LTC Local Refinement Consultation – simply not good enough from National Highways

Lower Thames Crossing: CPRE Kent believes there needs to be a further and final round of consultation

CPRE Kent has responded to the Lower Thames Crossing Local Refinement Consultation.

As with the previous National Highways consultation, our main takeaway has been yet further frustration with the lack of detail provided, as well as the piecemeal fashion in which it is being provided.

There remain gaping holes in the information being provided; the documentation is very hard to navigate; key bits of information are buried in other documents from previous rounds of consultation; and key questions remain unanswered. There are also extremely important surveys such as air pollution surveys still yet to be done.

This is simply not good enough.

Sleek presentations, online videos and glossy brochures are one thing; however, it is the substance of the consultation that matters. 

It is for these reasons we strongly believe there needs to be a further and final round of consultation which brings together and updates all elements of the evidence base. This should be undertaken as a full statutory and be presented in cohesive and transparent manner. 

While this will never overcome our in-principle objection to the LTC project, this is the minimum that must be done to allow the people of Kent to fully understand the environmental, social and economic impacts of the LTC scheme.

  • CPRE Kent’s detailed comments on the consultation can be found here
  • For more on the Lower Thames Crossing, see here

Wednesday, June 22, 2022

Last call on LTC consultation: it ends today

The Lower Thames Crossing as it might look

Today’s the day!

The Local Refinement Consultation on the proposed Lower Thames Crossing concludes at 11.59pm tonight (Monday, June 20).

It is of course very much last call, and the matter is complex, so if you would like a helping hand you can see can Thames Crossing Action Group’s step-by-step guide to the National Highways consultation here

Every voice counts!

  • For more on the Lower Thames Crossing, see here

Monday, June 20, 2022

With less than a week to run on LTC consultation, here’s a step-by-step guide

The issues can be complex, so the Thames Crossing Action Group has produced a guide (pic TCAG)

Time is running short if you’re planning on taking part in what might be the final consultation on the proposed Lower Thames Crossing.

The Local Refinement Consultation set up by National Highways concludes at 11.59pm on Monday, June 20.

We highly recommend submitting your views as the more responses received by NH the better.

Our friends at the Thames Crossing Action Group say: “You can of course respond using the National Highways consultation response form, but please bear in mind that NH have designed the form to get the answers/feedback they want.

“If you do use it, please read the wording carefully!” 

TCAG suggests instead giving your views either via email or post, highlighting that “you don’t have to use the response form”.

The matter is of course complex and if you would like a helping hand you might be interested in TCAG’s step-by-step guide to the consultation. You can see that here

CPRE Kent believes there are many problems with the crossing proposals and it is disappointing that the NH consultation does not address any of them.

Those issues include:

1. The A2 is to be reduced to two lanes both London- and coastbound – four lanes already at full capacity during commuter hours.

2. The Lower Thames Crossing is the wrong solution at the wrong location. On completion – in 2030! – the misery of the Dartford crossing will continue. Will lorries prefer this shorter northerly route, saving them fuel costs? It is predicted that the LTC will only reduce the Dartford crossing traffic by some 4 per cent.

3. Congestion at Dartford should be addressed without further delay. It is caused by the ‘stopping’ of all traffic in order to escort large tankers and many European lorries through the obsolete tunnels. This is effectively a red traffic light on the M25 causing ‘domino accidents’. The LTC does not resolve this problem.

4. The decision to build LTC was based on the promise of private funding. It is now to be publicly funded at a cost of £8.2 billion and rising. The Queen Elizabeth Bridge cost £120 million in 1991 (Highways England, now National Highways, rejected a relatively small cost of installing ‘wind supports’ as those installed in most bridges). This would not equate to £8.2 billion, even with inflation.

5. The LTC is being planned as an all lanes running expressway – a smart motorway by another name. This means no hard shoulder and as yet no reliable danger-detection system.

  • You can order a consultation pack here (alternatively phone 0300 123 5000 or email info@lowerthamescrossing.co.uk)
  • The National Highways dedicated LTC web page is here
  • For more on the LTC, see here
  • To read CPRE Kent’s response to the spring 2020 LTC consultation, click here

Tuesday, June 14, 2022

Lower Thames Crossing: read CPRE Kent’s Gravesham committee response

How the the crossing, should it be built, might look in Kent

We reported here that what is likely to be the final consultation on the Lower Thames Crossing ends on Monday, June 20.

The Gravesham committee of CPRE Kent has been working on its response to the consultation and you can read that here – it might help you with your own.

