Agenda item

Environmental Impact Assessment Update


The Senior Consultant introduced the report and stated that it was divided into four sections: stakeholder engagement; Thurrock’s past concerns; Thurrock’s current concerns; and next steps. He explained that Highways England (HE) were currently revising the Environmental Impact Assessment (EIA), but that the table on the front page of the report outlined the process so far. He stated that the eleven topic chapters of the EIA document had been received from HE in July 2020, and the other technical documents had been received in August 2020. He described how Thurrock had commented on all these documents in October 2020, and HE had responded to these comments in February 2021, which Thurrock’s LTC team were still digesting and comparing to the EIA, within the Development Consent Order (DCO) Version 1. The Senior Consultant explained that the second page of the report included a table, which outlined the 11 topics that formed the EIA on the left-axis, compared to the stages of reporting on the top-axis. He stated that the team could then use this table to understand the Council’s issues with the EIA at that time. He explained that the table used a RAG system of reporting, with green boxes indicating that this area was satisfactory with no action needed; amber indicating there further work to be undertaken; red indicating there were some matters that require amendment; and purple indicating there were some priority matters that require urgent attention. He stated that all red and purple areas had been summarised in section four of the report, but many of the issues were within the amber category. He stated that those areas graded red or purple had been graded based on the information received in October 2020, and some progress had been made on some of these areas since then.

The Senior Consultant then outlined the rest of the paper, which covered four key issues, including air quality. He outlined the major issues surrounding air quality which included: emissions not being included from barges or non-road mobile machinery (NRMM); and, levels of PM10 and PM2.5 not being included for assessment or monitoring. He described how the team had not yet considered HE’s response to these issues, so the team were not yet sure if potential mitigation would take place or the right assessment had been undertaken. The Senior Consultant moved onto discuss cultural heritage and explained that HE had undertaken a full heritage assessment across Thurrock, but that Thurrock had questioned its methodology, and so HE were now re-doing the desk-based assessment. He added that there had also been incomplete archaeological surveys undertaken near the portal entrance. The Senior Consultant then explained that the team were currently assessing HE proposed landscape and biodiversity mitigation, but the team were unsure that the proposed mitigation would be adequate. He stated that the team were looking at the strategic area between Tilbury, Coalhouse Fort and Stanford-le-Hope, as this had an increased level of cultural heritage, as well as being environmentally important. He stated that HE believed the LTC scheme would create a biodiversity net gain of 15%, which Thurrock were also questioning, especially how it would be secured within the DCO Version 2.

The Senior Consultant moved on and discussed HE’s materials and waste strategy. He stated that HE had recently released a new site waste management plan, which the team were reviewing. He stated that the team are likely to encourage increased use of river traffic to transport materials, as this would reduce HGV traffic on local roads. He stated that the team were also pushing for more information regarding noise barriers, and were also trying to push for additional noise barrier locations along the route. He then explained issues surrounding population and human health, and felt that HE were now likely to be more transparent in this area. He described how the Community Impacts and Public Health Advisory Group (CIPHAG) would potentially be reformed, which could provide Thurrock and other local authorities with additional information regarding health impacts. He stated that Thurrock had published the Hatch report and non-technical summary that included 57 recommendations for mitigation, and early indications showed that HE would already accept and include two thirds of these within the DCO Version 2, subject to more detailed scrutiny. He stated that discussions regarding employment and skills were going well, and meetings were taking place regularly to discuss this. The Senior Consultant added that Thurrock were also seeking advice from Essex County Council regarding road drainage and water environment along the route, and the teams would be meeting next week to further this discussion. He summarised and explained that the cumulative assessment, which took into account all confirmed developments near the site, was also being developed, and the cut-off for such schemes is likely to be extended due to the DCO not being submitted until later in 2021.

The Chair thanked the Senior Consultant for the report and felt the team needed to push HE to include barges and non-road mobile machinery (NRMM) as part of their air quality assessment. Councillor Rice highlighted the issue of tree planting near the route, and urged the team to push for mature trees rather than whips. He felt that whips would take time to grow and therefore offer little protection, particularly for communities living in Tilbury, Ockendon and Chadwell St. Mary. He added that the trees also needed to be of a good standard to offer the necessary protection as soon as the route was opened. The Senior Consultant replied and stated that the landscape varied across Thurrock, and not all areas would be suitable for tree planting. He added that tree planting along similar routes usually consisted of standard or tall standard trees and whips, and stated that it would be unusual to plant semi-mature or mature trees, as they were expensive and were more likely to fail. He highlighted that the team were pushing HE on the issue of tree planting and would continue to do so. The Ecology and Biodiversity Officer added that HE would be considering different types of screening along the route, which included trees of various sizes. He explained that larger trees had an increased failure rate and were also slower to establish and grow. He stated that him and the team were currently working through tree planting along the route, including which mixture of trees to plant and where. He added that it also took greater energy to move larger trees which reduced their climate off-setting impact. He summarised and stated that the team were currently deciding on species choices and were focussing on faster growing trees.

