Tilbury2

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.

Tilbury2

Received 08 January 2018
From Gravesham Borough Council

Representation

Gravesham Borough Council (GBC) is located on the southern side of the River Thames opposite the site.
Gravesham supports the principle of Tilbury2 not only because of the benefits it brings in terms of sustainable transport and employment, but also because the heritage of our town is best appreciated in the context of a working and evolving river.

The Council is working with the Port of Tilbury on a number of thematic Statements of Common Ground, setting out the many areas where matters have been agreed and the limited areas where further work is required. The Council’s key areas of interest are the impact of the development relating to the following matters:

Archaeology and Cultural Heritage impacts

Key area of interest for GBC is the built heritage impacts. GBC is proud of its rich maritime history - see http://www.visitgravesend.co.uk/things-to-do/gravesend-riverside/ - and agrees, in general terms with the PoTLL, that the primary impact of the proposal is likely to be the intensification and spread of industrial development on the northern shore. This will not only impact directly on affected heritage assets but also change the context within which they are understood, appreciated and enjoyed during the day and at night.

The ES says “The operation of the Proposals is likely to have a potential impact upon the settings of the Scheduled Monuments of . . . New Tavern Fort and Gravesend Blockhouse, and the non-designated but nationally important Shornemead Fort. This will principally be through the visual effects of buildings, structures, the CMAT processing facilities, aggregate stockpiles on site, 100m high silo and large vessels at Ro-Ro and CMAT berths, as well as a significant increase in lighting effects at night”.
The submitted non-technical ES summary advises for “Operation: Adverse impact on setting of built heritage assets” that the “Approval of Thurrock Borough Council, in consultation with Historic England, in relation to surface details of key structures and final lighting strategy”. This doesn’t recognise the impact that lighting will have on views from GBC as highlighted above.

As the Council does not have its own archaeological support, we will defer to Historic England’s expertise.

Noise and vibration impacts

We are concerned about the proposed 24hr operation of the CMAT. The final PEIR issued on 13 June 2017 included “5.44 The CMAT is envisaged to operate 312 days per year (six days per week), 7am - 7pm Monday – Friday and 7am – 12pm Saturdays”. In the submission ES, 24 hour working is proposed with the ES indicating that night time CMAT activities would be major and significant at locations in Gravesend including the Gravesham Local Plan 2014 mixed use Canal Basin Regeneration Area Key Site (Policy CS04). The PoTLL considers that this is based on worst scenario modelling. Justification for the proposed 24/7 workings of the CMAT is being discussed between PoTLL and GBC and it was agreed that the PoTLL will be providing GBC with a justification of why 24/7 operation is necessary.
For the ES scoping, GBC’s concerns included “operation of the ships manoeuvring to and from the new port” and this is an area where agreement has not yet been reached. GBC considers that further work is also necessary around ensuring the provision of onshore electric plug-ins for moored ships to use rather than their engines because of the air and noise pollution impacts.

Ecological impacts

GBC recognises that understanding the ecological and biodiversity impacts of the project are extremely complex, with the project having the potential to impact directly and indirectly upon both the terrestrial and marine environments.
Whilst the development is outside the current site boundary of the Thames Estuary and Marshes SPA and the Ramsar site, the Council is keen to ensure that these international important sites are not adversely affected by the proposal. With the understanding of our limited expertise in this area, GBC defers to the expertise of Natural England, RSPB, MMO, KCC Ecology, Environment Agency etc

Air quality impacts

The PLA is developing an air quality strategy for the Thames that looks into shore-side power, emissions monitoring and a port-wide air quality inventory for the river. GBC is not convinced, at present, that Tilbury2 is fulfilling its potential as a strategically important infrastructure project.
Cumulative impact with the Lower Thames Crossing (LTC)
GBC is anticipating that the PoTLL will agree a SoCG with Highways England to ensure that the traffic impacts on Gravesham, generated by the Port of Tilbury, by virtue of the LTC once built, are comprehensively modelled and mitigated for and don’t fall between these 2 NSIP projects.

Additional comments

The PoTLL is proposing a range of compensation, monitoring and mitigation which will be secured by DCO requirement with and without additional legal agreements. The PoTLL has offered to produce a document which more clearly explains how these measures are secured via the DCO. This assistance is appreciated.