Monday, June 6, 2022

Lower Thames Crossing: what might be the final consultation begins tomorrow

Lower Thames Crossing… it’s time for another consultation

Lower Thames Crossing. Consultations. We’ve been here before, right?
Well, yes, the build-up to the potential building of the new road does seem to have been around a long time, but the next consultation is, we suspect, likely to be the last before National Highways resubmits its plans.

The Local Refinement Consultation begins tomorrow (Thursday, May 12) and ends on Monday, June 20.

If this is indeed to be the final consultation, we would urge all interested to make their views known.

NH says the consultation gives “giving local communities the chance to have their say on some refinements to the project”.

It adds: “The Local Refinement Consultation is taking place to share a number of updates made to the project based on feedback from a consultation in 2021, ongoing stakeholder engagement and technical surveys.

“Following feedback from Thurrock Council the project has also amended its plans for Tilbury Fields, a new public park on the north bank of the Thames, to make space for the planned Thames Freeport.”

Proposed refinements include:

  • More public open space to the east of the tunnel entrance in Kent, connected to Chalk Park – the proposed new public park overlooking the Thames
  • Additional environmental compensation and mitigation, with potential woodland and public access
  • Replace a slip road on the A13 junction with a new link from the Orsett Cock roundabout to the A1089 to reduce traffic impacts on local roads
  • Modifying the access to the northern tunnel portal, providing safer operation of the tunnel facilities and better access for emergency services
  • A new footbridge over the A127 and further improvements for walkers, cyclists and horse-riders, including improved bridleways
  • Further refinement of utility works to enable the project to be built

NH is holding a series of public information events:

Kent

Friday, May 20 (2pm-8pm): Cascades Leisure Centre, Thong Lane, Gravesend DA12 4LG

Monday, May 23 (2pm-8pm): Village Hotel, Castle View, Forstal Road, Maidstone ME14 3AQ

Thursday, June 9 (2pm-8pm): Bridgewood Manor Hotel, near Bluebell Hill, Walderslade Woods, Chatham ME5 9AX

Friday, 10 June (2pm-8pm): Shorne Village Hall, 16 The Street, Shorne DA12 3EA

Essex

Thursday, May 19 (2pm-8pm): The Civic Hall, Blackshots Lane, Grays RM16 2JU

Friday, May 27 (2pm-8pm): North Street Hall, 24 North Street, Hornchurch RM11 1QX

Monday, June 9 (2pm-8pm): East Thurrock Community Association, 77 Corringham Road, Stanford-le-Hope SS17 0NU

Tuesday, June 7 (2pm-8pm): Tilbury Community Association, Civic Square, Tilbury RM18 8AA

Monday, June 13 (2pm-8pm): Orsett Hall Hotel, Prince Charles Avenue, Orsett RM16 3HS

  • You can order a consultation pack here (alternatively phone 0300 123 5000 or email info@lowerthamescrossing.co.uk)
  • The National Highways dedicated LTC web page is here
  • For more on the LTC, see here
  • To read CPRE Kent’s response to the spring 2020 LTC consultation, click here

Wednesday, May 11, 2022

The revised NPPF is out! Not bedtime reading maybe, but it’s going to play a big part in planning policy

This year’s NPPF consultation focused largely on design codes and ‘building beautiful’

A revised version of the National Planning Policy Framework has been published this month (July) – see here.
The new incarnation follows this year’s consultation, which focused primarily on incorporating design codes and building-beautiful recommendations.
The full government consultation response can be found here, while the original comments made by CPRE to the consultation are here
The changes are largely incremental and as anticipated though are to be formally applied from the date of publication (Tuesday, July 20) for both Local Plans not yet at examination and planning decisions.
For immediate practical purposes, all paragraph numbers from paragraph 53 onwards have now changed – here is a tracked version illustrating the differences between the February 2019 version of the NPPF and this latest edition.

  • For more on the NPPF, see here

Thursday, July 29, 2021

Swale consultation extended but councillors won’t be getting a report back before Local Plan is submitted

Swale Borough Council has agreed to extend its current Local Plan consultation until Friday, April 30.
The decision was made at a meeting of full council on Wednesday, February 24, and all residents in the borough will receive letters telling them about the state of the Plan.
However, councillors did not agree to have the outcome of the consultation reported back to them before submitting the Plan for examination. This was contrary to what CPRE Kent had suggested.
An amendment supporting such a report was rejected by 24 votes to 18 – a disappointing outcome, we believe.

  • To read more about the Swale Local Plan, see here

Monday, March 8, 2021

Swale Local Plan: have your say now!

