Lower Thames Crossing Annexes 1-7 Technical Assessment

Annex 1 Development (‘red line’) boundary

Annex 2: Current Lower Thames Crossing Scheme Proposals

Annex 3 Housing development quantities

Table 1: Comparison of LTC model development inputs with adopted and emerging local plans and Government’s standard local housing need calculation (as at 2017)

Local Core Scenario Phasing Comments Authority Assumptions (Housing only) – totals are cumulative (Figure is number of 2026 2031 2041 2051 dwellings 2009 – 25 used in LTC V2 model)

Basildon 3,444 6,885 6,885 6,885 LTC not showing any housing development in Basildon post 2031.

(6,800) Revised publication version of Local Plan (2014 – 34) going to Council 18 October 2018 with housing target of 17,791 or 889 dpa + area of search post 2031. See http://www.basildonmeetings.info/ieListDocuments.aspx?CId=216&MId=6436 .

Local Housing Need based on standard methodology (according to report) should now be around 991 dpa. If this figure is correct, then the local housing need over the period to opening of LTC (2016 -26) would be around 9,900 dwellings compared to 3,444 used in modelling.

For period to design year (2016 – 41) the local housing requirement based on 991 dpa would be 24,775. The modelling therefore is based on a housing figure that is around 17,890 below what might reasonably be expected for the design year if growth targets are met.

Even if the lower 889 dpa was to be rolled forward over the period 2016 – 41, this would result in a housing requirement of 22,225 with the 6,885 figure used in the modelling representing a 15,340 dwelling shortfall. Bexley 3,563 3,563 3,563 3,563 LTC not showing any housing development in Bexley post 2026. Government’s standard methodology established housing need in Bexley as being 1,723 dpa in 2017 but this will be subject to change (No figure) given release of latest household projections and the possibility that Government may change methodology. Annex 3 Housing development quantities

Bexley’s adopted Core Strategy (2012) is available at https://www.bexley.gov.uk/sites/default/files/2018-01/Bexley-Core-Strategy.pdf . This was based on a then London Plan housing requirement equivalent to 335 dwellings per year.

Bexley is currently in the process of updating its local plan and has adopted a growth strategy covering the period 2020 – 2050 that will inform the emerging document – see links at http://democracy.bexley.gov.uk/ieListDocuments.aspx?CId=149&MId=28502&Ver=4 .

The intention is to plan for around 31,500 new homes over this period, subject to the necessary infrastructure being provided. This equates to an annualised housing figure of 1,050 per annum, with areas for new housing development and jobs identified.

This would be increased under Policy H1 of the Draft New London Plan at https://www.london.gov.uk/sites/default/files/draft_london_plan_chapter_4.pdf which provides an annualised average housing target of 1,245 dpa for the period 2019/20 – 2028/29.

Based on the lower figure for the period 2016 – 2019/2020; the higher figure for 2020/21 – 2028/29; and the Government’s standard methodology figure (2017) thereafter the housing requirement would be: 10,053 for 2016 – 26; 17,234 to 2031; 34,464 to 2041 (design year for LTC); and 68,928 to 2051. The modelling therefore is based on a housing figure that is around 30,901 below what might reasonably be expected for the 2041 design year if growth targets are met.

Even if the lower 1,245 dpa figure was to be rolled forward for the period 2026 – 2041, this would provide for a total of 28,728 dwellings over the period 2016 – 2041 – still 25,165 higher than the figure used in the modelling. Brentwood 1,500 3,080 4,080 4,080 The Brentwood Replacement Local Plan was adopted in 2005 and therefore pre-dates both the NPPF 2012 and the 2018 update. (7,585) This is available at https://www.brentwood.gov.uk/pdf/30102013165238u.pdf . It should be noted that Annex 3 Housing development quantities

this does not contain a relevant local housing needs target. It is however in the process of updating this to cover the period 2015 – 2030 with details available on-line at http://www.brentwood.gov.uk/index.php?cid=694 .

Brentwood Council published a Regulation 18 consultation draft of its site allocations plan to meet local housing needs in January 2018. This set out that the local objectively assessed need was for 380 dpa but noted the Government’s standard methodology resulted in a higher figure of 454 dpa see https://brentwood.moderngov.co.uk/ieListDocuments.aspx?CId=128&MId=1927 .

The SoS has threatened to intervene if the council does not make progress on updating its local plan – see http://www.brentwood.gov.uk/pdf/07062018141103000000.pdf . It is unclear when the council will proceed to submission given the Regulation 19 consultation has not yet taken place. An Extraordinary Meeting of the Council is scheduled for 8 November 2018 but no agenda was on-line at the time of writing.

Brentwood is engaging with other South Essex Councils with the objective of developing a joint long term strategic planning strategy for the wider area to 2050 – see Memorandum of Understanding at https://democracy.southend.gov.uk/documents/s22648/05%20APPENDIX%201%20- %20South%20Essex%20Joint%20Strategic%20Plan%20Memorandum%20of%20Understanding%20 2018.pdf

Given uncertainty and the fact that the submission version of the local plan has yet to be published, the most robust approach to determining scale of housing development is to use the higher figure produced under the Government’s standard methodology (2017) which give a figure of 454 dpa. However, this should be treated with a degree of caution because this is likely to be subject to change given release of latest household projections and the possibility that Government may change methodology.

This aside, the housing requirement for Brentwood would be 4,450 for 2016 - 2026; 6,720 to 2031; 11,260 to 2041 (design year for LTC); and 15,800 to 2051. The LTC figure is therefore some 7,180 light for the 2041 design year.

Bromley 8,131 8,131 8,131 8,131 LTC not showing any additional housing in Bromley post 2026. Government’s standard methodology established housing need in Bromley as being 2,564 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change Annex 3 Housing development quantities

(No figure) methodology.

Policy H3.3 and Table 3.1 of the existing adopted London Plan (2016) at https://www.london.gov.uk/sites/default/files/the_london_plan_2016_jan_2017_fix.pdf provides an annualised average housing target of 641 dpa for the period 2015 – 25. This would be increased under Policy H1 of the Draft New London Plan at https://www.london.gov.uk/sites/default/files/draft_london_plan_chapter_4.pdf which provides an annualised average housing target of 1,424 dpa for the period 2019/20 – 2028/29…..well below the Government’s centrally produced figure.

As per the approach taken with Bexley above, based on the lower figure for the period 2016 – 2019/2020; the higher figure for 2020/21 – 2028/29; and the Government’s standard methodology figure (2017) thereafter the housing requirement would be: 11,891 for 2016 – 26; 21,291 to 2031; 46,931 to 2041 (design year for LTC); and 72,571 to 2051. The modelling therefore is based on a housing figure that is around 38,800 below what might reasonably be expected for the design year if growth targets are met.

Even if the lower 1,424 dpa figure was to be rolled forward for the period 2026 – 2041, this would provide a total of 44,641 dwellings over the period 2016 – 41 – still 36,520 higher than the figure used in the modelling.

Castle Point 0 0 0 0 LTC not showing any housing development in Castle Point over entire project period.

(4,086) Local Plan review in progress and housing need figure to 2050 will be set in conjunction with other South Essex authorities (see reference in Brentford above).

Most recent document currently available on council’s website (May 2017) analysing housing need at South Essex level from 2014 base is available at https://www.castlepoint.gov.uk/download.cfm?doc=docm93jijm4n3557.pdf&ver=5939 . This suggests a housing need of 300 dpa after having regard to impact of GLA area.

Government’s standard methodology established housing need in Castle Point as being 342 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology. Annex 3 Housing development quantities

Based on Government’s (2017) housing requirement the need would be around 3,420 dwellings for period 2016 - 2026; 5,130 to 2031; 8,550 to 2041 (design year for LTC); and 11,970 to 2051.

The LTC figure is therefore some 8,550 light for the 2041 design year.

Dartford 12,716 15,821 16,521 16,521 LTC not showing any additional housing growth in Dartford beyond 2041. Only site delivering any housing in 10 years beyond 2031 is Dartford Town Centre and Northern Gateway – 700 units. Rate of (18,403) delivery in Eastern Quarry should be checked with Ebbsfleet Development Corporation (EDC) – only 2,650 seems low.

Dartford in process of updating local plan. Existing Core Strategy (2011) remains South East Plan based with housing target above local need – see https://www.dartford.gov.uk/by- category/environment-and-planning2/new-planning-homepage/planning-policy/adopted-plans

Likely that delivery will be front loaded over period due to EDC being charged with delivery at pace.

Government’s standard methodology established housing need in Dartford as being 778 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

Based on this, housing requirement would be 7,780 for 2016 - 2026; 11,600 to 2031; 19,450 to 2041 (design year for LTC); and 27,230 to 2051.

The LTC figure is therefore some 2,929 light for the 2041 design year.

NB. No allowance made within transport assessment for London Resort theme park. Unclear as to whether site 69 in list for 800 dwellings and 2,300 sqm B2 industry at Swanscombe Peninsula (including Croxton and Gary site) is supposed to be a surrogate for this in non- theme park world.

Gravesham 2,692 3,424 3,424 3,424 LTC not showing any housing development in Gravesham beyond 2031, with only 732 in the 10 years 2026 – 31. (5,249) Adopted local plan Core Strategy adopted in 2014 – see http://www.gravesham.gov.uk/home/planning-and-building/local-plan/gravesham-local-plan-core- strategy . In process of updating local plan to consider options for meeting identified housing need Annex 3 Housing development quantities

shortfall to 2028.

Government’s standard methodology established housing need in Gravesham as being 508 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

Based on this, housing requirement would be 5,080 for 2016 - 2026; 7,621 to 2031; 12,700 to 2041 (design year for LTC); and 17,780 to 2051. Figures differ from recent local plan consultation due to different base and need to take into account backlog.

The LTC figure is therefore some 9,276 light for the 2041 design year.

Havering 1,873 1,873 1,873 1,873 LTC not showing any housing development in Havering beyond 2026.

(No figure) Havering local plan 2016 – 31 has been submitted for examination see https://www.havering.gov.uk/downloads/download/641/havering_local_plan . This plans for 17,550 dwellings over this period compared to the 1,873 set out in the LTC modelling.

Government’s standard methodology established housing need in Havering as being 1,821 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

In this instance, it would seem appropriate to apply the emerging local plan figure of 1,170 dpa for the period 2016 – 19 and the higher figure of 1,875 dpa thereafter given it accords with the emerging London Plan and Government estimate, rolling it forward post 2031.

Based on this, the housing requirement for Havering would be 16,635 for the period 2016 – 26; 26,010 Annex 3 Housing development quantities

to 2031; 44,760 to 2041 (LTC design year); and 63,510 to 2051.

The LTC figure is therefore some 42,887 light for the 2041 design year – the 1,873 figure used actually only represents 1 year’s housing requirement under the emerging London Plan.

Even if the lower 1,170 dpa figure were used for the entire period up to 2041, this would still give a total of 29,250 dwellings or some 27,377 more than used in the LTC modelling.

Maidstone 2,190 3,284 3,649 3,649 Maidstone BC adopted a new local plan covering the period 2011 - 2031 in October 2017 based on delivering 883 dpa see - . http://www.maidstone.gov.uk/home/primary-services/planning-and- (5,478) building/primary-areas/local-plan-information/tier-3-primary-areas/what-is-the-local-plan

This compares to the Government’s standard methodology which established housing need in Maidstone as being 1,236 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

Clearly, there is a major difference between the two figures and given Maidstone will be required to review its local plan within 5 years, it is prudent for the purposes of this exercise to base the first 5 years on the lower figure and increase it to the higher thereafter.

Based on this, housing requirement would be 10,595 for 2016 – 26; 16,775 to 2031; 29,135 to 2041 (design year for LTC); and 41,360 to 2051.

The LTC figure is therefore some 25,486 light for the 2041 design year.

Even if the 883 dpa figure was to be used for the 25 year period 2016 – 41 (LTC design year), the total would still be 22,075 or some 18,426 dwellings more than used in the LTC modelling.

Medway 2,019 2,409 2,409 2,409 LTC shows no housing development in the Medway area post 2026.

(13,279) Medway is in the process of updating its local plan for period 2012 - 35, with a consultation on strategic options having been undertaken in March – June 2018 at https://www.medway.gov.uk/info/200133/planning/525/planning_public_consultations .

This includes a number of options based on a locally assessed need for 1,281 homes per year. A number of major sites are identified for potential development on the Hoo Peninsula which in general Annex 3 Housing development quantities

terms are common to all options. This could mean between 9,318 – 12,162 new homes are delivered in this location. None of these appear to have been included in the modelling for LTC, even though they are likely to load onto junctions associated with the LTC project via A289 Wainscott By-Pass etc. See consultation booklet at https://www.medway.gov.uk/downloads/file/2088/development_strategy_consultation_booklet

The locally derived figure of 1,281 dpa compares to the Government’s standard methodology which established housing need in Medway as being 1,655 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

Based on the Government (2017) figure, housing requirement would be 16,550 for 2016 – 26; 24,825 to 2031; 41,375 to 2041 (design year for LTC); and 57,925 to 2051.

The LTC figure is therefore some 38,966 light for the 2041 design year.

NB. It should also be noted that the LTC modelling fails to include any commercial development on the Hoo Peninsula. Whilst final employment land allocations are currently not known, LTC modelling should have regard to the presence of large strategic employment sites at the Isle of Grain and Kingsnorth which are likely to expand.

Also, there are now plan to create an Innovation Park at Rochester Airport that will impact on the M2/A229 junction – see https://www.medway.gov.uk/info/200177/regeneration/738/innovation_park_medway.

Given it is intended that this could deliver up to 100,000 sqm of commercial floorspace (similar to what is assumed for Eastern Quarry, Dartford) this should be included in the modelling as it would take up capacity on a key junction feeding LTC.

Sevenoaks 1,526 1,526 1,526 1,526 LTC shows no housing development in Sevenoaks post 2026.

(1,196) Sevenoaks in process of updating local plan for period 2015 – 35, seeking to address Government requirement to deliver up to 14,000 new dwellings by the end of that period. See consultation webpage https://www.sevenoaks.gov.uk/info/20069128/new_local_plan/389/draft_local_plan_consultation . Annex 3 Housing development quantities

The Government’s standard methodology established housing need in Sevenoaks as being 698 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

Based on this figure, the housing requirement for Sevenoaks would be 6,980 for 2016 – 26; 10,400 to 2031; 17,450 to 2041 (design year for LTC); and 24,430 to 2051.

This is clearly challenging for Sevenoaks given the extent of Green Belt and environmental designations covering the area. The recent consultation seeks to identify sites where development could be located through to 2035 but with a minor shortfall (approx.500) against need. However, the figures do provide an indication of how the general scale of need might be accommodated at least through to 2035.

At least some of this development could occur in areas which may impact on the M25/M20 junction at Swanley and/or in the area of Hartley/Longfield which could impact on the local highway network in Dartford/Gravesham close to the river crossings. Because Sevenoaks has not reached a preferred options stage, these impacts have not as yet been tested.

Based on the Government’s (2017) figures for annualised housing need in Sevenoaks, the LTC figure is around 15,924 light for the 2041 design year.

NB. Development in south of district not likely to have significant effect on M25 corridor so modelling should seek to distinguish in broad terms what scale of development is likely to go where and take this into account.

Thurrock 1,806 5,044 5,044 5,044 LTC shows no housing development in Thurrock post 2031.

(12,460) The Current adopted Thurrock Core Strategy (updated 2015) covers the period through to 2026 – see https://www.thurrock.gov.uk/sites/default/files/assets/documents/core_strategy_adopted_2011_amend ed_2015.pdf . Policy CSSP1 notes that the former East of England Plan contained a Thurrock housing figure of 18,500 for the period 2001 – 21. Thurrock therefore allocated 13,500 for the period 2009 – 21 and 4,750 for the next 5 year period 2021 – 26 – latter equates to 950 dpa.

Thurrock is in the process of updating its local plan for the period, with a report having been put on the agenda for full Council on the 25 July 2018 prior to commencement of a stage 2 Issues and Options Annex 3 Housing development quantities

consultation.

This was withdrawn due to the publication by Government of the new National Planning Policy Framework and the consultation has yet to take place. See https://democracy.thurrock.gov.uk/ieListDocuments.aspx?CId=134&MId=5475&Ver=4 + printed draft minutes.

However, the report does refer to a housing need requirement of 31,763 over a 20 year period. This equates to 1,588 dpa.

This is higher that the figure produced using the Government’s standard method (2017) of 1,158 dpa but this will be subject to change given release of latest household projections and the possibility that Government may change methodology.

Thurrock is also engaging with other South Essex authorities in terms of determining development needs and a joint spatial strategy which may also result in different figures/distributions of development.

Based on the Government’s (2017) lower figure for annualised housing need (1,158 dpa), the housing requirement for Thurrock would be 11,580 for 2016 – 26; 17,380 to 2031; 28,950 to 2041 (design year for LTC); and 40,530 to 2051.

Based on the above, the LTC figure is around 23,906 light for the 2041 design year. Clearly, the shortfall would be greater had the Thurrock derived figure been used.

NB: Whilst they do not appear in the uncertainty log, the Transport Report does set out how the DP World and Tilbury port developments have been factored into the modelling, based on the Transport Assessments that supported the applications.

The Tilbury2 Transport Assessment (Oct 2017) is available on line at https://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/TR030003/TR030003-000254- ES%20Appendix%2013.A%20Transport%20Assessment.pdf

This predicts that the development will generate 3,041 vehicle movements per day (2,123 HGV and 618 staff movements) and provides forecasts for the following time periods (which has a Annex 3 Housing development quantities

good fit with LTC peaks):

• Strategic Road Network AM peak (7.00 – 8.00) • Local Road Network AM peak (8.15 – 9.15) • Inter Peak (13.00 – 14.00) • Evening Peak Hour (17.00 – 18.00)

Tonbridge 2,540 3,101 3,101 3,101 LTC shows no housing development in Tonbridge and Malling post 2031. and Malling The current adopted Tonbridge and Malling local plan Core Strategy (2007) covers the period 2006 – (5,078) 21 – see https://www.tmbc.gov.uk/__data/assets/pdf_file/0020/13808/Core_Strategy.pdf . Policy CP15 includes a housing target figure for this period of 6,375 dwellings, which equates to 425 dpa over a 15 year period.

Tonbridge and Malling is currently in the process of updating its local plan. Public consultation on Regulation 19 pre-submission version taking place over period 1 Oct 2018 – 19 Nov 2018. Regulation 19 document available on line at https://www.tmbc.gov.uk/__data/assets/pdf_file/0005/618890/Local_Plan_Reg19_Consultation_web.p df .

Policy LP3 plans for 6,834 dwellings over the period 2019/20 – 2030/31 or the equivalent of 569 dpa.

The Government’s standard methodology established housing need in Tonbridge and Malling as being 859 dpa in 2017 but this will be subject to change given release of latest household projections and the possibility that Government may change methodology. The locally derived housing need figure is therefore well below that suggested by the new standard methodology.

If the existing adopted local plan figure applies up to adoption of the new local plan in say 2019/20; the emerging plan is found sound and the lower figure applies for the first 5 years post adoption before a review is required; and something like the Government centrally derived figure applies thereafter – the following would provide a broad idea of the likely housing requirement: 2016 – 26 = 5,838; 10,133 to 2031; 18,723 to 2041 (LTC design year); and 27,313 to 2051.

Based on the above calculation, the LTC figure is around 15,622 light for the 2041 design year.

NB: It should be noted that the LTC figure for 2031 is actually less than half that set out in the Annex 3 Housing development quantities

Tonbridge Regulation 19 document, ignoring any delivery prior to the adoption of the new local plan or delivery in the 10 years thereafter leading up to the 2041 design year.

