely to have an even greater impact on both local and Strategic Road Network in terms of flow and capacity. It is noted that the Maidstone Local Plan Review and supporting documents are currently undergoing Examination in Public. Wider network impacts MBC remains concerned regarding the impact of the Project on the local road network. In particular around sections of the A229, A249, M20 east of the A229 and M2 Junction 3 at the interchange with the A229/Bluebell Hill due to increased traffic levels. MBC advocates concurrent provision of road and junction improvements to ensure the benefits of the speedier, more reliable river crossing are not stymied by insufficient road infrastructure further along the road network, and to ensure that local traffic is not unduly impacted as a result of the crossing. MBC therefore strongly recommends that the project is accompanied by funded improvements to the road network. Wider network improvements MBC supports in principle the changes National Highways have made to the route since the preferred route announcement was made in 2017, particularly the widening of the M2 and A2 to Junction 1 and the redesign of the M2/A2 junction in order to cut journey times and improve junction safety. Notwithstanding this support, MBC considers that additional wider network improvements are required to mitigate impacts on the local road network, as set out above. Air quality MBC understands that the Air Quality Assessment has been completed for the DCO Environmental Statement. It further understands that this work has not modelled impacts and identified mitigations outside of the area immediately impacted by the Lower Thames Crossing, including Maidstone borough, and that this work is ongoing. MBC seeks assurances that the assessment is sufficiently robust and that any mitigation measures have been adequately identified and will be implemented in a timely manner. It is imperative that National Highways work closely with Maidstone Borough Council and Kent County Council to agree appropriate mitigation measures to manage the effects of traffic in all of the affected areas, including in Maidstone borough. Nitrogen deposition Maidstone Borough Council supports the expansion of the Order Limits to include land to the south of the M2 between junctions 3 & 4 (Blue Bell Hill) as this would provide the necessary land for nitrogen and ammonia deposition compensation. MBC confirm that the expansion of the Order Limits does not impact upon the existing or proposed spatial strategies outlined in the adopted Maidstone Local Plan or draft Maidstone Local Plan Review. Maidstone Borough Council would welcome cross-boundary cooperation work in relation to the site south of the M2 at Blue Bell Hill as it falls within the authority area of: Maidstone Borough Council, Tonbridge and Malling Borough Council and Kent County Council. MBC await further information from Highways England and other stakeholders in this respect. Sincerely, Philip Coyne Interim Director Local Plan Review Maidstone Borough Council