Thames Gateway Bridge Inspector's Report

Report to the Secretary of State for Communities and Local Government and the Secretary of State for Transport
By Michael Ellison MA(Oxon)

An Inspector appointed by the Secretary of State for Communities and Local Government and the Secretary of State for Transport
The Planning Inspectorate 4/11 Eagle Wing Temple Quay House 2 The Square Temple Quay Bristol BS1 6PN 0117 372 6372
Date: 17 November 2006
Assisted by John Watson BSc(Hons), FIHT, MICE,

MCMI
TOWN AND COUNTRY PLANNING ACT 1990 HIGHWAYS ACT 1980 ACQUISITION OF LAND ACT 1981 NEW ROADS AND STREET WORKS ACT 1991 ooooo APPLICATIONS FOR PLANNING PERMISSION by TRANSPORT FOR LONDON in connection with THE PROPOSED THAMES GATEWAY BRIDGE THE A2012 GLA ROAD (THAMES GATEWAY BRIDGE) SPECIAL ROADS AND BRIDGE SCHEME 2004 THE A2012 GLA ROAD (THAMES GATEWAY BRIDGE) (SIDE ROADS) ORDER 2004 THE A2012 GLA ROAD (THAMES GATEWAY BRIDGE) COMPULSORY PURCHASE ORDER 2004 THE A2012 GLA ROAD (THAMES GATEWAY BRIDGE) TOLL ORDER 2004 ooooo
Inquiries opened on 7 June 2005 File refs: APP/G5750/V/05/1174146; APP/E5330/V/05/1174147; APP/G5750/V/05/1177533; DN5002/55/12/M/1; DN5002/55/7/1; DN5002/60/1/03
TABLE OF CONTENTS CASE DETAILS ...........................................................................................1 1 2 3 4 5 6 7 8 9 INTRODUCTION ...................................................................................3 DESCRIPTION OF THE SITE AND ITS SURROUNDINGS ........................ 17 LEGAL/PROCEDURAL SUBMISSIONS .................................................. 20 THE CASE FOR TRANSPORT FOR LONDON ........................................... 35 THE CASES OF THE SUPPORTERS ..................................................... 145 THE CASES OF THE OBJECTORS .....................................................15682 REPRESENTATIONS ..466 OVERALL RESPONSE BY TRANSPORT FOR LONDON........................46673 CONCLUSIONS...............................................................................46687
10 RECOMMENDATIONS ........................................................................ 578
Thames Gateway Bridge Inquiry - Abbreviations used in this Report AADT AGAB AOD AQMA AST BCG CAA CABE CEMM COBA COMEAP CPRE CPS CTRL CSDSE DBFO Annual Averaged Weekday Traffic Flow Action Group Against the Bridge Above Ordnance Datum Air Quality Management Area Appraisal Summary Table Boroughs Consultative Group Civil Aviation Authority Commission for Architecture and the Built Environment Construction Environmental Management Manual Cost Benefit Analysis The Committee on the Medical Effects of Air Pollution Campaign to Protect Rural England Crown Prosecution Service Channel Tunnel Rail Link The Commission on Sustainable Development in the South East The proposed design, build, finance, operate concession intended to be used to secure the construction and operation of the proposed Thames Gateway Bridge Department for Environment, Food and Rural Affairs Department for Transport The Docklands Light Railway Design Manual for Roads and Bridges A reference to the inquiry transcript, Day - Page - Line Environment Agency English Heritage Economic Impact Report The proposed East London River Crossing, considered at public inquiries in 1985/86 and 1990/91 East London Transit Ecological Management Plan English Nature Environmental Research Group The Environmental Statement for the scheme Friends of the Earth Greenwich Action to Stop Pollution Gross Domestic Product The result of a calculation that combines the absolute and percentage differences between modelled and observed traffic flows to give a measure of goodness of fit. Greater London Authority Greater London Authority Act 1999 Greenwich and Lewisham Friends of the Earth Greenlands in Trust
DEFRA DfT DLR DMRB D-P-LEA EH EIR ELRC ELT EMP EN ERG ES FoE GASP GDP GEH
GLA GLAA 1999 GLFoE GLIT
Greenwich GTL GWAG GWT ha HA 1980 HGV HIA IMD ITEA km LATS LB LCA LCC LCY LDA LIP LMVR LSC LTGF LTUC m MCEU MHNRA NAO NATA NEFG Newham NPV NRTF NTEM PARC PCPA 2004 pcu PFI PIA PLA PPG PPS SACTRA SATURN SBI
The London Borough of Greenwich Gateway to London Greenwich Wildlife Advisory Group Greenwich Waterfront Transit hectare(s) Highways Act 1980 Heavy Goods Vehicle Health Impact Assessment Index of Multiple Deprivation Integrated Transport, Economics and Appraisal Division of the Department for Transport kilometre(s) London Area Transport Survey London Borough (as in LB Bexley London Borough of Bexley) Landscape Character Area London Cycling Campaign London City Airport London Development Agency Local Implementation Plan Local Model Validation Report Learning and Skills Council London Thames Gateway Forum London Transport Users Committee metre(s) Marine Consents and Environment Unit Manor House Neighbourhood Residents Association National Audit Office New Approach to Appraisal Bexley LA21 Natural Environment Focus Group The London Borough of Newham Net Present Value National Road Traffic Forecasts National Trip End Model People Against the River Crossing Planning and Compulsory Purchase Act 2004 Passenger car units, a standardised unit of traffic volume Private Finance Initiative Personal injury accident The Port of London Authority Planning Policy Guidance Planning Policy Statement Standing Advisory Committee for Trunk Road Assessment Simulation and Assignment of Traffic in Urban Road Networks computer programme Site of Borough Importance for Nature Conservation
SDS SEA SELSHA SMI SMRA SNCI SOA SRA SSSI SWCF T2000 TCPA 1990 TEMPRO TfL TGB TGLP the Boroughs Agreement the Compulsory Purchase Order the construction site application the Development Corporation the inquiry
The Governments Sustainable Development Strategy Strategic Environmental Assessment South East London Strategic Health Authority Site of Metropolitan Importance for Nature Conservation St Michaels Residents Association Site of Nature Conservation Importance Super Output Area Saints Residents Association Site of Special Scientific Interest Simon Wolff Charitable Foundation Transport 2000 Town and Country Planning Act 1990 The National Trip End Model Transport for London The proposed Thames Gateway Bridge Thames Gateway London Partnership An agreement under S 106 TCPA 1990 and other powers between TfL, and the London Boroughs of Barking & Dagenham, Greenwich, Newham and Redbridge The A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 Application P/05/0428 made by TfL to Newham dated 10 March 2005 The London Thames Gateway Development Corporation The concurrent inquiries held into the Special Roads Scheme, the Side Roads Order, the Compulsory Purchase Order, the Toll Order and the planning applications Application P/04/1170 made by TfL to Newham dated 20 July 2004 and application 04/1800/F made by TfL to Greenwich dated 20 July 2004 Application P/04/1170 made by TfL to Newham dated 20 July 2004, application 04/1800/F made by TfL to Greenwich dated 20 July 2004 and application P/05/0428 made by TfL to Newham dated 10 March 2005 The A2012 GLA Road (Thames Gateway Bridge) (Side Roads) Order 2004 The A2012 GLA Road (Thames Gateway Bridge) Special Roads and Bridge Scheme 2004 The South Woodford to Barking Relief Road The A2012 GLA Road (Thames Gateway Bridge) Toll Order 2004 Unitary Development Plan Woolwich and District Antiquarian Society World Health Organisation Zone of Visual Influence
the main bridge applications the planning applications
the Side Roads Order the Special Roads Scheme the SWBRR the Toll Order UDP WDAS WHO ZVI
REPORT TO THE SECRETARY OF STATE FOR COMMUNITIES AND LOCAL GOVERNMENT AND THE SECRETARY OF STATE FOR TRANSPORT - THE THAMES GATEWAY BRIDGE INQUIRY ___________________________________________________________________________________________
CASE DETAILS Appeal ref: APP/G5750/V/05/1174146 Land adjoining A406, A13, A1020 Royal Docks Road and Armada Way, London E6 and IG11 together with part of the River Thames at Gallions Reach, London E6 This application (ref: P/04/1170) was made by Transport for London (TfL) to the London Borough of Newham (Newham) and is dated 20 July 2004. It was called in for decision by the First Secretary of State (who was then responsible for these matters) under Section 77 of the Town and Country Planning Act 1990 (TCPA 1990) on 19 January 2005. The development proposed is Thames Gateway Bridge, linking the A13/A406 in Beckton to the A2016 Eastern Way, Thamesmead, and associated works and buildings. Summary of Recommendation: That planning permission be refused.
Appeal ref: APP/E5330/V/05/1174147 Part of River Thames at Gallions Reach, London SE28, and land between the River Thames and A 2016 Eastern Way, Thamesmead, London SE28 This application (ref: 04/1800/F) was made by TfL to the London Borough of Greenwich (Greenwich) and is dated 20 July 2004. It was called in for decision by the First Secretary of State under Section 77 of the TCPA 1990 on 19 January 2005. The development proposed is Thames Gateway Bridge, linking the A13/A406 in Beckton to the A2016 Eastern Way, Thamesmead, and associated works and buildings. Summary of Recommendation: That planning permission be refused.
Appeal ref: APP/G5750/V/05/1177533 Land east of Armada Way, Beckton, London E6 This application (ref: P/05/0428) was made by TfL to Newham and is dated 10 March 2005. It was called in for decision by the First Secretary of State under Section 77 of the TCPA 1990 on 24 March 2005.
The development proposed is an additional area for a construction work site and an amendment to the area shown as a construction work site for the Thames Gateway Bridge in application ref P/04/1170. Summary of Recommendation: That planning permission be granted subject to the conditions referred to in the formal decision and set out in Appendix E to this report.
Scheme ref: DN5002/55/12/M/1 The A2012 GLA Road (Thames Gateway Bridge) Special Roads and Bridge Scheme 2004 This Scheme is made under Sections 16, 17 and 106 of the Highways Act 1980 (HA 1980), and is referred to in this report as the Special Roads Scheme. The Special Roads Scheme was made on 5 August 2004, and submitted to the Secretary of State for Transport for confirmation. There were 2,320 objections specifically to the Special Roads Scheme outstanding at the commencement of the inquiries, together with 629 objections to the scheme generally. The Order would authorise TfL to provide a new special road, 3.37km in length, between Beckton and Thamesmead, including a stretch over the navigable waters of the River Thames, together with four connecting special roads. Summary of Recommendation: That the Scheme be not confirmed.
Order ref: DN5002/55/7/1 The A2012 GLA Road (Thames Gateway Bridge) (Side Roads) Order 2004 This Order is made under Sections 14, 18 and 125 of the HA 1980, and is referred to in this report as the Side Roads Order. The Order was made on 5 August 2004, and submitted to the Secretary of State for Transport for confirmation. There were 2,314 objections specifically to the Side Roads Order outstanding at the commencement of the inquiries. The Order would authorise TfL to improve highways, stop up highways, construct new highways and provide new means of access to premises in the vicinity of the proposed special roads which would be authorised by the Special Roads Scheme. It would provide the interface between the special roads and the existing highway system. It would also authorise TfL to transfer certain of the new highways constructed to the highway authorities of Newham and Greenwich. Summary of Recommendation: That the Order be not confirmed.
Order ref: DN5002/60/1/03 The A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 This Order is made under Sections 239, 240, 245, 246, 249, 250 and 260 of the HA 1980, and is referred to in this report as the Compulsory Purchase Order. The Order was made on 12 August 2004, and submitted to the Secretary of State for Transport for confirmation. There were 1,670 objections specifically to the Compulsory Purchase Order outstanding at the commencement of the inquiries, of which 12 were statutory objections. The Order would authorise TfL to acquire compulsorily the land and interests in land listed in the schedule to the Order, to carry out the work which would be authorised by the Special Roads Scheme and the Side Roads Order, if confirmed, including mitigation works and the provision of exchange public open space. Summary of Recommendation: That the Order be not confirmed.
Order ref: Toll Order The A2012 GLA Road (Thames Gateway Bridge) Toll Order 2004 This Order is made under Sections 6, 7 and 13 of the New Roads and Street Works Act 1991, and is referred to in this report as the Toll Order. The Order was made on 5 August 2004, and submitted to the Secretary of State for Transport for confirmation. There were 2,112 objections specifically to the Toll Order outstanding at the commencement of the inquiries. The Order would authorise TfL to set the toll charge within a prescribed maximum in relation to a one way use of the proposed Thames Gateway Bridge for a period of forty years from its opening.
Summary of Recommendation: That the Order be not confirmed.
INTRODUCTION
The purpose and scale of the proposals 1.1 The Thames Gateway Bridge (TGB) scheme would provide a new crossing of the River Thames between Beckton and Thamesmead, with a view to reducing the barrier to the movement of people and goods that is formed by the river. The scheme seeks to improve accessibility to and within the Thames Gateway area in order to support the regeneration of East London.
3
1.2
The Thames Gateway area comprises a corridor stretching eastwards on both banks of the river from the City of London and Lewisham in inner London, across the Metropolitan boundary, to Thurrock and Gravesham in the east. The scheme would provide a four lane dual carriageway road (with two lanes in each direction) for general highway traffic between the A13/A406 junction at Beckton and the A2016 in Thamesmead. In addition, there would be two segregated public transport lanes across the TGB and on sections of the approach roads to the north and south, and pedestrian and cycle routes would also be provided. The actual bridge would be approximately 650m long and about 33m wide. It would be designed to fit within the constraints imposed by the requirements of shipping on the River Thames and of aircraft movements to and from London City Airport (LCY), the runway of which extends to within approximately 1.4km of the site of the proposed bridge. The proposed location for the bridge is shown on Figure 1.1 of Document D809, and the proposed carriageway, cycleway and footway arrangement is shown clearly in cross section on Document TfL/23.
1.3
1.4
1.5
The planning applications 1.6 The main planning applications for the TGB (the main bridge applications), submitted to Newham and to Greenwich in July 2004, are expressed to be applications for full permission which are hybrid in form. The applications seek full planning permission for: a. the horizontal and vertical alignment of carriageways, footways and cycleways; b. embankments and retained embankments; c. slip roads and connections to the existing highways network; d. balancing ponds; e. remediation of land for use as replacement open space land with proposed access from the riverside path at Thamesmead; and f. temporary planning permission for work sites and river wharves. 1.8 On the other hand, planning permission for the following elements of the scheme is sought subject to conditions requiring details to be submitted for the approval of the local planning authorities, and requiring those details to
4
1.7
be in line with the parameters set out in a Design Statement submitted with the applications: a. bridge structures, including the location of the piers; b. the maintenance compound and revenue collection office; and c. the pumping stations. 1.9 In reality, the two main bridge applications amount to a single planning proposal for the construction of the TGB. Two applications were submitted only because parts of the proposed development fell within the areas of the two local planning authorities. The hybrid nature of the applications arises from the fact that the proposed development would be achieved, if permitted, by a Design, Build, Finance and Operate (DBFO) concession. This makes it impossible in practice to specify at this stage the precise detail of the bridge structure and the associated buildings. The promoters ask that landscape design should also be dealt with in planning conditions, because the detail of the landscaping would be dependent on the detailed design of the bridge structure. Such conditions would, however, be drafted in line with the design principles described in a Landscape and Urban Design Strategy Report, which was also submitted with the main bridge planning applications. Following submission of the main bridge applications, as a result of consultation between TfL and landowners who would be directly affected by the scheme, two amendments to the original scheme were submitted to the two local planning authorities. The application to Greenwich was amended on 5 November 2004 by the realignment of the public transport lane at Barnham Drive to avoid the sites of recently constructed houses and a pumping station. The application was also amended to provide for the relocation of an existing temporary haul route, which would otherwise have conflicted with the proposed public transport lane. The application to Newham was amended on 22 November 2004 by the upgrading of the footway providing access across the proposed A2012 special road to include provision for cyclists. Each of these amendments was accepted by the relevant local planning authority, and was taken into account when the application was considered. That consideration by the local planning authorities took place in Greenwich on 14 December 2004 and in Newham on 15 December 2004. Greenwich resolved to grant full planning permission, subject to conditions, to the satisfactory completion of a legal agreement and to referral to the Mayor of London and to the Government Office for London (Document
5
1.10
1.11
1.12
1.13
1.14
D846). Newham resolved that the Council was minded to approve the application, again subject to conditions, the completion of a legal agreement and to any direction from the Mayor of London (Document D847). 1.15 By letters dated 23 December 2004, notice was given on behalf of the Mayor of London that he would not direct refusal of the applications. Because the Mayor had been involved in promoting the project, and having regard to his position as Chair of TfL, he delegated his power to direct refusal to the Chief Executive of the Greater London Assembly. The decision not to direct refusal was thus in fact taken by Mr Anthony Meyer. By letters dated 19 January 2005, however, the First Secretary of State exercised his powers under Section 77 of the TCPA 1990 to call in the two main bridge applications for his own determination. In each case, the reason for this direction was expressed to be because the Secretary of State considered that the proposals might conflict with national and regional policies on important matters. Application P/05/0428 (the construction site application) was submitted by TfL to Newham in March 2005. It is a full application. It was put forward by TfL to seek to resolve an objection to the scheme by SecondSite Property Holdings Ltd. The proposal would reduce the extent of the work site shown in the main planning application to Newham to the north east of the proposed bridge abutment, and substitute an equivalent area of some 3.4ha to the south west of the bridge abutment. By letter dated 24 March 2005, this application was also called in for determination by the First Secretary of State under Section 77 of the TCPA 1990. The reason for the call in was that the Secretary of State considered that the application should not be dealt with in isolation from the main bridge applications. Following the call in decisions, further amendments to the main planning applications were submitted by TfL on 26 April 2005, designed to respond to the Port of London Authority (PLA)s requirement for 50m wide navigation channels in each of the side spans of the proposed bridge. Public notice of these amendments was given on 27 April 2005. The application originally submitted to Greenwich was also amended in September 2005, during the course of the inquiry, by a revision of the way in which the public transport route would leave the bridge and connect with Barnham Drive. This amendment was also publicly advertised. It generated no fresh objection. In relation to the main bridge applications, the Secretary of State specified the following matters about which he particularly wished to be informed for the purposes of his consideration of the applications: a. The extent to which the proposal conforms to the adopted development plan, including the Spatial Development Strategy for Greater London,
6
1.16
1.17
1.18
1.19
1.20
having regard to Section 38(6) of the Planning and Compulsory Purchase Act 2004 and other material considerations, including, in relation to the London Borough of Greenwich, the extent to which the application may be premature, having regard to progress towards adoption of the emerging Greenwich Unitary Development Plan. b. The extent to which the proposal accords with national planning policy on transport set out in Planning Policy Guidance Note 13 - Transport (PPG13), particularly with regard to: i. the impact of the proposal on traffic generation and overall travel patterns having regard to the desirability of achieving development that minimises the need to travel, particularly by private car; maximising use by non car modes of travel, particularly public transport, cycling and walking; the impact of the development on traffic congestion in the local area.
ii.
iii.
c. The effects of noise and pollution, including air quality, (Planning Policy Statement 23 (PPS23) - Planning and Pollution Control and PPG24 Planning and Noise) on the surrounding areas arising from: i. ii. construction of the bridge; the traffic which would be generated by the proposal if it was operational.
d. The extent to which the proposed development would be likely to have an impact on the local flora and fauna and any conservation sites, having regard to the Governments policies in PPG9 - Nature Conservation on conserving the diversity of wildlife and their habitats. e. The extent to which the proposal would, if granted planning permission, secure a high quality of design, having regard to the general advice in PPS1 and current advice on good design practice contained in By Design - Urban design in the planning system: towards better practice. f. Any implications of the proposal for regeneration of the Thames Gateway and other deprived areas particularly with regard to employment and other economic impacts. g. Whether any permission should be subject to conditions and, if so, the form which they should take. h. Any other relevant material planning considerations.
7
1.21
No additional matter requiring particular information was identified by the Secretary of State as a result of the calling in of the construction site application. Following a transfer of Ministerial functions, responsibility for the decision on the planning applications now rests with the Secretary of State for Communities and Local Government. With the coming into operation on 31 October 2005 of the London Thames Gateway Development Corporation (Planning Functions) Order 2005 (SI 2005 No 2721), responsibility for planning functions over most of that part of the application site falling within Newham passed to the London Thames Gateway Development Corporation (the Development Corporation). The boundaries of the Development Corporations development control responsibilities are shown on Document TfL/24Q. In relation to the application site, however, Newham remain responsible for the half width of the River Thames adjacent to the Newham shore and the footpaths and landscape areas to the west of the A1020 Royal Docks Road between the Docklands Light Railway (DLR) underbridge and the A13 junction. Both Newham and the Development Corporation have therefore taken part in the proceedings of the inquiries. Of the two bodies, the principal role has been taken by Newham, who supply development control services to the Development Corporation under an agency agreement.
1.22
1.23
Environmental assessment 1.24 An Environmental Statement (ES) was submitted with the planning applications. It comprises Document D808. It was supplemented by a set of Figures (Document D809), the Design Statement and the Landscape and Urban Design Strategy Report (Documents D810 and D811) and a set of general appendices (Document D812). The Non-Technical Summary comprises Document TfL/25. The Design Statement and the Landscape and Urban Design Strategy Report were replaced by an updated Design Statement (Document D855) in March 2005. The original ES was also supplemented by three addenda: a. Addendum 1 (Document D853), introduced in March 2005, dealt with modifications to the scheme introduced prior to the start of the inquiry, including the replacement construction work site, and also provided further information on two points requested by the Secretary of State the noise assessment reported in the original ES, and the extent to which mitigation measures would offset significant adverse environmental effects of the scheme. The Non-Technical Summary of Addendum 1 is contained in Document TfL/26. b. Addendum 2 (Document TfL/153), introduced in September 2005, dealt
8
1.25
1.26
with alterations to the scheme arising from the amended design for public transport access to the scheme in the Barnham Drive area of Greenwich. The Non-Technical Summary of Addendum 2 is contained in Document TfL/154. c. Addendum 3 (Document TfL/212, as amended by Document TfL/235), introduced in December 2005, dealt with the environmental implications of updated evidence on traffic introduced to the inquiry by the promoters in November 2005. The Non-Technical Summary of Addendum 3 is contained in Document TfL/213. The Scheme and the Orders 1.27 The Special Roads Scheme would determine the types of traffic which would be able to use the two lane dual carriageway of the TGB and the new connecting roads; it would also allow for the road to be tolled under the New Roads and Street Works Act; and it would authorise the construction over navigable waters of the TGB itself. The Scheme originally submitted comprises Document D834, but TfL seek confirmation of the Scheme in a modified form, as outlined in Document D859. The modifications requested by TfL to reflect the requirements of the PLA (as outlined in paragraph 1.18 above) would limit the range of the main span of the proposed bridge to between 270m and 290m. Document D859 also contains details of modifications requested by TfL to the Side Roads Order in the area of Barnham Drive/Grasshaven Way, Greenwich. Further modifications to this Order were sought as a result of the amendment to the Greenwich planning application made in September 2005 and referred to in paragraph 1.19 above. The Compulsory Purchase Order as originally submitted (Document D832) would have affected around 38ha of land in Newham and around 27ha of land in Greenwich. Amendments requested to this Order during the course of the inquiry would mean that the total area affected in Newham, if the Order were confirmed in the form now sought by the promoters, would be around 34.4ha, and in Greenwich around 26.3ha. The land which would be affected in Greenwich includes public open space, and the Order includes land to compensate for the proposed loss of that open space land. Application has been made by TfL for a certificate under Section 19(1)(a) of the Acquisition of Land Act 1981, confirming the acceptability of the proposed replacement open space land. There was no objection to the application for a Section 19 certificate, and the Secretary of State has apparently confirmed to TfL that such a certificate would be issued if the Compulsory Purchase Order were to be confirmed (paragraph 13.36 of Document TfL/15). Document TfL/313C/1 comprises the Compulsory Purchase Order in the modified form in which the promoters now seek its confirmation.
1.28
1.29
1.30
1.31
The Toll Order (Document D835) is promoted with the aim of ensuring through differential tolling that the TGB serves local rather than strategic traffic. It is also seen as providing a mechanism to regulate volumes of traffic over the bridge, and to assist in providing the funding for the bridge. Detailed drafting amendments to the Toll Order requested by TfL with a view to removing ambiguities in the Order are set out in Document TfL/332, and a further requested amendment is contained in Document TfL/214.
The public inquiries 1.32 Originally, the Lead Inspector for these inquiries was to be Mr R M Barker. Mr Barker conducted a Pre Inquiries Meeting on 4 April 2005. A note of that meeting comprises Document PID/1. Following my appointment as Lead Inspector, I held a further Procedural Meeting on 28 April 2005. A note of that meeting comprises Document PID/2. At both the Pre Inquiries Meeting and the Procedural Meeting, objectors to the applications and to the Scheme and Orders requested a postponement of the advertised starting date of the public inquiries. I reported on this request to the Secretaries of State on 9 May 2005, and the Secretaries of State issued their decision on the application on 17 May 2005. The decision was that the inquiries should open, as planned, on 7 June 2005, but that, following the hearing of the cases for the promoters, the supporters and any objector who wished to be heard during that first session of the inquiries, the inquiries should adjourn until 13 September 2005, when the cases of the remaining objectors would be heard. My report to the Secretaries of State on the issue of postponement is Document PID/3, and the decision letter on the issue is Document PID/4. John Watson sat as Assistant Inspector at the Procedural Meeting on 28 April 2005 and at the inquiries. I take this opportunity to record my gratitude to him for his assistance and support in the preparation for the inquiries, the hearing of the cases and the preparation of this report. The report and its recommendations are, however, solely my responsibility. I also wish to record my keen appreciation of the work of Graham Groom, who acted as Programme Officer for the inquiries, together with the valuable contributions made by a number of Mr Grooms colleagues from Persona Associates, notably Mr Chris Banks, who effectively took over as Programme Officer at the inquiries venue during the latter stages of the inquiries. The inquiries sat on: 7, 8, 9, 10, 14, 15, 16, 17, 21, 22, 23, 24, 28 and 30 June 2005
1.33
1.34
1.35
1.36
1.37
10
1, 5, 6, 7, 8, 20, 21, 22, 26 and 27 July 2005 13, 14, 15, 16, 21, 22, 23, 27, 28, 29 and 30 September 2005 4, 5, 6, 7, 11, 12, 13, 19, 20 and 21 October 2005 8, 9, 10, 11, 15, 16, 17 and 24 November 2005 2, 20 and 22, December 2005 21, 22, 23, 24 and 28 February 2006 1, 2, 3, 7, 8, 9, 10, 14, 15, 16, 17, 21, 22, 24, 28, 29 and 30 March 2006 4, 5, 18, 19, 20, 21, 25 and 26 April 2006 3 May 2006. All of these sittings took place at the premises of Charlton Athletic Football Club, The Valley, Floyd Road, Charlton, London SE7 8BL. Evening sessions of the inquiries were also held on 10 October 2005 and 16 November 2005 at the Bexley Civic Offices, The Broadway, Bexleyheath and on 13 March 2006 at The Marriott Hotel, 1 The Broadway, Bexleyheath. 1.38 An offer was made at the Pre Inquiries Meeting and at the Procedural Meeting to hold evening sessions of the inquiries to the north of the River Thames in Newham, if demand for such provision existed. This offer was regularly repeated at the inquiries. Despite contact from the Programme Officer, however, nobody who had indicated an intention to appear at the inquiries wished to take up the offer to make that appearance at an evening session in Newham. No evening session of the inquiries was therefore held to the north of the River. An original plan (referred to in Documents PID/3 and PID/4) to hold the second phase of the inquiries from September 2005 at Woolwich Town Hall was not pursued, because the venue would not have been available for parts of the required period, and the vast majority of the parties in regular attendance at the inquiries indicated that, in that situation, they would prefer sittings of the inquiries to continue at Charlton. I was present at all the sittings of the inquiries apart from that which took place on 15 November 2005. On that date, I was prevented by adverse weather conditions from returning to Charlton to sit at the inquiries. All parties present on 15 November agreed that the sitting of the inquiries planned for that date should continue with Mr Watson in the chair. By
11
1.39
1.40
agreement, the London Cycling Campaign, who appeared to make their objection on 15 November, were allowed to reiterate the gist of their opening submissions when they delivered their reserved closing on 26 April 2006. 1.41 Mr Watson was present at all sittings of the inquiries apart from that which took place on 20 December 2005. Because a transcript of the proceedings of the inquiries was made (Document INQ/2), it was possible for each of us to read verbatim the evidence given on the day on which we were not able to be present. I made a site visit to areas affected by the proposals before the inquiries, accompanied only by Mr Barker, on 4 April 2005, and a further visit, accompanied only by Mr Watson, on 27 April 2005. At the suggestion of one of the parties, a site visit to certain sites was made by Mr Watson and me on 29 June 2005 in the company of representatives of the promoters and of the objectors. The sites concerned are listed in Document TfL/62. It was considered that there would be advantage in viewing these sites during the summer months, given that it seemed likely at the time that the normal accompanied site visit towards the end of the inquiries would be taking place during winter. In fact, that proved not to be the case, since the accompanied site visits just before and after the close of the inquiries took place on 27 and 28 April and on 4 May 2006. Mr Watson and I also made a further unaccompanied site visit during the hours of darkness on 3 May 2006 to locations agreed in advance with the parties. When notice of the inquiries was given on 25 February 2005, the Secretary of State for Transport directed that details of any alternative route which a party wished to suggest that a highway or proposed highway should follow should be submitted to him not later than 22 April 2005. No such alternative route was submitted by any party to the inquiries. The inquiries notice also provided for proceedings on the Scheme and the Orders to be taken concurrently by virtue of Section 257 of the HA 1980. Given the close connection between the Scheme and the Orders and the planning applications, it was agreed at the Procedural Meeting on 28 April 2005 (paragraph 2.2 of the note of the Meeting, Document PID/2) that the inquiries into the planning applications would also be taken concurrently. That being so, in the balance of this report I shall refer to the concurrent inquiries as the inquiry. Another matter agreed at the Procedural Meeting (at paragraphs 5.1 and 5.2 of the note) was that the conflict between the requirements of Rule 15(4) of the Town and Country Planning (Inquiries Procedure) (England) Rules 2000 on the one hand, and Rule 15 (2) of the Compulsory Purchase by Non-Ministerial Acquiring Authorities (Inquiries Procedure) Rules 1990 and Rule 24(2) of the Highways (Inquiries Procedure) Rules 1994 on the other hand, should be resolved in favour of the 1990 and the 1994 Rules.
12
1.42
1.43
1.44
1.45
1.46
This decision was implemented at the inquiry. 1.47 A Statement of Common Ground was agreed between TfL, Newham and Greenwich on 9 May 2005. It comprises Document TfL/17. It covers the development for which permission is sought; the planning history; the scheme objectives; national and regional guidance; the development plan; highway matters; public transport development; environmental consequences; planning conditions and legal agreements; and other matters. Reference will be made to it as appropriate in this report, though it should be noted that in some respects (for example, in relation to planning conditions and legal agreements) the positions of the parties to the Statement of Common Ground developed during the course of the inquiry. An inquiry website was operational by 7 March 2005 at www.persona.uk.com/thamesgateway/index.htm. It includes (among other items) a list of the deposit documents for the inquiry, many of which are available in electronic form for downloading. At the opening of the inquiry, it was confirmed by TfL, by Newham and by Greenwich that the relevant statutory formalities for which each of them was responsible had been carried out. (At that stage, the Development Corporation had not acceded to its planning responsibilities in the area.) There was no objection raised regarding the statutory formalities at the opening of the inquiry, but I raised an issue with TfL concerning the deposit of documents in connection with the inquiry. This issue is discussed in detail at paragraphs 3.28 to 3.40 and 9.5 to 9.15 below. A written representation had also been made by Mr J P OHara regarding an aspect of the formalities in connection with the Toll Order. This is dealt with at paragraphs 3.41 and 3.42 and at paragraph 9.16 below.
1.48
1.49
Objections and representations 1.50 There were 2,949 objections outstanding to the Special Roads and Bridge Scheme or to the TGB proposal generally before the inquiry when it opened. Most of these were objections to the principle of a Thames crossing open to general vehicular traffic in this location. Of this total of 2,949 objections, 2,836 were contained in petitions (608) or in one of eight standard form letters of objection (2,228). Some 143 of these standard forms were signed by or on behalf of more than one (usually two) people. On the other hand, there were 47 expressions of support for the proposal, 11 of which were in standard form. There were also 12 representations. These documents are contained in 11 folders of objections and representations which accompany this report. No representation had been received either for or against the called in construction site application, and no representation had been received regarding the advertised amendment to the main bridge applications referred to in paragraph 1.18 above.
13
1.51
1.52
During the inquiry, 1,819 further written representations were received which were opposed to the proposed development, all but 35 of them in standard form. Nine written representations in support of the development were received. There were two further representations. These additional letters are contained in a further 6 folders of objections and representations, which again accompany this report. Twenty two objections were withdrawn during the inquiry. These included all the twelve statutory objections to the Compulsory Purchase Order which had remained outstanding at the opening of the inquiry. Five objections to the Special Roads Scheme, six objections to the Side Roads Order, and four objections to the Toll Order were also withdrawn during the inquiry. (These numbers do not add up to 22, because some objectors had objected to more than one of the Orders.) Copies of the letters withdrawing those objections are contained in Document INQ/30. Two objections to the Toll Order were withdrawn not by letter but by way of mention by the advocate concerned in closing the case of the party which had made the objection. One of the objections withdrawn during the inquiry was that submitted on behalf of Tate & Lyle Industries Ltd. I mention it particularly because, at the opening of the inquiry, Mr Watson declared that he had a small shareholding in Tate & Lyle, and that he would take no part in the consideration of issues raised by that Companys objection - access by river to their premises. The main grounds of objection to the proposals were: a. that they did not conform to the Development Plan for the area or to national planning guidance. b. that the traffic modelling carried out by the promoters was inadequate. c. that the proposed development would lead to unacceptable levels of traffic congestion, especially in LB Bexley. d. that the consequences of additional traffic arising from the proposed development would lead to unacceptable levels of air and noise pollution. e. that the proposed development was in reality the first phase of a plan to link the A406 to the A2 by means of a motorway standard road. f. that the proposed development would not deliver the regeneration benefits claimed for it. g. that the proposed development would have an unacceptable impact on wildlife and nature conservation. h. that the public consultation in relation to the proposed development had
14
1.53
1.54
been inadequate. i. that the tolling arrangements envisaged under the Toll Order were unacceptable.
j. that there were more acceptable ways in which the benefits aimed at by the proposed development could be achieved. 1.55 Some 62 objectors appeared at the inquiry, including some who were representing significant numbers of people opposed to the proposals. Seven supporters appeared at the inquiry. A full list of the appearances is attached as Appendix A to this report. An amount of 50,000 was initially made available by the promoters at the request of the Mayor of London in February 2005 to assist local residents objecting to the TGB project in preparing and presenting their case. These funds were, I understand, used principally to engage expert witnesses, who provided evidence upon which a number of objectors relied. The witnesses concerned are listed in Appendix A as appearing for an informal alliance of objectors. On behalf of individual objectors, some of these expert witnesses also cross examined witnesses for TfL and for their supporters who had given evidence within the area of expertise of the expert witness concerned.
1.56
Adjournments of the inquiry 1.57 During the inquiry, there were three significant adjournments and a further period during which few sittings of the inquiry took place. As indicated at paragraph 1.34 above, in confirming that the inquiry would open as planned on 7 June 2005, the Secretaries of State agreed that there would be an adjournment (which in effect ran from 27 July to 13 September 2005) to allow those objectors who required it more time to prepare their cases. On 21 July 2005, the promoters indicated that, in the light of evidence which had been adduced by L B Bexley to the effect that traffic in their area had increased to a greater extent than the promoters evidence suggested was the case, further traffic counts would be undertaken during September 2005 to create a revised traffic model. That work was done, and the revised traffic figures were presented to the inquiry on 10 November 2005, initially in Document TfL/200. On 30 November 2005, Document TfL/202 indicated the way on which these new traffic figures would alter and supplement the existing traffic evidence before the inquiry. In turn, this had an impact on the economic and environmental evidence before the inquiry. Seven of the promoters witnesses therefore read additional proofs of evidence and answered questions of clarification at the inquiry on 20 December 2005.
1.58
1.59
15
1.60
At my request, the knowledge that further evidence on this scale would be introduced was drawn to the attention of all active parties to the inquiry by the Programme Officer on 14 November 2005. This led to some parties who had already completed giving their evidence to the inquiry wishing to supplement that evidence, either in writing or by returning to the inquiry to give further oral evidence. It also led to some parties who were scheduled to appear at the inquiry in late November or December 2005 asking to defer their appearances until the additional evidence from the promoters was all available. For that reason, the inquiry sat on only two days between 17 November 2005 and 20 December 2005. The impact of the promoters new evidence on the forward programme of the inquiry was considered at a sitting of the inquiry on 22 December 2005. After lengthy discussion of the implications for parties (fully covered in the transcript for Day 57), I adjourned the inquiry until 21 February 2006. This adjournment was to allow the parties to assimilate the new evidence of the promoters, to prepare any evidence in response to an agreed timetable, and to arrange for the availability in some cases of advocates and expert witnesses. There was also an adjournment between 5 and 18 April 2006 to reflect the timing of the local school holidays for Easter. Those holidays were arranged for the period immediately before Easter Sunday. Following the introduction of the new traffic count evidence by the promoters, TfL agreed to make available, again at the request of the Mayor of London, a further sum of 15,000 to be spent by third party objectors on obtaining supplementary reports confined to the consideration of the revised traffic forecasts and their implications for the TGB proposals.
1.61
1.62
1.63
Agreement under Section 106 of the TCPA 1990 and other powers 1.64 Early in the inquiry, TfL submitted Document TfL/22, a draft Agreement between themselves, Newham, Greenwich and the London Boroughs of Barking & Dagenham, Bexley and Redbridge, to be made under Section 106 of the TCPA 1990, Section 111 of the Local Government Act 1972 and Section 2 of the Local Government Act 2000. It is referred to in this report as the Boroughs Agreement. By the conclusion of the inquiry, it was clear that this Agreement was not acceptable to L B Bexley. Document TfL/22C comprises an executed Boroughs Agreement between TfL, Newham, Greenwich, and the London Boroughs of Barking & Dagenham and Redbridge. It provides a mechanism for monitoring traffic and its environmental implications, implementing and financing mitigation measures, the provision of information to the Boroughs, and their involvement in the formulation of policy on the use of the bridge by public transport services and on tolling policy. I deal with this Agreement in detail at paragraphs 4.433 to 4.439 and at 9.316 to 9.327 below.
16
1.65
1.66
Document TfL/22D comprises an executed Unilateral Undertaking offered by TfL to L B Bexley, in effect guaranteeing Bexley the benefits of the Boroughs Agreement.
Structure of this report 1.67 Section 2 of this report contains a description of the site which would be subject to the proposed development, together with a description of the immediately surrounding areas. Section 3 sets out a number of legal and procedural submissions made during the course of the inquiry. Section 4 gives the gist of the case for TfL, the promoters of the TGB scheme. Section 5 sets out the gist of the cases of the supporters, and Section 6 outlines the main points of the cases of the objectors, together with the response of TfL to the specific points raised by way of objection where such an individual response was made. Section 7 records the gist of the representations received regarding the proposed development. Section 8 sets out the main points of the overall response of TfL to the objections and representations. Section 9 comprises my conclusions, and my recommendations are set out in Section 10. The documents listed in Appendix B to the report include proofs of evidence submitted to the inquiry and also summary proofs read at the inquiry. My report takes account, however, not just of the proofs of evidence, but of the evidence as given, including points brought out in cross examination. It reflects the cases of the parties as they were ultimately put to the inquiry, picking up amendments and additions to the evidence received during the course of the inquiry. The inquiry documents include the Attendance Sheets for each day of the inquiry (Document INQ/1). It is not the current practice of the Planning Inspectorate to make Attendance Sheets an inquiry document, but that change has been made since the inquiry closed. It was stated throughout this inquiry that the Attendance Sheets would be an inquiry document, and they have therefore been retained as such. Should the Secretary of State decide that the planning permissions sought in this case should be granted, I set out in Appendix C the conditions which I would recommend should be imposed on application ref: P/04/1170; in Appendix D the conditions which I would recommend should be imposed on application ref: 04/1800/F; and in Appendix E the conditions which I would recommend should be imposed on application ref: P/05/0428.
1.68
1.69
2 2.1
DESCRIPTION OF THE SITE AND ITS SURROUNDINGS Document TfL/34 illustrates the site of the proposed TGB scheme in the context of East London. The scheme would provide a crossing of the River Thames at Gallions Reach. The Statement of Common Ground between TfL, Newham and Greenwich (Document TfL/17) includes an agreed site description at section 2.4. There is nothing within that description with which I disagree. The remainder of section 2 of this report simply seeks to add some additional detail to it.
17
River Thames 2.2 Downstream of the City of London, the tidal River Thames meanders eastward past the Isle of Dogs (to the north) and the Blackwall peninsula (on the south bank) with its Tunnel. Some 6.5km further east is the length of the river known as Gallions Reach leading, in turn, to Barking Reach and ultimately to the sea. The Dartford Crossing is about 14.5km downstream from Gallions Reach. The river is also crossed at the Woolwich Ferry, about 1.6km upstream from Gallions Reach. There is also a foot tunnel beneath the river at Woolwich. The River Roding joins the Thames from the north at Barking Reach.
North Bank 2.3 Immediately to the north of the river and east of the City are found, from west to east, the London Boroughs of Tower Hamlets, Newham, Barking & Dagenham, and Havering. The County of Essex lies beyond. Further to the north are Hackney, Waltham Forest and Redbridge Boroughs. The land falls gently from the north toward the Thames. Through Newham, Barking & Dagenham and Havering, the A13 dual carriageway road runs broadly parallel with, and about 1.6km north of, the river. Other radial routes in this part of London include the A124 through East Ham and Barking, the A118 through Manor Park and Ilford, and the A12 through Wanstead and Newbury Park via the Redbridge junction. These radial routes are linked by the A406 North Circular Road dual carriageway orbital route which also gives access, north of the Redbridge junction, to the M11 motorway. The south-easternmost section of the A406 North Circular Road is also known as the South Woodford to Barking Relief Road (the SWBRR). South of the A13, the A1020 Royal Docks Road and, beyond it, the A117 Woolwich Manor Way lead from the North Circular Road to the Woolwich Ferry. The Gallions Reach Shopping Park stands to the east of Royal Docks Road and the DLR stations at Gallions Reach and Beckton are nearby. Armada Way gives access from Royal Docks Road to the Shopping Park and to an area undergoing redevelopment at the time of the inquiry. Beckton Reach Sewage Treatment Works lie between the Gallions Reach Shopping Park and the River Roding, and take road access from Royal Docks Road via Eric Clarke Lane. Claps Gate Lane meets Royal Docks Road opposite Eric Clarke Lane and leads to the Gateway and Beckton Triangle retail parks. LCY is to the west of Woolwich Manor Way; its runway is on an east/west axis, and extends to about 1.4km to the west of the site of the scheme. The site of the scheme to the north of the River Thames is close to land uses which are predominantly non-residential in character. A large, mixed, urban area lies beyond. The site on the north bank is in the London Borough of Newham.
