Representation by Dartford Borough Council (Dartford Borough Council)
- Date submitted
- 24 February 2023
- Submitted by
- Local authorities
Below is Dartford Borough Council’s Relevant Representation and confirmation of the Council’s registration as an Interested Party. A letter copy of the Relevant Representation will also be sent via email. Our Ref: 22/01207/NSIP 1. Dartford Borough welcomes the submission of the application for a DCO for the Lower Thames Crossing and supports the proposal due to the significant benefits that the scheme will bring to the Dartford area. 2. The Borough is a tier 2 authority that has ambitious growth plans in order to bring about regeneration of the area. The A282 / M25 Dartford Crossing and the arterial A2 London-Dover routes generate high volumes of traffic flowing through the Borough with environmental implications. Although the Borough benefits from its location adjacent to the Dartford Crossing, as well as its other strategic road connections, the economy of the Borough and the health and well-being of its residents is severely affected by the regular congestion that occurs on the local road network due to incidents on the strategic network. The need for the project 3. The design capacity of Dartford Crossing of 135,000 vehicles per day is well surpassed by current daily use of more than 180,000 vehicles per day according to National Highways 2019 flow data. The need for the Lower Thames Crossing is clearly documented in the submission documents for the proposal. However, as growth in both London and Kent continues, the pressure on the Dartford Crossing will get worse. The lack of capacity is exacerbated by the age of the tunnels and their physical constraints, including maximum height limits and bends in the tunnels restricting width of HGV’s and need to stop traffic to accommodate dangerous loads. This results in slow and unreliable journeys and a high level of incidents at the Dartford Crossing and its approach that in turn leads to traffic diverting to local roads. This leads to junction blocking and road congestion on the local network and associated additional impacts on air quality in the surrounding residential areas and Dartford town centre. The impact on the local road network is particularly severe when long-running incidents occur at the Crossing. This has severe impacts on local businesses as well as on the daily life of local residents. 4. The regular instances of congestion and lack of predictability of road conditions places a significant constraint on economic growth in the local area. Investment decisions to locate or expand in the area are deterred because of traffic conditions with development being constrained by the lack of capacity at Junctions 1a, 1b and the A2 junction. Access and egress from the Strategic Road network is constrained and east west movement across the junctions is impeded. Employers find it difficult to recruit and retain staff because of the difficult journeys, whether by private vehicle or bus. Planned mitigation for development includes improved public transport, however even the Fastrack bus service, which features significant sections of dedicated routeway, is compromised by the wider impacts and lack of resilience of Dartford’s highway network. 5. It is becoming increasingly difficult in planning determinations to reconcile the government’s objectives for housing and employment growth in the area with the objective of keeping the Strategic Road Network performing adequately, or at ‘nil detriment’ as National Highways (NH) expects. Studies have shown that there are limitations to significantly increase the existing capacity of Dartford Crossing and impacts on the operation of the A282 junctions with 1a, 1b and 2 including surrounding strategic and local roads. Further pressure on the existing road network in and around the Dartford Crossing is therefore likely to slow the planned growth in the area surrounding the crossing. 6. In addition to providing additional capacity, the proposed Lower Thames Crossing will increase the resilience of the road network. Studies show that when there is congestion at the Dartford Crossing, traffic diverts to other crossings (notably the Blackwall Tunnel) or goes the long way round the M25. The provision of a new crossing will release capacity at the Dartford Crossing, thereby also releasing capacity on the wider transport network. It will provide for added resilience in the event of an incident. This will also create resilience of the strategic road network between Kent, the Midlands/North and mainland Europe. 7. Dartford Borough Council’s view is that the Lower Thames Crossing should be provided as soon as is feasible Wider Network Impacts Management and Monitoring Plan (WNIMMP) 8. DBC is supportive of NH’s proposal specified under Requirement 14 of the draft DCO (Application Document 3.1) which requires a monitoring scheme with details of operational traffic impact monitoring scheme to be submitted in writing as part of the WNIMMP submission to the Secretary of State following consultation with the local highway authorities and bodies listed in Table 2 of the Application Document Ref: TR010032/APP/7.12 Version 1.0 – October 2022. This identified DBC as one of the relevant stakeholders to be consulted on the WNIMMP. It is noted that as part of Requirement 14, the before and after surveys will include at least one year before project opening and one year and five years post project opening respectively. 9. However, it is proposed that NH consultation with DBC on the WNIMMP will be through Kent County Council (KCC) which is expected to incorporate DBC and other districts in the County. Whilst KCC is the highway authority for the Dartford Borough area, DBC is keen that there should be direct consultation with NH as well as with KCC, and that this should be required as part of the Requirement 14 approval process. This is to ensure that any identified areas of concern related to wider impacts on local roads in Dartford are taken into account. Discussions are ongoing with NH on this matter. 10. It is noted that the list of proposed traffic data monitoring location sites are identified in Plate 5.1 of the Application Document Ref: TR010032/App/7.12 Version 1.0 dated October 2022. However, junctions A282 / J1b and J2 of the M25 are excluded. Similarly there are no plans to undertake air quality monitoring as part of the before and after surveys. Congestion from the Dartford Crossing impacts on the operational capacities of these junctions and contributes significantly to the air quality issues in the area. The A282 Tunnel Approach is part of the Air Quality Management Area within Dartford. Consultation between NH and DBC would achieve greater collaboration between both parties in terms of managing the wider impacts of the project on the strategic, major and local routes in the Dartford area. Discussions are ongoing with NH on this matter. Construction Impacts 11. NH’s transport assessment of the construction impacts show minimal impact on Dartford area. If the DCO application is granted, construction is planned between January 2025 and December 2030 with the project becoming operational in 2031. A total of eleven works phases have been modelled. Traffic management south of the River would involve introducing narrow lanes and a 50mph maximum speed limit on the A2. Other local traffic management measures are also planned as the works progresses mainly around the A2 / M2 and Gravesham borough area. DBC are supportive of the approach in the Code of Construction Practice setting out the management of environmental impacts for the construction of the project, however, discussions are ongoing between NH and KCC regarding baseline traffic data monitoring before the commencement / during the construction period. Conclusion 12. DBC are very supportive of the Lower Thames Crossing project and are keen to see the implementation of the Crossing as soon as is possible. 13. DBC will continue to engage with NH, KCC and other relevant bodies on key matters to support the delivery and management during and after implementation of LTC.