Classification: Public Key Decision: No

Gravesham Borough Council

Report to: Cabinet

Date: 7 September 2020

Reporting officer: Director (Planning and Development)

Subject: Consultation

Purpose and summary of report: To appraise the Cabinet of the content of the current consultation being undertaken on the London Resort and highlight some of the issues that the project will need to address Recommendations: This report is for information only

1. Introduction

1.1 On 27 July 2020 London Resort launched a statutory consultation on its current proposals. The project is being taken forward by means of a Development Consent Order application (DCO) which is currently timetabled for November 2020.

1.2 In 2014/2015 London Resort went through a number of steps in the statutory process, however it has been agreed with the Planning Inspectorate (PINS) that these be repeated given the evolution of the project and the passage of time.

1.3 In July 2020, an Environmental Scoping report was submitted to PINS on which , and other Local Authorities and Statutory Agencies commented. Gravesham’s response was detailed, and a copy of the submitted report (approved by the Executive) with a detailed response at section 4 and associated appendices, are attached as Appendices 2 and 3 respectively.

1.4 PINS issued the scoping opinion on 29 July 2020, which sets out the areas the applicant needs to look at and provide information on. This does not mean that these will turn out to have significant effects (positive or negative) but that they need to be researched and evaluated.

1.5 The current consultation material consists of:  Section 47 & 48 Notices (statutory notices)  Guide to Consultation  Illustrative Master Plan - as seen before  Illustrative Parameter Plans – give an idea of scale and massing of the development  Land Plans – which show land to be acquired or used (below is GBC only)  Draft Development Consent Order  Draft Explanatory Memorandum – includes development description  Works Plans (geographical extent of the schedule in draft DCO – see below)  New Statement of Community Consultation (SoCC) and comments thereon  Preliminary Environmental Impact Assessment (PEIR) – chapters and non- technical summary

2. The current proposals

2.1 The current development description (see plans in Appendix 4) is for the construction of buildings and facilities for tourism and leisure uses including:  events spaces, themed rides, entertainment venues, theatres and cinemas;  ancillary retail, dining and entertainment facilities;  guest facilities;  two internal visitor entrance areas comprising ticketing point and ancillary commercial uses;  hard and soft landscaping including amenity water features such as ponds and canals; and  pedestrian and cycle access routes including the provision of pedestrian and cycle infrastructure.

2.2 The construction of up to three multi-storey parking buildings within the / Gravesham portion of the site as part of a maximum provision of 7,500 car spaces, 150 coach parking spaces, 350 motorcycle spaces and 250 secure cycle spaces for visitors.

2.3 The construction of up to three multi-storey parking buildings within the Thurrock portion of the site as part of a maximum provision of 2,500 car spaces and 55 coach parking spaces for visitors.

2.4 Highway works comprising works to the A2 to provide a junction connecting the A2 with the road leading to the proposed development;

2.5 Associated works related to the safeguarding and diversion of underground utility connections.

2.6 Associated development  four hotels with a total of up to 3,550 rooms providing family, upmarket, luxury and themed accommodation;  a covered market with ancillary uses including kitchens, storage, loading, servicing and laundry services;  a ‘conferention centre’ (a combined conference and convention centre) with a floor area of up to 11,000 m2 and eSports Arena with a total floorspace of up to 16,500 m2 including ancillary accommodation and loading bay;

2  an enclosed waterpark;  ‘Back of House’ buildings and facilities to support the proposed development’s operations including: (a) a security command and crisis centre; (b) maintenance facilities; (c) costuming facilities; (d) employee administration and welfare; (e) medical facilities; (f) offices; (g) storage facilities; (h) service roads and access roads connection to local network; (i) hard and soft landscaping including amenity features; and (j) up to 500 staff car spaces:  a visitor centre and staff training facilities building with associated staff parking;  a road leading from the A2(T) to the proposed development of up to four lanes (i.e. up to two lanes in each direction);  ecological mitigation and enhancement works;  a transport interchange area with coach driver facilities, pedestrian plaza, landscaping, pedestrian and cycle way, ‘people mover’ road, vehicle road, coach parking and a maximum provision of 250 car spaces;  services and infrastructure buildings including energy centre, district cooling plant, service yard, welfare facilities, substations, data centres, central backup generator, central gas boiler backup, water storage and treatment stations, grey water recycling, and waste transfer facilities;  a river boat terminal and floating pontoon on the south side of the River Thames;  works to the existing Riverside Terminal, and the creation of pedestrian routes and a floating pontoon and flood defence works on the north side of the River Thames;  the construction of a dedicated terminal building for visitors and staff arriving by rail at Ebbsfleet International Station, including retail and catering facilities;  the creation of a green zone to include areas of environmental enhancement and wildlife habitat creation adjacent to the River Thames including the creation of pedestrian and cycle routes;  the enhancement of flood defence works;  the construction of staff accommodation of up to 500 dwellings, including associated vehicle, cycle and pedestrian routes and landscape works;  roundabout upgrade works on the north side of the River Thames;  highway upgrade / capacity works on the north side of the River Thames;  works to an existing surface level car park;  works to Ebbsfleet International Station surface car park;