2.4
2.5
2.6
18
South Bank 2.7 Proceeding from west to east, the Blackwall peninsula, Woolwich and much of the Thamesmead residential area stand on the south bank of the Thames in the London Borough of Greenwich. The adjacent Borough to the east is Bexley, whose waterfront includes part of Thamesmead, the Crossness Sewage Treatment Works, various employment related sites and the town of Erith. The County of Kent lies to the east of Bexley. Close to the river, the land rises gently to the south, but within about 2km of the river the gradient becomes steeper as a ridge is approached. This ridge runs approximately from west to east and includes Plumstead Common, Winns Common, Bostall Woods and Belvedere. The main radial routes in this part of South East London are as follows. The A2016 dual carriageway road runs broadly parallel to the river between Woolwich and Erith, typically about 1.6km from the river bank, and incorporates Western Way, Eastern Way and Bronze Age Way. The A206 follows an inland route from Greenwich via Woolwich to Erith (ascending the ridge as it approaches Bostall Heath) and then continues south and east to the Dartford Crossing via Junction 1a of the M25. The A2016 and the A206 diverge about a mile south-west of the proposed scheme and meet again at the Town Hall roundabout at Erith. The A207 follows the linear route of ancient Watling Street, generally about 2.4km south of the A206 (west of Erith) but is diverted from that route as it passes the town centre at Bexleyheath; it then leads east to the M25 at Junction 1b. The A2 crosses Blackheath, to the south of Greenwich, to meet the A102 Blackwall Tunnel Southern Approach and the A207 before turning south and east to run broadly parallel to the A207, up to about 1.6km to its south. The A2 meets the M25 at Junction 2. The main orbital routes in the area broadly to the south of the site of the scheme are the A205 South Circular Road and the A2041 Harrow Manorway/Knee Hill route. The A205 runs south from the Woolwich Ferry terminus (immediately to the north west of Woolwich town centre) and links the A206, the A207 and the A2 to continue towards South, and South West, London. The A2041 Harrow Manorway meets the A2016 Eastern Way about 1.2km to the east of the site of the scheme, and the A2041 then runs south to climb Knee Hill to the ridge and meet the A206 at a crossroads at Bostall Heath. The orbital route continues south via Brampton Road, not signed as a classified route, to meet the A207 a short distance from the A221 Danson Road which leads south to the A2. The scheme would connect to this road network at the junction of A2016 Western Way, A2041 Central Way, A2016 Eastern Way, and White Hart Avenue, currently a roundabout. Residential development has taken place alongside the scheme corridor. The corridor itself is readily distinguished, and an open space remains to its north on the approach to the Thames. The whole of the area south of the Thames described here is predominantly residential, except where indicated otherwise above and at the Blackwall
19
2.8
2.9
2.10
2.11
peninsula and New Charlton to its immediate east, Woolwich town centre, the area east of Western Way and around White Hart Avenue, and to the south of Eastern Way. The non-residential uses in these locations include retail, employment, a barracks, and Belmarsh Prison. There are, in addition, several sizeable areas of open space. 2.12 The landfall of the bridge on the south bank of the Thames would be in the London Borough of Greenwich.
PROCEDURAL AND LEGAL SUBMISSIONS
Procedural issues Cross examination by expert witnesses 3.1 As indicated at paragraph 1.56 above, some of the expert witnesses funded by the grant made at the request of the Mayor of London cross examined, on behalf of objectors, witnesses for the promoters who were giving evidence within the area of their expertise. It seemed to me to be sensible to allow that to take place, rather than insisting on cross examination being undertaken only by the nominated advocate for an individual objector. It avoided the need for what in most cases were not specialist, professional advocates to be advised by an expert witness on appropriate subject matters for cross examination, and then for them to need to take instructions on the purport of the answers received. What I was not prepared to allow was for the expert witnesses to be allowed to cross examine in their own right, acting as if they were parties to the inquiry or Counsel to the inquiry rather than as witnesses, with the objectors for whom they appeared retaining the right to cross examine the same witness for the promoters on the same evidence. Although this issue was the subject of quite extensive discussion in the early days of the inquiry, I believe that, in the event, the arrangements made worked to the satisfaction of all parties concerned.
3.2
3.3
Applications for witness summonses 3.4 On behalf of the Simon Wolff Charitable Foundation (SWCF), Mrs Nina Tuckman made applications for witness summonses to compel the attendance at the inquiry to give evidence of the Mayor of London and Professor David Begg, a member of the Board of TfL, and a former Chair of the Standing Advisory Committee for Trunk Road Assessment (SACTRA) and of the Commission for Integrated Transport. The applications were made on 15 June 2005, and are covered in the transcript of the inquiry (Document INQ/2) at Day 6 from page 165 line 13 to page 193 line 9. In essence, Mrs Tuckman wished the Mayor of London
20
3.5
to be called to the inquiry to explain why his previous opposition to a bridge over the Thames in the area of the TGB proposal had changed to support for the proposal. Mrs Tuckman conceded at D6 P183 L20 and at D6 P184 L2 that her motive for seeking the attendance of the Mayor of London was a political one. No ground was adduced for the issue of a witness summons addressed to Professor Begg. 3.6 I considered the applications, and responded to them on the following day (D7 P3 L5 to P6 L16). I refused to issue a witness summons addressed to the Mayor of London because I had not been satisfied that, without his attendance, I would not be able to make a proper or adequate report to the Secretaries of State. Indeed, the motive for seeking the Mayors attendance had clearly been stated to be a political motive. In relation to Professor Begg, there was no ground advanced for the need for his attendance, and that application was therefore also refused. Subsequently, I agreed to hear a further application from Mrs Tuckman for a witness summons to be addressed to Professor Begg. This application was made on 29 September 2005 (D34 P193 L26 to P209 L15). Mrs Tuckman argued that Professor Begg should be called to give evidence because he was one of the members of the TfL Board who voted against applying for powers to achieve the construction of the TGB. The application was only narrowly approved by the Board, and, in voting against, Professor Begg had contended that the economic case for the bridge was a complete shambles. It was not possible to reach a conclusion on the witness summons application in relation to Professor Begg on 29 September 2005, because various documents in connection with the application remained to be provided by the SWCF. In the event, before those documents were provided, Mr Stern (who appeared with Mrs Tuckman for the SWCF) subsequently withdrew the application at the inquiry on 5 October 2005 (D37 P186 L12). At an early stage during the inquiry, Ms Rebecca Lush also indicated that she wished to appear at the inquiry to seek a witness summons addressed to the Mayor of London, but this was not a matter which she pursued by attending the inquiry to make her application.
3.7
3.8
3.9
Other procedural applications made and issues raised on behalf of the Simon Wolff Charitable Foundation 3.10 Mrs Tuckman repeatedly asked for an opportunity to cross examine Mr Charles George QC, who led for TfL. She did not accept my ruling that a person who appeared purely as an advocate for a party did not give evidence, and was therefore not open to cross examination. Mrs Tuckman also complained that the stenographer repeatedly interrupted Mr Stern when he was addressing or giving evidence to the inquiry. The
21
3.11
reason for this was that Mr Stern often spoke very quickly, and I considered it better practice to allow the stenographer to raise the matter immediately when she was not able to keep up with what was being said, rather than for an attempt to need to be made at a later stage to recreate what had been said. This issue (and a related issue of some witnesses speaking very quietly) needed to be raised with a handful of other people who spoke at the inquiry; Mr Stern was by no means the only person who was politely interrupted in this way. 3.12 Mrs Tuckman also suggested that there were defects in the transcript of the inquiry, which she suggested was being censored in some way. She did not indicate by whom she considered that this was being done. In fact, the procedure for seeking amendments to the transcript was explained by me at the opening of the inquiry (D1 P71 L21 to P72 L11). During the 89 days of the inquiry, very few amendments to the transcript were proposed, and even fewer needed to be made. I note that Mr Stern was very complimentary regarding the standard and accuracy of the transcript (D45 P12 L4 to L13). Mrs Tuckman also contended that it was wrong for an Inspector to seek confirmation that an expression of support or objection to the TGB proposal, made by a representative on behalf of a statutory or voluntary body, had been properly authorised by that body. It had been indicated in the notes of the Pre Inquiry Meeting (Document PID/1) at paragraph 55 that this information should be included in the proofs of those who gave evidence for statutory or voluntary bodies, together with some information about the nature of the body concerned and the extent of its membership. Those who did not include this information in their proofs were asked to provide it at the inquiry, whether they were in support of the TGB proposal or against it. No other party raised any objection to providing this information, which I have routinely sought at inquiries for many years in accordance with standard practice. Again, I note that Mr Stern indicated at D37 P186 L18-20 that he regarded the request for confirmation of authority as quite legitimate. A further issue raised during the inquiry by Mrs Tuckman concerned the desire of the SWCF and People Against the River Crossing (PARC), another non statutory objector, to commission further evidence from Professor Whitelegg, one of the experts who gave evidence to the inquiry funded from the finance provided to objectors at the request of the Mayor of London. The SWCF indicated by email to the Programme Officer on 31 August 2005 that they wished to commission additional work from Professor Whitelegg over and above that which he had already submitted to the inquiry. The subject matter of that additional work was not disclosed. It was stated, however, that Professor Whitelegg would not be available to present the product of his additional work to the inquiry until January 2006. At the time this issue was raised, the programme for the inquiry ended with the closing for the promoters scheduled for 8 December 2005. Professor Whitelegg had been on the list of witnesses the SWCF had indicated at the
22
3.13
3.14
3.15
PIM on 4 April 2005 that they would be calling at the inquiry. Outline proofs of evidence from objectors had been required by 31 May 2005, and proofs had been required by 16 August 2005. No proof from Professor Whitelegg had been submitted by the SWCF by that date. Mrs Tuckman appeared at the inquiry on 29 September 2005 (D34 P209 L16 to P231 L4) to argue that the inquiry should continue until January 2006 to accommodate further evidence from Professor Whitelegg, which she considered it would take three days to deliver at the inquiry. 3.16 Against the background that objectors had known since 28 April 2005 the deadlines to which they should be working for the provision of proofs of evidence, I was not prepared to agree to the inquiry continuing into January 2006 solely to allow the receipt of further evidence from Professor Whitelegg. I agreed, however, that I would allow such further evidence provided Professor Whitelegg would be able to appear at the inquiry to deliver it on or before 25 November 2005, and his proof would be available by 21 October 2005. Mr Stern subsequently indicated on 19 October 2005 (D44 P6 L24) that Professor Whitelegg would not be able to meet this timetable. When it became clear that the new evidence introduced by the promoters (paragraphs 1.59 to 1.61 above) would extend the inquiry beyond early December, I caused the Programme Officer to write to the SWCF and to PARC on 14 November 2005, to advise their representatives that it would clearly now be possible for Professor Whitelegg to appear at the inquiry in January or later, depending on the progress of the inquiry in 2006. In the event, Professor Whitelegg was not instructed by SWCF and PARC, and the further contributions he made to the inquiry during February and March 2006 were presented, like his original evidence, on behalf of objectors generally. This further evidence was received by 14 February 2006, the deadline fixed on 22 December 2005 for receipt of additional evidence from the expert witnesses assisting the objectors. In an email addressed to the Programme Officer on 26 November 2005, Mrs Tuckman stated that it was apparent to her during the three days on which Mr Stern had given evidence that neither of the Inspectors understood enough mathematics to know what was going on. Mrs Tuckman moved on from this premise to suggest that this made it likely that, on any conflict of evidence between Professor Rosewell (whom Mrs Tuckman described as a pretty lady) and Mr Stern (whom she described as a formidable intellect with impeccable academic attainments), the Inspectors would be likely to prefer beauty to intellect. No evidence was produced to justify the claim that the Inspectors did not understand Mr Sterns evidence. Such evidence as is provided by the transcript of the inquiry suggests the exact opposite. A few examples appear at D44 P161 L21 to P162 L4; D44 P163 L5 to L17; D44 P197 L7 to L13; D46 P77 L14 to L21; D48 P3 L10 to P4 L11; D48 P70 L20 to P71 L3; D48 P74 L2 to P75 L14; D48 P110 L12 to P111 L15; D48 P166 L13 to P168 L16. Many further examples could be quoted to support the same point. In
23
3.17
3.18
3.19
many of them, Mr Stern himself clearly accepts that the Inspectors are following and have understood his evidence. 3.20 In relation to the basis on which evidence presented to the inquiry would be (and has been) assessed, I made it clear at the first session of the inquiry following receipt of Mrs Tuckmans email that evidence would be evaluated on its own merits, without regard to either the beauty or the intellect of the witness providing it (D55 P5 L17 to P6 L14). Mrs Tuckman also made a general complaint at the inquiry that the Inspectors did not deal with the case impartially. She considered that they were too close to the promoters, and offered them too much assistance. In particular, Mrs Tuckman contended that the Inspectors ate lunch with the promoters and at their expense. Neither of those contentions is factually correct, as acknowledged not just by the promoters but by representatives of other objectors (D88 P80 L13 to P82 L10). Mrs Tuckman also considered that Counsel for the promoters were allowed to bully witnesses. In response to that claim, I make the point that I have been involved in more than 400 public inquiries, either as an advocate or as an Inspector over the last 38 years, and I saw no example of a witness being bullied by Counsel at this inquiry. Had I done so, I should have intervened. Fortunately, in this case, there is a transcript of the proceedings, which can provide its own evidence in relation to the claims both of impartiality and of bullying. As regards the allegation that TfL were favoured by the Inspectors, this does not square with decisions taken on a number of significant issues which have arisen during the conduct of the case. For example, the promoters originally refused to provide a transcript service for the inquiry, but, on the insistence of the Inspectors, one was provided. TfL argued that the inquiry should open as planned on 7 June 2005, and continue until it was completed. Their original position was that all proofs of evidence should be available at the same time, 10 May 2005. I recommended to the Secretaries of State that the inquiry should be adjourned until 13 September 2005 after the promoters and supporters had given their evidence, in order to allow more time for the objectors to prepare their cases. TfL argued that the expert witnesses for the objectors should each be attached to an individual objector, and should give evidence as part of the case of that objector. I agreed that the experts could give their evidence as part of an overall case against the scheme, and, as indicated at paragraph 3.1 above, they were allowed to cross examine the promoters expert witnesses on the subject matter of their expertise, so long as they were nominally attached to an objectors case. When TfL produced their new traffic evidence, they originally argued that the inquiry should reopen after Christmas on 31 January 2006. I ruled that the inquiry should reopen on 21 February 2006, because I did not believe that the earlier date would allow sufficient time for objectors to prepare their responses to the new evidence.
3.21
3.22
3.23
24
Issues regarding access to the inquiry hall 3.24 At the Pre Inquiry Meeting on 4 April 2005, an issue had arisen regarding objectors being allowed access to the venue at the same time as the promoters. I therefore took particular care to emphasise to the managers of the inquiry venue, ahead of the opening of the inquiry, that access to the inquiry hall should be available each day to all parties at the same time, from 8.30am. Despite this action, problems arose on the first day of the inquiry. Following a re-emphasis of the importance which I attached to this issue, there was no subsequent problem. The problems which had arisen on the first day of the inquiry were raised again, however, on Day 55, 2 December 2005, by Mr T Grant, who appeared for the St Michaels Residents Association (SMRA). Mr Grant had apparently made a complaint to the Metropolitan Police of common assault against certain staff of Charlton Athletic Football Club arising from the events which took place before the opening of the inquiry on 7 June 2005. He had heard from the Police on 1 December 2005 that no further action was to be taken on his complaint, since the Crown Prosecution Service (CPS) considered that the action taken by staff of the Football Club was reasonable and proportional in the circumstances. Mr Grant argued that this meant that the CPS had given clearance for security staff to eject anybody from the building in which the inquiry was being held, without giving any reason for their actions. In that situation, Mr Grant contended that the inquiry could no longer be regarded as a public inquiry, guaranteed to be open to anybody who wished to attend. Mr Grant submitted that the inquiry should be adjourned, and the Office of the Deputy Prime Minister should be asked to seek a review of the decision of the CPS. I was not prepared to adjourn the inquiry on that basis. There had been no problem regarding access to the building or to the inquiry hall since the first morning of the inquiry. It did not seem to me that there was any real threat to public access to the inquiry arising from the decision of the CPS, which related to the particular circumstances of an event which took place before the opening of the inquiry. I agreed, however, to reiterate to the staff at the venue the importance which I attached to parties having equal access to the inquiry venue. That was done, and, so far as I am aware, no problem regarding access to the inquiry venue or hall arose during the balance of the inquiry.
3.25
3.26
Accuracy of quotations from the transcript contained in the closing submissions of the promoters 3.27 On the last day of the inquiry, following the closing submissions made on behalf of the promoters, Mr Bourn for Transport 2000 (T2000), Mrs Tuckman for SWCF, Mrs Wise for Action Group Against the Bridge (AGAB), and Mrs Brown all raised issues regarding the accuracy of the quotations attributed to them in the promoters closing submissions. In this report, where any evidence or admission has been relied on, that evidence or
25
admission has been checked against the transcript. Weight has been given only to the exact words of the witness concerned and the context in which they were spoken. Legal issues The availability and location of deposited documents 3.28 When the Inspectors (then Mr R M Barker and Mr M Ellison) received their sets of deposit documents for the inquiry on 17 March 2005, it was quickly noticed that Documents D801 (the Inspectors report on the 1985/86 East London River Crossing inquiry) and D802 (the Inspectors report on the 1990/91 inquiry) had each been sent without the pages containing the Inspectors conclusions and recommendations. This matter was raised by the Inspectors with the Programme Officer on 24 March 2005, and he, in turn, asked the promoters to make good the deficiency. Despite repeated requests for the missing pages to be supplied, including a request which I made at the Procedural Meeting held on 28 April 2005, the missing sections of the two reports were not supplied to the Inspectors (by then, Mr M Ellison and Mr J Watson) until early June 2005, just after the opening of the inquiry. This caused me to wonder whether the deposit documents available for consultation by the public were similarly incomplete. Mr Watson therefore attended on 27 April 2005 at the place at which the deposit documents were said in the promoters statement of case to be held. Mr Watson asked to see Document D801. Pages 199 to 390 inclusive were missing from the document he was shown. I referred to this matter at paragraph 1.15 of my report to the Secretaries of State on the issue of postponement of the inquiry (Document PID/3). I also raised it again at the opening of the inquiry (D1 P83 L6 to L21). Evidence was given to the inquiry on behalf of the promoters to the effect that the deposit copy of Document D801 was at all times complete. When Mr Watson went to check the document on 27 April 2005, because he arrived marginally outside the hours during which the deposit documents were officially available for consultation, he was shown what was described as a TfL working copy of Document D801 rather than the deposit copy. This TfL working copy happened to have exactly the same pages missing from it as the copies supplied to the Inspectors. Evidence was given that the deposit copy of Document D801 was checked by TfL on 29 April 2005 and found to be complete. There was no challenge to this evidence. I raised two other issues concerning the deposit documents. Both related to the location at which they were held. The statement of case issued by the promoters (both the original December 2004 version and the revised version issued in March 2005 which comprises Document TfL/15) indicated that documents would be on deposit at Parnell
26
3.29
3.30
3.31
3.32
House, 25 Wilton Road, London, SW1V 1LW. It became clear before the inquiry opened (from Document INQ/4) that the deposit documents were in fact held at the Data Room, Victoria Station House, London, which was said in evidence to be some 50 to 60 metres from Parnell House. The reason for this was stated to be that there was no space available to hold the documents in Parnell House, a building which also did not offer good access for people with access related disabilities. Victoria Station House was said to have good access, but the room in which the deposit documents were held was not staffed. The TfL staff dealing with the TGB scheme were located in Parnell House, and people wishing to view the documents were therefore directed to that location, from which they could be taken by a member of the TGB Project Team to Victoria Station House. In fact, only four people ever asked for access to the deposit documents (including Mr Watson). 3.33 The various sets of Rules which govern this inquiry make slightly different provision for the availability of documents in advance of the inquiry. The most specific requirements are contained in Rule 16 of the Highways (Inquiries Procedure) Rules 1994, which apply to the Special Roads Scheme and the Side Roads Order. Rule 16(2)(b) provides that each statutory objector must be given notice of all places within each area in which the proposals contained in the order or scheme are to have effect (or as close as reasonably possible to any such area), where a copy of every document or the relevant part of any document which the promoting authority intends to refer to or put in evidence may be inspected free of charge at all reasonable hours until the date of commencement of the inquiry. 3.34 As indicated already in this report, the proposed TGB would run from Beckton in Newham to Thamesmead in Greenwich. Parnell House is located in the City of Westminster, some 17.5km as the crow flies from the location of the proposed bridge. The promoters contend that the reference in Rule 16 (2) (b) to all places imposes no requirement to make the documents available in more than one place. They argue further that, since the Rules do not define what is meant by area, Greater London can properly be regarded as the area in which the [TGB] proposals .. are to have effect. They therefore contend that the availability of documents for inspection at Parnell House/Victoria Station House complies with the Rules. In the alternative, if area means that part of Greenwich and Newham within which the TGB proposals are to have effect (that is, TfL suggest, the land subject to the Orders), then TfL submit that there is nowhere within the Order lands where the documents could have been made available for inspection. They suggest that Parnell House, situated as it is very close to Victoria Station, can properly be regarded as being a place as close as reasonably possible to the lands subject to the Order.
3.35
3.36
27
3.37
If, contrary to that submission, it is considered that there has been a procedural error, the promoters argue that the correct approach is to consider all the facts and circumstances of the case in which the issue arises [and] seek to do what is just in all the circumstances, the approach adopted by the Court of Appeal in R v Home Secretary ex parte Jeyeantham [2000] 1 WLR 354 at page 359. In this case, it is the promoters submission that the requirement in Rule 16 (2) (b) is directory only; that there has been substantial compliance with it, in that the documents have been made available for inspection; and that there is no evidence that anybody has been prejudiced by the choice of Parnell House as a location for the deposit documents. Additionally, the promoters make the point that all the planning application documents, including the ES, were placed on deposit at locations in Newham and Greenwich during the objection periods ending in September 2004, and copies of that restricted range of documents were made available at five locations in Bexley from 12 April 2005. The full set of more than 300 deposit documents was available in the inquiry library from 6 June 2005, the day before the opening of the inquiry, and, shortly after the commencement of the inquiry, a further set was prepared and made available in the objectors room at the inquiry venue. Access to the inquiry library was available even during periods when the inquiry was not sitting. The arguments of the promoters on this issue are set out in full in Document TfL/316. One objector, Mr P Berry, made the point that documents on deposit in Central London between 9.30am and 4pm on Mondays to Fridays were not easy to consult for people from Newham, Greenwich or Bexley who were in employment or had caring responsibilities. Many other objectors argued that documents should have been available at an earlier stage in Bexley, where, the objectors contended, the major effects of traffic from the proposed bridge would be felt. Mr J P OHara, who made a written objection to the Toll Order, also raised an issue concerning deposit documents. He argued that, under paragraph 1(3) of Schedule 2 to the New Roads and Street Works Act 1991, TfL were required to make available for inspection with the deposited copy of the Toll Order a statement providing prescribed information concerning the concessionaire and the concession agreement. This had not been done; and, indeed, could not be done, because no concessionaire had been appointed. He contended, therefore, that the application for the Toll Order was premature. In response, TfL argue that paragraph 1(3) of Schedule 2 does not apply to the Toll Order for the TGB, because the Order would not be one which was the subject of a concession agreement as defined in Section 1(1) of the Act of 1991. No concessionaire would be appointed under the Order to enjoy the right conferred by the Order to charge tolls. The right to charge tolls would remain with TfL as the highway authority for the special road.
28
3.38
3.39
3.40
3.41
3.42
The availability to objectors of information obtained under the Statistics of Trade Act 1947 and the Employment and Training Act 1973 3.43 Part of the material used to produce the Regeneration Statement put in by TfL in support of the case for the TGB (Document D822) included calculations seeking to show that improving access to an area increases potential employment density in that area. One of the objectors, SWCF, wished to have access to the data from which this analysis had been produced in order to check the workings and the conclusions. A complete set of the raw data was refused by TfL, because it had been obtained by Professor Rosewell, the witness who dealt with these matters for the promoters, and by Volterra, her consultancy, under a notice issued by the Chancellor of the Exchequer under Section 1 of the Statistics of Trade Act 1947 and Section 4 of the Employment and Training Act 1973. This notice and the Acts under which it was issued prohibited the passing of the data to unlicensed third parties, subject to criminal sanctions. The justification for the line taken by TfL on this matter was explained at the inquiry (D48 P7 L14 to P19 L6), and the supporting documentation was presented in Document TfL/194. In the event, the issue was resolved by the promoters securing a licence for Mr Stern of SWCF to have access to the information he wished to see (D71 P32 L2 to L8).
3.44
3.45
The extent to which TfL can commit to a minimum level of public transport service across the proposed bridge 3.46 One of the issues raised by LB Bexley in what ultimately became their objection to the proposed TGB was that, if the bridge was built, there should be a commitment by TfL to provide a minimum level of public transport service for a minimum period across the bridge (see paragraph 6.54 below). A similar point was raised by the London Transport Users Committee (see paragraph 7.5 below). The purpose of that proposed provision would be to encourage the use of public transport to cross the bridge, thereby reducing use by private cars. Bexley argued that such a commitment could be contained in the Boroughs Agreement. They suggested that TfL could enter into a forward commitment to provide public passenger transport services within Greater London, or, alternatively, that the Mayor of London could give a lawful direction to that effect to TfL under Section 155 (1) of the Greater London Authority Act 1999 (GLAA 1999), and that this would be consistent with the Mayors responsibilities under Section 174 (2) of that Act. These arguments are set out in full in Documents 1774/5 and 1774/5A, and are pursued in the correspondence between Bexley, TfL and the Mayor of London contained in Document 1774/36, culminating in the letter from the Mayor of London of 7 March 2006 (Document 1744/36A). In line with that last mentioned letter, the promoters position is that TfL
29
3.47
cannot make such a forward commitment (which would not come into operational effect until around 2013 at the earliest); to do so would fetter their statutory duty to determine which London transport services are required to provide safe, integrated, efficient and economic services at the time at which those services fall to be provided. TfL refer to the decision of the House of Lords in R v Home Secretary ex parte Venables (1998) AC 407, and, in particular, to the speech of Lord Browne-Wilkinson at page 497, in which he says, the person on whom the power is conferred cannot fetter the future exercise of his discretion by committing himself now as to the way in which he will exercise his power in the future. 3.48 TfL argue that such an agreement as Bexley seek would not be necessary or expedient to facilitate the discharge by it of its functions under paragraph 32 of Schedule 11 to the GLAA 1999. On the contrary, the promoters argue that such an agreement would fetter TfLs duty to determine service levels from time to time in the light of the then prevailing circumstances. TfL contend that it follows that the Mayor could not use his power of direction under Section 155 (1) of the Act to cause TfL to enter into such an agreement. In a letter dated 18 July 2005 to the Leader of Bexley Council (Document TfL/112), the Mayor states that, whilst his hope is that, over time, higher levels of service than 20 buses per hour in each direction across the proposed TGB might be achieved, he was advised that it would not be legally appropriate for him or TfL to offer a contractual guarantee of a specific minimum service level at this stage. In fact, in a later letter of 7 March 2006 (Document 1774/36A), the Mayor states that, regardless of the legal position, I would consider it inappropriate to go further than this in making a legally binding commitment over future levels of service on a particular element of the transport network. Future service levels should be determined having regard to all relevant circumstances prevailing at the time. The promoters arguments on these matters are set out in full at pages 46 and 47 of Document TfL/33 and paragraphs 5.1.33 to 5.1.41 of Document TfL/334. Extracts from text books on administrative law dealing with the issue of the fettering of a discretion are contained in Document TfL/328.
3.49
3.50
Legal issues concerning the Environmental Statement 3.51 The ES was prepared under the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (Document D409) by which the European Community Directive 85/337/EEC, as amended by Directive 97/11/EC (Document D301 provides a consolidated version), were implemented in England and Wales. Eight issues were raised by objectors regarding the compliance of the ES and its three Addenda (listed in paragraph 1.26 above) with the requirements of the Regulations and the Directives.
30
3.52
Mr David Black argues that the TGB scheme should have been assessed under the 1999 Regulations as a Schedule 1 rather than a Schedule 2 development. This is because he considers that there is no legally binding guarantee that would prevent the extension as far as the A2 on the southern side of the River Thames of the road which would be carried by the proposed bridge. As an extension of the A406 North Circular Road, the road serving both sides of the TGB would thus run for more than 10km in a continuous length. This argument is set out in section 6 and 8 of Document 1994/1/A1 and at page 8 of Document 1994/13. The promoters respond that an extension of the proposed road is not part of the presently proposed development, and that there is therefore no basis for treating the TGB as a Schedule 1 development. Their argument is set out at paragraph 5.68.12 of Document TfL/334. Mr Black next argues that the ES is deficient under Article 3 of the EC Directive in that it fails to identify, describe and assess the scheme as part of the strategic highway system. Mr Black contends that the ES should take account of what he describes as the inevitable future extension of the TGB to the A2 and the A20 (Document 1994/1/A1 paragraphs 8.2 to 8.4). The promoters again state that there is no proposal to extend the road to the A2 or to the A20 (Document TfL/334 paragraph 5.68.12). Mr Blacks third point concerns Article 5 of the EC Directive, again raising the issue of the true extent of the eventual project. He argues that the description of the project in the ES is inadequate, because in reality the proposal represents the first stage in what will become a strategic highway link. He contends that what he says will become a strategic highway link would have a very different profile from that of what the promoters claim to be merely a local link road (Document 1994/1/A1 paragraph 8.7). The promoters respond that various strategic aspects of the TGB are described in the ES, including its regeneration potential, but that the scheme is correctly described as having a primarily local purpose (Document TfL/334 paragraph 5.68.13). Mr Black next argues that the ES is deficient in terms of Article 5 of the Directive because the project traffic forecasts cannot be relied upon, so that the local impact could be considerably more adverse than presented by the developer. He suggests that the impact of increasing volumes of traffic on residential areas and open spaces, in particular Lesnes Abbey Wood, requires a more impartial analysis (Document 1994/13, page 8). The promoters respond that traffic forecasts cannot be conclusive as to what will happen, but they are a useful tool for environmental assessment. The ES Addendum 3 properly assesses the likely significant effects of the TGB in the light of the promoters revised traffic modelling (Document TfL/334 paragraph 5.68.14).
31
3.53
3.54
3.55
3.56
3.57
3.58
3.59
3.60
Mr Blacks fifth point again concerns Article 5 of the Directive. He claims that Article 5 (3) has been breached, in that light and heavy rail alternatives should have been properly assessed before a preferred option was selected (Document 1994/13 page 8). The promoters respond that all that is required by Article 5 (3) is an outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects. The promoters argue that there is therefore no obligation under the Directive to assess alternatives. It is left to the developer to decide what if any alternatives he will study, and (if he does study alternatives) to refer to the main alternatives in the ES. The promoters submit that this was done in this case. Heavy rail was not considered to be a main alternative, and was therefore not included in the ES, but the extension of the Docklands Light Railway (DLR) and tram options were considered at paragraph 4.6 of Document D808). Mr Blacks final point of challenge to the ES concerns Articles 6 and 8 of the Directive. He contends that Article 6 requires that local people and local authorities need to be given the opportunity to choose between alternative options. In this case, he claims that they have simply been presented with a road bridge or no bridge as alternatives. Under Article 8, Mr Black argues that the results of the consultation must be taken into account, but, in this case, he claims that the project has been imposed on local communities, before a consensus on transport needs and priorities has been established (Document 1944/13 pages 8 and 9). The promoters respond that there is no obligation under either the Directive or the Regulations to consult on alternatives, although it was in fact open to consultees to bring forward alternatives at various stages, including at the inquiry (Document TfL/334 paragraph 5.68.16). The seventh point of challenge to the ES is raised by L B Bexley and Mr Roy Carrier. In essence, it is argued that, because there is uncertainty as to the environmental effects of the proposed development and the precise mitigation measures which would be implemented to address them, the ES fails to comply with Part II of Schedule 4 to the 1999 Regulations. It is alleged that the approach adopted in the ES of identifying potential mitigation measures and making provision for further possible schemes to be carried out in the light of experience means that it is not possible to allow the public to debate the environmental issues before a decision on the scheme is taken. Mr Carrier makes the point that nor is it possible to consider the environmental implications of the mitigation measures themselves. This in turn means that it is not possible for those considering whether consent to the development should be given to consider the impact and mitigation in the light of public response to consideration of the implications. Mr Carrier goes on to argue that, just as Elias J found in Hereford Waste Watchers v Hereford Council [2005] EWHC 191 at paragraph 34.4 that if
32
3.61
3.62
3.63
3.64
3.65
the planning authority is left uncertain as to the effects of a proposal, so that it is not sure whether they may be significant or not, it cannot seek to regulate any future potential difficulties merely by the imposition of conditions, so it is equally not open to the promoters in this case to seek to address future potential difficulties through the medium of the Boroughs Agreement. 3.66 These issues are dealt with in detail in Appendix A to Document 1774/15, in section 3 of Document 1544/1/A, section 3 of Document 1544/1/A1 and section 3 of Document 1544/1/A2. The promoters respond that they do not accept that the seventh point of challenge to the ES is valid, given the minor nature of any likely off-site mitigation measures. They make the point that the Government has taken a precisely similar approach in relation to developing an appropriate package of mitigation measures in due course for Crossrail (currently the subject of a hybrid Bill before Parliament), as evidenced by Document TfL/129 at section 28, page 10. Furthermore, in Humber Sea Terminal Ltd v Secretary of State for Transport [2006] 1 P & CR 5 at paragraphs 52 to 54, it was held that, in the absence of evidence that the proposed mitigation measures would be the main or likely significant effects of the project, the omission of some of them from the ES did not prevent it from being a lawful ES. Moreover, since the issue was first raised by L B Bexley and Mr Carrier in their initial submissions to the inquiry, greater certainty as to the mitigation measures and the likely environmental effects of them had been achieved. This issue had been specifically addressed in Tables 3.7 and 3.8 of Addendum 3 to the ES (Document TfL/212). The mitigation measures which would be implemented before the date of the bridge opening are set out in Schedule 3 Part 1A to Document TfL/22C. Part 2 of Schedule 3 to that document sets out indicative monitoring and mitigation measures which would be considered in the light of operational experience of the TGB. The promoters argue that the 1999 Regulations do not require any further environmental information to be provided in respect of the mitigation of the environmental impact of the TGBs scheme. These issues are dealt with in detail at paragraph 5.1.42 and 43 and at 5.71.4 and 5 of Document TfL/334. The final legal issue concerning the ES was also raised by L B Bexley, and again relied on the Hereford Waste Watchers case. Bexley argue that until there is a reliable traffic model (which, they claim, is not the case at present), it is impossible to assess the ability of tolls to suppress demand over the proposed bridge, and to identify the consequences for local roads, the necessary mitigation measures and the effect on the potential for regeneration. In their submission, there is an incompatibility between the objectives of the scheme - regeneration, traffic management, revenue raising and environmental protection for the residential areas of Bexley through which so much traffic will have to pass. Bexley argue that the worst case must be assessed as a matter of law, because it may occur, and there would be no conditions or other mechanisms to prevent it from
33
3.67
3.68
3.69
occurring. These arguments are set out in Document 1774/47 at paragraphs 2(iv) and 52. 3.70 The promoters respond that the only requirement of the Regulations is to describe the likely significant effects of the development on the environment. There is no requirement to assess the worst possible case. The Regulations speak of what is reasonably required, and of the main effects which the development is likely to have on the environment. The promoters contend that the original ES, as supplemented, in particular, by Addendum 3, demonstrates that TfL have carried out a proper and very full assessment of the likely significant environmental effects of the proposal. These arguments are set out more fully at paragraphs 5.1.44 to 5.1.45 of Document TfL/334.
The need for a Strategic Environmental Assessment 3.71 Ms Janet Mackinnon argues that both the overall development proposals for the Thames Gateway and the plan for the proposed TGB should have been subject to a Strategic Environmental Assessment (SEA) under EC Directive 2001/42/EC and the Environmental Assessment of Plans and Programmes Regulations 2004. The same point was raised in a written representation by Greenlands in Trust. Assessment under Directive 85/337/EEC (such as that undertaken in the ES in this case) takes place when options for significant change are often already limited. An SEA would require the environmental effects of a broad range of plans and programmes for the whole area to be taken into account while those plans are actually being developed. The definition of plan is to be read widely. An SEA is to be carried out as part of the consideration of the Thurrock Local Development Framework, and the same approach should be taken in relation to the TGB. The fact that a new Local Development Framework for L B Barking & Dagenham (one of the authorities which would be affected by the proposed TGB) will need to be embarked upon in the near future, and that that will require an SEA, underlines the need for a similar approach in relation to the TGB. These arguments are fully set out in Documents 4237/1/A, 4237/1/A2, 4237/6 4237/7 and 4237/10. In response, the promoters make the point that the requirement for an SEA relates to the preparation of plans and policies, not to the assessment of individual planning applications. Moreover, it applies to local development documents where formal preparation began after 21 July 2004. The Greater London Assembly adopted the London Plan (Document D620) in February 2004, and it therefore does not fall within the provisions of the 2004 Regulations. These arguments are set out more fully at paragraphs 4.6 to 4.9 of Document TfL/REB/4237/1 and at paragraph 5.79.9 of Document TfL/334.
3.72
3.73
34
THE CASE FOR TRANSPORT FOR LONDON
The material points are: Background 4.1 The Greater London Plan, published in 1944, proposed three ring roads around London: a. The C Ring, a sub arterial road, following the line of the then already extant North Circular Road, with the replacement of the Woolwich Ferry by means of a bridge or tunnel to provide a fixed Thames crossing at Gallions Reach. b. The D Ring, an express arterial road with a new Thames crossing in the vicinity of what are now the Dartford M25 tunnels and the Queen Elizabeth II Bridge. c. The E Ring, a sub arterial road forming an outer ring around London that did not join up across the River Thames. 4.2 The 1944 Plan drew a distinction between the sub arterial roads, which would be main roads in the built up area along which frontage development would be acceptable, and the arterial road (the D Ring) along which no frontage development would be permitted. Thus, in 1944, it was planned that the new crossing at Gallions Reach would have a more local function than the then proposed new crossing at Dartford. During the late 1970s and 1980s, however, the proposal for a crossing at Gallions Reach was changed. The national Government of the time saw the East London River Crossing (ELRC) as a component of the national strategic highway network. In 1984, the Secretary of State for Transport published draft Orders for roads and a bridge scheme to deliver a Thames crossing on a similar line to the one proposed for the TGB, but with the road then continuing to provide a major link to the A2 in the south. The ELRC proposal was the subject of two lengthy public inquiries. The 1985/86 inquiry considered the possibility of a crossing by way of a bridge or a tunnel. The relevant Secretaries of State decided to confirm the principle of a new bridge with a link road to the A2, but to review the design of the bridge in the light of concern regarding its traffic capacity, the recommended inclusion of a cycleway, and the effect which the height of the proposed bridge would have on the future development of LCY. The second inquiry in 1990/91 led to a decision to authorise a bridge with a dual three lane carriageway. The Inspectors reports on those two inquiries comprise Documents D801 and D802. The decision letters will be found at Documents 1944/3 and 1944/4.
4.3
4.4
35
4.5
There were two challenges to the decisions of the Secretaries of State to make the relevant Orders in 1991. The first was from Greenwich, and it was rejected by the High Court. The second was a challenge from the European Commission, on the basis that the environmental assessments made by the Department for Transport (DfT) at the original 1985/96 inquiry did not comply with the requirements of the European Directive on environmental assessments. Whilst this challenge was still in train, the Government decided, in July 1993, to withdraw its support for ELRC. The Secretary of State announced that the Government, while still fully committed to meeting the need for a new road link across the Thames in East London as a key element in the strategy to regenerate the Thames Gateway, felt that the current ELRC scheme, designed and chosen some time ago, fails to meet the high environmental standards we now apply to new road schemes. The Government therefore began examining alternative solutions to the approved ELRC scheme, which would still meet the same strategic objectives, but have less impact on the local environment. It consulted on river crossing options in 1995 (Document D803), and published proposals for a revised package of river crossing schemes as part of its 1996 document A Transport Strategy for London (Document TfL/180). The new proposals emerging from this review were for a more local dual two lane carriageway bridge scheme, with the addition of dedicated public transport links, as part of a river crossings package which also included a rail crossing at Woolwich and a third Blackwall Tunnel. The bridge proposals included tolling, which reflected concerns raised at the ELRC inquiries by local Boroughs that tolling was needed to help limit potential use of the bridge by longer distance traffic. It is these proposals which have been refined by TfL in the development of the current TGB scheme. Formal revocation of the made ELRC Orders took place in March 1997 (Document 1944/5), with continuing safeguarding for the proposed bridge approaches consistent with a short scheme, which did not link to the A2 in the south.
4.6
4.7
4.8
The policy context for the TGB proposal - the Thames Gateway 4.9 The case for the TGB needs to be seen within the wider context of policy within the Thames Gateway. During the last century, the eastern part of London, which includes the Thames Gateway, was a prime location for heavy manufacturing and polluting industries. It had the advantages of being near Londons main port facilities and of prevailing winds blowing smoke away from the rest of the City. The dramatic reduction in employment in manufacturing industries which has taken place in recent decades has, however, hit East London hard. The
36
4.10
4.11
area has also been adversely affected by the decline of Londons Docklands, which was rapid after the mid 1960s. The last of Londons enclosed docks had closed by 1981. 4.12 A legacy of land with poor access, much of it with problems of contamination to address, provided a significant challenge to those seeking to achieve regeneration and development in the area. But the Thames Gateway area was increasingly recognised as a regional priority for regeneration during the 1980s and early 1990s. The Governments 1989 Strategic Guidance for London Planning Authorities (Document D646) sought to modify historic patterns of growth across London by increasing growth in the east of London and reducing development pressures in the west. This was reinforced by statutory Regional Planning Guidance for the South East (RPG9 - Document D647), published in 1994. It identified the area now referred to as the Thames Gateway as having the capacity to accept significant levels of housing and employment development, alongside improvements in environmental quality. Investment in improvements in transport infrastructure was identified, however, as necessary to create the potential to attract such higher levels of development. The Government published the Thames Gateway Planning Framework (RPG9A - Document D648) in 1995, as a supplement to the strategic planning guidance contained in RPG9. RPG9A states that the area had originally been seen as a collection of disparate sites, but that the Thames Gateway needed a wider framework for sustainable economic, social and environmental regeneration. The problems to be tackled included a need for improvements in road and rail links. RPG9A also states that new and improved cross river links are needed to address the recognised imbalance between the number of river crossings to the east and west of London and to remove the north/south barrier effect of the Thames. RPG9A remarks that the Thames Gateway exists in a competitive context for investment, and that, to compete successfully, it must provide no less than the level of accessibility available elsewhere. The document therefore proposed a number of new river crossings, including a river crossing at Gallions Reach. This was later refined as the current TGB proposal, a multi-modal toll road linking into the local road network, rather than into the strategic network. Since the publication of RPG9A, further relevant Government policy has emerged in the Transport White Paper of 1997 and the Urban White Paper of 2000. These documents promote a better integrated transport system, better coordinated with land use planning, and give greater emphasis to seeking sustainable patterns of development, typically at higher densities, supported by good transport accessibility (particularly by public transport), as well as continuing to seek the redevelopment of brownfield sites. This has further increased the policy emphasis on transport improvements both to encourage and to complement investment in higher density, higher
37
4.13
4.14
4.15
4.16
quality development. The scheme is one of a series of transport proposals which would support development in the Thames Gateway, thus reducing pressure to accommodate growth through low density development in the Green Belt and in green spaces which would typically be more car dependent. 4.17 In February 2003, the Government launched the programme Sustainable Communities: Building a better future (Document D670). This programme aims to tackle housing supply issues in the South East of England by accelerating growth in four defined growth areas, one of which is the Thames Gateway. A progress report issued in August 2003 (Document D651) confirmed the Governments aim to ensure the development of 120,000 new homes in the Thames Gateway by 2016. A five year plan, published by the Government in January 2005 (Document D671), gives more detail on how this aim will be achieved. It identifies the TGB as relevant new infrastructure in the Thames Gateway supporting the programme. The Government has also worked in partnership with the Mayor of London, the East of England Assembly and the South East of England Assembly to produce a joint inter-regional planning statement, Growth and Regeneration in the Thames Gateway. Published in August 2004, this statement (Document TfL/20) summarises the latest agreed high level planning strategy for the Thames Gateway and the requirements to deliver the aspirations of the Governments plans for the area. The statement notes that the Regional Planning bodies consider that the housing and employment figures for 2016 in the document could only be achieved if current transport infrastructure planning assumptions are delivered as soon as possible within the 2016 time frame. Those assumptions include the TGB being open by 2013. The statement indicates that the TGB is one of four transport projects critical to success in delivering the Sustainable Communities agenda, because they have the largest effects on increasing the capacity of the region. The other three critical transport projects identified are the Channel Tunnel Rail Link (CTRL), Crossrail, and a Lower Thames Crossing to the east of the existing Dartford Crossing. The statement particularly highlights the need to address poor connectivity between the north and south sides of the river in the Thames Gateway, and identifies the TGB as contributing to solving this problem.
