Representation by National Highways (National Highways)
- Date submitted
- 20 November 2023
- Submitted by
- Members of the public/businesses
National Highways has been identified as a statutory consultee, in relation to the Immingham Green Energy Terminal, pursuant to Section 42 of the Planning Act 2008, and as a relevant consultation body for the purposes of Regulations 11 and 13 of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017. As part of the consultation process, we have reviewed the following documents prepared by Associated British Ports [ABP]: • Immingham Green Energy Terminal 6.2 Environmental Statement Chapter 11: Traffic & Transport (TR030008 Volume 6); • 6.4 Environmental Statement Appendices Appendix 11.B: Traffic and Transport Cumulative Effects Assessment, • Immingham Green Energy Terminal 6.7 Outline Construction Traffic Management Plan (TR030008 Volume 6); and • Volume 6 Appendix A: Outline Construction Worker Travel Plan. In September 2022, we reviewed the Environmental Impact Assessment Scoping Report and concluded, given the nature and scale of development and its proximity to the SRN, the application should be accompanied by a Transport Assessment (TA), Travel Plan (TP), and Construction Traffic Management Plan (CTMP) to identify the impact of the development on access and accessibility, sustainability, and the free flow of traffic, and to inform the preparation of the ES. However, ABP states a separate TA has not been prepared as the full details of trip generation and distribution for both the construction phase and operational phases are included within Section 11.7 of the Traffic and Transport chapter. After a review of the Traffic and Transport chapter, we would consider the information and material included as what would be expected within a TA and therefore the assessment is sufficient to reach a view without the need for a separate TA. However, we would still expect a TP to be prepared for the operational stage of the project in order to manage down the traffic impact of development and maximise the accessibility of and within sites by walking, wheeling, cycling, public transport, and shared travel, in line Circular 01/2022. Construction trip generation, distribution and assessments After review, we would conclude that the volume of construction vehicle trips distributed on to the SRN has the potential to result in a material impact on junction operation. Consequently, we would request that ABP provides a junction capacity assessment for the A180 / A1173. After a review of WebTRIS data for the A180, we would consider 07:00-08:00 and 16:00-17:00 as more appropriate weekday peak hour periods than 08:00-09:00 and 17:00-18:00 for the SRN. Please note that Section D.2.7 of TAG Unit M3.1 gives the PCU for HGVs on motorways and all-purpose dual carriageways as 2.5. Given the nature of the highway network around the proposed development site, we request that the PCU equivalent value of 2.5 is used in order to ensure an appropriate assessment of anticipated vehicular traffic associated with the development. We would suggest that ABP also considers the inclusion of construction traffic associated with the enabling works on land east of Rosper Road, Killingholme (PA/2023/502) in addition to the stated committed developments within the ‘Traffic and Transport Cumulative Effects Assessment’. Subject to the impact at the SRN, there may be a requirement for National Highways to request mitigation measures, e.g., that the arrivals and departures of construction staff occur outside of the SRN peak periods. Operational trip generation and distribution We would typically expect the operational trip generation methodology to be revised to reflect Circular 01/2022 policy. However, considering the predicted operational impact on the SRN as highlighted, it is not anticipated that the proposed operational development traffic will have a significant material impact on SRN junction capacity. Nonetheless, we would still expect a TP to be prepared for the operational stage of the project in order to manage down the traffic impact of development and maximise the accessibility of and within sites by walking, wheeling, cycling, public transport, and shared travel. Outline Construction Traffic Management Plan We have reviewed the Outline Construction Management Plan (OCTMP) and would offer the following comments. It is stated that the contractor will liaise fully with the Police, Local Highway Authority and National Highways regarding any AIL movement to ensure that all required measures and approvals are in place. We would consider this appropriate. Additionally, it is also proposed that wheel cleaning facilities would be installed on site from the start of the construction phase, and all HGVs leaving the construction site would be required to wheel wash when exiting the site. We would note the OCTMP should also include the following: • A dust management plan; • noise management plan; • Pollution prevention measures; • Contractor parking. Recommendation On the basis of the above, National Highways’ requires further assessments to be agreed. I trust this response is helpful, but should you require any further information please do not hesitate to contact me.