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

Lower Thames Crossing: learn the latest about the scheme at four drop-in events

Lower Thames Crossing… what do you want to know?

In one of our longer-running sagas, National Highways (formerly Highways England) has announced four Lower Thames Crossing drop-in events at which visitors can learn about project updates and ask any questions they have.
We are told there will be information about proposed routes for walkers, cyclists and horse-riders, along with news of how the government agency is working with schools and businesses to create jobs and skills opportunities.
These are not consultation events, but National Highways has confirmed it is working with local authorities on the next round of LTC consultation. It has sent them a draft Statement of Community Consultation proposing a four-week consultation from March 24-April 22.

Information events

Wednesday, February 16, 4pm-8pm: New Windmill Hall, St Mary’s Lane, Upminster, Essex RM14 2QH

Thursday, February 17, 4pm-8pm: East Tilbury village hall, East Tilbury, Essex RM18 8RB

Monday, February 28, 4pm-8pm: Orsett Village Hall, Mill Lane/High Road, Orsett, Essex RM16 3HB

Thursday, March 3, 4pm-8pm: Kent Room, Gravesham Borough Council Civic Centre, Windmill Street, Gravesend, Kent DA 1AU

  • For more on the Lower Thames Crossing, click here

Monday, February 14, 2022

Lower Thames Crossing: Community Impacts Consultation begins this month

Lower Thames Crossing… the process rumbles on

The next round of public consultation on the Lower Thames Crossing begins on Wednesday, July 14, and runs for eight weeks until Wednesday, September 8.
Highways England says: “This Community Impacts Consultation will give people the opportunity to review and comment on our plans to build and operate the Lower Thames Crossing, and how we propose to reduce our impact on the local community and environment.
“Topics include changes to traffic, air quality, noise and vibration, as well as the impact of the new crossing on the environment and landscape.
“The consultation will also include some changes made to the project since the previous consultation in 2020. This includes a reduction in the area needed to build and operate the scheme, a smaller impact on local properties and woodland, and new public spaces on both sides of the River Thames.
“We have also summarised how the feedback provided during earlier consultations has been used in the development of the project.”
CPRE Kent believes a new crossing is not an acceptable option.
Speaking before a previous round of consultation on the project, Alex Hills, CPRE Kent’s Gravesham district chairman, said: “Cities in this country and around the world have become aware that, due to the dreadful Covid-19 disease, more needs to be done to boost active travel (walking and cycling).
“This is partly to enable social distancing and partly to reduce air pollution. The Climate Change Committee has called for proposed spending on roads to be spent on measures that offer better value for money and at the same time reduce congestion and air pollution.
“Increasing investment in active travel, sustainable transport and broadband all offer better value for money. The KenEx tramline (see here) could take up to 10 per cent of traffic using the Dartford crossing for £600 million as opposed to a new crossing costing at least £6.8 billion and increasing congestion.”
Highways England plans to submit a new application for a Development Consent Order this year, starting an 18-month examination process. If it wins consent, HE aims to begin construction in 2024, with the new road opening in 2029 or 2030.

  • The consultation materials are due to be released at one minute past midnight on July 14; they will be available here
  • For more on the Lower Thames Crossing, click here
  • To read CPRE Kent’s response to the spring 2020 LTC consultation, click here

