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 Thurrock Council


This Relevant Representation made is made on behalf of Thurrock Council. The
Order Limits, as identified on the ‘Location Plan’ accompanying the submission, is
entirely within the administrative boundary of Thurrock Council, although those
proposed works located below the Mean Low Water Mark are beyond the jurisdiction
of the Council as local planning authority.


As noted within the submitted application, the Port of Tilbury has operated from its
current site (to the west of the application site) since the late 19th century. The
existing Port is a major presence and employer within the Borough.

Development Plan Policy Overview

The statutory development plan for Thurrock is the Thurrock Core Strategy and
Policies for the Management of Development (as adopted 2015). Paragraph 3.18 of
the Core Strategy identifies Tilbury as a ‘Regeneration Area’ and paragraph 3.34
states that Tilbury is a key location for employment in the Borough and will provide
between 1,600 and 3,800 additional jobs in logistics, port and riverside industries.
Paragraph 3.36 of the Core Strategy refers to enhancement of the landscape setting
of Tilbury Fort and paragraph 3.37 refers to improvements to public access and
informal recreation along the riverside at Tilbury. Table 3 of the Core Strategy lists a
number of Strategic Spatial Objectives including increased prosperity and
employment growth in Thurrock in the five employment hubs - including Tilbury
(SS02) and port-related activity at Tilbury (SS019).

The Council’s Core Strategy Spatial Policy for Sustainable Employment Growth
(CSSP2) identifies Tilbury Port as an economic cluster and an area for future
development. Port operations, logistics, transport and construction are identified as
core sectors for Tilbury by this policy. Finally, Core Strategy Thematic Policy
CSTP28 (River Thames) promotes the economic and commercial function of the
river through, inter-alia, safeguarding additional adjacent land required for further
port development.

Although the selected Development Plan policies referred to above generally support
the economic function of the Port of Tilbury, the Council places great importance on
balancing any Port expansion against the full range of environmental considerations
and in light of the development plan policy designations described below.

Development Plan Policy Designation

The Order Limits is subject to the following planning policy designations as defined
by the Core Strategy policies map:

- Green Belt;
- Primary Industrial and Commercial Areas;
- Employment Broad Location – Urban Extension;
- Green Chains;
- Local Nature Reserves; and
- Road Improvement Schemes.

It is notable that areas within the Order Limits have no land use policy designations
within the Core Strategy.

Summary of Main Issues / Impacts

The Council considers that the main issues and impacts associated with the
proposals are as identified in the submitted documentation, in particular the
Environmental Statement. These issues and impacts comprise (in no particular

Socio-economics: the Core Strategy (paragraph 3.8) notes that the most
deprived wards in Thurrock include Tilbury St. Chad’s, adjacent to the Order
Limits. The non-statutory Tilbury Development Framework (October 2017) also
notes the high incidence of adults in Tilbury with no educational qualifications.
The impact of and opportunities / benefits arising from the proposals during
construction and operation are therefore an issue for consideration.

Health: this issue partly overlaps with the topics of air quality and noise referred
to below and socio-economics referred to above. The inclusion of a Health
chapter within the Environmental Statement provides an analysis of potential
impacts on well-being and quality of life and is a relevant issue for

Landscape Character and Visual Impact: the area within the Order Limits
displays different landscape and visual features, however the common
character of Tilbury and the site is a low-lying, flat landform adjacent to the
River Thames. The proposed warehouse building, ancillary buildings /
structures, container storage, silo, aggregates stockpiles, aggregates
processing facilities, artificial lighting, road and rail infrastructure and
associated vehicle movements and berthed vessels will all impact to a degree
on landscape and visual receptors. Accordingly landscape and visual impact is
a relevant issue for consideration.

Terrestrial Ecology: the Council does not intend to comment on the issue of
Marine Ecology as this matter is beyond the jurisdiction of the local planning
authority. Although parcels of land within the Order Limits will be of limited
value for ecological interests, parts of the site are designated as Local Nature
reserves by the Development Plan or provide habitat of some potential value
for these interests. The potential impacts on terrestrial ecology during
construction and operation, as well as proposals to mitigate impact are relevant

Archaeology and Cultural Heritage: the submitted Environmental Statement
considers both terrestrial and marine archaeology. As the jurisdiction of the
Council as local planning authority terminates at the low water mark it is unlikely that the Council will comment on marine issues under this heading.
The Environmental Statement correctly identifies Tilbury Fort as an important
heritage asset located south of the proposed road and rail infrastructure
corridor and west of the proposed extended berth, trailer / container storage,
warehouse building and aggregates processing / storage facilities. The setting
of the Fort is currently influenced by Port-related development to its west. The
Council considers that any further impact on the setting of the heritage asset
from the proposals is an important relevant consideration. The Council also
considers that the extent to which the proposals can contribute to the policy
objective of enhancing public access to the Fort and riverside is a relevant

Land-Side Transport: the potential impact of additional vehicle movements on
the local road network during the construction and operation of the
development, and in particular the operation of the A1089 / Dock Road /
Thurrock Park Way roundabout junction (the Asda roundabout) is an important
relevant consideration. The Council also considers that the relationship
between the proposals and the local walking and cycle network, including
public rights of way are relevant considerations.

