Back to list Lower Thames Crossing

Representation by Gravesham Borough Council (Gravesham Borough Council)

Date submitted
24 February 2023
Submitted by
Local authorities

Gravesham Borough Council PINS Reference: TR010032 Relevant Representation Gravesham Borough Council has consistently opposed the Lower Thames Crossing on an alignment east of Gravesend due to concerns over the impacts to homes, businesses, communities, residents' health and well-being, and environmental impacts for little local benefit. Elected Council members have unanimously endorsed this position. It however has always been accepted that there is a need for an improvement to access across the river on the east side of London given the current pressures on the Dartford Crossing, which requires a solution at Dartford. The Borough Council is the Planning Authority for the scheme in Kent, apart from the nitrogen deposition sites located in the areas of Maidstone Borough Council and Tonbridge & Malling Borough Council. Kent County Council is the transport authority for all three areas. Medway Council has both functions for its area. From the point of view of the local community all subject areas discussed below potentially have implications for them, regardless of which body has primary responsibility. Despite its fundamental objection to the project the Council has worked constructively with National Highways to develop and improve the project, if it is built, to avoid, mitigate and compensate for the impacts as appropriate. This process has resulted in some relatively small changes being made to the proposals over the numerous consultations. These seem to have been primarily driven by the development of the scheme rather than responding to consultation responses. The Council approaches the applicant as it would any proposer of a major development project. The Council has several more general high level concerns which are outlined first, and then some more specific matters are dealt with using the order and chapter numbering of the Environmental Statement for ease of reference. Process concerns raised in the Council’s Adequacy of Consultation response in relation to National Highways are not repeated here. This representation considers the issues primarily from the perspective of Gravesham, but it is appreciated that these have to be placed in the context of the scheme as a unit. In a business case sense, the core tests are whether the whole project produces a positive BCR, is value for money and will achieve its stated seven objectives. Locally it is whether the claimed benefits to the Borough outweigh the negative impacts, making due allowance for the mitigation and compensation proposals. Benefits elsewhere are of little value to local residents or businesses. As the Environmental Statement does, it is important to distinguish between the construction impacts and the operational impacts from the completed scheme. The current construction programme implies a 51/2 year construction period which is considerably longer than the time taken in the past to build, for example, the A2 Bean & Ebbsfleet junction improvements, moving the A2 past Gravesend, or building Channel Tunnel Rail Link (now HS1 which included widening the M2). Some disruption is inevitable in a major construction project, but the scale of this project means that these impacts will last for a considerable period, and therefore have a greater impact on the local environment. The key elements of the scheme in Gravesham include: • Increase from 8 to 12 lanes of the A2 west from M2 J1 (Three Crutches) in the Kent Downs AoNB • A multilevel junction between A2 and A122 with connections to A2 Marling Cross (Gravesend East) and Cobham/Shorne junctions • An increasingly deep cutting on the A122 leading to the southern tunnel portal which is 28m below ground level • Twin tunnels, bored from the north, running under the rural area east of Chalk and the North Kent marshes • Diversions to some existing highways and public rights of way, high pressure gas pipelines, 400Kv overhead lines and other utilities Key issues Content of the application – the Borough Council has found trying to analyse the application in detail a complex process due to information on topics being scattered across many documents and not always consistently. New issues may therefore emerge. Various different methodologies have been applied in an inconsistent way. There is a focus on individual impacts rather than the overall implications of the scheme in the round, either within topics or across them. Many small impacts individually will become highly significant when considered in combination, even if they do not break some pre-set threshold. For member of the public the result is confusing and difficult to understand when seeking to understand the implications for them. Principle of the project – as noted above the Council opposes the routing of the additional cross river capacity east of Gravesend but has constructively engaged with National Highways without prejudice to that overall position. Route selection process – the current project has emerged from work undertaken in a series of reports by consultants for Department of Transport dating back in 2009. The 2017 route selection process was based on an outline