4.18
4.19
The overall aims of the TGB proposal 4.20 The overall aims of the TGB proposal are thus to improve accessibility to and within the Thames Gateway area and to support the regeneration of East London, particularly in the Boroughs immediately adjacent to the proposed TGB. These aims of the scheme would be achieved by:
38
4.21
a. Increasing accessibility to a wider range of amenities, jobs and business and other opportunities b. Reducing the barrier to the movement of people and goods that is formed by the river c. Maximising economic, transport, social, benefits and opportunities to local people environmental and other
d. Integrating local transport networks on both sides of the river e. Providing reliable journey times for all modes of transport f. Achieving value for money g. Implementing high quality design h. Deterring long distance through traffic. 4.22 These aims are accepted by TfL and the local planning authorities of Newham and Greenwich in the Statement of Common Ground (Document TfL/17, paragraph 4.2.3). The TGB is a strategic project, because it would play a part in the enhancement of existing employment opportunities, the creation of new employment opportunities, and the provision of thousands of new homes. But it is not designed to be part of a strategic route. The aim is to deter rather than to encourage long distance through traffic. It is not suggested that the TGB alone would ensure the success of the London part of the Thames Gateway area; nor that, without the TGB, the Thames Gateway project would automatically and necessarily fail. It is contended, however, that the TGB is essential to achieve high quality, dense development within the time scale currently planned at national, regional and local level.
4.23
4.24
THE PLANNING APPLICATIONS The proposed scheme - highway design Scheme brief 4.25 The overall aims of the TGB proposal were reflected in the scheme brief for the highway design, which was to provide: a. A six lane bridge, of which two lanes would be dedicated for busway
39
use to connect the East London Transit (the ELT) on the north side of the river with the Greenwich Waterfront Transit (the GWT) on the south. b. Light rail compatibility. c. Separate provision for pedestrians and cyclists. d. A local link with the primary purpose of supporting regeneration of the Thames Gateway. e. Approach works to connect to the existing local road network at the A13/A406 junction to the north and with the A2016 to the south. Scheme description 4.26 The scheme is illustrated by figures B1 to B4 of Document TfL/P/02/3, save for the amendment in the area of Barnham Drive referred to at paragraph 1.19 above. The overall length of the scheme would be some 4.8km. This would include the new special road, with a length of 3.37km and other proposed highways, all as shown on plan number TfL/TGB/SRS/1 in the A2012 GLA Road (Thames Gateway Bridge) Special Roads and Bridge Scheme 2004 (Document D834). The scheme is described in the following paragraphs, proceeding broadly from north to south. The south-eastern end of the A406 North Circular Road is at its junction with the A13 road. This grade separated junction consists of a signalcontrolled roundabout beneath which the A13 road passes on an approximately east/west axis. The scheme would meet the A406 a short distance to the north of this junction and would pass over the junction on a prominent new viaduct as a dual two-lane carriageway. Traffic wishing to turn between the A13 and the new road would be accommodated by a slip road rising from the roundabout (for southbound traffic) and a slip road descending from the new road to the Royal Docks Road/Eric Clarke Lane/Claps Gate Lane junction, from which northbound traffic on the scheme could gain access to the roundabout. The roundabout and the Claps Gate Lane junction would be enlarged. The scheme would bridge over Eric Clarke Lane to the east of the Claps Gate Lane junction. The scheme would continue on embankments and viaducts southwards as a dual three lane carriageway towards its junction with Armada Way (to the east) and the A1020 Royal Docks Road (to the west and south), known as the Winsor Terrace Junction. This would be a grade separated junction with a low level roundabout over which the scheme would pass as a dual two lane carriageway. New or improved footpath/cycleways would be provided at ground level to the west of this section of the scheme, connecting to existing facilities near the A13, to Gallions Reach Shopping Park and elsewhere as shown on Figure B6 of Document TfL/P/02/3.
4.27
4.28
40
4.29
To the south of the proposed Winsor Terrace Junction the scheme would continue as a dual two lane carriageway on an embankment, connecting to a viaduct beneath which the existing rail access to the DLR Depot would pass. The viaduct would continue, turning to the south-east and leading to the TGB, which would cross the river approximately at right angles to the banks. The ground level new or improved footway/cycleway previously mentioned would continue south to Woolwich Manor Way, from which a ramp for pedestrians, cyclists and public transport vehicles would climb to meet the main line of the scheme, some 300m west of the river bank. Connection would be possible between the foot of this ramp and the proposed ELT. A permanent operations and maintenance compound would be located close to the scheme, a short distance south-east of its crossing of the DLR. The compound, shown on figures B2 and B7 of TfL/P/02/3 would contain three buildings and other facilities needed for the operation of the bridge. Among these would be an office for the use of staff administering the electronic toll collection system. The design of these buildings would be required by condition to be submitted to the local planning authority for subsequent approval. From this point, the scheme would continue across the river, on an alignment straight in plan, as a triple two lane carriageway road. The north-eastern and central carriageways would be for all motor traffic, and the south-western carriageway would be for buses, although capable of modification to accommodate trams or light rail. Overhead power supply cables for trams or light rail could be provided within the public transport lanes. A shared footway/cycleway 4m wide would be provided on the south-western side of the bridge. The scheme would pass some 40m above the north river bank and about 37.5m above the south bank. Lift access to the bridge for pedestrians and cyclists would be provided on each side of the river. Two possible lift locations are identified on each side. Off-line cycleways would be provided broadly parallel to the scheme north of the river, connecting with it at various points, and they would also connect frequently with the local cycle networks. The scheme would ascend at a gradient of 5% from a point near the DLR crossing to a long crest near the centre of the river, falling at a similar gradient from the crest to the south east. The maximum road level of the bridge would be 58m above Ordnance Datum (AOD), subject to an allowance of 1m up or down to accommodate variations in the design at the detailed design stage. The north bank of the river on the line of the scheme is about 5.5m AOD, and the south bank, 7.1m AOD. The variation in earthworks on the north bank that would arise from the stated design variation could be accommodated within the land included in the Compulsory Purchase Order. The pedestrian/cycle access from Woolwich Manor Way up to the scheme would slope at up to 5%. Pedestrians and cyclists could be physically discomforted using the TGB if the crosswind gust speed is above 14.4 metres per second (i.e. Met Office
41
4.30
4.31
4.32
4.33
Gale Force 7), although parapets along the TGB edge would provide some protection from the wind, especially south westerly winds. At this wind speed, however, there is no specific danger of being blown off the edge of the TGB. Such wind speeds could occur for 730 hours per year, approximately half of which would be during the evening or night times, when the number of pedestrians and cyclists using the TGB would be likely to be low. No barrier would be provided between the footway/cycleway and public transport corridor unless that corridor were to be used for light rail rather than buses. 4.34 The bridge would present a long 5% downhill gradient to cyclists which might lead to excessive speed. To constrain cycle speeds, chicanes and barriers might be introduced on the footway/cycleway, and the bridge operator would be instructed to take enforcement action against cyclists who use the public transport lanes. Such use would contravene the Traffic Regulation Order. On the south bank, the scheme would descend on a viaduct through Tripcock Park to alight on an embankment a short distance south east of Barnham Drive. A little further on the scheme would diverge; the two all traffic carriageways would continue towards the Thamesmead Junction, while the busway and the pedestrian/cycleway would turn away from the main alignment into the Barnham Drive Public Transport Loop. At the Thamesmead Junction, the existing roundabout at the junction of Central Way, Western Way, Eastern Way and White Hart Avenue would be replaced by a composite junction incorporating a roundabout and other features, with signal-controlled cycle and pedestrian facilities on each arm. The main line of the scheme would pass over this junction, to which it would be connected by on- and off-slips, and would connect directly into A2016 Eastern Way a little way further south-east. As a result of these changes, access to or from Nathan Way could no longer be taken, as it can at present, from or to the eastbound side of Eastern Way. Instead, such movements would be provided for by a new junction between White Hart Avenue and the eastern part of Purland Road and a new length of road eastwards from Purland Road to Nathan Way. Beyond Barnham Drive and the Thamesmead Junction, the scheme would provide public transport connections to the GWT and would connect at several points with the existing pedestrian and cycleway networks, and with those proposed for the White Hart Triangle and Tripcock Park. The Thames Path which runs alongside the south bank of the river would be upgraded through the scheme corridor as part of the works. Figure B6 of TfL/P/02/3 illustrates existing and proposed footways and cycleways on and near the scheme. Noise barriers would be provided at various locations throughout the scheme as shown on Figures B1 to B4 of TfL/P/02/3. The final details of these would be subject to approval by the local planning authorities.
4.35
4.36
4.37
4.38
42
4.39
Surface water drainage from the scheme would be via petrol interceptors and, where necessary, attenuation ponds to either the A406 highway drainage system (at the extreme north of the scheme), Whitings Sewer (classified as main river by the Environment Agency), the River Thames, the Gallions Canal or the existing highway drainage system near Thamesmead. The forms of the attenuation ponds would be determined at the detailed design stage. Discharges to Whitings Sewer and the Thames would require a Discharge Consent from the Environment Agency (EA) under the Water Resources Act 1991 (D218). As indicated in Document TfL/79, the EA expects that such consents would be issued as a matter of routine. Discharges to the River Thames would require a Drainage Outfall Licence, issued under the Food and Environmental Protection Act 1985 (D205). The PLA, EA and local planning authorities are content with the proposed planning condition 29 in Documents TfL/24T and TfL/24U, requiring the submission of surface water drainage details for approval, and thus no difficulty is expected with regard to such a licence being issued at the appropriate time. Street lighting would be provided throughout the new road. In view of the proximity of LCY, full cut-off flat glass lanterns would be used. The detailed design of the lighting installation would be subject to approval by the local planning authorities in consultation with LCY, the Civil Aviation Authority (CAA) and the PLA. Where plant or equipment belonging to a utility company would be affected by the scheme, mitigation, protection or diversion measures have been agreed in principle and cost estimates provided by the utility companies. To enhance the safety of the public on the scheme, closed circuit television would be provided to allow the roads, footways, cycleways and lifts to be monitored. Arrangements for monitoring would be made by TfL.
4.40
4.41
4.42
Traffic Regulation Order 4.43 Use of the busway on the scheme would be controlled by a Traffic Regulation Order, which would restrict the use to local public transport services, emergency vehicles and maintenance vehicles. Taxis and buses other than local buses (for example, tourist coaches) would be required to travel in the general traffic lanes. The Order would also restrict the use of the pedestrian/cycleway to use by pedestrians and cyclists.
Scheme modifications 4.44 The proposals for the Barnham Drive public transport loop were changed during the inquiry, as indicated at paragraph 1.19 above. The loop would provide the connection between the scheme and the GWT, and would also connect the footway/cycleway on the bridge to the existing local network of such facilities. While at the time of making the Orders the GWT was proposed to follow the alignment shown on Figure B3 of TfL/P/02/3, TfL
43
decided following public consultation on the route of the GWT that the GWT in West Thamesmead should be located on a different alignment, alongside Western Way. The proposed loop is therefore modified to accommodate this change. There would be a cost saving of about 1.5m. The modified proposal is shown on Figure B3 of TfL/P/02/5. The proposed amendments to the planning application and the Side Roads Order were published and nearby residents notified. No objection or representation was received by the due date of 4 November 2005. In its letter dated 22 September 2005 to the Local Authority Orders section of the Government Office for the North East (Document TfL/161) TfL ask: a. The Secretary of State for Transport to make additional modifications to the Side Roads Order as set out in TfL/159. b. The First Secretary of State (who was then responsible for dealing with the planning applications) to make: i. amendments to the called in planning application originally submitted to Greenwich as described in TfL/161 and illustrated by drawing TBTGRC/P2/HIG/035 in the Design Statement dated July 2004 and updated in March 2005 and September 2005 (TfL/155).
ii. amendments to the Design Statement Volume 2 of the Appendices to the Environmental Statement (July 2004 updated March 2005 and September 2005) as set out in TfL/156. 4.45 A further change is proposed to be made to the published scheme proposals at Barnham Drive. The scheme proposals allow for a separate busway as part of the GWT proposal between Western Way and Central Way. Barnham Drive was incomplete at the time of the inquiry, consisting of a road between Central Way and Grasshaven Way to the north of the scheme; and also consisting of a short cul de sac off Hill View Drive, to the south of the scheme. It is intended that these two sections of Barnham Drive should be connected as a development road in due course, passing beneath the scheme. The busway would be built immediately to the north and west of this proposed development road and would join Barnham Drive close to the east of its junction with Grasshaven Way. Responding to objections, TfL wish to modify their proposals for that junction, previously published and incorporated in the Side Roads Order, the Compulsory Purchase Order and the planning application. The modified proposals would allow a different form of junction and are shown by TfL/42 (the junction layout), figure B8 of TfL/P/02/3 (the Side Road Order as proposed to be modified) and TfL/39 (changes to the Compulsory Purchase Order). Two potential modifications to the scheme, neither of which is supported by TfL, have been evaluated in response to queries at the inquiry. One would make the busway on the bridge and its approaches available to all traffic.
44
4.46
This would require junction alterations at the southern end of the bridge, a new planning application and modification of the Orders. The works cost of this option is estimated to be at least 1.25 million. The other option would provide a dual three lane carriageway over the bridge instead of the triple two lane carriageway proposed. Additional land would be required. Conversion of the bridge and its approaches to this configuration would be disruptive to traffic over a period of about 19 months. The works cost would be about 47.5 million. A new planning application and new Orders would be needed. Travel times for public transport would increase, and some of the potential benefits of the scheme would be lost. Off-site mitigation measures 4.47 Subsequent to TfLs revision during the inquiry of the traffic model and proposed tolling regime, indicative traffic mitigation measures were submitted to the inquiry. These would mitigate the effects of the scheme in Harrow Manorway and in Hurst Lane. It is expected that the GWT would be implemented before the scheme, and that alterations would be made as part of the GWT works to Harrow Manorway to mitigate the combined traffic effects of the GWT and the TGB scheme. The proposals presented to the inquiry were intended to provide sufficient mitigation of the effects of the TGB alone, in the event that the GWT is not implemented before the TGB is opened. No land acquisition would be needed for the measures now proposed. The off-site mitigation measures promoted as part of the scheme were prepared with no allowance for Crossrail, which at the time of the inquiry was the subject of a Bill before Parliament. TfL assume that if Crossrail were to result in increased traffic movements on Harrow Manorway, this would be addressed as part of the Crossrail project. The proposals for Harrow Manorway are shown in TfL/203. This road is a dual carriageway between its junctions with Eastern Way and Yarnton Way, and on the bridge and associated approaches over the railway at Abbey Wood station. A bus lane is present on each carriageway over part of the bridge. The remainder of the road is a single carriageway. The mitigation works would provide a 3m wide bus lane and a single traffic lane up to 4.9m wide on each carriageway of the dual carriageway sections. A single (northbound) 3m wide bus lane would be added to the two traffic lanes on the single carriageway section, where the adjacent footways would in part be reduced to 2m wide - the desirable minimum width for a footway with moderate pedestrian flows. The roundabout at the grade separated Eastern Way junction would be signalised, with an uncontrolled filter for traffic passing from Harrow Manorway to the westbound carriageway of Eastern Way. The roundabout at the Harrow Manorway/Yarnton Way junction would be converted to traffic signal control, with signalised right turn filters and left turn filters. The total estimated cost of these works is 1.83m.
4.48
4.49
4.50
45
4.51
The proposed mitigation measures would allow sufficient carriageway capacity in Harrow Manorway to accommodate the traffic that would arise with the scheme in the assessment year, although monitoring may indicate a need to omit the bus lanes. The modified Harrow Manorway/Eastern Way junction would satisfactorily in the assessment year with the scheme in place. work
4.52
4.53
At the Harrow Manorway/Yarnton Way junction, the scheme, with the proposed mitigation, would cause a general increase in morning and evening peak hour congestion and a doubling of the maximum queue lengths. No mitigation measures are proposed at the Harrow Manorway/Knee Hill/McLeod Road junction. The scheme would increase the queue on the Knee Hill approach to this junction from 10 to 38 passenger car units (pcu) in the morning peak hour and from 2 to 29 pcu in the evening peak hour, while other queues would change by no more than 1 pcu. The situation with the scheme is not significantly different from the situation without the scheme. The western section of Hurst Lane would be converted to one-way working from west to east only. This would prevent its use by traffic seeking a short cut to avoid the right-turn movement at the junction of Knee Hill and the A206.
4.54
4.55
Technical standards 4.56 The scheme alignment would comply with relevant sections of Document D522, the Design Manual for Roads and Bridges (DMRB). The minimum headroom at the crossing of the DLR would comply with the relevant specification (Document D526). The proposed gradient of the bridge and its approaches would comply with DfT Local Transport Note 1/89 Making Way for Cyclists (Document D536) and the Institution of Highways and Transportations Revised Guidelines for Reducing Mobility Handicaps, Towards a Barrier Free Environment (Document D544). The proposed bridge gradient would also allow future conversion of the busway to rail based public transport such as tram or DLR. The width of the public transport lanes would comply with the design standards for the ELT and the GWT (Document D727) which incorporate relevant guidance from the Health and Safety Executive on tramways (Document D542). Carriageway widths generally would meet or exceed the requirements of the DMRB save for a departure from standard in the matter of the proposed slip roads, for which a standard width of 7m with two 3.5m lanes and no hard shoulder or hard strip is proposed. This departure is considered appropriate in the urban context of the scheme, and is approved by TfLs Technical Advice Team (Document D578).
4.57
46
4.58
The A13/A406, Winsor Terrace and Thamesmead junctions were designed in accordance with the DMRB. The standard design computer program TRANSYT was used for the A13/A406 and Thamesmead junctions and the standard ARCADY software was used for the Winsor Terrace junction. Appropriate standard software was used for the assessment of off-site junctions where necessary. The scheme has been the subject of a Road Safety Audit carried out in accordance with the DMRB. The Audit Team report and the Design Team response are contained in Documents D573 and D574. All the recommendations have either been addressed by design modifications or by agreeing exceptions, or are capable of being addressed in detailed design. A departure from DMRB standards is proposed in Harrow Manorway and has been agreed with Greenwich, the highway authority for that road. No offsite mitigation works have been the subject of road safety audits apart from the proposals for Harrow Manorway.
4.59
The proposed scheme - bridge engineering 4.60 This part of the promoters case deals with bridge engineering on that part of the scheme between (a) the abutment at the DLR Beckton Depot to the north of the Thames and (b) the abutment near Barnham Drive in Thamesmead, to the south of the river, illustrated by Figure 1 of TfL/P/03/3. The length of this section would be about 2km. The detailed form of this part of the scheme would be the subject of a subsequent planning application. It would be submitted by the successful bidder for the concession to build and operate the bridge. The requirements for design quality in the tender invitation and the tenderers proposals would be reviewed and assessed by the Design Panel which would be set up as part of the arrangements contained in Document D855. This proposed process is described in more detail at paragraph 4.351 below. The parameters within which the design would be developed would include: a. The requirements of the PLA and LCY in respect of navigation clearance beneath and provision for aircraft traffic above the bridge. These are shown on drawing TBTGRC/P2/TGB/005 revision 4 and TBTGRC/P2/TGB/006 revision 3 in document TfL/24X. The same document presents agreed upper bound limits for temporary works, such as cranes, associated with the construction of the bridge. b. The Design Statement (Document D855), which describes the design principles for the scheme including layout, scale and visual appearance. c. The DMRB. The bridge would be designed for highway loading and for light rail loading. 4.62 The main bridge would be 33.3m wide. To the north of Armada Way, the viaduct would carry only the dual carriageway road and would be 19.85m
47
4.61
wide and the public transport/cycleway/footway ramp would be 13.8m wide. Figure C5 of Document TfL/P/03/3 illustrates the proposed crosssection save that if the public transport corridor was used for buses (as is initially intended) rather than light rail, there would be no barrier between that corridor and the footway/cycleway. 4.63 The main bridge would be supported by two piers in the river, located to provide a main span of between 270m and 290m with navigable channels between and to either side. The specified navigation channel is required to be at least 230m wide. The bridge superstructure could be built in either concrete or steel. Illustrative designs for a concrete bridge have been prepared. The bridge piers in the river would be capable of withstanding collisions with vessels of up to 55,000 deadweight tonnes, the largest ship that could pass safely under the bridge. The approach viaducts would have spans ranging from 60m to 75m, and would be of a form consistent with the external appearance of the main span. Ancillaries and street furniture on the bridge would conform to the Design Statement, and would be consistent with those elsewhere on the scheme. Lighting columns would be provided, and the main bridge would be illuminated by feature lighting. Lighting details would be subject to approval by the local planning authorities, the PLA and LCY. Wind conditions at the site have been investigated. No wind shielding for vehicles would be necessary. The bridge would be likely to be closed, on average, for 1.3 hours each year as a result of adverse weather. This would probably consist of one closure each year. The edge parapet next to the pedestrian and cycle lane should be designed to protect pedestrians and cyclists from the wind, by using solid or partially infilled parapets. The PLA have identified constraints on the form of the bridge with regard to the navigation of vessels beneath it. The bridge would stand some 1.4km east of the end of the runway at LCY, and the height, form and material of the bridge are significant to the operation of the airport. The operational safety of LCY would be secured by planning conditions. The PLA require that the pier at the northern end of the main span should be positioned as shown by Figure C6a of TfL/P/03/3. There is some flexibility in the location of the other main pier and the first viaduct pier on each side (which may also be in the river), as shown by the drawing. The PLAs requirements necessitate a change in the Special Roads and Bridge Scheme from its form as made by TfL on 5 August 2004 (D834) to that shown by Document D859. The headroom beneath the bridge would be 7.8m less than that at the Queen Elizabeth II Bridge at Dartford, and 3.7m more than at Tower Bridge in its open configuration. The Ministry of Defence is satisfied with the
48
4.64
4.65
4.66
4.67
4.68
4.69
proposed clearance beneath the scheme in relation to vessels which it would wish to be able to travel upstream of the proposed bridge. Tate and Lyle take deliveries upstream of the site of the scheme by bulk carrier ship, and are satisfied with the proposal. All but 5% of the 50,000 to 55,000 deadweight tonnes class of bulk carriers would be able to pass beneath the bridge. Cruise vessels that currently use the river would be able to pass beneath the proposed bridge, but the headroom may cause some restriction on the future trade of new, larger cruise ships. 4.70 A Navigation Safety Risk Assessment undertaken by the PLA (Document D815) has identified safety measures that would be needed due to the bridge. Risk control measures, agreed by TfL and the PLA, would be implemented and would maintain risks at the same levels currently adopted by the PLA for the rest of the port. The PLA operate a radar system in the Thames as an aid to navigation. A radar mast associated with this would be close to the new bridge and would be replaced by two installations, one downstream of the bridge and one upstream. It is proposed to mount the downstream equipment on the west tower of the Barking Reach Flood Barrier. Planning permission was granted, subject to conditions, by Newham on 10 March 2005 (Document D860). The upstream equipment would be mounted at Woolwich. Planning permission was granted, subject to conditions, by Greenwich on 27 October 2005 (Document TfL/198). Hydraulic studies have been carried out by HR Wallingford in consultation with the PLA and the EA to assess the effects of the bridge on the river regime. The range of possible pier positions has been tested and the effects described (Table 6.1, Document D853). In general there would be little change to the existing sediment regime. Additional accretion would be limited and would not affect navigation. Any erosion would be limited since the river bed sediments are relatively coarse grained. Once the final proposals for the pier locations and shapes become known, the modelling work would be finalised. Documents TfL/24T and TfL/24U set out the planning conditions proposed for the scheme on the north and south sides of the river. A Construction Environmental Management Manual (CEMM) would be prepared to define how the environmental effects of the construction of the whole scheme would be managed. The first three components of the CEMM would be produced prior to the tendering process to ensure that: a. The concessionaire would identify environmental effects of the proposed works and develop an Ecological Management Plan (EMP) for acceptance by TfL before starting any works; b. Appropriate environmental design management procedures would be implemented during detailed design of the project to ensure that significant environmental impacts are avoided/minimised, wherever practicable; and
49
4.71
4.72
4.73
c. Environmental risks would be identified and managed effectively as part of the contracting arrangement. 4.74 At the detailed design stage, the concessionaire would develop the EMP and, once it is approved, comply with it.
The proposed scheme - the construction site application 4.75 The construction site (in its revised form, referred to at paragraph 1.17 above) would now be located between Armada Way and the River Thames, adjacent to the proposed bridge alignment. In selecting this site, proximity to the proposed bridge and good accessibility by road and river were key considerations. There would also be two smaller temporary working areas located on the south side of the river, alongside the west side of the proposed viaduct and on the west side of the proposed new road north of Western Way. The main working area would include offices for site personnel, car parking, material storage and treatment and prefabrication of construction elements. The sites of these proposed temporary working areas are illustrated by Figure C11 of Document TfL/P/03/3. As indicated above at paragraph 1.26, Addendum 1 to the ES provides a summary of the likely effects of the revised working arrangements now proposed. Planning conditions proposed to be applied to the use of these areas have been designed to minimise the impact of the temporary use, and those in relation to the construction site application are set out in Document TfL/24S. Temporary berthing jetties would be constructed on each side of the river for use by barges and other vessels transporting construction materials and waste to and from the site. They would be removed and the piles reduced to below bed level after completion of construction.
4.76
4.77
4.78
4.79
4.80
Scheme appraisal - traffic, tolling, economic appraisal and public transport Introduction 4.81 The scheme has been appraised in accordance with the DfTs WebTag guidance (Document D524). Thus the effects of the scheme are considered in respect of environment, safety, economy, accessibility and integration; and these are balanced to determine the overall net worth of the project. Additionally, consideration is given to the schemes effects on various regeneration-related matters, which are: constrained local access to job opportunities, poor access to education, training, healthcare and other facilities, poor access to workforces and markets for employers and high
50
levels of unemployment. 4.82 A key objective for the scheme is to improve journey times for local residents and businesses to employment or workforce respectively. The scheme is one of three river crossings which are proposed in order to overcome the barrier effect of the River Thames in East London. The others are: a. the Woolwich extension of the DLR, which has all necessary approvals and which is being progressed. b. Crossrail Line 1, which was the subject of a Parliamentary Bill at the time of the inquiry. In addition, improvements to the crossing capability are planned in the Blackwall area by way of the Silvertown link. 4.84 This group of projects, including the scheme, should be seen as one entity in contributing to transport improvements and the regeneration of East London. However, the analysis set out here focuses on the specific effects of the TGB. The original Appraisal Summary Table (AST) was set out at Table 36 of Document TfL/P/04/5. This was replaced at an early stage of the inquiry by Document TfL/P/04/6/1. When the additional traffic surveys were undertaken during the inquiry as reported in Document TfL/200, there was a further review of the AST, and the final version produced by the promoters is contained in Annex 1 of Document TfL/P/04/8.
4.83
4.85
Existing development and networks 4.86 The London Boroughs of Barking & Dagenham, Bexley, Greenwich, Newham and Redbridge would benefit most from the scheme. The 1.1 million residents of these Boroughs constitute about 15% of the population of London, but only about 9% of the capitals jobs are in those Boroughs. The whole of the Thames Gateway area in London houses almost one-third of Londons population and provides about one-fifth of the jobs in London. By contrast, five Boroughs in West London (Ealing, Hammersmith & Fulham, Hounslow, Richmond and Wandsworth) also make up about 15% of the population but accommodate 13% of the jobs in London. The Thames is a major barrier to movement in the Thames Gateway. The Woolwich Ferry is the only crossing for road users on the 19km stretch of the river between the Blackwall Tunnel and the Dartford Crossing. Public transport crossings for the same area are the Jubilee Line Extension, crossing between North Greenwich and Canning Town, and a bus service through the Blackwall Tunnel. There is no bus service available to the
51
4.87
general public over the Dartford Crossing. Pedestrians and cyclists can cross by the Woolwich Ferry and the adjacent Woolwich Foot Tunnel. 4.88 Interruptions to traffic on the crossings at Blackwall, Woolwich and Dartford caused, for example, by traffic accidents, roadworks or restrictions on ferry operations, can be very disruptive and make journeys across the river, whether by car or bus, very unreliable. Problems with the Blackwall Tunnel in particular can have a widespread effect over East and South East London. All three crossings operate more or less at capacity now at times of peak traffic, and will continue to do so in 2016. Traffic congestion levels in October 2003 are illustrated by Document TfL/118. At that time, roadworks were under way on the A13, and the associated congestion will have been a factor in delays shown on other parallel routes. In the PM peak period, congestion north of the river was more extensive than in the AM peak. With the exception of the A406 approach to the A13, traffic on the roads forecast to be used by TGB traffic was not subject to delay. The scheme would ease those delays on the A406 by providing a flyover of the A406/A13 roundabout for traffic moving between the north and the south of the junction. Delays elsewhere near the northern end of the scheme were small. To the south, there was congestion at Woolwich town centre, Thames Road in Bexley (subsequently dualled), Bexleyheath town centre and along the A207. The key roads approaching the scheme from the south had generally light congestion in the areas that are forecast to be used by TGB traffic. Most railways in this part of London follow radial routes, largely parallel to the river. The DLR Woolwich extension will provide the most easterly river crossing by rail and, if built, Crossrail would provide a further rail crossing of the river, near the Woolwich Ferry. Buses are the other main component of public transport in the area. Many services are centred on Barking, Woolwich and North Greenwich. Buses are particularly important in Thamesmead. The scheme includes no proposal for changing the Woolwich Ferry, but the promoters expect to review the use of the ferry in the light of the effects of the scheme and the DLR Woolwich Extension. The ferry has a capacity of about 150 vehicles per hour in each direction. Parliamentary approval would be needed for any major change in the operation of the ferry.
4.89
4.90
4.91
4.92
Forecast development and committed transport schemes 4.93 The transport appraisal of the scheme incorporates, in the do minimum and other future cases: a. Development assumptions from the draft London Plan (D610), which forecasts substantial growth in population and employment in the Thames Gateway.
52
b.
Public transport proposals which were, at the time of the inquiry, either committed or included in the TfL Investment Plan (D628), including: i. ii. iii. iv. v. vi. vii. viii. ix. DLR Woolwich Extension. East London Transit (Phase 1 and a link to Gallions Reach). Greenwich Waterfront Transit (Phase 1). Channel Tunnel Rail Link including domestic services. Thameslink 2000. East London Line Extension. Rail upgrading as part of re-franchising. Bus service expansion. London Underground frequency/capacity increases due to public private partnership programmes. Terminal 5 links for Heathrow Express and Piccadilly Line. West London Tram and Cross river Tram.
x. xi. c.
The following main highway proposals: i. ii. A13 Ironbridge/Canning Town improvement. Junction improvements on the A13 at A112, A117 and Movers Lane. Plumstead Road environmental improvement. A406 planned improvements. A206 Thames Road dualling in Bexley. M25 widening between the M11 and the Dartford Crossing, from Junction 1b to Junction 3 and from Junction 5 to Junction 7.
iii. iv. v. vi.
53
4.94
The transport model also incorporates the Central London Congestion Charge as introduced in February 2003, but no possible future extensions. Tolls at the Dartford Crossing are modelled at current value, and the Blackwall Tunnel is assumed to remain free of charge. The expected effects on highway capacity of the two Transit schemes and current on-highway bus priority schemes were included in the assessment. The effect of Crossrail was assessed by means of a sensitivity test.
Transport modelling 4.95 Three computer-based models were used to produce forecasts of the likely use of the scheme and its effects on traffic and public transport use elsewhere: a. The LTS model. This is the standard strategic level model used for transport scheme assessment in London. It recognises the principal range of potential impacts of new infrastructure, including the effects of network changes and tolls; and of people choosing to use new or different routes or different travel modes; or to work or live in different places. The LTS model simulates the potential for generating more traffic through longer trips and some trip generation. It predicts the overall pattern of movement arising from a given scenario, and estimates the amount of movement between each modelled pair of travel origins and destinations (the result is known as a trip matrix). It was used in this way to generate trip matrices for various scenarios with and without the scheme and for various toll regimes. b. Two further models were then used to assign to the network the trips that the LTS model had forecast, mode by mode. The first of these was the Local TGX, a local highway network model based on that used by the DfT and the Government Office for London for the East Thames Appraisal Framework study in 1996 to 1998. It is based on the standard SATURN computer software. c. The second assignment model used was TfLs Railplan model, which covers all forms of public transport. Traffic modelling 4.96 The local models were developed and initially calibrated using actual travel patterns in the 2001 base year. Travel patterns were derived from the London Area Transport Surveys and other travel survey data. The Local TGX model was initially calibrated/validated against 1996 traffic count and survey data, then re-calibrated using 2001 survey data to produce the Reference Case Model, which satisfactorily models the principal effects of the TGB over a wide area. Subsequently, following traffic surveys undertaken at 29 junctions in the area during September 2005, the Reference Case Model was re-calibrated and re-validated using the new data to produce the Cordon Model. The new surveys were taken following
54
suggestions that traffic growth in Bexley had been higher since 2001 than originally envisaged. 4.97 The Cordon Model is a refined AM peak traffic model suitable for assessing the traffic effect of the scheme in the core study area (Bexley, East Greenwich and Newham), ensuring that modelled base year traffic flows on local roads there reflect actual traffic levels. The DMRB (Document D522) provides guidance for model validation (Volume 12, Section 2, Part 1, Table 4.2). That guidance was drawn up for inter-urban corridor models, and not for congested city models with multiple routeing options, and so in the case of the proposed scheme it would be extremely difficult to satisfy all the guidelines outlined in the DMRB. Validation should be against independent data, and rigorous justification should be provided if the DMRB recommendation is not followed. There was insufficient data to allow full independent validation. In 2003, this was discussed with ITEA, the Integrated Transport, Economics and Appraisal Division of the DfT, who confirmed that although the validation did not meet certain standard criteria recommended in DMRB, the results were considered fit for the Department of Transports purpose at that time. (The quotation is from the DfT letter of 24 June 2005, exhibited in Document 1774/2/F.) 4.99 The DMRB guidelines are as follows: a. The model convergence criterion: the modelled flows on over 90% of links should change by less than 5% over four consecutive iterations and the delta function should be less than 1%. b. The screenline flow guideline: the GEH statistic (the result of a calculation that combines the absolute and percentage differences between modelled and observed traffic flows to give a measure of goodness of fit) for the total flow across a screenline should be less than 4 for all or nearly all cases. c. The link flow guideline: in not less than 85% of all cases each link should either have a GEH value less than 5 or the observed flow should be within a certain amount of the modelled flow (the DMRB Link Guideline). d. The journey time guidance: for at least 85% of routes the modelled and observed journey times should differ by no more than 15% or, if higher, 1 minute. 4.100 The following table compares the Reference Case Model and the Cordon
55
4.98
Model for the AM peak with the DMRB Guidelines: Traffic Model Calibration: Comparison of DMRB Guidelines With Model Outcomes: AM Peak DMRB Guideline Convergence DMRB At least 90% of links Delta < 1% Overall Screenline Flow GEH<4 in all or nearly all cases Reference Case Model Over 95% Delta < 0.2% GEH<4 in 13 out of 18 cases Cordon Model Over 90% Delta < 0.2% GEH<4 in 15 out of 18 cases
Link Flow: Screenline Links GEH < 5 Link Guideline 85% or more 85% or more 70% 70% 66% 65%
Link Flow: Core Study Area GEH < 5 Link Guideline Journey Time within 15% or 1 minute 85% or more 85% or more 85% or more 43% 43% 67% 54% 54% 59%
4.101 Additional tests have been applied. In discussion with ITEA, it was agreed that an additional consideration of whether the GEH statistic was not less than 8 would be used for the link flow results, and that the performance of the model should also be presented against a 25% variation in modelled and observed journey times. This additional work is not endorsed by ITEA, but was agreed to provide an additional means of understanding the operation of the model. These tests are summarised as follows: Traffic Model Calibration: AM Peak: Additional Tests Additional Test Link Flow: Screenline Links GEH < 8 Link Flow: Core Study Area 75% 77% Reference Case Model Cordon Model
56
GEH < 8 Journey Time within 25% or 1 minute
54% 82%
68% 77%
4.102 The Reference Case Model provides a suitable tool for assessing the principal effects of the TGB over a wide area. The overall performance of the Cordon Model is generally comparable to other models attempting to model traffic in complex urban areas; it is a suitable tool for assessing and testing the impact of the scheme, providing an improved means of assessing traffic flows especially in the Bexley area. Because the TGB would be a river crossing, with limited direct alternatives, forecasts of flows across the bridge will be more robust than for links, where there would be more numerous alternative routes. Traffic modelling cannot provide precise detailed forecasts at the level of every street in a local area. But the modelling evidence which has been provided by TfL delivers a robust forecast of broader changes in traffic which would be expected to use the TGB and the corridors leading to it. Document TfL/307 provides a more lengthy assessment of the reliability and limitations of the evidence available through modelling. The interpeak model 4.103 The interpeak model is directly relevant to conditions during the interpeak period and also allows estimation of the annual traffic figures used for assessment of some environmental effects of the scheme. 4.104 The following table compares the Reference Case Model for the interpeak period with the DMRB Guidelines. No Cordon Model was produced for this period. Traffic Model Calibration: Comparison of DMRB Guidelines With Model Outcomes: Inter Peak DMRB Guideline Convergence DMRB At least 90% of links Delta < 1% Link Flow: Screenline Links GEH < 5 Link Flow 85% or more 65% inbound, 79% outbound Reference Case Model Over 95% Delta < 0.2%
57
Journey Time within 15% or 1 minute
85% or more
59%
PM peak models 4.105 The modelling work described so far has excluded the PM peak. The DMRB seeks rigorous justification of such an exclusion. It was determined that a separate PM peak model would not be necessary, and that PM peak operation of junctions significantly affected by the scheme would be considered separately. This was done by reversing the AM peak flows and then making adjustments to reconcile the 2001 base model with the 2005 traffic survey results. This approach has the potential disadvantage that movements that are easy (such as left turns) in the AM peak might attract more traffic than their reverse (such as the more difficult right turn), and so the PM reversal might synthesise unrealistically high levels of such conflicting traffic. 4.106 The DMRB advises that, for critical movements, it is not advisable to derive unobserved movements in one peak period by transposing the equivalent observed movements from the other peak period. Rigorous justification for doing otherwise is needed. As critical movements across the Thames screenline were surveyed in both directions of travel, it was not necessary to derive unobserved movements in the way described. 4.107 In determining the modelling strategy, it is necessary to consider whether the result will provide an acceptable understanding of the potential traffic (and consequential) effects of the scheme. In this regard, the promoters considered the views of stakeholders, the availability of previous work and the degree to which AM and PM flows differ and could not be dealt with as mirror images. Stakeholders were first consulted in 2003, and no stakeholder concern was apparent until April 2005. The ELRC proposals had no PM model, which the Inspector for that inquiry accepted, and only AM models were available from which to build the scheme model. Traffic levels overall in the PM peak hour are marginally lower than in the AM peak hour, but the flows are not totally reversed. Nevertheless, it was not necessary in terms of the reliability of forecasts of impacts to develop a PM peak model, because the overall traffic conditions do not differ substantially except as regards directionality of the traffic. This is borne out by traffic surveys at six sites in the study area. Traffic forecast reliability 4.108 The performance of the model against the DMRB guidelines is considered satisfactory, given the complexity of the network modelled. It is important to distinguish between the precision of modelling individual link flows, and the general reliability and robustness of the model. The DMRB recognises that traffic modelling can never be precise.