Hydrogeology and Ground Conditions: parts of the area within the Order Limits
were formerly used in connection with the coal-fired Tilbury Power Station.
Accordingly there is the potential for ground contamination and this issue, along
with proposals for associated remediation and impacts on hydrogeology, are
relevant considerations.

Water Resources and Flood Risk: the Tilbury area, including land within the
Order Limits is generally flat, low-lying former marshland located on the
northern bank of the River Thames. The issue of flood risk is therefore a
relevant consideration.

Noise and Vibration: sensitive receptors, particularly residential occupiers are
located close to the proposed infrastructure corridor, storage areas and the
Construction Materials and Aggregates Terminal. The impacts of noise and
vibration from construction activities and during the operational phase of the
development are relevant considerations.

Air Quality: similar to the topic of noise and vibration, sensitive receptors,
including residential occupiers are located close to both the access
infrastructure corridor and the operational areas of Tilbury2. The impacts on air
quality from the construction and operational phases of development, including
emissions from vehicles are relevant considerations.

The following comments summarise the current position from the main Thurrock
Council service areas:

Thurrock Council Environmental Health

The submitted Construction Environment Management Plan (ref. 6.9) has been
reviewed and it is considered that the implementation of the measures and
procedures enclosed in this document are sufficient to provide suitable mitigation
during the construction period.

The submitted Operational Management Plan (ref. 6.10) has been reviewed. Areas
of the report, with regards to operational noise, are highlighted. The applicant may
be aware that the Port has been subject to noise complaints from ship generators
operating overnight.

Section 7.4 refers to air quality and dust control measures:

- Lower emission engines as they are developed;
- Improved dust control systems for handling of bulk cargoes;
- Ability to provide shore power to vessels as technology improves so vessel
engines can be turned down in port, reducing emissions; and
- Adoption of electric vehicles as technology improves and makes this equipment
viable for operational uses.

The supply of shore power also would have a positive effect on noise and allow
greater control of potential noise from ships. It is suggested that providing shore
power should be looked on as a priority in any improvement programme. Generally
the document lays out a basis for future operations and actions required when they
come to light and will rely on professional competence of the persons in control for
those areas they are responsible. The ongoing improvements outlined and subject
to technical availability so are to an extent aspirational. Nevertheless it is considered
that the document provided a basis for the future operation of the Port and industrial

With regard to air quality, the submitted air quality assessment and appendices have
been reviewed and it is agreed that the proposed development will not have a
significant impact on relevant receptors in terms of the modelled outputs for nitrogen
dioxide (NO2) and particulate matter (PM10 & PM2.5). The assessment considered
areas of most relevant public exposure in relation to the impacts generated from the
proposed development, and all modelled receptors in this assessment were
appropriate. All the modelled receptors fall either below or well below the relevant
air quality objectives for NO2, PM10, and PM2.5. There was one receptor (R10) along
Dock Road Tilbury, nearest St Andrews Road which had a “moderate adverse”
impact. The “Do Something (DS) 2020 modelled scenario showed a concentration
of 30.6 Microgram/m3, with a change of 4.4 microgram/m3 from the “Do Minimum”(DM) 2020
scenario. This is not a concern as it is well below the air quality objective 40 microgram/m3 for NO2. There were also four “slight adverse” impacts at receptors (R9, R13, R14
and R19), however all of these were below the air quality objective for NO2 and
hence are not a concern. The remaining receptors were all classed as “negligible”
and these were all below the air quality objective for NO2, and are not an issue. In
addition the modelled PM10 and PM2.5 outputs were all classed as a “negligible”
impact. All of these receptors were below the air quality objective 40 microgram/m3 for
PM10. However the report did not state daily mean exceedences for PM 10.
Additional information was requested from the consultants on daily mean PM 10
modelling results. After receiving this information it is confirmed that this will not lead
to any further exceedences at the modelled receptors either, and is not an issue.
The Environmental Health Officer is satisfied that the model used in the assessment
was appropriate, and it was also used in accordance with the criteria laid out in the
Defra TG(16) Technical Guidance. The assessment represented a worst case
scenario, and the model verification process was robust, and limited any
uncertainties associated with the model. The Environmental Health Officer is
therefore satisfied that the proposed development in terms of the “Operational
Phase” will not have any foreseeable or lasting impact in terms of air quality on
nearby residential receptors most at risk from this development.

