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 Purfleet Real Estate Limited

Representation

This representation is made by Purfleet Real Estate Limited (“PRE”).

Introduction
Purfleet Real Estate (“PRE”) is the owner of Purfleet Thames Terminal (“PTT”), which is located upstream of the Development on the north side of the Thames, just to the west of the Dartford Crossing. PTT is operated by a sister company, C.RO Ports London Limited (“C.RO”). C.RO also operates Dartford International Ferry Terminal (“DIFT”), located on the south side of the Thames, just to the east of the Dartford Crossing.

PRE and C.RO Ports London Limited are part of the CLdN Group, an integrated roll-on roll-off short sea shipping and ports operator. The Group’s segment is unaccompanied freight, including trailers, containers and new automotive products. Its core trade is on the North Sea between the U.K. and the continent, operating liner services between its UK terminals (PTT and Dartford on Thames, and at Killingholme on the River Humber) and its terminals at Rotterdam (Netherlands), Flushing (Netherlands) and Zeebrugge (Belgium). It also serves third party vessel operators at its UK terminals.

Currently, most vessels call at PTT. It operates on a 24/7 basis to cater for vessel unloading and loading operations, and to receive and deliver freight to and from customers’ nominated hauliers. PTT currently receives 20 scheduled vessel calls per week, mostly Monday to Friday. During busy periods, additional calls will typically happen and schedules may become continuous during weekends. In 2016, PTT handled for 420,059 containers and trailer freight units and 252,478 new passenger cars and commercial vehicles. During this time, there were 1,113 vessel calls from Rotterdam and Zeebrugge.

PRE is making this representation on behalf of the CLdN Group as it is the owner and developer of the Group’s major facility on the River Thames.

The Application
PRE has no objection in principle to the Development. As the brief description of the CLdN Group’s operations will indicate, PTT and DIFT’s priority in reviewing the effects of any new development in the area is to ensure the continued efficient and effective operation of its terminals, in relation to road access, continued navigation for its vessels on the River Thames, and no change in the function of its berths in respect of dredging or other maintenance requirements.

Road access
The results of the Transport Assessment are noted, and it is acknowledged that most impacts are likely to relate to roads in the vicinity of the Development and to the east of PTT and DIFT. However, a key consideration is the continued functioning of the M25 and the A13.

PTT is a major road user and most HGV traffic arrives and leaves via local strategic freight routes, to connect to the A13 and the M25. Junction 30 of the M25 is therefore a major junction to be considered. PRE is concerned that any construction or operational traffic from the Development does not impede the function of these strategic routes without adequate mitigation being put in place.

PRE would like to draw the Secretary of State’s attention to the fact that over the last two years, Thurrock Council has granted a number of planning permissions for development at PTT, all of which required the submission of transport assessments. This included modelling work on the impact of proposals on traffic flows in the area. In particular, on 4 May 2017 Thurrock Council granted three planning permissions relating to major development at the Terminal, as follows:
- Ref. 16/01574/FUL for the construction of a new access and roundabout;
- Ref. 16/01528/FUL for the construction of a new bridge over the railway; and
- Ref. 16/01698/FUL for redevelopment of cargo handling areas and storage, including car decking, across the Terminal.

Prior to this, Thurrock Council had granted a number of other permissions for level storage at land comprised within PTT, as follows:
- Ref: 14/01387/FUL for level storage and associated works at former Esso lubricating oils site;
- Ref: 15/00268 for level storage and associated infrastructure works at former Paper Mills site; and
- Ref. 16/01698/FUL for level storage and associated infrastructure works at former Purfleet Farm.

PRE intends to implement these consents and has been in the process of discharging conditions and taking the necessary steps to carry out the authorized development.

It may be that Thurrock Council does not consider any cumulative impacts will arise between PRE’s proposals and the Development. Whilst PRE would not expect the assessment of cumulative impacts to address every development in the local area, it wishes to ensure that the examining authority is aware of other developments in the area whose transport impacts have been assessed and can consider them accordingly.

River access
PRE does not anticipate that the Development should interfere with the continued access to and use of the River Thames by vessels serving PTT and DIFT. It notes the protective provisions included in the draft Development Consent Order for the benefit of the Port of London Authority (“PLA”). PRE is not aware of the PLA’s views on navigation but would expect the examining authority to ensure that the PLA’s responsibilities and powers to ensure the continued effective use of the River by all operators are maintained.

Other marine effects
Existing and proposed river works licences for PTT are summarized on pages 10-218, 10-219, 11-147 and 11-148 of the environmental statement. It is noted that the purpose of this assessment is to investigate the cumulative effects of the Development with existing river works and dredging, rather than on the activities (and related port operations) authorised by those licences. PRE does not anticipate that dredging related to the Development would affect its operations; the Marine Management Organisation and the Port of London Authority should manage that through the negotiation of the respective licences and their inclusion in the Development Consent Order.
To update the examining authority, PRE has recently received planning permission from Thurrock Council for the jetty replacement works referred to in the pages listed above (reference 16/01601/FUL) and is now progressing the respective marine/river works licences with the Marine Management Organisation and the PLA. Construction on the works is expected to commence during Q1 2018.
Summary and conclusions

As stated above, PRE and the wider CLdN Group are major users of the River Thames and surrounding infrastructure as part of their operations. Whilst there is no objection in principle to the Development it is vital to ensure that construction and operation of the Development will not impede the operations of PRE and its related Group companies and requests that the examining authority should ensure that these are fully scrutinised during the examination.