58
4.109 Although there are many uncertainties at the very local level, at the strategic level such factors as planned population growth and the disposition of development are clearly set out in the development plan. There are no plans for other substantial changes to the road network. Hence future traffic demand and the network that will carry it are clear. 4.110 The reliability of a traffic forecast for an individual link will depend to an extent on the number of alternative links that traffic could use instead. Because the scheme would be a river crossing, the number of alternatives is few, and so the flow forecasts on the scheme are robust. As links further from the scheme are considered, two issues arise: the level of detail that is necessary, and the effect of uncertainties inherent in forecasting many years ahead in an area of rapid expected change identified for regeneration. 4.111 It would be unreasonable to expect to forecast flows precisely along every individual residential road. This would require an impractically detailed knowledge of travel behaviour in the area. 4.112 Equally, finely detailed knowledge of the road network in 2016 is not available. The highway authorities are active in making individual small changes to the network in response to existing or new traffic issues, and the cumulative effect of these cannot be reliably predicted at the local level. 4.113 In judging the effects of the scheme on individual roads, the context of forecast changes on parallel routes should be considered. Such judgement has been exercised by the promoters with regard to the effects of the scheme and in developing the mitigation strategy set out in the Boroughs Agreement (Document TfL/22C). 4.114 The approach taken provides a robust forecast of broader changes in traffic expected to use the scheme and along the corridors leading to it and along other corridors or across screenlines. Local junction traffic models 4.115 Detailed junction models have been prepared to assess the future performance of each of the 29 junctions surveyed. These models incorporate the 2005 traffic survey data so as to allow for any differences between the base year 2001 forecasts and those survey results. This necessarily introduces double counting of the 2001 to 2005 traffic growth, which is included in the Cordon Model forecasts from 2001 to 2016. The projections are therefore robust in this regard. Public transport model 4.116 The local public transport model was developed from that produced early in 2003 for Crossrail, and refined to make it more suitable for the scheme. Travel patterns were developed from the LTS model and assigned to the
59
refined Local-Railplan model, producing forecasts for the AM peak period (0700 to 1000) for 2016. The model incorporates the best estimate of bus service levels in 2016 although, because of the flexibility of bus scheduling and the long forward projection, these are unlikely to represent a firm assessment of conditions then. Allowance is also made for the ELT and the GWT, and the possibility that Crossrail might also be available is included. 4.117 Document D821 sets out the public transport model validation report, which concludes that the calibrated model provides a robust foundation for the appraisal of the public transport aspects of the scheme. Modelled values of time 4.118 The changes in travel time associated with a scheme are an important consideration in its assessment. Time spent travelling during working hours is a cost to the employers business, and the assumption is made in the assessment that savings in travel time during working hours convert nonproductive time to productive use. Most journeys, including travel to work trips made in the employees own time, are not made during working hours, but nevertheless people implicitly put a value on their own time and will trade a cheaper, slower journey against a faster, more expensive one. 4.119 Behavioural values of time used in the highway model (for drivers and passengers in motorised road vehicles other than public transport) are based on information produced by the Transport Research Laboratory and provided in discussion with the DfT regarding values of time for use in modelling of congestion charging or tolling options for multi-modal studies (Document TfL/59). The perceived values of time so derived were factored to take account of vehicle occupancy based on the DfT Transport Economics Note (D572) and inflation in the value of time in real terms expected by the 2016 assessment year. Those factored values were included in the toll assessment. Tables 3, 4 and 5 of TfL/P/04/5 present the findings. The standard TUBA computer program was used to carry out the economic appraisal for highway users. 4.120 The values of time used in the public transport appraisal are based on TfLs standard business case processes, and are summarised in Table 6 of TfL/P/04/5. Modelled future years 4.121 The forecasts generated from use of the models have been factored on the basis of observed daily and annual traffic variations to provide modelled daily and annual flow data. Allowance is also made for interaction between the scheme and other cross river traffic, and for the effect of tolls. 4.122 The scheme would be expected to open in 2013. The London Plan time horizon for the modelled development changes is the year 2016, which is accordingly used as the assessment year for the scheme. The model and
60
appraisal assume the full effects of the scheme would emerge by 2016. Subsequently, longer-term annual traffic growth in the local area of less than 1% may arise, but this would be constrained by the lack of additional capacity in the road network. The proposed toll regime has been designed to restrain further any undesirable traffic growth while allowing the TGB to remain relatively free-flowing. 4.123 The DMRB guidance is that, as an absolute minimum, forecasts should be prepared for at least two years, and these should be within one or two years of the anticipated opening and of the 15th year. Rigorous justification for alternative courses of action is required by the DMRB. Forecasts for two years were prepared: the latest year for which population and employment forecasts are available (2016, the end of the current London Plan period), and 2021. The scheme is a special case and DMRB guidance is not entirely appropriate. Large changes in travel patterns would arise from the scheme, which would not all have taken place one or two years after opening and so the 2016 forecast is better. Since the scheme would be tolled so as to stop congestion on it, the normal trend-based forecast is not appropriate, and the 2021 forecast has been used (10 years after opening) to represent the period after 2021. Because of the intended tolling regime, this approach is robust. Alternatives considered 4.124 Various alternative excluded: crossings were considered. Those considerations
a. A further public transport only crossing, because such crossings were already proposed in the forms of the DLR Woolwich extension and the Crossrail line; and b. A crossing without segregated public transport provision, because of the Governments and the Mayor of Londons commitment to maximising the use of public transport. 4.125 The options that were considered involved alternative locations for the scheme, and alternative infrastructure provision at the crossing. 4.126 Five alternative locations for a new crossing and one alternative alignment were evaluated against criteria that required the preferred option to serve new development sites, connect well with the current and proposed road network and with public transport, be practicable in engineering terms without major impacts on existing development and not have serious environmental impacts. The finding is that the scheme would perform better than any of the alternatives considered. 4.127 A tunnel option was rejected on grounds of cost, increased disturbance of contaminated land, higher operational cost, difficulty in providing a transit connection to Gallions Reach Station and poor environment for pedestrians
61
and cyclists. A number of alternative highway junction layouts and link alignments were considered but none performed better than the scheme. 4.128 Alternative forms of public transport provision on the bridge were also considered. Heavy rail would be too costly, because of the extent of the works needed to connect to the national rail network (perhaps from Custom House to Erith) and the longer elevated approaches needed to the bridge because of the necessarily slacker gradient required by rail. An extension of the DLR would have a worse business case than the bus proposals in the scheme since the DLR option would cost 50m more, reduce the convenience of DLR services to Beckton and provide no additional net benefit. Light rail or tram services over the new bridge would not attract enough passengers to be economically justified. Nevertheless, the scheme has been designed to allow upgrading to light rail or DLR should this be justified later. Background growth in travel demand 4.129 The LTS forecasts for the do-minimum case in 2016 include, among other things, the following: a. An increase in the overall number of trips in the LTS area. b. An increase in road traffic. During the AM peak hour the amount of traffic (measured in vehicle kilometres during that hour) in the five Boroughs (Barking & Dagenham, Bexley, Greenwich, Newham and Redbridge) is estimated to increase by 12% (Document TfL/208). c. An increase in public transport traffic, by about 25% across London and by about 35% in the four Boroughs (Barking & Dagenham, Bexley, Greenwich and Newham), reflecting the effects of the public transport schemes included in the do-minimum case. The public transport share of all trips is expected to increase. 4.130 The DMRB requires that, when aggregated to district level, the resultant trip end growth must match that derived from the National Trip End Model (NTEM) estimates. Rigorous justification is sought for alternative courses of action. This requirement is particularly relevant to inter-urban schemes whereas this scheme is principally local in its effects. Indeed the DMRB recommends that National Road Traffic Forecasts (NRTF) should not be used for car trips in urban areas. The scheme forecasts are based on the London Plan and the higher-tier LTS model. It is compared with the NTEM (or TEMPRO) forecasts in the following table:
62
Comparison of traffic growth forecasts for the Five Boroughs (change in car trips) 2001 to 2016 Tempro Policy model Tempro Trend model Scheme forecast +20% 2016 to 2021 +4% 2021 to 2031 +6.5%
+12%
+3%
+2%
+10%
+4%
Nil
4.131 The DMRB recommends high growth and low growth forecasts for each assessment year but this refers to the use of NTEM forecasts, which were not used. However, a high traffic scenario for TGB traffic was examined. 4.132 In cases where growth factors are based on higher tier models, the DMRB requires that the higher tier model must have been thoroughly validated. Such validation must confirm that the input assumptions (such as land use, economic growth and car ownership) are consistent with those on the NTEM or NRTF. Rigorous justification is sought for alternative courses of action. The higher tier model (LTS) has been validated and its input assumptions are broadly consistent with NTEM. 4.133 The DMRB requires that the realism of any growth constraint techniques used must be demonstrated and their use justified. No growth constraint technique as envisaged in this section of the DMRB was used. Use of the LTS model makes allowance for the more complex influences on future travel patterns. Tolls 4.134 Tolls would be charged for the use of the bridge by motor vehicles (other than on the busway) and certain other classes of vehicle listed below. The purposes of the tolls would include: a. To control traffic; more particularly, to help local people use the TGB, particularly those people who live in areas targeted for regeneration and of relative deprivation, while aiming to limit traffic growth so as to control congestion and manage adverse environmental impacts. b. To generate revenue to help pay for the scheme.
63
4.135 The tolls would have the following features: a. Tolls on the TGB would be higher than those on the Dartford Crossing. All the modelling undertaken has proceeded on this basis. b. Car-driving local residents, that is those living in a defined area (the discount area), would pay less than other car drivers. c. A day pass system for commercial vehicles, allowing them to cross the new bridge repeatedly while paying only for the first two crossings. It is judged that a 50% premium over the toll at Dartford would be enough to minimise potential transfers of through traffic. d. There would be flexibility in setting tolls within the maximum allowed by the Toll Order. This flexibility would allow the tolls to be used to manage traffic, minimise the likelihood of having to apply for a new Tolling Order (which would create risks to the project funding), and provide scope for reviews of the tolls in the light of any future information. e. The maximum toll allowed by the Order would increase in subsequent years according to a formula set out in the Toll Order so as to preserve the real value of the maximum tolls until the scheme was opened, to increase thereafter in line with the retail price index, and to neutralise the expected natural growth in traffic after the scheme was opened. The original maximum tolls at July 2004 prices for one-way use of the bridge (incorporating the amendment requested by TfL in Document TfL/214) would be: Description of traffic Original maximum toll (July 2004 prices) 6.00
Motor cars, motor cycles and motor caravans Small goods vehicles Any other vehicles
8.10 13.05
f. It is expected that in practice tolls lower than the maximum allowed by the Order would be set. Because concerns about congestion relate to peak period traffic levels, higher tolls would manage the use of the bridge so as to reduce traffic volumes there at those times. Tolls would be set from time to time by TfL after consultation with the Councils of the London Boroughs of Barking & Dagenham, Bexley, Greenwich,
64
Newham and Redbridge (all of which would be eligible to join the Boroughs Consultative Group (BCG), and all of which apart from Bexley are willing to do so (TFL/22C)). The extent of the discount area might also be reviewed periodically following consultation with the BCG. g. There is no power in law to include a minimum toll in a toll order, nor any power to require a toll to be charged. The only circumstance in which tolls would not be charged would be where another form of road charging, either national, London-wide or local, would make separate tolling of the scheme unnecessary. The Traffic Management Act 2004 requires TfL, as a local traffic authority, to manage its network so as to secure the expeditious movement of traffic. TfL would be required to exercise its power of tolling reasonably at all times having regard to all material considerations. 4.136 Buses, taxis, private hire vehicles, motor cycles and vehicles displaying a blue badge would be exempt from tolls. The Order also provides exemption for marked police vehicles, fire engines, ambulances, invalid carriages and the like (though only certain invalid carriages would be able to use the footway of the proposed bridge, as indicated in Document TfL/48), and vehicles used in connection with toll collection or the upkeep of the bridge. 4.137 Tolls could be collected with the assistance of an automatic number plate recognition system, similar to that already in use with the Congestion Charge. Cameras would be mounted on gantries above the scheme. No toll plaza would be needed for such a system. Payment would instead be via telephone, the internet and other means similar to those used for the Congestion Charge. Bidders for the concession would be invited to propose a system to a specification prepared by TfL and within the site boundary as identified by the Orders. 4.138 The revenue effects of different toll regimes have been considered, as have the effects on the transport economic benefits of the scheme. Figures D27 and D28 in TfL/P/04/3 illustrate the findings. In finalising the toll proposal, these effects have been balanced against the effects of the scheme on traffic conditions distant from the site and on regeneration. 4.139 The discount area used in the scheme assessment is illustrated on Document TfL/223. That Document shows both the originally planned discount area and the reduced discount area now envisaged following the traffic counts of September 2005 and the development of the Cordon Model. Broadly, the discount area now proposed would include that part of Bexley north of Erith and the A206, the north eastern part of Greenwich, most of Newham, the southernmost part of Redbridge and almost all of Barking & Dagenham. Residents and businesses in those areas would be entitled, upon registration, to reduced tolls, which would be levied in the same manner as tolls payable by others.
65
4.140 If journey time changes were the only changes made by the scheme, then the bridge might form part of routes attractive to long distance through traffic. The proposed tolls were determined following consideration, among other things, of modelled travel times for alternative routes and the modelled values of vehicle travel time, so that vehicle users making long distance trips that might otherwise use the bridge (if untolled) would be deterred from doing so. The tolls that are, subject to review as set out previously, proposed to be implemented initially are as follows: Proposed Tolls (at 2004 prices) Cars Light Goods Vehicles Other Goods Vehicles
Peak Periods (0700 to 1000 and 1600 to 1900 Monday to Friday) Full Toll Discounted toll for local residents Off-Peak Periods Full Toll Discounted toll for local residents 2.00 1.00 2.70 2.70 4.35 4.35 3.00 1.00 4.00 4.00 6.50 6.50
4.141 The key effects on road traffic of the scheme with these tolls would be: a. Journey time savings of 25 to 30 minutes for local cross river journeys, resulting in very substantial improvements in accessibility. b. Total AM peak hour use of the TGB would be some 4,500 vehicles. Some 87% of these would be cars, falling to 81% in the inter peak period. c. AM peak traffic would increase beyond the do minimum case by 4% in the five local Boroughs and by 0.2% in London as a whole. d. The majority (59%) of new traffic associated with the scheme in the four Boroughs would be that on the new bridge and the approaches to it, with 32% on the A13, A406 and A2016.
66
e. AM peak traffic using the new bridge would be predominantly (over 90%) from origins in the four local Boroughs and 45% of non-business car trips would be to or from deprived wards. f. The volume of longer distance through traffic which neither starts nor ends in the four Boroughs nearest the scheme would be less than 2%. g. There would be very little change to traffic levels on other river crossings in East London. h. There would be only small changes in traffic flows on trunk roads (the M11, several kilometres north of the scheme, and the M25 several kilometres to its east) as a result of the scheme. The Highways Agency have been consulted and express no concern. In a letter dated 29 March 2005, the Agency indicate that they regard it as unlikely that through traffic from the M25 would use the TGB to cross the Thames in preference to the Dartford Crossing. That being so, they regard the impact of the proposed TGB as a no change situation in relation to the M25 (Representation no 2042). This conclusion is based on modelling by the TfL team, which the Highways Agency do not necessarily endorse. i. About 35% to 40% of traffic on the scheme (AM peak and interpeak) would be making trips wholly within the four Boroughs.
4.142 Comparison (in Document TfL/89) with the M6 toll road illustrates the likely effect of the tolls on use of the scheme by heavy goods vehicles (HGVs). Even where there is extensive congestion on parallel roads, high levels of toll will deter HGVs. The values of time used in the scheme assessment indicate that a typical HGV user would be willing to pay some 9.70 at 2004 prices to avoid a 30 minute delay. While the evidence from the M6 toll road might suggest that HGV users are more resistant to tolls than the scheme analysis assumes, it does not indicate that HGVs would not be affected by the tolls proposed for the scheme. 4.143 An alternative toll regime was also considered in detail. This was that initially presented to the inquiry. It differed from the scheme proposal in that the alternative would charge the same toll during peak periods as the scheme proposal would charge during off-peak periods; and in that the discount area would be larger, with a greater part of Bexley included. When tested with the re-based model, the alternative was predicted to result in 5,736 vehicles using the new bridge in the AM peak hour and 14% more traffic (than the do-minimum case) crossing the Bexley screenline (TfL/202 figure 1). This could lead to excessive levels of congestion. The scheme proposal, with less peak hour traffic on the bridge and 7% less traffic crossing the Bexley screenline, is therefore to be preferred. Sensitivity analysis high demand and tolls 4.144 Although the modelling described so far is robust within the normal
67
parameters set by the DfT for traffic forecasting, a further assessment (made in response to public consultation) considers the effect of another scenario. 4.145 In that case, it is postulated that more traffic would use the scheme than forecast, in which case tolls higher than previously assumed would be needed to achieve the schemes regenerative objectives and to constrain traffic volumes. This sensitivity analysis examines the situation in which 25% more traffic would be attracted to the scheme than in the Reference Case Model. The finding is that, if tolls were doubled at peak times, then the traffic using the scheme would be reduced broadly to those previously predicted. But this is an extreme scenario, not expected to arise in practice. 4.146 Targeted tolls could be used in the event that traffic patterns associated with the scheme differed in some other way from that modelled. For example, if there were to be more use of the scheme by longer distance through traffic than is expected by the promoters, then general tolls might be increased, but discounted tolls for local residents might remain unchanged. The river crossings package 4.147 In addition to the scheme and the DLR extension to Woolwich (already under construction and with its effects incorporated within the 2016 baseline), new river crossings are being promoted at Silvertown and as part of Crossrail. The expected effect of the Crossrail proposal, if it and the scheme were both implemented, is set out in the promoters evidence on public transport. 4.148 The Silvertown proposal is for a road scheme. It would increase flows in the overall Blackwall corridor, and would reduce traffic flows on the scheme by about 5% in each direction. 4.149 If Crossrail and Silvertown were both implemented, the scheme economic benefits of the TGB would not be undermined. The reasoning to support this statement is set out in Document TfL/199. Performance of junctions within the scheme 4.150 The performances in the 2016 assessment year of the road junctions that would form part of the scheme have been assessed, with the following results: a. The A13/A406 grade-separated junction would include the existing signal-controlled roundabout. Such roundabouts need to be managed so that excessive internal queues do not form, since these may cause the junction to lock up (i.e. become heavily congested). The roundabout
68
has been assessed with the standard TRANSYT software and in accordance with the TRANSYT manual. The highest levels of demand would occur in the PM peak design case. This has been generated by reversing the AM peak flows, and makes no allowance for drivers to use alternative routes to avoid the junction. With high levels of demand, there would be potential for queues to extend beyond the space available on certain links, but such variation would be limited by earlier links in the junction, and there would be capacity where relevant on previous links to hold the excess queue. The software does not allow such an arrangement to be modelled. At times, the junction would have difficulty in accommodating the traffic seeking to use it, as it does today; although the scheme would remove some traffic from the roundabout and improve control. The DMRB identifies that a change in traffic levels of 30% to 60% is likely to be associated with a moderate change in community severance. b. The Winsor Terrace junction has been designed to accommodate the most demanding combination of traffic flows likely to arise there, and would function satisfactorily. This approach is analogous to that recommended by the Institution of Highways and Transportation Guidelines for Traffic Impact Assessment. c. The junction of the scheme with A2016 Eastern Way/Central Way would function in the AM and PM peaks with the average delay per vehicle on any approach not exceeding 24 seconds. Off site traffic mitigation measures 4.151 The effect of the scheme on the local road network was assessed on the following basis: a. All links where one-way traffic flows are modelled to increase as a result of the scheme both by more than 30% and by at least 120 vehicles per hour have been considered in detail to assess whether they are on roads unsuitable for such an increase and whether the changes are likely to result in increased severance. b. Junction performance has been reviewed where the model indicates a significant increase in flows, or where the ratio of traffic volume to junction capacity exceeds 85% and would be increased by more than 2% by the scheme. c. Further detailed assessment of 29 junctions affected by the scheme was also undertaken. 4.152 The main routes to the scheme would be the A406 and Royal Albert Way on the north side of the river, and Eastern Way, Western Way and Harrow Manorway in the south. Roads that would experience more than a 30% traffic increase (and might consequently generate or increase severance)
69
are predominantly purpose built high capacity roads where pedestrian access is already limited and local severance is not relevant. Where this is not the case, the absolute increase attributable to the scheme would be small. If increased severance was experienced then this could be addressed by extra pedestrian facilities and traffic calming. 4.153 Twenty nine existing junctions were identified at which the promoters, following consultation with the local London Borough Council, considered the scheme would be likely to have a material effect on traffic conditions. These were assessed using the appropriate standard computer software or design method recommended by the DMRB. 4.154 Although the TGX traffic model from which the modelled flows derive will not always be a precise representation of current traffic levels on every road, for the 29 key junctions adjustments were made to the appraisal to reflect the variances between the TGX model forecasts for 2001 and the 2005 counts. 4.155 The following off-site traffic mitigation measures are proposed in association with the scheme and are included in the with-scheme modelled scenario: a. Alterations to Harrow Manorway and in Hurst Lane as described in the promoters highways evidence. b. Albert Road/A206 Woolwich Road junction: traffic signals would be provided which would also deal with congestion due to traffic growth not related to the scheme. 4.156 Further traffic mitigation measures have been identified as potentially necessary and would be implemented if appropriate before the scheme is opened to traffic, but not included in the with scheme model: a. Banned right turn from Woolwich Road to Knee Hill and from Bostall Hill to Brampton Road. b. Traffic signal control at the Woolwich Road/New Road junction. c. Mini-roundabout or signal control at the Gilbert Road/St Augustines Road junction. d. A lorry ban in Knee Hill, New Road and Brampton Road and/or route management. e. Traffic calming measures, to be determined, in the Bedonwell Road area and the Sandgate Road area to maintain traffic levels at do minimum levels.
70
f. Public transport priority measures at Picardy Manor Way and perhaps traffic calming. g. Improved route management at Heron Hill/Picardy Road and perhaps traffic calming. h. Signalisation of the Albert Road/A206 Woolwich Road junction, primarily in response to traffic changes not related to the scheme. i. A bus lane at Pettman Crescent and other, minor, changes. The PM peak delay on Plumstead High Street westbound would increase by about 90 seconds. This would be just acceptable and would prompt some traffic to divert elsewhere.
j. Capacity improvements at the A117/A1020 Gallions Roundabout. 4.157 The performance of further road junctions in the 2016 assessment year with the scheme in place has been assessed. The findings are set out in document TfL/210: a. A406/A118 junction: there would be small queues and delays with and without the scheme in the AM and PM peaks. In most cases, delays would be reduced by the scheme. b. A406/A124 junction: the scheme would reduce delays here. c. Harrow Manorway/Knee Hill junction: longer queues would form on the Knee Hill (south) approach as a result of the scheme, increasing delays by about 50 seconds in the AM and PM peaks. Morning peak traffic flows on Knee Hill would increase by 1% northbound and around 19% southbound as a result of the scheme: a two-way increase of around 9%. Because the narrower section of Knee Hill does not have frontage access or bus stops, it could accommodate the busiest direction flows established by TA79/99 Determination of Urban Road Capacity (Document TfL/123) in each direction, and would thus be able to accommodate the estimated 2016 with-scheme modelled flows. d. Brampton Road/King Harolds Way junction: the scheme would cause some extra delays on King Harolds Way in the AM peak, and a reduction in queues on Brampton Road in the PM peak. e. Lower Road/Picardy Road junction: the scheme would cause some delays in the PM peak, affecting only a very small number of vehicles. f. Bronze Age Way/Bexley Road and Bostall Hill/Basildon Road: the scheme would not adversely affect conditions at these junctions.
71
g. Abbey Road/New Road, Woolwich Road/New Road, Brampton Road/Longleigh Lane, Picardy Manor Way/Bronze Age Way, Picardy Manor Way/Lower Road, Erith Road/Picardy Road, junctions: no queues or delays are forecast. h. Crook Log/Brampton Road, Crook Log/Danson Road and Danson Road/Lodge Lane, A13/Woolwich Manor Way junctions: traffic queues and delays would be reduced by the scheme. i. Plumstead Road/Burrage Road junction where delays to one movement would increase in the AM peak but reduce in the PM peak as a result of the scheme; others would be unaffected.
4.158 For ten years after the opening of the scheme, traffic conditions at various other locations would be monitored and, if found necessary as a result of the scheme, measures would be introduced in mitigation. An indicative list of those locations is given in part 2 of Schedule 3 of Document TfL/22C. Such mitigation measures could be proposed by TfL or the BCG and, when agreed by the BCG and TfL, would be carried out by the highway authority for the road principally in question at the expense of the GLA within the following limit. TfL would establish a fund from which the cost of all off-site mitigation works, other than in Harrow Manorway and at its junction with Eastern Way, would be met. The fund value would initially be 14.5m at April 2005 prices, falling as expenditure on monitoring, forecasting and mitigation measures was incurred, but rising to an extent to reflect inflation. The potential costs associated with the additional measures outlined above would be small in relation to the overall contingency allowed in the funding provision. These arrangements are set out more fully in Documents TfL/22C and TfL/22D. 4.159 The cost of off-site mitigation measures, other than those proposed for Harrow Manorway, are compared with the funds available as follows: Costs of off-site mitigation measures Committed expenditure: monitoring and works 4.2 million that would be carried out Further expenditure: proposed monitoring and 4.7 million works that might result Measures that may no longer be required: up to Reserve funds 1.1 million 5.6 million to 6.7 million
72
Total mitigation funds proposed to be available
14.5 million
There is thus a reserve of at least 5.6m out of the total mitigation funding available of 14.5m. 4.160 Among the junctions that have been assessed are a series of sites along the A406 North Circular Road to the north of the scheme. Document TfL/282 (prepared in response to Documents INQ/19 and INQ/20) considers conditions there during the AM peak. That and evidence given orally indicate as follows: a. The modelled flows for 2016 on the A406 mainline between the M11 and the scheme are greater than the modelled flows there for 2001 other than on two links. The exceptions are the northbound carriageway between the A13 and the A124, where a 4% reduction is forecast, and the southbound carriageway, where a 5% reduction is forecast. Factors expected to influence traffic changes along the A406 are set out in TfL/282. b. Document INQ/28 (which raised questions posed by the Inspector regarding the information contained in Document TfL/282) correctly sets out the surveyed and modelled AM peak traffic flows along this section of the A406. The estimated 2016 do-minimum southbound flows here are lower than the 2005 surveyed flows by between 469 (automatic traffic counters, on A406 between A118 and A12) and 1,214 (junction count, A406 approach to A13 junction) pcus per hour, while the northbound 2016 do-minimum flows are up to 640 pcus per hour greater than the 2005 survey findings. Surveyed flows on the A406, other than those directly obtained from automatic traffic counters, are deduced in such a way that they may be subject to cumulative survey error as one proceeds further north. The models assessment of traffic flows on the A406 in 2001 is an underestimate of the flows surveyed in 2005. c. In the light of traffic counts taken at the junctions of the A406 with, respectively, the A124, A118 and A12, the modelled base year traffic flows at those junctions were adjusted. The adjustments so made are reflected in Diagram C of Document INQ/21, where the Inspector has again correctly summarised the evidence put forward by TfL. The differences between the adjusted and unadjusted flows shown in that document are as follows. A specific traffic flow may be represented either in vehicles per hour or in passenger car units per hour; here, a traffic volume reported in pcu/hr would be numerically about 5% higher than its equivalent in veh/hr.
Flow adjustments at A406 Junctions: Base Year Junction Movement Unadjusted flows 73 Adjusted flows
(veh/hr) A406/A124 Northbound off-slip Southbound off-slip A406/A118 Northbound off-slip Northbound on-slip Southbound off-slip A406/A12 Northbound off-slip Southbound on-slip 966 1,082 1,254 835 619 485 929
(pcu/hr) 366 944 721 777 441 691 2401
d. This section of the A406 is an urban motorway in the terms of the DMRBs guidance on urban road capacity. On that basis, the A406 mainline would accommodate the 2005 surveyed flows plus the modelled increase in flows in 2016 due to the scheme, without significant congestion. The model indicates that traffic flows on the A406 would fall during the period between 2005 and 2016. e. Weaving on this section of the A406, with the forecast 2016 with scheme flows, is incorporated in the traffic model. 4.161 Two sites often become congested and would be worsened by the scheme, but no mitigation is proposed in association with the scheme. They are: a. The Plumstead High Street/Wickham Lane junction. There is congestion here in the morning peak and the scheme would make that worse. Greenwich Council would lead in identifying a solution to the underlying issues. b. The A12/A406 junction at Redbridge, where substantial queues are forecast in the assessment year with or without the scheme. There was at the time of the inquiry no firm plan to resolve congestion here. TfL propose to undertake a study in 2006/7 to establish what improvements could be made here. Transport effects of the scheme 4.162 The scheme would result in substantial reductions in journey times for trips crossing the river, with savings of up to 40 minutes (or up to 70%) in the AM peak. Time savings in the inter-peak periods are typically smaller but would still be substantial. An effect of this would be that many people would be brought within reasonable commuting distance of a wider range of jobs; and that many businesses would be able to access larger markets. A typical journey to work in London takes 45 minutes, and the scheme would bring into that range (for example) a fourfold increase in the number of jobs accessible by car from Thamesmead, and an increase of 195% in the
74
population within a similar driving time of Woolwich. There would be benefits too for public transport users with (for example) a 166% increase in employment opportunities for bus users living in Thamesmead, and a 56% increase in the population catchment of Woolwich for those travelling by bus. 4.163 The improved accessibility that the scheme would bring would have three main effects on travel behaviour: a. Some people would divert to the TGB from other river crossings, because the scheme would offer the quickest route for them. About 50 trips would transfer in this way during the AM peak hour in 2016. b. Some people would change their mode of travel. Total annual average daily traffic on the whole modelled network in 2016 would be greater as a result of the scheme by 610,000 vehicle kilometres each day, about 1.75%. Public transport patronage throughout the modelled area would be less in 2016 if the scheme were built (35.8% modal share) than if it were not (35.9% modal share), although both figures are higher than that for 2001 (33.3% modal share). c. Some people would change where they live or work. 4.164 By causing some traffic to divert to cross river trips, the changes in traffic patterns would also affect journey times for some movements that do not cross the river. Most such journeys would experience a small time saving. Transport economic assessment 4.165 The following table summarises the transport economic assessment of the scheme at 1998 prices discounted to 1998. The appraisal period is for 30 years: Item Users Total benefits to highway users Total benefits to public transport users Total effect on users Operators Total costs Total revenues to operators Net effect on operators (revenues less costs) Effect on Government
75
Present Value (m, 1998)
1,635 144 1,779
468 281 -187
Total effect on Government Present Value of Scheme benefits (User benefits + revenues + effect on Government) Present Value of Costs (Capital + operating costs) Net Present Value of Scheme Benefit:cost Ratio
-80 1,980
468
1,512 4.2:1
The benefits the scheme would bring to highway users are reflected in this table as the value of travel time savings (1,758m) plus the saving in vehicle operating costs (160m) minus the cost of extra accidents (108m) and minus user charges (175m), all at 1998 prices discounted to 1998, hence the figure of 1,635 shown in the table. 4.166 When assessed over a 60 year appraisal period, the net present value of the scheme is 3,305m and the benefit:cost ratio is 5.9:1. 4.167 DfT guidance is that a benefit:cost ratio greater than 2 is considered high value for money. Public transport 4.168 The Mayors Transport Strategy (D630) and the London Plan (D620) outline transport improvements proposed for the decade following the start of the inquiry. These include rail improvements intended to meet increased demand for radial movement into Central London, and bus/transit schemes to meet the expected more dispersed and lower flows for local, orbital and feeder public transport services. Figure D2 of Document TfL/P/04/3 illustrates these in their context. 4.169 The rail proposals include two new river crossings: the DLR extension from LCY to Woolwich and, subsequently, a branch of Crossrail Line 1 would connect Abbey Wood railway station via a further new river crossing to Custom House and the Isle of Dogs. The DLR would also be extended to Barking Reach. 4.170 The Thames Gateway Transit network would consist initially of bus transit services, that is, on- or off-road busways used by the latest and most advanced buses and provided with modern bus stops. Local bus services would be restructured to complement the Transit network as it develops. There would be good connections with other public transport. Appendix 1 of TfL/P/04/4 describes the proposal more fully.
76
4.171 On the southern side of the river, the GWT is proposed to link Abbey Wood station to North Greenwich Station via Woolwich town centre. It would serve the key development areas in Thamesmead. The first phase of the GWT is expected to open during 2008/09. The other element of the Transit proposal would be on the north side of the river and would be known as the ELT. This is proposed to have two branches: one between Ilford and Dagenham Dock via Barking, and the other from Barking to Barking Reach. The first phase is expected to open during 2006/07. 4.172 The scheme would provide a segregated route across the Thames for bus transit and conventional bus services, and would connect the GWT and the ELT. This would allow direct journeys between centres such as Abbey Wood and Barking without unnecessary duplication or competing with the DLR extension to Woolwich. The proposed bridge would be capable of accommodating trams if this were later felt appropriate. 4.173 Firm proposals for public transport routes and frequencies across the new bridge, and the types of vehicle (bus or tram) to be used, would be finalised about one or two years before the bridge opened. Currently, on the basis of the expected use of the bridge, bus services at a frequency of about 20 buses per hour are expected to be justifiable. The proposals would provide: a. Direct cross river services, extending and employing upgraded technology as demand grows and the GWT and ELT networks develop. b. The potential for wider direct orbital bus services on the bridges segregated bus route, connecting (for example) Thamesmead or Woolwich with Stratford or Dagenham Dock. c. Faster links to interchanges with the DLR at Gallions Reach (as well as Woolwich) and with national heavy rail at Barking, Woolwich and Abbey Wood and future Crossrail services at Abbey Wood. d. Scope easily to increase public transports ability to meet extra demand as development takes place. 4.174 TfL would regularly review the operation of bus services using the bridge and would consult the local London Borough Councils. The possibility of incorporating alternative technologies, such as trams, on the bridge would be considered along with similar decisions for the GWT and ELT services. 4.175 The scheme would significantly improve public transport journey times for important movements nearby. For example, orbital movements across the river to Beckton, Barking and Custom House would take less than half the current time. But radial movements would be largely unchanged. The public transport accessibility improvements caused by the scheme would be significant, although less than those forecast for highway traffic. About 20 to 25 per cent of all people using the scheme during the AM peak period would do so by public transport, and the total number of people crossing
77
the Thames in East London by public transport would increase by about 1,600 during the AM peak. 4.176 Crossrail would reduce the use of bus services on the scheme by people travelling to radial rail services, and cross river bus services would be primarily used for orbital trips. Crossrail would reduce vehicular traffic on the scheme by about 1.5%. It would also increase traffic in the Harrow Manorway corridor by some 10%, and result in increased use of Knee Hill to access Abbey Wood station. Pedestrians and cyclists 4.177 Given the significant distances involved in using the new bridge, it is unlikely that it would be used as a regular walking route. It would be more likely to be the focus of leisure walking. The bridge would, however, be useful as a regular cycle route. Accident analysis 4.178 The numbers of personal injury accidents (PIAs) with and without the scheme in the assessment year have been assessed using accident frequencies taken from the COBA manual in the DMRB (D522). All links in the modelled area were considered. 4.179 The scheme would lead to a small overall reduction in accident risk, offset by an increase in traffic volume. Annual vehicle kilometres would increase in the modelled area by 0.47%. The net effect of this would be that an extra 121 PIAs are predicted to occur throughout the modelled area in 2016 if the scheme was built. The yearly casualties arising from these accidents are modelled to include 1 fatality, 6 serious injuries and some 114 slight injuries. No change to these estimates was made when the Cordon Model was produced. The DMRB method assumes a positive correlation between traffic volumes and annual accident rates and so, since the Cordon Model shows generally lower flows than the Reference Case Model, this approach is robust . M25 traffic conditions and routeing 4.180 Some objectors suggest that the M25 is heavily congested, and that the scheme would provide part of an alternative route that drivers would find attractive. Information on traffic speeds on the M25 is available on the Highways Agencys web site (TfL/211). This shows that, with the exception of the Dartford Crossing, traffic on each link of the M25 between the M11 and the M20 travels at more than 30 mph at nearly all times. For much of any route to or from the scheme, 30 mph would be the maximum achievable, and speeds would generally be much lower. 4.181 Comparison of modelled 2016 AM peak hour journey time forecasts
78
between the M25/M20 junction and the M25/M11 junction indicates that use of the scheme and local roads would incur a very substantial time penalty of some 20 to 30 minutes. In addition, non-local people would pay a higher toll to use the scheme than they would at Dartford. 4.182 The modelled travel times along the M25 (between the M20 and the M11) are similar to those measured and reported in the Local Model Validation Report (LMVR) (D829). The clockwise movement meets the DMRB validation criterion; the anticlockwise movement does not. While traffic on the M25 is expected to increase in the period to 2016, widening is also planned between the M11 and M20 other than at Dartford, as included in the model. Closures of Blackwall Tunnel and Dartford Crossing 4.183 The Blackwall Tunnel has two broadly parallel bores. In the period 2000 to 2005, there were two major incidents at Blackwall Tunnel resulting in a closure of over two hours. Typically, during each month there are between 2 and 4 closures which last for up to 45 minutes. Records of these incidents are limited. Planned closures of either bore for maintenance occur at night. More detailed information was compiled for the whole of 2005, during which period there were roughly two closures per month of the northbound tunnel and roughly one each month southbound. Half of all closures are for less than 20 minutes. No record was kept of the times of closures. Almost half the incidents related to broken down vehicles. 4.184 The Dartford Crossing consists of the Bridge and the Tunnel. Between 1 January 1998 and 11 July 2005 the bridge was totally closed on 35 occasions, of which 8 were during the weekday peak periods. In the same period, both bores of the tunnel were closed on 30 occasions, including 14 closures during 2004 in which the tunnels were closed for several short periods due to a total of 7 incidents; and one bore only was closed on 56 occasions. Conformity of these proposals with the Development Plan 4.185 Consideration of the planning applications in this case takes place against the background of the current transition from the provisions of the TCPA 1990 and advice contained in Planning Policy Guidance Notes to the reformed system of development control brought about by the amendments contained in the PCPA 2004, supported by advice contained in Planning Policy Statements. 4.186 It remains the case, however, under Section 38(6) of the PCPA 2004, that the determination of a planning application must be made in accordance with the Development Plan unless material considerations indicate otherwise. By paragraph 1(1) of Schedule 8 to the PCPA 2004, a reference to the Development Plan is to be construed as a reference to the spatial development strategy for an area in Greater London and to the Development Plan for the purposes of Section 27 or 54 of the TCPA 1990.
79
Newham and Greenwich are both in Greater London. The GLAA 1999 established the Greater London Authority (GLA), and gave the Mayor of London responsibility for developing a number of statutory strategies for London. The London Plan (Document D620), published by the Mayor of London in February 2004, provides the spatial development strategy for Greater London. 4.187 The other Development Plan documents for the area in which the TGB would be located are the Newham Unitary Development Plan (UDP) 2001 (Document D634) and the Greenwich UDP 1994 (Document D616). A review of the Greenwich UDP was at second deposit draft stage at the opening of the inquiry. By the time the inquiry closed, it was the subject of an Inspectors report which had been considered by the Council. 4.188 In construing the various Development Plan documents, it should be borne in mind that Section 38(5) of the PCPA 2004 provides that, if to any extent a policy contained in the Development Plan for an area conflicts with another policy in the Development Plan, the conflict must be resolved in favour of the policy which is contained in the last document to be adopted, approved or published. 4.189 Section 15(2A) of the TCPA 1990 also provides that a UDP shall not be adopted by a London Borough Council unless it is in general conformity with the spatial development strategy, that is the London Plan. The Newham UDP 4.190 Newham adopted their UDP in June 2001. It was a review of the first Newham UDP, adopted in 1997, and it did not extend the life of that Plan beyond the existing Plan date of 2006/7. 4.191 At section 6.4 of the Statement of Common Ground (Document TfL/17), Newham and TfL identify as relevant policies in the UDP Policies T12 and S33. 4.192 Policy T12 provides that the Council supports in principle the package of Thames crossings as included in Strategic Guidance for London Planning Authorities, namely, a multi-modal bridge crossing at Gallions Reach; a rail tunnel crossing at Woolwich; and a road crossing at Silvertown. The requirement for the TGB scheme to accommodate a number of different modes of transport, especially public transport, cycling and walking, is in line with Policy T5, and the incorporation of the capacity to accept a light rapid transit system over the bridge would be in line with Policy T6. Equally, the existing proposal to run buses in segregated lanes would comply with Policy T7. 4.193 Policy S33 states that the local planning authority will promote and support the physical extension and improvement of the public transport system, in particular to serve major development sites and town centres. The
80
Statement of Common Ground notes that, in Newham, there is a significant number of sites identified as Major Opportunity Zones, several of which are located adjacent to the safeguarded route for the TGB. Some of these sites have already been developed, and the policies contained in the UDP would enable the development of the remaining sites to take place. In particular, in line with Policy T4 of the UDP, the proposed bridge would assist in opening up the former Beckton Gasworks site for comprehensive development. It would also assist the development of Major Opportunity Zones 13 and 15, Albert Dock Basin (North Side) and Beckton Gateway. 4.194 In addition, Policies EQ9, EQ10 EQ11, EQ16 and EQ46 have a bearing on the TGB proposal. 4.195 Policy EQ9 applies a presumption against development which would have an adverse impact on the nature conservation value of designated sites of nature conservation importance. Policy EQ10 lists a series of brownfield sites within which the Council will seek the conservation of existing biodiversity as well as its enhancement in appropriate cases. Policy EQ11 offers protection to protected species or to Biodiversity Action Plan species which are uncommon, declining or under threat in London. Policy EQ16 shows the corridor for the TGB as a green corridor within which development proposals will be expected to retain existing landscape features and to contribute positively to the Councils environmental improvement objectives. Policy EQ46 sets out the Councils policy on air quality management for proposals which lead to the generation of traffic. The Policy provides that the cumulative air pollution impact of existing uses and the proposed development will be a material consideration in the assessment of an application. Where the impact of a proposed development on the use or amenity of land is likely to be significant in air quality terms, the development may be refused or measures to mitigate its impact may be required by the imposition of conditions. The Greenwich UDP 4.196 The Greenwich UDP was adopted in November 1994. It thus dates from a time when the safeguarding for the previous ELRC was still in force. Originally intended to guide development until 2001, its life has been extended to 2006. 4.197 Policy M9 schemes, opposed minimum of the adopted UDP safeguards a number of light rail and highway including ELRC, but Policy M21 makes it plain that Greenwich the proposed ELRC scheme, and would safeguard only the required land.
4.198 When Greenwich considered the current TGB proposal, Policy M21 was not referred to as a relevant policy in the report to the Planning Board (Document D844), because the present proposal does not extend to the A2. 4.199 Greenwich published a First Deposit Draft to review its UDP in March 2002.