Noise and Vibration - Section 17.0 in the Environmental Statement (ES) contains the
assessment of Noise and Vibration. The assessment uses a standard reporting
approach and the methodology employed agreed in advance with this section.

There is overall agreement with the assessment, and the EHO is satisfied that it has
covered all the relevant noise and vibration impacts both in the construction and
operation of the proposed Tilbury2 development. The EIA Significance criteria
developed is acceptable, and is summarised in Table 17.15 for both construction and
operational phases, depending on the source. The Policy Significance Criteria with
respect to effect thresholds, LOAEL and SOAEL, are acceptable and these are
summarised in Table 17.16 for both construction and operational phases.

The development “Scheme Design and Embedded Mitigation” detailed in paragraph
17.134 (page 17-36) will minimise scheme impacts. It is proposed to install the noise
barriers within the transport corridor before the construction of the road and rail links
to further mitigate construction noise. A noise reassessment will be made on the
basis of the finalised operational design and procedures for the RORO and CMAT
(as required by the DCO) and, where a significant effect is predicted for a receptor,
an offer of sound insulation will be made.

There will be further potential to mitigate impacts during both the construction and
operational phase as detailed in paragraphs 17.223 to 17.226, including temporary
noise screening of static plant during construction.

The Operational Residual Impacts paragraph 17.229 refers to a Table 17.14, but this
appears to be the wrong table. This should be table 17.46 – “Summary of Airborne
Noise Significance” on page 17-53. The daytime operational port noise is indicated
to have a significant noise impact at receptors near NSR2 in Sandhurst Road plus
two others in Gravesham. For those receptors an offer of sound insulation to the
dwellings is proposed to minimise the residual effect to “minor”.

Additional “errata” documents were submitted to PINS on the 22 December 2017. I
have examined those documents that could have a bearing on comments from this
section, and I do not believe any alterations to our comments will be required.
In document “TR030003-000467-PoTLL-T2-EX-11 Errata ES Chapter 5 Track
Changes” I have noted the addition of “Extent and method of piling” detailing
terrestrial and marine piling in paragraphs 5.115 to 5.118.

Thurrock Council Flood Risk

Key comments will be in relation to discharge rates for the northern area of the site
and the access road. We will also wish to comment on flood risk for the whole site.
In addition we are likely to submit comments in relation to water quality and also the
treatment / culverting of existing watercourses. We have previously highlighted
these issues and some previous concerns are still outstanding. However, we are
expecting continuing dialogue with the applicant.

Thurrock Council Public Health

Noise – there are concerns on this issue and would require further discussion or
information on the assessed health impact of noise on local residents, which appears
to be underestimated in relation to the existing population. Local residents already
experience higher rates of long-term conditions and early deaths from circulatory
disease, stroke and CHD all of which can be impacted by noise. Further detail on
baseline existing background noise is also requested. Mitigation measures include
noise insulation to homes yet it is not defined who would become eligible / receive an
assessment and the geographical boundaries of this – more information is required
on this and how this will be funded.

Active travel / cycling & walking – further discussion and clarification is required on
how it is intended to ensure active and sustainable travel is a priority for employees
and visitors to the site. Further discussion and information is required on the
mitigation measures which have been assessed to have a positive impact on local
resident walking and cycling in the local area including access to the riverfront. This
is to ensure all options are fully considered and are appropriately linked into local
initiatives, and funding contributions are adequately requested.

Local Employment –the skills and employment strategy should match the needs of
the local population.

Air Quality – respiratory disease deaths, hospital admissions for COPD and
premature mortality from cancer are experienced more often than average in Tilbury
and we would request further discussion on the mitigation measures – in particular
the use of cleaner, greener vehicles. Supply of shore power should be given priority.

Thurrock Council Waste

Thurrock Council raises the following concerns with regard to the waste matters that
are considered in Chapter 19 of the Environment Statement (ES) and supporting

- the failure to address the baseline waste arisings and capacity within Thurrock
as the Waste Planning Authority (and the host authority) and the inappropriate
use instead of the Essex & Southend Waste Local Plan data as a proxy
(Thurrock waste data is not included with the Essex & Southend plan);

- incorrect assumptions are made in the ES methodology regarding Thurrock
C,D&E waste arisings and flows derived from the EA data in order to justify that
Essex data should be used as a proxy for the baselines assessment of waste

- the ES methodology fails to adequately acknowledge or assess the potential
impacts during the operation phase of waste arisings from the asphalt and
concrete batching and block-making process identified as proposed uses within
the development.

