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Strongly opposed to damaging new crossing
CPRE Kent has raised significant concerns about the proposed Lower Thames crossing including fears over air quality, transport, devastation of areas of countryside and the complete failure of strategic planning which means it won’t even solve the problem.
Responding the Highways England consultation, we have stressed that we are strongly opposed to option C (bored tunnels from Gravesend) but we would also oppose option A at Dartford because of the longer-term induced traffic growth, congestion and reduction in air quality.
Director Hilary Newport said: “The planned crossing would damage important areas of countryside that are a vital ‘green lung’ to the urban population of the Medway towns, providing recreation and the opportunity for quiet enjoyment of the countryside which is so important for physical and psychological health.”
These areas include ancient woodland and Metropolitan Green Belt. There would also be an impact on the wider area, a loss of amenity in and around Shorne Country Park and the open landscapes to the north.
Post Opening Performance Evaluation (POPE) studies for new roads schemes have repeatedly shown that new road routes do not just relieve congestion, but create and attract new traffic.
There is already an over-reliance on the channel corridor and the channel crossings for the transport of goods to and from Europe. This should be an issue of national concern for the UK’s resilience and security. Not only is there the need to implement Operation Stack during periods of disruption, but even during normal operations, the Dover ‘Traffic Assessment Project’ (’Dover TAP’) is frequently used to hold back port-bound HGVs on the A20 to limit congestion and air pollution in Dover Town Centre. This of course simply displaces the same congestion and air quality concerns to other parts of the roads network.
Much of the freight traffic heading to Europe through Kent sets off from places remote from Kent, such as the logistics hubs in the Midlands and even as far away as Scotland and Ireland. The proportion of freight to or from the north using ports in southern England should be reduced. Existing roll-on roll-off ports (such as Newhaven, Portsmouth, Purfleet etc.) should be incentivised to offer both driver-accompanied and unaccompanied trailer services. There should also be support for roll-on roll-off freight facilities at new ports such as London Gateway.
It is also unacceptable that this consultation has been embarked upon under the assumption that rail has been “…ruled out as a solution to the problems at Dartford” (Consultation Document, p10) and that no consideration has been given to the use of additional ports north of the Thames.
The proposals take no account of the consequences on the wider highways network of a twin bore tunnel east of Gravesend. There will be an impact on the M2/A2 further afield, the A229 which links the M2 and M20 at Bluebell Hill within the Kent Downs Area of Outstanding Natural Beauty and the A2 between Faversham and Dover. Plus the proposals fail to mention what the elevated number of HGVs travelling through Kent will do when their drivers are forced to stop because of drivers’ hours regulations. We already suffer the blight of illegal overnight lorry parking on unsuitable roads.
Plus, because of the elevated risk of flooding in the area, adequate flood defences will be needed. which will have further significant landscape impacts.
Dr Newport said: “This is piecemeal highways planning that has failed to demonstrate integration with Kent’s highways network, and which is neither strategic nor soundly planned.”
Finally, we are very concerned about the negative effect on air quality. In April 2014, the Court of Justice of the European Union ruled that the UK must act rapidly to clean up illegal levels of air pollution. We query whether these proposals, which fail to consider any solutions other than the accommodation of ever-increasing road-based traffic, can possibly be pursued in the light of the CJEU ruling. A solution needs to be found to the current intolerable levels of air pollution at the existing Dartford Crossings. However the solutions proposed will ultimately make the existing problems significantly worse.
You can read our full submission here.
March 23rd 2016.
- 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