design consulted upon in 2016 that did not include rebuilding the A2 through the Kent Downs AoNB and was confusing in relation to the approach adopted to improvements at the Dartford Crossing. Circumstances have materially changed since then, especially in relation to matters like the carbon budget, climate change and the outworking of vehicle electrification on air quality. Design Strategy – this is woolly and vague and leaves far too much discretion of what is expedient for the contractor. Greater clarity and precision are needed, especially in the context of the impact on the Kent Downs AoNB and its setting. Overall Highway Design – the scheme creates a complex junction with the A2 sandwiched between two existing junctions and deleting the Cobham slip roads. Micro simulation work for Thurrock has shown that that the operation of the A13 Orsett Cock junction has serious issues not revealed by the Lower Thames Area Model (LTAM). The A2 junction needs to be subject to the same sort of analysis to ensure that is functions correctly. A particular concern are the 2 lane sections for A2 to M2 through traffic in both directions (very short eastbound, much longer westbound). Capacity issues at this location will impact not just on the strategic road network but also on local roads, as happens regularly now whenever there are congestion issues on the A2. The junction design results in the loss the Cobham South Services, which is a popular facility with local residents as well as those on long distance journeys. The result is a long gap between South Mimms (M25 J23) and either Medway or Maidstone services for traffic to/from A2/M2/M20/A20 corridors. The applicant claims that the project will increase the number of accidents due the length of new road, but that the rate of accidents will fall. The A122 is not proposed to be a motorway but is being designed to ‘smart motorway’ standards. That standard is now under review, with a moratorium on implementing such schemes, which if made permanent would have implications for this project. The Borough Council also notes that north of the river there was junction for access to the Port of Tilbury in the 2018 Statutory Consultation that was then deleted in 2020. This has now been resurrected to support the Thames Freeport, where the overall area covered is known but the detailed proposals are not in the public domain. Information has been supplied to National Highways by Thurrock Council. The proposals would appear to include development on land that is currently in Green Belt for which there are no public proposals to amend. There is no information on what the traffic implications of the proposal may be, and why development at, for example, Hoo has not been treated in the same way in the scheme design. The proposal also provides an opportunity to reinstate the Service area which is lacking from the current scheme. The Environmental Statement, on the basis of the recent Tewkesbury decision, should include an assessment of both benefits and impacts of development that is being directly supported. Assessment Methodology – The Council has consistently pointed out that the Design Manuel for Roads and Bridges (DMRB) is only guidance, and it cannot be relied upon alone. The criteria in the National Policy Statement for National Networks (NPSNN), National Planning Policy Framework (NPPF), the Environmental Regulations, the Planning Inspectorate scoping opinion, and case law, all take precedence where relevant. This has produced inconsistencies in the analysis with different guidance being used in different parts of the Environmental Statement. There is a general focus on specific impacts (fine as a starting point) but the translation of these into overall results can be methodologically defective. There is also a failure in some cases to fully reflect on the significance of the impacts (individually or cumulatively) or assess a reasonable worst case. Transport modelling – the Council has major concerns, repeatedly expressed over time, on the robustness of LTAM, and including the reliability of the flows for local roads. The transport assessment adopts a very narrow view of development and fails to take account the scales of housing development required by the Government standard method in North Kent (and the consequential jobs). This is allied with TEMPRO which artificially restricts the levels of development that are allowed. A scheme that constrains development in North Kent does not meet that stated objective of support sustainable local development and regional economic growth. The requirement for a Green Book appraisal for comparative purposes with other schemes is fully appreciated, however the project stands to be Examined based on a reasonable worst case for the purposes of Environmental Assessment to allow definition of the Rochdale envelope, as set out in the policy and guidance documents referred to above. The scheme rests on the assumption that current cross channel vehicle and HGV flows seeking to go north of London from Kent will divert off the A20/M20 corridor onto the A2/M20 corridor. The A229 is a local Kent road which in provides the shortest link between the M20 J6 and M2 J3 up Bluebell Hill. No proposals are included in the application for improving this