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Representation by Highways England (Highways England)

Date submitted
8 October 2018
Submitted by
Other statutory consultees

Highways England wishes to register as an interested party in respect of the application by RiverOak Strategic Partners Ltd for a Development Consent Order for the upgrade and reopening of Manston Airport primarily as a cargo airport, with some passenger services, with a capacity of at least 12,000 air cargo movements per year.

Highways England is a strategic road authority appointed by the Secretary of State as the highway authority, traffic authority and street authority for the strategic road network. In respect of the application our particular interest is in the M2 Motorway A2 Trunk Road.

Amongst other things our licence to operate as a strategic highway authority requires us to ensure the effective operation of the network; protect and improve the safety of the network and to conform to the principles of sustainable development. "Sustainable development" means encouraging economic growth while protecting the environment and improving safety and quality of life for current and future generations.

The Secretary of State’s policy in respect of the strategic road network and the delivery of sustainable development is set out in Department for Transport Circular 02/2013.

Highways England commented on the Reopening Manston Airport – Consultation 2018 on 15th February 2018 advising ‘We remain neutral on the principle of the proposals, as the appropriateness of them is not a matter that Highways England will be required to determine. However, as a statutory consultee we need sufficient confidence that the proposals will not have a detrimental effect on the safe and efficient operation of our network. In this regard we note that the initial vehicular trip generation information within the PIER appendices indicates that in the order of 800 Peak Hour vehicles could be generated by the proposals at peak operation (2039). Whilst initial distribution proportions have been identified, these do not extend to our road network (M2/A2 corridor). In our opinion it is not unreasonable to assume that a proportion of the peak hour generated trips will use the M2/A2 corridor and we therefore require further information to enable Highways England to provide you with a substantive response.

We understand that a Transport Assessment is being produced, and will form part of the DCO application. We require this document to evaluate both the SRN and Local Road Network, and provide us with the volume of Peak Hour trips being generated on the SRN (by junction / location).’

Paragraph 109 of the 2018 National Planning Policy Framework 109 states that development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe. In the absence of the requested assessments of M2 Junction 7 and Duke of York Roundabout at the junction of the A2 and A258 and taking into account the cumulative impact of development proposed in the emerging Thanet District Local Plan, the applicant has not demonstrated that the development will have an acceptable impact on highway safety or that the residual cumulative impacts on the road network would not be severe.

Therefore Highways England objects to the proposed development.