After last week’s full council vote, the Swale Local Plan is now out for consultation.
Residents and other interested parties have until Tuesday, March 23, to submit their comments.
CPRE Kent and others have cautioned against going to this formal stage of consultation without undertaking the Draft Issues and Options consultation that had previously been promised.
It remains an overriding concern that this decision may inadvertently delay the Plan, either by hostile third-party challenge or through failure of the legal and procedural test at the Local Plan examination. The latter happened recently with the Tonbridge and Malling and Sevenoaks Local Plans.
Of course, a delayed Plan means a greater risk of speculative applications in the meantime.
These fears are compounded by the lack of the necessary evidence base to inform this consultation, most notably the absence of the required Sustainability Appraisal.
It is extremely concerning that a decision to go to consultation has been made before this important work has been finalised. We would urge Swale Borough Council to ensure the required six weeks is available to consider this evidence once it is completed.
More generally, CPRE Kent will be considering the detail of Swale’s Plan and supporting evidence over the coming weeks. Our early concerns, however, include:

  • The lack of meaningful consultation undertaken so far. This is particularly the case for the development now being proposed at Teynham and Lynsted
  • The lack of traffic modelling. This is a significant evidential requirement that goes to the heart of the soundness of the Plan and runs across many separate issues. The need and importance of such evidence is clearly set out in planning guidance
  • The uncertainty as to what infrastructure is required to deliver the Plan. Most notably, this includes whether a bypass at Teynham is required and the extent of improvement at junctions 5 and 7 of the M2
  • The chosen distribution of development leading to a worsening of air quality in the borough’s Air Quality Management Areas (AQMAs)
  • The coalescence of the two contrasting parish settlements of rural Lynsted and more urbanised Teynham.

This list is not exhaustive and represents our initial views only. We would, however, strongly encourage all of you who care for the future of Swale to consider carefully the proposals and make your opinions known.
The consultation document can be found here

Tuesday, February 9, 2021

Proposed changes to the country’s planning system: CPRE Kent chairman’s statement

John Wotton, CPRE Kent chairman, has given a statement regarding the government’s proposed – and highly contentious – changes to the country’s planning system.  
Mr Wotton said: “The policies in the Planning for the Future White Paper published in August, combined with the measures in a separate consultation paper, Changes to the Current Planning System, are wide-ranging and, in my view, potentially disastrous for the countryside, especially in Kent and other parts of the South East, where the pressure for unsustainable development is already intense.
“Increased housing targets will be set by central government, under a complex formula, with a view to building at least 300,000 homes per year and will be binding on local planning authorities, whose ability to review and refuse planning will be reduced.
“A new system of zoning will designate all land as either growth, renewal or so-called ‘protected’ zones. The opportunities for the public to participate in the plan-making and place-making processes will be curtailed.
“I believe that opposing these changes is a fundamental necessity for protecting the Kent countryside, which we all love.”

Monday, November 2, 2020

Another important consultation on new planning rules closes…

Photo: Peter Newport

Consultation on the second major tranche of proposed changes to the planning regime closed yesterday (Thursday, October 29). Despite the government’s stated aims of ‘levelling up’ the country and prioritising brownfield redevelopment, we see little within the proposals that would actually achieve that. Along with so many others in the wider CPRE network, we raised our concerns over the proposals, which would see a significant increase in the amount of rural land that would have to be allocated for housing, and would mean people would see a dramatic reduction in their ability to have a say about how their communities develop.

It was heartening to see so many MPs echo CPRE’s concerns in a parliamentary debate on Thursday, October 8. We hope our concerns will be heeded and we can maintain a planning system that has communities, nature and the climate at its heart.

You can read the CPRE Kent response here:

And the national ‘One CPRE’ response can be found here:

Read our response to the consultation on planning changes

We’re doing our best to stop damaging proposals being bulldozed through

CPRE Kent has submitted its response to the government’s Changes to the Current Planning System consultation (click here).
The process could have an ultimately devastating impact on much of Kent, with almost all the county’s district authorities facing housebuilding hikes of up to 125 per cent.
If the consultation figures are accepted as part of planning policy, Kent will need to build an extra 2,835 homes a year on top of current targets, which are already frighteningly high.

  • You can read the national CPRE response here

Friday, October 30, 2020

CPRE responds to planning consultation that could spell destruction for our countryside

How much more of this can Kent take?

We have already referred to the government’s Changes to the Current Planning System consultation (click here) and the drastic effect it could have on Kent, with almost all the county’s district authorities facing annual housebuilding hikes of up to 125 per cent.
If the consultation figures, based on what has already been described as “another rogue algorithm”, are accepted as part of planning policy, Kent will need to build an extra 2,835 homes a year on top of current targets, which are already eye-wateringly high.
Now CPRE has produced its response to the consultation and you can read it here.
At almost 9,700 words, you might not want to tackle it in one sitting, but it is an important document and one we hope will cause the government to reconsider what are potentially highly damaging proposals to our countryside and indeed our way of life.