length of road or the two motorway junctions which are already over capacity at peak times. For the scheme to work improvement to the A229 should be treated as Associated Development, since it is critical to linking the A2/M2 and M20/A20 corridors and providing relief at Dartford. Most of the traffic on the M25/A282 is going ‘round’ London in some sense, for which diverting east of Gravesend is a much longer trip and therefore unlikely to happen. The modelling shows the initial relief at the Dartford Crossing evaporates in 15 years, and based on past experience, when the toll booths were removed, will happen much faster than projected. The problems at the Dartford Crossing highlighted in the objectives are not actually being addressed and will remain an issue. The Dartford Crossing was designed for 135,000 vehicles per day, it is now operating over capacity and is regularly used by over 150,000 vehicles per day. Thurrock Council’s analysis of the official National Highways data shows that the proposed new crossing would take as little as 4% of traffic away in the morning peak hour, and 11% in the pm peak hour. Robustness has been claimed as a benefit, and objective, but there has been no substantive analysis of how the road network (M25/A282/A13/A2/A122) would function in the event of major disruption, since the current issues with the northbound tunnels at Dartford would largely remain. Disruption, especially northbound as the Dartford crossing, regularly occurs and it is clear from the projected flow numbers that one crossing cannot accommodate the combined flow. Monitoring strategy - the Council wishes to see a comprehensive strategy for every potential impact (modified as appropriate to the specifics of each topic) that establishes a base line before construction starts, monitors during construction, and carries on monitoring once operation commences to establish actual outcomes with agreed interventions as needed to ameliorate those impacts. As an example, there is no point in monitoring traffic levels 1 year before opening given the disruption that construction will cause in that period. This needs to be allied to potential set of actions that may be taken if the impacts are not as expected and accepted by the Secretary of State in granting the DCO. The Borough Councils role in this process, and dealing with Requirements, will need to be funded by the applicant to ensure cost recovery. Mitigation and Compensation – as an overall point the precise form of these and the connection back to impacts is not always clear. In particular is not transparent how some of the planting proposals relate to the impacts of the scheme. Heritage – as indicated above this is closely related to landscape and nature conservation areas. Past projects, and survey work for this project, has indicated that the area is rich in heritage assets. The methodology used starts from individual harms but fails to follow this properly through into the overall assessment. The result is an underestimate of the impacts, and therefore the application contains insufficient mitigation. This is particularly true for the village of Thong, with its conservation area, and its setting in the wider historic landscape. Landscape impacts – the project on the surface lies either within, or in the setting of, the Kent Downs Area of Outstanding Natural Beauty. Consideration of this cannot be divorced from the heritage and ecological considerations. The entire scheme in Gravesham sits on land that was once part of the Cobham Estate (Earl’s of Darnley) stretching from the Thames to the Medway via Cobham Park (Registered Grade II*), giving it an historical cohesiveness. In the AoNB the current A2 has a split carriageway which combined with the HS1 landscaping softens the impact considerably. The proposed scheme keeps this basic transport corridor in width, but with an extension to accommodate diverted utilities to the north and a surfaced cycle route to the south, within the registered park. This effectively removes most of the existing landscaping along the A2 and creates a highly urban environment with 12 lanes of A2 traffic, signage and lighting. Th project dramatically increases the severance, which is not fully acknowledged in the analysis. At Thong Lane south land bridge with the various slip roads and the extended Darnley Lodge Lane there are 17 lanes. The three level A2 junction sits in the setting of the AoNB and along with the destruction of the HS1 landscaping forms a major urban intrusion. The A122 to A2 west slip road appears to sit some 14m above existing ground level. Despite repeated requests proper 3D digital model and cross sections of the junction have not been produced to enable the various relationships to be understood. The fly throughs are not a substitute. The methodology used in the landscape assessment lacks clarity and is applied inconsistently. It is not clear how this relates to the overall impact of the scheme. As in other topic areas there is tendency to average the impacts rather than taking the worst as required by guidance. The major impact on the landscape is not mitigatable given the existing space and constraints, and some of the major planting proposals round Thong go against the historical context. The areas of planting