Monday, July 5, 2021

High Court challenge puts Lower Thames Crossing in the spotlight

In the news again… the Lower Thames Crossing

The future of the proposed Lower Thames Crossing was highlighted this week (Tuesday and Wednesday, June 29-30) when a legal challenge against the government’s roadbuilding programme was heard in the High Court.
The challenge was brought by the Transport Action Network and targeted the Department for Transport’s £27.4 billion roadbuilding scheme (labelled Road Investment Strategy 2, or RIS2), saying it breached climate and air quality laws.
TAN claims the government has failing to consider fully the Paris Agreement, which commits the UK to tackling climate change by limiting global warming to less than 2°C. Indeed, the group says the transport secretary pulled plans to cut CO2 emissions for a tranche of upgrades and new schemes.
RIS2 includes 50 schemes, the largest of which is the £8.2bn Lower Thames Crossing.
TAN said it expected the DfT to contest its challenge, saying commitments to climate change were not “obviously material” to roadbuilding schemes.
However, Chris Todd, TAN director, said: “Trying to argue climate change isn’t ‘obviously material’ to approving the largest-ever roads programme is like saying public health is not relevant to reform of smoking rules.
“In an audacious attempt to protect his addiction to asphalt, [Transport Secretary Grant ] Shapps is now seeking a legal precedent that decision-makers can ignore climate targets.
“This puts ministers on a collision course with the Climate Change Committee, which [has] called on the government to adopt a Net Zero Test for all policy decisions.”
Laura Blake, chairman of the Thames Crossing Action Group, said: “We know that the proposed Lower Thames Crossing would create over five million tonnes of carbon emissions, along with all the other negative impacts which we would suffer if the LTC were to go ahead.
“We have many serious concerns about the impacts of the proposed Lower Thames Crossing and feel it is essential that all the negative impacts of the scheme should be taken into account.
“We are grateful to TAN for bringing this legal challenge on climate grounds against the government’s £27bn roadbuilding programme, which of course includes the £8.2bn Lower Thames Crossing.
“We wholeheartedly support this legal challenge and appreciate all the hard work by TAN and the legal team.”

  • For more on the Lower Thames Crossing, click here
  • Transport Action Network has set up a ‘Stop the largest ever road-building programme’ CrowdJustice page

Thursday, July 1, 2021

London Resort developer accused of providing ‘insufficient’ information on traffic impact

The scheme targeted for the Swanscombe peninsula (pic LRHC)

The developer behind the proposed London Resort theme park has been accused of failing to provide enough information about the impact of increased traffic on road and rail in north Kent and London.
In damning submissions from leading transport organisations to the Planning Inspectorate, it is suggested that transport infrastructure could be overwhelmed by traffic from the development, on the Swanscombe peninsula.
Highways England says there has been “insufficient information” to allow conclusive statements on traffic impact, citing junctions 2 and 30 of the M25, the A13/A1089 junction and the A2/M2 east of the M25 as potential problem spots.
Transport for London, meanwhile, has slammed London Resort Holding Company’s lack of an “appropriate assessment methodology”, saying it could mask “significant impacts that must be mitigated”.
It said: “The failure to use appropriate modelling means that impacts on the rail and Underground network have not been assessed with any degree of certainty.
“The arbitrary assumptions about the scale of traffic that will use the north Kent lines risks ignoring potential impacts at their central London termini and on interchange flows at Abbey Wood (to the Elizabeth line).”
It also warned that the development could cause congestion on north Kent roads and lead to problems at east London road tunnels.
For its part, Network Rail was concerned about impact on stations close to the planned development as well as the effect on the Ebbsfleet Southern Link and HS1.
As if all that were not enough, the C2E Partnership feared that the scheme could take up land earmarked for a potential Crossrail extension to Ebbsfleet.
A list of Relevant Representations was published on Planning Inspectorate website in April after its deadline for comments had passed.

  • For more on the London Resort scheme, click here

Tuesday, May 25, 2021

Revised Lower Thames Crossing plans miss Easter target date

‘It’s been a really busy time for the project,’ according to a Highways England statement

Highways England has failed to hit its own target in resubmitting plans for the Lower Thames Crossing.
In November, the government agency withdrew its application for a Development Consent Order to build the Lower Thames Crossing, saying it would put in revised plans to the Planning Inspectorate by Easter.
However, they have yet to appear, Highways England just offering the following statement:
“It’s been a really busy time for the project as we continue to work hard to submit our revised planning application later this year.
“We’re absolutely determined to bring you these benefits as soon as possible, so it’s essential we continue to maintain momentum on the project.
“We initially submitted our planning application back in October, which we then withdrew following some feedback from the Planning Inspectorate.
“They have asked us to provide some more information on some technical elements of our application.
“We’re busy bringing this information together, but we also see this as a great opportunity to strengthen our application as we continue to work with key stakeholders to make the Lower Thames Crossing the best it can possibly be.”