Emerging policy LP3 includes a number of strategic housing allocations in the north of the council area that do not appear to have been taken into account in the LTC schedule. These include:

• Bushey Wood, Eccles – 900 dwellings • East of Hermitage Lane, Aylesford – 1,000 dwellings • North of Borough Green – 1,720 dwellings • Broadwater Farm, North of Kings Hill – 900 dwellings

Phasing of delivery of these sites is set out at pages 91 – 92 of the consultation document.

NB. Development in south of district around Tonbridge not likely to have significant effect on M25 corridor so modelling should seek to distinguish in broad terms what scale of development is likely to go where and take this into account. Regulation 19 consultation policy LP3 in terms of the major residential development sites splits development between two housing market areas, with approx.. 90% directed to north of council area.

NB. The figures used in the LTC Version 2 (V2) model are based on an uncertainly log having a base of 2009 with end date of 2025. It is inevitable therefore that there will be differences between those figures and the ones now being used because the log has been rebased to a 2016 survey year. No figures were included for the London boroughs in the LTC V2 model, with predicted traffic growth rates used instead. The V2 uncertainty log is available in the appendices to Volume 5 of the Scheme Assessment report produced for the 2016 consultation at https://highwaysengland.citizenspace.com/ltc/lower-thames-crossing- consultation/supporting_documents/Scheme%20Assessment%20Report%20%20Volume%205%20Appendices.pdf

Annex 3 Housing development quantities

Table 2: Scale of residential development shortfall within LTC modelling for core area

North of River

Council area Dwellings at year of opening 2026 Dwellings at design year 2041 Comments

(figure gives total LTC Est. Shortfall LTC Est. Shortfall number of dwellings schedule development schedule development in area at 2017) figure Requirement figure Requirement

Basildon (77,350) 3,444 9,900 6,456 6,885 22,225 15,340 Based on Government’s (2017) local housing need figure 991 dpa

Brentwood (32,940) 1,500 4,450 2,950 4,080 11,260 7,180 Based on Government’s (2017) local housing need figure 454 dpa

Castle Point (38,460) 0 3,420 3,420 0 8,550 8,550 Based Government’s (2017) local housing need figure 342 dpa

Havering (101,720) 1,873 16,635 14,762 1,873 44,760 42,887 Based on emerging local plan figure 1,170 dpa for 2016 – 19 and higher Government’s (2017) local housing need figure 1,875 dpa thereafter.

Thurrock (66,470) 1,806 11,580 9,774 5,044 28,950 23,906 Based on Government’s (2017) local housing need figure of 1,158 dpa.

Total shortfall 37,362 97,863

Total existing dwellings in whole area of the above 2017 – 316,940. Estimated shortfall at 2041 therefore represents around equivalent of 23% of existing stock. Shortfall in Thurrock in 2041 represents around equivalent of 37% of existing stock.

Source for total number of dwellings in each area at 2017: Table 100 at https://www.gov.uk/government/statistical-data-sets/live-tables-on-dwelling-stock- including-vacants .

Annex 3 Housing development quantities

South of River

Council area Dwellings at year of opening 2026 Dwellings at design year 2041 Comments

(figure gives total LTC Est. Shortfall LTC Est. Shortfall number of dwellings schedule development schedule development in area at 2017) figure Requirement figure Requirement

Bexley (97,630) 3,563 10,053 6,490 3,563 34,464 30,901 Based on 446 dpa for the period 2016 – 2019/2020; 1,245 dpa for 2020/21 – 2028/29; and the Government’s standard methodology figure (2017) of 991 dpa thereafter (see Table 1 above)

Bromley (138,420) 8,131 11,891 3,760 8,131 46,931 38,800 Based on 641 dpa for the period 2016 – 2019/2020; 1,424 dpa for 2020/21 – 2028/29; and the Government’s standard methodology figure (2017) of 2,564 dpa thereafter (see Table 1 above)

Dartford (45,270) 12,716 7,780 +4,936 16,521 19,450 2,929 Based on Government’s (2017) local housing need figure of 778 dpa.

Gravesham (43,000) 2,692 5,080 2,388 3,424 12,700 9,276 Based on Government’s (2017) local housing need figure of 508 dpa.

Maidstone (69,700) 2,190 10,595 8,405 3,649 29,135 25,486 First 5 years based on recently adopted local plan figure of 883 dpa + on Government’s (2017) local housing need figure of 1,236 dpa thereafter.

Medway (113,820) 2,019 16,550 14,531 2,409 41,375 38,966 Based on Government’s (2017) local housing need figure of 1,655 dpa. Annex 3 Housing development quantities

Sevenoaks (49,870) 1,526 6,980 5,454 1,526 17,450 15,924 Based on Government’s (2017) local housing need figure of 698 dpa.

Tonbridge and Malling 2,540 5,838 3,298 3,101 18,723 15,622 Based on existing local plan figure of 425 (53,600) dpa to 2019/20; emerging local plan for 569 dpa for 5 years post adoption; and Government’s (2017) local housing need figure of 859 dpa thereafter.

Total Shortfall 39,390 177,904

Total existing dwellings in whole area of the above 2017 – 611,310. Estimated shortfall at 2041 therefore represents around equivalent of 29% of existing stock. Shortfall in Dartford/Gravesham at 2041 represents the equivalent of 14% of existing stock - 12,205 dwellings represents two additional developments of a similar scale to Eastern Quarry.

Source for total number of dwellings in each area at 2017: Table 100 at https://www.gov.uk/government/statistical-data-sets/live-tables-on-dwelling-stock- including-vacants .

Annex 4 Air Quality report

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing – PEIR Mountfield Park

November 2018 Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Document Control Sheet

Identification Client Gravesham Borough Council Document Title Air Quality Peer Review – Lower Thames Crossing - PEIR Bureau Veritas Project No. 6481789/AQ/R1

Contact Details Company Name Bureau Veritas UK Limited Gravesham Borough Council Contact Name Jamie Clayton Tony Chadwick Position Principal Consultant (Air Quality) Acting Planning Policy Manager Address 2nd Floor, Atlantic House Civic Centre Atlas Business Park Gravesend Simonsway, Wythenshawe Kent Manchester DA12 1AU M22 5PR Telephone 07794 119598 01474 337404 e-mail [email protected] [email protected] Websites www.bureauveritas.co.uk www.gravesham.gov.uk

Configuration Reason for Issue/Summary Version Date Author Status of Changes 1 14/11/2018 J Clayton Issued to Client Draft

Name Job Title Signature

Prepared By J Clayton Principal Consultant

Approved By R Maggs Consulting Group Manager

Commercial In Confidence © Bureau Veritas UK Limited The copyright in this work is vested in Bureau Veritas UK Limited, and the information contained herein is confidential. This work, either in whole or in part, may not be reproduced or disclosed to others or used for any purpose, other than for internal client evaluation, without Bureau Veritas’ prior written approval. Bureau Veritas UK Limited, Registered in England & Wales, Company Number: 01758622 Registered Office: Suite 308, Fort Dunlop, Fort Parkway, Birmingham B24 9FD

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Table of Contents

1 Introduction 2

2 Methodology 2

3 Peer Review Findings 4 3.1 Scoping 4 3.2 PEIR 9 3.2.1 Baseline 9 3.2.2 Construction Phase 9 3.2.3 Operational Phase 10

4 Conclusions and Recommendations 12

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

1 Introduction Bureau Veritas (BV) has been appointed by Gravesham Borough Council (the Council) to peer review the air quality chapter of the Preliminary Environmental Information Report (PEIR) for the proposed Lower Thames Crossing (LTC) road scheme. Highways England (the Applicant) is seeking a Development Consent Order (DCO) for this major highways development, which is partially within the boundary of The Council. The current proposals for the LTC comprise a new road link (three lanes in each direction) connecting the A2 in Kent, east of Gravesend with the M25, south of junction 29. The highway will pass under the Thames via two 16m diameter tunnels, with a length of approximately 4km. The aim of this new highway connection will be to reduce congestion at the existing Thames crossing (bridge and tunnel) at Dartford. Construction of the new highway, and all associated junctions and road improvements, is expected to take approximately seven years, with a provisional opening year of 2027. The primary purpose of this report is to ensure that the preliminary air quality information submitted by the applicant, and subsequently the proposals for further detailed assessment, follows an appropriate methodology and makes reference to – and utilises as far as possible – the custom and practice guidance that is available locally and nationally for such an assessment.

2 Methodology A number of methodologies can be applied to the peer review of air quality assessments. In brief, the assessment, or proposals for such, should comply with:  the need to clearly set the defined existing conditions at the Site;  the extent to which the development is likely to impact on the environment; and  an assessment of the significance of such impacts as benchmarked against relevant and available criteria. The whole assessment should be made against prevailing planning policies set by Government, local and regional bodies. The following primary documents have been reviewed: . LTC Preliminary Environmental Information Report (2018) - Volume 1 (Chapter 6 Air Quality) . LTC Preliminary Environmental Information Report (2018) - Volume 2 (Air Quality Appendices A - D) . LTC Preliminary Environmental Information Report (2018) - Volume 3 (Air Quality Figures 6.1 - 6.2) . LTC 13a Map book 1: General Arrangements . LTC 13b Map book 2: Land use plans The review has also included consideration of information provided by the Applicant within the Environmental Impact Assessment (EIA) Scoping Report (SR) (October 2017) submitted by the Applicant, and the subsequent scoping response issued by the Council (1 December 2017), and the Scoping Opinion issued by the Planning Inspectorate (PINS) (December 2017). Primary Regulations, standards and best practice guidance referred to in this review include: . The National Policy Statement for National Networks (December 2014) [NPSNN] . The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 [EIA Regs]

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

. The Design Manual for Roads and Bridges, Volume 11 Environmental Assessment, Section 3 Environmental Assessment Techniques, Part 1 Air Quality HA 207/07 . Local Air Quality Management Technical Guidance (LAQM.TG)(16) issued by the Department for the Environment, Food and Rural Affairs (Defra, 2016)

. IAN 170/12v3 Updated air quality advice on the assessment of future NOx and NO2 projections for users of DMRB Volume 11, Section 3, Part 1 'Air Quality, November 2013 . IAN 174/13 Updated advice for evaluating significant local air quality effects for users of DMRB Volume 11, Section 3, Part 1 Air Quality (HA207/07), June 2013 . IAN 175/13 Updated advice on risk assessment related to compliance with the EU Directive on ambient air quality and on the production of Scheme Air Quality Action Plans for users of DMRB Volume 11, Section 3, Part 1 Air Quality (HA207/07), June 2013 . IAN 185/15, Updated traffic, air quality and noise advice on the assessment of link speeds and generation of vehicle data into ‘speed-bands’ for users of DMRB Volume 11, Section 3, Part 1 ‘Air Quality and Volume 11 The air quality assessment has thus been peer reviewed in order to inform the Council around issues that may constitute the need for:  any further clarification: namely those issues for which further detail would provide for additional transparency and/or a clearer understanding on; or  an omission: those issues deemed within the peer review to be lacking within the preliminary assessment which, if not addressed within the subsequent Environmental Statement (ES), may prevent the local planning authority (LPA) from making an informed decision related to the impacts of the proposed development.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

3 Peer Review Findings

3.1 Scoping Table 1 below provides a summary of the comments by the Council within their scoping response, and commentary on whether, and to what extent, these comments have been acknowledged or addressed within the PEIR. Table 1: Scoping Responses by the Council Item Commentary There is serious concern about the effect of the Three receptors have been considered at Marling introduction of a significant new source of Cross and Riverview Park (PEIR0507, PEIR0112 pollution on the Borough (particularly at Marling and PEIR0086). The highest predicted NO2 Cross, Thong, Riverview Park and Chalk) as well concentration in the Do Something (DS) scenario as the impact on the existing AQMA [Air Quality at any of these three receptors is 28.1µg/m3 at Management Area] on the A2 because of PEIR0507, an increase of 0.7µg/m3 from the Do widening. minimum (DM) scenario. Two receptors have been considered at Thong (PEIR0506 and PEIR0078). The highest predicted NO2 concentration in the DS scenario at either of these two receptors is 18.5µg/m3 at PEIR0078. The maximum increase in NO2 concentrations between the DM and DS scenarios occurs at PEIR0506 where an increase of 2.9µg/m3 is predicted. Three receptors have been considered at Chalk (PEIR0003, PEIR0526 and PEIR0527). The highest predicted NO2 concentration in the DS scenario at any of these three receptors is 20.9µg/m3 at PEIR0526. The maximum increase in NO2 concentrations between the DM and DS scenarios occurs at PEIR0527 where an increase of 3.8µg/m3 is predicted. 24 existing receptors have been considered along the A2 AQMA. The highest predicted NO2 concentration in the DS scenario at any of these receptors is 34.7µg/m3 at PEIR0177. The maximum increase in NO2 concentrations between the DM and DS scenarios occurs at PEIR0244 where an increase of 5.4µg/m3 is predicted. It is understood that a revised assessment of impacts from emissions from operational road traffic will be presented in the ES using revised traffic inputs. All modelled results presented in the PEIR are therefore subject to change in the final assessment presented in the subsequent ES.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Item Commentary

It is noted that although nitrogen dioxide NO2 and Paragraph 6.3.19 states that whilst the PEIR has particulate matter PM10 are to be modelled and not specifically modelled the PM2.5 concentration monitored, there is a significant omission of PM2.5, annual mean concentrations are expected to be 3 which should be included in the analysis. It is well below the EU limit value of 25μg/m at all already included in the Public Health Outcomes receptors. Annual mean PM10 concentrations Framework (PHOF) for Public Health purposes. modelled at receptors in the Do Minimum (DM) This should also apply to the analysis of the and Do Something (DS) scenarios have however regional implications (para 6.7.17). been compared to the PM2.5 limit value to demonstrate that PM2.5 concentrations will be below this threshold.

Impacts from PM2.5 will therefore be inferred by assuming that PM10 predicted concentrations will remain below PM2.5 objective levels. Given the emerging evidence pointing towards exposure to PM2.5 having no safe threshold GBC may wish to seek a more complete PM2.5 assessment.

Part of the route is within the A2 Trunk Road Air Impacts from the construction phase of the project Quality Management Area, and measures should have not been considered in the PEIR. Air quality be taken to mitigate any adverse impact on this impacts from construction will need to be AQMA during both the construction and operation considered as part of the ES submitted with the phase so that air pollution levels do not worsen in DCO application and careful consideration needed the existing AQMA and also so that its area does to ensure no detriment to air quality during not need to be expanded. construction arises. The key test is whether air quality standards are The results of the PEIR assessment indicate that breached at any point on the network. breaches of the annual mean NO2 air quality objective will occur at 16 receptor locations in the DS scenario. However all 16 of these receptors are observed to also exceed in the DM scenario. The assessment therefore dose not predict that the development will cause and exceedences of air quality objective. It is understood that a revised assessment of impacts from emissions from operational road traffic will be presented in the ES using revised traffic inputs. All modelled results presented in the PEIR are therefore subject to change in the final assessment presented in the subsequent ES.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Item Commentary 6.4.3 - local background monitoring data should Paragraphs 6.3.54 – 6.3.57 details the approach be used if the data set shows monitored the assessment has taken regarding assumed background levels to be higher than the national background concentrations in the model. A background mapping. Again, it would be useful for comparison between 31 background monitoring both to be used for comparison. Some additional sites across the study area with Defra mapped monitoring locations are suggested: background concentrations has been undertaken. Based on this comparison the Defra mapped Site Site Location Pollutant AQMA Ref Type background concentrations have been uplifted by a factor of 1.45 for NO2 for all modelled scenarios. GR137 RS 570719, 171143 NO No 2 Background PM10 concentrations have not been

GR138 RS 570583, 169549 NO2 Yes adjusted from Defra mapped concentrations due to limited background monitoring sites across the GR141 RS 569588, 169603 NO Yes 2 study area. GR142 RS 567500, 169836 NO2 Yes The study has therefore not assessed impacts using either local background monitoring or the Defra background maps in isolation but with a single approach which considers both sources. The additional roadside monitoring locations suggested are not considered in the assessment as they were not commissioned until 2017 and the base year of the study (year model verification was undertaken) was 2016. The additional roadside monitoring locations do not appear as modelled receptor locations in the PEIR. 6.6.5 - consideration of the exposure of the Paragraphs 6.3.48 – 6.3. 51 details the human vehicle occupants to air pollution should be made receptors which have been considered in the in relation to congestion particularly in cuttings PEIR air quality assessment. The receptor and in the tunnel. Mitigation measures must then locations have been chosen based on guidance be included in the design to ensure their exposure provided in LAQM.TG(16). This does not include does not exceed the EU Limit Values. receptors relating to occupants of road vehicles. It is not standard practice for pollutant exposure to occupants of road vehicles to be included within an air quality assessment as the location would not meet this siting criteria for annual mean objectives outlined in Box 1.1 of LAQM.TG(16). Air quality mitigation measures for operational impacts have not been included within the PEIR but should be included within the final Environmental Statement (ES).

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Item Commentary 6.7.4 - all reasonable steps should be taken to Impacts from the construction phase of the project design the route, the road’s construction and have not been considered in the PEIR although it intrinsic design and construction so that there are is acknowledged that the construction phase of no adverse impacts on any relevant receptor the project has the potential to affect air quality during the operation phase. It is noted that if the because of emissions of dust, emissions from tunnels are bored from the south there are Non-Road Mobile Machinery (NRMM) and from significant implications for the Chalk area and any construction vehicle movements by road, river and access routes. The impact on the locality through rail (para 6.6.3). the storage of spoil must be assessed and Air quality impacts from construction will be relevant mitigation measures implemented into considered as part of the ES submitted with the the construction phase. DCO application. A Code of Construction Practice (CoCP) will be prepared as part of the ES, which will set out mitigation measures to be implemented during the construction phase. 6.7.5 - disappointingly the Scoping Report states Paragraph 6.3.18 states that pollutant that if there are no sensitive receptors (such as concentrations have been predicted at sensitive residential properties, schools and designated receptors within 200m of the Affected Road sites) within 200m of the affected roads then the Network (ARN) in line with the DMRB guidance. local air quality effect of the scheme can be The PEIR has not included all roads which trigger considered not significant and no further air the DMRB ARN criteria, however paragraph quality assessment is required. During heavy 6.3.18 states that The ES will provide the congestion, particularly with a high proportion of modelled results for the full ARN and be fully HGV/HDV vehicles in the queues this is likely to compliant with DMRB. affect an area bigger than 200m. It may also No sensitive receptors at distances greater than cause breaches of the EU Limit Values. The 200m from the ARN have been considered in the Scoping Report makes reference to the EU Limit PEIR. Values in 6.7.10, 6.7.11 and 6.7.16 and confirms that a Compliance Assessment will be undertake An indicative Compliance Risk Assessment is to determine whether the Project with have an detailed in paragraphs 6.6.43 - 6.6.44, however impact on compliance with the EU Air Quality this only considers the maximum predicted Directive. All steps should be taken so as not to concentrations in the Do Something (DS) scenario cause a breach of the EU Limit Values. and the maximum increase in concentrations predicted by the scheme. The indicative assessment concludes that the project is considered to have a low risk of leading to non- compliance with the EU Directive on Ambient Air Quality. A full compliance risk assessment taking into account of all receptors will be undertaken for the ES.