proposed (including ammonia compensation areas) constitute a major change to the landscape in their own right which has not been assessed and have been in long term agricultural use. Planning – Impacts on many topic areas are summarised elsewhere, so the focus here is on the Local Plan and Green Belt. The proposal significantly constrains the options for possible future development on the east side of Gravesend not only from physical presence of the road itself but also from the extensive areas given over to planting and landscaping. This has resulted in the Council having to look at other potential sites elsewhere in the Green Belt to accommodate housing need, which may be more damaging than the east side of Gravesend. The combination of SSSI’s (including Ramsar/SPA), AoNB and heritage assets significantly constrain the areas of search in the Borough. The disruption from the construction of the project may seriously constrain development delivery in the 2025-2030 period as well have long term implications on the capacity of some junctions. The Council is having to spend hundreds of thousands of pounds on transport modelling for the local plan. The proposal is inappropriate development in the Green Belt, as agreed by the applicant, who seeks to make a very special circumstance case. The analysis of Green Belt is biased towards landscape and does not properly assess all the harms or benefits the project will bring. The Examining Authority is not therefore provided with the rigorous analysis and information necessary to assess the Green Belt impact and is not in a position to arrive at a view of the balance to be struck on the basis of paragraph 148 of the National Planning Policy Framework and the ‘other considerations’ that need to be taken into account. This document needs to be rewritten. Construction impact – scale of the impacts in the strip from south from the river to A2 and then along the A2 corridor to the M2 as highlighted above lasts for up to 51/2 years. Although some impacts are of small scale individually, and may not break specific thresholds, the cumulative effect of them combined, especially where the scale of change is large, have significant implications. This will impact on local residents and businesses in Gravesend, especially the Riverview Park area, the urban part of Thong Lane and Thong itself, and will be of major significance. The Development Consent Order and associated Control Documents err on the side of flexibility which fails to provide clarity and certainty that is needed, but can be addressed via the Requirements and a comprehensive monitoring strategy. Many residential properties are in close proximity to the construction area and completed scheme, including the residential properties along the east side of Thong Lane, along with Polperro and the traveller’s site on Rochester Road (A226), which are cut outs in the development boundary. A number of residential properties at Marling Cross are demolished, along with businesses at that location and at Thong. There are several areas where the Council is of the opinion that more precision is required in the application. In this complex environment detail cannot be simply left to the contractors at a later date, who may argue that whatever is being sought is not expedient. This is not to deny that there are details that can be sorted later, or that new ideas and approaches may need to be considered. Allied with this the Council firmly believes that Requirements should be determined by the appropriate Authority, not the antiquated idea that the Secretary of State can be judge and jury (illustrated by the lack of an appeal mechanism). The schedule 6 process (as it was entitled under the Channel Tunnel Rail Link Act 1996) worked well in this regard. At the very least there needs to be a agreed process of consultation prior to submission of any Requirements applications, with the Councils role fully funded. Socio-economic – in the short term the construction period results in major disruption to the local and strategic road network. This has implications that will spread out into the Gravesend/Northfleet urban area and the rural settlements to the south and east on everything from long distance trips on the A2 to local access to schools and GP surgeries. This must include perceived as well as actual impact. Noise, dust, and disturbance around the construction sites need to be strictly monitored and controlled. Communication with local residents needs to be robust and not hampered by the construction contract boundary on Thong Lane. The impact of construction workers on an already stressed housing market is a major concern. The Council does not agree that there is sufficient capacity in the local housing market, particularly the private rented sector, to accommodate the level of demand. There is a local housing crisis with the Council paying hundreds of thousands of pounds to house people in urgent need and Plan B is needed if our fears are realised i.e. the project limits the availability of accommodation for local residents, exacerbating rental levels and the displacement of current tenants. There is a need for proper training and contractor opportunities for local residents and businesses to take advantage of to maximise local