Councillor Muldowney felt it was good to see increased transparency from HE, and thanked the team for their hard work in digesting and responding to the information that HE provided. She felt that although it was good to receive this information before DCO submission, and that the team were moving in the right direction, no mitigation had yet been confirmed. The Senior Consultant agreed that mitigation included in the Hatch report had not yet been confirmed, but reassured the Task Force that this was normal for this stage in the process. He explained that HE also had to take into consideration the views and mitigation requests of other local authorities, stakeholders, and environmental stakeholders, and highlighted that it could take time to balance these views and reach an agreed level of mitigation. He mentioned that the process surrounding mitigation had not been started in earnest until recently, and the process had only recently become more open, with more information sharing. He added that the LTC team were also paid for through Thurrock’s Planning Performance Agreement, which meant that Thurrock did not have to pay for many external consultancy services needed to review the DCO documentation and resolve issues. He summarised and stated that the team were now drilling down into the detail of the Hatch report with HE, and felt that agreement on this could be reached by late spring/early summer. He added that this agreement would then be secured either through the DCO Version 2 or separate legal agreements. Councillor Muldowney added that she felt the report did not consider green infrastructure, such as open and leisure spaces which had been captured as part of the Hatch report. She also highlighted the increased use of bridleways in the scheme and questioned how the team were proposing to stop anti-social behaviour, particularly from motorbikes, in these areas. The Ecology and Biodiversity Officer replied that the team were currently looking at Coalhouse Fort and how to link this to open spaces in the area, as well as focussing on strategic open spaces. He added that the Environmental Impact Assessment (EIA) included many separate routes, which the team were trying to link together, including through inter-directorate working and through external stakeholders. He stated that it would be a balancing act to ensure Public Rights of Way (PRoW) were open enough for all users, but also prevented anti-social behaviour. He explained that a number of barriers and structures could be put in place to limit access, but these were not fool-proof and bikes would still be able to get through. He commented that regular policing would need to take place, but highlighted that the more legitimate users who used the bridleway, the less likely it was to experience anti-social behaviour on motorbikes. The Ecology and Biodiversity Officer summarised and stated that the team were working through all these issues with HE, and were liaising closely with the PRoW team to look at the issue of anti-social behaviour and were working on this in detail.

The Business Representative highlighted the construction impacts of the proposed scheme and felt that by using the river and ports to transport goods, it could reduce construction traffic on Thurrock roads by at least 50%. He stated that the new aggregate terminal in Tilbury 2 would be up and running by quarter 4 2021, and felt that Thurrock should be pushing HE to consider river usage for construction traffic, which would reduce traffic on the roads and improve air quality. He added that if the ports were used for construction traffic, different machinery could be used on the roads, such as muck moving machines, which would also reduce air pollution. He felt that by using the ports, the scheme could also improve local businesses. The Senior Consultant responded and stated that the Planning Inspectorate had expressed concern at the DCO Version 1 regarding the transport assessment, as this had not been shared with Thurrock and had not been linked to the site waste management plan, Navigational Risk Assessment or the Health and Equalities Impact Assessment (HEqIA). He stated that HE had assessed construction traffic by a worst case of much HGV traffic, and would then need to provide mitigation for this level. He mentioned that any form of construction traffic reduction would be good, as this would also improve road safety, and the team were likely to encourage to increase river transport usage. He summarised and stated that Thurrock would not get involved in commercial discussions, but the DCO Version 2 should secure some level of river transport for materials and waste.

The Thames Crossing Action Group (TCAG) Representative highlighted point 12.3 of the report and questioned the figure of £7billion estimated economic benefit. She commented that the last figure given for economic benefit had been in 2017 when the government had announced £8billion of benefit at the preferred route announcement. The Senior Consultant replied that the figure of £7billion had been provided within DCO documentation by HE, but stated that he did not know if this referred to DCO Version 1 or any preceding documents. He stated that he would look into this and reply in writing.