3  the construction of a multi-storey car park, including two alternative locations for such car park;  works and connections to the existing Southern Water Sewage Treatment Plant  works and connections related to the existing UKPN Ebbsfleet substation  works and connections related to the existing UKPN Northfleet East substation  further associated development within the Order limits including: (a) ancillary support and servicing facilities; (b) internal estate roads, maintenance accesses and footways; (c) bunds, embankments, swales, landscaping and boundary treatments, earthworks and earthwork retaining structures; (d) footways, cycle tracks, bridleways and footpath linkages; (e) water supply works, foul drainage provision, foul pumping stations, surface water management systems, balancing ponds (surface and underground), attenuation and culverting; (f) connections to mains services and provision of utilities infrastructure including secondary substations and gas pressure reducing stations; (g) diversion of high pressure gas main, other pipelines and services; (h) demolition of existing buildings and structures within the Order limits; (i) provision of security features to include security fencing, gatehouses, CCTV and ancillary measures; (j) public art; (k) signage including archways; (l) lighting; (m) general maintenance facilities; (n) enhancements to existing public transport infrastructure and services; (o) infrastructure to allow connection to existing electricity, gas and water/waste water networks, including relocation of apparatus of statutory undertakers’ equipment where required; (p) drainage works; (q) hard and soft landscape works throughout the development, incorporating earth shaping; (r) provision of ecological mitigation; (s) works to protect features of archaeological and paleontological interest; (t) ancillary emergency response facilities such as medical and fire points; and (u) such other works as may be necessary or expedient for the purpose of or in connection with the construction (including site compounds) or use of the authorised development and which are within the scope of the environmental impact assessment recorded in the environmental statement or which are unlikely to give rise to any materially new or materially different environmental effects from those assessed in the Environmental Statement. 4 2.7 In summary the resort consists of two Leisure cores (Gate 1 to be built first) around a central area with hotels, restaurants and retail space out on Peninsular, split between Dartford and Gravesham. There is extensive parking and a transport interchange. Access is from the A2 by means of a dedicated dual carriageway from the Ebbsfleet junction alongside HS1. Additional transport facilities and a bus link are provided from Ebbsfleet International (on what is now car park F).

2.8 There is pedestrian access from Swanscombe via Pilgrims Road. There will also be access from Manor Way (Swanscombe) for local buses and deliveries. Footpaths will be retained/diverted out on the Peninsular where there will be a jetty for ferry services to Central London and Tilbury (public access is possible through the resort).

2.9 At Tilbury it is proposed to provide additional car parking and enhanced ferry facilities. It would also be used to support the construction process and supplied to the resorts servicing needs.

3. Direct impacts

3.1 Whilst the majority of the ‘works’ are in Dartford BC’s area the following are proposed in Gravesham:  Botany Marsh (Britannia side) – for ecological mitigation  Botany Marsh (West side) part of Gate 1  Northfleet Rise west of A226 – Temporary possession and long-term rights as a possible location for a multi-storey car park  Part of car park C – temporary possession and long-term rights – but parameter plan shows 21m high structure of a multi-storey car park  Northfleet Waste Water Treatment works – temporary possession and long- term rights  A2 – for highway works

4. Benefits and opportunities

4.1 The proposal is an exciting one, promising significant job creation with thousands of direct and indirect jobs created for construction and operation of the London Resort with a combination of full-time, part-time and seasonal roles. They estimate that the Project will generate around 8,700 skilled or semi-skilled jobs directly on-site during peak times in 2025. This figure is expected to increase to over 17,000 jobs on-site by 2038.

4.2 These jobs will be allocated across the two theme parks, Water Park, dining, retail, hotels, and facilities including the Conferention centre and eSports centre, and includes full time, part time and seasonal roles.

4.3 The estimated breakdown in 2038 is below:  Approximately 6,500 full time jobs  Approximately 3,700 part time jobs  Approximately 7,100 seasonal jobs

5 4.4 There are expected to be a peak of up to 4,100 jobs supported on site during the construction period.

4.5 It would bring with it major economic benefits from the opportunities for local businesses to provide goods and services to the park itself and to visitors. It would a major boost to the development in the area as a major development of international significance.