economic gain. Impacts will vary by topic and location but there is the overall concern over the cumulative impact of numerous small items when aggregated on the health and wellbeing of the local population and businesses. The principal of a Community Fund is welcomed, but there also needs to be large scale forward funding for major projects across the wider corridor to tackle social, economic, leisure, heritage, ecology and landscape issues. When operational the scheme will improve north south access over the Thames and aid long distance travel flows where the A122 provides a logical route, but in local terms offers little benefit. Current consented and proposed development in North West Kent are or will be provided with sufficient transport access and capacity based on the whole transport network, since A122 cannot be assumed. This includes a large scale emphasis on public transport, which this project does not address. Road User charging. – the applicant is proposing to align charges and other details of the charging regime with those at the Dartford Crossing, such as hours in which the charges apply, discounts and exemptions. The DCO will also include powers enabling the Secretary of State for Transport to apply a local resident discount for charges imposed under the DCO to residents of the local authorities in which the tunnel entrances would be situated i.e. those living in Gravesham and Thurrock. It is proposed that the same user charging mechanism i.e. an extended Dart Charge, will be used for both the existing and new crossing. The Council welcomes this but requires that the local residents discount be applied to both the current Dartford and new Lower Thames crossing and is brought in from start of construction by way of compensation for the disruption that will be caused. Public Transport – the project is a pure road scheme and makes no provision for sustainable travel other than the changes to the PROW network necessitated by the scheme. It will be possible to run public bus services through the tunnel, charge free, but otherwise the scheme does not enhance the modal split as part of supporting development in North Kent, in fact it puts more vehicles on the network contrary to local transport objectives. Some additional schemes have/are being developed using Designated Funds, but these of course are not part of the mitigation and compensation for the project. The Tilbury Ferry is a facility into which investment could be made. Environmental Statement (Numbering and order follow that of the ES chapters) 5. Air quality – our consultants advise that methodology is generally sound, but there are concerns over whether an appropriate methodology and assumptions have been employed to obtain background concentrations. There are some significant variances in the modelled results and those monitored, outside the normal 25% variation, where the model result is below the actual. This may lead to under predictions of impact, especially given the concerns over the traffic modelling, and therefore needs revisiting. PM2.5 has not been modelled, but broad assumptions made around its the relationship to PM10. This methodology is not the most helpful in determining the likely effects of PM2.5. The annual mean Air Quality Strategy objective is stated as 25 µg/m3 when it is actually 20 µg/m3. Taken together these factors have implications for the human health impacts, in an area where the potential for long term health impacts is a matter of growing public concern. Monitoring would be a clear way to check how far the predictions match reality and the need, or not, to take further action. 6. Cultural Heritage – the appraisal is confused in methodological terms and as to what guidance is being followed. As noted above the entire route in Kent is on land that historically formed part of the Cobham Estate. Dramatic change has occurred over time (e.g. development on the east side of Gravesend as well as the A2 itself), but this background supplies the historic framework for considering impact and future change, as set out in guidance. The area is rich in archaeological remains (especially along Watling Street). The village of Thong (Conservation Area with a number of non-designated buildings) is impacted by A122 to the west and proposed planting schemes around it, which will significantly alter its character as a settlement in open countryside framed by woodland. The Milton construction site, CA3b, as shown in the plane could involve the towpath (NCN1/NG2) and the Thames & Medway canal (a non-designated heritage asset). Considerable archaeological investigations have been carried out, with significant results, but this has not be done for the Southern Valley Golf Course or the areas of new planting proposed to compensate for ammonia deposition. It is not therefore known whether these are deliverable in archaeological terms. Notwithstanding previous interventions that have been harmful to heritage interest, the Council is of the opinion that these would be compounded by the harm caused by the introduction of the A122 link road, the new multi-layered A2 junction and the changes to be made along the A2 corridor. The Council considers that the impact of these changes has been under-estimated within the Environmental Statement and the application itself and that the embodied mitigation is insufficient in itself to address the level of harm. There are also aspects of the proposed mitigation, particularly to the east of the settlement of Thong, the Council considers to be harmful to heritage significance and which would be inappropriate and should be changed. As such, the Council is of the opinion that a package of compensation is required to address harm that is not satisfactorily dealt with through embodied mitigation and will seek to agree a way forward with the applicant prior to the examination. 