6.8.1 - there is reference to there being some Impacts from the construction phase of the project potential for adverse effects during the have not been considered in the PEIR, although it construction phase and goes on to say that as is acknowledged that the construction phase of these are temporary they will be minimised. the project has the potential to affect air quality However, the construction phase is 6 years, and because of emissions of dust, emissions from as such the impact is long term, albeit that it may Non-Road Mobile Machinery (NRMM) and from cease at the end of the construction phase. Six construction vehicle movements by road, river and years is a significant amount of time and as such rail (para 6.6.3). any adverse impact during the construction phase Air quality impacts from construction will need to should be given due consideration and all be considered as part of the ES submitted with the reasonable steps should be carried out to mitigate DCO application. these impacts as far as is possible.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Item Commentary 6.9.5 - Air Quality monitoring should be continued A 12 month project specific monitoring survey has indefinitely after the opening year so that the local been undertaken as detailed in paragraph 6.3.11. authorities, the public and Highways England are This covered the period from August 2017 to aware of the impact on nearby residents and August 2018. areas of importance e.g. SSSIs [Sites of Special The PEIR provides no commitment for any other Scientific Interest] etc. and so that any areas of monitoring. exceedance of the objectives and any AQMA boundaries are kept up to date. A Code of Construction Practice (CoCP) will be prepared as part of the ES, which will set out mitigation measures to be implemented during the construction phase. It is possible that air quality monitoring will be included within the CoCP, although this is not explicitly stated. 6.9.5 - the provision of buffer zones along the The PEIR provides no commitment for buffer length of the new road should be ensured so as to zones along the road length to provide space for provide space for air quality mitigation, e.g. air quality mitigation. bunding, this will assist in the mitigation of noise A Code of Construction Practice (CoCP) will be also. Bunding would also be a good use for left- prepared as part of the ES, which will set out over spoil. mitigation measures to be implemented during the construction phase.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

3.2 PEIR 3.2.1 Baseline a) The baseline conditions have been established within 200m of the ARN as per the DMRB guidance. Annual mean air quality monitoring data for the year 2016 has been obtained from LAQM monitoring locations from 22 local authorities, Highways England historic air quality monitoring sites and project specific air quality monitoring sites. Data collected from local authority sites is made up of both NO2 diffusion tubes and automatic monitoring sites.

b) Background NO2 concentrations have been calculated by undertaking a comparison of monitored background NO2 and Defra background mapped NO2 at 31 background monitoring sites across the study area. Based on this comparison Defra mapped concentrations have been uplifted by a factor of 1.45 for all modelled scenarios. Following model verification an uplift in assumed background values from the Defra mapped concentrations will result in a lower component from modelled road sources, which in turn will result in a smaller change in NO2 concentrations between the DM and DS scenarios. It is therefore necessary that any uplift to background concentrations is subjected to the correct level of scrutiny to ensure it is appropriate across the full extent of the study area. c) All air quality monitoring data utilised presently in the PEIR has been collected in, or adjusted to, the year 2016. It is assumed that 2016 will remain the base year of assessment in the revised air quality assessment to be presented in the ES. It is not clear how the revised assessment will therefore take into account any changes in monitored concentrations between 2016 and 2018. Additionally it is not clear if the revised assessment will consider the use of any monitoring sites commissioned after 2016 such as sites GR137, GR138, GR141 and GR142 commissioned by GBC in 2017. It may therefore be appropriate for the revised version of the modelling assessment presented in the ES to consider a later base year of 2017 or 2018. 3.2.2 Construction Phase Construction Dust Assessment a) PEIR Vol 1 para 6.6.3 details that although the project has the potential to affect air quality due to emissions from construction dust, these effects have not been considered in the PEIR. It is further stated that they will be considered as part of the ES to be submitted with the DCO application. b) An appropriate assessment of construction dust should be included as part of the ES utilising guidance such as the Institute of Air Quality Management: Guidance on the assessment of dust from demolition and construction (2014). Following the construction dust assessment, appropriate mitigation measures should be outlined to inform the Code of Construction Practice (CoCP) to be submitted as part of the ES. A list of mitigation measures that will be considered is provided following PEIR Vol 1 para 6.6.4, this broadly follows the types of measures outlined in the IAQM guidance and so is considered appropriate subject to the further assessment. Construction Emissions from Non-Road Mobile Machinery c) PEIR Vol 1 para 6.6.3 details that although the project has the potential to affect air quality due to emissions from Non-Road Mobile Machinery (NRMM), these effects have not been considered in the PEIR. It is further stated that they will be considered as part of the ES to be submitted with the DCO application. d) An appropriate assessment of NRMM emissions should be included as part of the ES where appropriate taking into account the requirements of the London NRMM standards as outlined in the Mayor of London’s The Control of Dust and Emissions during Construction and Demolition SPG.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

Construction Emissions from vehicle movements on road, river and rail. e) PEIR Vol 1 para 6.6.3 details although the project has the potential to affect air quality due to emissions from construction vehicle movements by road, river and rail, that these effects have not been considered in the PEIR, but that they will be considered as part of the ES. f) An appropriate assessment of emissions from construction traffic should be undertaken. As no traffic figures or detailed construction phasing have been provided it is not possible to indicate what an appropriate assessment method would be. GBR comments provided in the scoping report have indicated that as the construction phase will be 6 years it is not appropriate for construction impacts to be considered as temporary. Additionally, as the construction period will occur before the assessment year of 2026, less of a shift to cleaner vehicles will have occurred and so a greater impact is likely to occur than if construction traffic was assessed for the year of 2026. It may therefore be appropriate for the assessment of emissions from construction road vehicles to consider the earliest possible year of peak construction. g) As no details of the required construction vehicle movements for river or rail is provided it is not possible to indicate what an appropriate impact assessment method would be. Where appropriate, however, impacts of emissions from vehicle movements from river and rail should be included in the ES submitted as part of the DCO, or suitable justification provided for their exclusion. 3.2.3 Operational Phase Emissions from Roads Vehicle Movements a) It is understood that a revised assessment of impacts from emissions from operational road traffic will be presented in the ES. The assessment presented in the PEIR therefore only provides an indication of assessed impacts at key receptors. Due to the fact that all modelled results are likely to change in the ES assessment submission this review has focused on the proposed assessment methodology, rather than the preliminary results at specific a receptors. b) The air quality modelling assessment presented in the PEIR has utilised base data for the year 2016 and assumed an operational assessment year of 2026. As pollutant concentrations are in general expected to show a marginal decrease year on year, 2026 is considered an appropriate assessment year in light of the current provisional opening year of 2027. c) Key changes to traffic to the South of the River Thames are presented in para 6.6.12. Of particular pertinence to GBC are points d, e and f. Traffic data presented in PEIR Vol 1 chapter 6, presented as Annual Average Daily Traffic (AADT), have been rounded to the nearest 1000 vehicles. AADT traffic flows have only been presented at key receptor locations in the PEIR but it is acknowledged that full traffic data will be made available in the ES submitted with the DCO application. d) Although it has not been possible to consider fully traffic data changes at receptors as part of this review there appears to be an error in Table 6.15 in relation to receptor PEIR0023. The tables seems to suggest that an increase in traffic of “<100” results in a decrease in NO2 concentration from 68µg/m3 to 66.7µg/m3. e) GIS traffic data files have been made available for review with the PEIR submission however this data is only for peak hours, and only for future year (2026) scenarios. In order to effectively review the air quality modelling results, and confirm that all appropriate receptor locations have been included, 24 hour AADT data should be made available for both base year (2016) and future year scenarios. f) PEIR Vol 1 para 6.3.43 – 6.3.45 provides detail on the road traffic emission factors which the air quality assessment has for NO2 and PM10. The study has utilised emission factors derived from an update to the speed band emission factors published in the Highways England (HE) Interim Advice Note (IAN) 185/15. These factors were released following the publication of the latest version of the Defra’s Emissions Factors Toolkit (EFT). Uncertainty in future year NO2 projections has been considered by utilising the methodology outlined in HE IAN 170/12 v3. The method outlined in the IAN 170/12 involves undertaking NO2/NOx gap analysis, based on

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

the adjustment of modelled NO2/NOx for both the 2026 DM and 2026 DS scenarios. Para 6.3.61 states that “although the IAN 170/12 was released prior to the latest version of Defra’s EFT if has still been utilised in the air quality assessment as it provides more pessimistic modelled concentrations than relying solely on Defra modelling tools”. The assessment therefore does not make use of the latest COPERT emissions factors and modelling tools provided by Defra but seeks to provide more pessimistic predictions for future year scenarios through use of the gap analysis. As the Defra modelling tools have been updated a number of times since the release of HE IAN 170/12 further analysis should be presented to verify the statement that its use still represents a more pessimistic approach. g) 185 roadside diffusion tube and automatic monitoring sites have been used for the purpose of model verification. Table B4 in PEIR Vol 2 provides model verification factors for 13 zones across the modelled area. These factors range from 0.97 (a model over prediction) at the A127 Junction to 5.92 (a large model under prediction) at Dartford urban gradient. Although the table provides the number of receptors and verification points associated with each of the verification zones the data presented in the PEIR does not detail which receptors and verification points are linked to which zones. It has therefore not been possible to undertake a full analysis of model verification using the data presented as part of the PEIR submission, so whilst the method presented is in agreement with that presented in LAQM.TG(16) it cannot presently be tested fully. h) Other than the mention of the Dartford urban gradient zone in Table B4 of PEIR Vol 2 the assessment does not make any reference as to how emissions from vehicles on roads of different gradients have been considered in the assessment. LAQM.TG(16) para 7.250 onwards provides a methodology for considering changes in emissions from vehicles on roads of different gradients. The impact of different road gradients on pollutant emissions should be considered in the revised assessment to be presented in the ES. Compliance Risk Assessment i) An indicative Compliance Risk Assessment is detailed in PEIR Vol 1 paras 6.6.43 - 6.6.44, however this only considers the maximum predicted concentrations in the Do Something (DS) scenario and the maximum increase in concentrations predicted by the scheme. The indicative assessment concludes that the project is considered to have a low risk of leading to non- compliance with the EU Directive on Ambient Air Quality. A full compliance risk assessment taking into account of all receptors will be undertaken for the ES.

Gravesham Borough Council Air Quality Peer Review Lower Thames Crossing - PEIR

4 Conclusions and Recommendations Bureau Veritas have undertaken a review of the air quality assessment presented within the PEIR. As the air quality assessment presents only initial results, which are subject to change in submission of the final ES this review has focused mainly on the methodology detailed, rather than results predicted at individual receptors. As complete traffic data has not been provided it has not been possible replicate results or to test the model verification method applied or to confirm that all appropriate receptor locations have been assessed. Due to the large model domain and complex nature of the zoned verification it is requested that more information around model verification is provided. Although the assessment does not make use of the Defra air quality modelling tools the assessment has been undertaken following the method outlined in the DMRB guidance supplemented by the use of several HE IANs. Further validation of this method is recommended to confirm that future year assessment predictions are not less conservative than if the assessment had utilised the Defra modelling tools which incorporate the latest COPERT emission factors. The initial assessment provides no consideration to varying of vehicle emissions on roads of different gradients or provides no commentary on how any changes in monitored concentrations from 2016 to 2018 will be captured within the assessment. The assessment as presented in the PEIR provides no assessment of construction impacts although this should be provided in the ES submitted as part of the DCO application.

12 Annex 5a Heritage Issues note

Cultural Heritage

Policy relevant to the LTC on the historic environment is set out in paragraphs 5.120 – 5.142 of the NPSNN (2014). This basically restates national policy as now set out in the NPPF (2018) at paragraphs 184 – 202. Policy CS20 of the adopted Gravesham Local Plan Core Strategy (2014) establishes the local policy position, once again reflecting national policy.

Whilst ‘saved’ policies TC2 (Listed Buildings); TC3 (Development Affecting Conservation Areas); and TC7 (Archaeological Sites) from the Gravesham Local Plan First Review (1994) are also relevant, national policy as set out in the NPSNN would take precedence where there is conflict.

Whilst the Council has recently (April 2018) consulted on a number of development management policies, these are at an early stage and very limited weight should be accorded them at this stage given they may change and have yet to be subject to examination. In any event, they are intended primarily to provide a local interpretation of national policies.

The decision maker also has statutory responsibilities imposed by sections 66 and 72 of the Planning (Listed Buildings and Conservation Areas) Act 1990. In considering whether to grant planning permission for development that affects a listed building or its setting, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historical interest which it possesses.

Similarly, with respect to the exercise of his planning functions in relation to any other buildings or land within a conservation area, the Secretary of State must pay special attention to the desirability of preserving of enhancing the character or appearance of that area. Section 66(2) extends this requirement to historic gardens under Part 1 of the Historic Buildings and Monuments Act 1953.

For the sake of completeness, scheduled monuments are accorded protection under a separate process contained in the Ancient Monuments and Archaeological Areas Act 1979.

As the LTC scheme would constitute a DCO application under the Planning Act 2008 (as amended), all issues and permissions would be dealt with concurrently through the examination process, with the final decision being taken by the Secretary of State in accordance with sections 103 – 107 of the Act.

It should also be noted that the LTC project would require an Environmental Statement (ES) under the terms of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2017 (the EIA Regulations). This would require significant environmental impacts in relation to cultural heritage, including architectural and archaeological aspects, and landscape to be clearly set out and the Secretary of State would have to take this into consideration in making any decision.

National policy on the historic environment

The Courts have held that the statutory responsibilities noted above will have been discharged where due process as set out in national policy is duly followed. It is important therefore in considering the proposals and information provided to date whether this is

consistent with national policy and whether there are any gaps or outstanding issues that need to be addressed. Making the applicant aware of any issues in this respect is in accordance with the principle that the process should be ‘front loaded’ – a primary purpose of the statutory consultation.

Heritage assets comprise those elements of the historic environment that hold value to this and future generations because of their historic, archaeological, architectural or artistic interest. They may include buildings, monuments, sites, places, area or landscapes. The sum of the heritage interests that an asset holds is referred to as its ‘significance’. Significance derives not only from the asset’s physical preference but also from its setting.

The setting of a heritage asset is the surroundings in which it is experienced. Its extent is not fixed and may change as the assets and its surroundings evolve. Elements of a setting may make a positive or negative contribution to the significance of an asset, may affect the ability to appreciate that significance or may be neutral. It is important in this respect to appreciate that the setting may extend beyond a physical or visual connection between assets as economic, social and historic connections can also be material – including historic relationships between places.

Some heritage assets have a level of significance that justifies official designation – including listed buildings of different grades; conservation areas; registered parks and gardens; and scheduled monuments. Non-designated heritage assets of archaeological interest that possess demonstrably equivalent significance to scheduled monuments should be considered subject to the same policies as designated heritage assets.

Consideration must also be given to impacts on non-designated heritage assets on the basis of clear evidence that the assets merit consideration in the decision making process, even though these would be accorded lesser value than those assets which have been formally designated. NPPF paragraph 197 is also relevant in this respect in that this requires a balanced judgement to be made in weighing applications that directly or in-directly affect such assets, having regard to the scale of any harm or loss and the significance of the asset.

The applicant is required to undertake an assessment of the likely significant heritage impacts of their proposal as part of the EIA and describe these in their ES. This should describe the significance of the affected heritage assets and include any contribution made by their setting to that significance. Such an assessment should be proportionate and be no more than is sufficient to understand such impacts. Where the proposal has the potential to include heritage assets with archaeological interest, the ES should include an appropriate desk-based assessment and, where necessary, a field based evaluation.

In terms of decision making, the Secretary of State is required to identify and assess the particular significance of any heritage asset that may be affected by the proposal, taking into account available evidence and expertise. He should take into account the nature of the significance of heritage assets and the value they hold for this and future generations whilst using this understanding to avoid or minimise conflict between their conservation and any aspect of the proposal.

In so doing, he should take into account the desirability of sustaining and, where appropriate, enhancing the significance of heritage assets, the contribution made by their settings and the positive contribution their conservation can make to sustainable communities. The

desirability of new development making a positive contribution to the character and local distinctiveness of the historic environment should also be taken into account.

When considering the impact of the proposal on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be.

Given heritage assets are irreplaceable, harm or loss of any designated asset should require clear and convincing justification. Substantial harm to or loss of a grade II Listed Building or a grade II Registered Park or Garden should be exceptional. Substantial harm to or loss of designated assets of the highest significance, including Scheduled Monuments, grade 1 and II* Listed Buildings, and grade 1 and II* Registered Park or Garden should be wholly exceptional.

Any harmful impact of the significance of a designated heritage asset should be weighed against the public benefit of the development, recognising that greater harm to significance will require greater justification for any loss.

National policy applies different tests depending on the degree of harm caused to designated heritage assets. It is important in the decision making process therefore to determine whether the degree of harm is ‘substantial’ or ‘less than substantial’ – neither are actually defined within the NPSNN or NPPF and this is a matter of professional judgement based on the evidence and having regard to relevant guidance.

Where a proposal will lead substantial harm to or total loss of significance of a designated heritage asset, development consent should be refused unless it can be demonstrated that such harm or loss is necessary in order to deliver substantial public benefits that outweigh that loss or harm, or alternatively that all of the following apply:

• The nature of the heritage asset prevents all reasonable uses of the site; and • No viable use of the heritage asset itself can be found in the medium terms through appropriate marketing that will enable its conservation; and • Conservation by grant-funding or some form of charitable or public ownership is demonstrably not possible; and • The harm or loss is outweighed by the benefit of bringing the site back into use.

Where the proposal will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal, including securing its optimum viable use. In so doing, the requirement to still accord great weight to the asset’s conservation still applies in the planning balance.

National policy recognises that not all elements of a Conservation Area will necessarily contribute towards its significance. Where the proposal would result in the loss of a building (or other element) that makes a positive contribution to the Conservation Area, this should be treated as either substantial or less than substantial harm, as appropriate, taking into account the relative significance of the elements affected and the contribution they make toward significance. Opportunities should also be sought where development is proposed within Conservation Areas and within their settings to enhance or better reveal their significance.

National policy continues by setting out that where the loss of significance of any heritage asset has been justified, a requirement should be imposed that prevents this occurring until such time as the relevant development or part of development has commenced.

Provisions are also made within policy requiring the recording and advancement of understanding of assets that stand to be lost, although the ability to record should not be a factor in deciding whether development consent should be granted. Similarly, policy recognises that there is the potential for archaeological assets to be discovered during the course of construction and it would be appropriate to impose requirements in such case to ensure that such assets are identified and properly treated as necessary.

Guidance on how national policy should be applied

There does not appear to be any guidance issued on how the policies within the NSPNN on the historic environment should be applied. Planning Practice Guidance on Conserving and Enhancing the Historic Environment (updated 22 February 2018) may be of relevance given the similarity of policies set out in the NPPF with the NPSNN. This is available on-line at https://www.gov.uk/guidance/conserving-and-enhancing-the-historic-environment

Historic England also issue guidance on assessing impact on heritage assets and the contribution made by their settings. This includes:

• Conservation Principles: Policies and Guidance (2008) available on line at https://historicengland.org.uk/images-books/publications/conservation-principles- sustainable-management-historic- environment/conservationprinciplespoliciesandguidanceapril08web/ • GPA2 : Managing Significance in Decision-Taking in the Historic Environment (2015) available on-line at : https://historicengland.org.uk/images-books/publications/gpa2- managing-significance-in-decision-taking/gpa2/ • GPA3 : The Setting of Heritage Assets (2017) available at https://historicengland.org.uk/images-books/publications/gpa3-setting-of-heritage- assets/heag180-gpa3-setting-heritage-assets/

In addition, the Department of Transport issues its own guidance on how impacts on the historic environment should be assessed for the purposes of EIA in relation to major projects such as the LTC. This guidance is set out in the Design Manual for Roads and Bridges (DMRB) and its web-based Transport Assessment Guidance (WebTAG) as follows:

• DMRB Vol 11, Section 3, Part 2 on Cultural Heritage (2007) available on line at http://www.standardsforhighways.co.uk/ha/standards/dmrb/vol11/section3/ha20807.p df • TAG Unit A3 Chapter 8 on Environmental Impact Appraisal (2015) available on-line at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachm ent_data/file/638648/TAG_unit_a3_envir_imp_app_dec_15.pdf .