81
This was intended to cover the period 2001-2011 (or 2016 in some instances). Following public consultation, a Second Deposit Draft was published in April 2004. It was the subject of a public inquiry in January and February 2005. By the time the TGB inquiry closed, the Inspectors report on the review of the Greenwich UDP had been received by the Council and, in all respects material to this inquiry, had been accepted (see paragraph 2 of Document 2703/58). 4.200 The UDP review provides express support for the TGB. Policy M3(i) advocates the extension of the public transport network into Thamesmead, and Policy M3a mentions with approval the TGB. Policy M13 gives express approval to certain safeguarded schemes, including the TGB. All these policies were retained in the UDP, despite objections to them at the First Deposit Draft stage. Policy M14 seeks to keep new road building in the Borough to an absolute minimum, but accepts road building or improvement where its primary purpose is to facilitate development or regeneration and this will be done in association with a programme of traffic management or major public transport improvements. 4.201 The safeguarded alignment for the TGB scheme would pass through the proposed Tripcock Point District Park. Land to the north is allocated for the proposed Tripcock Point residential led mixed use development. The scheme would also support the development of the Gallions Reach residential development to the south of Tripcock Park and the light industrial development at the White Hart Triangle. 4.202 The UDP review also contains a number of environmental policies which would apply to the TGB scheme. Policy O17 identifies and protects a network of Sites of Nature Conservation Importance (SNCI). One of them is the part of the River Thames within the Borough boundary. Policy O20 relates to protected or priority species. Policy O22 encourages the retention of features of nature conservation interest and the completion of ecological management plans to ensure the maximum degree of wildlife conservation. Policy E6 requires development proposals with the potential to cause a deterioration in air quality to demonstrate measures to reduce the likely impact. Policy E7 indicates that developers should link development to public transport. 4.203 Formal adoption of the review of the Greenwich UDP is likely to take place before a decision is issued on the TGB proposal. If that proves to be the case, confirmation of the fact will be sent by Greenwich to the Secretary of State. The issue of prematurity in relation to the emerging UDP in Greenwich 4.204 Paragraph 17 of The Planning (Document D655) provides that: System: General Principles 2005
In some circumstances, it may be justifiable to refuse planning

82
permission on grounds of prematurity where a development plan document is being prepared or is under review, but it has not yet been adopted. This may be appropriate where a proposed development is so substantial, or where the cumulative effect would be so significant, that granting permission could prejudice the development plan document by predetermining decisions about the scale, location or phasing of new development which are being addressed in the policy in the development plan document. 4.205 Approval of the TGB would not predetermine decisions about the scale, location or phasing of development which is being addressed in the policy of the emerging UDP, because the principle of the river crossing is established by the safeguarding in Policy M9 of the adopted Greenwich UDP. The scheme is an essential part of the infrastructure needed to support economic development in Greenwich. It is specifically supported in Policy M13(iii) of the emerging UDP, which has been retained following consideration of objections to it. There is no phasing proposal which seeks to delay its implementation, and early planning permission would not prejudice other policies of the emerging UDP. 4.206 Events have moved on since the adopted Greenwich UDP was prepared. The ELRC scheme is no longer supported. It is a different (the current) scheme which is supported by more up to date regional policy documents. Where there is conflict between development plan documents, the most recent policy should take precedence. The most recent adopted policy as at the close of the inquiry in this case is contained in the London Plan, with which, in any event, the Greenwich UDP policies are required to be in general conformity under Section 12(3C) and 12(7) of the TCPA 1990. The London Plan 4.207 Turning therefore to the London Plan (Document D620), this was published following an Examination in Public (Document D613) in February 2004. The Plan identifies the key issue for London of accommodating growth sustainably within its borders, without encroaching either on the Green Belt or Londons other open spaces. This is a very substantial challenge in the context of the Plans projections of growth of 636,000 jobs and 800,000 population in London between 2001 and 2016. Achieving this goal requires more intensive development, integration of the scale and phasing of development with public transport availability, ensuring land and other resources are brought forward, and identifying clear spatial priorities. Locating growth in London rather than beyond its boundaries will reduce long distance travel and encourage greater use of public transport rather than the car. But to encourage investment, regeneration and the creation of sustainable communities in the Thames Gateway, the level and quality of infrastructure, including transport infrastructure and services, needs to be greatly improved. 4.208 Objective 5 of the London Plan relates to improving Londons transport. The key policy directions for achieving this objective include:
83
a. improving and expanding Londons public transport through increased and phased investment in services and infrastructure; b. minimising the need to travel and the growth of journey lengths; c. integrating development with public transport to ensure that there is a proper fit between development and the capacity of the public transport network to service it over the period of the plan, taking appropriate opportunities to intensify the use of land where current or future transport capacity allows and connecting Londoners to employment opportunities; d. tackling congestion through levels of restraint of car use appropriate to different parts of London and the provision of alternatives, the improvement of access on foot and cycling and better and safer facilities for pedestrians and cyclists; and e. improving the sustainable movement of freight within and around London, including the use of water and rail. 4.209 Paragraph 3.195 of the London Plan notes that the River Thames restricts development in East London, and that improving access for people, goods and services between the north and south of the Thames is a key priority in the regeneration and development of the Thames Gateway region. 4.210 In particular, the London Plan includes a policy, 3C.14, supporting the principle of the TGB. That policy states that The Mayor supports in principle the new Thames River Crossings in East London. These should achieve regeneration benefits and incorporate high environmental standards. TfL should, in partnership with the London Development Agency (LDA), promote detailed proposals for these crossings. 4.211 In the context of the London Plan, there has been substantial work undertaken on sub regional development framework documents, detailing key London Plan implications and development priorities for individual sub regions. The draft East London sub regional development framework repeats the London Plans analysis of the need for enhanced accessibility across the Thames in East London to encourage suitable development, and the endorsement of the TGB as a key element of the strategy to address this need. 4.212 So far as new roads are concerned, however, London Plan Policy 3C.15 sets out criteria for judging new road schemes in London which state in effect that all road schemes in London should: a. Contribute to Londons economic regeneration and development
84
b. Not increase the net traffic capacity of the corridor unless essential to regeneration c. Provide a net benefit to Londons environment d. Improve safety for all users e. Improve conditions for pedestrians, cyclists, disabled people, public transport and business f. Integrate with local and strategic land use planning policies. Where schemes worsen conditions when judged against any of these criteria, the scheme should not proceed unless benefits in other areas very substantially outweigh any disbenefits, and unavoidable disbenefits are mitigated. UDP policies should incorporate these criteria for assessing road scheme proposals. 4.213 Applying these criteria to the TGB proposals, the scheme would make a vital contribution to the economic regeneration and development of the Thames Gateway. There would be a net increase in the traffic capacity of the corridor, but that would be essential to achieving the vital contribution to regeneration. There would be some adverse impact to Londons environment through additional noise, but there would also be a positive impact through the visual feature of the bridge itself and the landscape proposals for the route corridor. The construction of the TGB would lead to a small overall increase of 1.4% in the number of road casualties in the study area. This is the result of an increase in traffic volume, partially counterbalanced by a greater share of traffic being carried on roads with a lower accident rate. The scheme would improve conditions for pedestrians, cyclists, people with disabilities, public transport and business by providing a footway suitable for wheelchair users, dedicated bus lanes and a cycle path, at the same time offering improved access to markets and labour markets for local businesses. The proposal is integrated with local and strategic land use planning policies. 4.214 The slight adverse impacts in relation to the environment and safety are substantially outweighed by the benefits offered in relation to the other criteria. The proposal therefore complies with Policy 3C.15 of the London Plan. A detailed evaluation of the scheme against the provisions of Policy 3C.15 is contained in Document TfL/REB/1774/2/A. This was updated following the new traffic evidence at paragraphs 2.1.6 to 2.1.8 of Document TfL/P/01/6. 4.215 Policy 2A.2 of the London Plan identifies Opportunity Areas across London which should accommodate substantial numbers of new jobs and homes, together with Areas of Intensification (Policy 2A.3), which have significant potential to accommodate increases in jobs and employment. The location of these areas in relation to the proposed TGB is shown in London Plan map
85
5C.1 (page 241 of Document D620). The proposed TGB would be well related to these areas, with the Royal Docks and Thamesmead Opportunity Areas and the Beckton and Woolwich Town Centre/Royal Arsenal Area of Intensification very close by. Other identified areas in the London Plan which would benefit from the accessibility improvements that the TGB would bring are Barking Reach (now called Barking Riverside), Stratford and Belvedere/Erith. 4.216 The Plan makes clear that regeneration is not just a matter of physical improvements and development, but needs to benefit local communities. Analysis set out in the ES demonstrates that the TGB would bring significant accessibility improvements to local areas of deprivation. To achieve that, it is accepted that action would be needed to improve skills and reduce barriers to employment. The Plan promotes this coordinated approach. 4.217 The Examination in Public Panel Report on the draft London Plan (Document D613) noted that a number of respondents expressed concern that the TGB would result in further traffic and highway congestion and other detrimental impacts. The Panel supported the principle of the proposed new river crossings, however. No change to the policy on river crossings was recommended, but the Panel suggested that it should be made clear that the reference in the draft London Plan to these schemes improving regional and local movement did not mean encouraging longer distance commuting by road. This recommendation was incorporated in paragraph 5.58 of the adopted Plan. The Panel also supported the potential for the two lanes reserved for public transport in the scheme being constructed to be able to accommodate light rail. 4.218 The Panel Report acknowledged that, even though the river crossings are seen as a package, they have differing anticipated construction dates, and each needs to be justified on the basis of its own business case (paragraph 5.29 of Document D613). 4.219 The London Plan underwent a full independent Sustainability Appraisal of each of its policies, in line with the guidance contained in Government Office for London Circular 1/2000 (Document D519). In relation to the Thames crossings policy, the Sustainability Appraisal notes some uncertainties about car dependency and biodiversity and marginal concerns about ecological and amenity quality of the River Thames. These uncertainties are listed in Appendix 5 of Document TfL/P/01/3. However, the Appraisal put these uncertainties in the context of many positive aspects of the TGB from a sustainability perspective, and recognised that mechanisms such as differential tolls might discourage long distance car travel. Other policy documents of the Mayor of London 4.220 The London Plan is part of a series of statutory policy documents produced
86
by the Mayor of London. The Mayors Transport Strategy 4.221 The Mayors Transport Strategy (Document D630) was adopted in July 2001 following statutory consultation. It was revised in July 2004, principally to deal with issues regarding the Central London Congestion Charge, but there was no change to those parts of the Strategy relevant to the TGB. 4.222 The Strategy places a strong emphasis on better public transport facilities, but also recognises the importance of the private car for travel, and of road freight. The Strategy seeks improved journey time reliability for cars, and more reliable, sustainable and efficient distribution of goods and services as two of its ten key objectives. Policy 4G.8 of the Strategy sets similar criteria for the approval of new road schemes to those contained in Policy 3C.15 of the London Plan, listed at paragraph 4.212 above. 4.223 The Strategy acknowledges the significant difference between Central London, where development densities and public transport provision and use are all exceptionally high, and Outer London, where it is accepted that the car plays, and will continue to play, a very significant role even after implementation of the Strategys planned improvements to alternative means of transport. In East London, the Strategy recognises the need to improve transport access, to reduce the north/south barrier caused by the river, and to support regeneration. 4.224 The Transport Strategy outlines a balanced package of new river crossings within East London to improve rail and local road based travel opportunities. In the order of priority given in the Strategy, the river crossings package includes a rail crossing at Woolwich, the TGB at Thamesmead, and a road bridge or tunnel between Silvertown and North Greenwich (the Silvertown link). 4.225 The rail crossing will run as an extension to the DLR under the Thames from LCY to Woolwich Arsenal. It was authorised under the Transport and Works Act 1992 in April 2004. The concession to design, build and maintain the line has been let. Funding for the scheme is identified in TfLs five year investment programme, and it is planned to be in operation by early 2009. 4.226 If approved, the opening of the TGB is planned to take place by 2013. 4.227 The Silvertown link would join the Greenwich Peninsula and the Silvertown/Royal Docks areas. It would aim to ease traffic congestion around the Blackwall Tunnel. It could take the form of a tunnel, but this will only be decided after a further process of assessment and consultation. The Silvertown link is not in TfLs business and investment plan for 2005 to 2010, but it is envisaged that it would follow the planned implementation of the TGB.
87
4.228 Since the publication of the London Plan, a proposal has been developed for a south eastern branch of Crossrail, the major project to link Londons mainline stations by heavy rail. The south eastern branch would cross the Thames in tunnel to provide a major new link between the North Kent Line and the Central London core section of the scheme. As indicated at paragraph 3.65 above, Crossrail is currently the subject of a hybrid Bill in Parliament, seeking powers for the scheme. 4.229 The case for the TGB has been assessed without Crossrail, but sensitivity tests assuming that both the TGB and Crossrail are built have also been covered in the evidence in support of the TGB scheme. London Economic Development Strategy 4.230 The statutory London Economic Development Strategy, prepared by the LDA on behalf of the Mayor of London and published in January 2005 (Document D668), clearly identifies the TGB as important to delivering regeneration and development in East London. It states that The London Plan identifies East London as the Mayors priority area for regeneration, development and infrastructural investment and as the place where a substantial amount of Londons expected growth should be accommodated. However, meeting these objectives will require massive infrastructure investment, particularly in transport (including Crossrail, the TGB and proposed transit schemes). The Mayors Environmental Strategies 4.231 The strategic contribution which the TGB would make to supporting a more sustainable future pattern of development for London, together with TfLs commitments to mitigate negative environmental impacts as set out in the ES, are consistent with the Mayors Environmental Strategies, which address air quality, noise and biodiversity issues. National Planning Policy Guidance 4.232 National land use planning policies are set out in the form of PPGs and PPSs. They indicate the Governments policies on various planning issues, influence regional planning guidance and local Development Plans, and they are a material consideration in the determination of planning applications. 4.233 Issued guidance on Transport (PPG 13), Planning and Pollution Control (PPS 23), Planning and Noise (PPG 24), Nature Conservation (PPS 9) and High Quality and Inclusive Design (PPS 1) are all relevant to the TGB applications, and are dealt with in sections which follow. 4.234 PPS 1 deals also, however, with Delivering Sustainable Development. The principle of sustainable development is a common theme throughout recent
88
Government policy documents. It acknowledges that development should continue, but it implies that it should only take place where it does not use natural resources or pollute the environment to an extent that it leaves future generations unable to continue to develop or to meet their needs. 4.235 The TGB scheme embodies principles of sustainable development by: a. providing a bridge that will meet the economic and social needs of existing and future generations to cross the River Thames in East London; b. including a range of transport modes by means of lanes dedicated for private vehicles, public transport, walking and cycling, with the opportunity of introducing rail based transport in the future; c. reusing former industrial land for the route of the scheme; d. enabling the regeneration of brownfield sites located north and south of the river; e. incorporating measures to protect existing biodiversity; and f. providing an ecologically diverse landscape framework for the proposed highways. Distinction between the TGB proposal and the former ELRC proposal 4.236 In the light of the history of the ELRC proposal, it is emphasised that the proposed TGB contrasts with the ELRC proposal in the following ways: a. Its key objective is to support local regeneration and development rather than to improve accessibility for longer distance traffic. b. It does not link to the inter-regionally strategic A2 route. c. For general traffic, the proposal is for a dual two lane carriageway rather than a dual three lane carriageway. d. It includes segregated provision for public transport, walking and cycling. e. It incorporates a differential tolling strategy to assist in demand management. f. It is being promoted as being part of a wider, public transport focused transport strategy to support a statutory plan that integrates
89
development and transport in a sustainable way. Compliance of the proposals with national planning policy on transport 4.237 The Transport White Paper, A New Deal for Transport: Better for Everyone, published in 1998 (Document D105), introduced the Governments aim for a more integrated transport system based on improved public transport and less dependence on the private car. The aim of the policy was to reduce congestion and pollution. It acknowledged that the development of new roads can have the effect of increasing car traffic and congestion. It called (at paragraph 1.22 of the White Paper) for more integration with land use planning so that transport and planning work together to support more sustainable travel choices and to reduce the need to travel. 4.238 Transport 2010: The Ten Year Plan, produced in 2000 (Document D104) provides a year by year strategy for transforming the transport system up to 2010. The strategy is based on a partnership between the public and private sectors to provide a modern integrated high quality transport system. The Ten Year Plan acknowledges that substantial investment will have to be made in transport infrastructure in London. It specifically endorses (at paragraph 6.72) what it describes as the new East Thames crossings for road and rail and other schemes to improve access to regeneration areas, encouraging investment and jobs. 4.239 PPG13 (Document D637) was revised in 2001, and has as its key objectives the promotion of more sustainable transport choices for both people and for moving freight; the promotion of accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling; and the reduction of the need to travel, especially by car. PPG13 lays particular stress on integrating land use and transport planning in order to increase sustainability. 4.240 PPG13 recognises (in Annex A) that London has its own arrangements for ensuring the sustainable integration of land use and transport through the Mayors strategies. 4.241 The TGB is a multi-modal scheme, with the primary aim of improving access to areas in East London that have potential for regeneration, both north and south of the River Thames. Whilst it is true that the main use of the scheme would be by cars and lorries, TfL have maximised the opportunities for public transport, pedestrians and cyclists at the proposed new crossing by providing segregated lanes and paths, which would encourage these non-car modes. The proposed bus routes would integrate with a public transport interchange at Gallions Reach DLR station. 4.242 The full impact of the Mayors Transport Strategy for maximising the use of non-car modes at the proposed river crossings in East London should be seen in the context of the two additional proposed crossings by rail in that
90
area. These are the DLR extension to Woolwich, and the proposed Crossrail Thames crossing between Custom House and Abbey Wood stations. 4.243 The latest Government transport policy paper is the July 2004 White Paper Future of Transport (Document D108). It notes the importance of striking the right balance between environmental, economic and social objectives. All three are stated to be pillars of the United Kingdoms strategy for sustainable development. 4.244 The proposals for the TGB conform to national transport policy in the following ways: a. the TGB would provide an integrated approach to transport in East London as a multi-modal crossing, providing part of a package with other Thames crossings including the DLR Woolwich extension and the Silvertown crossing; b. the TGB involves a partnership between the public and private sector; c. the TGB conforms to the specific endorsement of the East Thames crossings in Transport 2010: The Ten Year Plan; d. the TGB is a product of integration between transport and development planning in East London; and e. the TGB would enable the provision of an extensive network of bus based travel in East London by linking the proposed ELT with the GWT. 4.245 The TfL five year investment programme commits 1,830m of capital to transport investment in East London. Of that total, all but the 460m allocated to the TGB and the 25m allocated to the dualling of Thames Road in the southern part of the Thames Gateway is intended for public transport schemes. The TGB would also benefit public transport as well as private and business travel. The great majority of current and planned transport investment in London is thus focused on public transport, in line with the Transport Strategys objective of encouraging an increasing proportion of travel to be by public transport rather than by car. The effects of the scheme in relation to noise and pollution Noise and vibration 4.246 PPG24 : Planning and Noise (Document D660) gives guidance to planning authorities on the use of their powers to minimise the adverse impact of noise. Where practicable, noise sensitive developments should be separated from major sources of noise. Equally, noisy developments should be kept away from noise sensitive areas. Where such a separation of land use is not possible, consideration should be given to imposing planning
91
conditions to effect control or mitigation of noise. 4.247 Guidance on new road schemes is given in Annex 3 of PPG24. The advice recommends the use of the Calculation of Road Traffic Noise (Document D517) for the prediction of future noise levels arising from a new road scheme, and the use of the DMRB for the assessment of the noise impact of new road schemes. Subsequently, further advice on noise assessment has been included in the Transport Analysis Guidance website, printed as Document D524. 4.248 The noise impact assessment for this case has been prepared in accordance with that published guidance and in consultation with the affected local London Boroughs and the GLA. At the request of the GLA, the traffic noise predictions were extended beyond the DMRB standard distance of measurement of 300m to 500m either side of the proposed road layout. In addition, again at the request of the GLA, the noise impact on amenity areas up to 1000m from the line of the proposed road was assessed. 4.249 For construction works, noise predictions were carried out for a distance of 200m on either side of planned construction and demolition works. 4.250 Ten representative residential areas were identified for detailed assessment, together with five school sites and a number of commercial sites. There was no other noise sensitive receptor (such as a hospital or church) within the assessment corridor. 4.251 The scheme would affect traffic flows in roads outside the scheme corridor. Noise predictions were therefore made for all properties within 50m of roads outside the scheme corridor which would experience a change in baseline traffic flow of more than plus 25% or more than minus 20%, or which would have a with scheme 18 hour traffic flow of more than 1,000 vehicles Annual Averaged Weekday Traffic Flow (AADT). 4.252 The assessment of operational noise is based on predicted traffic flows in 2016, to allow traffic to build up to a normal level after the predicted opening of the TGB. The current baseline noise climate around the scheme is based on a combination of measurement and prediction, as required by DMRB. The noise climate that would prevail in 2016 should the TGB not be built is assessed by using predicted future traffic flows. When future flows were reassessed during the course of the inquiry, as indicated above, the impact on the operational noise assessments was recalculated, as indicated below. Construction noise and vibration 4.253 The impact of temporary construction noise and vibration can be controlled under powers contained in the Control of Pollution Act 1974. Section 60 of that Act authorises the issue of abatement notices after disturbance has taken place; but Section 61 allows a more proactive approach by requiring
92
prior consent for an agreed programme of work to minimise noise and vibration. TfL are committed to using the Section 61 approach, and suggest the imposition of appropriate planning conditions to achieve this. 4.254 There is no current British Standard for acceptable noise and vibration levels arising from construction work, though an earlier version of BS 5228 (Document D508) suggested that a faade level of 70 Decibels (dB) equivalent continuous sound level over a period of twelve hours would be acceptable at any individual residence. 4.255 For the TGB scheme, TfL would require the concessionaire constructor by contract to restrict construction noise to below 70dB equivalent over one hour at the faade of exposed residential properties and to below 65dB at the faade of noise sensitive properties such as schools. Where best practicable means would not be sufficient to keep noise levels below 75dB, the concessionaire would be required to provide noise insulation to affected sites if the exceedence of the level persisted for more than 10 out of 15 consecutive working days. 4.256 Although the actual construction programme would be finalised only after selection of the contractor, an indicative schedule of works is contained in Chapter 3 of the ES, and this has been used to estimate the incidence of construction noise. The predictions assume that the full range of activities relevant to that particular receptor was taking place simultaneously close to the boundary of the receptor for the full hour. This therefore produces an atypically high predicted noise level, amounting to a worst case scenario. 4.257 The figures produced by the application of this approach demonstrate that there is no residential property where the noise level would breach the TfL criterion of exceeding 75dB for more than 10 days out of any 15 day period. 4.258 In relation to schools which would be affected by the scheme, at Langdon Secondary School and Woolwich Polytechnic School, the noise impact during construction would be negligible. At Gallions Primary School, exposure to noise levels between 65 and 70dB is predicted on 144 days, with 6 days at over 70dB. Exposure at the site of the proposed Tripcock Park School is predicted as 7 days between 65 and 70dB, while at the site of the proposed Gallions Reach School the predicted exposure is 45 days above 70dB and 169 days between 65 and 70dB. For all schools, however, the predicted figures provide over estimates, because they are based upon construction taking place over six days each week continuously throughout the year, whereas schools are operational for five day a week during 39 weeks of the year. The reduced occupancy of the schools means that actual exposure periods would be 62.5% of the predicted exposure periods. The overall impact on the normal operations of the school day would therefore be slight. 4.259 The potential impact of construction vibration would depend largely on the actual piling method used. The choice and monitoring of piling methods
93
would therefore be a feature of the Section 61 agreement. 4.260 That agreement would also detail the methods to be used by the contractor to reduce the noise and vibration impact of construction to the lowest possible practicable level and the monitoring which would take place to ensure that the requirements of the agreement were being followed. Operational noise and vibration 4.261 The impact of operational noise has been assessed using an A weighting applied to the dB value, to aim to match the frequency sensitivity of the sound meter to that of the human ear. As recommended by DMRB, the A weighted sound level that is exceeded for 10% of an 18 hour measurement period has been used to predict residents dissatisfaction with the likely level of traffic noise based on the traffic levels predicted by the traffic model. 4.262 The final noise impact assessment is based on the use of low noise road surfaces throughout the scheme, and the installation of noise barriers to reduce the impact on all noise sensitive properties which would otherwise face an increase of 5dBA as a result of the scheme. 4.263 Normally, a change of at least 3dBA is considered to be required for a perceptible change in noise level to be noticed. Following a change in traffic flow, however, people may find appreciable benefits or disbenefits when noise changes are as small as 1dBA (equivalent to a 25% change in traffic flow). In assessing the TGB scheme, therefore, both the short term impact following the introduction of the scheme and the long term steady state impact have been determined. 4.264 A total of 11,973 properties has been included in the road traffic noise impact assessment. With the scheme in operation and assuming the recommended noise mitigation measures to be in place, 7,260 properties would experience a long term increase in traffic noise of at least 1dBA, and 3,867 properties would experience a similar decrease. 4.265 The noise climate in the area close to the south bank of the Thames is currently low because of the absence of any major road. In this area, the increase in noise levels caused by the scheme would be significant when compared with the predicted future baseline levels. The absolute value of the resulting noise levels would, however, remain below the World Health Organisation (WHO) limits for the onset of moderate community annoyance. Moreover, no single property would qualify for noise insulation under the Noise Insulation Regulations 1975 as a result of the scheme. 4.266 Following the method of DMRB, the predicted noise levels for traffic flows can be translated into numbers of people disturbed by changes in the noise levels. This analysis shows that, immediately following the implementation of the scheme, there would be an increase of 4,569 in the predicted total
94
number of people bothered by traffic noise compared to the baseline. In the longer term, when response to the level of traffic noise tends to revert to the steady state relationship, the predicted number of people bothered by traffic noise would increase by 85 compared to the long term baseline. 4.267 At the request of the Secretary of State, the effect of a 25% increase in traffic above that predicted for the planned operation of the bridge was examined. This analysis showed that a 25% increase in the traffic using the TGB would result in an additional 124 people bothered by traffic noise in the short term, and an additional 20 people bothered by the traffic noise in the longer term. Even with this increase, however, no property would qualify for noise insulation under the 1975 Regulations. 4.268 In terms of night time noise impact on residential properties, some 531 properties would experience an increase in night time noise equal to or greater than 3dBA. The vast majority of these homes would be located on the south side of the river in existing or proposed residential areas that currently are not subject to high levels of traffic noise. For the noisier locations (currently greater than 50dBA), there would be a negligible increase in exposure. 4.269 The WHO suggest that residents need to close their bedroom windows to enjoy sleep undisturbed by traffic noise when the average continuous night time sound level exceeds 42dB. PPG24 suggests a level of 45dB. No property which currently has an average night time (10pm to 6am) continuous average sound level below 45dB would exceed the 45dB limit as a result of the scheme. 4.270 The DMRB provides a different criterion for estimating possible sleep disturbance. Properties at risk are defined as those where, as a result of traffic growth, 68dBA would be exceeded for 10% of the time in each of the 18 one hour periods between 6am and midnight on a typical weekday, and where the average weekday flow between 10pm and 6am is likely to exceed 10% of the total daily traffic flow. Applying that criterion, no property should experience a change in levels of sleep disturbance as a result of the TGB scheme. 4.271 Turning to the impact of predicted operational noise on schools, at Langdon Secondary School, an increase of 0.6dB after the scheme opened would amount to a negligible adverse effect. At Gallions Primary School, the predicted increase of 3.7dB would represent a moderate adverse effect. At Woolwich Polytechnic School, the anticipated 6dB increase would amount to a substantial adverse effect, and the planned schools at Tripcock Park and Gallions Reach are predicted to face substantial adverse rises of 8.5dB and 9.7dB. Those significant increases are, however, the result of the prevailing background levels being so low. In absolute terms, the predicted noise levels at these schools are all below the WHO advisory level for the onset of moderate community annoyance. The peak traffic hours in the area concerned may well also lie outside the school day, so that the effective noise exposure of the schools would be less than the figures appear to
95
show. 4.272 The two local education authorities are exploring with TfL methods for achieving the best possible internal noise conditions within each school. For example, the provision of a noise barrier to the west of the A1020 alongside Royal Docks Road would limit the noise at the most exposed faade of Gallions Primary School to just 1dB over the long term baseline level. 4.273 In relation to the effect of operational noise on public open spaces, along the river banks and within Tripcock Park, the daytime noise levels would be between 46dBA and 52dBA. Those levels are not particularly low, but are typical of parks within London. Expected increases in noise levels in public open spaces would be of the order of 1dB to 3dB. 4.274 The rebasing of the traffic flow forecasts and the adjustments to the tolling regime put forward by TfL in November and December 2005 result in the prediction of an overall reduction of 1% in total vehicle kilometres during the morning peak. This is insignificant in its effect on noise levels. The updated 2016 baseline shows increased traffic flows through some areas of Bexley, however. The revised 2016 two way traffic flowing across a screenline running east-west across Bexley is 70% greater than the previous forecast for the same situation without the TGB. This indicates that the noise impact of increasing traffic in 2016 without the TGB in that area was underestimated in the original ES. 4.275 With the TGB, the new traffic figures combined with the new tolling arrangements lead to a predicted 19% reduction in the total number of vehicles which would use the proposed bridge during the morning peak. This is equivalent to a reduction of 0.9dB in noise levels. The combined annual use of the TGB is predicted to fall by 13%, which would be equivalent to a reduction of 0.6dB in noise levels. Across the Bexley screenline, traffic flows are predicted to increase by 7% above the flows for 2016 without the TGB. This corresponds to an increase of 0.315dB, which would be imperceptible to normal human hearing. 4.276 With the exception of one property in Beckton, all the receptor sites used in the ES would experience a reduction in the noise level rating (the difference between the with scheme noise level and the baseline noise level) as a result of the updating of the traffic flow forecasts. At the exceptional property, the increase in the noise level rating would be 0.2dB, which would not be perceptible. 4.277 The noise levels at all the existing schools would also reduce. In particular, the noise level at Gallions Primary School would fall by 3.2dB, thereby reducing the noise impact from a moderately adverse to a negligible adverse impact. 4.278 On areas in Bexley outside the scheme corridor, there are increases in the noise levels on some roads and decreases on others. The revised traffic
96
data predicts increases in the baseline noise levels for 2016 along 12 of the 16 links assessed. The difference between those new baseline levels and the predicted 2016 with scheme noise levels is equally balanced - there are eight increases and eight decreases. 4.279 For the majority of significant road links, the noise impact would remain unaltered as a result of the revised traffic flow data. For those links where there would be an increase in the with scheme noise level, the relative increase is minor, and insufficient to require an upgrade in the noise impact assessment. 4.280 The revised traffic flow data concerned the morning peak hour traffic. It did not address any change in traffic flow giving rise to night time noise. The evidence regarding the impact of traffic on night time noise levels is thus unaffected by the revised traffic data. 4.281 Airborne vibration impact has been assessed using the methodology of the DMRB. There is a marginal predicted increase of 13 in the number of people who would be bothered by traffic vibration above the number predicted for the long term baseline. This assessment is not varied by the new traffic figures. Air quality 4.282 The proposed TGB would be located in the Thames valley at a point where it is wide and open. There is no significant feature to impede or modify general air-flows across the area. The study area for the air quality assessment is therefore much wider than the immediate surroundings of the TGB and approach roads. It stretches from the City of London in the west to the M25 in the east, and from the southern end of the M1 in the north to the A2 in the south. 4.283 The TGB would be located half way between the centre of London and the M25. It would thus be set in the transitional area between higher levels of air pollutants in Central London and lower rural levels to the east. 4.284 The Governments Air Quality Strategy and Addendum (Documents D102 and D103) set objectives for ten pollutants, based on national standards and EU limit values. In fact, the national standards are at least as stringent as the EU limit values. They set out the extent to which the Government expects a particular standard or guideline to be achieved by a certain date. 4.285 The objectives for seven of the pollutants are prescribed in the Air Quality (England) Regulations 2000 (Document D413) and the Air Quality (England) Amendment Regulations 2002 (Document D414). There are also provisional objectives for PM10 (particulate matter less than 10 micrometres in diameter). These are non-statutory. Under the Air Quality Strategy, all local authorities have to assess air quality within their area against the statutory objectives. If a likely exceedence is identified, then they must
97
declare an Air Quality Management Area (AQMA) and prepare an Action Plan. 4.286 PPS23: Planning and Pollution Control (Document D661) contains advice on when air quality should be a material consideration in development control decisions. It requires consideration of the existing and likely future air quality in an area, including any AQMAs. Appendix 1G to the PPS states that the impact of development is likely to be particularly important a. where the development is proposed inside, or adjacent to an AQMA b. where the development could in itself result in the designation of an AQMA; and c. where to grant planning permission would conflict with, or render unworkable, elements of a local authoritys air quality action plan.
4.287 PPS23 goes on to say that It is not the case that all planning applications for developments inside or adjacent to AQMAs should be refused if the development would result in a deterioration of local air quality. 4.288 The Mayors air quality strategy provides a regional policy context. This recognises that the capital has some of the worst air quality in the UK. It identifies nitrogen dioxide and PM10 as key pollutants in London. It also recognizes that the national objectives for nitrogen dioxide (annual mean) set for 2005 and PM10 (daily mean) set for 2004 will be extremely challenging for London. 4.289 Each individual local planning authority also has its own set of policies aimed at minimising air pollution through the control of development. The policies of Newham and Greenwich are mentioned above at paragraphs 4.195 and 4.202 respectively. 4.290 Nitrogen dioxide and PM10 would be the key pollutants arising from traffic during operation of the TGB, along with dust and PM10 arising during construction. Some consideration was also given to benzene at an early stage of the assessment process, but it was shown that there was no risk of this pollutant exceeding the statutory air quality objective. 4.291 The impact on air quality of changed traffic flows due to the TGB has been assessed by detailed modelling of concentrations across a large area of East London. Concentration maps have been produced, together with results for 27 representative worst case receptors. Account has been taken of typical and worst case weather conditions. The results are assessed against UK objectives. The overall change in exposure for people alongside the roads with the greatest change in traffic has also been calculated. The construction impacts are assessed qualitatively, based on distances from the sources of dust and PM10.
98
4.292 The approach to the assessment was discussed and agreed with the appropriate officers in the relevant local authorities and the GLA. 4.293 Existing air quality across the study area has been established by assembling local authority monitoring data for 2002 and by modelling to show the pattern across the whole area, and not just at the monitoring stations. Measured concentrations for 2003 were also included in the assessment of existing conditions, as concentrations were higher in 2003 than 2002 as a result of the unusual weather conditions in 2003. 4.294 Concentrations of nitrogen dioxide, and to a lesser extent PM10, currently exceed the air quality objectives at various locations. These exceedences are more likely close to busy roads and towards the centre of London. As a result of these exceedences, all the local authorities in the study area, with the exception of Bexley, have declared AQMAs for road traffic. Bexley has an AQMA for industrially related fugitive PM10 emissions. 4.295 Future baseline air quality has been defined by modelling, using a model developed specifically for London at Kings College, London. This model has been used widely by London local authorities and the GLA. 4.296 A considerable improvement in air quality is expected by 2016, partly as a result of lower emissions from new motor vehicles and partly as a result of actions taken in AQMAs. On the other hand, predicted increases in baseline traffic must be taken into account. Overall, it is anticipated that, without the TGB, there would be no exceedence of the PM10 objective in 2016, although there may still be some locations where the annual mean nitrogen dioxide objective is exceeded. 4.297 Changes in traffic due to the TGB would alter exposure to air pollutants for people close to the affected roads. Across the study area these changes would be almost imperceptible. The main increases would occur along the A13, the A406 and the A1020 to the north of the river and the A2016 to the south. Elsewhere, concentrations would increase or decrease due to the TGB, with the majority of the decreases being to the south of the river. Most of these changes would be very small (1-5%). A few moderate increases (up to 11%) would occur, but concentrations at 21 of the 27 chosen worst case receptors would remain well below the objectives. Calculation of the predicted overall change for people living alongside the roads which would be most affected by the TGB shows an overall minor adverse effect more people are exposed to an increase than a decrease. Wider-scale impacts would be related to total emissions. These would decline significantly by 2016 for nitrogen dioxide and PM10 and to a lesser extent for carbon dioxide. The TGB would give rise to an extremely small increase in emissions, which would not be significant. 4.298 Dust emissions during construction can increase dust soiling and PM10 concentrations. For the most important sources, haul routes, there is a residual risk, after mitigation, of soiling effects out to about 100m, whilst
99
for PM10 and vegetation effects may arise out to about 25m. A number of residential properties, allotments, commercial activities, a school and a proposed school, may be affected by dust soiling, with only a few of these also at risk of PM10 effects. Construction vehicles would be likely to have a very small temporary impact on pollutant concentrations along the A406, Royal Docks Road and Central Way. 4.299 Mitigation would be applied through the CEMM. A range of measures would be used to minimise the potential for dust. A programme of monitoring would be agreed with the local authorities. The tolling regime would minimise through traffic during operation of the TGB, while other measures would be agreed with the appropriate local authorities to deal with any local traffic management issues. 4.300 The air quality assessment fully takes account of the national air quality objectives and the presence of AQMAs, both of which are key elements of the Governments and the Mayors air quality strategies, as well as of PPS23. The Association of London Government guidance has been followed, and account taken of the ALG criteria for assessing significance. The impacts have been assessed in relation to the local policies, in particular those of Newham and Greenwich. It is concluded that the TGB would not conflict with these policies. Both Councils accepted that the TGB was not in conflict with these policies when they resolved to grant planning permission. 4.301 The assessment has shown that by 2016, by which time the TGB would be fully operational, there would have been substantial improvements in air quality. This would translate into significant benefits to the health of those living in the study area. The TGB would alter the balance of these health benefits slightly, with some people having a slightly lower risk and others a slightly higher risk. Overall, the TGB would not give rise to noticeable changes to the health of people in the study area. 4.302 Using the revised traffic flow data and allowing for the associated adjustments proposed to be made to the tolling regime would have minimal implications for the modelled air quality. It would not change the links previously identified as busy, and would not therefore affect the choice of representative receptors. It would make no material difference to the assessment of the concentrations which would be found at those receptors. The changes in traffic flow predicted for the most significantly affected links would be slightly smaller than those on the same links in the reference case model. The rebased model gives rise to slightly lower total baseline figures for vehicle kilometres in 2016 with or without the TGB. The rebased traffic figures therefore do not alter the conclusions that the TGB would give rise to only a minor adverse impact on air quality, and that there is no overriding air quality ground to refuse planning permission for the TGB.
100
The effects of the scheme on local flora and fauna and any conservation sites 4.303 The Statement of Matters for the inquiry refers to PPG9: Nature Conservation (paragraph 1.20(d) above). While the inquiry was sitting, this was replaced by PPS9: Biodiversity and Geological Conservation. Among the key principles of PPS9 are: a. Planning decisions should be based upon up to date information about the environmental characteristics of their areas. b. Planning decisions should aim to maintain and enhance, restore or add to biodiversity interests. Appropriate weight should be attached to designated sites of international, national and local importance and to protected species. c. The aim of planning decisions should be to prevent harm to biodiversity. When granting planning permission would result in significant harm, local planning authorities need to be satisfied that the development cannot reasonably be located on any alternative site that would result in less or no harm. In the absence of any such alternative, adequate mitigation measures should be put in place. If the effects of the development cannot be mitigated, appropriate compensation measures should be sought. If significant harm cannot be prevented, mitigated or compensated, then planning permission should be refused. 4.304 Regionally, Policy 3D.12 of the London Plan underlines that opportunities should be taken to achieve positive gains for conservation through the form and design of development. Where appropriate, measures may include creating, enhancing and managing wildlife habitat and natural landscape. 4.305 Relevant policies in the UDPs of Newham and Greenwich are listed at paragraphs 4.195 and 4.202 above. 4.306 The choice of route for the proposed new river crossing was subject to environmental appraisal, in which ecological considerations played a part. The options which were considered are illustrated at Figure 4.1 of the ES figures volume (Document D809). Of the seven alternative alignments considered, Alignment 6 Rainham Marshes to Erith was rejected because it affected the Inner Thames Marshes Site of Special Scientific Interest (SSSI), a nationally important site. Alignment 5 Heart of Thames Gateway to Belvedere was also rejected because it passed close to the Inner Thames Marshes SSSI. 4.307 Once the route had been chosen, land take from sites and habitats of nature conservation significance was reduced during the development of the engineering design. To permit that to take place, however, a detailed environmental assessment of the scheme corridor had to be undertaken.
101
4.308 The environmental assessment of the scheme was carried out in accordance with the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999. The methodology used followed guidance given in DMRB (Document D522) and in the WebTag Guidance (Document D524). Baseline conditions were established by a desk study, supplemented by new fieldwork agreed with key consultees including English Nature (EN), the EA and the Biodiversity Division of the GLA. Baseline conditions 4.309 The area of the scheme is dominated by the River Thames, and the land on both sides of the river falls within the historic floodplain of the river. 4.310 To the north of the river, the area surrounding the route of the proposed TGB scheme is currently dominated by brownfield sites, with derelict and contaminated land from its industrial past. There has been some redevelopment since the 1980s, with many further new developments proposed or currently under construction. 4.311 To the south of the river, Plumstead and Erith Marshes were reclaimed over centuries for use as farmland. During the early nineteenth century, much of the reclaimed land was purchased for use by the former Royal Woolwich Arsenal. The Arsenal closed in 1967, and much of the land has been subject to remediation over the last twenty years prior to redevelopment. The part of the former Arsenal in the vicinity of the scheme is being developed as a public park, Tripcock Park. 4.312 Proposals for the safeguarding of the scheme corridor have protected the corridor from redevelopment over the last twenty five years or so, and the derelict land of the corridor therefore now supports extensive areas of wasteland habitats. Baseline conditions - designated sites 4.313 No internationally or nationally important site would be affected by the TGB scheme. The development would, however, cross two locally important sites, the River Thames and Tidal Tributaries Site of Metropolitan Importance (SMI) and the Beckton Ditches and Grassland Site of Borough Importance (SBI). Four further locally important sites lie adjacent to the scheme boundary, the Cuckolds Haven Nature Reserve SBI, the Greenway and Old Ford Nature Reserve SBI, the Thamesmead Historic Area and Wetlands SBI, and the Birchmere SBI. The location and extent of these sites are shown on the map at Appendix M3 of Document TfL/P/13/3. 4.314 Two further SMIs lie approximately 1.5km to the east and south of the south easterly extremity of the scheme, the Erith Marshes SMI and the Lesnes Abbey Woods and Bostall Woods SMI.
102
4.315 Much of Beckton Meadows, which lie within the Beckton Ditches and Grassland SBI, is identified in the Newham UDP as part of Major Opportunity Zone 15. The Meadows are therefore likely to have been developed and the SBI significantly reduced in area by the planned construction period for the proposed TGB. Baseline conditions - habitats 4.316 The grassland, wasteland and wetland habitats found within the route were evaluated in the ES as being individually of low to medium importance. 4.317 On both sides of the river, inter tidal mudflats are exposed at low tide. On the southern bank, there are small areas of reed bed and scattered salt marsh plants at the upper levels of the foreshore. These are poor examples of habitats which are of national importance, priority habitats within the UK Biodiversity Action Plan (Document D106). They were evaluated in the ES as being individually of low importance. 4.318 Overall, the habitats within the study area were assessed in the ES as being of medium importance because they formed more or less a continuous corridor in an otherwise urban area. Baseline conditions - species 4.319 Seven species afforded full or partial protection under the Wildlife and Countryside Act 1981 were identified within the scheme corridor. 4.320 The water vole is a priority species in the UK Biodiversity Action Plan, and is present in the Thamesmead Historic Area and Wetlands SBI. While no roost was identified, common pipistrelle, soprano pipistrelle and noctule bats were recorded feeding within the same SBI. A small population of grass snake is present on Beckton Meadows. Smooth newts were recorded in the ditch between Eric Clarke Lane and the A13. Two palmate newts, a species less common in London, were noted at the northern end of Beckton Meadows. Although no black redstart was recorded within the study area during the 2003 survey, parts of the scheme corridor support potential breeding and foraging habitats for this species. Black redstart is a priority species in the London Biodiversity Action Plan, and has previously been recorded as breeding within Beckton Gas Works site. 4.321 The River Thames in the vicinity of the scheme makes a major contribution to the over wintering teal population in the inner Thames estuary. 4.322 Whilst there is no evidence to suggest that the Thames in the vicinity of the scheme is of specific value to any fish species recorded, the shallow areas near the margins of the river are likely to represent spawning and feeding areas, and to form part of migration routes.