7. Landscape and Visual – as noted above the project in Gravesham is located in or in the setting of the Kent Downs AoNB. The National Policy Statement for National Networks is clear about the AoNB being treated at the same level as National Parks and the Broads, and lists three criteria to be taken into account (para 5.151): •? the need for the development, including in terms of any national considerations, and the impact of consenting, or not consenting it, upon the local economy; • the cost of, and scope for, developing elsewhere, outside the designated area, or meeting the need for it in some other way; and • any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated. The Borough Council is of the opinion that the project fails on all three criteria. Over the development of the project the Green Bridges at Thong Lane North (over A122), Thong Lane South and Brewers Road (both over A2) have been expanded in width, which the Councils welcomes, but those over the A2 in particular should be made larger still and thought given to how the ecology linkage could be enhanced given where they land on the south side. The area around Park Pale needs further examination to ensure the best result can be achieved. The A2 in Gravesham is already lit, however the A122 junction comes on three levels and the alignment to the tunnel portal introduces new lighting in an area that does not currently have much of it. Assuming best practice in construction (where combined with 24 hour working the areas involved are much larger) and operation is followed there will still be potential impacts on residential properties close by, and Thames Estuary and Marshes Ramsar. The nature conservation impacts are unclear and need further exploration. 8. Terrestrial Biodiversity – the project impacts on Shorne and Ashenbank SSSI, including destroying areas of designated Ancient Woodland. Some of this is caused by the need to create a utilities corridor for diverted plant, most notable a large gas pipeline. The two land bridges over the A2 are currently inadequate in width to connect the habitats north and south of the A2. It is unclear how the new large areas of planting south of the A2, along the A122 and around Shorne will function in relation to the existing habitats in the area. The Environmental Statement reports significant impacts on Ecological receptors from poor air quality, but it is not clear from the submitted material what these are. The approach to ammonia uses software that is not industry standard, and the results are not clear so it is not possible to say whether the assessment is appropriate or not. 9. Marine Biodiversity – no specific comments and defer to Marine Management Organisation, the Port of London Authority, Natural England and other bodies. 10. Geology and Soils - The project in Kent the road sits mainly on chalk forming the North Downs, though the Shorne Wood/Ashenbank Wood/Cobham Park area with its woods are a mixture of sand and clays and other materials sitting above that. These deposits result in a number of perched water tables as well as forming the overall landscape character, with woods on the clays etc. and open fields, on the chalk. The North Kent marshes are river deposits underlain by chalk, where the critical element is the water table to support the wading bird population. This also means that construction in the AoNB is on more unstable material, quite apart from the need to avoid any impact on the stability of HS1 (186 mph max speed). 11. Material Assets and Waste – The scheme aims to consume as much as possible of its spoil on site, with only the export of potentially contaminated waste and the import of structural fill for features such as the false cutting near Thong for which chalk is not a suitable material. This will be brought in by road along the A2 via the Marling Cross junction, with significant impact. The cutting leading to the southern tunnel portal produces more spoil than the tunnels under the river, which is used for landscaping and the creation of Chalk Park. The latter proposal introduces unnatural features into the landscape as a means of disposing of spoil. Whilst the approach is compatible with Kent Minerals and Waste plan it fails to take account of opportunities to use other modes or approaches. 