It should be noted that whilst the DMRB and WebTAG remains helpful and provide templates for how impacts on the historic environment may be assessed, their approach is not entirely consistent with the NPSNN or NPPF (or indeed with each other) in that the latter (as the most recent iteration) generally categorises impacts within a range of ‘large

beneficial’ and ‘large adverse’ without clearly linking this to the policy terms ‘substantial’ or ‘less than substantial’ harm to provide a clear basis against which the relevant policy tests should be applied. This issue was raised at the EIA Scoping stage but does not appear to have been addressed.

In any event, whilst such a process-led approach may be helpful in providing analytical transparency, it should not be applied dogmatically because assessment of impacts ultimately relies on professional judgement.

Attention is also drawn to WebTAG Unit A3 at 5.3 onwards, which deals with the general approach the Department for Transport itself states should be adopted when considering impacts in the following environmental topic areas - landscape, townscape, the historic environment, biodiversity and the water environment. Step 5 on the overall environmental assessment score states at 5.3.19 as follows:

5.3.19 The following guidelines should be used to derive the overall assessment score for a topic from assessments on a number of separate key environmental resources. The advice here on the accumulation of environmental assessments is intended to provide a transparent and systematic basis for accumulating site or location specific results, while also allowing for the exercise of expert judgement.

• Most adverse category. The principle here is that a scheme as a whole should be assessed according to the most adverse assessment of the key environmental resources affected. For example, if a scheme affects, say, five key environmental resources, of which one is in the 'large adverse' category and the remaining four are 'slight adverse', then the overall assessment score should be 'large adverse'. The rationale for this approach is that highly adverse impacts should not be diluted or masked by less adverse impacts. It also encourages the development of alternative schemes which avoid such adverse outcomes.

• Cumulative adverse effects. The principle here is that, where it is clear that there is a cumulative effect across a range of key environmental resources, then the scheme as a whole should be scored in a higher category than the key environmental resources in isolation. For example, a scheme may affect a number of key environmental resources, each of which is assessed 'slight adverse'. Where it is clear that there is a cumulative effect across the key environmental resources, the scheme as a whole would be assessed as 'moderate adverse'. The existence of cumulative effects will usually depend on there being some similarity in the characteristic features or attributes of the affected key environmental resources. For example, a group of biodiversity sites might all be habitats for the same species of plant or animal.

• Balancing adverse and beneficial effects. The principle here is that, where there is a genuine compensatory effect, adverse assessments on some key environmental resources may be balanced by beneficial assessments on others. However, the precautionary principle is especially relevant here. The key issue is whether there are genuine compensatory effects. In most cases, it will be necessary to consider the impacts on each key environmental resource at a

detailed level, to ensure that the features lost from one key environmental resource are provided at another. For example, adverse assessments on groundwater supply at one location would probably need to be offset by beneficial assessments on groundwater supply at another location - beneficial assessments on floodplain would probably not provide genuine compensation. The scope for genuine compensatory effects will often be determined by the substitutability of attributes. In most cases, there is great uncertainty about the scope for substitutability, thus balancing should err on the side of caution. In particular, balancing should be restricted to 'slight' or, exceptionally, 'moderate' assessments. It is very unlikely that adequate compensatory effects can be identified to justify any balancing of 'large adverse' or 'very large adverse' assessments.

Gravesham BC would expect these principles to be consistently applied within any ES submitted in support of the DCO application.

With particular reference to the WebTAG requirement to adopt the most adverse category of impact set out above, it is noted that north of the River Thames the LTC proposals appear to result in the destruction of a Scheduled Monument at Orsett (crop marks) and the demolition of a number of listed buildings. As such, it is assumed that the project as a whole will be treated as resulting in Substantial Harm and the appropriate national policy tests applied.

Applicant’s Preliminary Assessment

The applicant’s assessment is contained within Chapter 7 of the PEIR (Vol 1); Tables E1 – 5 of the PEIR Appendices (Vol 2); and the relevant PEIR Figures (Vol 3).

Much of what has been provided in connection with the current Statutory Consultation relates to the identification of affected heritage assets of differing levels of significance along the route and within a 1km zone of influence to provide a baseline. Policy as contained within the NPSNN, NPPF and the development plan for each area is also set out. The stated methodology for assessing impacts within the PEIR is taken from Volume 11, Section 3, Part 2 of the Design Manual for Roads and Bridges (DTp document HA208/07).

A preliminary assessment is then undertaken dividing the LTC proposals into three sections – South of the River Thames; the Tunnels; and North of the River Thames. The relevant sections of text relating to each are as follows:

Section of LTC Baseline Potential Effects and Mitigation Measures

During Operational Construction

South of the River Paras 7.4.9 – Table 7.6 Paras 7.6.3 – 7.6.5 Thames 7.4.18

Tunnels Paras 7.4.19 – Table 7.7 7.4.28

North of the River Paras 7.4.29 – Table 7.8 Thames 7.4.49

The Applicant’s Preliminary Assessment assumes a future baseline with heritage assets remaining in broadly the same condition in the absence of the LTC project. Some archaeological remains would tend to suffer slow deterioration because of continued ploughing of arable fields. Climate change could have a potential impact on archaeology but built heritage is likely to remain in a similar condition subject to regular maintenance.

The Applicant’s Preliminary Assessment then sets out (at paras 7.5.1 – 7.5.8) the further baseline information and surveys required to complete the assessment. This includes:

• Completion of the archaeological walkover survey; • Completion of setting survey – unclear from text whether this has already been done; • Completion of condition survey; • Aerial mapping study and analysis of LiDAR data; • Geophysical survey; • Trial trenching; • Historic Land Use Characterisation (HLC) study; and • Palaeolithic period assessment.

Comments on Applicant’s Preliminary Assessment

As noted above, Volume 11, Section 3, Part 2 of the Design Manual for Roads and Bridges (DTp document HA208/07) is a dated document and not entirely consistent with the approach set out in the NPSNN etc. This will need to be addressed by the applicant.

It should be noted that Gravesham BC made extensive comments on heritage assets that might be affected by the project south of the River Thames at the EIA Scoping Stage. It is not intended to repeat those comments here, although regard should still be had to them.

The area within which the LTC would run in Gravesham is particularly historic, with heritage being multi-faceted and multi-layered. Many designated and non-designated heritage assets inter-relate within this context and need to be understood in combination. Cumulative harm to the significance of these assets in terms of how they are understood and appreciated for their historic, archaeological, architectural or artistic interest is therefore an important consideration.

Whilst the appendices contain a significant amount of information on the historic environment, the schedule of non-designated heritage assets is difficult to negotiate or interpret. Also, the mapping doesn’t appear to include the full list of entries. Given the nature of the information provided it would also have been useful if a commentary could have been provided detailing whether there are thought to be any significant clusters and how this has informed the approach to further investigations.

There are also a number on non-designated heritage assets that are missing from the list – presumably because they do not as yet appear in the Kent HERS. These are:

• Within Thong lies the site of Mounken Barn, a medieval tithe barn used to collect a portion of corn and grain as payment of tithe to Rochester Cathedral/Priory from lands located in Shorne, Cobham and Chalk.1 As noted below, this appears to provide a longstanding connection between Randall Manor and what was known as the ‘Borough of Thong’. This relationship needs to be understood as it contributes towards the significance of the Thong Conservation Area. The site of the barn and yard is shown on the 1842 tithe map for Shorne (entry number 301) as lying immediately north of footpath NS167 as it joins the west side of Thong Lane.2 The tithe barn appears to have been demolished in the period 1842-63 with the back of the site now occupied by two modern farm buildings.3 • Thong Lodge lies to the east of Thong Lane, accessed by a track that once formed the carriage entrance to the Cobham Hall Estate through the woods. This was built around 1816 and is believed to be to a design by one of Humphry Repton’s sons. An engraving of the lodge is contained in J.C. Loudon’s The Landscape Gardening and Landscape Architecture of the Late Humphry Repton Esq (1839).4 The Medway Archives also has a similar tinted oval print.5 • Further to the south down Thong Lane lies a 1930s house called Thong Mead. This is of interest because it is believed to have been designed by the eminent architect Sir Herbert Baker of Owletts, Cobham for a member of his family. Baker was a contemporary Edwin Lutyens and friend of T.E. Lawrence.6 He also designed the tombstone of Ivo Bligh (later 8th Earl of Darnley and England cricket captain responsible for bringing back the Ashes in 1882/3) in Cobham churchyard and (amongst other things) the 1926 grandstand at Lords Cricket Ground – donating the weathervane depicting Old Father Time.7

Aside from the above, the following general points are made in respect of the approach and content of the PEIR on the historic environment.

1. Whilst it is accepted that the PEIR only provides a preliminary view and that work is still on-going, what has been presented within the consultation material appears to be very

1 See E. Hasted – An Historical and Topographical Survey of the County of Kent (1797) at https://www.british- history.ac.uk/survey-kent/vol3/pp442-456 . 2 A transcript of the Shorne tithe apportionment is available on line at https://www.kentarchaeology.org.uk/Research/Maps/SHN/02.htm . There are also records relating to the tithe for the Borough of Thong in the Darnley papers kept at the Medway Archives. (https://cityark.medway.gov.uk/Details/archive/110020110) and a deposition in an Exchequer case dated 1700 in the National Archives at Kew (http://discovery.nationalarchives.gov.uk/details/r/C3711964 ) 3 These would appear to be surplus to agricultural use as they are being marketed by agents Hobbs Parker – see https://www.hobbsparker.co.uk/Images/EA/Properties/F2450_DOC_00.pdf 4 See page 564 at https://books.google.co.uk/books?id=ce5hAAAAcAAJ&printsec=frontcover&dq=repton&hl=en&sa=X&ved=0ah UKEwj3wa_l-8TeAhWJh6YKHS6qBZQQ6AEINTAC#v=onepage&q=thong&f=false 5 See https://cityark.medway.gov.uk/wwwopacx/wwwopac.ashx?command=getcontent&server=files&value=DE402 _23_26.jpg 6 See https://books.google.co.uk/books?id=n8VyCwAAQBAJ&q=sir+herbert+baker#v=snippet&q=sir%20herbert%20 baker&f=false 7 See https://www.theguardian.com/sport/2015/jun/18/father-time-weather-vane-returns-lords-cricket- ground

superficial and lacks depth. As such, it is difficult to understand how the preliminary view on impacts and the effectiveness of mitigation have been reached. The consultation material provides very little analysis of the significance of heritage assets either individually or in combination and what contribution setting makes to their significance.

For example, the Thong Rural Conservation Area Appraisal SPD (2017) states that the following positive features form the wider setting of the conservation area:8

• The open arable fields to the east of the village, along the east edge of which, parallel to the line of Thong Lane, is rising ground on which is the view-enclosing feature of Shorne Woods; and • The wide, flat, arable country west and north-west of the village from within which the village appears to stand ‘islanded’ in the open landscape.

The Thong Conservation Area (CA) therefore derives much of its significance from its farmland setting in the lee of Shorne Woods. This relationship has endured for a significant period of time, as shown on the original 1797 Ordnance Survey drawings in the British Library; the 1842 Tithe Map of Shorne Parish; and subsequent Ordnance Survey plans of the area.

The new LTC link road would sever the farmland to the west of Thong whilst mitigation in the form of the creation of false cuttings etc. and woodland planting to both the east and west of the hamlet would fundamentally alter its setting and detract from its significance.

On this, whilst the proposed mitigation may be required (in part) to address adverse impacts in terms of landscape, visual intrusion, noise and natural environment, a more nuanced approach is required when considering impact on the historic environment – it should not be assumed that ‘one size’ of mitigation ‘fits all’ types of harm.

The ES should properly assess therefore not only the impact of the main elements of the development itself but also the proposed mitigation measures, which may have a positive, neutral or negative effect depending on what harm it is they are supposed to mitigate.

When looking at the Thong CA, consideration also needs to be given to its inter-relationship with the archaeological site of Randall Manor set at a higher level within Shorne Woods. There is clearly a relationship here given the tithes of the area were assigned to Rochester Cathedral/Priory and both therefore fell within the area known historically as the Borough of Thong.

As such, anything that adversely affects the setting of Thong CA also has the potential to adversely affect the significance of Randall Manor. Inter-visibility here is not critical in this relationship given setting can also have wider historic and socio-cultural dimensions.

Historic England should also be asked for their view as to whether Randall Manor should be assigned the same status as a Scheduled Monument for the purposes of the DCO application given this could affect that weight accorded any harm to significance through development within its setting in the overall planning balance.

8 https://drive.google.com/file/d/0B3rpRo7SzRqdbnQ0Q2I0RjRnQ1k/view

2. Concern is also expressed over the preliminary assessment of the impact of the proposal on the significance of the Grade II* Cobham Hall registered park and garden and other associated designated and non-designated assets. The PEIR assumes that whilst these impacts would be negative, they would be comparatively small and unlikely to be significant given the works lie on the northern boundary of the park/woodland and represent a comparatively small change from the current setting.

However, this preliminary analysis completely ignores the wider setting of the registered park and garden and other associated assets to the north of what is now the A2 trunk road. The hamlet of Thong was a small estate village with the adjoining woods and farmland forming part of that estate along with the lands now lying to the south of the A2. The historic park and garden therefore needs to be understood in that context.

As noted above, the original carriageway to Cobham Hall from the north-west is now the private driveway to Thong Lodge – the 1839/40 engraving mentioned above actually refers to it as the park keeper’s lodge. From this point, the carriageway passed through the woods to the main Shepherd’s Gate entrance to the more formal part of Cobham Park designed by Repton in the 1790s. That this part of Shorne Woods appears to have been considered part of Cobham Park itself is also evidenced by the 1842 Tithe Apportionment which refers to the ponds here as being ‘ponds in the park’.9

The corridor now formed by the A2 trunk road was prior to the 1920s occupied by a far more modest country lane reflecting the original alignment of Watling Street10 Around 1924/25 a new 2 to 3 lane A2 trunk road was constructed as part of an unemployed workers scheme to improve strategic infrastructure. A roadhouse called the Laughing Waters providing refreshments for people travelling on this new road was developed as a speculative venture on the site of what is now occupied by the Inn on the Lake at the southern end of Thong Lane in the 1930s.11

Subsequently, the A2 was turned into a dual carriageway road in the 1960s and then widened further up to the present day. Some of these works were permitted under the Channel Tunnel Rail Link Act 1996, which also provided for the construction of the HS1 railway line adjacent. This resulted in the destruction of the old Watling Street country lane in the vicinity of Repton’s Ponds and a significant change in the context of the historic Grade II* registered park and garden both at this point and to the west.

The continued widening of the A2/HS1 transport corridor has therefore resulted in an incremental deterioration of the context within which heritage assets in this area are understood and appreciated, both through increased severance and intrusion through noise, light, fumes, and other associated activity.

9 See entries 308, 309, 315 and 317 in the 1842 Tithe Apportionment at https://www.kentarchaeology.org.uk/Research/Maps/SHN/02.htm 10 See photograph at https://apps.medway.gov.uk/apps/medwayimages/details.asp?docid=1124647&searchtype=all&pg=7&pga=3 7&search=cobham 11 For a photograph of the Laughing Waters see https://britainfromabove.org.uk/image/epw051613 . The Victoria and Albert Museum also has an electronic copy of a menu from the Laughing Waters at https://collections.vam.ac.uk/item/O1459629/laughing-water-restaurant-cobham-tariff-menu/

It is wrong to suggest therefore that LTC will only have a minor adverse impact on the Grade II* registered park and garden because the LTC works only affect its northern edge – it further severs the designated asset from its wider context and the way it is appreciated and understood.

In this respect, the advice set out in Historic England’s advice note GPA3 on The Setting of Heritage Assets (2nd edition, 2017) is relevant:

Cumulative change

Where the significance of a heritage asset has been compromised in the past by unsympathetic development affecting its setting, to accord with NPPF policies consideration still needs to be given to whether additional change will further detract from, or can enhance, the significance of the asset. Negative change could include severing the last link between an asset and its original setting; positive change could include the restoration of a building’s original designed landscape or the removal of structures impairing key views of it (see also paragraph 40 for screening of intrusive developments).

The LTC works would clearly represent an additional change which is likely to further detract from the significance of multiple assets which needs to be properly considered and addressed within the ES.

In this respect, the conclusions reached within the historic environment and landscape section of the PEIR would appear to be completely at odds with each other in terms of appreciation of severity of impact.

For example, Table 7.6 deals with construction impacts south of the River Thames and in terms of the Grade II* registered park and garden states that whilst there would be a negative effect, this is unlikely to be significant given the comparatively small change from the current setting. Similarly, in terms of impact on the Thong CA and White Horse Cottage (Grade II listed) the preliminary assessment states that whilst these could be negative and significant during construction, they are likely to change in nature and potentially reduce in magnitude when the scheme is operational.

Paragraphs 7.6.3 – 7.6.5 then provides a very short assessment of operational impacts, stating that ‘there will be no additional impacts to any heritage assets during the operation phase of the Project’. Whilst it is recognised that the nature of impacts may change from the construction to operational phase, it is suggested that these will reduce in magnitude with remaining adverse effects mitigated through earthworks and landscaping.

This is rather different from the landscape appraisal which in terms of the operational phase at Table 8.14 states the following in respect of the Kent Downs AONB (LCA 4 West Kent Downs) area – including the setting of the Thong CA:

The 14-lane carriageway within the AONB, along with the realignment of the adjacent local roads, the encroachment within the HS1 land to the south, the longer overbridges at Brewers Road and Thong Lane, the associated loss of important established mature trees and HS1 mitigation planting, would result in a major alteration in the scale and rural appearance of the A2 corridor through the AONB.

The loss of the important trees and the HS1 mitigation planting would also result in greater physical severance between the landscapes on either side of the A2 as well as a reduction in the containment of the road infrastructure, such as gantries, signs and street lighting, resulting in the A2 and HS1 corridor having a greater presence in the adjacent rural landscape. In addition, the increase in traffic flows along the A2/Project route, through the AONB may result in increased traffic noise within the adjacent landscape and recreational areas as well as within the historic Cobham Hall and Park.

The A2/Project route junction on the eastbound side of the A2 and the loss of linear vegetation on the westbound side up to HS1, within the Higham Arable Farmlands (Thong), would have a major alteration to the scale and rural appearance, resulting in urban encroachment into the immediate western setting of the AONB.

It is considered that the operational impacts of the Project route within the area and the adjacent Higham Arable Farmlands (Thong), would have a direct Major Negative change on the character of the A2 corridor through the AONB and its immediate setting.

Given the Grade II* registered park and garden lies within the AoNB (and this extends to the north of the A2 to include parts of Shorne Woods, that once formed part of the historic park but remain an important part of its setting) it is difficult to reconcile how the landscape impact can be Major Negative but impact on the historic environment is far less.

This anomaly becomes increasingly odd when it is considered that the heritage designation itself relates to the significance of the area in landscape terms – is the PEIR really trying to say that the operational impact on landscape in general is Major Negative but is less in terms of effects on the historic landscape?

Also, as set out above, the setting of the Thong CA would also be fundamentally changed by the LTC and associated mitigation and this will adversely affect the significance of this designated asset – along with other designated and non-designated assets in combination with it.

Once again, it is difficult to understand how the landscape impact is considered to be Major Negative but that on the historic environment is less when setting makes such a major contribution towards the significance of the assets.

Overall, Gravesham BC would argue that the PEIR significantly underestimates the impact of the LTC scheme on the historic environment and that the proposed mitigation measures may in themselves contribute toward harm. Whilst these mitigation measures may be required for other legitimate reasons, the potential residual harm in terms of the significance of heritage assets should be recognised and a comprehensive package of compensatory measures agreed.

