To: Transport for London River Crossings Consultation Team

From: Jenny BatesFriends of the Earth London Campaigner020 7566 163326-28 Underwood StreetLondon N1 7JQwww.foe.co.uk07884 003107@BatesJenny

February 2013

Re River Crossings consultationhttps://consultations.tfl.gov.uk/rivercrossings/consultation

I refer you to our response to the previous consultation of spring 2012:http://stopcityairportmasterplan.tumblr.com/post/19516615101/friends-of-the-earth-response-to-

tfls-initial

Professor Phil Goodwin's article on how new traffic is generated when there is new road space created was attached and now linked here: http://stopcityairportmasterplan.tumblr.com/post/19513243412/induced-traffic-again-and-again-and-again

I also refer to the submissions made by John Elliott and Michele Dix of TfL to the London Assembly Transport Committee on this issue following/prior to (respectively) their seminar on 9th Jan 2013 - number 7 and 9 respectively in the document linked here: http://www.london.gov.uk/sites/default/files/Written%20submissions.pdf

We strongly object to any new crossing for vehicles at Silvertown/Blackwall or Gallion's Reach.

PROCESS

The current consultation must be deemed invalid and a new process on possible new river crossings for east London started.

Current consultation process

This current consultation follows on fromthe one before it of spring 2012, which was based on needs and options considered in the TfL Planning and Corporate Panel paper “Update on east London river crossings review” of 8 July 2009 – item 6 of this:http://www.tfl.gov.uk/corporate/about-tfl/boardandchiefofficers/papers/8232.aspx

It seems clear TfL considered that the process (including requirements of identifying needs/problems, developing objectives, looking at a wide set of options before shortlisting etc) for deriving the package consulted on had been completed.In reality this process which resulted in this package being consulted on was far from adequate - including that there were no environmental aspects to the objectives, that the set of options under b) did not include any non road capacity increasing options, nor c) any Public Transport (PT) only new crossing options ie this was far from a proper long list, as we have said before – and perhaps TflL later accepted.

Also the schemes appear to have been progressed to develop and be developed by the Mayor's Transport Strategy (MTS) and London Plan (LP) in a chicken and egg sort of way – both feeding into the MTS and being assessed against it.

However the MTS development did not make up for the lack of proper consideration of alternatives - it's IIA of October 2009 shows only strategic options for alternative spatial patterns of development within London, and their transport outcomes, were looked at ie not eg strategic options related to alternative mode investment scenarios.

TfL developed the Strategic Assessment Framework (SAF) following the publication of the MTS to judge options against MTS policies, but this had not been used apparently in developing the proposals prior to the 2012 and current consultation.

We condemned the 2012 consultation for positive assertions on the supposed beneficial impacts, and again this consultation has assertions on how the schemes “would” “help the economy...to flourish” and “would” “also help to reduce delays and congestion...” when studies referred to have not been made available, and there is evidence TfL is well aware of that this could well not be so, or even that impacts could be the opposite.

TfL have not enabled people to comment wider on other ways to help address the problems or suggest other alternatives. The consultation materials in the 2012 consultation did not give this opportunity – the document only asked for comments and responses “on the proposed package” - only if someone went into the questionaire did Q6 ask what else could be done. Those wanting to comment wider could well have been put off bothering to get as far as the questionaire given comment was only being sought on the proposed package, according to the document.

This current consultation does not ask for or offer a way for wider/other alternatives to be put forward – Q9 asks only for “any further comments on the options we have described”.

Further issues:

The Mayor is understood to have said on 30th January 2013, ie before the current consultation has closed, that they were “going ahead with a tunnel at Silvertown, a Blackwall 2 Crossing” which could clearly put off people responding to the current consultation.http://stopcityairportmasterplan.tumblr.com/post/41939296156/press-release-boris-johnson-corrupted-the

The 2 Local Planning Authorities relevant for both schemes have launched an “all out” Bridge the Gap campaign to support the current proposals - encouraging supportive responses from residents,

when they have not got adequate information. Also this is unacceptable as they would have a role to play if things were progressed eg in producing a Local Impact Report.

