Representation by Redrow Homes Limited (Redrow Homes Limited)
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
Redrow has an interest in development sites in the vicinity of, and area affected by, the Lower Thames Crossing (LTC). The following three points provide an outline of the principal submissions Redrow intends to make as a written representation in relation to the application. 1: National Highways’ (NH) recently agreed position on MedwayOne is that M2 Junction 1 (M2J1) is at capacity. MedwayOne has been excluded from the LTC Modelling (paragraph 4.1.13 of ‘7.7 Combined Modelling and Appraisal Report – Appendix C – Transport Forecasting Package’). Table 4.1 of that report sets out the standard criteria for including schemes within the core scenario. MedwayOne meets the criteria for inclusion. The reason given for exclusion (that ‘development proposals do not include necessary highway interventions’ in the opinion of National Highways) is not a relevant consideration in decision making in the context of the uncertainty log. The traffic flow through M2J1 with LTC is therefore under reported. A similar principle applies to Highstead Park which was excluded from the modelling for the same reasons. 2: The modelled performance of M2J1, is reported in ‘7.9 Transport Assessment’ (‘the TA’). Plate 6.11 of the TA shows the westbound on-slip from the A289 to the M2 to be exceeding 95% volume over capacity (V/C) in the AM peak in 2016 – the highest and worst reported categorisation in the report – and unchanged in 2045 (Plate 7.19). The eastbound off slip from the M2 to the A289 is reported as being 85-95% V/C in the PM peak in 2016, worsening to >95% V/C by 2045 (Plate 7.23). The introduction of the LTC worsen performance in both directions in the AM with >95% V/C. Similarly in the PM, the eastbound off slip from the M2 to the A289 shows a greater extent of >95% V/C with the introduction of the LTC. The LTC should be required to adequately mitigate its adverse effects on the network. Worsening the performance of a junction already forecast to operate at 95% V/C could reasonably be considered to be a severe residual cumulative impact on the road network with the potential to create unacceptable impact on highway safety, contrary to paragraph 111 of the NPPF. 3: The categorisation of impacts described in section 7.6 of the TA under-represents the impacts of the LTC. The methodology does not consider the disproportionately severe impact of worsening a junction which is already at, or exceeding, capacity compared with a junction which is otherwise within capacity. It also does not consider the relative importance of particular parts of the network in the context of their function and the volume carried. Plates 7.28 and 7.30 show the adverse effects at M2J1 and categorises these as slight to moderate adverse, but given the national and regional significance of the M2 and A289 respectively, and the high volumes carried, and given that demand at this junction is forecast to exceed capacity and that this will be materially worsened by the LTC, this must be categorised as major adverse and must be mitigated.