3. One aspect of the historic environment that does not appear to have been considered is the existing pattern or roads, paths and trackways within the area and whether these have significance as non-designated heritage assets. For example, the A2 follows the line of the Roman Watling Street; Scotland Lane is an ancient sunken north-south track

connecting through to Thong Lane; and Brewers Road/Shorne Ridgeway is an ancient track extending out from Watling Street to hold sites around Hoo St Werburgh on the Hoo Peninsula. Such features (including the pattern of footpaths) may also be important in terms of how the landscape and settlement of the area is understood.

The LTC project has the potential to increase severance in terms of how non-motorised users (NMUs) move through the landscape and understand/appreciate the historic environment. It is important therefore that this aspect is not ignored within any analysis of the historic environment because poor choices in terms of design for NMUs could adversely affect significance of heritage assets and the historic environment in general.

This extends to the way in which Green Bridges are designed to reduce severance across the A2 to land to the south so that they are capable of performing a variety of functions – i.e. improving landscape, nature conservation, and NMU connectivity. On this, it is suggested that LTC should be used to explore best practice in Green Bridge design, following advice set out in publications by Natural England12 and the Landscape Institute13.

4. Another aspect that requires further attention is the impact of increased traffic flows on the local road network. These also have the potential to adversely impact on the historic environment some distance away from the project itself and these effects need to be properly understood both under normal operating conditions and during times when incidents cause ‘rat running’.

For example, increased traffic flows through the Thong CA would have an effect not only on road safety but also on how the CA is perceived, understood and appreciated. Increased traffic flows also bring with them the potential for damage to buildings, boundary walls and verges whilst traffic calming to mitigate adverse impacts also have the potential to incrementally change the character of an area detrimental to significance.

Further away from the scheme itself, increased traffic flows through CAs such as at Cobham; Shorne; Chestnut Green, Shorne and along the A227 Wrotham Road could also have an adverse impact that needs to be understood.

Local traffic modelling should be sufficiently robust to understand such impacts and a package of measures or mechanism included within any DCO to ensure that these are mitigated should issues arise.

5. The PEIR suggests that the Grade II listed Shorne/Cobham boundary stone may be affected by works to the south of HS1. It is understood that this was originally put in place following a dispute between the parishes in 1808 over who was responsible for maintaining parts of Watling Street. Unfortunately, the boundary stone was broken, repaired and moved to its current location when HS1 was constructed. Should it be necessary to move it again, it is suggested that this should be discussed with Gravesham BC and the parish councils prior to submission of the DCO.

Conclusion

12 See Natural England: Green Bridges – a literature review (2015) at http://publications.naturalengland.org.uk/publication/6312886965108736 13 See Landscape Institute – Guidance on Designing Green Bridges (2015) at https://www.landscapeinstitute.org/wp-content/uploads/2018/01/tgn-09-2015-green-bridges.pdf

As noted above, it is unfortunate that the PEIR is quite superficial in its analysis of impacts on the historic environment to the south of the River Thames, particular in relation to those areas where the project will have above ground impacts along the A2 corridor; in the vicinity of the Thong CA; and east of Thong Lane/Riverview Park. There is also the potential for the area around Chalk Church to be adversely affected both during construction and operation – in terms of the latter particularly where this results in increased background traffic noise.

In making these comments, it has been necessary to concentrate on key areas of concern. Previous comments at the EIA Scoping Stage set out other areas of potential interest in relation to archaeology, the post WWI smallholding scheme around Thong and Chalk; and the development of Gravesend Airport/RAF Gravesend. These areas will also need to be properly addressed in the final ES and the approach adopted at the submission stage.

Whilst Gravesham BC would naturally defer to the expertise of Historic England and Kent County Council on archaeological issues, the issue has been raised previously of evidence of earthworks shown on pre-war aerial photographs to the east of Thong Lane to the north of the Cascades Leisure Centre and their possible relationship with earlier field systems shown on publically available LiDAR (Light Detection and Ranging) images.

The importance of these needs to be better understood. Whilst it is understood that a new LiDAR survey has been undertaken along the route, this has yet to be released to stakeholders (including Gravesham) and it clearly should be as soon as possible to allow meaningful discussion to take place on such aspects.14

Overall, Gravesham BC considers that the PEIR underestimates the potential impact of the LTC on the historic environment and is not convinced that the proposed mitigation is entirely appropriate given that it could itself have an adverse impact on the way in which heritage assets are understood and appreciated. This would appear to be a result (at least in part) from a failure to properly understand how the area has developed and how a number of the heritage assets derive significance from their setting both individually and in combination.

Given the scale of the LTC intervention and its overall impact, it is difficult to see how adverse impacts on the historic environment can be adequately mitigated. In order to arrive at the best possible outcome should a DCO be granted for the scheme, Gravesham BC would ask to work more closely with Highways England to consider whether design changes are possible that could further mitigate impacts; to refine mitigation proposals so that these better reveal the significance of affected heritage assets; and to assess whether a package of compensation measures can be put together to offset residual adverse impacts that cannot be adequately mitigated.

14 An aerial photograph taken by the Luftwaffe on 4 June 1939 is available on-line at https://www.alamy.com/stock-photo-gravesend-kent-4th-june-1939-30092011.html Annex 5b Heritage Conservation

Heritage Environment Planning and Nola Cooper Enforcement Invicta House GT EPE County Hall First Floor, Invicta House MAIDSTONE County Hall ME14 1XX Maidstone Kent ME14 1XX Phone: 03000 413448 Ask for: Ms Wendy Rogers Email: [email protected]

19 November 2018

SENT BY EMAIL

Re: Lower Thames Crossing Preliminary Environmental Information Report Statutory Consultation 2018

Thank you for consulting Heritage Conservation on the above PEIR consultation documents.

The documents including the outline PEIR, including Map Books and General Arrangements, Engineering Arrangements and outline environmental assessments including Chapter 7 on Heritage with associated drawings in Appendices.

General comments The lower Thames estuary is rich in cultural heritage, a reflection of its role as a conduit for trade and transport throughout history and as an area rich in raw materials and other resources. As a result of its strategic role the River Thames has been important for defence of the realm throughout history which is demonstrated in the numerous designated and undesignated post-medieval fortifications situated along its banks. Many of these fortifications were designed to work together with important lines of sight across and along the Thames at various locations. The River Thames moved south to its current location during the Anglian glaciation so the area (including the Thames itself) contains important information on the Pleistocene geology and early human occupation of the southern British Isles.

The current PEIR assessment of the historic environment is inadequate in several key aspects:

• There is no assessment of the collective impact of the whole scheme on the integrated historic environment. The cultural heritage assessment covers individual components or heritage assets, not the whole. The ES Chapter 7 on the historic environment provides a baseline description of heritage assets along the route and within vicinity. There is also a Table of potential effects and mitigation for designated heritage assets (Table 7.6). Although the baseline description includes designated and non-designated heritage assets there is no assessment of the collective impact of this scheme of the historic environment as a whole. Heritage assets have individual value but they are also key components of a much broader picture of interconnecting groups with complex interrelationships. These components make up the “place” and give the distinctive character of an area. The land which this scheme runs through has a distinctive character and unique history. This broader historic mosaic can be reflected through historic landscape assessments which describe heritage assets within their setting, both landscape and chronological settings. But the PEIR does not seem to include any assessment of the historic landscape of the route South of the Thames.

It is essential the Cultural Heritage assessment in the final ES includes assessment of the collective impact of a significantly larger transport link on the multi-dimensional historic environment as a whole, not just on individual heritage assets. For example, what is the historic relationship of medieval Cobham Hall and parkland to Shorne Wood and to the surrounding fields and local routeways, and what is the impact of the A2 LTC junction on this relationship? Another example, what is the impact of LTC on Gravesend Airfield heritage; not just the surviving structures but also on the relationship between the structures; on the understanding, awareness and appreciation of the airfield within the local community and national enthusiasts. The LTC is extending across open fields and is going to have a major impact visually, as well as in terms of noise and lighting, and the full range of impacts need to be described not just on individual heritage assets but also on the wider historic environment as a whole.

• The proposed historic landscape assessment of the land south of the Thames is not of sufficient depth

There are proposals to use the current Kent HLC but this is not detailed and very broad brush. There are also intentions to use the Hoo Peninsula data which does cover most of the LTC south of the Thames but there are a few areas, such as Jeskyns Wood, which are not covered. It would be beneficial to undertake a targeted HLC for the area south of the A2/LTC junction, for example around Jeskyns Wood, and to add the data to the Hoo Peninsula data.

However, HLC provides only a baseline and there is a need for a far more rigorous assessment of the landscape affected by the LTC scheme. Landscape evidence of Early Prehistoric activity is not likely to be on the surface but visual evidence and connections to later prehistoric activity through to 20th century use is present in the form of clusters of cropmarks, ancient field systems, historic woodland, routeways, field boundaries, military sightlines and runways etc. HL assessment should also include wider analysis of setting and key views, historic and literary associations and community value. The historical and literary associations of heritage assets should be considered e.g. use of certain buildings as models for locations or key events in Dicken’s novels and life.

Therefore I recommend that the historic landscape assessment uses and updates the Hoo Peninsula HLC but then provides an assessment of the prehistoric through to 20th century military, settlement and agrarian landscape as it can be perceived today and then how the LTC will impact on that understanding.

• The proposed mitigation is far too limited. It focuses on designated heritage assets and does not include all impacts from noise, light, vibration during construction and long term use. The mitigation needs to be proportionate and reasonable and it should also be inclusive and cover both individual heritage assets and the wider historic environment.

For example, mitigation should include measures to compensate for harm to Gravesend Airfield, through retention and conservation of individual structures wherever possible and establishment of a heritage trail, thereby raising awareness and appreciation of this WWII heritage. Another example of improving and broadening the mitigation measures could be recognition of the use of the ridgeway as a variety of distinctive routeways over 1000s of years, not just as the Roman Watling Street but as prehistoric trackways through to post medieval telegraph routes.

A variety of mitigation measures should be considered and should be informed by the nature and character of the heritage asset(s), including the perception of the wider landscape as certain viewpoints. Screening may be acceptable for some assets but unlikely to be appropriate for military sites and historic landscape elements unless woodland is a key component.

Mitigation should seek to include conservation measures wherever possible and identify opportunities for enhancement. This scheme does present opportunities to raise awareness and understanding of the historic environment through artwork or activities, which can provide some offset to unavoidable harm.

Mitigation for heritage needs to include all impacts, including impacts from ecological and SuDs measures. The consequences of all mitigation measures need to be fully understood and described. There may well be areas where mitigation for ecology will have an impact on archaeology, for example, establishing areas for environmental mitigation and/or translocation of soils, tree planting etc, will have impact on heritage assets and especially on buried archaeology. As such mitigation for heritage needs to be appropriately broad ranging and inclusive, in order to ensure suitable mitigation is appropriately integrated into construction programmes and long term land management and restoration programmes.

We welcome the opportunity to comment on the scheme details at this early stage but emphasise that our comments are based on the current heritage data, including the present HER, which may not necessarily highlight all significant heritage sites along the route.

The assessment data provided so far is arranged in a manner which is not entirely helpful in comparing details and assessing the impact of the chosen design on the currently known heritage. The detail scheme plans are at a different scale to the heritage plans, making it challenging to consider the impacts on the heritage resource. It would be more helpful in the final ES data to have one section on Cultural Heritage (archaeology, historic buildings and historic landscapes) with a single plan showing all heritage constraints and the HER, then with another plan of showing the heritage data with the basic scheme superimposed on top. This would be more conducive to comparing the potential impacts on the historic environment. Therefore, we recommend that any forthcoming full EIA provides plans which clearly show the scheme impacts on one plan showing all known heritage assets, including an up to date HER.

In conclusion, there is a need for more in-depth and integrated assessment of the historic environment; archaeology, historic buildings and historic landscapes and their interrelationships, to ensure the ES reflects a sound understanding of the heritage assets affected by the LTC scheme. The assessment carried out so far is not sufficiently detailed to enable informed decisions on the mitigation for the chosen route. Although we understand the heritage assessment will include preliminary fieldwork, LiDAR, selected geophysical survey and other specialist assessments, etc, we are currently not aware of the range of the preliminary fieldwork nor viewed the results. The majority of the proposed route has not been subject to formal investigations and the data on the archaeological resource in particular is limited. Therefore, we would suggest there is potential for significant as yet unknown archaeology to survive and final decisions on preferred design options and mitigation should not be made until more detailed field assessments have been undertaken.

I hope these comments are helpful and I would be happy to discuss any of the above further.

Yours sincerely

Wendy Rogers

Heritage Conservation

Detailed comments on PEIR 2018 (KCC Heritage November 2018)

Preliminary detailed comments are as follows:

Chapter 2 Project Design

2.15 – provision of designed environmental mitigation such as earth bunds, balancing ponds, translocation of soils, landscaping, planting etc could have impact on heritage, particularly on buried archaeology. The archaeological consequences of environmental mitigation needs to be thoroughly considered at all stages of the scheme.

2.16 – temporary landtake and measures, such as site compounds, could have impact on heritage, particularly buried archaeology. Mitigation for heritage, particularly buried archaeology, needs to be thoroughly considered for even temporary measures.

2.17 – Services and utility diversions could have impact on heritage, particularly buried archaeology. Mitigation for heritage, particularly buried archaeology, needs to be thoroughly considered for all services and utility diversion works.

2.17 – enabling works and variations to scheme groundworks could have impact on heritage, particularly buried archaeology. Mitigation for heritage, particularly buried archaeology, needs to be thoroughly considered for all enabling and variation to scheme works

2.18.2 – archaeological investigations need to take place prior to groundworks in each particular area, including for utility diversions and for enabling works.

2.18.11 – the construction and use of site compounds need to be subject to full archaeological assessment and mitigation. The proposed Highways Construction Compound South of Thames and the South Portal Compound (fig 2.2a) overly many undated cropmarks and part of the Gravesend Airfield. Suitable archaeological mitigation is needed prior to these site compounds being established.

Chapter 5: Environmental Assessment Methodology

Detailed comments are being provided to the LTC team and we welcome the direct liaison regarding the fieldwork proposed and the assessment as it progresses.

Chapter 7: Cultural Heritage

The rural nature of this scheme significantly increases the risk of encountering as yet unknown archaeology which may be of importance. There are a number of cropmarks south of St Mary’s Church which indicate the presence of an extensive multi-period occupation site and post-medieval brick kilns are thought to survive in the former Shorne brickfields. We recommend that fieldwork is needed to support any desk-based assessment for the EIA to clarify the potential for significant buried archaeology along the chosen route, especially of all the cropmarks known within the location of the two site compounds south of the Thames.

In general there is insufficient consideration of the Thames and Medway Canal, 20th century defensive lines and Gravesend Airfield, or the Milton Rifle Range; their settings, character and wider landscape context. It will be a requirement to clarify the impact of the scheme on the canal and other “larger heritage assets”, including the airfield and the full historic Cobham Parkland, not just the current designated area.

There is a need for broader and more detailed consideration of impact on historic landscape from lighting. This could be a major harm factor for a variety of receptors, including setting of designated heritage assets, especially listed buildings, and the Grade II* Cobham Park. In addition, as this scheme runs through a rural area, lighting could have a wider impact on the historic character of the landscape, including the historic marshland and open field system south of the Thames. Mitigation should not just include adding more trees. There needs to be mitigation considered appropriate for open landscapes as “screening” is not necessarily going to be most appropriate and could be detrimental to the significance of some military heritage assets and historic long views from Cobham and Shorne.

Historic landscapes south of the Thames are not fully highlighted as a cultural heritage issue throughout this PEIR. There are considerations of landscape and visual impacts, covering ancient woodland etc, and the setting of Listed Buildings is raised but there is no clarity in how assessment of historic landscapes would be covered. We recommend assessment adheres to the DMRB Volume 11 and associated guidelines and to the 2013 GLVA (although there is a distinct difference between natural landscape assessment and historic landscape assessment.) In addition, the HLC for Kent is not of sufficient detail. We recommend that the assessment for historic landscapes includes a detailed HLC, as recommended by the DMRB. This is particularly needed in view of the green field and rural nature of the scheme.

We welcome the appreciation of the potential impact on marine archaeology from the bridge and immersed tunnel and the acknowledgement that there could be an impact on significant geoarchaeological deposits. We note the proposed programme of geoarchaeological assessment (PEIR chapter 7)

There is no mention of options to consider impact on Bluebell Hill from increased traffic to the M2 from the M20. We welcome this in terms of the potential reduction of impact on the historic environment but maintain that any off-line works to the A229 Bluebell Hill could have a major impact on the historic environment, especially the nationally important Medway Megaliths. The impact of increased traffic between the M20 and M2 as a direct result of the Lower Thames Crossing should be part of the assessment.

5.128 Requirement (p128) I note that the ES will include the results of suitable field evaluation. I would welcome clarification of what is “suitable” field evaluation. I welcome the proposals to undertake geophysical surveying but I recommend there is a need for targeted trial trenching and/or test pitting. Non-intrusive field techniques cannot always clarify date and nature of heritage assets, especially cropmarks. As such some intrusive archaeological fieldworks may be useful.

5.129 Requirement (p128) states that the DBA and Es will provide an assessment of the value of the heritage assets, including descriptions of the nature of their significance. Assessment of the “value” of the heritage assets needs to be based on Historic England national criteria.

7.4.9 The Dairy at Cobham Hall is currently subject to a planning consent for conservation and conversion to residential and works are underway.

7.4.15 There is mention of the Roman Watling Street but there is a need to consider earlier and later use of this routway along the ridge. There are indications from formal investigations at the A2 Cyclopark, that this route may be of prehistoric origins. There are also indications of this route being important, named post medieval routes, eg telegraph and poll route. I recommend the need for both assessment of archaeological data and documentary data to clarify the multi-period and diverse use of this ridgeline routeway.

It is essential that documentary and cartographic assessment is thorough. Early maps from the Cobham Estate must be an essential information source.

7.5.2 It is essential that the walkover survey includes all the proposed mitigation areas as well as the main scheme. Creation of habitats and receptor site mitigation can have major implications for archaeological mitigation. As such mitigation for natural environment needs to be taken in to account throughout the heritage assessment.

7.5.3 It is not acceptable for the assessment of setting to simply focus on designated heritage assets. It is essential that the setting of all heritage assets is considered, especially in view of the range of heritage assets, from Gravesend Airfield to Historic England identified historic farmsteads. Assessment of the setting of historic assets may well merge with a suitable historic landscape assessment.

Table 7.6 Effects and mitigation of key heritage assets south of the River Thames

Receptor: Non-designated heritage assets within the Development Boundary: Potential mitigation south of the Thames will need to be covered by WSIs agreed with the County Archaeologist.

Receptor: Cobham hall registered park and garden – there needs to be consideration of impact beyond the existing northern edge of asset. It is believed Cobham Park extended north of A2 routeway and remains directly associated with the designated parkland, such as earlier park pales or access points, might require mitigation equivalent to its significance.

Receptor: Cobham Hall including Temple, Engine House, Aviary The Dairy The Mausoleum The Mount Bowl Barrow, Romano-British villa and 19th century reservoir are an extremely varied collection of heritage assets with different attributes and needs. Mitigation for these heritage assets should not be lumped together. Some of the historic buildings are at a distance and may just require mitigation for visual impact but the Romano British villa is very close to the scheme. There is high potential for associated archaeological remains which could be considered to be of equivalent importance. As such I recommend that the heritage assets within Cobham Hall are dealt with separately.

Receptor: Church of St Mary Chalk – the assessment needs to include impact from increased noise, vibration and lighting during construction and operation. Consideration of visual screening only is not sufficient. This heritage asset is so close to major works including the tunnel entrance, there needs to be a comprehensive assessment of all possible short term and long term impacts.