4.6 In 2015, the Council was advised that LRCH would provide supply chain opportunities for a wide range of local, regional and national businesses including:  Waste management  Tech industries  Cleaning  Laundry  Security  Car hire  Florists

4.7 LRCH’s pay and employment strategy, and its comparison to the local offer, will impact on how attractive it is as an employer and the impact it has on existing local businesses staff retention issues. Inclusivity has been flagged by Members as an area that they think could be a positive for local residents.

5. Potential threats

5.1 Transport is the key area of concern. It is clear that LRCH recognise that this is a fundamental issue that needs addressing and they have included a range of proposals to try to mitigate any impacts. The proposal north of the river for the Park & Glide is a clear expression of this desire to look innovatively. However, as Members highlighted at the Member briefing on 12 August, what happens if those assumptions on traffic volumes modal shift are wrong?

5.2 Vehicle parking is another area of concern and how this is impacted by LRCH’s ticketing and parking strategy. Concerns include:

 Charging for car parking will drive people to: o park in and then use public transport to get to resort o park in local roads  If a CPZ is proposed: o Who pays? o How will this impact on local residents and businesses? For example websites like https://en.parkopedia.co.uk/parking/attraction/legoland- windsor-berkshire/ highlight parking options including sites such as supermarkets

5.3 Part of Gravesend’s USP is the river and the Gravesend-Tilbury ferry. The proposal includes:

6  Floating jetty and ferry terminal on the Peninsula, enabling use of the river both for construction, and for visitors and staff during operation - reducing traffic impacts on local roads and the wider road network

 A new Thames Clipper service from central London, providing a ferry service to the London Resort

5.4 GBC’s response to the LRCH’s scoping report, referred to at 1.3, included:

Currently the existing Gravesend to Tilbury Ferry provides the only non- motorised link on the river outside of London and it is essential that the ferry service improvements proposed do not mean that this essential and valued service is lost. Mention is made of additional including links to Tilbury, and combined with a service from central London are mentioned. Enhanced rather than replacement services are to be welcomed. Thames Clippers have run a trial service from Gravesend and a holistic approach to service provision is required. Allied with this is the future of the Tilbury Ferry as part of enhancing cross river public transport opportunities.

5.5 LRCH are proposing restaurants and other commercial uses outside of the payline which appears similar to Universal’s Citywalk in Orlando which is described as:  Entertainment - You'll find some of Orlando's hottest nightclubs featuring the best in live entertainment. There's live music every night at CityWalk™, from rock to jazz to reggae to salsa. Whether it's a special night out with friends, a romantic dinner, or a night of dancing, CityWalk™ is the place to be.  Dining – As for food — we've gotcha covered. Whether you want to grab a quick breakfast on the way to the theme parks, take in a light lunch, enjoy a full course dinner or kick back with friends over late-night drinks, you can choose from a wide range of restaurants offering everything from fine dining cuisine to all-American burgers and fries. o Bigfire joins the collection of unique and fun venues at CityWalk.  Shopping - One of the best things about Universal CityWalk® is that you can take a bit of it home with you. CityWalk® offers a variety of shops and boutiques where you can pick up a souvenir for the folks back home or buy yourself something that you've always wanted.

5.6 Depending on the nature of this offer it should negatively impact on local businesses. It is worth noting that the St Georges Phase 2 proposal includes a Civic Centre with a theatre and cinema as well as restaurants and entertainment.

5.7 Whilst the Council broadly welcomes the statement on page 33 of the consultation document that “We will ensure that there is a net gain in biodiversity by undertaking habitat remediation and creation and retaining existing ecologically important features and habitats where possible”, the site is complex and the caveat of “where possible” is a little concerning. Although not mentioned in the consultation document, a Marine Conservation Zone (MCZ) was designated on 31 May 2019 and that is in the area where the floating jetty and ferry terminal on the Peninsula are located. As part of the flood defence works, they are proposing to breach the old flood defences to allow a new area of salt marsh to develop along the river frontage.

5.8 Buglife have started a petition “to protect this wildlife haven from an unnecessary and ill-thought development, saving it for future generations to enjoy” with the strapline ‘The London Resort Theme Park would be No Fun for Nature’. They are recommending that the site should be designated as a Site of Special Scientific 7 Interest https://www.buglife.org.uk/campaigns/save-swanscombe-marshes/. The Council will need reassurance about LRCH’s proposals and Natural ’s views will be key.

5.9 Environmental impacts are another area of concern including:  Noise – construction and operational impacts  Air quality – construction and operational impacts  Water demand is a significant area of concern. The consultation recognises that North is considered water stressed with existing infrastructure in the area is likely to meet demand only up to 2035. Therefore, impact of water demand at the Kent Project Site and surrounding areas needs to be considered for the design life of the development. The PEIR says that demand will be about 9Ml per day and that they intend to re-commission a borehole for abstraction. To give some context, the water demand in 2006-07 in Gravesham was 24Ml per day.

