5 March 2012
FRIENDS OF THE EARTH RESPONSE TO TFL’S ‘INITIAL’ CONSULTATION ON PROPOSED RIVER CROSSINGS FOR VEHICLES IN EAST LONDON
We consider this consultation process to have been very unsatisfactory in a number of ways.
1. this consultation presents 2 crossings for vehicles without any alternatives and without having shown that these are the best means to tackle identified problems. The Government’s criteria include:
"Criterion 1 When to consult
Formal consultation should take place at a stage when there is scope to influence the policy outcome.”
2. duration - the consultation is only 4 weeks, while the Government’s criteria includes:
"Criterion 2- Duration of consultation exercises
Consultations should normally last for at least 12 weeks with consideration given to longer timescales where feasible and sensible. ”
3. there is a failure to provide proper and balanced information.
The press release refers to ‘initial studies have found’ and refers to positive sounding things about the claimed benefits of the crossings, but the studies are not included or available. I have asked for those studies and any other back ground material, but nothing has been provided. This is completely unacceptable - all material available should be provided, and to not qualify and give a fuller picture of the findings when not providing the studies is even worse.
The press release contains information not available on the consultation page such as the figure for 6k vehicles per hour, but many respondents will not have seen the press release.
Various claims are made, particularly about easing of congestion and about regeneration benefits, without being substantiated. Indeed there is substantial evidence that these crossing might not achieve these results, and indeed that they could worsen conditions in some respects. For instance the results of a year long public inquiry into the Thames Gateway road bridge (TGB) showed that this was ”likely to cause increased congestion”. There is a reference to “we would carefully manage the traffic and air quality impacts”, but the implications of this are not set out, such as that this could involve tolling or some wider road user charging.
The Government’s consultation criteria also include the following - that ‘costs’ should be included as well as ‘benefits’:
"Criterion 3- Clarity of scope and impact
Consultation documents should be clear about the consultation process, what is being proposed, the scope to influence and the expected costs and benefits of the proposals.”.
The impact on certain groups has not been established or communicated - yet some of these likely to be most adversely affected such as the poorest who tend to live near main roads and so be worst affected by traffic and pollution, are also least likely to respond without proper outreach by TfL.
4. question 5 (as below) in the online response questionaire is unacceptable - the most negative option available is that the new crossings ‘won’t make a difference’, but the spectrum is only on the positive ie there’s no option to respond that someone believes they would make things worse, or to manage that there would be implications they did not like eg some sort of road user charging
If you do experience problems, how far do you believe the proposed package will help to address these?It will make a big difference / It will make some difference / It won’t make a difference / Not applicable
If you do not think it will make a difference, what else could be done to improve river crossings?”
ISSUES WITH CLAIMS ABOUT RELIEVING PROBLEMS AT BLACKWALL
Blackwall Silvertown road tunnel:
The release and consultation document make various claims about the benefits to congestion and traffic flow etc.
It is completely accepted that new roads/more road capacity for vehicles generates new traffic. This is accepted by TfL, and was so with the TGB.
Professor Phil Goodwin’s article for LTT is attached which sets this out clearly.
The existing 4 lanes of traffic at Blackwall would become 8 (confirmed to me by Michele Dix), and all the traffic has to get to and from the tunnels using existing roads – traffic would just be expected to increase all around the area.
Congestion would be expected also to increase in the area, including becoming a problem where it is not at the moment, with bottlenecks maybe just being relocated. Queuing at Blackwall could return to close to existing levels, and even within a short time span - if people are prepared to queue now they would be expected to in future (this assumes there is potential unmet demand, which is likely).
This would not be good for business any more than for residents, including those in Bexley through which the A2 feeder road runs, and various cut-throughs exist.
The last time the Blackwall tunnel doubled in size, the traffic more than doubled in the peak period within a year - according to the empirical study done by John Elliott for the GLC in 1985 referred to in Phil Goodwin’s article (I can supply the relevant information).
A July 2003 report for the ODPM (“Relationship between Transport and Development in the Thames Gateway” by consultants Llewelyn Davies and Steer Davies Gleave, with Roger Tym & Partners and Atkins) found that congestion on existing crossings east of Tower Bridge would be “not significantly alleviated by the additional capacity provided by the Thames Gateway Bridge and Silvertown Link”. Thus even with both these road crossings, it was considered there would be hardly any relief.
