Civic Offices, New Road, Grays Essex RM17 6SL Application by Port of Tilbury London Limited for an Order Granting Development Consent for a Proposed Port Terminal at the Former Tilbury Power Station (‘Tilbury2’) Ref: TR030003 The Examining Authority’s First Written Questions and requests for information (FWQs) Issued on 27th February 2018 Thurrock Council (TC) response 1 Civic Offices, New Road, Grays Essex RM17 6SL 1.1 Air Quality FWQ Question to: Question: TC response: 1.1.3 Applicant, TC In TC’s relevant representation [RR- a) Ward level data for local health statistics is available on 031], TC asserts that respiratory disease the Public Health England web-site deaths, hospital admissions for Chronic (www.localhealth.org.uk). Relevant local health data Obstructive Pulmonary Disease (COPD) from this web-site for Thurrock Borough and the two and premature mortality from cancer are wards closest to the site (Tilbury St. Chads and Tilbury experienced more often than average in Riverside & Thurrock Park) is reproduced at Appendices Tilbury, and TC requests further 1.1.3. discussion on the mitigation measures – in particular the use of cleaner and greener vehicles. Supply of shore power should also be given priority: a) Would TC supply its evidence for its assertion regarding the health effects stated above? b) Would the Applicant state its response to TC’s points above? 1.2 Biodiversity, Ecology and Natural Environment 1.2.13 Applicant, TC Local Wildlife Sites Please explain how The last published Local Wildlife Site review (Thurrock many LoWS have been designated in Biodiversity Study 2007) identified a total of 70 Local Wildlife the Thurrock Council area. Sites (see Appendix 1.2.13). A new review of the Local Wildlife Sites was undertaken in 2016 with a draft report produced in 2017. There were some issues that needed to be addressed before the new sites can all be adopted. 1.2.14 TC Local Wildlife Sites Please advise The current citations and maps for the two existing Local whether the site plans and details of the Wildlife Sites are attached (Appendix 1.2.14a). These are LoWSs that would be directly impacted still showing on the Council system. However the Council is by the Proposed Development, provided not in a position to confirm whether the Tilbury Centre LWS 2 Civic Offices, New Road, Grays Essex RM17 6SL by the Applicant [APP-047] remain is still present due to the ongoing demolition works in the extant, or whether any boundary surrounding area. changes or grounds for designation have changed. If there have been changes, The draft citation for the proposed new Local Wildlife Site please provide up to date versions of the area is also attached (Appendix 1.2.14b). This has been relevant documents. shared with the Tilbury 2 ecologists previously and is shown in their reports. 1.4 Consideration of Alternatives 1.4.1 Applicant (parts a to In ES paragraph 6.36, the Applicant d) From a technical point of view it is not strictly necessary d); TC, Kent County explains that the CMAT facility is “more to co-locate such plants close to aggregates. However, Council and Essex easily located away from the jetty itself from an environmental point of view it is considered County Council as the process of moving aggregate from desirable to have the supply of aggregates near to (parts d, e only). self-discharging vessels by conveyor is mineral activities as this would reduce handling, vehicle not distance sensitive.” movements and the potential for dust during production a) In view of this, why is there not any of the products. It also would make measures to control consideration of alternative locations dust easier to implement as the potential dust producing for the CMAT within other areas of areas would be limited in extent. There are also the port or on nearby industrial land? sustainability benefits, notably reducing the need for b) Would all of the aggregates arriving double-handling, in locating processing facilities close to at the Tilbury2 facility be within self- the first importation point of the material, and at a river discharging ships? and rail-connected location. TC notes that Cemex c) What is the maximum distance that operates an existing cement plant at the Port of Tilbury self-discharged aggregate (from and Aggregate Industries operate a concrete plant at dredgers or ships) could be moved London Gateway Port. The location of processing by conveyor to reach an aggregate facilities at wharf, jetty or port locations would therefore processing plant, or stockpile appear to be common. locations? d) Is it essential to co-locate asphalt e) Hanson Cement, Purfleet Works, London Road, West plants, concrete plants and concrete Thurrock RM20 3NL: this site shares conveyors with block making facility close to the aggregate storage and a cement batching plant. source of aggregates? 