5.10 Accommodation for staff and visitors is another area which could negatively impact on the borough. LRCH estimate that 14% of visits to the main Gate 1 in 2025 will be from those already staying on-site, increasing to 26% in 2029. In 2015, they estimated around 25% of overnight guests will stay at the resort with some uncertainty about where the other 75% of overnight guests were going to be located – with friends / family, or hotels in London / north Kent / wider Kent etc? We will need to understand the 2020 situation. In 2029, around 23% of visitors are expected to be from overseas. On page 45 it says “It will be a destination with a global profile, with up to 35% of visitors projected to come from overseas”. It is assumed that the difference is partly due to the opening of gate 2.

5.11 At the Member briefing on 12 August, LRCH were challenged about whether the project will happen as the project has been on the cards since 2012. MHCLG’s Tailored Review of Ebbsfleet Development Corporation, published in February 2018, concluded that the Government needs to review the implications of the London Resort proposal, particularly for the central area of the garden city. The EDC was advised that it should explore ways to mitigate the impacts, such that a realistic scheme for the central area can be brought forward within the next two years.

6. Conclusion

6.1 The Council continues to be actively involved with the proposal and, inherently, it does feel like the LRCH team are trying to be open and transparent about their proposal and the impacts that it will have. However, officers will maintain that ongoing dialogue with the LRCH team to ensure that any concerns this Council may have are addressed through the process.

6.2 There are naturally a number of matters that need to be explored further with the applicant to understand what the full implications are and what can be done to mitigate for the impacts. As a unique form of development the only comparators are international, so it is not easy to draw on other experience. It is also a 24 hours operation (although not open all that time the site will need extensive servicing) so there are, for example, traffic implications at off peak times which may interact with Bluewater.

6.3 Part of the problem is the degree of uncertainty. If the project is the success that LRCH thinks it will be, Gravesend could benefit significantly from the spin-off tourism jobs and footfall as well as the direct, indirect and catalytic jobs in the supply chain.

8 However if things become tighter, the proposal could be a negative force on Gravesend town centre and the local economy. Bluewater has always been a competitor to Gravesend town centre but when its scope was much narrower, it was less of an issue. Now that it is ‘scrabbling’ for occupiers, it is constantly trying to diversify its offer and will ‘steal’ anything unique and successful from neighbours, i.e. panic room-like offer.

7. BACKGROUND PAPERS

7.1 LRCH consultation material can be found at https://consultation.londonresort.info/surveys/50 and their web site at https://londonresort.info/

7.2 PINS web site at https://infrastructure.planninginspectorate.gov.uk/projects/south- east/the-london-resort/ and the Environmental Scoping Opinion at https://infrastructure.planninginspectorate.gov.uk/wp- content/ipc/uploads/projects/BC080001/BC080001-000300-LNRS%20- %20Scoping%20Opinion_COMBINED%20v2.pdf

Anyone wishing to inspect background papers should, in the first place, be directed to Committee & Electoral Services who will make the necessary arrangements.

9 IMPLICATIONS APPENDIX 1 Legal None

Finance and Value None for Money

Risk Assessment Engagement with the process will assist the applicant in making a robust application and assist in reducing the input to the process at the later stages

Data Protection A data protection impact assessment (DPIA) should be carried out at the start of Impact Assessment any major project involving the use of personal data or if you are making a significant change to an existing process. a. Does the project/change being recommended through this paper involve the processing of personal data or special category data or criminal offence data? No A definition of each type of data can be found on the Information Commissioner’s Office website via the above links. b. If yes to question a, have you completed and attached a DPIA including Data Protection Officer advice? N/A c. If no to question b, please seek advice from your nominated DPIA assessor or the Information Governance Team at gdpr@.gov.uk. N/A Equality Impact a. Does the decision being made or recommended through this paper have Assessment potential to cause adverse impact or discriminate against different groups in the community? If yes, please explain answer. No as it as about a consultation b. Does the decision being made or recommended through this paper make a positive contribution to promoting equality? If yes, please explain answer. No In submitting this report, the Chief Officer doing so is confirming that they have given due regard to the equality impacts of the decision being considered, as noted in the table above Corporate Plan #2 – Place (Enhance the vibrancy of Gravesham’s economy)

Climate Change As this relates to a consultation, there are no climate change implications, albeit the promoters are proposing a range of sustainability measures

Crime and Disorder As this relates to a consultation, there are no crime and disorder implications

Digital and website As this relates to a consultation, there are no digital / website implications implications

Safeguarding As this relates to a consultation, there are no safeguarding implications children and vulnerable adults