Receptor: Tilbury Fort, Gravesend Blockhouse New Tavern Fort - assessment of these designated assets needs to thoroughly consider their function and especially the need for their visual relationships. Sight lines are a key factor in the significance of these assets and “visual screening” is likely to be more harmful.

Receptor: Coalhouse Fort Battery – again assessment needs to thoroughly consider function and especially the need for visual relationships. Sight lines are a key factor in the significance of these military assets and “visual screening” is likely to be more harmful.

Receptor: Cliffe Fort: assessment needs to thoroughly consider function and especially the need for visual relationships. Sight lines are a key factor in the significance of these military assets and “visual screening” is likely to be more harmful.

Other heritage sites requiring greater consideration:

St Thomas’ Well – Cobham Park – conserved as part of HS1 works but may now be impacted by new scheme. Need appropriate details of mitigation for this heritage asset.

Chapter 7 baseline heritage assessment does not mention the Thames and Medway Canal, 20th century defensive lines or the Milton Rifle Range in sufficient detail. The immersed tunnel may well have an impact on the Thames and Medway Canal and Milton Rifle Range although the details of the impact are not clear at this stage.

In addition, there is no specific mention of historic landscapes assessment for the land south of the Thames in Kent. As this scheme runs through an open landscape there could be major impacts from built development. The landscape approaching the river is rich and distinctive with multi-period sites visible or close to the surface of green fields. This could potentially be highlighted as being of high sensitivity. We recommend the guidance in DMRB Volume 11 on historic landscapes is adhered to. In particular there should be consideration of cumulative impacts and post-operational or long term impacts on this open space east of Gravesend and west of Rochester.

WR Heritage Conservation KCC

Annex 5c Heritage Conservation additional

22nd November 2018

SENT BY EMAIL

Re: Lower Thames Crossing Statutory Consultation November 2018

Thank you for consulting Heritage Conservation on the above. We have already provided comments on the PEIR – Wendy Rogers’ letter of 19th November 2018 and will also be providing comments on the assessment methodology for cultural heritage in the next few days. The comments below relate specifically to the consultation questions where relevant to the historic environment.

Question 2a. – support

Question 2b. – strongly support

Question 2c. - On historic environment grounds we support the selection of the preferred route as other route options, particularly Options B, D1, D2 and E, would on current evidence have a greater negative effect on the historic environment.

We strongly support the extension of the bored tunnel beyond the alluvial deposits south of the Thames and St Mary’s Church as this should with appropriate design provide protection for buried archaeological landscapes, important waterlogged palaeoenvironmental evidence, important heratge assets such as the Milton Rifle Range and St Mary’s Church.

Question 3b. – It is important that structures such as bridges, viaducts and embankments are designed to minimise the adverse impact on important heritage assets such as Cobham Park and nearby Scheduled Monuments and listed buildings; as noted in our comments on the PEIR it will be important to consider impacts in relation to historic landscapes rather than just individual assets.

Question 3c. - It is important the tunnel portal is designed to minimise negative effects on St Mary’s Church – it should not be assumed that screening through earth bunding or tree planting will mitigate any adverse impact as such features may be inappropriate in the landscape context.

Question 6b. – It is important that proposals for habitat creation and other environmental mitigation measures do not adversely affect important heritage assets and landscapes.

Question 13. – The Lower Thames Crossing will have a great impact on the landscapes and communities of this part of North Kent for a considerable period of time. As part of the mitigation package it would be appropriate to consider setting up and funding a body similar to the Rail Link Countryside Initiative which was created during construction of HS1. This initiative helped build goodwill with local communities by funding and facilitating community and environmental enhancement projects within a certain distance of the scheme. If such an initiative is created, criteria for environmental enhancement projects should include historic landscapes and heritage assets as well as the natural environment.

We would be happy to discuss any of the above further.

Yours sincerely

Lis Dyson

Heritage Conservation Manager

Annex 6a Landscape report from Val Hyland Assoc.

Lower Thames Crossing proposal November 2018

The headline issues relating to the PEIR assessment of effects on landscape character and visual amenity

Report to Gravesham Borough Council

Version: Final Draft V Hyland November 2018 Associates Ltd Introduction A Preliminary Environmental Information Report (PEIR) has been produced by Highways England, for a proposal to develop a Lower Thames Crossing (LTC). The PEIR has been produced following production of, and consultation on, a previous Scoping Report in 2017.

This Summary Report highlights the headline issues that have emerged from an appraisal of the PEIR in its assessment of the landscape and visual effects of the LTC proposal in the study area south of the River Thames.

This report raises key issues concerning the methodology used to undertake the process of Landscape and Visual Impact Assessment and its application and suggests further work that is now necessary.

Some issues overlap with other disciplines, notably Cultural Heritage, Biodiversity and Tranquillity (noise). Also, this response may include and overlap with issues covered by the Kent Downs Area of Outstanding Natural Beauty (KDAONB) Unit in their response to the PEIR.

This report responds to the issues raised by the Planning Inspectorate (PINS) and Gravesham Borough Council at the Environmental Impact Assessment (EIA) Scoping Report stage. This report may cover some issues more extensively, in order to expand the point and cover other headline issues.

This report also appraises the mitigation proposals and raises further potential mitigation and/or compensation issues for consideration.

Approach This report is based on an appraisal of Chapter 8 in Volume 1 of the PEIR, and other documents in the PEIR suite of documents.

Landscape and Visual Impact Assessment (LVIA) as part of an Environmental Impact Assessment usually follows a prescribed methodology. The aim of the methodology is to systematically appraise the existing landscape condition, to identify all the significant physical and visual characteristics and assess their quality or value as well as their sensitivity and the perceived visual amenity value. These then provide a baseline against which the key landscape and visual effects can be predicted and evaluated, and their magnitude and significance assessed. Table 1.0 response to question 1 (below) appraises the methodology used in the PEIR assessment.

The precise methodology for a LVIA can vary between different guidance sources, but generally follows a similar approach, namely:

For all stages of the project:-

i. Baseline Study ii. Legislation and planning policy context iii. Extent of study area iv. Identify landscape and visual receptors v. Project description vi. Identification of landscape and visual effects vii. The scale, extent and duration of the project proposal, and the magnitude and type of its potential effects at various stages viii. Assessment of significance of effects

ix. Proposed mitigation

The PEIR includes the selection of assessment type (see Table 3.0 response to question 3 below). This suggests the assessment is following methodology from the DMRB and the relevant Interim Advice Note1

DMRB Volume 11 provides guidance on Environmental Assessment. It appears that Chapter 8 of the PEIR may have followed this guidance. DMRB Volume 11 states that assessment levels are dependent on the potential environmental effects, the stage of project planning and the next project decision. The level of assessment carried out may be either Scoping, Simple or Detailed. These stages are not sequential, but consequential i.e. the results of one assessment level may determine further assessment work required.

In this case the criteria for a ‘Detailed Assessment’ appear to be met in that they include the likelihood of significant landscape and/or visual effects. However, the assessment appears to be part ‘Detailed Assessment’ and part ‘Simple Assessment’. It is not clear. General points

The Landscape chapter is not easy to read. The information is not laid out in a way that makes the assessment and its stages clear.

It is not clear which methodology is used in the assessment. This can cause some confusion. For example, there needs to be a clear distinction between the terms ‘impact’ and ‘effect’, and a consistent approach in their use. This follows best-practice national guidance2 and is important in conveying information to a non-technical audience. Terms used to describe landscape and visual effects vary and it is not easy to follow which guidance has been used.

Comments on Methodology used in the PEIR

i. Baseline Study: To assess landscape, there needs to be an understanding of the value of the landscape. This is assessed from a range of factors including condition, quality and perceptual and other factors. National Character Areas (NCAs) are referenced in the PEIR, with extracts from the Statement of Environmental Opportunity (SEO) for each NCA3. However, the descriptions and key characteristics of the NCAs are missing. The descriptions are vital in highlighting the important features of the areas and must not be discounted. For example, the Greater Thames Estuary NCA describes the rich historical associations of the area, including the distinctive military heritage along the coastline. The retention of views between these historic forts is a part of the heritage of the forts, but it is not mentioned and not reflected in the assessment.

1IAN 135/10 - this advice note sets out the requirements for the Highways Agency (Highways England) and Service Providers on the assessment of landscape and visual effects of highways projects. 2 National best-practice guidance for Landscape and Visual Impact Assessment is provided in ‘Guidelines for Landscape and Visual Impact Assessment – Third Edition’ by the Landscape Institute and Institute of Environmental Management & Assessment 3 Natural England publishes profiles for England’s 159 National Character Areas (NCAs). The profiles are guidance documents to support the planning of conservation initiatives, and to inform choices about how land is managed and can change. They provide a description of the natural and cultural features that shape our landscapes, how the landscape has changed over time, the current key drivers for ongoing change, and a broad analysis of each area’s characteristics. Statements of Environmental Opportunity (SEOs) provide guidance on the critical issues, which could help to achieve sustainable growth and a more secure environmental future. NCAs 81, 113 and 119 are relevant to this proposal.

The PEIR barely mentions heritage in its use of the NCAs. Similarly, there is no information on field patterns; a significant issue in an open, flattish landscape. Also, the NCA landscape change data is not mentioned. These are significant omissions, as the pressures on the landscape and the current landscape quality should be important factors in the assessment.

The use of local landscape characterisation is better as it includes a wider range of issues. Characteristics of nine of the 23 Local Character Areas (LCAs) have been considered. It is stated that those not considered will be reviewed at a later stage.

The evaluation of landscape needs to consider both the LCA and the historic landscape characterisation. The assessment also needs to address the many historic features which are important in their own right as well as features of the landscape.

Historic Landscape Characterisation Reports are not included, but they are available for this area and should be considered. Sites of heritage importance, Registered Parks and Gardens and Conservation Areas are included in the PEIR, and sites with sensitive biodiversity are mentioned. However, the issue of impacts on the historic environment, and the effects on the setting of heritage assets of the proposal – including the proposed mitigation - do not appear to be considered in the assessment process. ii. Legislation and planning policy context: National and local policy requirements are included in the PEIR. However, legislative requirements are also included in the list of NPSNN requirements, and it is unclear as to whether the current version of the assessment responds to the NPSNN requirements, other than to list them.

In addition, the assessment does not include GBC Local Plan Policy CS02 which relates to the scale and distribution of development and includes reference to development being compatible with national policies for protecting the Green Belt.

Also missing from the PEIR, the requirements in Policy CS12 include account to be taken of the KDAONB Management Plan (2014-2019), The Gravesham Landscape Character Assessment (2009), and the Cluster Studies (notably The Shorne to Shore Cluster Study). Other important and relevant guidance documents not referenced in the PEIR include Local Plan policy evidence documents - Gravesham Green Belt Study, PPG 17 Open Space, Sport and Recreation Study 2010, and Gravesham Landscape Sensitivity and Capacity Study by LUC (March 2016) iii. Extent of study area: Visual Baseline is informed by Landscape Character Assessment data and the potential extent of visibility of the project. See Table 1.0 responses to questions 2 and 3 (below). iv. Identify landscape and visual receptors: See Baseline Study section above for information on landscape receptors.

Visual Receptors (i.e. people who might be able to see the proposal and be affected by it) and the extent and quality of their views are identified, and with the exception of road users in vehicles and HS1 train passengers (who are not considered) appear to be representative of the range of receptors that might be affected by the project.

Visual Receptors: A number of viewpoints were selected to illustrate the effects of the proposal on ‘visual receptors’. 18 viewpoints were selected in the Gravesham area (i.e. the LTC area south of the Thames); 6 of which were reproduced as visualisations with proposals shown in place, and 5 of the 18 views were also taken at night to show the effects of lighting.

The results of the selection of viewpoints:

• View 2 visualisation fails to provide a realistic image. Existing screening vegetation is shown in place. In reality the viewer may be able to see the parallel feeder roads to the A2 and possibly the HS1 track. • View 4 should provide a night view as it could be affected by lighting and the loss of screening vegetation. • View 5 visualisation shows a view from a bridge that will be demolished; and shows the view of a nearby proposed bridge. This is very unhelpful and should show the viewpoint from the new bridge (which might reveal an expansive view of the proposed A2/LTC junction). • View 6b is a view from Jeskyn’s Woodland towards the proposed A2/LTC junction. Again, it may be misleading in retaining the HS1 screening vegetation. The reality may be a starker view of the junction infrastructure. • View 7 visualisation of a view from Thong Village provides little for the reader to understand, and it is not clear at what stage of the project the view is meant to represent. • Views 8 and 9 should also show night views, so that the potential contrast may be seen. • View 12 visualisation is unhelpful. All the existing vegetation is in place, and the landform has not changed. • View 17 from the Saxon Shore Way should be added to with a view north across the Thames to Essex, as the works north of river may have visual effects on the visual receptor along the south coast. • There are only 2 viewpoints along the A2 transport corridor. This is a key part of the AONB where significant changes can be anticipated as a result of this proposal.

It is recommended that further work be carried out to increase the number of viewpoints, and to address the issues set out above. v. Project description: This is not included in Chapter 8 but is found elsewhere in the PEIR suite of documents

Figure 1.0 Flow-chart of LVIA process

vi. Identification of landscape and visual effects: (With reference to Figure 1.0 above)

The significance of landscape effects is assessed from a combination of landscape character, sensitivity to change, and value, considered with the magnitude of the proposal.

Landscape Value: All AONB landscape receptors are assessed as being of High Value (this is the highest value in the scale from IAN 135/10). Other areas outside the AONB are assessed as either High or Medium Value. This is considered appropriate. The PEIR states that some issues relating to the valuing of the landscape are to be considered at a later stage of the PEIR. It is recommended that the approach taken includes additional issues that may contribute to understanding value (see Appendix X). These are also set out in the GLVIA.

The significance of visual effects is assessed by considering the sensitivity of the receptor with the magnitude of the proposal.

Visual Sensitivity: With the exception of the Golf Course receptor (Medium Sensitivity) all visual receptors and viewpoints are assessed as having High Sensitivity. This is the highest category in the scale used (IAN 135/10) and is considered appropriate. vii. The scale, extent and duration of the project proposal, and the magnitude and type of its potential landscape and visual effects at various stages:

The scale and detail necessary to fully assess the effects of the proposal are not yet finalised. It is therefore impossible to fully assess the effects on landscape and visual receptors with any certainty. It is understood that the construction phase is estimated at 7 years. However, more detail will be required as to the programming of the different elements of work and their potential effects.

Areas of concern, where more information is needed to adequately assess effects, include:

The scale, mass and height of the proposed junction of the A2 and LTC; the land-take, removal of screening vegetation, change in character and effective severance of the AONB along the A2 transport corridor; the extent, depth and type of cuttings at the main road junction and northwards along the route to the tunnel south portal, the new landforms created by the route and its proposed mitigation over the short, medium and long-term. It is recommended that more realistic photomontages and 3D modelling are developed to better represent the proposal. viii. Assessment of significance of effects The PEIR has assessed the potential likely significant effects of the project, both in its construction phase and when operational. However, the PEIR makes clear that the process of assessment is ongoing and is subject to change.

The guidance in IAN 135/10 (Section 3.29) states that “In general, more significance is likely to be placed on large long term or permanent changes than small short-term temporary ones”.

For Landscape effects:

Construction Phase: All landscape effects are considered to be negative (or adverse, depending on the guidance followed), and either Major, Moderate or Minor in their significance. This is considered acceptable given the criteria and guidance used. However, it is recommended that this be reviewed when revised views and photomontage images are available.

At completion: All landscape effects are considered to be negative (or adverse, depending on the guidance followed), and either Major, Moderate or Negligible in their significance. This is considered acceptable given the criteria and guidance used. However, it is recommended that this be reviewed when revised views and photomontage images are available.

For Visual effects:

Construction phase: All visual effects are considered to be negative (or adverse, depending on the guidance followed), and either Major, Moderate or Minor in their significance. This is considered acceptable given the criteria and guidance used. However, it is recommended that this be reviewed when revised views and photomontage images are available.

At completion: All visual effects are considered to be negative (or adverse, depending on the guidance followed), and either Major, Moderate or Minor in their significance. This is considered acceptable given the criteria and guidance used. However, it is recommended that this be reviewed when revised views and photomontage images are available.

Points to note from the assessment of significance of effects include: Construction phase: the removal of existing vegetation; in particular the removal of vegetation that is part of the mitigation for the route of HS1 (and may still be part of an agreement for its retention) and along the A2 transport corridor will result in significant impacts to the landscape and visual quality of the area as experienced by a range of users/receptors. This is recognised by the PEIR as a significant issue but is repeated here for emphasis.

All significant effects are assessed as Negative. The guidance (IAN 135/10) indicates that at worst the ‘Major Negative’ category4, would:

Be at complete variance with the character (including quality and value) of the landscape.

Cause the integrity of characteristic features and elements to be lost.

Cause a sense of place to be lost

A Moderate Negative effect would:

Conflict with the character (including quality and value) of the landscape.

Have an adverse impact on characteristic features or elements.

Diminish a sense of place

This will require a strategic and large-scale approach to mitigation. The PEIR, however, considers each element of mitigation separately.

The results of the assessment would suggest that overall, the size, massing and siting of the proposal appears to be out of scale and character with the surrounding landscape. A junction comprising large, multi-level, hard-built elements within the setting of the AONB, with deep cuttings, and set against a flattish, open landscape will be problematic to mitigate. ix. Proposed mitigation:

Initial mitigation measures are shown in the PEIR document - Outline Environmental Masterplan (EMP), and mitigation proposals are listed for each landscape receptor at construction and completion stage.

4 IAN 135/10 does not use the term Major in its description of effects but uses the terms Very Large or Large to apply to negative effects (NB It is assumed this means ‘Major’ as applied to the assessment)

It is considered that the listed proposals are overly detailed and premature; and the EMP is too broad-brush and may be inappropriate for the character of the landscape. For example, the landtake constraints imposed on the scheme in the A2 corridor mean that vertical elements of mitigation are proposed to reduce the impact of noise and visual intrusion through the corridor. Elements which may not be appropriate for the setting should not be used in order to improve a poor choice of route.

Mitigation should not disrupt or change the character of this landscape (e.g. by extensive coverage of woodland planting in a traditionally open landscape with Green Belt status, or by introducing new landforms). The current proposals (in the EMP) do not appear to take account of the heritage interest of the area or the setting of important heritage features or landscape elements.

In addition, large-scale acquisition and mitigation could affect the archaeological interests of the area.

The guidance in the NPSNN (Sections 5.159-5.161) states that the reduction in scale of the proposals or otherwise amending the design may help to mitigate the visual and landscape effects of the proposal. It is recommended that options are developed to reflect this guidance.

Explanation is required as to how mitigation is to be secured, and the means by which land management in the operational phase is to be secured (i.e. retained within the highways estate or returned to management by other landowners).

Although mitigation is mentioned as should be the first resort, compensation should also be considered. The guidance (NPSNN Section 5.162) indicates that improvements to local access and open space may assist in providing mitigation. In this way Green Infrastructure as part of the mitigation scheme could provide positive environmental and economic benefits. This is an important area for consideration by the promoters of this proposal, as Gravesham BC has made clear its aspirations to develop the Green Grid within an overall Green Infrastructure Network in the area included in the proposal.

NPSNN Section 5.175 requires the protection of green infrastructure networks from development, and for strengthening of the networks. This section of the guidance also refers to the value of linear infrastructure in supporting biodiversity and ecosystems.