103
4.323 Overall, the scheme corridor was assessed in the ES to be of medium importance for terrestrial invertebrates, fish and wintering waterfowl. It was assessed to be of low to medium importance for plants, water vole, benthic invertebrates, breeding birds and amphibians. Potential effects of the proposed scheme 4.324 The scheme would involve a temporary land take from the inter tidal mud and sub tidal habitats within the River Thames and Tidal Tributaries SMI. These areas would be required for the construction of the temporary berthing and access jetties and piers referred to at paragraph 4.80 above. 4.325 There would be a loss of 19.3ha of habitats during construction of the TGB scheme, with an additional 1.1ha likely to suffer some degradation due to shading. An area of 15.9ha would be reinstated after construction, with an additional 2ha managed to enhance its wildlife value. Overall, therefore, there would be a net loss of approximately 2.5ha of wildlife habitat to the scheme. 4.326 During construction, the concessionaire would be required to control environmental effects arising from construction activities in accordance with the agreed CEMM. All site clearance and construction works would be required to be carried out to avoid any impact on protected or priority species. Clearance of scrub, trees and wetlands would be programmed, for example, to take place outside the main bird breeding season. The construction site on the north bank of the Thames would be screened from the river in order to reduce the risk of disturbance to waterfowl, including teal. Similarly, solid screening would be used to reduce dust deposition and noise and visual disturbance to sites that support sensitive species of note. 4.327 Following construction, the TGB would cause some shading to river habitats, particularly to the east of the bridge. Shading for more than three hours a day effectively means that the habitat is permanently lost. In that category, there are two small areas of marginal vegetation on the south bank of the Thames - one of approximately 8 sq m dominated by common reed, and a second of approximately 6 sq m dominated by sea couch with small areas of sea aster. 4.328 The introduction of piers into the river channel would not have a significant effect on the river bed ecology away from the piers, but further hydraulic modelling, in consultation with the EA, could be required by condition once the position of the piers within the river channel has been definitely determined. The same approach is planned in relation to mitigation measures to address the potential loss of areas of foreshore used by small and juvenile fish moving up and down the river. 4.329 There would be a land take of around 3ha from the Beckton Ditches and Grassland SBI as a result of the construction of the viaduct over the A13 and the realignment of the A406. This would represent some 9% of the
104
area of the SBI. 4.330 Within Newham, there is a net loss of land of recognised value for biodiversity. As a result, TfL are committed in the Boroughs Agreement to pay to Newham 500,000 to spend on work for the benefit of biodiversity within the Borough. 4.331 During operation, the risk of pollution to watercourses and wetlands close to the road would be a minimised by the direction of surface water run off away from sensitive receptors and by the use of appropriate water treatment systems. The nature conservation value of drainage features such as the three attenuation ponds and the drainage ditch adjacent to the Beckton Ditches and Grassland SBI would be maximised by appropriate detailed design and planting. 4.332 The landscaping of the new road corridor would also provide the opportunity for large areas of habitat creation. The habitats proposed to be created are illustrated at Figures 13.4A to 13.4C of Document D809. They include 6ha of species rich grassland and 2.6ha of woodland. 4.333 In addition, extra shoreline habitat creation is planned if the southern back pier is placed on the foreshore. The low sea wall immediately shorewards of the most extensive area of reeds and other riverside plants present on the foreshore would be removed, leaving an area of about 300 sq m between the current reed bed and the Thames Walk. Reed bed habitat would be created within this newly exposed area of shoreline. 4.334 An area of degraded urban wasteland of around 1.5ha, south of the Winsor Terrace junction with the proposed transit route and the existing A406 would be conserved and managed for nature conservation, as would a second area of approximately 0.5ha north of the Thamesmead Historic Area and Wetland SBI. 4.335 An EMP would be prepared in consultation with relevant organisations to ensure that the areas of habitat created, both within the landscaping of the scheme and elsewhere were managed appropriately. In this way, the value of the habitats created would be maximised, and the objectives of the mitigation and compensation works would be achieved. 4.336 The residual ecological effects resulting from the scheme would thus be: a. temporary and permanent land take from the Beckton Ditches and Grassland SBI (minor adverse effect) b. temporary and permanent land take from the River Thames and Tidal Tributaries SMI, potentially affecting benthic invertebrates and fish (minor adverse effect)
105
c. construction noise and visual disturbance to waterfowl using the River Thames, especially teal (minor adverse effect) d. temporary and permanent land take from habitats used by breeding birds (minor adverse effect) e. temporary and permanent land take from urban wasteland habitats, potentially affecting terrestrial invertebrates (moderate adverse effect). 4.337 Overall, the scheme would have a minor adverse effect on nature conservation and biodiversity. 4.338 EN have no objection in principle to the TGB proposal, and welcome the proposed mitigation and compensation package. EA originally objected to the proposed development, but they decided that their concerns were satisfactorily addressed by the mitigation measures proposed, so long as they were translated into appropriate planning conditions which were imposed on any planning permission granted. EA took part in the two round table conditions sessions held during the inquiry, and were satisfied by the conditions agreed between TfL and the local planning authorities discussed at those sessions. The extent to which the proposal would secure a high quality of design Introduction 4.339 In general, bridge designs can respond creatively to a given set of constraints. In the case of the scheme, the relevant constraints are set out in the Design Statement (Documents D810 and D855). Any design that emerged from the competitive procurement process would be required to adhere to the technical and planning constraints of the illustrative scheme. A Design Panel would be established to ensure compliance with this approach. Although illustrative designs have been prepared for the bridge, it is not intended that those should define its form. Policy context and documentation 4.340 The call-in letter of 19 January 2005 (Document D850) refers to the general advice in Annex A to PPG1 General Policy and Principles, draft PPS1, and current advice on good design practice in By Design Urban Design In The Planning System: Towards Better Practice. Subsequently PPS1 Delivering Sustainable Development (Document D662) was published, and that and By Design (Document D664) set out fundamental principles of design. 4.341 TfL endorse the spirit and content of these documents. They refer to the importance of ensuring high quality development through good and inclusive design, integrated into the natural and built environments. This is reflected in the London Plan (D620), which refers to the importance of high
106
quality design along the River Thames, part of the Blue Ribbon Network. The London Plans second Objective to make London a better city for people to live in is supported by a key policy direction to improve the quality of Londoners lives and their environment through better designed buildings and public spaces. This is spelt out in detail in Chapter 4B of the Plan, where policies present a clear context for a project of the significance and scale of the TGB. Policy 4C.20 says that the Mayor will, and the Boroughs should, seek a high quality of design for all waterside development. Policy 4C.22 requires the unique character and openness of the river to be protected by any structures over it, and the London Plan notes the importance of bridges for communications and service provision and as monuments and tourist attractions. 4.342 The Design Statement meets these broader objectives for design quality, while recognising the need to meet clear technical and operational constraints. The subsequent stages of project development and procurement can ensure that these objectives receive the highest priority in delivering a solution of high design quality. Appropriate mechanisms are in place to ensure this. Urban potential of the scheme 4.343 By virtue of its location, scale, context and nature, the scheme would be much more than just a bridge. It would have significant civic value, of benefit to London as a whole. It would become a major feature in the townscape, with the potential of enhancing views to and from the river. It would, over time, become an integral part of Londons changing lifestyles and landscapes, as long as enough flexibility is allowed to promote integration and connectivity with neighbouring areas. It could act as an important part of a proposed extended group of open spaces (the Green Grid Strategy proposed by the Office of the Deputy Prime Minister in Creating Sustainable Communities: Greening the Gateway, Document TfL/38); the centrepiece of a large-scale regeneration corridor linking open spaces and existing structures that are currently underused. It would contribute strongly to the urban as well as the social landscape of East London. Precedents 4.344 There are many precedents for procuring high quality design through design competitions and through variations of design and construct contracts. These include, for example, the Second Severn Crossing and the Bingley Inner Relief Road, both of which received several awards for the quality of their design; and the Brighton Library, a Private Finance Initiative (PFI) project that was short listed for the Sterling Prize, an important architectural award. 4.345 The most recent and highly successful outcome of a similar process to that proposed for the scheme is the Millau Viaduct, which opened in France in
107
January 2005. This entire project was funded by a tailor-made consortium, awarded the concession by the French Department of Transport and Public Works, in exchange for financing the scheme, estimated at over 300m. A high quality of design was achieved. 4.346 Further examples of good design include the Stonecutters Bridge, currently under construction in Hong Kong, the resund Bridge between Sweden and Denmark (the opening of which is associated with an improvement in inward investment in the region, a decline in unemployment and a dramatic increase in vehicular and public transport use) and the Coronado Bridge at San Diego in the USA. Successful DBFO projects in the UK involving PFI funding such as the system proposed for the scheme, include the M6 toll motorway, the second Severn crossing, sections of the DLR and the Dartford Crossing (TfL/53 and TfL/86). 4.347 In July 2005, the GLA Architecture and Urbanism Unit published Commissioning a sustainable and well-designed city: A guide to competitive selection of architects and urban designers (TfL/106). This guide, written for public bodies, recommends key steps needed to achieve a well-managed and efficient selection process for architects and urban designers. The process is endorsed and would be followed by TfL. Design quality 4.348 Two key attributes in design quality are that of being distinguished above other, lesser, products and that of sustaining appeal for a long time. These derive from the ability of the product to function well, to create a lasting sense of well being and admiration, and to inspire others to achieve quality. The quality of design of the TGB would be important because it should function well and contribute to sustainable development and regeneration in East London; and because such a dominant structure has the potential through its appearance to attract quality riverside development and recreational use. 4.349 The means by which TfL would obtain a high quality of design are set out in the Draft Design Quality Strategy (TfL/46). This describes the procurement process, outlined in paragraphs 4.455 to 4.457 of this report, and the role of the Design Panel, noting that no single definitive design would exist until the preferred bidder has been selected by TfL. The Design Statement (D810) emphasises the importance of high quality design and, critically, TfLs intention to offer the concessionaire the opportunity and flexibility to improve on the illustrative design. It provides the appropriate framework for the development of a more detailed design in the next stage of the procurement process, and is neither so generic as to be valueless nor so prescriptive as to be overly constraining. Design Panel 4.350 The credentials of the Design Panel are set out in considerable detail in
108
Document TfL/45. The Panel members are widely experienced, with backgrounds in architecture, engineering and landscape design. At the time of the inquiry the Panel members and their current appointments were as follows: a. Michael Clarke, TfLs Project Director for the scheme and the TfL Design Champion. b. Professor Ricky Burdett, Centennial Professor of Architecture and Urbanism at the London School of Economics, Project Leader to the GLAs Architecture and Urbanism Unit and architectural advisor to the Mayor of London, and a member of the City of Barcelonas Quality Committee. Professor Burdett is architectural advisor to the BBC, the Tate, the National Heritage Lottery Fund, the Natural History Museum and the British Film Institute and to a number of clients in the private sector. c. Sir Jack Zunz, Non-Executive Director of the Innisfree PFI Fund and a member of the AA Foundation. d. Edmund Hollinghurst, Visiting Professor at Southampton University, Staff Consultant to the Asian Development Bank, Aesthetic Advisor to the Highways Agency and a member of the Design Review Panel of The Commission for Architecture and the Built Environment (CABE). e. Michel Desvigne, a landscape architect. Role of the Design Panel in the selection procedure and design evaluation 4.351 The role of the Design Panel would be: a. At prequalification stage, to define the attributes relating to quality in design which applicants for prequalification should demonstrate, and then to assist in the review of the parts of the submissions relating to design quality. b. At tender stage, to help prepare the definition of design quality in the promoters requirements; to assess each bidders definitive design proposals and report on whether the required design quality has been achieved; to sign off tenderers design proposals before submission of the commercial tenders and, should the Panel wish, to give feedback to tenderers and to suggest improvements to design quality. c. In due course, the design submitted by the preferred bidder would be submitted to the local planning authorities for approval of details required by conditions on the planning permission. At this stage, the Design Panels views on the preferred bid would be made available to the local planning authorities, who would be able to seek further views
109
from the Design Panel and others before reaching their decision in relation to the approval of details. Landscape and visual issues Zones of visual influence 4.352 Primary and Secondary Zones of Visual Influence (ZVI) for the scheme have been established. They are shown on Figure H7 of Document TfL/P/08/3. The Primary ZVI includes areas next to the land needed for the scheme, where receptors would be exposed to foreground views of the scheme or of construction activities. Beyond this, on the south side of the river is the Secondary ZVI, within which there would be intermittent views of the scheme. To the north, the topography results in an indeterminate Secondary ZVI. The scheme may also be visible in the long distance from high buildings beyond the Secondary ZVI. Existing land uses and landscape features 4.353 The scheme corridor includes diverse land uses. To the north of the river are found vacant land, existing transport routes, gas and sewage works, power transmission lines, radio mast sites, waste management facilities and extensive industrial and retail parks. To the south, the scheme would pass a landfill site (expected to become a public park in due course, Tripcock Park), residential areas and land designated for housing. Most of the urban wasteland near the site is rich in grassland species. Viewed from the river banks, the scheme would be set in a broad riverine landscape, disturbed for the most part by seemingly fragmented man-made structures. Policy context 4.354 No international or national landscape designation relates to the ZVIs of the scheme. 4.355 The London Plan (D620) establishes the Thames Policy Area and the Blue Ribbon network, within both of which the scheme would lie. Here, development must be attractive and appropriate, taking into account various identified factors, and the effect of development on river prospects and any locally designated views must also be addressed. The Plan also defines Green Chains, areas of linked but separate open spaces and the footpaths between them, all accessible to the public. The scheme corridor would potentially provide a Green Chain, bringing together the north and south sides of the river and connecting to other parts of the London Thames Gateway Green Grid such as the Northern Outfall Sewer Greenway (TfL/P/08/3 Figure H1A). 4.356 Local UDPs identify views which should be protected. Figure H7 of Document TfL/P/08/2 locates those within which the scheme would lie,
110
including views from the river bank in Barking & Dagenham, the Beckton Alps in Newham, and St Marys Church, Shrewsbury Park and Winns Common in Greenwich. Additionally, the Figure shows affected views along the River Thames and, importantly, one through the Royal Albert Dock to Canary Wharf. Landscape changes associated with the scheme 4.357 The main features that the scheme would introduce into the landscape are the road, earthworks, viaducts and bridge previously described. The indicative landscape master plan, shown on figures H8A, H8B and H8C of Document TfL/P/08/3, includes scheme proposals and those by others on nearby land. North of the river, the scheme would provide native grassland and some tree planting on the embankment sides and further native or amenity grassland elsewhere, with a tree screen on the northern side of the maintenance compound. Two balancing ponds would be formed. To the south of the Thames, a further balancing pond would be formed, partly beneath the viaduct bearing the road. The embankments to the south of Barnham Drive would be grassed and planted with mixed deciduous and evergreen trees with evergreen shrubs beneath, providing an effective visual screen (Document TfL/153 chapter 9). Amenity grassland would surround the Thamesmead grade-separated road junction near the southern end of the scheme. 4.358 The landscaping proposals for the scheme are consistent with those for adjacent sites, as expressed in the Royal Albert Basin Development Framework prepared by Newham (D649) and the Tripcock Point Thamesmead Development Framework by Greenwich (D657). Assessment method 4.359 The method of landscape and visual impact assessment is based upon the general approach provided by the Institute of Environmental Management and Assessment and the Landscape Institute (D531) which also follows, in principle, the guidelines laid down for landscape assessment and visual impact assessment within the DMRB (D522) and elsewhere. It comprises desk study and field survey and is described in more detail in the ES. Effects of the scheme 4.360 Twenty seven Landscape Character Areas (LCAs) have been identified in or immediately adjacent to the ZVIs. The extents of these are shown in figure H5 of Document TfL/P/08/3 and they are described in the ES (D808). Ten of these LCAs would be affected by the scheme. The effects on each have been assessed in three situations: during construction, on the date of opening the scheme and fifteen years after opening. 4.361 Progressing from north to south, the schemes effects on each of the ten LCAs would be as follows:
111
a. LCA18 A13/A406/A1020 Road Corridor: construction would have a negative effect of moderate severity. The negative effect of the completed scheme would be minor at the year of opening, improving to negligible or positive after 15 years. b. LCA9 Beckton Gateway Leisure: a minor negative effect during construction would also arise from the scheme at opening and after 15 years. c. LCA8 Beckton Meadows: construction would have a negligible effect on the landscape here, as would the completed scheme at opening and after 15 years. d. LCA6 Beckton Gateway Mixed Use Area: given the low sensitivity of this area and the low magnitude of change, the construction effect would be negligible, as would that of the scheme at opening. Planting here would mature to make the scheme have a positive effect by year 15. e. LCA5 Gallions Reach Undeveloped Land: this would be an area of extensive construction activity, close to the River Thames. The effect during construction would be negative, of major/moderate severity. The completed scheme would pass this area on a viaduct, having a major/moderate negative effect upon completion, but in the long term adjacent redevelopment integrated with the landscape master plan would be likely to lead to a positive change. f. LCA23 River Thames: given the high sensitivity of this LCA and the high magnitude of impact, the construction effect would be negative of major severity. Since the bridge would become a landmark and give spatial coherence to its wider and immediate context, its effect upon completion and thereafter would be significant and positive. g. LCA20 Broadwaters and Gallions Reach Urban Village, Thamesmead: the scheme, including the public transport loop, and the construction compound would be sited here. The effect during construction would be negative and of minor severity. Minor negative effects would remain upon completion and would continue to year 15. h. LCA21 Tripcock Park: construction would have a major/moderately severe negative effect here, as would the scheme at the year of opening. The Landscape Masterplan for Tripcock Park takes the scheme into account and, if implemented, would reduce the severity to negative moderate. Subsequently, as vegetation grows further and if the park is well maintained, the effect could be moderate and positive. i. LCA22 Thamesmead Residential Areas: construction would have a negative, moderately severe effect here. Upon completion, the schemes effect would reduce to minor negative, due to the limited intrusion and the small amount of land take from existing open space. The proposed planting would reduce this still further to minor or
112
negligible by year 15. j. LCA24 White Hart Triangle and Belmarsh Prison: construction would have a minor negative effect here. Upon completion, the schemes effect would be negligible, improving to positive by year 15. 4.362 Of these areas, only Tripcock Park would experience a lasting moderate or worse negative effect as a result of the scheme. All other effects would be less severe, or temporary. 4.363 The scheme would enhance the protected views and vistas identified in the various UDPs. It would improve public access to open space. 4.364 The effect the scheme would have on high sensitivity visual receptors has also been assessed. The principal such receptors are walkers and cyclists on certain routes, users of pleasure boats, and residents of Gallions Point, all of whom would benefit in this respect, and local residents in Thamesmead Phase 4 (yet to be built at the time of the inquiry), Blaney Crescent and Marathon Way who would be severely affected by the scheme. However, the overall visual effect of the scheme would be beneficial: some 2,257 properties would benefit from the scheme in visual terms, whereas some 757 properties would be disadvantaged. 4.365 Users of the scheme would find it visually pleasurable because the route alignments would offer variety and interest, the viaducts and the bridge would provide dramatic experiences, a diversity of interesting views would be available from the scheme and the landscape treatments proposed would be pleasing to the eye. 4.366 The introduction of the scheme into the landscape would be notable because it would become a significant landmark, enhancing the sense of place and local identity; and because it would provide major benefits for those who would have clear and regular views of the bridge and for those who would be able to obtain views from it. 4.367 Subject to the proposed planning conditions, the scheme would enhance the existing landscapes, especially the river and the riparian landscapes. It would uphold high design principles, complement the development of Green Chain corridors, and set and stimulate the adoption of high quality landscape design to the benefit of the scheme and the wider ZVIs. Regeneration implications of the scheme Current conditions in the Thames Gateway 4.368 RPG9A (D648) identifies the Thames Gateway as that area to the east of Deptford Creek and the Royal Docks, extending along the north bank of the Thames to Thurrock and along the south bank to Sheppey. The northern
113
boundary is generally the A13 road but the area extends further north along the Lea Valley to Stratford. The southern boundary in London is the A207 road and, in Kent, the A2/M2 route. Annex 4 of RPG9A provides a map. 4.369 As indicated above, this area formerly hosted heavy manufacturing and polluting industries which are now in decline. There are therefore now many vacant, unused or under used sites which provide an opportunity for growth without recourse to greenfield land. The Thames Gateway contains Londons largest supply of brownfield sites, and is a major focus for regeneration. 4.370 The TGB would connect some of the most deprived areas in London. Unemployment in April 2005 was over 12% of working-age residents in Newham and over 9% in Greenwich, whereas the figure for London as a whole was 7%. Weekly average earnings in Greenwich in 2004 were 480; in Newham, 460; in all of London, 620; and nationally, 475. Comparison of conditions in the five Boroughs nearest the site of the TGB (Barking & Dagenham, Bexley, Greenwich, Newham and Redbridge) with those in a group of five Boroughs in West London a similar distance from the centre of the City (Ealing, Hammersmith & Fulham, Hounslow, Richmond and Wandsworth) has identified the following: a. The West London Boroughs have proportionately fewer claimants of either Incapacity Benefit or Job Seekers Allowance. b. Three of the five East London Boroughs were among the 50 most deprived districts in England (based on the ODPMs Index of Multiple Deprivation (IMD) published in 2004) whereas only one of the five West London Boroughs was. c. The West London group is better provided with recreational facilities than the East London group. d. Educational and medical provision is also stronger in the West London group of Boroughs than in the Eastern group. 4.371 The IMD shows that 23 of the 24 wards in Newham and 10 of the 36 wards in Greenwich are among the most deprived 10% in England. Accessibility in the Thames Gateway 4.372 Accessibility is defined in this case as the average of the number of people and the number of jobs that could be reached within 45 minutes (the average duration of a travel to work trip in London) by road (assessed using the LTS traffic model) and by rail. The accessibility index compares the accessibility of a particular ward with the average accessibility throughout London, defined as having an accessibility index of 100 in the year 2001. The current ward figures are illustrated by Appendix E2 of TfL/P/05/3 and
114
summarised as the average Borough accessibility index. 4.373 The following table compares the average Borough accessibility indices for the East London and West London groups. All the Boroughs near the proposed TGB, other than Newham, have below-average accessibility, whereas two of the West London Boroughs are significantly above the London average. As one moves further from the centre, the accessibility index falls significantly. Average Borough Accessibility Index 2001, London = 100 East London Barking & Dagenham Bexley Greenwich Newham Redbridge Group Average 83 55 70 117 93 83 Ealing Hammersmith & Fulham Hounslow Richmond Wandsworth Group Average West London 91 129 72 65 121 96
4.374 In the Thames Gateway, the River Thames acts as a physical barrier, reducing accessibility so that South East London, in particular, does not fully benefit from developments in the east of London such as the expansion of business and financial services at Canary Wharf and the investment around the Royal Docks. The reduced accessibility limits the jobs available to residents and limits the workforce available to employers. The significance of accessibility 4.375 Research has been carried out on the relationship in London between accessibility and the densities of population and employment, measured in terms of people or jobs per unit area. The research is reported in Document D822. The research findings include the following: a. The densities of employment and population are independent of accessibility where the Access Index is less than about 71. b. For locations with Access Indices between about 71 and 152, higher employment density and population density tend to be associated with higher access indices. c. Where the Access Index is greater than 152, greater Access Indices tend to be associated with lower population density. d. Where the Access Index exceeds 152, employment density tends to be
115
strongly associated with greater values of accessibility. This observed finding is based on data from 35 wards around the City of London, but it is unlikely that the employment density there could be matched elsewhere. (The City of London itself is atypically high in this respect and is excluded from the analysis.) For prediction purposes, two alternative bases for assessment are therefore proposed: i. The Constrained approach, which assumes the accessibility: employment density relationship to be proportionately the same for locations whose Access Index exceeds 152 as it is for those whose Access Index is between 126 and 152; and ii. The Adjusted approach, midway between the Constrained approach and the much higher, observed, results from near the City. 4.376 These findings do not imply a causal relationship between accessibility and either employment density or population density. Nor has there been any use of such relationships in forecasting, because time series data are not available. But the approach can be relied upon for two reasons: first, there are sensible and plausible accounts (accepted and supported by practitioners and academic analysis) of a relationship between accessibility and people and jobs, and, secondly, that in London the difference between different levels of accessibility and employment and population is supported by the available evidence. The findings allow an assessment of the degree of accessibility necessary, among other factors, to allow particular densities of employment or population to be achieved. Government guidance 4.377 The DfTs Transport Analysis Guidance (WebTag, D524, unit 3.5.8) refers to the preparation of an economic impact report (EIR) which it considers to be an essential part of the appraisal of the wider economic impacts of a scheme designed to stimulate economic activity in a regeneration area. An EIR should provide a description of how the regeneration areas economy operates, the role which transport plays in it, why improved transport would contribute to regeneration by leading to new jobs and/or reduced unemployment, and why the risks are that the employment effects will not arise or may even turn out to be damaging. The WebTag identifies five specific entries that should be made in the AST. The WebTag guidance was published in June 2003, by which time the analytical work on the effect of the scheme was complete. The Regeneration Statement (D822) was prepared in line with the EIR guidance so far as was relevant; but it takes a wider focus than the EIR guidance does on unemployment for existing residents and differs in a number of other ways described in document TfL/263. 4.378 Unit 3.5.9 of WebTag, dealing with the treatment of costs, is addressed in the promoters evidence on traffic, tolls and so on, and in its evidence on
116
bridge engineering and cost estimates. 4.379 Unit 3.5.10 of WebTag is a worksheet framework for the EIR, and is an alternative presentation of the promoters work of that sort. 4.380 At unit 3.5.11, WebTag considers accessibility. The promoters accessibility calculations largely use the LTS model which covers all modes and provides detailed zone by zone analysis. The regeneration analysis did not use a weighted set of travel bands (although WebTag suggests that access time weighting is used) but instead took a 45 minute standard as an average travel time for work in London. The Mayors Transport Strategy, published in 2001, identifies the average travel to work time in Central London in 1999 as 56 minutes; in Inner London it was 42 minutes; and in Outer London the average was 31 minutes (Document D630, paragraphs 2.75, 2.82 and 2.86). 4.381 WebTag unit 3.5.12 deals with questionnaires for business interviews. The Regeneration Statement itself did not include a questionnaire approach. Since London First planned a survey of its own, both in the area and beyond, a further survey was not necessary. 4.382 All the available data sources listed in Unit 3.5.13 were used. 4.383 The London First survey of all its members had a 77% response rate, of which 81% said they would benefit or greatly benefit from the scheme. While this cannot be interpreted as a firm commitment, it goes beyond hypothesis. London First also conducted interviews with 14 local employers and developers. They found (1987/1/B): a. One company with 350 employees considered their ability to continue operating, especially in the light of planned expansion, depends on the scheme. Another, of similar size, has moved out. b. Two companies were unwilling to locate to the area because of poor transport. Four others, together employing 2,500 people, believe that they are restricted by their inability to access labour pools south of the river. One other finds costs increased by lack of reliable river crossings. c. Five developers were interviewed. Two considered that further phases of development (current phases of which have employment potential for 3,000) depend on the scheme. Other views were that the scheme would increase development density and speed of occupancy on sites with potential for 24,000 jobs, and that it would offer opportunities for smaller businesses to locate in the area. 4.384 Gateway to London has also presented evidence of five individual businesses views of the effect of the scheme (1752/4/A).
117
4.385 On these bases, TfL concludes that the absence of the scheme has contributed to the loss of around 800 jobs and has put 2,850 jobs at risk. The creation of 3,000 further jobs is delayed at best, and the potential for a further 24,000 is substantially weakened. The effect of the scheme on accessibility 4.386 The scheme would cause an increase in accessibility in East London. The extent and degree of that change has been assessed on the basis set out in paragraph 4.372 above, and is summarised in document TfL/265 and the following table. TfL/265 presents findings for the toll regime originally described to the inquiry, and for that now proposed. The absolute changes to accessibility indices, on a ward basis and comparing Do Minimum with the With Scheme cases in 2016, would have been as follows: Absolute Change In Accessibility Index Due To Scheme In 2016 Number Of Wards With Stated Accessibility Change
Original Toll Proposal Between 20 and 30 Between 10 and 20 Between 5 and 10 Between 1 and 5 Less than 1 3 16 30 129 604
Revised Toll Proposal 0 13 10 118 641
4.387 To the south of the river, the wards with the highest gain in accessibility would be in the Thamesmead area and the areas of progressively lower increase form bands broadly parallel with the river. The Do Minimum accessibility index in this area is generally between 30 and 70 for example, in Thamesmead and the areas to its south and east; rising in the west to between 70 and 100. The increase in accessibility as a result of the scheme would be less in individual wards on the north side of the river but the area affected would be larger. 4.388 The scheme would also change accessibility elsewhere in London. The scheme with the currently proposed tolls would cause the accessibility of one ward in Hillingdon to increase by between 1 and 5 index points, and there would be smaller increases elsewhere in that Borough and in eight others in West and South London. The factors which affect these modelled travel time differences include new road and public transport route options that the scheme would create, changes in travel times resulting from the
118
scheme (particularly, in this context, on the M25 west of London) and residual noise in the model (noise has only a small effect in the model and would not affect the conclusions for East London). Overall, the changes in accessibility forecast in West London are very small. The potential regenerative effect of the scheme 4.389 Regeneration is the provision of more and higher quality jobs and homes. The findings summarised above are used to assess the potentials for increased employment and increased population that are likely to be associated with the scheme either on its own or in conjunction with Crossrail. Because the model is unlikely to be exact, a range of results has been generated by the use of the Constrained (lower) and Adjusted (higher) scenarios as previously described. The results include the following: a. The scheme is likely to increase potential employment by between 24,800 and 41,900, of which between 18,600 and 29,100 would be in the five London Boroughs nearest the scheme as follows: Increases in potential employment caused by the scheme If Crossrail is not complete Lower scenario Barking Bexley Greenwich Newham Redbridge Five Boroughs Subtotal Thames Gateway Subtotal 3,300 0 4,400 5,300 5,600 18,600 Upper scenario 3,500 500 5,500 6,200 6,100 21,800 If Crossrail is complete Lower scenario 3,200 2,800 7,800 5,900 6,100 25,800 Upper scenario 3,500 4,100 7,900 7,100 6,500 29,100
24,800
30,700
33,500
41,900
The difference between the Five Boroughs Subtotal and the Thames Gateway Subtotal comprises the benefit which the scheme would also bring to Hackney, Havering, Lewisham, Tower Hamlets and Waltham Forest, as shown in Table 2.1 of Document TfL/P/05/4.
119
b. The scheme is likely to increase potential population by between 57,500 and 82,200, of which between 48,800 and 69,600 would be in the five London Boroughs nearest the scheme as follows: Increases in potential population caused by the scheme If Crossrail is not complete Lower scenario Barking Bexley Greenwich Newham Redbridge Five Boroughs Subtotal Thames Gateway Subtotal 10,800 0 13,100 10,000 14,900 48,800 Upper scenario 11,600 1,100 16,100 10,700 15,900 55,400 If Crossrail is complete Lower scenario 10,700 5,500 23,400 8,800 15,400 63,800 Upper scenario 11,600 8,300 23,700 9,500 16,500 69,600
57,500
66,000
74,200
82,200
The difference between the Five Boroughs Subtotal and the Thames Gateway Subtotal comprises the benefit which the scheme would also bring to Hackney, Havering, Lewisham, Tower Hamlets and Waltham Forest, as shown in Table 2.2 of Document TfL/P/05/4. 4.390 The extent to which these potentials would be realised depends on several factors, including site availability. A study published in 2002 (D826) based on research in about the year 2000 considered sites in the area whose boundaries were the A102, A2, Dartford Crossing and A13. Some 4,600ha of vacant development land on 212 sites were identified, providing capacity for over 200,000 jobs and more than 60,000 housing units. The study concluded that development in the Thames Gateway was inhibited by poor accessibility, and that the TGB would be likely to bring forward an extra 19,500 jobs and 21,800 homes in Newham, Barking & Dagenham, Havering, Bexley and Greenwich. 4.391 The potential effect of the scheme on unemployment in the five Boroughs has been assessed in a way that sets aside any developing patterns which may affect either the local or the national economy and that is based on underlying structural patterns. Allowance is made for the proportion of new jobs in the area likely to be taken up by local residents (two thirds) and the proportion of such jobs likely to be taken up by unemployed people
120
(between one third and one half). The results are as follows: Potential Effect of the TGB on Employment and Unemployment in the 5 Boroughs Base: 2001 With-TGB poorest case 67.0% 4.1% With-TGB best case 67.8% 3.3%
Employment Unemployment
66.2% 4.9%
4.392 In the above table, the poorest case combines the constrained scenario with the case in which Crossrail is not provided, and the best case combines the adjusted scenario with the case in which Crossrail is provided. 4.393 The scheme would have substantial positive effects on employment and population potential. There would also be other beneficial labour market impacts on unemployment. Health and the quality of life 4.394 An acceptable standard of accessibility is a key element in attracting the range of different types of residents and employers that contribute to a successful community. Attracting new residents also helps create employment opportunities locally and supports community facilities such as hospitals or cinemas. 4.395 Reductions in unemployment are shown by research by various authoritative parties to be likely to lead to improvements in health. Studies have found that unemployed people and their families suffer a substantially increased risk of premature death, including suicide; that the health effects of unemployment are related to psychological and financial problems; and that unemployed people are more anxious and depressed and less happy than those in work, even low-paid individuals. Unemployment can lead to poorer health through increased poverty and hardship, and through social exclusion. Complementary programmes 4.396 A number of central Government programmes designed to improve skills and access to jobs are available in Newham and Greenwich. These include: a. New Deal for Communities, available in part of Newham (Office of the Deputy Prime Minister).
121
b. Neighbourhood Renewal Fund (ODPM). c. Action Teams for Jobs and Ethnic Minority Outreach (Department for Work and Pensions). d. Employment Zones (DWP) in Newham and Step Up (DWP) in Greenwich. e. Excellence in Cities (Department for Education and Skills). f. Education Action Zones (DES) at 14 schools in Greenwich. g. The Phoenix Fund (Department of Trade and Industry) in Newham. h. Single Regeneration Budget (ODPM). i. Liveability Fund (ODPM) in Greenwich.
j. Home Zones (DfT). 4.397 The total value of these programmes cannot be reliably established, but is estimated to be more than 256.6m for the two Boroughs between 1999 and 2006. 4.398 The scale of change envisaged for the Thames Gateway area means that the projections for the area are inextricably linked to the provision of infrastructure. The nature of the opportunities available is likely to change as time passes. It is therefore necessary to provide opportunities for people to gain new and more advanced skills, and for communities to create their own range of opportunities. 4.399 The scheme would be an essential part of the group of measures that will make possible the creation of a successful community. Alternatives considered 4.400 PPG13 (Document D637) Transport Annex C states: In planning for local infrastructure, including roads, local authorities should ensure that their approach is compatible with the New Approach to Appraisal. Particular emphasis should be given to the need to explore a full range of alternative solutions to problems, including solutions other than road enhancement. The RTS sets out the regional priorities for trunk roads and local roads of regional or sub-regional significance.
122
The assessment of alternatives to which this passage refers is specific to planning for local infrastructure where local authorities are considering promoting a local road to address problems in their area. The exercise is not directed to local roads of sub-regional significance, such as the scheme, the regional priority for which has been established in the regional planning and transport strategy (RPG9A, D648), the Inter-regional Planning Statement (TfL/20), the Mayors Transport Strategy (D630) and the London Plan (D620). 4.401 The potential for regeneration with or without a new river crossing at Gallions Reach has been considered at various times since the ELRC was abandoned in 1993. These include: a. The Eastern River Crossings Assessment (1994) which considered six possible schemes for road or rail crossings. b. The Draft Thames Gateway Planning Framework, issued by the Department of the Environment in 1994. It stated that new and improved cross river links are essential to increase the potential hinterland of many of the development sites in Thames Gateway. They are also needed to remove the north/south barrier effect of the Thames: the small number of crossings east of the City of London has added substantial distance and time to what could be short road or rail journeys. New crossings will help the area function more efficiently. c. RPG9A (1995) refers to a river crossing in the Gallions Reach area and states the benefits it would bring. d. RPG3 Strategic Guidance for London Planning Authorities: Consultation Draft says that improved crossings of the Thames to the east of Tower Bridge are significant for the Governments regeneration strategy for Docklands and the Thames Gateway. e. In 1995 the Government Office for London consultation on the River Crossings to the East of Tower Bridge set out the Governments thinking on river crossings and reviewed ten options. f. A Transport Strategy for London (GoL/DfT, TfL/180) incorporated the Governments response to consultation and introduced the idea of a multi-modal package of crossings. A crossing at Gallions Reach was considered and benefits identified. The possibility of achieving regeneration and economic development without further road crossings was discussed and rejected. Public transport could not meet even a substantial proportion of travel demand in the outer parts of Greater London. Accessibility improvements may be needed to facilitate regeneration. There appears to be a prima facie case for additional cross river road capacity in East London. If additional crossing capacity
123
was not provided, there would be continued or worsening congestion at existing crossings and their approaches, which would cause adverse impacts on inward investment, local jobs and the local environment. g. In May 1996 a study by Victor Hausner Associates Socio Economic Impacts of the Thames Gateway Road/Rail Crossing concluded that a bridge at Gallions Reach would stimulate regeneration. h. RPG3 Strategic Guidance for London Planning Authorities (1996; D646) says that the Thames Gateway Planning Framework emphasises the importance of providing new and improved cross river links in east London if the area is to function more efficiently and fulfil its development potential. This was repeated in RPG3B Strategic Planning Guidance for the River Thames (1997; D650). i. The East Thames River Crossing Appraisal Framework (1998; D527) was commissioned by the Government Office for London and the DETR. It considered various road options for the scheme together with other crossing proposals. Omitting the scheme would reduce regeneration potential, whereas the improved accessibility it would bring would lead to another 3,600 jobs and some 100,000 sq m of new floor space to be developed.
j. Further references to the need for additional crossings appear in: i. ii. The East London Integrated Transport Study (1998). The East Thames River Crossings: Summary of Economic Regeneration Impact (1999; D807) which suggested a net gain of 25,000 jobs from the package of crossings. The Thames Gateway River Crossings: Final Report of 2000, which considered that regeneration to the east of Gallions Reach would slow down in the absence of the river crossings, of which the Scheme would have the largest regenerative effect. The Thames Gateway Review (2001, D653) referred to the continuing importance of the proposals and the regeneration benefits that transport investment had brought at Ebbsfleet, along the A13 inside the M25, and at the Medway river crossings. Relationship between Transport and Development in the Thames Gateway (2003, 1991/1/110) Transport and development in the Thames Gateway (2003, Appendix 18 to 1752/1/B).
124
iii.
iv.
v.
vi.
k. The 2002 report Thames Crossings The Regeneration Case, Social and Economic Impacts, Final Report (D826) focuses on the role of transport infrastructure in supporting regeneration in the Thames Gateway area, with particular reference to the scheme and the Silvertown crossing. If the scheme did not proceed then the regeneration policies in the draft London Plan would be undermined. l. The Panel Report (D613) that followed the examination in public of the draft London Plan refers to general agreement that the provision of adequate transport accessibility is key to regeneration in the area. There is general acceptance that development in East London has been constrained, in part, by its poor connections across the Thames.
4.402 There has been no specific study that has considered how East London might be regenerated without a river crossing. Possible planning conditions 4.403 Three inquiry sessions were devoted to an informal and without prejudice discussion on conditions, in which all parties to the inquiry were invited to participate. Following those sessions, it can be stated that complete agreement has been reached with the three local planning authorities directly concerned in this matter (Newham, Greenwich and the Development Corporation) in relation to the conditions proposed by TfL. There is also agreement on those conditions from the EA, the PLA and LCY. 4.404 If the Secretary of State is minded to grant planning permission, she is invited to impose the conditions set out in Document TfL/24S in relation to the temporary construction worksite; the conditions set out in Document TfL/24T in relation to the main bridge application to the north of the river; and the conditions set out in Document TfL/24U in relation to the main bridge application to the south of the river. A full size set of the plans referred to in the proposed conditions is contained in Document TfL/24X. Where those plans represent revisions to the plans originally submitted, the reasons for those revisions are tracked and explained in Document TfL/24Z/1. 4.405 In relation to the proposed conditions regarding the main bridge applications, (Documents TfL/24U and TfL/24T), condition 1 defines the relevant local planning authority and condition 2 would set out a schedule of approved plans, given that there has been a number of amendments to the plans originally submitted. 4.406 Notwithstanding the normal duration of planning permissions of three years in accordance with Section 51 of the PCPA 2004, the promoters seek a condition prescribing a life of seven years for any planning permission granted in this case. This is requested to reflect the complexity of the development proposed and the time which would be required to follow the planned procurement arrangements and the outstanding design issues they
125
would involve. 4.407 Conditions 4 and 5 deal with the process for securing approval from the local planning authorities, and conditions 6 and 7 deal with definitions. Condition 8 would require the design of the works to be in accordance with the provisions of the Design Statement (Document D855). 4.408 Conditions 9 to 16 would provide for the submission and consideration by the relevant local planning authority of detailed drawings showing plans, sections and elevations of the features not provided for in detail in the plans submitted with the main bridge applications. They include the proposed lifts for pedestrians and cyclists to either side of the TGB. 4.409 Condition 17 would ensure that the bridge and its associated street furniture did not impinge on the obstacle limitation surfaces of the LCY, and conditions 18 to 23 would be included to allow prior consideration by LCY and the CAA of the potential impact of lighting, landscaping and public art proposals in relation to the TGB on safety at LCY. Similar prior consideration of lighting would be secured for the PLA to ensure safety of navigation on the River Thames. LCY and the CAA would also be involved in prior consideration of the location and height of cranes and other plant and equipment used during construction. Information from these consultations would be provided to the relevant local planning authorities before they determined the requests for approval. 4.410 Condition 24 would provide for the approval by the relevant local planning authority of arrangements to optimise the delivery of construction materials and the removal of construction waste by river. Prior consultation with the PLA and the EA would be required. Before development commenced, approval would also be necessary under conditions 25 to 30 to the details of local hydraulic impacts, modifications to flood defences, works in or beside watercourses, the disposal and attenuation of surface water run off from the site, the effects of drainage discharges into the River Thames, and disposal of contaminated surface or ground water. In each case, prior consultation with the PLA, the EA and (in relation to flood defences) appropriate riparian owners would be required. 4.411 Condition 31 would require approval by the relevant local planning authority of the arrangements for piling, with prior consultation with the EA and, in relation to piling in the River Thames, with the PLA. 4.412 Conditions 32 to 34 would deal with approval by the local planning authorities of temporary worksites, temporary housing for construction workers, and the details of any visual or noise screening. 4.413 Condition 35 would require the completion of a contaminated land assessment for consideration by the local planning authorities before any works commenced, with the inclusion of a remediation plan to deal with any contaminants discovered. Condition 36 would require the submission of a
126
validation report on completion of any necessary remediation works. 4.414 Condition 37 would set normal working hours for construction activities, with a process for approving work outside those hours when circumstances made it necessary, and an arrangement for dealing with emergency situations. 4.415 Condition 38 would require prior approval by the local planning authorities in consultation with the EA of the method, frequency and location of vibration, noise and dust monitoring during the construction period. Monitoring would be required by condition 39, together with the use of best practicable means to ensure that agreed levels are not exceeded. 4.416 Condition 40 would require soils or filling materials imported to the site to be shown to be safe. 4.417 Condition 41 would require wheel cleaning equipment to be used to prevent earth or mud being deposited on highways outside the site. 4.418 Condition 42 would require prior approval by the local planning authorities of an EMP to deliver the mitigation measure outlined in the ES. The local planning authorities would also need to have approved the CEMM (condition 43) and a detailed code of construction practice (condition 44) in advance of the commencement of construction. There would also need to be prior approval by the local planning authorities to a programme of archaeological work (condition 45), details of ecological enhancement measures and protection of wildlife habitats (condition 46), and methods of reducing the impacts of construction on fish, teal and other waterfowl (condition 47). All of these provisions would be dealt with by the local planning authorities in consultation with the appropriate specialist advisory bodies. Monitoring programmes to assess the impacts of these measures would be required by conditions 48 and 49. 4.419 Condition 50 would require details of ecological and engineering mitigation works to be agreed with the local planning authorities in consultation with the EA before any work was carried out within 5m of non main watercourses. 4.420 Conditions 51 to 53 would control tree planting, the protection of existing trees, and the replacement of any unsuccessful planting for a period of five years. 4.421 During the course of the inquiry, the Inspectors invited TfL and the other parties to the inquiry to consider the possible imposition of a planning condition aimed at regulating traffic on the TGB to a level of 4,525 vehicles per hour. This was understood to be the level which TfL considered, on the basis of their revised traffic evidence and their revised proposal for the toll discount area, would be likely to be produced. The Inspectors therefore asked the parties to consider the imposition of a planning condition to the
127
effect that The amount of motor traffic using the bridge other than on the bus lanes shall be such that the number of vehicles passing along the bridge from the northern bank plus the number of vehicles passing along it from the southern bank shall together not exceed 4,525 vehicles in any hour. 4.422 This would be enforced by peak period traffic signals at junctions already proposed on each approach to the bridge, which would allow the volume of traffic to be regulated on a rolling hourly basis. The proposal is set out in full in Document INQ/23. 4.423 The promoters recognise that the traffic effects which would arise from the TGB would need to be managed, but they do not consider that the appropriate means of managing this is by the imposition of a planning condition. TfL have a duty to manage the road network for which they are responsible under Section 16 of the Traffic Management Act 2004, and that duty is enforceable by the Secretary of State. Traffic over the bridge and in the feeder roads forming part of the local network could be managed by setting, and subsequently fine tuning, the tolling regime applicable to the bridge and by appropriate changes to junctions. Under the Boroughs Agreement and the Unilateral Undertaking, TfL are committed to ongoing monitoring of traffic conditions, and to settling the tolling regime in consultation with the Boroughs, who are the other traffic authorities concerned. 4.424 The traffic forecasts before the inquiry have been produced by TfL using the best practicable means available. As is the case with all traffic forecasts, however, they cannot be absolutely accurate. Changes will inevitably occur in the period up to 2016 which cannot now be predicted. TfL should retain the ability (in consultation with the Boroughs) to have regard to the actual traffic flows prevailing at the time, both on and off the bridge, to monitor traffic flows after the bridge opens, and to fine tune the tolling regime and other mitigation measures to take account of any change. The level of uncertainty in this case is no different from that which applies in any other major scheme. 4.425 If the proposed bridge opened in 2013, it would at that time carry fewer vehicles than the number predicted for 2016. The condition would therefore be superfluous for a period after the opening of the bridge. Congestion on the bridge is, in any event, not itself an issue. Imposing a fixed traffic limit on the bridge would not be an effective way of ensuring that local roads would be free of congestion. Mitigation should primarily be directed at managing traffic at the parts of the road network at which the congestion occurs. The suggested condition would be more restrictive than necessary to protect the local environment. The result might well be that there would be spare capacity on local roads, in which case the condition would have been unnecessary.