For more on this story, click here

Friday, April 16, 2021

Credit to Dartford council as it prepares a genuine brownfield-first strategy

Let’s hope Dartford Borough Council’s good work is not undone on the Swanscombe peninsula, which is threatened by the proposed London Resort theme park (pic Paul Buckley)

Consultation on Dartford Borough Council’s pre-submission version of its Local Plan closed today (Friday, April 9, 2021) and CPRE Kent feels this has been largely a positive example of Plan-making within the constraints of the planning system. 
By focusing development on well-connected brownfield sites within the town of Dartford and at Ebbsfleet Garden City, the Plan is essentially a genuine example of a brownfield-first strategy. Coupled with strong Green Belt protection policies and policies responding to the climate-change emergency, there is a lot to commend.
Of course, there remains areas where things could be better. We have taken exception to the continued support of roadbuilding within a borough that has some the worst air quality in the South East and the council’s continued support for the Lower Thames Crossing.
We have called on the authority to be bolder with measures to truly respond to our biodiversity crisis, along with further strengthening of active-travel measures.
We were disappointed not to see a policy protecting intrinsically dark landscapes. We have reminded it about the implications of Natural England’s designation of Swanscombe Marshes and land to the south as a Site of Special Scientific Interest.
Overall, though, there was certainly as much good as there was bad. We now must just hope that this good work is not undone should the proposed London Resort theme park be consented. 

  • You can read our comments here

Friday, April 9, 2021

Does Transport Secretary revelation scupper plans for Lower Thames Crossing?

Lower Thames Crossing… where do we go now?

Campaigners against the building of the Lower Thames Crossing between Kent and Essex have been encouraged by the news that the Secretary of State for Transport ignored the advice of his own officers in refusing to review the government’s road policy.   
The Guardian’s front-page story revealed how Grant Shapps had dismissed the advice from civil servants that the policy should have been reviewed on environmental grounds.
The newspaper says: “It has been a legal requirement to take into account the environmental impact of such [road] projects since 2014. Shapps appears to have pressed ahead despite the advice of civil servants in his own department.”
It suggests that the £27 billion expansion of England’s road network – described by Chancellor Rishi Sunak a year ago as the country’s “largest ever” roadbuilding programme – “has been thrown into doubt” by the revelation.
It came as Transport Action Network sought a judicial review of the strategy to develop such road projects as the Lower Thames Crossing, the Stonehenge tunnel and the A46 Newark bypass.
The Guardian says evidence that Mr Shapps had overridden Whitehall advice was disclosed only “at the 11th hour to the claimants” in the High Court case. That advice had been to review the 2014 National Policy Statement on national networks.
The TAN claim centres on the decision not to review all or part of the NPS and has now been amended to introduce Shapps’s decision to dismiss the civil servants’ advice; this runs alongside the original grounds that the roadbuilding policy was not compatible with commitments to the environment and air quality.
David Wolfe QC states in his submission: “On the day before the limitation period for issuing this challenge was due to expire, the defendant [Mr Shapps] provided the claimant [Transport Action Network] with the advice of his officials, which was that it was appropriate to review the NPS.”
He adds: “The claimants have been presented, on the one hand, with official reasoning in support of a review, and on the other, with a decision by the defendant not to review the NPS, with no explanation of why, or on the basis of what information or considerations, he chose to depart from his officials’ advice.”
Government lawyers, however, claim Mr Shapps has no duty to give reasons for his decision and that the claim is baseless.
Chris Todd, Transport Action Network director, said: “The largest-ever roads programme and world-leading emissions cuts were always the strangest of bedfellows.
“Far from ‘building back better’, the government’s £27bn roads plan would pollute communities, tear through treasured green spaces and turn up the heat on the planet, while making congestion worse. Our legal challenge seeks to end this nightmare and prioritise what’s important to people.”