The proposed severance of the KDAONB along the widened A2 corridor and A2/LTC junction, and removal of central reservation from the A2 along this section, will not only have a significant effect on the landscape, and on access routes, but may also have an effect on the biodiversity interests of sites to the immediate north and south. In addition, the experience of walkers, riders and cyclists crossing the newly widened road corridor will be significantly affected by the proposal.

If the proposal goes ahead, there will be a need for a green crossing (or more than one crossing) of the transport corridor. The crossing would need to be carefully designed to ensure that it could function as a wildlife corridor, as well as a landscape function in providing a continuation of the landscapes to either side of the road corridor. So, it would need to be big. The green bridge could be an exemplar, and a lasting legacy for the future. The Landscape Institute has published advice on best practice in Green Bridge Design5

5 See Landscape Institute – Guidance on Designing Green Bridges (2015) at https://www.landscapeinstitute.org/wp-content/uploads/2018/01/tgn-09-2015-green-bridges.pdf

The above issues are further reinforced by the guidance in NPSNN Section 5.164 which refers to the Green Belt and the aim to keep land permanently open, and section 5.178 regarding Green Belts and inappropriate development. The guidance thus supports mitigation proposals that provide open space, access opportunities and retaining an open landscape.

Sections 5.180 and 5.184 are relevant to the access network. The functionality and connectivity of the network will be compromised by the proposal. Diversions of routes must be carefully designed with the involvement of a range of stakeholders to ensure that the network is viable, and the experience of users is not unduly compromised.

Noise is considered in a separate topic report. However, there is a link with the enjoyment of the landscape, in particular those areas of the landscape that are currently tranquil. This is relevant to areas of the KDAONB, and notably areas within Shorne Woods Country Park. Mitigation proposals should consider how to minimise the noise pollution to these areas.

The guidance provided by IAN 135/10 requires mitigation measures to be developed as part of an iterative design process. This is useful, as the full extent and significance of effects may not be fully appreciated until further stages of design are developed.

The PEIR states that a fully detailed assessment of mitigation required will be undertaken before submission of the DCO. This is to be supported. It is recommended that local stakeholders are consulted - in the case of professional stakeholders, this should be both individually and collectively - during this process.

Given the factors outlined in the previous sections plus the complexity of this project, its ongoing development and refinement, an approach to mitigation which aims to address the issues individually and by topic is unlikely to be effective. The setting and scale of proposals are important, as the landscape is so varied across the study area. It is recommended that a mitigation strategy is needed for a project of this scale and complexity. This approach accords with the aims outlined in the NPSNN to mitigate environmental and social impacts, improve accessibility, support sustainable transport, reduce severance, retain and enhance landscape character and retain the openness of the landscape as required of its Green Belt status.

A Mitigation Strategy (which may extend beyond the scope of works associated with the road scheme) could:-

• take a strategic approach to the whole landscape to be affected and the wider impacts,

• be in place to take short, medium and long-term actions forward as necessary over the life of the scheme and beyond, and develop alongside the road design,

• address the severance of the protected landscape,

• address the loss of local amenity use to adjoining populations,

• address the severance and diversion of access routes, and the qualitative impacts on users (receptors)

• reconnect and enhance habitats, the setting of heritage features and enhance landscape character,

• maintain and enhance long views and local views; to include long views to and across the Thames and from the Kent Downs,

• make links with the biodiversity and cultural heritage topics affected by this proposal,

• examine the remaining open space, cultural, environmental and access assets, and propose new, coherent networks that will make a positive contribution to the Green Network

• Support the investment needed for infrastructure in the Green Network

• contribute to modal shift and promote sustainable transport in the area

• address the needs of cyclists and pedestrians

• have the potential to address local deficits of open space and recreational facilities identified in the Gravesham Open Space, Sport and Recreation Study

A good example of a similar - and local - initiative is the Cobham Ashenbank Management Scheme (CAMS). As a result of HS1 (then Channel Tunnel Rail Link) the Cobham Ashenbank Management Scheme was set up with an endowment from the developer of £750,0006

CAMS created a series of projects which delivered over £7m worth of work in the local and wider area because of the impact on the historic park.

Two separate initiatives, one either side of the River Thames, with shared aims and objectives, may prove more practical in terms of management.

Potential sources of funding (mitigation and) compensation initiative:

Potentially a strategic initiative could be included for funding through the (HE) Designated Funds Programme.

Under the HE’s Road Investment Strategy funds are being awarded to improve the surroundings of the Strategic Road Network in a way that ‘supports and protects people and the things we value for quality of life, both now and in the future’.

The Designated Funds Programme aims to deliver ‘environmental, social and economic benefits to the people, communities and businesses who live and work alongside our strategic road network’.

Gravesham BC’s CIL allocations as well as external bidding by Gravesham BC, Medway Council, Kent County Council and others may also be considered for inclusion where topic areas overlap; thus providing match-funding for the initiative. Conclusions The landscape assessment component of the PEIR appears to be informed by a number of sources of guidance, but not consistently, and the assessment appears to be neither a Simple nor a Detailed Assessment under the terms of the guidance.

Further information is needed to better inform all stages of the assessment before it is revised prior to DCO submission.

Cumulative effects are not mentioned.

6 1996 prices; equates to £1.4million at 2018 prices ref http://www.in2013dollars.com/1996-GBP-in- 2017?amount=750000

The assessment is confusing and not easy to read.

It is clear that many of the potential effects of this proposal are interconnected, and they should be considered together. This is due to the nature of this area - its protected landscape, its areas of sensitive landscape (some internationally recognised), its range of cultural heritage assets and historic landscape elements, the proximity of residential populations, the effects of the proposal on the access network - and the scale of the proposal.

The proposals are likely to result in significant changes to the landscape, with degraded quality of the landscape overall, at least in the short to medium-term. A mitigation strategy is vital to ensure that a comprehensive and cross-cutting approach is taken that will recognise the special qualities and character of the component areas, and deal with the difficult issue of phasing works and limiting the landscape and visual effects throughout the process.

The selection of the LTC route has serious implications for the KDAONB. The effects on views which are part of the cultural heritage, the severance of the northern part of the AONB, and the erosion of landscape and visual quality of the AONB as a result of the proposed scheme along the A2 transport corridor, which change the nature of the landscape to a hard-edged and urban environment, out of scale with the existing landscape and stripped of screening vegetation.

The choice of route also means that a new and alien piece of transport infrastructure is to be introduced into a protected landscape and its setting.

The effects of noise are dealt with in another topic of the PEIR. However, the effects of noise on the area should be considered alongside visual and landscape impacts as they are so closely connected, and noise can exacerbate other issues.

Appendix A: Issues raised previously

Table1.0 PINS Scoping Report issues

Issues raised in PINS Scoping Report re Landscape Assessment component of the EIA Scoping Report 1. References to DMRB and IAN 135/10 need to be checked for consistency with the NPSNN, NPPF and the 2017 Environmental Regulations - all of which take precedence. The Highways Agency is guided by The National Policy Statement for National Networks (NPSNN) as well as other key legislative/policy requirements.

The NPSNN sets out Government’s policies to deliver development of nationally significant infrastructure projects (NSIPs) on the national road.

The Client has advised that ‘Analysis on all topics should start from the basis of the NPSNN requirements not from any other guidance’. (quote from GBC’s response to scoping report Dec 2017)

The NPSNN refers to some of the nationally recognised best practice guidance in the ‘Guidelines for Landscape and Visual Impact Assessment, 3rd Edition, April 2013 (GLVIA)’ The PEIR states the intention to consider the GLVIA in its assessment. However, the methodology appears to diverge from this guidance in places, and considers other documents, including the Design Manual for Roads and Bridges (DMRB) and Interim Advice Note (IAN) 135/10 which may be out of date in respect of landscape and visual impact assessment, as it pre-dates the latest (Third edition) GLVIA.

Recommended: NPSNN 2014 and GLVIA (Third edition) 2013 are the most relevant and up to date guidance documents. However, DMRB Vol 10 provides very detailed guidance on environmental design in relation to new roads, and in this respect should be read alongside the NPSNN and GLVIA.

2. The Zone of Visual Impact (ZVI) should extend as far as is necessary and not be subject to an arbitrary 2km limit. It needs to take into account the height of structures (bridges, gantries etc.). This will need to be agreed with the Borough Council. 3. Study area for visual amenity: How is the 2km ZVI justified? It needs to be adequate to establish the likely impacts of the proposal. The ZVI should be agreed with consultees. Visibility is a significant issue - of both the works and the completed scheme. The study area includes protected landscapes, historic landscapes and associated views, and the flatter landscape of the Green Belt land affords long and distant views. The ZVI should extend as far as is necessary and not be subject to an arbitrary 2km limit. It needs to consider the height of structures (bridges, gantries etc.), and views to and from the (works on the) northern side of the River Thames. The GLVIA recommends that a Zone of Theoretical Influence (ZTV) should also be identified and updated as the scheme is refined.

The PEIR states that the 2km ZVI is “the extent to which potential significant landscape and visual effects are likely to occur”. And “to verify this, a ZTV has also been prepared for a wider 5km study area”.

Recommended: The 2km ZVI and 5km ZTV proposed in the PEIR are acceptable at this stage but should be kept under review as the project develops, and more information on the visibility of the scheme and its elements is made available. This will need to be agreed with the Borough Council.

4. Receptors: Thorough consideration of the views to and from the KDAONB See above 5. Assessment periods: the estimated construction duration should be clear and accurate. Seven years is stated in the PEIR documents. 6. Description of effects: The terms short-term, medium-term and long-term should be defined and consistent. Cannot verify in the PEIR 7. Mitigation (operational phase): Explanation is required as to how mitigation is to be secured, and the means by which land management in the operational phase is to be secured (i.e. retained within the highways estate or returned to management by other landowners). This appears to remain an issue. See above

Table 2.0 Gravesham BC Scoping Report issues

Gravesham BC issues raised on the landscape assessment component of the EIA Scoping Report 1. The 2016 consultation failed to properly consider Green Belt as a significant policy constraint

All land in the study are (south of the Thames) is either within the KDAONB or Metropolitan Green Belt. Green Belt needs to be considered for its role as a permanent and open landscape. The PEIR references Green Belt and its inclusion in Section 9 of the NPPF. Paragraph 79 of the NPPF states “the essential characteristics of Green Belts are their openness and their permanence.” The PEIR also lists the reference to paragraph 5.164 of the NPSNN which recognises Green Belts and states the “fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open”.

However, the PEIR7 notes that Green Belt is considered in the landscape assessment chapter in terms of its role as a planning designation and importance at the national level (i.e. not in terms of its permanence and open landscape)

The PEIR does not include a reference to Gravesham BC’s Local Plan Strategic Objective SO8 which aims to preserve the openness of the Green Belt, maintain its national and local planning purposes and protect it from inappropriate development. Policies to deliver the objective include CS02 which relates to the scale and distribution of development. It includes reference to development being compatible with national policies for protecting the Green Belt.

2. There is a lack of clarity in the scheme description of what is being proposed along the A2 corridor within the North Downs AONB, or the layout of the A2 junction which affects the setting of the AONB. The works are described, but there is a lack of visual material to support the description, and at all stages of the project development (see above) 3. As a result of the revised proposals there is likely to be a significant impact from the removal of existing vegetation with consequential impacts on the AONB.

4. This corridor contains substantial landscaping from the construction of HS1 and the widening of the A2 to 4 lanes, along with the separation of the existing carriageways. Potentially, on the basis of the red line boundary, there could be severe disruption during construction and considerable damage to existing landscaping and planting.

5. A worst case would be a hard-built form corridor of road and rail combined which is of much greater width (and therefore impact) than at present. It will be necessary to consider the combined impact of both the widened A2 and HS1.

6. The possible need to reconstruct of modify existing bridge structures over the A2 could have significant further impacts.

7. There is potential for significant reduction in tranquillity as a result of both construction and the final scheme.

The issue of vegetation removal, and notably the removal of screening vegetation for HS1 is not adequately dealt with in the assessment and is included in the appraisal of the assessment methodology (above).

It appears that the A2 transport corridor is to be intensified in terms of hard-built roads and removal of soft landscaping. This is also dealt with in the response – see above. The PEIR states that tranquillity is to be dealt with at a later stage and is discussed in the response to the assessment – above.

8. The scheme from the tunnel portal to the A2 has implications for the setting of the AONB as well as the open landscape east of Gravesend and views from the North Kent Marshes and possibly from Thurrock. The response to the assessment includes these issues – see above. 9. The cutting leading up to Thong Lane could be a white scar if it has steep sides with no seeding. Seeding is proposed in some areas, but this is likely to remain an issue during the construction phase.

7 PEIR Volume One Chapter 8 section 8.3.12

More detail is needed as the design develops. 10. Views of residents in Riverview Park, along Thong Lane and in the village of Thong could be significantly impacted upon. Mitigation is proposed in the PEIR, including the use of hoardings, but there will be significant negative effects. 11. At Chalk as well as visual intrusion the scale of any buildings at the tunnel portal (including any ventilation stack) could be significant in the flatter landscape. This is not clear from the visualisations, partly due to the large scale of the views, and partly because no visualisations are provided showing tunnel cranes, buildings in the construction compound or ventilation shafts. 12. It is unclear if the scheme has any implications for Three Crutches/Strood residents. The viewpoints do not extend further east than Park Pale. 13. The noise (chapter) part of the analysis deals with impact on receptors, but it is important to note that the impact of the scheme on tranquillity in such places as Jeskyns, Cobham Park and Shorne Country Park is also relevant. The PEIR states that tranquillity studies will be carried out. 14. In some areas the geographical scope needs to be expanded. It is a subject area where the impacts appear to be major/highly significant. Recommended: The ZVI and ZTV should be kept under review as the proposals develop. 15. Reference is made to local development plans and policies, but these do not seem to be referenced anywhere in the Scoping Report. The Local Plan and its policies are referenced, but the list is incomplete (see also Comments on Methodology above) 16. It is assumed that the analysis will start from the assumption that the whole route is lit (the A2 is already). This is assumed. Recommended: Visualisations need to provide more realistic night-time views, without screening landscaping where it has been removed as part of the works. 17. The area south of the A2 needs to be subject to as much analysis as the north. This is in addition to the PROW network and local routes like the Darnley Trail. Recommended: Further visual analysis is carried out along the A2 transport corridor and south of the A2 in the KDAONB. 18. Reference is made to the setting of AONB north of the A2 but this also applies to the south at Jeskyns (Forestry Commission) which straddles the AONB boundary. The PEIR refers to the sites within the KDAONB both to the immediate south and north of the A2. All sites in the KDAONB located near to the A2 are likely to suffer some landscape and visual effects as a result of the proposal in the short, medium and long-term. 19. Potential landscape impacts are a product of the current route choice and design parameters. Both these elements will need to be reviewed. In particular reducing the design speed of the crossing to 50 mph would have major benefits in mitigating the impact on landscape and other features. At this stage, not enough is known about the detailed design proposals or the noise effects of the proposal. For example, the shape of the land profiling in cuttings along the route could have a significant effect on noise, but also on the landscape effects and the usability of the surrounding land. Recommended: Consideration to be given to a comparison of noise effects for different design speeds of the road. 20. Although mitigation is mentioned as should be the first resort, compensation should also be considered. See section on Mitigation above. 21. The promoter should be required to commission a 3D computer generated landscape model of the project to evaluate landscape impacts and the effectiveness of mitigation over time. Fly-through? Doesn’t provide an accurate representation of the likely viewpoints of people on the

ground. Better 3D modelling is required to help a wider audience visualise the proposals. Table 3.0 Standard Questions raised by the Client (Gravesham BC)

Standard Questions to be answered

1. Whether issues previously raised have been addressed PEIR Volume 1 requires the EIA to reflect PINS Scoping Opinion. See Table 1.0 above for detailed response 2. Is the methodology appropriate to the topic area?

The EIA Regulations define the PEIR as information which ‘is reasonably required for the consultation bodies to develop an informed view of the likely significant environmental effects of the development (and of any associated development)’

In addition, the EIA Regulations state that A good PEI document is one that enables consultees (both specialist and non-specialist) to understand the likely environmental effects of the Proposed Development and helps to inform their consultation responses on the Proposed Development during the pre-application stage. The level of detail and type of PEI may vary according to when in the design process the consultation is carried out, the target audience and the complexity of the Proposed Development and the receiving environment.

HE guidance for LVIAs is set out in the NPSNN which in turn refers to the GLVIA (Third edition) The PEIR uses guidance from the NPSNN and the IAN 135/10 and DMRB (see also Table 1.0 above)

The methodology is confusing due to referencing a number of guidance sources, but the approach is considered appropriate.

The question is whether the approach taken to landscape assessment may be easily understood by non-specialists. At present that answer is probably no. There is no appropriate 3D modelling that illustrates the landscape and views in relation to the scheme in its construction phase and when complete.

3. Has that methodology been correctly applied?

It appears that Chapter 8 of the PEIR may have followed guidance in DMRB Volume 11, in setting out the principles of assessment. The guidance states that assessment levels are dependent on the potential environmental effects, the stage of project planning and the next project decision. The assessment levels stated are Scoping Assessment, Simple Assessment, and Detailed Assessment. The assessment in Chapter 8 appears to be a hybrid of a Simple and a Detailed Assessment. Further work is therefore needed to develop a Detailed Assessment for the Environmental Statement.

Regarding the KDAONB, the methodology makes clear (NPSNN Sections 5.150-5.152) the importance of conserving scenic beauty in AONBs. It goes on to state that permission for development may only be granted in exceptional circumstances and states a strong presumption against road widening or building in AONBs. The guidance (NPSNN Sections 5.170-5.171) states the presumption against development in the Green Belt.

The guidance also addresses developments outside nationally designated areas (in this case the

KDAONB) which might affect them.

The PEIR establishes that the area of the proposal within Kent and outside the AONB is the setting for the AONB. In this regard, it could be argued that the elements of the proposal outside the KDAONB could have an effect on it and should therefore be taken into account when considering effects on the AONB.

Guidance from IAN 135/10 is also used in the assessment. It is confusing.

A potential weakness in the process for this large-scale and complex scheme is the consultation process thus far, which has taken place with stakeholders on an individual or group basis; with the potential for responses to be made by topic, organisation or area basis. The large-scale nature of this proposal requires a similarly large-scale and strategic response; one which includes the breadth of topics and full extent of the scheme area (see also Mitigation section above).

4. Has the significance of the impact(s) been assessed and is the result reasonable? Significance of landscape and visual receptors has been assessed and the magnitude (i.e. nature of effect). This is based on currently available information and is considered to be incomplete. See above.

5. Is there a clear link between analysis and the emerging design?

It is unclear. The route and design come first at this stage, and the assessment appears to be retro- fitting mitigation proposals.

6. What further work needs to be done?

The PEIR states the following work is needed:-

Chapter 8 of the PEIR Volume 1 (Section 8.5) recognises the need to assess townscape effects on built form in Thong Village. And Chapter 7 (Cultural Heritage) confirms that… a landscape design proposal will take account of the setting of Thong Village…

Further visual analysis will also take place over the next few months. Surveys will also be carried out to identify existing areas of tranquillity.

An extended vertical analysis will be carried out. This should help to visualise the effect of some of the vertical elements of the proposal and may reveal additional visual receptors to add to the LVIA.

Further receptor viewpoints will also be discussed with the KDAONB and Gravesham BC.

It is further recommended that:-

A full detailed LVIA is required for the ES.

Further information on the proposal is also required, and at all stages of the development.

The ZVI/ZTV should be re-examined as the proposal develops.

Local stakeholders (including land managers) should be involved in in the collecting of further data, in particular the work to identify areas of tranquillity, and the identification of further visual

16 receptors.

7. Appropriate mitigation and/or compensation See above

Appendix X: Issues to be considered in assessing the value of landscapes Landscape condition and/or quality. This should be available in NCAs or LCAs but is currently missing from the information base.