As previously asserted in response to the previous 2012 consultation, any supposed support for these schemes cannot be taken as such for several reasons – yet such supposed support from the 2012 consultation has been cited in the current consultation. Because this unjustifiably gives the impression of support, it could have influenced the response of people to the current consultation. This in turn means that for this reason, as well as others including those above, any supposed support for the schemes from the current consultation cannot be taken as such.

New documents during the consultation

However, there has now been a new suite of 2 documents – both published after the start of the current consultation, as stated on the current consultation website.

The new needs document (dated October 2012) has a new set of needs/investment criteria, and the options paper (dated December 2012) a new set of local programme objectives (LPOs), a new long list of options including new options not previously considered (and not included in the current consultation), but moves on from the supposed (but still inadequate) long list to shortlisted schemes (an unlikely coincidence as these are in fact those which were already currently being consulted on), and even on to indicative packages and a preferred package (another unlikely coincidence as this is the preferred package already currently being consulted on) – and all without consultation.

The new needs assessment or investment criteria are combined with the LP objectives for the study area to produce new local programme objectives (LPOs) (Options paper 1.20) – but these are inadequate eg in only seeking “To minimise and adverse impact of any proposal on health, safety and the environment”.

These new LPOs in turn are part of the assessment of options, together with the SAF which was designed to assess options against MTS outcomes (Options paper 2.1). But the inadequate LPOs undermine and invalidate the joint assessment with the SAF. Further, the new needs/LPOs undermine any reliance on the LP or MTS for support ie the new documents reveal a new revised framework which includes new objectives developed since the MTS to be considered alongside it.

These new documents appear theoretically a better (though still inadequate) process to derive options and a package (compared to that which resulted in the currently consulted on schemes), but they re-start the clock. Despite the apparent linking of the needs document by Michele Dix in her letter to the London Assembly scrutiny (link above), they cannot relate to the package which was consulted on in 2012 and further currently now – except by apparent chance or co-incidence. The current consultation was already underway based on different needs and objectives etc. The new documents invalidate the current consultation – consultation would have to be based on the new material (needs, objectives etc).

New process still inadequate

The new supposedly wide range of options or long list is no such thing and is inadequate. It does not consider several options and ideas already put forward for consideration or other new ones, and does not consider any possible combination of measures not including new road capacity.

However, even with this new process to date people have not had a chance to input to influence things at an early enough stage (as well as issues mentioned here above)

Even now the options document refers to some modelling work, as does Michele Dix's letter to the London Assembly scrutiny, but nothing is provided to support their claims – all supporting material must be made available.

This new process and new documents are not adequate and Green Book and Webtag cannot be considered to have been followed. A complete new process must be started from a review of needs assessment, properly involving consultation at appropriate times.CURRENT CONSULTATION

Notwithstanding the above ie even if the current consultation was valid and had been developed properly, and was not invalidated by the new documents and other problems, the schemes and package proposed do not stand up to scrutiny - even on the stated problems the consultation says are trying to be solved.

Planning policy

The schemes are not compatible with national policy including the NPPF which sets out the requirement for sustainable development (with a definition). The clear need for solutions that work to meet economic, social and environmental goals jointly as win-win-win, not schemes that 'balance' these goals against each other, is one key aspect of non-compliance.

The schemes are also not compatible with regional strategies including London Plan policies 6.4 and 6.12.

Traffic and congestion

As well as the Silvertown road tunnel, we are opposed to a vehicle ferry at Gallions Reach and to a fixed link road crossing there – a vehicle ferry would almost inevitably lead to a fixed road link.

According to expert opinion (see John Elliott letter following the London Assembly seminar linked above) even with tolling these schemes would generate, and result in, significantly more traffic and mean worse congestion in the wider area.

If tolled so heavily that there was no new generated traffic – then what is the point?Traffic would arrive at the next point quicker and result just in a different pattern of congestion.