The above issues and evidence, known to TfL , should have been set out in the consultation. TfL say: ”we would carefully manage the traffic and air quality impacts”, but what this could mean was not set out, such that people considering the material were not made aware that this in itself could have negative impacts such as tolling or road user charging.
Even with tolling the TGB was not going to have the positive impact on existing crossing problems that many expected. TfL admitted that in the morning peak “the TGB is forecast to have little impact on the forecast flows on the other river crossings.” Indeed TfL went on to admit to “…flows through the (Blackwall) tunnel remaining more or less unchanged” (in the AM peak hour) (EIA Traffic and Transport Report 4.2.3). Even TfL’s expectation in its original case that there would be some less queuing at Blackwall with the TGB disappeared in the revised case. Yet businesses and the public had cited expected reduction of existing congestion as one of the key reasons they supported the TGB in response to market research and consultation.
If TfL believe traffic and congestion and pollution problems can be adequately managed, as is stated, these problems could also be managed now rather than trying to resolve them by increasing capacity. However the Mayor has not been prepared to take the necessary action to tackle traffic, congestion or pollution with measures such as a wider road user charging. Indeed he has taken some negative steps such as removed road traffic reduction targets from policy and weakened parking standards. Generating more traffic that had to be managed would just make this more difficult, when we are not on track to meet eg air pollution or climate change targets as it is.
The need for added resilience is cited by TfL, but just having another crossing which is also full is not providing resilience - some sort of management/road user charging in relation to the existing crossings would be a better way to provide resilience.
Gallion’s Reach vehicle ferry which could replace the Woolwich ferry:
It is completely unacceptable that there is no mention in either document (unless i missed it) that the ferry could be replaced with a ‘fixed link’ (ie probably meaning a bridge) later - despite being something that is already in the London Plan and MTS. Consultees are not being made aware that in showing support for a ferry that is something that could easily, maybe inevitably, lead to a version of the TGB, in turn resulting in much more traffic.
TfL do indicate that there would be queuing for the new ferry, but such queuing could itself lead to calls for a fixed link, especially as the south access road in particular is at the location of that for the TGB, with the north access only joining the existing road network at a different place. The Mayor has also weakened the criteria for building new roads in the London Plan.
The ferry could itself lead to traffic generation if a new one was in addition to the Woolwich ferry, but it would open the door to much more traffic generation from a fixed link.
TfL say a new ferry could carry more vehicles per boat than the existing Woolwich ferry, but so could new boats at the Woolwich ferry ie that is no reason for a new ferry.
Any apparent support shown in this consultation for either crossing for vehicles would not be anything of the kind and cannot be used to claim support for the proposals.
Instead better use can be made of existing crossings:
TfL is already making considerable improvements in reliability/resilience at Blackwall
Much more could be done to take vehicles that do not need to be on existing crossings off them, so making more space for those that do need to be there - that is increasing the proportion of road crossing trips that really do need to be by vehicle. This could be achieved by a variety of means including those listed below - essentially planning for reducing the need to travel, improving walking, cycling and public transport provision.
There is also much that could be done re freight consolidation.
ISSUES WITH CLAIMS ABOUT REGENERATION
TfL made big claims for regeneration for the TGB, however these did not stand up when properly scrutinised at the Public Inquiry, with the Inspector concluding they were uncertain and not justifying the admitted problems.
Roadbuilding would be expected to result in more spread out development and that such as warehousing and distribution uses which are low density and low employment uses (these were to be the main beneficiaries of the TGB), which would not be making the best use of important space in east London.
TfL cite the growth in jobs and population expected in east and south east London - but the London Plan makes clear that most of both of these is on north side of the river anyway.
Particular sites are referred to - Royal Docks on north and Greenwich Peninsula on south - but these face each other across the river. 4 new lanes of traffic are not needed to connect the north and south waterfront sites, indeed they would cause problems. Walk and cycle bridge(s) and/or walk and cycle ferry crossing(s) would be far more beneficial (the ferry could serve multiple destinations).
1. The proposals are a bad use of funds - they do not help everyone, they would only or primarily benefit vehicle users.
The case for the TGB showed that 94% benefits would be for vehicle users, when 2/3 and up to ¾ in the wards closest the the scheme did not have a car. The TGB case also showed that building it would mean less walking, cycling and public transport use and more accidents than if it were not built. And both of these points were despite the fact that 2 of the 6 lanes were to be reserved for public transport, plus there would have been separate walking and cycling provision.