128
4.426 Restricting entry to the bridge in the manner proposed would also have serious traffic effects. When the bridge was restricted to traffic, vehicles would build up waiting for the bridge to reopen, and might attempt to retrace their route, adding to congestion. The Woolwich Ferry blocking back into Woolwich provides a very local example of the potential for waiting traffic to cause traffic standstill. 4.427 Problems at Blackwall or Dartford, with a possible significant diversion of traffic, could cause demand to exceed 4,525 in an hour. Compliance with the condition could require total closure of the TGB to avert traffic chaos as traffic waited for its slot within each rolling hour. 4.428 The modelled figure of 4,525 represents, in any event, an average, not the upper band of the daily variations. Given the risk of regular restrictions with the figure set at 4,525, it would be likely that TfL would need to set tolls to achieve typical levels of use well below that limit in order to ensure that restriction was a rare event. This would clearly undermine the contribution of the TGB to regeneration. The restriction proposed would deter prospective bidders for the concession to construct and operate the bridge. 4.429 It is unnecessary to impose such a condition, because TfL must carry out their statutory functions under the Traffic Management Act in a reasonable way. Paragraph 22 of Circular 11/95 (Document INQ/12), dealing with planning conditions, provides that conditions should not duplicate controls available under other legislation. The proposed condition is also unreasonable, because it would be unduly restrictive in that it would lack flexibility and be capable of causing the harm identified in paragraphs 4.425 to 4.428 above. Such a condition would therefore not comply with the guidance contained in Circular 11/95. 4.430 The full response of TfL to the planning condition suggested by the Inspectors is contained in Document TfL/279. 4.431 Turning to the conditions proposed for the construction site application (set out in Document TfL/24S), these reflect the fact that the only local planning authority involved would be the Development Corporation (condition 1) and that any planning permission would relate to the drawing appropriate to this application (condition 2). Apart from that, Document TfL/24S simply includes those of the conditions relating to the main bridge applications which are relevant to the construction site application, namely conditions 4 to 8, 19, 23, 28, 30 to 3, 35 to 45 and 48. Other relevant material planning considerations The Boroughs Agreement and the Unilateral Undertaking 4.432 The Boroughs Agreement and the Unilateral Undertaking are briefly described at paragraphs 1.64 to 1.66 above. The Boroughs Agreement is
129
made under Section 111 of the Local Government Act 1972 and Section 2 of the Local Government Act 2000. As regards Newham, it is made also under the provisions of Section 106 TCPA 1990, because TfL own land in Newham required for the scheme. By clause 3 of the Agreement, as soon as TfL own land required for the scheme in Greenwich, they will enter into a Section 106 Agreement with Greenwich, repeating the terms of the Boroughs Agreement. If the scheme is approved, TfL have committed themselves not to commence construction of the scheme in Greenwich until the Section 106 Agreement with Greenwich is concluded. 4.433 Subject to approval for and a decision to commence construction of the TGB, under the Boroughs Agreement TfL would a. Set up the BCG as a forum to discuss the tolling regime, related public transport provision, traffic and environmental impacts of the TGB, and monitoring and mitigation measures to manage those impacts. b. Provide for the monitoring of use of the bridge so that information on volumes and patterns of traffic could be provided to the BCG. c. Provide for the maintenance of two air quality monitoring stations, one to the north and one to the south of the TGB to make information available to the BCG. d. For ten years after the opening of the bridge, monitor the impact of traffic on the highway network, and report on it to the BCG. The BCG may propose mitigation measures where material traffic, safety or environmental effects have been caused by or are predicted to arise from changes in traffic patterns as a result of the opening of the TGB. Lists of measures which it is agreed would be necessary and of further potential measures are set out in schedule 3 to the Agreement. e. Provide a sum of 14.5m (uprated by a formula to cover inflation) to meet the costs of surveys, monitoring and highway and traffic mitigation measures agreed to be necessary. This sum includes adequate funding for the committed mitigation measures, for undertaking future surveys and mitigation measures agreed to be necessary, and a significant contingency sum to provide for measures not yet identified. Additional detail is provided at paragraphs 4.155 to 4.159 above. f. Provide dedicated public transport lanes over the proposed bridge. g. Provide Public Transport Service Development Statements for discussion with the relevant Boroughs to increase patronage of public transport.
130
h. Prepare an Education Plan, to allow local schools and colleges to learn from the construction of the TGB. i. Give consideration to sustainability measures in letting any contract for the construction and operation of the bridge.
j. Develop a low emissions strategy for vehicles using the TGB. k. Construct a Riverside Walk and Cycle Track in Greenwich. l. Fund a bursary scheme for residents of Newham to attend courses in civil or structural engineering.
m. Provide up to 200,000 to promote employment and training of local people and businesses in Newham. n. Require the concessionaire to prepare an employment strategy which is designed to promote the employment of local people and to operate a training scheme for new employees. o. Require the concessionaire to operate a procurement strategy to encourage local businesses to bid for contracts to supply goods or services. p. Create a public open space in Greenwich. q. Fund off site mitigation measures in Newham at a cost of up to 500,000 (uprated by a formula to cover inflation). r. Fund noise mitigation measures at Gallions Primary School. 4.434 The Unilateral Undertaking commits TfL to provide those benefits of the Boroughs Agreement appropriate to LB Bexley to Bexley, despite the fact that Bexley have decided not to be a party to the Boroughs Agreement. Essentially, this is all the provisions except for those particular to Newham and/or to Greenwich, such as the Riverside Walk in Greenwich and the funding of off site mitigation in Newham. There is provision for Bexley to join the Boroughs Agreement in the future, should the Council decide to do so. 4.435 TfL consider that all the provisions of the Boroughs Agreement are material considerations which the Secretaries of State can properly take into account in deciding the planning applications and determining the Orders (Document TfL/334 paragraph 6(h)(3) at page 225). It is accepted, however, that only some of the provisions can strictly be regarded as essential for the grant of the planning permissions. Document TfL/323, which is a response to Document INQ/14, provides an analysis of each of
131
the commitments contained in the Boroughs Agreement. It indicates the way in which each of them has been included in the overall scheme assessments, and of the way in which each of them is consistent with the requirements of the Development Plan and relevant planning policy. 4.436 Those commitments regarded by TfL as essential to the grant of planning permission are the provisions concerning air quality monitoring during construction, traffic monitoring, mitigation measures arising from changes in traffic patterns, the provision of dedicated public transport lanes, the commitment to providing replacement open space, and the funding of off site mitigation measures in Newham. 4.437 Some of the Boroughs who are party to the Boroughs Agreement regard a wider range of issues dealt with in the Agreement as essential to the grant of planning permission. This will be referred to in the reporting of their submissions to the inquiry. 4.438 LB Bexley contend that TfL should provide an unlimited fund to deal with unspecified additional mitigation measures beyond those provided for in the Boroughs Agreement. TfL consider that this would be a novel and wholly unjustified provision to make, and request the Secretary of State so to find. Other material considerations 4.439 Amongst other material considerations are the mitigation measures offered by TfL outside the Boroughs Agreement. There is mitigation which forms part of the overall approach to the scheme, such as the proposed tolling mechanism, which is designed to act as a control on the level and therefore the impact of traffic on the proposed bridge. Secondly, there are those items of the development for which planning permission is sought which are provided purely to mitigate the effects of the proposal. This mitigation by design is demonstrated in various aspects of the proposal, such as the noise barriers north and south of the bridge and the landscaping planned as part of the scheme. Many of these proposals will only be finalised in liaison with other bodies, such as EN and the EA, at the time of approval of details, but they will be managed through the EMP, for which a proposed condition provides. Project strategy and programme Context of the scheme 4.440 As indicated above, the potential for regeneration of the Thames Gateway is recognised in national, regional and local planning policy documents. On 19 November 2002, the Board of TfL approved the development of the project, and, on 24 March 2004, the Board of TfL, having been informed that the scheme would meet the criteria listed in Policy 4G.8 of the Mayors Transport Strategy (D630, D825), agreed that powers to implement the scheme should be sought. The London Plan (including Policy 3C.15) was
132
published only on 12 February 2004. Policy 3C.15 was not referred to in the report to the Board of TfL for the meeting on 24 March 2004, but the wording of Policy 4G.8 of the Mayors Transport Strategy raises the same issues as those identified in Policy 3C.15. Design options 4.441 Prior to the selection of the preferred option solution, a comprehensive series of design option reviews and risk evaluation took place. Environmental specialists were closely involved in this work, which developed acceptable and workable solutions. Sustainability 4.442 TfL agreed sustainable development to be that which meets the needs of the present without compromising the ability of future generations to meet their own needs. The scheme would be sustainable development. By providing a linkage across the river it would provide the opportunity to enhance regeneration, particularly of derelict and unused areas; it would provide an opportunity for job creation and landscape improvements, and for car use one of a mixture of transport modes that the public will want to use (D74 P125 and 126). External consultations 4.443 During the development of the scheme various stakeholders were consulted regularly by TfL. These included the London Boroughs of Greenwich, Bexley, Newham, Barking & Dagenham and Redbridge, the EA, EN, English Heritage (EH), the Thames Gateway London Partnership (TGLP), the PLA, LCY, Government departments and business groups. Some 80 meetings took place with local authorities over the two year period when the project was being developed, and the scheme was modified in various ways as a result of these (TfL/P/09/3, Appendix I/3). A full list of consulted stakeholders, of which there were more than 200, appears on pages 84 to 99 of Document D827. This allowed specialist and local representative input to the development of the scheme. 4.444 Prior to the inquiry, the general public was also consulted directly at a number of stages in the development of the scheme: a. The Mayors Transport Strategy (D630) was the subject of public consultation in January 2001, reported in July 2001 (D751). The Strategy includes the potential for a new river crossing at the site of the scheme. This consultation resulted in over 100,000 responses (written responses, telephone enquiries and web site hits), of which half a dozen responses by organisations expressed concerns about traffic generation associated with the scheme whilst others expressed strong support.
133
b. The Draft London Plan (D610) was the subject of public consultation from June to September in 2002. Reference is included to the Mayors support in principle for the scheme in Policy 3C.12, page 189. c. On 13 May 2003, TfL started public consultation on the scheme. The work was coordinated by the TfL Consultation Unit. No pilot survey to check the usefulness of the questionnaire was considered necessary. Consultation continued until 12 August 2003. Key stakeholders were encouraged to respond; local minority ethnic, voluntary and community organisations were contacted in the most effective way; and a series of exhibitions and roadshows was held. Some 460,000 flyers were distributed to properties across an area covering ten different local authorities. Around 40,000 consultation brochures, including copies of the questionnaire, were printed for distribution to homes in the area immediately surrounding the proposed site; the exact number delivered is not known. Over 36,000 consultation brochures were issued at roadshows, static display exhibitions or via the call centre. More than 17,000 people visited the TGB website and 1,828 completed online questionnaires. During 28 days of exhibitions at 11 different locations, more than 9,600 people visited the roadshow - an average of over 340 visitors per day. In total, 5,290 people completed questionnaires. This is a satisfactory response rate, and gives rise to no need for analysis of the non-responses. The consultation achieved wide awareness and high visibility. A report of the consultation was presented to the inquiry (D827). Key findings include: i. 85% of people supported building a bridge at the proposed location. 74% of respondents said they expect to drive across the bridge by car if it were built. 76% of respondents wanted the Woolwich Ferry kept open. When asked what kind of public transport they would like to see on the bridge, 51% expressed a preference for buses.
ii.
iii. iv.
d. In April 2004, an interim version of the Environmental Impact Assessment was issued to stakeholders for comment and published on the project website; an additional provision of early information. e. In August 2004, a 10-week extended consultation period started, following submission of the planning application for the scheme to the local planning authorities. Consultation took place through the public deposit of the planning application at the offices of the local planning authorities and at public libraries near the site of the scheme, site notices, notices in local newspapers, the distribution of 75,000 neighbour notices within about 3km of the scheme centreline and a further 3,000 in the area around Brampton Road, Bexley, and staffed public exhibitions at Woolwich, Thamesmead, Bexleyheath and two at
134
Beckton. f. Further consultation took place in Thamesmead during November 2004 as a result of proposed amendments to the transit route near Barnham Drive. No objection resulted from this. g. The London Borough of Newham undertook further public consultation during April 2005 in respect of planning application reference P/05/0428 for the construction work site. The statutory requirements for consultation were met and, in addition, all those who had responded to Newham regarding the scheme were again consulted about the work site proposal. Future programme 4.445 Subject to the confirmation of Orders and the grant of planning permission, the land acquisition and CPO process would be completed by 2009; the concession contract would be awarded in Spring 2009; and the scheme would be completed and first open during the spring of 2013. These dates are derived form the latest version of the forward programme contained in Document TfL/310. Cost estimates 4.446 The cost of the construction contract for the scheme has been estimated assuming that construction would be procured by the concessionaire as a design and build contract. The construction cost estimate is 378,000,000 at quarter 3 of 2003 prices, and includes an allowance of 44% for risk and contingency in accordance with the Treasury Green Book (Document D577). 4.447 The estimated yearly operational cost of the scheme is 4,379,000 or, assuming a 20% optimism bias, 5,250,000. These figures include, among other things, toll operating costs. Funding and procurement Funding requirement 4.448 The funding requirement for the project between April 2005 and the end of construction is estimated, on a 2012 cost base, to be as follows: Funding requirement, April 2005 to end of construction (2013) Item Amount ( million) Totals ( million)
135
Project development and land acquisition Inflation Subtotal Construction cost Concessionaire development costs Inflation Financing costs Subtotal Grand total Sources of funding
79.9
12.9 92.8 377.5 5.0 96.2 69.2 547.9 640.7
4.449 Funding for project development and land acquisition will be met from TfLs own resources and provision is identified in TfLs business plan for the period 2005 to 2010. 4.450 Funding for the construction of the scheme would be met through private sector debt and equity. Following an appropriate tender process, a private sector concessionaire would be appointed to finance, design and build the scheme, to manage, operate and maintain the bridge during the concession period (expected to be between 25 and 35 years) and to manage operate and maintain the tolling system. 4.451 The concession agreement would allow for the toll revenue from the bridge to be paid to the concessionaire. Tolls would be set by TfL. According to the traffic model, the toll revenue would not be enough to fund the project, and TfL would therefore make performance based payments to the concessionaire, funded by PFI credits. The change in the proposed toll regime announced during the inquiry (TfL/202) would reduce total toll revenue, over 30 years, by about 23 million below that previously expected equivalent to 11 million in present value terms or about 1.8% less revenue during the operation phase of the project. It therefore remains the case that a combination of toll revenues and PFI credits would be enough to fund the scheme. 4.452 The DfT confirmed on 18 December 2003 (TfL/P/06/3, Appendix F5) that, in principle, it was prepared to make available up to 200m of PFI credits to help with funding for the scheme subject to the following:
136
a. The presence of satisfactory business and environmental cases and a financial structure that meets the criteria for PFI credits, offers better value for money than the conventionally procured alternative, and limits the financial exposure of central Government; and b. The grant of any necessary authorisation, the successful completion of all statutory procedures and final approval by Ministers. 4.453 The PFI credits would provide funding in addition to the grants received by TfL from the DfT and would be specific to the scheme. No resources would need to be diverted from other TfL projects other than the 80 million project development and land costs, and probably any costs incurred by TfL in underwriting a revenue shortfall to the concessionaire arising, for example, from traffic flows on the bridge being less than forecast by the traffic model. Bidders for the project would prepare their own analysis of the traffic assumptions and reliability of the traffic model during the 19month period planned to be allowed for procurement negotiations. 4.454 TfLs project team and advisers are experienced in PFI projects. They are confident that a combination of toll revenues and 200m of PFI credits would be sufficient to fund the scheme and that funding would be achieved at the appropriate time. Procurement 4.455 Potential concessionaires would be invited to express their interest in the project by an advertisement in the Official Journal of the European Union. Interested parties would complete a pre-qualification questionnaire, on the basis of which a small number of pre-qualified bidders would be identified. Those would be invited to submit bids. 4.456 The competition would be based on a number of factors, among which would be the level of the performance based (that is, based on the availability of the bridge for traffic and perhaps other matters yet to be determined) payment stream the concessionaire would require from TfL in return for building and operating the bridge for the concession period. The contract would set out a mechanism for compensating the concessionaire if he suffered as a result of tolls set by TfL, but TfL would make no undertaking to the concessionaire as to the way in which it would determine tolls. There might be provision for TfL to claw back any excess returns that would otherwise be made by the concessionaire. The risk allocation for the scheme is expected to be based, in large part, on the standard risk allocation for PFI projects as approved by the Treasury. 4.457 The concessionaire would be appointed to design, build, finance and operate the scheme for a concession period as indicated above within the maximum concession period of 40 years. Bidders would be provided with, among other things, a brief for the scheme design. This would allow some flexibility in design, which is why the current planning applications are
137
hybrid in nature. Bidders would be encouraged to submit their own detailed design proposals for options within the brief. Design quality aspects of bids from potential concessionaires would be assessed by the Design Panel. The successful bidder would be appointed by TfL. Overall 4.458 The planning applications are in accordance with the Development Plan. National planning policy, a material consideration in relation to the applications, also offers support for the scheme. The proposals offer benefits for the local area which substantially outweigh any disadvantages arising from the scheme. Such disadvantages are, in any event, substantially mitigated by actions proposed by the promoters. Subject to the agreed conditions, and having regard to the commitments undertaken by the promoters in the Boroughs Agreement and the Unilateral Undertaking, the promoters ask that the three planning permissions applied for should be granted. THE SPECIAL ROADS SCHEME 4.459 The purposes for which the Special Roads Scheme is promoted are outlined in paragraph 1.27 above. Sections 16, 17 and 106 of the HA 1980 do not provide criteria for confirmation. The test is therefore whether confirmation would be appropriate (that is, justified on its merits), balancing any public or private disadvantages against any public benefits. 4.460 The Special Roads Scheme would provide the authority to build a bridge over the navigable waters of the river. Its confirmation is also essential if tolls are to be charged under the Toll Order for crossing the proposed bridge. The ability to charge a toll is essential to the system for controlling the extent of the use of the bridge and the impact of traffic on the surrounding area. 4.461 Without the bridge, the benefits sought for the area in terms of improved accessibility and regeneration could not be achieved. 4.462 No ground of objection specifically relating to the Special Roads Scheme remains outstanding. The many general objections to the overall TGB proposal which include an objection to the Special Roads Scheme do not identify any particular ground of objection to that Scheme. 4.463 The promoters request the confirmation of the Special Roads Scheme with the incorporation of the amendments they put forward on 26 April 2005, before the opening of the inquiry, which are set out in Document D859. THE SIDE ROADS ORDER 4.464 The Side Roads Order is promoted to improve certain lengths of highway;
138
to stop up certain lengths of highway; to construct new highways along certain routes; and to provide new private means of access at certain locations. The highways concerned include footways and cycleways. The details of the highways which would be improved, stopped up or created, together with the details of the new private means of access which would be created, are set out in the schedules to the Side Roads Order, as amended by Document D859 and by Document TfL/159. 4.465 The promoters ask for the Side Roads Order to be confirmed, incorporating the amendments contained in both those documents. 4.466 Again, the HA 1980 does not provide criteria for confirmation of a Side Roads Order. The relevant test is therefore whether it is appropriate to confirm, balancing any public or private disadvantages against any public benefits. 4.467 Reasonably convenient replacement sections of highway would be provided under the Order for all highways which would be stopped up, as required by Section 14(6) of the HA 1980. This has not been challenged by any objector. The new and improved highways proposed are necessary to deliver the benefits which the construction of the bridge would provide. 4.468 No existing private means of access to any premises would be affected by the Order. 4.469 The promoters request the confirmation of the Side Roads Order, amended as indicated above, to allow the public benefits which would flow from the construction of the TGB to be realised. THE COMPULSORY PURCHASE ORDER 4.470 The legal tests against which the Compulsory Purchase Order falls to be considered are, first, whether all the land is required for the proposed construction or operation of the TGB; and, secondly, whether the acquisition falls within the statutory powers under which TfL seek to acquire the land. These are Sections 239, 240, 245, 246, 249, 250 and 260 of HA 1980. They cover the acquisition of land and rights over land for the construction or improvement of a highway, land to provide buildings or facilities in connection with a highway, mitigation land, and land to be provided in exchange for open space land acquired. 4.471 ODPM Circular 06/04, the current Government guidance on compulsory purchase, does not apply to this scheme, because of the transitional provisions contained in paragraph 4 of that Circular and paragraph 9 of Part 1 of the Memorandum to the Circular. TfL would, however, accept the recommendation contained in paragraph 4 of Part 2 of the Memorandum to Circular 06/04, in that TfL would offer back to any dispossessed freeholder or long leaseholder under the revised Crichel Down Rules land acquired compulsorily if, in the longer term, continuing ownership of the land was
139
not necessary for the scheme. 4.472 The guidance which does apply to this scheme is contained in ODPM Circular 02/03. Paragraph 14 of that Circular requires the promoting authority to show that there is a compelling case for compulsory acquisition of the land covered by the Order in the public interest. Since the coming into force of the Human Rights Act 1998, the acquiring authority must also be sure that the purposes for which the Compulsory Purchase Order is made justify interfering with the human rights of those with an interest in the land affected. 4.473 Under Article 1 of the First Protocol of the European Convention on Human Rights, acquisition is only justified if a. there is a legitimate aim for the acquisition b. the conditions provided by law are met c. the expropriation is in the public interest d. the expropriation is proportionate in the sense of being no more than necessary to achieve the required purpose, taking into account alternatives and the impact on the person being dispossessed.
4.474 The promoters already own a substantial amount of land required for the TGB scheme, and, while the inquiry was running, further land was acquired by agreement. The position as at 23 June 2005 was shown on Document TfL/P/14/4. 4.475 Under the Compulsory Purchase Order, the promoters seek to acquire the balance of the land, interests in and rights over land necessary to enable the safe and efficient construction, operation and maintenance of the highways proposed in the Special Roads Scheme and the Side Roads Order. 4.476 The promoters seek to acquire the freehold interest and all subsidiary interests in the land required for the footprint of the road infrastructure. In addition, the Order covers a 5m strip of land adjacent to the bridge in order to provide access for its future maintenance and repair. The extent of the land covered by the Compulsory Purchase Order is therefore determined primarily by the design of the road. 4.477 In addition, however, a. sufficient land has been included in the Order to permit some design flexibility in the position of the bridge piers for the main bridge over the River Thames.
140
b. land has been included to provide exchange open space land to replace public open space on the south eastern bank of the river in Greenwich required for the scheme. c. land has been included to provide reasonable temporary work sites for the contractor. These are necessary to avoid foreseeable delay to the construction programme which might arise if a landowner found it possible to seek ransom payments from a contractor for working space. d. land necessary to provide mitigation of the impact of the scheme, for example by landscaping. 4.478 All the land covered by the Compulsory Purchase Order as now put forward for confirmation is required for the proposed construction or operation of the TGB including the purposes listed above, and all of it is within the statutory powers upon which the promoters rely. 4.479 During the course of the inquiry, the promoters have continued to negotiate with owners of land within the Compulsory Purchase Order, and, as a result, some amendments to the Order are sought which reduce the total land covered by the Order as indicated at paragraph 1.29 above. Document TfL/313C/1 shows the Order in the form in which TfL now ask for it to be confirmed. This includes some small parcels of land which were not covered by the Order as originally drafted. In each case, the consent of the owner of the land to its inclusion in the Order has been obtained. The detailed reason for each variation from the original Order is set out in Document TfL/313B. That Document also includes the agreement of the owners of additional parcels of land to their inclusion in the Order. 4.480 The benefits in terms of accessibility and regeneration which TfL seek to provide for the area cannot be achieved without the construction of the TGB. The bridge could not be built without the compulsory purchase of the necessary land. 4.481 The Order will necessitate the acquisition of some private interests in land, but, by negotiation, its impact on individuals has been minimised. All statutory objections to the Order have been withdrawn. 4.482 There would be no acquisition of residential property under the Order, nor would any commercial building be acquired. Only one small building would be demolished, a derelict World War II pill box. 4.483 The scheme could be resourced and completed within a reasonable time. Related Orders and Consents required 4.484 In addition to the matters that were the subject of the inquiry, the following consents have been given or would be needed if the scheme were to
141
proceed: a. The Exchange Land Certificate to confirm that the Secretary of State is satisfied that there will be given in exchange for the public open space included in the Compulsory Purchase Order (Plots 510 and 514) exchange land which is not less in area and is equally advantageous to those with rights or benefits over the land to be taken. As indicated at paragraph 1.29 above, paragraph 13.36 of TfLs statement of case indicates that the necessary Certificate would be issued by the Secretary of State, subject to confirmation of the Compulsory Purchase Order. Counsel for TfL indicated at the inquiry that an amendment to paragraph 4 of the Exchange Land Certificate would be required to reflect the fact that, by agreement, TfL were asking that one of the replacement land plots (Plot 511) should be deleted from the Compulsory Purchase Order. b. The Highway (Designation of GLA Roads) (Thames Gateway Bridge) Order. This Order would provide for the new roads constituting the TGB scheme, as well as some short lengths of existing Borough roads, to become GLA roads. TfL would therefore have responsibility for them as highway authority. The consent of both Greenwich and Newham has been given to the Order, and the Mayor of London approved it on 19 April 2006 (Document TfL/308). c. The A2012 GLA Road (London Boroughs of Greenwich and Newham) (Public Transport Bridge) Order 2006. This is the Traffic Regulation Order mentioned at paragraph 4.43 above, made to ensure the provision of dedicated public transport lanes and the exclusive use of parts of the proposed TGB for cyclists and pedestrians. It was made on 20 April 2006 (Document TfL/315), and would operate immediately if the bridge were built. d. Planning permission for replacement Vessel Traffic Service radar antennae, upstream and downstream of the proposed bridge to provide continued safe navigation for vessels on the River Thames. Permission for these replacement antennae was given by Newham on 10 March 2005 (Document D860) and by Greenwich on 27 October 2005 (Document TfL/198). e. The approval of the Secretary of State under Section 76 of the Port of London Act 1968 (D212) would be required for construction works on the tidal river bed. Applications for such approvals are administered by the Marine Consents and Environment Unit of the Department for Environment, Food and Rural Affairs (DEFRA) and the DfT. The MCEU routinely consults the PLA and EA in such matters and both seek assurance that the proposed works would cause no obstacle to the maintenance of an acceptable river regime which would be so in the case of the scheme. It is therefore unlikely that the need for a Section 76 consent would prevent or frustrate the implementation of the scheme (TfL/310, 5.5 and Appendix 3 to that Document).
142
f. The approval of the EA is required by the Section 109 of the Water Resources Act 1991 (D218) and the Thames Regions Land Drainage Byelaws 1981 in respect of any works affecting or within 16m of any tidal flood defence structure and for construction works in, over, under or within 8m of a Main River. The Water Resources Act 1991 and the Land Drainage Byelaws also require the consent of the EA for the discharge of surface water into controlled waters. Details of the reuse and disposal of treated soil in connection with the scheme would be submitted to the EA so that a Pollution Prevention and Control permit may be issued in accordance with the Pollution Prevention and Control Regulations 2000. The EA has been consulted and, subject to the relevant proposed planning conditions (which would form the framework for these consents as appropriate), expects the approvals would be a matter of routine. g. A Sea Disposal Licence, authorising the concessionaire to deposit articles in UK territorial waters or to dispose of material at sea, would be sought from DEFRA in accordance with the Food and Environment Protection Act 1985. In view of the general satisfaction expressed by the PLA and the EA, there is no apparent obstacle to such a licence being granted at the appropriate time. However, if no licence were to be granted, then alternative arrangements could be made (TfL/310, 5.9). h. A Marine Works Licence, authorising works in the river below Mean High Water Spring Tide, would be sought from DEFRA in accordance with Section 5 of the Food and Environment Protection Act 1985, and would be considered by the MCEU in consultation with the PLA. Given the extent of prior consultation with the PLA, again no difficulty is envisaged in securing this licence (TfL/310, 5.4). i. A Drainage Outfall Licence for surface water drainage outfalls on either side of the river would be sought from the MCEU on behalf of DEFRA, in accordance with Section 5 of the Food and Environment Protection Act 1985. As part of this process, applications would also be made to the PLA, EA and the local planning authority, all of whom are content with the relevant proposed planning condition. Such applications are routine, and TfL is not aware that any difficulty would arise (TfL/301, 5.7).
j. An OFCOM licence for the Marine Radar and SHF radio links would be sought in accordance with the Telecommunications Act. The relevant radar facilities have been granted planning permission (TfL/198). The PLA have experience of obtaining OFCOM licences, and have told TfL that they expect no difficulty in obtaining licences for the scheme radars. The SHF radio equipment is type approved by OFCOM, and so again no difficulty is expected in obtaining licences (TfL/301, 5.8). THE TOLL ORDER 4.485 The purpose of proposing that tolls should be charged on the TGB and the features of the tolling scheme which it is intended to operate if the bridge is
143
built have already been discussed in some detail at paragraphs 4.134 to 4.146 above. This is because tolling is so integral to the proposals for the bridge, both to control traffic on the bridge and to generate revenue to help to pay for the scheme. 4.486 About two thirds of the bridge costs would be met by tolling; the rest by PFI credits. Bids would be invited on the basis of the levels of traffic TfL have predicted on the bridge. Once bids have been made, the concessionaire would take the risk that the traffic might not materialise. 4.487 The Toll Order would not authorise the charging of tolls by the concessionaire. Tolls would be set and charged by TfL. There is no requirement for the Toll Order to specify the actual tolls which would be charged, so long as it specifies the maximum tolls which may be charged. It would not be sensible to prescribe now the tolls which would be appropriate to charge at a 2013 opening date or thereafter. 4.488 The Order would allow different maxima to be specified for different descriptions of traffic, and it would allow the amounts to be varied in accordance with a prescribed formula. Within the prescribed maxima, TfL would be authorised to charge according to their own tariff, which could be varied form time to time. 4.489 The possibility of differential tolling is important in ensuring that the TGB would serve primarily a local function, rather than facilitating longer distance through traffic which is unrelated to local regeneration. There could be differential tolls related to the time at which the bridge was used as well as related to the type of traffic using the bridge. This would allow the charging of higher tolls during peak use periods. 4.490 The Order as drafted includes a substantial degree of flexibility to charge higher tolls than those originally proposed. The promoters consider it unlikely that it would be necessary to levy a toll higher than 4 (at todays values) for a car to cross the bridge. Nevertheless, TfL see the logic of being able to go beyond that figure (up rated for inflation under the provisions in the Order) without the necessity of promoting a Toll Revision Order. TfL therefore accepts that it would be appropriate to increase the highest permissible toll for cars from 4 to 6, as some objectors suggest. Indeed, TfL would have no in principle objection to a higher figure, although it is not considered that a case has been made for a higher maximum car toll than 6. 4.491 The precise levels of the initial tolls and the boundaries of the discount area referred to in paragraphs 4.135, 4.139 and 4.140 above would be the subject of consultation through the BCG in the lead up to the opening of the TGB, though, as a matter of law, the decision on toll amounts would be taken by TfL. The same process would be followed to reach a final decision on whether or not to impose a toll on motorcycles.
144
4.492 The definition of local traffic and the determination of exempted descriptions of traffic might change over time, and the Order would allow this throughout the forty year period for which it would initially run. An extension of that period is permissible under Section 12 of the New Roads and Street Works Act 1991. 4.493 The 1991 Act does not set out any criterion for the making by TfL or the confirmation by the Secretary of State of the Toll Order. It is sufficient if the Secretary of State is satisfied that it is appropriate to confirm the Order. In the case of the TGB, it is essential that the charging of tolls is possible for the reasons outlined in paragraphs 4.486 above. 4.494 If (but only if) the Special Roads Scheme is confirmed, so that the TGB becomes a special road, then the Secretary of State must also confirm the Toll Order. Section 6(5) of the New Roads and Street Works Act 1991 provides that The Secretary of State shall not make or confirm the scheme or the toll order unless he makes or confirms them both. 4.495 The promoters ask the Secretary of State to confirm the Toll Order subject to the amendments they have requested in Documents TfL/214 (to increase the original maximum tolls) and TfL/332 (a drafting clarification).
THE CASES OF THE SUPPORTERS
The material points are: London Borough of Greenwich Council 5.1 At the start of the inquiry Greenwich supported the scheme, but with some concerns. During the inquiry those concerns were allayed, and the Council is now an unqualified supporter of the scheme. All holding objections submitted by the Council have been withdrawn.
Land use planning 5.2 The development of the site at Gallions Reach for a new multi-modal river crossing represents the culmination of a considerable period of planning guidance preparation by Central Government, the GLA and Greenwich Council. The proposals are generally consistent with all current planning policy, including the Boroughs UDP, the emerging UDP, the London Plan, strategic planning policies and PPGs and PPSs. The Council expects that Greenwichs emerging UDP will be adopted by the time the Secretaries of State consider this report. The Council will advise the Secretaries of State when the UDP is adopted. The emerging UDP
145
5.3
provides express policy support for the scheme. Regeneration 5.4 The scheme would assist regeneration in Woolwich and Thamesmead in particular, parts of the Borough of Greenwich with substantial social and economic needs. It would also advance regional and national policy by supporting regeneration in the Thames Gateway. Local residents would gain from access to employment opportunities across the river, and local businesses would gain easier access to customers and suppliers. The north-eastern part of the Borough would become more attractive for economic investment, and many jobs would be created. Past transport improvements such as the Jubilee Line Extension have aided regeneration, and the Council is confident that the scheme would have a similar effect.
Flood defences 5.5 The forthcoming review of the Thames Barrier and associated flood defence structures can be expected to alleviate any long term increase in flood risk arising from the scheme, climate change and storm surges. The engineering design would allow for possible future raising of the defence level.
Transport 5.6 The schemes fully integrated public transport lanes would provide public transport across the river of sufficient quality to provide a genuine alternative to private car travel. While the Council would have preferred to see these lanes used by trams from the outset, it is content to leave this preference as an aspiration for the future, and to express its support for the public transport that would be provided. The Council are satisfied that the absence of any southward extension of the scheme, coupled with the tolling proposals, would ensure that it would remain a road for local rather than national journeys.
5.7
The Boroughs Agreement 5.8 The Council are satisfied that the provisions of the Boroughs Agreement (Document TfL/22C) meet their earlier concerns about the effect of the scheme on air quality. That Agreement is commended as a model of responsible and realistic cooperation between public authorities, which has significantly improved the overall proposals. Considerable weight should be given to it. The Council also welcome the environmental enhancements that the scheme will bring: new open space, the riverside walk, linkages across the river for cyclists and pedestrians, viewing areas and ecological
146
5.9
enhancements. Conditions 5.10 It should also be noted that there are fully agreed conditions, which are jointly recommended by the promoters and the three local planning authorities concerned (Greenwich, Newham and the Development Corporation) to be imposed on any planning permissions. These have again been the subject of informed and constructive discussion, both within the inquiry and outside it. Greenwich would not favour the condition suggested by the Inspectors in Document INQ/23 (set out in paragraph 4.421 above). The Council do not consider that it would meet the tests on necessity and enforcement contained in Circular 11/95. Traffic forecasts are just as likely to provide an overestimate as an underestimate. It would be inappropriate to limit vehicles over the bridge to 4,525 per hour if any congestion turns out to be less than envisaged. The Boroughs Agreement provides the basis for a more flexible means of limiting the number of vehicles crossing the proposed bridge.
5.11
Overall 5.12 While the proposed bridge might well cause some adverse environmental impacts, these need to be balanced against the wider benefits and improvements that the community will experience. The comprehensive package of mitigation measures and ongoing monitoring and management which the Boroughs Agreement would deliver would keep any adverse impacts within acceptable limits.
Scheme design 5.13 The Greenwich UDP seeks a good quality of design. The proposed Design Panel would ensure that the scheme would provide an identifiable landmark in an area that needs such a structure. The local planning authorities would have the chance to reach a final conclusion on design issues within the framework provided by the Design Statement and the conditions which it has been suggested should be imposed on any planning permissions. The planning authorities would consult one another in so doing. The project programme allows sufficient time for proper consideration of the proposals. Greenwich have a track record of achieving excellent design outcomes, as indicated by the list of key developments in the area which have received Civic Trust recognition in recent years (Document 2703/18). The Council consider that the scheme offers the opportunity of introducing a stunning new structure to give this part of Greenwich a nationally recognised landmark.
147
London Borough of Newham Council The position of Newham on the matters before the inquiry 5.14 At the opening of the inquiry, Newham were identified as supporters of the TGB scheme, but with some points of concern which needed to be addressed. In fact, in their initial representations, Newham Council objected to the Side Roads Order and the Toll Order. On 27 June 2005 the Council withdrew their objection to the Side Roads Order. The Mayor of Newham also authorised his staff to withdraw the Councils objection to the Toll Order, subject to the conclusion of the Boroughs Agreement. Newham Council subsequently entered into that Agreement, but no formal written notice was given to the inquiry that Newhams objection to the Toll Order was withdrawn. In closing their case, however, Counsel for Newham indicated that the objection to the Toll Order was also withdrawn (Document 2687/26, paragraph 5). Indeed, having regard to the conclusion of the Boroughs Agreement (to which significant weight ought to be attached) and to the agreement reached on the conditions which should be attached to any planning permissions, Newham now offer unqualified support for the Scheme, the applications and the Orders. The TGB proposals have aroused very little controversy in Newham. There has been hardly any opposition from the public, and the proposals have received consistent support from the Council. That position is not the result of inertia, or a lack of public interest in the physical environment amongst those living in Newham, but rather a broad recognition of the obvious and significant benefits that the TGB proposals hold in store for that part of London. Newham have a clear and consistent objective of promoting the regeneration of the Borough, and have long recognised the importance of achieving an additional river crossing in order to secure that objective.
5.15
5.16
5.17
Policy support for the TGB 5.18 The proposed TGB and associated carriageways within Newham would run along a route which has been safeguarded in the Boroughs UDP. The land use planning in the area most directly affected by the proposals has been guided by their anticipated arrival for many years. The safeguarded route lies within the Thames Gateway area, which has long been identified as an area for regeneration and development, and it adjoins three separate UDP designated Major Opportunity Zones. Failure to permit the TGB would constitute a severe setback to the prospects of successfully regenerating these urban brownfield sites. The regeneration of the extensive areas of physical dereliction and economic and social deprivation that exist in this part of London is vital to the continued economic growth of the Capital. The overarching objective of Newhams UDP is to secure regeneration.
148
5.19
These proposals would play a very significant role in furthering that objective. The introduction to the UDP sets out the Councils vision for the future, namely that by the year 2010 Newham will be a major business location, and a place where people will choose to live and work. Establishing investor confidence is essential to the achievement of the Councils vision. A decision to allow the TGB to proceed would deliver a major strategic boost to investor confidence in this part of London 5.20 Policy T12 of the UDP states that the Council support in principle a multimodal bridge at Gallions Reach. Paragraph 7.69 of the supporting text acknowledges that the scheme may have some adverse effects on the environment of Newham and adjoining Boroughs. These, it says, need to be minimised through sensitive design and other appropriate measures. Newham consider that to have been achieved here. Policy T11 indicates that the Council will only support the construction of new roads when these will bring net economic and/or environmental benefits to the Borough. Regard will be had to likely consequences of new roads for neighbouring boroughs, and measures will be taken, where appropriate, to minimise any likely adverse effects. The supporting text at paragraph 7.64 explains that the TGB is one of two links that are needed to complete Newhams road network. 5.22 Newham consider that the proposals would provide important net economic benefits, and that any likely adverse effects have been minimised so far as reasonably practicable. The Council have considered the likely consequences of the TGB for neighbouring Boroughs, and do not find them to be unacceptable, a judgement which appears to be shared by all neighbouring Boroughs apart from Bexley. The TGB is also expressly supported by the London Plan, the regional level of the Development Plan for Newham. Newham consider that the TGB meets the criteria for the approval of new road schemes contained in Policy 3C.15 of the London Plan. a. It would contribute to Londons economic regeneration and development, making a significant and vital contribution to the economic regeneration and development of a particularly deprived part of East London, and therefore to London as a whole. b. To the extent that the net traffic capacity of the corridor would be increased, it would without doubt be essential to the regeneration of the area. c. Some relatively limited environmental disbenefits would be likely to
149
5.21
5.23
result from the proposals, but Newham consider that the physical regeneration of the area, and the addition of a well designed bridge would far outweigh those disbenefits and provide a net gain. d. As a result of shifting traffic to higher quality roads, the effect of the bridge would be an overall reduction in the rate of accidents per mile. Any increase in the overall total of accidents as a result simply of increasing the overall length of the highway cannot be a rational basis for turning the proposals away. e. In comparison with the existing position, where the river cannot be crossed at Gallions Reach by pedestrians, cyclists, people with disabilities, public transport and businesses, there would be a significant and lasting improvement in conditions. f. Both the strategic and the local land use planning policies assume that a proposal of this sort will go ahead in this part of East London. 5.24 Newham consider that the proposed TGB would not worsen materially conditions against any of the criteria in Policy 3C.15. But if it is considered that conditions would be worsened, the regeneration benefits associated with the bridge would massively outweigh any disbenefits; and the combined effect of the Boroughs Agreement and the agreed conditions would mitigate any unavoidable disbenefits to an acceptable degree. Newham therefore conclude that the proposed TGB accords with the relevant policies in the Development Plan for their area, and that the presumption should be in favour of the scheme unless material considerations indicate otherwise.
5.25
The contribution of the TGB to regeneration in Newham 5.26 The TGB would help regeneration in Newham in two main ways. First, it would increase the catchment area within a reasonable time to, from and within the study area. This would increase the number and range of employment opportunities available within an acceptable travel time for residents on both sides of the river, and, so far as businesses are concerned, it would increase the number of potential employees, markets and suppliers reasonably available to them. Secondly, it would serve to stimulate demand and bring forward development of sites that might not otherwise have taken place. There has been debate at the inquiry about the number of jobs and homes which might be expected to arise from these proposals. The prediction of regeneration effects is not a precise science. Newham suggest that the estimates should be regarded as being of an indicative nature only. But there can be no sensible doubt that increasing accessibility through the creation of a new river crossing would stimulate regeneration, and that the stimulus it would provide would be a significant one.
150
5.27
Traffic conditions on Newhams main roads 5.28 Document 2687/18 is a written representation that describes current traffic congestion on Newhams main road network, as follows: a. The A13 Newham Way runs fairly freely westbound. Peak period congestion occurs at the A13 junctions with the A117 and the A112. The A13 eastbound is very congested in the evening peak, with very slow moving traffic east of the A406, caused by lack of capacity at Movers Lane. b. The A124 Barking Road is heavily congested at its junction with the A406 during the morning and evening peak periods. c. The A118 Romford Road is heavily congested at its junction with the A406 during the morning peak period, and congested there during the evening peak. d. The A406 main line reduces from three to two lanes at its junctions with the A118 and the A124, and is congested at both during the peak hours. Conditions become very poor during the evening peak: the severe congestion on the A13 eastbound at Movers Lane results in the A406 southbound traffic often queuing from its junction with the A124 towards the A13, and this causes large scale diversion on to the A124, at which times the queue on the slip road often stretches back on to the A406. The potential traffic and transportation impact on Newham of the TGB proposal 5.29 Jacobs Babtie are the consulting engineers appointed variously by Newham and by Greenwich to review TfLs traffic modelling work on the scheme. The work they undertook on behalf of Newham Council largely considered the Reference Case Model. TfL revised their traffic model and produced the Cordon Model after Newhams appearance at the inquiry. Newham subsequently submitted Document 2687/23 as a written representation. This notes, among other things, that the Cordon Model suggests lower flows in Newham as a result of the scheme than the previous modelling; that it demonstrates the effectiveness of tolls for managing traffic; and that it does not alter Newhams case for conditionally (at that stage) supporting the scheme. The modelling approach taken by TfL in preparing the Reference Case Model is consistent with that used to assess recent major transport schemes in London, including Crossrail, Congestion Charging and the Cross River Tram. It allows all significant traffic responses to be assessed, and, although there may be some, probably insignificant, inconsistencies in the work, the approach taken is appropriate for the regeneration purpose of the scheme. The Regeneration Case model demonstrates that the concept of the TGB is robust in transport terms.
