The views expressed in this page do not represent those of the Planning Inspectorate. This page consists of content submitted to the Planning Inspectorate by the public and other interested parties, giving their views of this proposal.


Received 08 January 2018
From Kent County Council


Simone Wilding
National Infrastructure
Temple Quay House
2 The Square
Bristol BS1 6PN


Environment, Planning and Enforcement
Invicta House
County Hall
ME14 1XX

Phone: 03000 415673
Ask for: Francesca Potter
Email: [email protected]

8 January 2018

Dear Simone,

Re: Application by Port of Tilbury London Limited for an Order granting Development Consent for a proposed port terminal at the Former Tilbury Power Station (‘Tilbury2’) – Relevant Representation Submission

Following the Planning Inspectorate’s acceptance (21 November 2017) of an application for a Development Consent Order (DCO) for Tilbury2, Kent County Council (KCC) requests to be registered as an Interested Party at the Examination.

This letter provides a summary of the main aspects of the proposal which KCC agrees and/or disagrees, together with an appropriate explanation, in accordance with the Planning Inspectorate Advice Note 8.3. In summary, an outline of the principal submissions that KCC intends to make in relation to the application will concern:

- Highways and transportation as the Local Highway Authority for Kent;
- Minerals and waste as the Minerals and Waste Planning Authority for Kent;
- Resilience; and
- Biodiversity.

Highways and Transportation

KCC supports modal shift from road to sea and rail. The application proposes 2 or 3 train movements per day. The application must ensure capacity of available train paths through London. KCC’s stance is in favour of rail freight as long as it does not adversely affect peak passenger rail services.

Due to the significant HGV movements associated with this application, KCC would urge consideration of lorry parking provision, provided as part of the application. There is an existing shortfall of designated lorry parks in both Kent and Thurrock which leads to issues of road safety, damage to roads/verges and litter/human waste which can cause issues when close to residential areas.

This application would create increased competition with similar ports in Kent such as the Port of Sheerness and Thamesport (Medway). However, although economically adverse, this application could result in reduced HGV movements in Kent if container/Ro-Ro ships are docked at Tilbury instead of Kent ports.

Therefore, any increase in Ro-Ro traffic (trailer) from European ports such as Rotterdam/Zebrugge/Esbjerg may lead to a decrease in HGVs travelling through the Channel Ports, thus reducing the demands on the Kent network.

Minerals and Waste

The submission documents state the Construction Materials and Aggregates Terminal is likely to have a throughput of circa 1.9 million metric tonnes of bulk products per annum. Whilst the amount of mineral importation is not listed, it is likely to be significant proportion of the overall 1.9 million tonnes.

The County Council has an aggregate import and export relationship with Essex, in that some of Kent’s landwon soft sands are exported to Essex. The potential for increased aggregate importation is likely to help make the East of England area more capable of meeting its needs.

Overall, enhanced importation capacity into Essex is likely to reduce reliance on Kent’s own landwon supply. As landwon materials deplete across Kent and Essex, the importation of aggregates from marine sources will increasingly be used to substitute historical sources of supply – an approach that is supported in the National Planning Policy Framework (NPPF).

Project Resilience

The County Council notes that no risk assessment has been submitted that sets out mitigation for increased risk of maritime pollution incidents from vessels using the facility and re-fuelling / bunker operations, and no reference appears to have been made to this issue. Design parameters for both the facility and its operation should seek to minimise the risk of maritime pollution occurring and additionally, ensure sufficient contingency planning and containment (via drainage infrastructure and lagoons) and response in the event of any incident.

To this end, landscape design parameters should seek to maximise bio-security to curtail potentially destructive exotic organisms, and environmental services including flood attenuation, air quality and phytoremediation [the use of planting for remediation] should also be capitalised upon where possible. Planting plans should therefore comprise 100% native and UK grown trees and shrubs, with the species selection informed by historic biodiversity. Reference should be made to local pollen core data to evidence research into suitable flora species with consideration of the inclusion of species that bring particular environmental benefits, in addition to contributing to landscape and biodiversity.

Access and egress arrangements, muster points, security infrastructure, pollution control and containment of firefighting water should inform masterplanning to deliver a resilient port facility.

For long-term resilience of biodiversity on the site, planning parameters should ensure that niches for wildlife, such as bat tubes, bricks and swift bricks, areintergrated into to new structures at the facility where possible. Further, the significant extent of new highway planned within the site should ensure wildlife-friendly surface water drainage gullies and other infrastructure.


The County Council supports the range of ecological surveys that have been undertaken by the applicant to gain a thorough understanding of the ecology of the site.

Full details should be provided to show how the site design has taken account of the biodiversity of the site. Any design needs to adhere to the ‘avoid, mitigate, compensate’ hierarchy as set out in the NPPF, where possible. It is also recommended that the application includes details of ecological enhancements, above and beyond the mitigation/compensation measures required, to ensure that net gains for biodiversity are achieved.

Enhancements should therefore be an integral part of both the mitigation and overall design strategy for the project. If off-site compensatory habitat provision is required, it would be beneficial to work closely with other strategic developments nearby to utilise opportunities that can deliver a more ecologically coherent outcome than that which could be achieved working independently.

Habitat loss across the site looks likely as a result of the application; and consideration will need to be given to whether the remaining habitats will continue to provide the same ecological function as the mitigation strategy evolves. If the reduced size, fragmentation/isolation or disturbance of the habitats means that the habitats are unlikely to function as part of a coherent ecological network, the scale of compensatory habitat required is likely to increase.

The assessment of any likely significant impacts upon the Thames Estuary and Marshes Special Protection Zone (SPA) within the Habitat Regulations Assessment (as per the Conservation of Habitats and Species Regulations 2017) is welcomed. All necessary mitigation measures outlined in the Habitats Regulation Assessment will need to be incorporated into the masterplan to demonstrate that they are achievable and implementable.


KCC looks forward to working with the applicant and Planning Inspectorate as the project progresses through the DCO process. We will welcome the opportunity to comment on matters of detail throughout the Examination.

Should you require any additional information or clarification, please do not hesitate to contact me.

Yours sincerely,

Katie Stewart
Director - Environment, Planning and Enforcement