Cultural heritage interests. These are listed in the LCA summaries but not fully addressed, and need to be cross-referenced with the Cultural Heritage chapter and response.

Perceptual qualities, such as the tranquillity of the western area of Shorne Woods Country Park amongst other sites in the KDAONB in this area (it is suggested that this be included in any further studies).

Associations, such as the link with Humphrey Repton at Cobham (landscape designer for the parkland around Cobham Hall). The landscape has been recently undergoing restoration including key views. NB the literary link with Charles Dickens and the Thames Marshes has been mentioned in the proposal report. Also, the relevance of the pattern of historic routeways that may be affected by the proposal.

Also, Rarity, Representativeness, Conservation interests and Recreational value, such as recognition of the publicly accessible - and jointly promoted - group of sites to the immediate north and south of the A2, including Shorne Woods CP, Jeskyn’s Woodland, Ashenbank Woods, Cobham Park and Ranscombe Country Park which welcome hundreds of thousands of visitors each year.

Specially promoted views, such as the view from Darnley Mausoleum, views from Shorne Woods Country Park, the view northwards from Jeskyn’s Park and views from Cobham Hall. Also the views from promoted access routes – such as the National Cycle Routes, Saxon Shore Way and Darnley Trail, and the Timeball and Telegraph Long Distance Walk, which links from Deal to Greenwich. NB Some views are included in the PEIR.

Prepared for Gravesham Borough Council by:

Val Hyland BA DipLA (Hons) CMLI, Director

V Hyland Associates Ltd

01233 812195 – 07740 185381

[email protected]

Registered in England, number 8953928 Registered Office: Silverthorn, Scotton Street, Wye, Kent TN25 5BZ

Annex 6b Kent Downs AoNB Unit Comments

LTC STATUTORY CONSULTATION OCTOBER 2018 KEY KENT DOWN AONB UNIT POINTS

 The NPSNN advises at paragraphs 5.151 to 5.155 that there is a strong presumption against any significant road widening or building of new roads in an AONB, unless it can be shown that there are compelling reasons for the new or enhanced capacity and any benefits must significantly outweigh the costs.

 The proposed scheme has been amended substantially since the previous consultation in 2016 to include a major widening of the M2/A2 corridor for a length of 2 km through the Kent Downs AONB south of the Shorne Woods Country Park which would result in a 14 lane wide highway through the AONB.

 In view of the fundamental presumption against road widening set out in the NPSNN and for the presumption against major developments within AONBs specified in the NPPF, a case for the need for these new works will need to be adequately addressed in the DCO application.

 The proposed changes to the scheme will result in significant increased adverse impacts to the Kent Downs AONB. Impacts would arise as a result of vegetation clearance including tree loss from the existing wide central reservation and from both sides of the highway and established mitigation for HS2, increasing the width of the highway from 8 to 14 lanes, engineering operations such as retaining walls, embankments, cuttings, provision of a new access to the haulage firm at Park Pale and the creation of balancing ponds.

 The proposals would also result in a greater physical and visual severance of the landscape to the north and south of the A2. Further impacts would arise as a result of noise both during construction and subsequently as a result of additional traffic using the route and due to additional lighting and signage.

 The widening of the A2 may also result in direct loss of ancient woodland along with habitat loss of the woodland and impacts to Shorne and Ashenbank Woods SSSIs.

 The proposal would also impact on the setting of the AONB, including as a result of the construction compound proposed just to the south of Thong, further removal of vegetation between HS1 and the A2 and a block of woodland immediately west of the AONB boundary, and as a result of the new highways infrastructure including junction connecting the crossing with the A2 being visible from the AONB, changing views from agricultural rural land to extensive highway infrastructure.  The impacts on the AONB are recognised in the PIER with a predicted impact of Major negative change on the landscape of the Kent Downs AONB both during construction and subsequent operation and Major to Moderate negative visual impacts.

 It is advised at 6.2.4 of the ‘Approach to Design, Construction and Operation’ Report that the design of the Project will be influenced by five overarching considerations, including environmental constraints such as the AONB designation and that impacts will be minimised and/or mitigated wherever practicable and that the scheme seeks to deliver a positive legacy for local communities and the environment.

 The scope for mitigation in the A2/M2 transport corridor is limited because of the restricted width of the highway boundary and constraints of the HS1 line to the south and woodland to the north which is designated Ancient Woodland and SSSI. However the AONB Unit is concerned that insufficient mitigation is proposed in view of the significant residual harm that would result to the AONB. Scope for mitigation further from the current highway boundary needs to be sought, including consideration of any off site works that would help mitigate visual effects. Opportunities for advance planting also need to be established at an early stage. Green bridges need to sufficiently wide to be of true landscape and wildlife benefit. We are also keen to ensure opportunities for improving linkages for non- motorised users between the existing green infrastructure in the locality are fully embraced. It is understood that mitigation needs to be included within the red line for the DCO application and it is therefore imperative that opportunities for mitigation are established at this stage.

 In view of the limited opportunities for mitigation to moderate harm to the AONB, substantial compensation should be made, commensurate with the significant level of permanent harm. This would be in compliance with the Kent Downs AONB Management Plan policy SD12 which states that ‘Transport and infrastructure schemes are expected to avoid the Kent Downs AONB as far as practicable. Essential developments will be expected to fit unobtrusively into the landscape, respect landscape character, be mitigated by sympathetic landscape and design measures and provide environmental compensation by benefits to natural beauty elsewhere in the AONB’.

 With regards to the design of the highway, the AONB Unit would expect flexibility in the highway design; full trunk road standards guidance should be relaxed to allow for a more sensitive design to respond to the protected landscape. Annex 6c CTRL and LTC cross sections in AoNB

Westbound Collector Eastbound Separation M2 M2 Separation Road Collector Road Zone Eastbound Westbound Zone Central Reserve

1 1 2 3 Boundary Boundary Fence Fence Hard Hard Hard 5.00 Verge Lane 1 Lane 2 Lane 1 Lane 2 Lane 3 Lane 4 Lane 4 Lane 3 Lane 2 Lane 1 Lane 2 Lane 1 Verge 5.00 5.00 Shoulder 3.65 3.65 Shoulder 3.65 3.70 3.70 3.65 3.65 3.70 3.70 3.65 Shoulder 3.65 3.65 2.50 3.30 3.30 3.30 Hardstrip Hardstrip Hardstrip Hardstrip Hardstrip 1.00 1.00 1.00 1.00 1.00 Annex 7a Noise & Vibration

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing – PEIR Mountfield Park

November 2018 Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

Document Control Sheet

Identification Client Gravesham Borough Council Document Title Noise & Vibration Peer Review – Lower Thames Crossing - PEIR Bureau Veritas Project No. 6481789/N&V/R1

Contact Details Company Name Bureau Veritas UK Limited Gravesham Borough Council Contact Name Ric Cope Tony Chadwick Position Technical Director (Acoustics & Vibration) Acting Planning Policy Manager Address 2nd Floor, Atlantic House Civic Centre Atlas Business Park Gravesend Simonsway, Wythenshawe Kent Manchester DA12 1AU M22 5PR Telephone 07974 576085 01474 337404 e-mail [email protected] [email protected] Websites www.bureauveritas.co.uk www.gravesham.gov.uk

Configuration Reason for Issue/Summary Version Date Author Status of Changes 2 22/11/2018 R Cope Updated following comments Final

Name Job Title Signature

Prepared By R Cope Technical Director

Approved By R Maggs Consulting Group Manager

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

Table of Contents

1 Introduction 2

2 Methodology 2

3 Peer Review Findings 3 3.1 Scoping 3 3.2 PEIR 5 3.2.1 Baseline 5 3.2.2 Construction Phase 5 3.2.3 Operational Phase 6

4 Conclusions and Recommendations 7

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

1 Introduction Bureau Veritas (BV) has been appointed by Gravesham Borough Council (the Council) to peer review the noise and vibration chapter of the Preliminary Environmental Information Report (PEIR) for the proposed Lower Thames Crossing (LTC) road scheme. Highways England (the Applicant) is seeking a Development Consent Order (DCO) for this major highways development, which is partially within the boundary of The Council. The current proposals for the LTC comprise a new road link (three lanes in each direction) connecting the A2 in Kent, east of Gravesend with the M25, south of junction 29. The proposed highway will pass under the Thames via two 16m diameter tunnels, with a length of approximately 4km. The aim of this new highway connection will be to reduce congestion at the existing Thames crossing (bridge and tunnel) at Dartford. Construction of the new highway, and all associated junctions and road improvements, is expected to take approximately seven years, with a provisional opening year of 2027. The primary purpose of this report is to ensure that the preliminary noise and vibration information submitted by the applicant, and subsequently the proposals for further detailed assessment, follows an appropriate methodology and makes reference to – and utilises as far as possible – the custom and practice guidance that is available locally and nationally for such an assessment of this scale and nature.

2 Methodology A number of methodologies can be applied to the peer review of noise and vibration assessments. In brief, the assessment, or proposals for such, should comply with:  the need to clearly set the defined existing conditions at the Site;  the extent to which the development is likely to impact on the environment; and  an assessment of the significance of such impacts as benchmarked against relevant and available criteria. The whole assessment should be made against prevailing planning policies set by Government, local and regional bodies. The following primary documents have been reviewed: . LTC Preliminary Environmental Information Report - Volume 1 (Chapter 13) . LTC Preliminary Environmental Information Report - Volume 3 (Figures 13.1 - 13.3) . LTC 13a Map book 1: General Arrangements . LTC 13b Map book 2: Land use plans The review has also included consideration of information provided by the applicant within the EIA Scoping Report (SR) (October 2017) submitted by the Applicant, and the subsequent scoping response issued by the Council (01 December 2017), and the Scoping Opinion issued by the Planning Inspectorate (PINS) (December 2017). Primary Regulations, standards and best practice guidance referred to in this review include: . The National Policy Statement for National Networks (December 2014) [NPSNN] . The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 [EIA Regs]

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

. The Design Manual for Roads and Bridges, Volume 11 Environmental Assessment, Section 3 Environmental Assessment Techniques, Part 7 Noise and Vibration HD 213/11 –Rev 1 [DMRB] . Calculation of Road Traffic Noise 1988 [CRTN] . British Standard 5228-1:2009+A1:2014 ‘ Code of practice for noise and vibration control on construction and open sites – Part 1: Noise [BS5228-1] . British Standard 5228-2:2009+A1:2014 ‘ Code of practice for noise and vibration control on construction and open sites – Part 2: Vibration [BS5228-2] The noise and vibration assessment has thus been peer reviewed in order to inform the Council around issues that may constitute the need for:  any further clarification: namely those issues for which further detail would provide for additional transparency and/or a clearer understanding on such as assessment methods, assumptions, data, etc; or  an omission: those issues deemed within the peer review to be lacking within the preliminary assessment which, if not addressed within the subsequent Environmental Statement (ES), may prevent the planning authority from making an informed decision related to the impacts of the proposed development.

3 Peer Review Findings

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

12.4.6 - More long term baseline noise There have been no long term baseline noise measurement points required on the measurements along the western side of the route, western side of the route. based on the PEIR Vol 3 Figure 13.2. All measurements (16 no.) to date are daytime only (CRTN Shortened Measurement Procedure). PEIR Vol 1 Table 13.2 states that further noise surveys will be conducted during both daytime and night-time periods, including weekday/weekend periods. 12.6.3 - Current traffic associated with It is expected that traffic associated with Bluewater Bluewater Shopping Centre, and future Shopping Centre is included in the baseline and future traffic associated with London Resort (if scenario traffic forecasts. PIER Vol 1 para 2.24.4 built) identifies that future scenario traffic data for the detailed assessment noise modelling will include committed schemes only. It is expected that the traffic noise impact of London Resort (if built) or other significant planned projects would need to be assessed as part of the respective planning application for each scheme. 12.6.9 - Operational and construction noise As previously agreed by GBC, the proposed threshold levels triggers agreed by the Council values are considered reasonable and appropriate. 12.7 - Material transport by rail or water Although PIER Vol 1 Table 13.2 (page 418) states: should be considered to reduce road “Material transportation within the construction phase will transport. The use of a rail head connected use road, rail and water-based transportation systems to the North Kent Line in Kent should be where appropriate”, this contradicts the statement in considered. PIER Vol 1 para 2.18.30 which states that rail transport of excavated material has been deemed unsuitable. Further discussion on this issue is provided below (see Section 3.2.2e)

12.8.2 - Unpredictable vibration issues The SR para 12.7.18 states that potential vibration associated with chalk substrata. impacts will be assessed in accordance with BS5228-2, which is the correct standard. PEIR Vol 1 Table 13.15 states that predictive calculation in accordance with the above standard will be carried out once the Project specific construction information is known. No limit values are stated. BV consider that the prediction of groundborne vibration is extremely complex in terms of the number of variables. Whilst prediction following the standard algorithms in BS5228-2 should be carried out, the measures incorporated in the CoCP will be more critical to the control and management of vibration during piling and tunnelling works. Given the susceptibility of chalk substrata to lead to vibration issues, the CoCP should include provisions for trial vibration monitoring during the early stages of works, and an appropriate complaints response process. 12.9 - Mitigation to include low noise PEIR Vol 1 Table 13.16 defines the noise mitigation surfacing, noise barriers and pumping measures that will be considered for the operational equipment or ventilation equipment. phase, which satisfies the request.

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

3.2 PEIR 3.2.1 Baseline a) As stated in Table 1, additional baseline noise surveys will be conducted to inform the ES. This should include long-term unattended measurements (minimum 4 days) to allow for the variation in local meteorological conditions. It is understood that no additional consultation has been held with GBC Environmental Health department to agree monitoring locations and durations. It is expected that additional monitoring will include locations west of the proposed highway, at residential areas at Singlewell, Riverview Park and Chalk. b) Long-term surveys are required to understand both the road noise levels and the diurnal pattern. Further related comment is provided in Section 3.2.3b below. 3.2.2 Construction Phase Construction Noise Assessment a) PEIR Vol 1 para 13.3.16 states that only preliminary construction information is currently available, and therefore the assessment presented in PEIR Vol 1 Table 13.15 is of a qualitative nature. A detailed assessment, using noise prediction modelling will be undertaken once further information becomes available. This assessment should consider potential intra-project effects associated with various construction sites that may be active at the same time, including construction compounds. b) PIER Table 13.15 discusses “the potential for temporary changes in noise levels around areas identified for the potential jetty”. It is not clear from the information provided whether there is an option for a jetty on the south bank of the Thames Estuary, and this looks more feasible on the north bank, given the physical barriers that are the North Kent Railway and Thames Medway Canal. c) PIER Vol 1 para 2.18.15 identifies that a concrete batching plant (continuous operation) may be required at one or both of the tunnel portal construction compounds. As identified in PEIR Vol 1 Table 13.15, noise from this operation as well as that of a tunnel segment production facility will result in noise impacts over an extended duration. Likewise, if slurry Tunnel Boring Machines (TBMs) are required, operation of the slurry treatment plant would be continuous. PEIR Vol 1 Plate 2.6 indicates that the tunnelling phase will provisionally be from Q3 2021 to Q4 2026, albeit that it is expected that tunnel boring and lining would only take place for a portion of this period (not defined in the PEIR). Given the number and proximity of residential receptors south of the River Thames, impacts are likely to be less significant if these operations were to occur within the north tunnel portal compound. Vibration Assessment d) This issue is discussed in Table 1 above. The assessment of potential impacts from tunnel boring operations should consider both vibration and ground borne noise. There have been a number of research papers1,2 produced on the potential noise and vibration effects of tunnelling which should be considered. Temporary Road Noise Assessment e) PEIR Vol 1 Table 13.15 identifies potential noise impacts associated with temporary construction traffic required for deliveries and to transport excavated material off site. It is understood that the final solution for the transport of excavated material is still to be decided, although it must be expected that some road transport will be required. It is recommended that the assessment presented in the ES should consider a worst-case scenario (in accordance with the Rochdale Envelope principle approach as stated at PEIR Vol 1 para 2.1.16), as well as

1 Anderson, D. and Hiller, D. Noise and vibration issues in tunnels. 2 Hiller, D. and Hope, V. Groundborne vibration generated by mechanised construction activities, Proc. Institution of civil engineers, Geotechnical Engineering, 1998.

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

the likely scenario (mix of road and river), so that an informed decision can be made at the DCO Examination stage. 3.2.3 Operational Phase Permanent Road Noise Assessment a) Whilst it is understood that a full assessment will be presented in the ES in accordance with the Detailed Assessment methodology defined within DMRB, no preliminary indication of the potential road noise impacts at night is presented within the PEIR. Furthermore there was no consideration of night time noise effects presented in the SR, which is a requirement of DMRB para 7.7. b) Understanding the diurnal pattern of the future traffic flow will be critical to the assessment of night-time noise impacts. Due to the significant volume of HGV traffic likely to use the new highway at night to connect to and from Dover port, it is unlikely that TRL3 Method 3 would be appropriate. The assessment of future scenario road noise at night should be assessed using Method 1, which relies on hourly traffic data. The method to be adopted is not stated in the PEIR. c) PEIR Vol 3 Figure 13.3 shows the operational noise effects within the DMRB study area (600m from the carriageway edge). However, it appears that the presented boundary lines, and therefore the receptors they cover, are not consistent. For example, Sheet 3 of this figure presents the preliminary ‘Potential Short Term Operational Road Traffic Noise Impacts’ along the proposed highway to the east of Gravesend. Where the route bends, the boundary line does not remain parallel, so that the actual area of impact identified is much less (approximately 470m) than the 600m required. This results in a misleading representation of the scale of the adverse noise impact, which should include many more properties in Chalk. d) No reference is made to tunnel portal reflection effects in the PEIR. However, as there are no receptors within 100m of the proposed tunnel portal, the reflection effects would not be perceptible and therefore a detailed analysis of such effects is not required (DMRB para 4.8). Permanent Road Vibration Assessment e) In the SR, the Applicant sought to scope out further assessment of operational vibration effects, however it is noted that the PINS (Scoping Opinion Section 4.7 ID 1) rejected this approach, requesting that operational ground borne vibration be assessed within the ES. The report referenced within PEIR Vol 1 para 13.3.23 describes measurements of vibration propagation from cut and cover tunnels and not tunnels bored through the bedrock, which may have a solid connection (higher vibration transmissibility) to building foundations. It is acknowledged however that vibration generated by a new operational road, both at surface level and within tunnels, is unlikely to generate significant ground vibration, due to the lack of discontinuities in the road surface. Therefore, due to the low probability of adverse effects, further detailed prediction and assessment of vibration from road traffic in the operational phase is not considered to be necessary.

3 Abbott, P.G. and Nelson, P.M. (2002). Converting the UK traffic noise index LA10,18h to EU noise indices for noise mapping. Transport Research Laboratory, Crowthorne

Gravesham Borough Council Noise & Vibration Peer Review Lower Thames Crossing - PEIR

4 Conclusions and Recommendations Based on the information presented within the PEIR, Bureau Veritas are led to conclude that, whilst it would have been useful to have been provided with an initial indication of night time road noise impacts at this stage, the approach if followed to the full DMRB methodology will provide a robust assessment within the ES. Additional baseline noise monitoring is required to determine existing road noise levels at receptors, and to derive the diurnal pattern for road traffic noise along the strategic road network, which should align with the forecast hourly traffic data. Additional monitoring should include locations west of the proposed highway, at residential areas at Singlewell, Riverview Park and Chalk. The assessment information available within the PEIR limits the extent to which actual impacts can be appraised. However, key decisions regarding the construction phase will clearly significantly influence the degree of adverse impacts, notably the material excavation strategy and tunnel drive (enabling plant) location.

Annex 7b

Noise maps from PEIR