Agenda item
Thurrock Council Consultation Response (to follow)
Minutes:
The Interim Assistant Director Regeneration
and Place Delivery introduced the report and stated that the
National Highways (NH) consultation ended on 8 September 2021, but
Thurrock Council and other local authorities had received an
extended deadline of 6 October 2021 to submit responses, due to
internal governance processes. He asked that the Task Force
identify opportunities and potential amendments to the draft
consultation response before it went to Full Council for agreement
and final submission.
The Senior Consultant stated that the consultation response
included a 17 page short summary, a 100 page overall summary, and
approximately 500 pages of technical appendices. He stated that
this was an average length for a consultation response, and the
extension given to submit the response was due to governance
processes within local authorities. He explained that the
consultation response was split into seven sections, the first of
these being the adequacy of consultation and policy. He explained
that this document was approximately ten pages long and outlined
how meaningful the consultation had been, and if it had complied
with both National and National Highways (NH) policies.
The Senior Consultant outlined section two of the consultation
response which discussed traffic modelling and alternative
transport issues. He felt that this area presented issues for
Thurrock Council as the documents did not meet the necessary
objectives, and did not sufficiently identify alternatives. He
described how the third section of the response considered the
local impacts and benefits. He explained that Thurrock had
determined the proposed route would negatively impact local
connectivity, reduce the ability for housing development in the
area, and have a large impact on the local road network. He
mentioned that there was not enough detailed mitigation included in
the consultation for the proposed increase in traffic that would be
seen both during the construction phase and at route opening. The
Senior Consultant moved on and explained section four of the
consultation response which analysed construction impacts and
proposed mitigation. He stated that the response focussed on the
future, which included changes in travel patterns and the effect of
the government’s decarbonisation plan. He stated that the
current route proposal did not recognise the government’s
move towards decarbonisation, and did not include sufficient
provision for cycling and public rights of way routes. He added
that NH had not yet made a legal commitment to provide skills
training and employment for local people as part of the
construction phase, and also did not address how local companies
could become part of the procurement process.
The Senior Consultant explained section six of the response which
focussed on technical and process matters, such as Development
Consent Order (DCO) requirements. He explained that all of the DCO
requirements, except for the travellers site detailed design, had
to be approved by the Secretary of State under current proposals,
but officers were pushing for this to be amended, so approval could
be granted by Thurrock Council. He added that some of the utilities
realignment works would be Nationally Significant Infrastructure
projects in their own right, due to the size and complexity of the
works to be completed, and Thurrock felt there had been a lack of
assessment of these works by NH. He summarised and stated that the
team had also provided summaries of each of the technical
documents, as well as looking into compensation policies, and had
proposed additional recommendations for NH.
The Chair thanked the team for their hard work in producing the
documents, and felt that overall it was a good response. He queried
what data the team were still waiting on from NH. The Senior
Consultant stated that the team were currently waiting on traffic
modelling data, as the current data did not show the impact on
local traffic. He explained that NH had used 7-8am as the peak
traffic hour in the morning, but in Thurrock the peak hour was
between 8-9am, so traffic impacts could not be reasonably assessed.
He added that officers were also waiting for air quality and noise
monitoring data, as this had not been refreshed since the traffic
model had been updated. He commented that the team were also
waiting on the detail surrounding health impact data to be able to
understand impacts and what mitigation might be necessary.
Councillor Muldowney highlighted points 1.3.10 and 1.3.11 of the
consultation and policy document, and felt it was good to see
officers pushing for specific design alternatives. She felt that NH
were assuming that the route had already been agreed, but
highlighted that other schemes such as the A303 and A38 had not
been agreed at DCO. She also queried if NH were taking into account
PM2.5, which had recently been agreed by the House of Lords as part
of the Environment Bill, and would now be sent to the House of
Commons for agreement. She felt that there would be an increase in
PM2.5 along the route, particularly at the A13 junction where cars
and HGVs slowed and braked suddenly to exit and enter onto a
variety of roads. She stated that the proposed route would come
within 100 yards of residents of the Chadwell St Mary flats in
Godman Road, as well as the new school, and homes within the Little
Thurrock area. She added that there had not been an environmental
expert at the consultation event in Chadwell St Mary, or at other
events across the borough. She asked how likely it would be that
Thurrock Council could negotiate with NH about changing the
proposed route. The Interim Assistant Director Regeneration and
Place Delivery replied that the team had asked NH to provide more
evidence and data regarding air quality, but they had not yet
received this information. He stated that the lack of data and
information from NH was included in the consultation response. The
Senior Consultant added that if the House of Commons agreed the
amendment regarding PM2.5, and therefore became an Act of
Parliament before DCO submission, then Thurrock Council’s
case would be strengthened. He added that officers had also
questioned the nature of the A13 junction as it was complicated and
prevented westbound travel. He explained that the team had
requested to see NH alternative analysis of this junction, but this
had not yet been provided. He stated that the route would have an
impact on the local road network, such as increased rat-running and
reduced performance of junctions such as the Orsett Cock,
particularly when taking into consideration the proposed additional
housing in the borough. He explained that both the A38 and A303
junctions had been recommended for refusal by PINS, then overturned
by the Secretary of State, and then had been refused again by the
High Court at appeal, due in part to the lack of alternatives. He
stated that these two proposals provided a precedent for the LTC,
and the team were pushing for more evidence on this.