Thurrock Council Highways

Thurrock Council disagrees with some of the assumptions and opinions within the
submitted Transport Assessment. In particular, there are outstanding queries
regarding impact on the Asda roundabout junction and associated mitigation

Thurrock Council Historic Environment Advisor
- The Historic Environment Team would be unable to support his application.
- The proposed mitigation/enhancement measures lack clarity and detail with the
overall effectiveness of the proposed mitigation/enhancement appearing
- At present the proposed will cause considerable harm to the setting of a
Scheduled Monument of international significance.
- The initial Statement of Common Ground was not agreed with further clarity
and details required as well as some amendments.

- Archaeology: in general the scheme is largely acceptable with respect to below
ground archaeology, though there is a general lack, notably at the northern
extent of the site.
- Berths: there is very limited potential to reduce the level of harm caused by
extending the berth up-stream. This element of the proposed will not be
- Silo: the use of a single silo (rather than two shorter) in light grey will potentially
reduce the impact. Previous suggestions to locate it away from the shoreline
have not been implemented.
- Container Storage: given the amount and height, the proposal will have a
significant impact with the effectiveness of mitigation limited. The height, extent
and proximity of the storage remain a cause for concern.
- Lighting: the use of low level lighting will reduce the visual impact, however, the
impact remains significant.
- Warehouse: the use of light grey cladding will reduce the visual impact,
however, the overall size of the proposal remains a concern.
- Aggregates Storage: this area of the site is relatively undeveloped, the proposal
will cause harm with potential effectiveness of mitigation limited.
- New Road: there is a general lack of detail to accurately assess the
effectiveness of the proposed mitigation.

- Two Forts Way: the increased length of the berth will have a negative impact
upon the Two Forts Way with outward views being cut off. There remains great
scope to enhance this route by bringing it within the flood wall and raising it up
to gain outward views – viewing platforms would have the same effect.
- Downgrading of Fort Road: the effectiveness of this measure relies upon
detailing of traffic calming and limiting the size of vehicles utilising the route.
This need further more detailed consideration.
- Car Parking: the new car park at Worlds End Inn will improve the current
facilities, however, details are scant.
- Connectivity: whilst the proposed will retain connectivity with housing to the
north, the quality of experience along this route is a cause for concern. A
poorly considered scheme will not be an enhancement and may also lead to
anti-social behave and increase in flytipping etc.
- Interpretation: the proposed installation of way-finding / interpretation has not
been considered with sufficient care and attention, the quality of this
enhancement may be negligible.

Thurrock Council Landscape and Ecology Advisor

The surveys that have been undertaken are considered appropriate and deal with all
the plants, species and animals likely to be affected in an appropriate level of detail.
The ecological surveys conclude that the site currently supports a range of important
plants, animals and habitats. Sites such as the Lytag and Tilbury Centre LoWSs
support biodiversity resources measurable up to National levels of importance.
There are a number of rare and important plants, lichens and invertebrates found on
the site. A large proportion of the most significant habitats will be lost and there is
little scope for mitigation on-site. Despite the biodiversity value of the site there is as
yet no information about the nature of the proposed compensation scheme. Despite
references in the ES to a scheme being developed with NE, Essex Field Club and
Buglife they have had little involvement. The conclusions of the HRA report, that the
development will not have any significant likely impacts on features of qualifying interest, is accepted. While the argument presented by PoTLL regarding cumulative
assessment is noted there is still a major concern that the number of NSIP projects
in this area will have significant adverse ecological effects that will be hard to
mitigate. The piecemeal approach restricts the ability to achieve a
mitigation/compensation package at the scale necessary for the scale of
development in this area. The LVIA has been carried out using appropriate
methodology. There is still concern that there should have been an additional
viewpoint from the PRoW south of West Tilbury. There are major concerns over the
effects of the scheme on the setting of Tilbury Fort. A key concern is the impact of
the extended jetty which will bring the large ships much closer to the SAM. Although
the LVIA states that the ships are ‘temporary’ as it is expected that they will be there
for 4 hour twice a day it is likely that they will have a significant effect on visitors’
experiences. The overall development will be closer to the Fort than the existing
power station buildings. The new infrastructure corridor will also have adverse
effects introducing more movement and lighting closer to the Fort. The junction with
Fort Road will also likely be more visually intrusive. The overall landscape mitigation
package is considered to be very limited and will not achieve any significant benefits.
A more robust landscape mitigation scheme could also provide some additional
ecological mitigation features. It is considered that there should be more use of offsite planting etc. to achieve wider landscape mitigation measures.

Finally, Thurrock Council confirms that it is maintaining a dialogue with the Port of
Tilbury and is working to progress a Statement of Common Ground.