12. Noise and vibration – our consultants advise that methodology employed is in principle sufficient to address the potential issues, with the caveat over the inadequacy of the transport modelling. A significant change from the 2022 consultation in the submitted DCO has been the removal of the proposed noise barriers, and reliance placed instead on a low noise surface, which is supposedly 7.5 dB quieter. This type of surface decays with time, precise rate depending on the actual material used, implying that it will need to be replaced about every 10 years and that it is properly maintained so as to remain effective. The effectiveness of this approach requires clarification in the real world. It is noted that there is a 60% increase in traffic flow on Henhurst Road, Cobham, including more HGV’s, which raised issues on the impact on local roads, which needs monitoring. 13. Population and Human Health – Construction issues are mentioned above, but a particular point is the effectively cutting the PROW between A226 and A2. Access will need to use a new Thong Lane footpath (crossed by a haul road), the A226 footway or a long diversion for NCN177, about which the Council has serious concerns. The diverted NCN177 during construction is not as convenient and commodious as the current one and introduces potentially alien features into historic landscape and nature conservation areas. The route when operational introduces additional road crossings as well are contributing to the urbanisation of the rural area. The surfacing of some PROW routes does likewise. The project removes a pitch and putt course at the rear of the Cascades Leisure Centre and the Southern Valley Golf Course (18 hole pay and play). That latter has now closed as a direct result of uncertainties due to the proposed scheme, but although private provided for public use. Discussion is ongoing on the pitch and putt but there is no replacement for the Golf course or another active outdoor recreation facility. Chalk Park, and other mitigation/compensation areas, extend the open space offer but in an area that is already well provided for. The health and equalities impact assessment (HEqIA) considers a range of health determinants including air quality, noise and vibration, light pollution, mental health and well-being, as well as determinants related to accessibility to green space, services, and travel. The assessment then considers the sensitivity of a community to change. The assessment recognises that the cumulative health outcomes for communities in close proximity to construction activities, compounds and construction traffic routes will be negative and significant on quality of life and wellbeing including stress, anxiety, mental wellbeing, sleep disturbance and uncertainty. Whilst these are temporary, as the construction phase will last around 6 years (allowing for preliminary works), those communities in closest proximity to certain aspects will be impacted in a medium to long-term nature. The project is proposing a range of a range of measures to mitigate or reduce many of these issues, but the Council does not consider that that these are currently sufficient to address them. Another example where a monitoring strategy is needed. 14. Road drainage and water environment – the project results in several features to handle water either off the carriageway or through indirect effects on drainage. The most obvious of these is the cascade of drainage / infiltration ponds running northeast down the dry valley from Thong, unnatural features in a chalk landscape. Under the marshes a similar situation exists with the additional presence of the tidal Thames and its navigation channel. The ground stabilisation tunnel, in particular at the Milton site where it comes to the surface, has the potential to have a major impact on the water table The RAMSAR/SPA is primarily for wading birds, to maintenance of appropriate hydrological conditions is essential. This includes the marsh drainage system that passes beneath the Thames & Medway Canal and the resilience of the soft flood defences. Water levels in the canal need to be maintained. The technical issues involved are for Environment Agency, Kent County Council (as lead Local Flood Authority) and Port of London as appropriate to deal with. The Flood Risk Assessment appears not to have considered all risks, as required by the NPSNN, and if the tunnels have 120 year life so should the assessment. The drainage ponds pose a landscape and management issue, as does what happens should the proposed pumps fail for extracting water from the tunnels. The potential impacts from the construction process from surface run off given the size of land area involved are a concern. 15. Climate – the project is seeking to minimise its carbon footprint, but in a context where policy has changed dramatically since the route choice consultation in 2016. The project has a significant impact from both its construction (1.8 MtCO2e) and operation (4.9 MtCO2e over 60 year life including maintenance). The construction figure depends on achieving very ambitious targets which must carry a very high delivery risk. The operation metric is dependent on the achievement of Government decarbonisation goals, that on current progress look unlikely, and are not within National Highways direct control. Overall, this project is set in the context of the national carbon emissions, of which transport makes up 24% nationally, which is inappropriate as it fails to take into account the cumulative impact of all transport projects. The NPSNN having been approved in 2014 is clearly out of date from this point of view, no doubt to be rectified in the