If a tolling regime managed to result in a bit less queuing at Blackwall tunnel this could be achieved much more easily and cheaply and better by other means ie shifting the pattern of congestion eg by reducing road space on the approach(s) which would shift congestion further back, perhaps to smaller amounts in more places.

If the schemes resulted in some new generated traffic – and it must be assumed that TfL would allow some, as this is seen as a supposed benefit – more traffic would mean worse congestion in the wider area all around the schemes, which would be counter-productive.

The current consultation does not set out these issues - indeed the consultation materials make claims about congestion benefits but not costs, as mentioned above under process.

Even the fuller new options paper only hints at some possible problems – referring in relation to a Silvertown tunnel to “the extent of any wider congestion issues” being dependent on tolling, and how tolling gives “the potential to manage traffic generation to ensure that any demand growth is constrained to a level appropriate to the network capacity” -whatever that would be (6.104 and 6.105).

The new needs assessment document asserts that growth “means that further investment in the road network is required” (1.4), and talks of an imbalance between the highway network capacity and demand at the Blackwall tunnel as if building to meet demand so that capacity is balanced with it is somehow required.

TfL are aware of these traffic and congestion issues, including from the Inspectors report on the TGB, and our response to the 2012 consultation.

John Elliott's work, referred to in our response to the 2012 consultation, shows the last time Blackwall tunnel was doubled from 2 to 4 lanes traffic more than doubled in peak time within a year.http://stopcityairportmasterplan.tumblr.com/post/20012814230/presentation-slides-arguing-the-case-against-the

The TGB Inspector concluded that it would be “likely to cause increased congestion” - and that was with proposed tolling to control generated traffichttp://www.foe.co.uk/resource/press_releases/thames_gateway_road_bridge_06112008.html

The lack of significant impact on Blackwall flows and queuing from the TGB, and on congestion relief from both a Silvertown road tunnel and a Gallions Reach road crossing (in a 2003 ODPM report) are set out in our 2012 consultation response.

Current traffic levels need controlling now (and see below under air pollution) and there is not the political will to tackle this, so why add to roadspace and generate more traffic and then have to try and control even greater quantities?

More traffic would be expected to mean fewer people walking and cycling and taking public transport (PT) and more accidents than if the schemes were not built – ie as with the TGB which according to the Inspector would have resulted in “a shift against walking, cycling and public transport in favour of the private car" (9.422). A total of 94% of the benefits would have gone to road users, and that was with the TGB having separate walking and cycling lanes and 2 of the 6 lanes dedicated to public transport.

Road users

TfL make points about how not all journeys can be by PT or that “there will, however, continue to be a need for some journeys to be undertaken by vehicle...” (LP para 6.41) – yes, but nobody is suggesting all roads are closed down in the area or in London – just not increasing the capacity.

These proposals would also not be good for road users – indeed conditions would worsen for them as traffic increased and congestion worsened across the wider area.

Alternatively road users with essential journeys can be helped by demand reduction (including further freight consolidation), investment in walking and cycling facilities and improving existing PT, and investing in new PT infrastructure as needed – all helping free up existing roadspace for those journeys that do need to be done by vehicle.

Resilience, another key issue raised by TfL, is also not helped by having even more traffic in the area – cutting traffic levels not increasing it must be the way forward.

Further deployment and development of TfL's programme to help alleviate problems at Blackwall tunnel eg through intercepting unsuitable vehicles before they reach the tunnel etc would help with resilience.

Growth of population and jobs in east London

London's population has increased while traffic levels have fallen – the investment in PT in the capital has paid off and been successful. If London continues to grow it is even more important that planning works to reduce the need to travel and that any investment is directed to PT so that new potential journeys are avoided where possible and otherwise directed onto PT rather than vehicles. To provide more road space is to predict and provide, and more vehicle journeys is what would result. We get what we build and we must concentrate further investment in PT.

Just because there has been good investment in PT in the area already does not mean that the best thing isn't to concentrate further investment in PT.

Regeneration

With the TGB, even with differential tolling (ie to favour local people), the Inspector found that after a year-long inquiry and opportunity for TfL and GLA Economics to make their case, the promoters case did not stand up.