2. The effects on health through air pollution
The recent GLA report sets out that over 4k people die prematurely in London every year due to long term exposure to particulate pollution, and it is not just a central or inner London problem - it affects all of London (CAL borough figures
Air pollution has also been shown to cause asthma not just trigger or exacerbate it, disproportionately affects some of our most vulnerable ie young and old, and some of our poorest who live near main roads where air pollution is worst.
The TGB would have taken one receptor over an EU limit when this would not have been the case without the scheme and so was unacceptable.
Both ends of the existing Blackwall tunnel are already considerably exceeding the NO2 annual legal limit:
Tower Hamlets – Blackwall, and Greenwich – Woolwich flyover
However this is not a localized problem in the immediate vicinity of Blackwall tunnel - the area around is also seriously exceeding on NO2:
- on the north side of the river:
Tower Hamlets - Mile End Road: http://www.londonair.org.uk/london/asp/publicstats.asp?region=0&site=TH2&la_id=&network=All&postcode=&MapType=Google&zoom=11&lat=51.53053285458183&lon=0.0157928466796875
- and on the south side of the river:
We are not on track to meet EU targets and Professor Frank Kelly of Kings College told the EAC that to bring air pollution within EU limits we needed to cut traffic in London by a considerable percentage. We need to cut traffic levels not add to them - the more that is added the harder it is to manage, and the Mayor is not taking the necessary steps to manage the existing problems.
The Mayor’s current Economic Development Strategy (EDS) Table 2 “Attractiveness of London to business” shows how London suffers from poor ratings under ‘freedom from pollution’ and ‘quality of life’. The economy needs London to be an attractive and healthy place to work and live and visit.page 35 of this http://www.lda.gov.uk/Documents/Economic_Development_Strategy_(2010)_6543.pdf
3. climate change emissions
More traffic also adds to climate changing emissions and we are not on track to meet even existing targets let alone stronger ones now needed, and so help to keep global temperatures within the required levels. Climate change is and will affect Londoners through heatwaves, drought, subsidence and flooding.
WHAT ARE THE ALTERNATIVES
There are several possible alternatives already on the table including DLR extensions:
a. a north-south extension following the line of the Blackwall Tunnel southern approach
b. an extension to Thamesmead from the Woolwich branch
This includes an extension to thamesmead:
'Passive provision for extending the DLR to Thamesmead was included as part of the City Airport extension, and this proposal would see that option exercised.
The extension would be to Thamesmead via a junction just south of the river protected for that purpose, which would remove the need for reversing via Woolwich. New stations would be built and served at West Thamesmead and Thamesmead.
Canning Town-Woolwich Arsenal services would form the core of the service, being diverted instead to Thamesmead. This would effectively half the services to Woolwich Arsenal.’
A report commissioned by TfL into alternatives to the TGB showed that there were several options that came out better than any vehicle based option.
A cable car came out top with a multi-destination ferry and a walk/cycle/public transport crossing also strong.
Local people objected to the TGB in their thousands, and there were objectors from all 3 main parties ( indeed many voted in various elections for candidates who opposed the TGB)
We need to help build east and south east London as a clean green place to work, visit and live.
Friends of the Earth’s press release when Boris Johnson scrapped the TGB:
This includes key quotes from the Inspector’s report from the 2005-06 public inquiry into the TGB which found that:
• regeneration benefits do not “substantially outweigh” “the disbenefits of the scheme in terms of increased traffic, reduced safety, increased air pollution, and a shift against walking, cycling and public transport in favour of the private car” (9.422)
• the “whole justification of the TGB is based not on reducing the need to travel, but on increasing it” (9.145), that it “would facilitate commuting by car” (9.146) and be “likely to cause increased congestion” (9.187)
• the scheme would “result in a negative contribution to the Government’s commitment to reducing greenhouse gases” (9.427)
• of air quality being made worse as a result of the TGB: “in an area in which air quality has historically been low, and where it is identified as a current problem, I do not regard that as acceptable” (9.416).
Briefing on the problems of the Thames Gateway road bridge
Friends of the Earth London Campaigner
26-28 Underwood Street
London N1 7JQ
020 7566 1633