The Interim Assistant Director Regeneration and Place Delivery
added that although NH were continuing to state that the route had
been agreed, the recent engagement suggested that they were
rethinking their approach. He explained that although it was
unlikely that the route alignment would be changed, the Council
would continue to push for this change for as long as possible. He
stated that there was a risk that NH may not achieve DCO consent if
some of the design details stayed the same. The Senior Consultant
added that current government views on climate change and
decarbonisation also supported the Council’s view on amending
the current proposals, as it would be hard for the government to
argue in favour of a new road whilst pushing for
decarbonisation.
The Chair felt it was good to see a large number of residents
taking part in the consultation, and thanked them for their input.
Councillor Chukwu questioned how many people had responded to the
consultation. The Interim Assistant Director Regeneration and Place
Delivery replied that 2,700 people had responded to the
consultation (on LTC’s current count); 95,000 people had
visited the website; 274 people had attended the webinars; and NH
had undertaken eight days’ worth of call back sessions.
Councillor Chukwu questioned when the team would receive health
impact mitigation data. The Senior Consultant replied that the team
and NH were due to meet in October to discuss the health impacts,
before the mitigation could be analysed to determine if it was
adequate. He stated that currently NH were delayed due to the
number of consultation responses they were analysing. He explained
that the local authorities, as well as external stakeholders such
as the Thames Crossing Action Group (TCAG) and the Port of Tilbury
had submitted large consultation responses, which had pushed back
their deadlines. The Interim Assistant Director Regeneration and
Place Delivery thanked external stakeholders for their consultation
responses, which had proven a consistency in approach as all
responses had had common themes running through them.
The Resident Representative thanked officers for their hard work
and felt it was a good consultation response. The Chair echoed
these comments and felt there had been positive feedback from the
Task Force. The Senior Consultant stated that at DCO submission the
team would again submit an adequacy of consultation response, and
the team had so far found that although there had been lots of
consultation, it had not been adequately meaningful. He explained
that if the adequacy of consultation response was accepted by PINS,
Thurrock would then submit a Local Impact Report (LIR), which would
be highly technical. The Chair questioned when people would be able
to make representations to the Planning Inspectorate. The Senior
Consultant replied that it would not be until summer of next year,
and would be in-person or virtual depending on COVID restrictions.
He explained that residents could register once the application had
been accepted, and PINS advice notes would be provided explaining
how residents could get involved.
Councillor Muldowney also thanked residents for participating in
the consultation. She stated that she had spoken to numerous
residents about the scheme, and some were still unaware of it. She
felt that the Council should communicate to residents more
regularly regarding the scheme. She asked if information regarding
the Planning Inspectorate representations could be included in the
Council’s newsletter. The Assistant Director Regeneration and
Place Delivery replied that residents could continue to make
representations to NH up until DCO submission, regardless of
whether there was an ongoing consultation open. He commented that
he would encourage the communications team to publicise this up
until DCO submission, so more local residents could make
representations if they wished. He stated that the team were also
developing a programme of monthly themes so residents could make
representations to NH monthly about different issues. Councillor
Muldowney questioned if there was a difference between a statutory
and a non-statutory consultation, and the Senior Consultant replied
that there was no appreciable difference. Councillor Muldowney also
highlighted that the NH consultation documents had not been easy to
understand, for example there were no page numbers and it had been
hard to understand the different maps. The Chair summarised and
thanked the team for their hard work on the consultation
response.
RESOLVED: That the Task Force recommended the
Council:
1. Maintained its opposition to the Lower Thames Crossing in
Thurrock and pursuant to Section 42 (1)(b) of the Planning Act 2008
and objects in principle to the proposed scheme.
2. Agreed the consultation responses set out in Appendix A (Summary
Review of Community Impacts Consultation) and B (Appendices A-K),
and that these should be submitted to HE by 6 October 2021.
3. Agreed to delegate authority to the Chief Executive and
Corporate Director Resources and Place Delivery, in consultation
with Group Leaders, Portfolio Holder for Regeneration and Chair of
the LTC Task Force to make any final, minor changes to the
consultation response which may arise during the consideration of
the consultation response by Council on the night.
Supporting documents:
- LTC - Item 5 - LTC Consultation Response - 20 Sep 2021, item 25. PDF 379 KB
- LTC - Item 5 - Appendix A - LTC Consultation Response - Main Summary - 20 Sep 2021, item 25. PDF 2 MB
- LTC - Item 5 - Appendix B - LTC Consultation Response - Appendix A-B - 20 September 2021, item 25. PDF 2 MB
- LTC - Item 5 - Appendix C - LTC Consultation Response - Appendix C-G - 20 September 2021, item 25. PDF 4 MB
- LTC - Item 5 - Appendix D - LTC Consultation Response - Appendix H-K - 20 September 2021, item 25. PDF 3 MB