announced, but delayed, review. The Borough Council declared a climate emergency and has adopted a net zero target by 2050. The GHG emissions during construction (2024-2030) and operation (2030-2050) will potentially add to the baseline of what the Council are seeking to reduce and will make our task harder overall within the confines of the Borough boundary. National policy can be expected to change in this area. 16. Cumulative effects – as already indicated the Council considers that the cumulative impacts have been under represented, particularly where a number of small scale impacts come together. This topic will be explored further in the Local Impact Report and Written Representations. Table 16.10 lists major planning permissions and site allocations which include a number of sites in Gravesham described as ‘Site Allocations’. These are possible development sites included in the 2020 Regulation 18 Stage 2 consultation, which have yet to progress to Regulation 19, so are not formal ‘site allocations’. They do, along with sites elsewhere, illustrate the development quantities that have not been included in the transport modelling. Economic case – the proposal rests on an economic case that claims benefits exceed disbenefits. The BCR of this scheme has been declining as costs rise and can be expected to fall further as more appropriate mitigation and compensation requirements are included. The net result of the Environmental Assessment, Planning Statement and Appraisal Report it to seek to justify the scheme on the basis of the claimed public benefits whilst accepting that there are significant impacts for heritage, ecology, landscape and people etc. Locally the question is what benefit does Gravesham gain from the scheme, both during construction and operation. During construction on the plus side there is the possibility of new jobs, training opportunities, openings for existing and new businesses. On the negative side is the impact on local businesses and residents from the disruption from major roadworks on the A2, closure and/or disruption to local roads, impact of additional traffic and general disturbance. This has to include perceived impact (we won’t go to x because of the uncertainty as to access) as well as actual impacts, for example the 19 month closure of Brewers Road. When the crossing opens there will be additional capacity across the river (projected to be increase by 54% in pcu flow terms in 2045), but it is clear that much of the traffic is to/from the A2/M2 corridor (and M20/A20) further east. Due to the constraints of Green Belt, Nature Conservation, Heritage and Landscape there are no large areas of land for release in Gravesham. There is no equivalent to the Tilbury Freeport extension for example. So the journey to work area (in and out commuting) will expand, based on the use of cars, in contradiction to carbon reduction goals. Further it is not clear what sort of jobs will be on offer and whether they match the Gravesham labour market. Existing permitted or allocated development already has to have a robust transport strategy without the Lower Thames Crossing, since it cannot be assumed (or in some cases long proceed it). The transport infrastructure also has to support development further east along the North Kent coast, for which the A2/M2 is the primary route. This includes major development to the west in the Ebbsfleet Development Corporation area. A key element of North Kent transport strategy is maximising public transport usage, as exemplified by Fastrack. The submitted documentation provides a timeline for construction but this depends on the permission process not being delayed, the potential for judicial review and whether funding will be made available. The area has suffered from uncertainty in that regard since at least 2016. The draft skills strategy is appended to the draft heads of terms of section 106 agreement (see below). It is not clear how this would be delivered and by whom, and therefore how much benefit Gravesham would see. Section 106 - whilst National Highways have included a Section 106 Agreement Heads of Terms document (Application Document 7.3), this is very limited in scope primarily because National Highways only considered that an agreement would be drafted very late in the process. As the Council has advised National Highways, it is consider that a much more comprehensive document is required. This is particularly pertinent to resolving some of the Principal Areas of Disagreement Summary Schedule and will need to be seen in combination with Development Consent Order itself and the other control documents. Land issue The submitted application seeks to take powers to compulsory purchase the rear part of Cascades Leisure site complex on Thong Lane owned by Gravesham Borough Council to be part of the proposed Chalk Park, to accommodate diverted public rights of way, and small element of cutting leading to the southern portal. This land currently has a par 3 pitch and putt course on it. Discussions on this matter are ongoing, but in the interim the potential compulsory acquisition of this land is objected to, along with potential disruption to the operation of the Cascades Leisure Centre and its playing field uses during construction. 24 February 2023