3 Civic Offices, New Road, Grays Essex RM17 6SL e) Please could the host and Aggregate Industries, Purfleet Depot, Jurgens Road, neighbouring LPAs provide Purfleet RM19 1UA: road stone coating plant not co- examples of aggregate wharves located with wharf. Aggregates delivered by rail. (and/or railheads) which are co- located within their area, which host Kerneos Limited, Dolphin Way, Purfleet, RM19 1NZ: the types of secondary aggregate High alumina cement manufacturers. Not co-located processing facilities that are with any wharf railhead or any other direct source. All proposed in the CMAT, as well as materials delivered by road. any examples of the types of aggregate processing facilities that Tarmac Cement and Lime Limited Oliver Close West are proposed in the CMAT which are Thurrock, RM20 3EE: Bulk Terminal can take cement not co-located with any wharf and/or via rail head or jetty. railhead (or any other direct source of primary or recycled aggregate), Location plans for the above sites are attached as such as on industrial estates? Appendices 1.4.1e. 1.4.3 Applicant, TC Does the part of ES paragraph 6.38 The draft DCO (document ref. 3.1) submitted to accompany (quoted in FWQ 1.4.2) that states that it the application in October 2017 describes at Schedule 1 the is PoTLL’s investment objectives that are Nationally Significant Infrastructure Project (NSIP) as one of two key drivers for the location of comprising Work No. 1 that is the construction of a RoRo the CMAT on the ecologically important berth. The draft DCO (October 2017 submission) describes areas, confirm that it is questionable the remaining Works within Schedule 1 as Associated whether these aspects of the Proposed Development. Development should be considered to be ‘Associated Development’? However, at the Issue Specific Hearing on the draft DCO held on 21st February 2018 the Applicant stated that Work No.2 (the CMAT berth) was also considered part of the NSIP in addition to work No. 1. TC understands that the Applicant will submit a revised draft DCO at Deadline 1 which will define both Work Nos. 1 and 2 as the NSIP, with the remaining Works defined as Associated Development. 4 Civic Offices, New Road, Grays Essex RM17 6SL The definitions for NSIP Harbour Facilities is set out by Part 3 (24) of the Planning Act 2008 and TC notes that the proposals would accommodate more than one type of ship. Therefore, it may well be the case that Work No. 2 is indeed an NSIP as defined by the Act, rather than Associated Development. Paragraph 6.38 of the ES notes that there is more than one factor influencing the form of the proposed development. The answer to question ref. 1.4.1 (above) notes that there are potential environmental and sustainability benefits from the proposed location of the CMAT close to the source of the aggregates (i.e. the CMAT berth). This factor may add weight to the definition of the CMAT (Work No. 5) as Associated Development. 1.6 Contaminated Land and Waste 1.6.3 TC, Essex County Are the host and neighbouring waste No. The SWMP only considers the waste arising from the Council (ECC), Kent planning authorities satisfied with the demolition, excavation and construction phase and should County Council level of detail contained within the Site also include provision to consider the waste arising from the (KCC) Waste Management Plan? If not, why operational phase of the project. not? An estimate of the commercial waste arising from the canteen, offices and workshop has been provided. However, there is no calculation of the waste arising from the operation of the facility, including the batching and block-making facilities. Waste from this process are likely to include packaging wastes from the materials brought onto site, as well as reject materials from the process which will need to be recycled either on-site or elsewhere. The pro-forma used includes a table to “Specify Waste 5 Civic Offices, New Road, Grays Essex RM17 6SL Management Facilities” but the names of such facilities are only provided in generic terms. This means that it is not possible to assess whether the most sustainable options for managing the waste arising are to be used and whether these facilities are likely to have sufficient capacity to manage the arisings from the development. TC has provided the Applicant’s agent with a list of waste management facilities in the TC area, but this has not been used. For example, it is estimated that 53,200 tonnes of inert soils and stones and 56,177 tonnes of non-inert dredgings will be sent to an inert recycling facility. It is therefore important to understand the location of the facilities that will be used to recycle this material in order to understand the environmental impact.