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 Essex County Council

Representation

Essex County Council (ECC) wishes to register as an interested party.

ECC supports Tilbury 2 in principle, subject to the satisfactory receipt of additional information, amendments, mitigation and clarification to address the outstanding objections and concerns below:

Highways and Transportation
• Transport Assessment. Overall methodology considered sound. ECC maintains an outstanding concern regarding M25 J30 and require further clarification.
• Lower Thames Crossing. ECC expect Tilbury 2 & LTC to take account of respective proposals to ensure junction capacity.
• Framework Travel Plan. Clarification, information and mitigation required concerning sustainable travel modes and provision of public transport to coincide with shift patterns.
• Rail Freight. Seek reconsideration by Network Rail (and PoTLL) on the timing and priority of relevant enhancements in the 2017 Freight Network Study. Clarification required on the cumulative impacts on the rail network, passenger and freight capacity, connectivity and network resilience between Essex and London.
• All transport impacts will need to be mitigated.

Waste and Materials
Maintain an objection to the approach to waste related matters, contrary to national and local planning policy, especially the NPP for Waste, Thurrock LP and Essex and Southend Waste Local Plan (2017) (Essex WLP).
• Inappropriate use and application of the Essex WLP; Essex waste data and findings.
• Inappropriate and unjustified use of Essex as a “proxy study area” in the absence of Thurrock waste data.
• Lack of appropriate assessment of Thurrock and EA waste data.
• Lack of consideration of all neighbouring Waste Planning Authorities, GLA and WLPs within London, which influence waste activities within Thurrock.

Flood and Water Management
Additional information and clarification required concerning:
• Discharge rates for the northern area of the site and access road;
• Flood risk for the whole site;
• Water quality;
• Treatment / culverting of existing watercourses.

Economic Growth
Clarification required on how the benefits and use of the local supply chain and economy would be realised.

Landscape and Visual Impact
Clarification, additional information and mitigation measures required, including wider landscape. The majority of proposed landscape mitigation fails to adequately address wider significant adverse visual impacts on the setting of Tilbury Fort and wider surrounds including East and West Tilbury.

Ecology
Note the aim for temporary net loss in biodiversity with potential neutral or net gains over time and welcome the off-site habitat compensation for invertebrates; shadow HRA for likely impacts on European Sites; Priority s41 Habitat & Species clarification and translocation of PFA and Lytag for compensatory brownfield habitat

Clarification, additional information and amendments required concerning:
• All details in the BS42020:2013 model condition D.4.1 included within the DCO Requirement for a CEMP
• A long term Landscape and Ecological Management Plan (LEMP) will be a DCO requirement; should be cross referenced with final lighting strategy.
• Ecological details and embedded mitigation incorporated into the scheme design; advance habitat creation is essential.
• Bat surveys and mitigation

Historic Environment
Object in principle, due to considerable harm caused to the setting of Tilbury Fort a Scheduled Monument of international significance. The effectiveness of proposed mitigation/enhancement appears limited, further clarity, detail and amendments required.