Thursday, October 8, 2020 

Lower Thames Crossing consultation: time (really is!) running out to make your voice heard

At a minute to midnight on Wednesday, August 12, the consultation clock stops!

Time is almost up!
You have until 11.59pm tomorrow (Wednesday, August 12) to take part in Highways England’s consultation on further design revisions to the proposed Lower Thames Crossing.
CPRE Kent has made a response running to more than 5,000 words and, while you might not wish to go to quite such lengths, it would be useful to make your voice heard.
There are many issues with the project – not least regarding air pollution and climate change – but did you also know the following?
The A2 was widened both ways at great expense to four lanes. With the proposed refinements, the A2 coastbound would reduce from four lanes to two just east of the Gravesend East junction and also London-bound from four lanes to two before the Thong Lane bridge. It’s not easy to find the detail in the consultation document, but it’s there!
These pinch points would cause serious congestion – and should be reconsidered in the light of the recent decision permitting the operation of Manston airport, which will result in large vehicles carrying air-freight containers along the A2.
Any congestion on the A2 will result in vehicles rat-running at speed through the narrow lanes of surrounding areas such as Meopham, Sole Street and Cobham. This, we suggest, would appear contrary to the LTC Project Objective to “improve safety”.
There is very much more that can be said about a scheme likely to bring little benefit to Kent, but you can learn more here

  • You can join the Highways England consultation here

Tuesday, August 11, 2020

Truth about impact of the Lower Thames Crossing on local roads revealed at public meeting

Consultation on LTC design revisions is ending on Wednesday (August 12)

There was a healthy turn-out to a meeting from people keen to see copies of the latest Lower Thames Crossing design consultation.
The event, organised by the Gravesham committee of CPRE Kent and Meopham residents, gave all the chance to ask questions about the revised design proposals. It had been set up in view of Highways England’s belief that the documents being displayed only in Rochester Library was sufficient south of the river.
None of the many visitors at the meeting, held at Meopham Cricket Pavilion on Friday, July 31, realised that the junction of the tunnel access road and A2 would result in the A2 being reduced to two lanes in each direction at this point.
This pinch point is likely to cause huge congestion on the A2 and as a result greatly increase traffic on local roads such as the A227.

  • You can read more on the latest consultation here

Monday, August 10, 2020

Lower Thames Crossing: rallying call to take part in next phase of consultation

Four-week consultation starts on Tuesday, July 14

The next phase of consultation on the proposed Lower Thames Crossing begins this month.
Highways England is launching the four-week consultation on proposed design refinements to the planned road on Tuesday, July 14. It comes after 2018’s statutory consultation in 2018 and the supplementary consultation, which was completed this year.
From July 14, we will all be able to comment on the proposed refinements, which include:

  • Minor refinements to elements of the highways design
  • Updated paths for walkers, cyclists and horse riders
  • Proposals for redirecting and upgrading utilities
  • More detailed landscaping proposals
  • Further developed ecological mitigation measures

The consultation is a digital-first event, meaning that from July 14 to Wednesday, August 12, all materials, including an online feedback form, will be accessible here
You can also order printed copies of the consultation materials by emailing info@lowerthamescrossing.co.uk
The digital-first approach reflects social-distancing restrictions imposed by the government in response to the Covid-19 pandemic. Highways England says it is, though, setting up additional measures to ensure the public can engage in the consultation. These include:

  • Leaflets distributed to 135,000 properties within two kilometres of the route, giving residents notice of the consultation
  • From now, people can register their interest in the consultation and order hard copies of the consultation packs to arrive from the July 14 launch
  • Extensive media and social-media campaigns to raise awareness of the consultation

Highways England says that during the consultation period, July 14-August 12, it will provide:

  • Freephone consultation and call-back service for people to find out more and give their feedback on the proposals
  • Online public information exhibition, including videos, displays and documents library
  • Webinars to explain the key changes open to all members of the public
  • Updated and newly-interactive website
  • Social-media updates

Alex Hills, CPRE Kent’s Gravesham district chairman, said: “This could be the last consultation before a planning application is put in, so it is important that as many people as possible take part in this very short consultation.
“CPRE Kent is calling on people and organisations to order hard copies of the consultation for those who are not comfortable doing everything online.”

For more on the Lower Thames Crossing, see here and here

Friday, July 3, 2020