Remember, remember, the 20th of December...

Yes, Thursday, December 20, is the last day you can submit your comments on Highways England’s plans for the new Lower Thames Crossing.

We know that the pollution, congestion and delays at the existing Dartford-Thurrock crossings are intolerable, and agree that action needs to be taken to protect the lives and livelihoods of people living and working nearby, as well as those who use the crossing. However, the proposals for the new crossing will not fix these problems. The planned new crossing is now simply a mechanism to ‘unlock growth potential’, which means encouraging ever-more road journeys – not managing congestion.

It takes very little scrutiny of the proposal documents to realise that if the proposed crossing east of Gravesend and Tilbury were to be built, it would make barely any improvement on conditions at Dartford or western Thurrock.

Instead of an expensive and damaging new infrastructure project, in an area of the country that is already massively constrained and over-stressed, and which will lock in another generation to damaging car-dependent domestic and commercial development, CPRE Kent wants a better solution. We are calling for a sustainable national transport strategy that does not encourage the ceaseless growth of road-based traffic but focuses on genuinely sustainable policies for the movement of people and goods.

We will be submitting our consultation response next week and we’ll post it on this website for anyone interested to check out.

Meanwhile, you might like to look at some of our earlier comments:

• https://archive.cprekent.org.uk/roads/lower-thames-crossing-consultation-opens/
• https://archive.cprekent.org.uk/blog/radical-rethink-needed-thames-crossing-solution/
• https://archive.cprekent.org.uk/blog/meet-to-hear-our-views-on-lower-thames-crossing/

And here are thoughts of Alex Hills, our Dartford and Gravesham chairman:

• https://archive.cprekent.org.uk/blog/the-lower-thames-crossing-aiding-and-abetting-a-killer-of-thousands/

Here is the consultation submission from the Dartford and Gravesham Cycling Forum:

• D&G cycle forum LTC Submission final

Our friends at the Lower Thames Crossing Association have put together a useful ‘Don’t Panic’ guide to responding; you can find it here: https://ltca.org.uk/featured/a-guide-to-completing-the-consultation-questionnaire

You can see our response, submitted today (20th), here: CPRE Kent response to LTC Statutory Consultation

• Finally, and perhaps most importantly, if you would like to have your say, follow this link:

https://highwaysengland.citizenspace.com/ltc/consultation/?gclid=CJn9t7OHn98CFZKThQodac0O4g

14th December 2018: Updated 20th December

• A number of important documents have yet to emerge. For example, a rigorous transport plan and a finalised air-quality assessment. The latter is critical given that allocations at Teynham will feed extra traffic into AQMAs.
• There seems to be no coherent plan for infrastructure delivery – a key component of the plan given the allocations being proposed near the already crowded Junction 7.
• There seems to have been little or no cooperation with neighbouring boroughs or even parish councils within Swale itself.

The removal of a second consultation might have been understandable if this final version of the plan were similar to that being talked about at the beginning of the consultation process. It is, however, radically different in the following ways:

• There has been a major shift in the balance of housing allocations, away from the west of the borough over to the east, especially around the historic town of Faversham. This is a move that raises many concerns.
• A new large allocation, with accompanying A2 bypass, has appeared around Teynham and Lynsted, to which we are objecting.
• Housing allocations in the AONB around Neames Forstal that were judged “unsuitable” by the council’s own officers have now appeared as part of the housing numbers.
• Most of the housing allocations being proposed are on greenfield sites, many of them on Grade 1 agricultural land – a point to which we are strongly objecting.

Concerns about the rush to submit the plan

The haste with which the plan is being prepared is especially worrying given the concentration of housing in Faversham. If the town is to take a large amount of new housing, it is imperative that the policies concerning the area are carefully worked out to preserve, as far as possible, the unique nature of the town. The rush to submit the plan is likely to prove detrimental.

As Swale does not have a five-year land housing supply, it is open to speculative development proposals, many of which would run counter to the ideas contained in the current plan. Some are already appearing. This is a common situation, and one that, doubtless, is a reason behind Swale’s haste.

Our overriding fear, however, is that this emphasis on haste is ultimately going to prove counterproductive. This is because it is our view that the plan, in its current form, is unlikely to pass independent examination. We are urging Swale to listen to and act upon the comments being made about the plan and to return the plan to the council with appropriate modifications before submitting it to the Secretary of State.

Essentially, this means treating the current consultation not as the final one but as the ‘lost’ second consultation.

The consultation ends on Friday 30 April and we strongly urge residents to make their opinions known if they have not already done so.

Further information

• Read more on the Swale Local Plan
• Read CPRE Kent’s detailed comments on the plan
• View the council’s consultation document