Car-based development is not the way to help help regeneration – is not the best use of space and tends to result in spread out development with low-employment uses such as warehousing benefiting most.

In fact the main areas for regeneration are river front sites, actually facing each other across the river - and connecting them does not need road crossings and would actually blight their prospects. Multiple walk, cycle crossings with additional public transport capacity would be expected to be far more beneficial.

Alternatives

The area north of the river is designated a Green Enterprise District (and the whole of the Thames Gateway an ego region) – minimum standards of inward investment including green workplace travel plans etc would help cut demand and avoid unnecessary journeys, as would further work on

wider land use planning and reducing the need to travel.

Other measures include physical intervention such as re-allocating road space (eg to cycle routes/cycle super highways), narrowing roads to shift congestion patterns eg on the Blackwall southern approach.

Tolling existing crossings and/or road user charging London-wide, as needed, must be considered seriously.

These, along with improving existing public transport and new walk & cycle / public transport provision must be considered as options, and in combinations as components of packages.

There are many non-road capacity increasing options not considered in the current consultation (or in the new documents), let alone combinations of them (and with other measures) as packages.

These include various DLR or rail possibilities including a route off the Woolwich line to Thamesmead already allowed for (the business case for which must be revisited with up to date assumptions), a DLR along the Blackwall southern approach - which could come out differently in appraisal if done without new road capacity, various non-vehicle ferry or cable car options and other walk/cycle/public transport only options.

A proper look at a wider set of options and packages and how they could best complement Crossrail must be initiated.

Air pollution

More traffic from the proposed schemes would worsen air pollution.

London is one of the UK's zones for air pollution purposes and is currently failing to meet EU legal limits, and on NO2 there is no extension to the 2010 deadline granted or plan in place to meet limits by the dates required. EU limits must be met everywhere in a zone; cannot be taken over a limit and cannot exceed limits once attained; must not be worsened if already exceeding limits.

Air pollution already exceeds EU legal limits around both ends of both proposed schemes – links in our 2012 consultation response.

The TGB's extra traffic would have taken a receptor over the threshold for the NO2 annual limit when this would not have been the case without the scheme, and the Inspector said it was not acceptable to worsen air pollution when it was already a problem.

King's College London's Professor Frank Kelly told the government's Environmental Audit committee (EAC) that traffic in London would need to be cut by 20-30% in order to meet EU air pollution legal limits – cleaner vehicles are not enough ie traffic levels need to come down, ie can't be increased.

While air pollution is already the 2nd biggest cause (after smoking) of premature death, recent evidence reported from the WHO increases the imperative to take action, and is likely to result in tightening of requirements. http://europa.eu/rapid/press-release_IP-13-72_en.htm

As referred to in our 2012 consultation response, the EDS refers to business's poor rating of the attractiveness of London to business in relation to “freedom from pollution”.

With TfL's acknowledged fact that the most vulnerable in society and the poorest people (as they tend to live near main roads where air pollution is worst) are hit hardest by air pollution, an equalities impact assessment would not be favourable for any worsening of air pollution from increased traffic. This is particularly a problem as the poorest would tend to be least likely to contribute to the problem having low car ownership levels (the wards closest to both ends of the TGB had levels of only ¼ to a 1/3).

Climate changeLondon is not on track to meet its CO2 targets and the transport sector must play its part – currently its contribution is set to be very small.

TfL's Road TaskforceThe current work talks of issues of balancing moving and living functions, and of the conflict between them – but the problem is not movement per se as eg walking is not generally in conflict with a living function, but rather what type of movement. We need to work to reduce such conflict and the challenge is how to fit movement in with our environmental and social as well as economic requirements and pursue sustainable development. This can be aided by taking every opportunity and concentrating all investment in schemes that help to reduce not worsen such conflict ie in movement concentrated on walking and cycling and improving and extending as needed public transport for longer journeys. Everywhere in London must be liveable – eg at a minimum London must meet EU air pollution legal limits by the dates required. We cannot abandon any people or parts of London to be unliveable eg with unacceptable air pollution levels.ENDS