Inadequacies of the actual consultation
We looked at the inadequacies of the consultation materials in our previous update. Obviously there is also the glaring obvious inadequacies of the actual consultation being held at this time. We thought it was bad enough during the Supplementary Consultation earlier in 2020 when HE carried on with the consultation despite the COVID-19 pandemic. Planned consultation events were cancelled, deposit locations and info points were closed. Yet still HE considered it acceptable to continue with the consultation, rather than waiting until it could be held adequately and safely.
We expressed our serious concerns over this, as did local MPs, local authorities etc, yet when it came down to the Design Consultation HE still didn’t take our concerns into account, instead starting this latest consultation amongst the COVID-19 crisis.
The consultation is what they call ‘digital first’ meaning the majority of the consultation is being held online. Not everyone has internet connection, computers etc. Many only use mobile phones to access the internet with limited screen viewing capacity, especially for viewing maps etc which are hard enough to work out on a full computer screen.
Those that order the physical consultation pack, it contains a consultation guide, a Land Use Map and a General Arrangement Map, and a response form and freepost envelope to return it in.
The references in the guide as to referring to the Map Books are of course not possible if you aren’t online as you would have to phone or email HE to request copies of the full Map Books to be sent, as the consultation pack doesn’t include the same Map Books as being referred to in the guide.
Both maps in the pack are on such a scale that it is very difficult to see the level of detail most people would need and want. You can see which maps are sent by clicking through on the links just above. But bear in mind that these maps cannot be zoomed into like the online version, and they are printed on what appears to be A3 size paper (so the size of two A4 sheets side by side). Not enough detail even with a magnifying glass!
Only one response form is sent, despite the fact everyone in a household is at liberty to respond. If you use the form online to order the consultation pack there is no option to request additional response forms, you would have to take it upon yourself to email or phone and request them.
They also state that only one consultation pack will be sent per household, which we questioned and as far as we are aware as yet nobody has actually been refused copies when they have ordered more than one per household. But the fact they state this is off putting and on face value limiting.
One of the sections in the offficial response form ask you about Environmental impacts. However, in the consultation guide, it refers you to the Environmental Impacts Update booklet for more info about environmental aspects, which is not sent as a matter of course as part of the consultation pack. The onus is again on the public to have to request a copy separately from the consultation guide.
The Environmental Impacts Update gives lots of references to the Preliminary Environmental Investigation Report (PEIR). The PEIR was a document published back in 2018 as part of the Statutory Consultation and is over 600 pages long plus appendices. Again not available to those who are not online.
We would also highlight the fact that the development boundary has changed considerably since 2018 alone, so how constant references can be made in the Environmental Impacts Update in 2020 that environmental impacts are negligible since the PEIR is certainly not adequate or acceptable in our opinion. Some areas weren’t even in or that near to the development boundary in 2018, so of course the impact would have changed now it is in or adjacent to the development boundary in 2020.
It is also greatly lacking and highly frustrating that we are being repeatedly told that much of the environmental impact aspects that we and others want to know so that we can respond in a meaningful consultation will not be available until the Environmental Statement is published at Development Consent Order (DCO) stage.
Whilst everyone will of course be impacted by LTC if it goes ahead, those who would be impacted most on health grounds are also the very same people who are currently most at risk from COVID-19. Those same people who will most likely also be limited the most in being able to take part in this consultation, because they will likely be shielding etc.
We have now heard from numerous residents whose property/land would be impacted by LTC and who only got a copy of the letter they should have received at the start of consultation from the LTC Land & Property team, because they have contacted HE/LTC and requested a copy. Not the first time we and residents have experienced inadequacies relating to letters about LTC.
There have also been letters sent to residents from the Land & Property team about potential impacts to their homes for various reasons and on various levels, which were sent two weeks prior to the consultation starting. The letters stated that their property/land would now be impacted, but provided no info on how or to what scale it would be impacted. These residents had to wait 2 weeks to receive a further letter. They were not sent a consultation pack as a matter of course, this had to be requested. The second letters they received provided very little additional info from the first letter, and in some cases it was a further week, so 3 weeks in total after receiving the first letter, before they were able to get some answers and proper details from HE on how their property would be impacted. Totally stressful and totally inadequate and unacceptable.
There have been issues with booked telephone callback appointments not being made. When calls were made to the ‘help’line number being told that they do not deal with callbacks for LTC!
The webinars left a lot to be desired. You can read more about that in our update.
There are of course no consultation events able to be held because of COVID-19. So no opportunity to be able to ask your questions face to face and be able to be shown maps and plans and discuss it in person. Even if you are able to get online, often that face to face interaction just can’t be replaced with phone calls etc because you need to be able to see and point at maps etc.
Local authorities opinions
All three impacted local authorities, Gravesham, Thurrock, and Havering have expressed their concerns over the inadequacies of the actual consultation.
They have all told us that they have expressed their concerns directly to Highways England.
If you wish to share your concerns with your local authority about any inadequacies relating to the consultation please use these contact details:
- In Thurrock please email: LTCAdmin@thurrock.gov.uk or write to: LTC Admin, Thurrock Council, Civic Offices, New Road, Grays, RM17 6SL
- In Gravesham please email: major.projects@gravesham.gov.uk or write to: Major Projects, Gravesham Borough Council Civic Centre, Windmill Street, Gravesend, Kent, DA12 1AU
- In Havering please email: daniel.douglas@havering.gov.uk or write to: Daniel Douglas, London Borough of Havering, Town Hall, Main Road, Romford, RM1 3BB
They will also be able to report to the Planning Inspectorate about any inadequacies at DCO stage, so it’s important that they know about as many of the inadequacies as possible ready for when they do so!
Have your say
Obviously we are all entitled to have our own say on the inadequacies of the actual consultation too! Please do use the section in the official response form (or in your own words in your response letter or email) to have your say on the actual consultation. Tell them about your concerns giving as much detail as possible about any and all issues you wish!