Councillor Allen agreed with the Business Representative that use of the river for construction traffic would be good, but felt that there could also be some negatives, as ships were still large polluters as they could burn large quantities of oil. He stated that detailed work comparing the impact that ships compared to HGVs had on air quality needed to be undertaken. He added that trees along the route would also be important, and felt that juvenile trees would filter more air than adult trees, but required more upkeep. He questioned whether Natural England were involved in discussions regarding biodiversity in Thurrock. He also questioned the economic benefit to Thurrock, and felt that this could not be determined until HE knew how many vehicles would use the route. He queried if the team were working to promote wetland areas to create new habitats. The Senior Consultant responded the worst case scenario had to be mitigated against in the EIA, and this included the worst case scenario regarding construction traffic and plant and equipment. He added that HE employed a large traffic modelling team and stated that traffic modelling followed a strict methodology, for example by using mobile phone data to work out people’s journeys and habits, and this was part of how the volume of cars/other vehicles were predicted to use the route was calculated. He stated that although it was scrutinised for accuracy, it was still a model, and open to variation. The Ecology and Biodiversity Officer added that Natural England were involved in discussions regarding biodiversity, on both sides of the river. He stated that he had met with the Natural England team to discuss baseline biodiversity levels and invertebrate levels, and this had been discussed in detail. He added that the team had also considered the Habitat Regulation Assessment (HRA), which considered all of the potentially affected  international designated sites, such as Epping Forest, as well as the  Thames Estuary and Marshes Special Protection Area, , and that Natural England were working with HE on this to be able to inform the Planning Inspectorate. He added that the team were also looking at new wetland areas, for example in the Mardyke Valley, which could mitigate environmental affects both close to the route and further downstream, for example in Purfleet. He mentioned that there would also be balancing ponds along the route, and Thurrock were pushing to have the final say in the design of these ponds. He stated that the ponds should not be over engineered, and should be in-keeping with the local landscape.

Councillor Shinnick questioned the purple colour-coded areas, and asked how long it would take to receive updates regarding this from HE. She felt that Thurrock already had high rates of air pollution, and echoed comments regarding needing the right number and types of trees. The Senior Consultant replied that there were currently two purple areas and four red areas of concern, which were summarised at point 5.1-5.4 of the report. He commented that it would take some months to get change in these areas, as Thurrock were asking for air quality monitoring along the route, including for barges and construction machinery. He explained that HE only needed to meet certain standards, but Thurrock were pushing for more. He mentioned that if Thurrock could not get this level of mitigation agreed before DCO, then the Council could try again during the Examination phase.

The Chair questioned the baseline air quality conditions, and queried whether the baseline would stay the same or worsen once the route had been opened. The Senior Consultant explained the principle of NEWT, which meant ‘Not Environmentally Worse Than’ (although termed differently now), and stated that the general rule meant that HE did not have to improve air quality, it just should not worsen it without adequate mitigation. He added that local authorities and central government also had responsibilities for air quality and the government were currently pushing the green agenda. He added that as part of the Hatch report, Thurrock wished to plant an area of willows as a carbon offsetting measure. The Resident Representative asked if any update had been received regarding construction working hours, as previously these had been very long and would affect residents through increased noise and vibration. He also asked if false cuttings along the route could be increased in height using waste material, and if noise barriers would be absorptive or reflective, and how this would be measured. The Senior Consultant agreed that there was concern regarding working hours during construction, and how long HE had defined as the summer. He stated that this had been part of the Hatch recommendations, which had questioned the Code of Construction Practice (CoCP), and although working hours had been more or less standard, some proposed working days seemed long. He added that there needed to be a balance between having shorter working days over a longer period, or having longer working days over a shorter period, particularly near communities such as Linford and Chadwell St Mary. The Ecology and Biodiversity Officer added that the team also needed to find a balance between the height of the false cuttings, to ensure they did not have their own visual impact, and landscape planting, as it would be difficult for trees to survive where false cutting was particularly high. He added that there would also be logistical difficulties transporting waste materials to false cutting sites, and this could increase HGV movements. The Senior Consultant mentioned that the team were waiting on the noise assessment results to decide whether absorptive or reflective barriers would be better.

Councillor Spillman joined the meeting – 7.07pm

Councillor Allen stated that there would be no escort for hazardous vehicles in the tunnel, and queried whether this would increase the amount of hazardous goods being transport in the LTC compared to the Dartford tunnel. He added whether firefighting equipment, such as water, foam or dry powder sprinklers would be included in the tunnel. He felt that ideally there should be two new fire and rescue stations at either end of the tunnel portal. He also felt that the LTC tunnel could be the target of a terror attack, and asked if this had been considered. The Senior Consultant responded that Thurrock, Kent and Essex County Councils and Gravesham were in discussion with all blue light response services regarding tunnel safety and emergency service provision. He stated that Thurrock were currently waiting on the emergency services to confirm their requirements, such as cross passage distances and emergency provision. He added that any tunnel safety requirements would need to be legally secured, but the emergency services needed to outline their requirements before this stage. He felt that as the LTC would not require a tunnel escort, the LTC might see an increased number of hazardous vehicles compared to Dartford.

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