  • To read about the proposed Lower Thames Crossing, see here

Monday, March 8, 2021

Environmental mitigation, impact on traffic and approach to consultation among Lower Thames Crossing DCO issues

Lower Thames Crossing… the saga rumbles on

We reported last week that Highways England had withdrawn its application for a Development Consent Order to build the Lower Thames Crossing.
Now we have been updated by HE on the issues relating to the Planning Inspectorate and the likely way forward.
A message to  stakeholders said: “… we’ve now had further dialogue with the Planning Inspectorate about their expectations around our application.
“The fundamentals of the Lower Thames Crossing, including its objectives and location, will remain the same but we will further develop some technical information related to some elements of the scheme before we resubmit our application next year.
“The feedback from the Planning Inspectorate includes requests for:
“Further information on the impact of the project on traffic during the construction phase. We recognise that stakeholders are keen to find out more information about our construction traffic appraisals and will be engaging with them on these issues.
“Further assessments about how an existing jetty on the River Thames near the northern tunnel entrance construction site could potentially be used during the construction phase. The operation of the jetty could, if used, impact river traffic. We will be developing Navigational Impact Assessment and engaging with stakeholders on this topic.
“More details on our approach for managing materials and waste, including how the different contractors will coordinate the reusing, recycling or disposal of waste.  
“An enhanced Habitats Regulations Assessment to provide a more detailed explanation of our approach to assessment of potential effects on European designated sites where we have indicated there would be no likely significant effects as a result of the construction and operation of the new road alone, or in combination with other projects.
“More detail on our approach to the long-term management of the project’s proposed environmental mitigation.
“The Planning Inspectorate has also shared some feedback from Local Authorities on our approach to consultation. We will consider this feedback carefully as we refine key areas of our submission ahead of resubmitting our application for a Development Consent Order.
“For a project of the size and complexity of the Lower Thames Crossing, it is reasonable for the Planning Inspectorate to ask for further information, and we are doing everything we can to resubmit our application at the earliest opportunity.”

Friday, November 27, 2020

Lower Thames Crossing: bid for planning consent delayed

Plans to build the Lower Thames Crossing have been delayed with Highways England’s withdrawal of its application for a Development Consent Order.
“We’ve withdrawn the Development Consent Order application for the Lower Thames Crossing based on early feedback we’ve had from the Planning Inspectorate,” said a spokesman for HE.
“We will take time to collate the information required for the specific points raised and will be resubmitting the application early in the new year.”
Alex Hills, Gravesham chairman of CPRE Kent, said: “We would be happier if the application was completely withdrawn as it is an ill-thought-out scheme that will be massively damaging for Kent without solving the problems at the Dartford Crossing.”
For the scheme to progress, HE needs to be granted a DCO by the Planning Inspectorate, government’s planning agency.

Planning Inspectorate ‘feedback’ has resulted in the DCO application being withdrawn

Monday, November 23, 2020

Lower Thames Crossing: Highways England submits application for Development Consent Order

An impression of what could be coming our way

Highways England has submitted its application for a Development Consent Order for the Lower Thames Crossing.
The submission was made on Friday, October 23, to the Planning Inspectorate, which will decide, within 28 days, if it is accepted for examination.
HE expects the Planning Inspectorate to make its decision on acceptance by Friday, November 20. If the application is accepted for examination, the following process will unfold:
Pre-examination period: probably between late November and March 2021
Examination: anticipated from March to September 2021
Recommendation period: anticipated autumn 2021 to spring 2022
HE says: “Only after the recommendation period in 2022 would the application be formally presented to the Secretary of State for Transport for them to decide if the application is approved or not – and only if it is approved, could we start building the Lower Thames Crossing.”
Learn more about the application process, including how and at what stage you can get involved, here

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

Monday, October 26, 2020