151
5.30
5.31
Contrary to normal practice, the modelling forecast year is only four years after the planned year of opening. This potentially leads to an understatement of the impacts of the scheme on road and public transport networks. TfL undertook a high growth sensitivity test, increasing traffic on the bridge by 25% and then doubling tolls at peak periods. This suggests that, given the effect of the tolls, scheme impacts for 2027 (15 years after opening) could be constrained to the level of impacts forecast for 2016. Jacobs Babtie did not review in detail the modelling of tolls. The approach used by TfL in preparing the Reference Case Model of the highway network is appropriate for assessing the overall highway impacts of the scheme. The approach used in preparing the public transport model is appropriate in the context of the overall planning of the scheme, but more detailed modelling is likely to be needed at a later stage in planning public transport options on the bridge. The information provided to Jacobs Babtie by TfL in respect of the TRANSYT assessment of the proposed A13/A406 junction, a critical junction for Newham and for the scheme, on the basis of the Reference Case Model, was insufficient for full scrutiny of the design. Estimated saturation flows in the junction should be checked against reality. Traffic flows in the PM peak should be surveyed, since TfLs use of transposed flows might not be adequate. The TRANSYT model should be validated by monitoring queue lengths on site and comparing those with the models findings. No plan of the proposed junction had been provided, and so its ability to accommodate the expected internal queues could not be verified. The SATURN TGX Reference Case Model indicates that the A13/A406 junction and the Royal Docks Road/Armada Way junction would be over capacity in the AM peak design case; there was no forecast for the PM peak. The flexible strategy proposed by TfL for traffic monitoring and mitigation measures is sensible, given the uncertainties inherent in forecasting traffic demand on individual links and junctions. There are areas in the simulation area (of the Reference Case traffic model) that do not meet the calibration criteria set out in the DMRB. The matrix estimation technique, used by TfL in the Local Model Validation Report, is a generally accepted practice, although a number of practitioners have reservations about its use. Bexley criticised the work carried out for Newham in advising on traffic modelling by Jacobs Babtie. While some shortcomings were identified, there was nothing which would have led to a different conclusion. None of the criticisms went to the heart of the advice. Newham remain confident in the essential reliability and fitness for purpose of TfLs modelling work in assessing the position on Newhams roads. The local TGX model is not satisfactory for modelling local roads in Bexley,
152
5.32
5.33
5.34
5.35
5.36
5.37
5.38
since the zone size is too big, the network is too coarse and the origin and destination data would not be reliable at a local level. However, that was not the objective of the model. 5.39 The DMRB (Document D522) identifies that the accuracy of any model cannot be expected to represent reality except within a range or tolerance. Indeed, Newham understand and acknowledge the inherent limitations of modelling as a tool for predicting traffic impacts. But it is important that the degree of accuracy of any particular model is adequate for the decisions which need to be taken. In overall terms, Jacobs Babties advice has been that the general approach and methodology used by TfL is appropriate, and that the modelling and forecasts are sound and fit for purpose. The Reference Case Model is adequate for the purpose of regeneration. Regeneration schemes are distinguished from highway cases in that the latter are typically provided to relieve congestion, whereas the former tend to focus on a relatively small area and, in the case of this scheme, would provide a completely new highway on which traffic flows would be regulated by tolls. By building the scheme as a direct extension of the A406, traffic would be confined to the principal road network as far as possible. The scheme is a feasible and practical project, which would improve accessibility for the local populations on either side of the river, helping to promote regeneration in Newham. In order to achieve those objectives whilst avoiding the unwanted effects of induced traffic, a package of complementary measures is required. This would include the setting of an appropriate toll for the use of the bridge, together with the improvement of alternative modes of transport to the private car and appropriate traffic management measures. The flexibility of the mechanism available through the Boroughs Agreement means that it is not necessary to place undue reliance on the precise accuracy of the forecasts provided by modelling to manage the potential traffic impacts of the TGB.
5.40
5.41
Tolls 5.42 Newham welcome the proposal to toll the bridge. Tolls would be essential to control traffic volumes and the nature of trips made over the bridge. The Boroughs Agreement with TfL (TfL/22C) provides an acceptable mechanism for the Councils input to the toll review process. The rebased traffic model showing the impact of changes to the discount area and increases in tolls indicates that there would no longer be an increase in traffic on the A13 east of the TGB because of the reduction in northbound traffic using the TGB as a response to increased tolls. Newham consider that this, together with the reduced level of trips from outside the four local Boroughs predicted as a result of the same factor, serves to illustrate the advantages of the flexible tolling system as a tool for managing the impacts of the bridge.
153
5.43
Public transport 5.44 The scheme would enable the development of a comprehensive network of bus services that would:a. Allow good public transport interchange with DLR, London Underground and national rail services. b. Offer scope for increasing public transport capacity easily to match the pace of future development in this part of the Thames Gateway. c. Provide significant time savings on local cross river public transport journeys. 5.45 Newhams evidence at the start of the inquiry was that a minimum level of bus service across the bridge should be specified by the end of the inquiry (Document 2687/2/A1, 8.2). Subsequently, the Boroughs Agreement made on 19 April 2006 (Document TfL/22C), to which Newham is a party, provides in clause 9 that TfLs proposals for public transport on the bridge would be made available for consideration by Newham and the other Borough Councils party to the Agreement at least 12 months before the scheme opened; and that periodically during the ten-year period after the bridge opened TfL would review public transport provision on the bridge and seek the views of Newham and the other signatory Borough Councils. This proposal is acceptable to Newham in place of a minimum service level agreement.
Air quality and noise 5.46 Air quality in Newham currently fails to meet air quality objectives for nitrogen dioxide and particulates, and, as a result, an AQMA has been declared for nitrogen dioxide and particulates along the major roads in the Borough, including the A13 and the A406. The predicted changes which the bridge would bring about would be to increase nitrogen dioxide alongside the A406 and the A2016 by up to 4% and particulates by up to 2%. There would be smaller predicted increases along the A13. The draft Air Quality Action Plan which has been prepared in response to the air quality findings, however, (Document 2687/21) positively endorses the TGB proposal. The levels of emissions are expected to fall significantly between now and 2016 resulting from improvements in fuels and in vehicle technology. Current policies in both the London Plan and the Newham UDP mainly concentrate non residential uses in the areas close to the bridge. The negative air quality impact needs to be weighed against the benefits of increased accessibility for employment and training, with related
154
5.47
5.48
5.49
improvements in income and in the overall wellbeing of residents. With appropriate mitigation, the negative impacts of the scheme on air quality could be minimised. 5.50 As regards noise, the operation of the TGB would increase noise levels in the vicinity of the bridge and on feeder roads to the bridge, but within Newham those increases are expected to be modest, and would be addressed by suitable mitigation measures.
Ecology 5.51 There would undoubtedly be some ecological impacts associated with the proposals, and there would be a net loss of biodiversity within the application site. That is no more than would be expected from a proposal of this size and nature. A suitable set of mitigation measures has been secured, however, to offset the ecological impact. The residual impacts are not such as to outweigh the substantial benefits that would come from the construction of the TGB, and do not militate against the grant of planning permission.
Quality of design 5.52 The scheme would cross the Thames Policy Area identified in the Newham UDP 2001 (Document D634). Policy EQ4 of the UDP requires among other things that development in the Thames Policy Area should provide a high standard of urban design and visual amenity. Newham welcome the establishment of the proposed Design Panel and the aspirations for the TGB identified by the promoters. The project programme allows sufficient time for consideration of the matters covered by the suggested planning conditions. Greenwich would be consulted. Newham has worked well in the past with Greenwich, TfL, and the GLA Urbanism Unit.
A condition limiting the level of traffic on the proposed bridge 5.53 Newham would not favour such a condition. Traffic modelling is necessarily an imprecise tool. It is useful to determine the broad quantum of traffic effects which might be expected, but it is not sufficiently reliable in its predictions of effects at a local level to be used to determine in advance that a particular level of traffic using the bridge would not be acceptable. Moreover, the acceptable traffic level of 4,525 vehicles per hour cited in the condition suggested in Document INQ/23 is based on assumptions which reflect the predicted growth in background traffic as well as the predicted impact of the bridge itself. It is the combination of that traffic growth and traffic using the bridge which would give rise to the conditions which might be deemed unacceptable. In the early years following the opening of the bridge, however, background traffic levels may not require traffic on the bridge to be so heavily constrained as the draft condition suggests.
155
5.54
5.55
The Boroughs Agreement provides a more dynamic and appropriate mechanism for responding to traffic conditions over a wider area, which would be much preferable to simply limiting traffic levels crossing the bridge to a predetermined figure.
Essential commitments of the Boroughs Agreement 5.56 Newham agree with the assessment of TfL (at paragraph 4.436 above) regarding the provisions of the Boroughs Agreement which are essential to the grant of planning permission. In addition, however, Newham contend that air quality mitigation during operation of the bridge and the measures concerning employment, training and procurement are also essential to the grant of planning permission.
London Borough of Redbridge Council 5.57 Redbridge Council have from the outset supported the scheme, provided that adequate mitigation measures are implemented by TfL to address the environmental impact of the increased traffic levels expected. The Council consider that the mechanisms and the funding provided by the Boroughs Agreement should meet their reservations and concerns.
Current conditions in Redbridge 5.58 Redbridge is an outer London Borough to the north of the scheme, prosperous in its north and more deprived in its south. It is not in the Thames Gateway. As with the majority of outer London Boroughs, traffic congestion is generally an issue for the road network in Redbridge, particularly on the M11, A406 and A12. These carry a large proportion of traffic passing through the Borough to and from Central and South London and the north Docklands area. There are 14 locations in the Borough where congestion is particularly acute during the morning and evening peak periods, including the A406/A12 Redbridge Roundabout (2067/5A).
5.59
Regeneration 5.60 Ilford is the metropolitan centre in Redbridge and is located towards the south of the Borough including, in part, the two wards in the Borough that are among the 20% most deprived wards in England. The Council seek the regeneration of Ilford town centre to serve East London and the Thames Gateway and consider accessibility to be an important part of that process. Although the scheme is only one of a number of transport related proposals that will aid the regeneration of Ilford and Redbridge as a whole, its implementation is considered to be of prime importance due to the key link it would provide to the south of London a change that will be of particular
156
5.61
benefit to Redbridge since no such link exists at present. The effects of the new link would include: a. A reduction in trips between the Borough and Central London, as some such trips would transfer to destinations south of the river. This would benefit, for example, the Underground Central Line which at present is often at or above capacity. b. Improved accessibility to Ilford from South London. c. A contribution towards sustained economic growth in the Thames Gateway, as set out in Policy 3.3 of the Mayors Transport Strategy. 5.62 Redbridge Council accept the evidence of TfL with regard to the effects the scheme would have on accessibility and employment in the Borough. Three of the four most deprived wards in the Borough would potentially benefit the most from the scheme because they are near to the A406/A118 junction and because they would be likely to be better served by public transport.
Public transport 5.63 The ELT phase 1 is a proposed bus based rapid transit system running from Barking to Ilford, with a potential extension to Barkingside in northern Redbridge. Further possible future extensions would reach via Rainham and Romford to Harold Hill in Havering. It forms part of a package of proposals collectively referred to as Thames Gateway Transit, which also include the GWT and the TGB. Thus, by linking the ELT and the GWT, the scheme would form new connections in the south-east of the Thames Gateway sub region, allowing Redbridge residents to travel on new transit vehicles to connections south of the river. The initial phase of the ELT would serve the three most deprived wards in Redbridge. The Public Transport Development Statements that the Boroughs Agreement (Document TfL/22C) establishes would serve as a useful tool for identifying the changing needs and requirements for the public transport network in the future.
5.64
Alternative 5.65 As a comparator, Redbridge Council have considered a future situation in which the bridge had not been built. In that situation:a. Employment opportunities available to local residents would remain limited, as would access to opportunities for recreation and leisure. Residents in the relatively deprived south of the Borough would be most affected.
157
b. The existing longer than necessary journey times and distances between the north-east and the south-east of the sub-region would remain. c. The high demand for travel from Redbridge to central destinations would be likely to continue.
d. Accessibility in the area would be lower than with the scheme, hindering its regeneration. Traffic mitigation 5.66 Redbridge is likely to experience a significant increase in traffic flows, mainly on the A406, if the scheme goes ahead. The performance of the A118/A406 junction is of particular interest to Redbridge Council. TfL has thoroughly researched that junction and has undertaken, through the Boroughs Agreement (Document TfL/22C), to carry out appropriate monitoring of its performance once the scheme is opened.
Tolls - discount area 5.67 The proposed discount area would include the three relatively deprived wards in the south of the Borough. Redbridge Council consider that further slight amendment to the proposed discount area may be necessary to reflect local circumstances.
Air quality 5.68 Redbridge Council gave no expert evidence on air quality. The sole witness called by the Council noted that TfLs revised (Cordon) traffic model and their associated air quality modelling predicted lesser concentrations of nitrogen dioxide at the three receptors in the Borough predicted to be near or above the annual mean objective for that emission in 2016. He concluded that, although the scheme would be likely to result in minor adverse impacts on air quality, those impacts would be outweighed by the overall benefits of the scheme. The Boroughs Agreement (Document TfL/22C) would provide a Low Emission Strategy which would ensure that any adverse effects the scheme may have on air quality would be minimised.
5.69
Planning policy 5.70 Although the scheme would increase traffic in Redbridge and reduce air quality, it would also bring more jobs, better accessibility and better public transport. The positive effects of the scheme would outweigh the disadvantages associated with it.
158
A condition limiting the level of traffic on the proposed bridge 5.71 Redbridge do not consider a planning condition limiting the level of traffic on the proposed bridge to be appropriate, because it would create a flat ceiling, which would make no allowance for peaks and troughs at different times of the year, or when there are special events such as football matches that may cause a temporary higher level for traffic without prejudice to the overall year total. Discussion through the BCG would provide a better method of dealing with ongoing monitoring and control of traffic.
Essential commitments of the Boroughs Agreement 5.72 Redbridge consider that the provisions of the Boroughs Agreement relating to the creation of the BCG, the tolling regime, public transport development statements, and the monitoring and managing traffic and air quality (not just during construction) to be essential to the grant of planning permission. Other provisions of the Agreement are regarded as desirable.
Thames Gateway London Partnership 5.73 The TGLP was set up in 1995 to promote the economic, social and environmental regeneration of the East Thames. Its members include eleven London Boroughs in East London together with Dartford Borough Council and representatives from the five Universities, the two Strategic Health Authorities and the two Learning and Skills Councils (LSCs) in the area. It is governed by a Board made up of a senior representative from each of the member bodies. While the views of the Partnership are not binding on its constituent members, great care is taken to ensure that the expressed view of TGLP is in line with member views. No policy position is taken without either a full consensus or an appropriate caveat to clarify any difference which might exist between members. TGLP has consistently supported a bridge at Gallions Reach, provided it is part of a package of river crossings; it is a local bridge; the design and operation of the bridge would encourage public transport; and demand to use the bridge is managed in an effective way.
5.74
A package of river crossings 5.75 TGLP considers that there is a need for substantially improved public transport crossings of the Thames in East London. Public transport provision would be assisted by the dedicated public transport lanes on the proposed TGB, but more substantial improvements to public transport links will be achieved by the DLR crossing to Woolwich and the proposed heavy rail Crossrail extension. It has become clear that in practice these schemes (together with the
159
5.76
proposed crossing linking the Greenwich Peninsula and Silvertown) need to be progressed as separate schemes using different powers and processes and with a separate justification of each business case; but TGLP still sees them as an overall package. The public transport element of the additional crossing capacity created through these four schemes would exceed 80%. A local bridge 5.77 TGLP would not support a motorway style strategic connection between the A406 and the A2/A205. There is no such connection proposed in this application. The road proposals associated with the TGB would not cross the ancient woodland at Oxleas Wood, and any future attempt to make such a connection to the A2 would face great public and political opposition. The legal Orders permitting the connection to the A2 have been rescinded (as noted at paragraph 4.8 above), and land acquired in advance of the creation of that earlier planned link has been sold. The tolling of the TGB to deter long distance traffic from using it and the priority given to keeping public transport moving in dedicated lanes would ensure that the TGB remained a local crossing.
Priority for public transport 5.78 One of the fundamental conditions for TGLPs support for the TGB has always been that the bridge must provide scope for a major expansion of public transport services and improved north-south links to meet increased demand as new development occurs and measures are taken to reduce reliance on the private car. The public transport lanes must link the GWT and the ELT, to form the core of a growing network of Thames Gateway Transit services. These could be extended later to connect to Rainham, as planned, but also to the Kent Thameside Fastrack service and to the Silvertown Link. TGLP welcomes the proposed creation of the TGB with the potential for trams to use the public transport lanes. Trams would encourage greater use of public transport. TGLP also welcomes the fact that the public transport lanes would be fully segregated to keep other traffic out, and to keep buses moving. This was the reason why TGLP considered it essential to have full physical segregation between the public transport lanes and those which would be available for use by general traffic. Whilst TGLP has always insisted that the proposed TGB should include a public transport element, the reality is that public transport cannot cater for all the demands for trips in the Thames Gateway. A road bridge is needed as well as much improved public transport links. Good connections for commercial traffic between East Londons industrial areas are essential for job retention and growth. Local businesses need road access for their supplies and for the goods they distribute. That need cannot be met by public transport. The reduced operating costs possible with the bridge would be translated into lower costs, more choice and more jobs.
160
5.79
5.80
5.81
Moreover, some trips need cars - those that involve linked trips, trips made by people with certain disabilities, and trips conveying bulky goods. Those working unsocial hours, especially if they are women, may feel safer using private transport.
Demand management 5.82 TGLP supports the use of differential tolls on the TGB to control the use of the bridge by long distance traffic and the congestion caused by traffic growth. This must be allied with flexibility to change the toll levels and discounts easily. Such a regime has worked successfully for many years on the Itchen Bridge in Southampton, as described in Document 1752/1/E. TGLP considers that the arrangements set out in the Boroughs Agreement would deliver that level of flexibility. That is to be preferred as a method of managing demand to the proposal for a fixed hourly limit in traffic over the bridge put forward in Document INQ/23. TGLP considers that an overall hourly limit would be unacceptable, in that it would unnecessarily fetter the options of the BCG set up under the Boroughs Agreement. In fact, TGLP considers that there is a case for a higher maximum toll under the Toll Order than that requested by TfL. This would increase the flexibility available to TfL to manage demand in consultation with the BCG.
5.83
5.84
The need for the TGB 5.85 Compared with West London, East London is poorly served in terms of crossings of the Thames. In addition, the Thames Gateway has some of the areas with the highest levels of deprivation in London. There are not enough crossings and not enough local jobs, resulting in either long trips to work or unemployment. The Government and the Mayor intend that there should be regeneration and expansion in the Thames Gateway, with new sustainable communities. That is only achievable with higher densities in residential and commercial developments so that better public transport can be introduced effectively and economically. The aim is to create more compact urban areas, with more of the trips, especially those made by car, being shorter, and with a greater proportion of trips being made by public transport. The TGB would reduce the length of many of the existing cross river trips using Blackwall or Dartford, help to keep new local trips shorter, and provide more opportunities for cross river trips to be made by public transport. A new multi-modal TGB link would provide much improved accessibility for residents and businesses by road and public transport, not just to jobs to reduce unemployment, but also to other opportunities for health, education and recreation.
5.86
5.87
161
5.88
Translating increased accessibility into a precise increase in the number of jobs available is difficult. As SACTRA concluded in 1999, there is not an automatic process whereby new transport infrastructure results in economic development at all. In the particular circumstances of this case, however, Atkins (who were commissioned by TGLP to look into this issue in 2003) reported that a number of independent studies had concluded that the construction of the TGB would have a positive employment outcome. That was a conclusion which Atkins themselves supported, and it is also supported by the evidence adduced by TfL in this case. In January 2004, the TUC wrote (Document 1752/1/B, Annex 13) that Unions in London supported the proposal to build the TGB, but on condition that it is a stimulus to the economic and social regeneration of the area. The TUC suggested that active local labour recruitment and new training and learning facilities would maximise the local long term employment and regeneration impact. Provisions in the Boroughs Agreement seek to pick up some of those points, and the local LSC is addressing others as indicated below.
5.89
Regeneration - Training 5.90 The London East office of the LSC serves the City of London and the London Boroughs of Barking & Dagenham, Bexley, Greenwich, Hackney, Havering, Lewisham, Newham, Redbridge and Tower Hamlets. The LSC is a member of the TGLP, and its Executive Director gave evidence in support of the TGLP case. In 2004, the London East LSC invested about 400 million in the learning and skills of residents attending school sixth forms, colleges and workbased learning providers. The population of the area served by the London East LSC office is relatively less well skilled than the rest of London, but the majority of the new employment opportunities that would be generated by investment in the Thames Gateway would require high skill levels at Level 3 (equivalent to A level) or above. The LSC supports the scheme because of its potential contribution to ensuring a better-skilled local population able to succeed in new high quality jobs. It would do this in four ways. a. By making travel to study easier. The Thames is a barrier to movement. The proportion of learners crossing the river is higher in those Boroughs near to the Rotherhithe and Blackwall tunnels than in those further east and remote from river crossings. The scheme would enable greater mobility, and thus choice of courses, to residents on both sides of the river. In cross-examination, it was noted that the percentage of students crossing the river to study from Tower Hamlets was less than from Bexley. The percentages of students crossing the river from the
162
5.91
5.92
5.93
south are in every case greater than those crossing the river from the north (compare the southern Boroughs of Lewisham (14%), Greenwich (10%) and Bexley (8%) with, in the north, Tower Hamlets (7%), Newham (6%) and Barking & Dagenham(3%)). b. By allowing more college specialisation through access to a larger market. The increased catchment areas that the scheme would provide would allow colleges to run more high quality specialised courses. Currently colleges north of the river offer different specialisms from those to the south. Full duplication on each side of the river cannot be afforded. It is the aspiration of the LSC that capacity should expand to meet increased demand. Funds, although limited, are available from Government and possibly from employers to meet the cost of that expansion. c. By improving access to jobs. d. By providing greater flexibility in travel. The provision of a 24-hour integrated public transport system as part of the scheme would be particularly useful to shift workers. Shift work is growing in London, rising from 12% in 2001 to 14% in 2004. 5.94 The LSCs current activities and future plans for skills training are designed to ensure that local people will be able to benefit from the new jobs and the new access to jobs that the TGB would deliver. A skills audit identifies the existing skills of the workforce in the area, the skills requirements of the area in the future, and the resources available to deliver the training which the workforce would need to meet the future requirements of the area (Document TfL/148). These arrangements would be supported by the commitments contained in the Boroughs Agreement to introduce employment and procurement strategies, the Education Plan, the bursary scheme and the promotion of education and training.
Regeneration - impact on health 5.95 The South East London Strategic Health Authority (SELSHA) is a member of the TGLP. Its Regeneration Director gave evidence in support of the TGLP case on behalf of the National Health Service in South East London. SELSHA had approved this action, and supporting written statements were also submitted from representatives of the Primary Care Trusts in the area (Appendices 1 and 2 of Document 1752/3/B). In fact, the issue had also been considered by the North East London Strategic Health Authority, and that Authority had also taken a position of support for the TGB on health grounds (D16 P197 L19 to 25). The whole purpose of SELSHA is to make sure that the NHS in South East London delivers health care services and improves the health of the population. Similarly, it is a key objective of the TGLP to improve the quality of life for the community in the Thames Gateway. TGLP sees the
163
5.96
creation of the new jobs which would come to the area as a result of the building of the TGB to be a way of improving the overall health of the community. SELSHA agrees. Employment and access to jobs are key determinants of good health. 5.97 There is a tension in this situation, however, because SELSHA also accepts that the development of the TGB would increase traffic along certain roads, with the concern that that would create additional pollution, damaging health and the environment. There is, however, more to good health than air quality. Life expectancy increases as you move towards Central London along some corridors. Air quality is poor in Westminster, but life expectancy is significantly higher than in some areas with better air quality. Air quality and its impact on health is important, but some issues can have a significantly greater impact, especially when action is already being taken to improve air quality. SELSHA has taken the view that, on balance, considering all the available evidence relating to the TGB proposal, it supports the principle of building the bridge. There is extensive research which supports the view that improved employment opportunities in themselves will improve health. Conversely, unemployment has a major negative health impact.
5.98
5.99
5.100 Health and higher incomes are inextricably linked. Higher incomes lead to a higher health status, and every socio economic increase will result in a health improvement. It is widely agreed that socio economic disadvantage comes before poor health, so it is usually the case that income generates health in the first instance. 5.101 Unemployment is associated with morbidity, injuries, and premature mortality, especially from coronary heart disease. It is also related to depression, anxiety, self harm and suicide. Unemployment is particularly high in some ethnic minorities, with implications for the health of the people involved. 5.102 There is not a completely straightforward link between employment and health, however. If work is of low status and low pay, dangerous, or with no personal autonomy or control, then work can lead to health problems too. But when income is adequate, the individual is valued in the workplace, conditions are safe, and there is a degree of autonomy as to the way in which the work is carried out, then the impact on health is a positive one. 5.103 There are wide inequalities in the populations experience of health, varying by different geographical parts of London and different groups within it. A Government wide strategy to reduce health inequalities across England is set out in Tackling Health Inequalities: A Programme for Action (Department of Health 2003).
164
5.104 The Programme for Action recognises the vital contribution that economic prosperity makes to health, and that the economic regeneration of the most disadvantaged areas will make a key contribution to tackling health inequalities. It argues that sustainable work and education are important determinants of health inequality, and that aiming development opportunities at the most deprived communities will be an important way to break the cycle of disadvantage. 5.105 East London contains deprivation, poor economic and employment conditions, under employment, and areas of poor educational attainment. It is properly targeted for economic regeneration. The evidence produced by TfL indicates that the TGB would deliver economic regeneration. Because this is such a crucial question, SELSHA commissioned an independent review of that evidence from Professor Nigel Spence of Queen Mary College, London. His report forms Annex 3 to Document 1752/3/B. While he states that he would prefer to work at the lower end of the projected employment gains, he confirms that the research underpinning the study is generally sound and conforms to accepted standards. His conclusion is that there is little reason to think that the negative impacts of the proposed development will outweigh the benefits for health of increasing affluence and the alleviation of poverty - rather the opposite. 5.106 It would be important to ensure that the economic benefits of the construction of the TGB were felt in the local community, because that has not always happened with other regeneration schemes. The planned timescale for the building of the bridge, however, provides the opportunity to see that all the necessary programmes of skill development are in place to achieve this. 5.107 Despite concern at the potential health disbenefits to some residents who would be affected by increased traffic flows along the streets in which they live, SELSHA concludes that, on balance, the health impacts of the proposed TGB would be positive because of the potential uplift in income to the local area and the resulting decrease in deprivation. That remains the case following the revision of the traffic evidence and the various other topics covered in evidence which depend upon the traffic evidence. The issue has again been discussed in the NHS, and the view, on balance, remains that the TGB proposal should be supported. Regeneration - Development 5.108 Gateway To London (GTL), a company limited by guarantee, is an inward investment and business retention agency for the Thames Gateway London sub region. Its supporting evidence for the TGLP (Document 1752/4/A1) includes case studies to illustrate its conclusions. 5.109 GTL seeks to retain in the area local businesses that wish to relocate. Such businesses will currently not contemplate a cross river move, and avoid crossing the river as much as possible because the existing river crossings
165
are unreliable and because the height restriction on the northbound Blackwall Tunnel makes it impractical for large loads. The semi-circular market which results limits recruitment, suppliers and customers and so constrains business development. But proximity to the London market is one reason why businesses still find this acceptable. 5.110 GTL also seeks to attract to the area businesses from elsewhere in London or the UK. The issue of limited cross river access for staff and the movement of goods is a weakness that puts the region at a disadvantage to other competing locations. A review of potential inward investment cases that eventually did not come to the area shows that issues of access and the river crossing are serious. 5.111 The UK is the most important and favoured European location for foreign direct investment, and, of UK cities, London is the premier destination. Because of its long timescale, the scheme is an irrelevance to companies seeking to relocate from overseas. The opinions of overseas investors currently in London have been surveyed, and the findings consistently show internal and external transport links and access to suitably qualified staff to be among the most important factors influencing investment and expansion decisions. It is vital that these factors are not regarded as an impediment to future investment. 5.112 The Thames Gateway London sub region is the largest industrial area in London, and, with a considerable amount of vacant land (shown on document 1752/4/E) and buildings, it has the scale and scope to be an attractive and competitive location for new businesses. Modern niche manufacturing relies on production flexibility and speed to market, and so the opportunities to compete in this sector would be particularly enhanced by the scheme. For example, speculatively built factories and warehouses at White Hart Triangle have often been considered unattractive by potential occupiers: to them, the lack of a reliable and close at hand cross river connection is a big issue. Beam Reach, Hornchurch, is the principal site identified for manufacturing. It offers up to 15% subsidy for the capital costs of companies moving in, training grants, and rent levels which are 75% of those in West London. If the scheme were in place today, the site would be prime industrial land that might easily be taken up by suitable occupiers. 5.113 The location planning for distribution warehousing tends to be on a national level, and there is scepticism about major infrastructure projects. Such occupiers will only include the effects of the scheme in their location considerations once there is a firm commitment to the scheme. 5.114 The area is an established office location, planned in the London Plan to develop further. The market is strong in Docklands, but weak in the town centres. The scheme would enable office firms to attract staff from across the river. This would help to secure existing office space and would promote developer interest in new office developments.
166
5.115 The retail offer in the Thames Gateway town centres is becoming relatively less attractive. The scheme would improve the situation by providing larger catchment areas, so making town centres in the area more attractive to new occupiers. Long distance traffic 5.116 Logistics operators known to GTL are aware of the proposed toll regime and will want to minimise toll fees. Distribution sites are currently concentrated around the M25 and, on a smaller scale, at Dagenham Dock and White Hart Triangle. The proposed tolling regime would ensure minimum strategic lorry movements and could enhance a restricted number of local sites for local distribution use. Overall 5.117 TfLs public consultation programme carried out in July 2003 showed the vast majority of local residents supported the bridge, and that a small minority was opposed to its building. Subsequently, there has been criticism of the way in which that consultation was carried out. TGLP members did not register any concern or complaint with TGLP about the adequacy of the consultation process at the time. In fact, at that time, TGLP carried out its own information exercise to supplement the work being done by TfL. TGLPs brochure (a copy of which forms Annex 15 to Document 1752/3/B) outlined TGLPs position on the bridge, and the features, controls and reassurances that TGLP sought. Some 25,000 copies of this brochure were distributed in Greenwich, 40,000 in Bexley, and several thousand more through local authority members of the Partnership on both sides of the river. TGLP had good grounds to believe that the communities they represented would be generally supportive of the proposal, providing the safeguards which were sought were to be delivered. It was accepted, however, that even with all the conditions put forward by TGLP being met all community opposition to the bridge would not be removed. On the other hand, there was the near unanimous business opinion that the bridge would be good for regeneration, and the support of the TUC referred to above. 5.118 There have also been suggestions at the inquiry that further alternatives to the bridge should have been considered. The proposed location for the TGB links areas of deprivation and sites for higher housing densities with those with potential for more jobs. It fits in well with existing infrastructure and developments, with minimal disruption. Although other alignments have been considered in the past, the one proposed has been safeguarded and public knowledge for some time. More detailed examination now of others not considered suitable anyway would only increase blight, and delay the opening of this much needed crossing. 5.119 There has also been criticism of the traffic modelling for the scheme carried out on behalf of TfL. Strategic modelling is needed, but TGLP considers that
167
it is not reasonable to expect any model to predict with total accuracy traffic flows on specific local roads. A healthy scepticism about modelling is justified. That is why TGLP and the Boroughs have always argued for a flexible way of addressing actual traffic demands as they arise. That is now provided through the BCG. 5.120 The TGLP accepts that there will be environmental effects close to any new transport scheme, and appreciates that there would be some adverse consequences from the construction and use of the TGB. Most of those effects would, however, be mitigated by the proposals in the scheme and the safeguards contained in the Boroughs Agreement. That is why the TGLP is a supporter of the scheme. London First 5.121 London First is a business campaign group set up in 1992 to improve and promote London through business leadership. It is funded by 276 companies listed in Appendix 1 of Document 1987/1/A1. Planning policy 5.122 The Thames Gateway has been identified by successive Governments as a national priority for growth and regeneration. This is reflected in RPG9A and the London Plan, and in the establishment of the Development Corporation to facilitate development. 5.123 PPS1 states that sustainable development should be pursued in an integrated way. 5.124 Achieving a coherent vision and delivering regeneration in an integrated way cannot happen unless the areas north and south of the river are brought together, enabling business and residents easily to cross the river. The scheme is therefore critical to this integrated vision. The areas near each end of the bridge currently have fragmented and separate identities. For them to thrive and develop, they need 360 access rather than the 180 access that the river imposes. The current lack of access reduces confidence in the local economies and creates greater exposure to economic risks due to the isolated nature of local markets. The bridge would improve access. Regeneration and accessibility 5.125 West London has more river crossings than East London, and they allow businesses in the west to benefit from largely unencumbered catchment areas both north and south of the river. Increased accessibility also benefits local residents going to employment, shopping, leisure and other activities. The scheme would go some way to helping the five surrounding Boroughs and the east sub region address the imbalance between East and
168
West London. 5.126 Without the improved access provided by the scheme, continued poor access and restricted catchments are likely to make it very difficult for East London to meet the employment and housing growth targets in the London Plan. Large parts of East London have poorer public transport accessibility than West London. The scheme would link public transport on either side of the river, improving access to customers, jobs, skills and labour. 5.127 East London is more deprived than West London, partly as a result of poor accessibility in the east. Accessibility improvements and, critically, the scheme, would start to address those disparities. 5.128 Road transport is important for many elements of Londons economic activity, and the scheme would improve road based accessibility across the river. The lack of capacity of the existing river crossings at Blackwall, Woolwich Ferry and Dartford, and the effects of accidents, roadworks or restrictions to ferry operations are very significant, and make journeys across the river by car or bus very unreliable. Interviews with business decision makers found their view to be that the existing river crossings are insufficient for efficient operation. To them, the scheme is vital in improving efficiency. It would improve business performance by reducing journey times and uncertainty. 5.129 This view is supported by research into business location decision making (Document 1987/1/A1 page 30) which found that among 500 European businesses the importance of transport rose from 17% considering it the most important factor in 1997 to 25% in 2003. Access to labour is also an important factor in such decisions. The highly accessible locations of Westminster and the City are particularly attractive as a business location, and some of the surrounding Boroughs are becoming more popular, but East London, outside the City and Canary Wharf, is not an important location. A further body of research, into reasons for companies moving away from London, found poor transport within London to be the second most important reason after high property costs. 5.130 Demand for additional business premises stimulated by the scheme and the other new Thames river crossings would be likely to arise from businesss response to better accessibility and wider markets, from an increase in new business start ups near the crossings due to increased economic activity there, and from increased inward investment. Regeneration and development 5.131 The opportunity for development arises as accessibility increases land values and supports higher development densities. Table 4b.1 of the London Plan (Document D620, page 177) sets out permissible housing density ranges linked to public transport accessibility, and Plan policies require density to be maximised.
169
5.132 The average density of residential development completed in 2000 to 2003 in the five Boroughs nearest the scheme was 46.8 units per hectare, whereas the corresponding statistic for five Boroughs in West London (Ealing, Hammersmith & Fulham, Hounslow, Richmond and Wandsworth) was 62 units per hectare. East London has been unable to achieve the densities built in the more accessible Boroughs in the west. The increased accessibility provided by the scheme would allow development densities to increase. 5.133 This part of London contains a large amount of Londons strategic industrial land, but vacancy rates here are high and take-up is low. There is excess allocation of employment land in London, and national and regional planning policy seeks its release for mixed use and residential development. Of the 50 hectares to be released each year in London, 35 are in the eastern sub region. The improved accessibility that the scheme would provide would allow business to operate more efficiently, leading to better market performance and improved confidence within the area. 5.134 The office market in the Boroughs surrounding the scheme is poor. This too would be improved by the better accessibility the scheme would bring. 5.135 The three main retail centres in the area Woolwich, Thamesmead and Gallions Reach are under performing. The 360 catchment that the scheme would allow would help address their problems. 5.136 The results of TfLs revised traffic surveys were submitted to the inquiry after London Firsts evidence had been given. The evidence was therefore revised in the light of the new traffic evidence. Whilst the new evidence and the changes to the tolls and the discount area proposed by TfL in response to it would reduce traffic crossing the bridge, and also the regeneration benefits which would flow from the bridge, London First is still strongly of the view that the benefits of the TGB would remain substantial, and would still justify development. The TGB would still be a significant catalyst for regeneration. Views of Members of London First 5.137 A questionnaire was issued in March 2005 to all 276 members of London First, and 209 responded (Document 1987/1/B, Appendix 1). There were two questions: a. To what extent do you support or oppose the building of the Thames Gateway Bridge? to which 197 replied that they support or strongly support the scheme. To what extent would your business benefit or suffer from the building of the Thames Gateway Bridge? to which 168 replied that they expected to benefit or greatly benefit from the scheme.
b.
170
Only one member of London First replied indicating that it opposed the proposed TGB. 5.138 London First interviewed some 14 organisations in preparing their evidence for the inquiry: a. Developer A views the scheme as essential to allow the surrounding area to be developed to its full potential; it would make residential and commercial development more viable and attractive. Developer B proposes a peak-time ferry service from Woolwich Arsenal to Canary Wharf to overcome poor links across the river. The scheme is vital to the development of further phases of the Royal Arsenal site, it would enable people to live in Woolwich and easily access employment in Central London, Canary Wharf and the University of East London. The retail function of Woolwich would be helped by the scheme. This developer would invest more in the area if accessibility was increased. Developer C has commissioned a study that suggests an extra 12,000 jobs would be created in Greenwich if both Crossrail and the scheme were completed. The scheme would give better access for companies south of the river to Canary Wharf, improving their ability to supply goods and services there. The experience of this developer is that as transport links have improved, local employment has soared. Developer D considers the scheme a crucial piece of transport infrastructure for development and regeneration, which would allow businesses to access wider markets. It would increase the speed of take up of Royals Business Park, attract a wider range of potential occupiers and increase development density. Company A would greatly benefit from the scheme, which would ease traffic routeing and which is vital to the companys success. Company B finds the current lack of accessibility to the south side of the river affects its ability to attract and retain staff. The scheme would give access to an additional employment source. Company C employs 350 people and plans to expand. If the scheme did not proceed, then the companys servicing and distribution costs would be unsustainable and it would consider relocating out of East London. The scheme would increase the companys efficiency and access to labour. Company D expects to expand its turnover by a factor of 4 by 2030. It currently employs over 1,425 people. Currently relatively few of its employees live on the opposite (southern) side of the river, but the
171
b.
c.
d.
e.
f.
g.
h.
scheme would facilitate recruitment from that area. It would also improve the accessibility of the companys site to its customers. i. Partnership A is a consortium, some of whose members appeared at the inquiry in support of the scheme or were interviewed as part of London Firsts survey; other members did neither. The partnership agrees that the scheme would be a major catalyst to enhance development. Company E would save operating costs as a result of the scheme. Demand for road space across the river vastly exceeds capacity, and the scheme would relieve congestion and improve flexibility and choice. Company F would be able to access more easily the labour market on the south side of the river if the scheme were opened. Competitive disadvantage due to high distribution costs would be reduced. Developer E considers accessibility important to the development potential of a site. Without the scheme, further speculative development would be unlikely on its site near the southern end of the scheme. Company G supplies goods by road. It currently crosses the river by the Woolwich Ferry (which has very limited capacity) or the Blackwall Tunnel (unpredictable due to accidents and congestion). The scheme would improve its delivery service across the river to North London and its ability to recruit skilled workers who live north of the river. Developer F considers the scheme would improve take up rates due to the increased catchment areas for labour and sales it would allow.
j.
k.
l.
m.
n.
5.139 Six of these member organisations were reapproached to establish their views in the light of TfLs revised traffic evidence. All still felt that the TGB would be essential in assisting regeneration in the Thames Gateway region. Their detailed comments can be found in Appendix B to Document 1987/1/A2. The London Development Agency 5.140 The LDA is a functional body of the GLA with responsibility for coordinating economic development and regeneration across London. It is managed by a Board drawn mainly from the private sector. The Board has authorised the support which the LDA offers to the proposal before the inquiry. 5.141 The LDAs investment priorities are set out in the Mayors Economic Development Strategy (Document D668). The LDA is the largest landowner in the London Thames Gateway, which is the key location of LDA intervention. The Thames Gateway Development and Investment
172
Framework (Appendix 1 to Document 2007/1/A1), published in 2004 by the LDA in partnership with the NHS, the Housing Corporation, TGLP and TfL, set out a vision for sustainable regeneration for the Thames Gateway. 5.142 The LDAs activity in the Thames Gateway includes involvement in sites at Royal Docks, Silvertown and Albert Basin to the north of the Thames and at Royal Arsenal, Woolwich and White Hart Triangle to the south. Regeneration - employment 5.143 Physical infrastructure improvements, although important, form only part of the investment planned or needed in the Thames Gateway. It is necessary to provide support to allow local businesses to prosper, and to make sure that residents have appropriate skills to take advantage of new employment opportunities as they arise. Social infrastructure and community facilities are important, particularly with regard to health and education. The Thames Gateway Development and Investment Framework indicates expenditure of about 3.5 billion on skills training and other measures for the existing population and newcomers to the Thames Gateway. Regeneration - accessibility 5.144 However, improvements to transport infrastructure in the Thames Gateway remain critically important. The economic legacy of shipping and heavy industry has left a transport network that is not suitable for modern regeneration. The limited number of eastern river crossings reduces businesses ability to attract and retain a high quality workforce, and residents access to employment opportunities and local amenities. This is a likely contributory factor to the high levels of deprivation in the Thames Gateway. The area also has the highest number of development sites that currently are not being exploited. The London Plan (Document D620) indicates that improved transport links, training programmes and capacitybuilding initiatives should ensure that development opportunities benefit and assist in regenerating local communities. Transport investment is therefore a key to local regeneration, and should be such as to benefit all modes 5.145 Transport accessibility is at the forefront of developers minds. They share the aspirations of the GLA, London Boroughs and others for sustainable communities, for which access to markets, employees and employment is necessary. The scheme would make these more possible. 5.146 The LDA and developers would do their part to ensure that new developments are as sustainable in transport terms as possible. The scheme would also contribute to sustainable development, allowing people access to more local jobs and encouraging businesses to locate in the Thames Gateway, thus reducing pressures for longer-distance commuting. 5.147 The scheme would increase investor confidence.
173
Without it, the potential
for maximising the potential of sites a clear policy objective of the London Plan (D620, Policy 4B.3) would be much reduced as lower density developments were proposed and employers moved away. 5.148 In the light of the revised traffic evidence which TfL produced to the inquiry after the LDAs evidence had been submitted, the LDA reviewed the evidence it had given. Even with the lower traffic figures over the bridge and the amendments to the proposed tolling arrangements, the LDA considers that the regeneration impact of the TGB would remain significant. The bridge would remain an essential element in a broad package of measures, including but not limited to transport improvements, which is essential in improving accessibility and the attractiveness of the Thames Gateway as a location for employers and employees. The bridge remains important in ensuring the future viability of many sites and in contributing to developer confidence in the area. Mr Stefano Borella 5.149 Mr Borella is a resident of Erith. 5.150 Bexley is currently poorly accessible. The scheme is one among several proposals for river crossings that would benefit Bexley by improving accessibility, attracting investment and increasing employment. The bridge could also provide access to the Olympic Games in 2012. 5.151 There are traffic problems in some parts of Bexley, such as the Queen Street/Bronze Age Way junction in Erith. The scheme would increase traffic in Bexley to a degree, but if sufficient money for appropriate mitigation measures were made available in association with the scheme, then that traffic could be accommodated. Those measures should be implemented before the scheme opened. 5.152 The poor air quality in Bexley is currently an issue, although many of those who complain about it live in households with several vehicles and so contribute disproportionately to air pollution. Air quality issues should be taken into account when the scheme is built. 5.153 On balance, the scheme would bring a net benefit to Bexley, and it should be supported. Written submissions in support of the scheme 5.154 Many of the written representations in support of the TGB proposal make points covered in the cases of the supporters which have been outlined above. To the extent that these points have already been covered in the report, they are not repeated here. 5.155 I deal first with the London
174
Thames
Gateway
Development
Corporation, because they are now one of the local planning authorities in whose area the scheme would be partially carried out. 5.156 The Development Corporation consider that the TGB would be a local crossing of the river, but one which would have an important strategic regenerative role in both stimulating development and supporting proposed growth within the Thames Gateway. Not only would the bridge provide momentum for development in key regeneration nodes such as Stratford and the Lower Lea Valley, East Beckton, Barking town centre, Creekmouth and Riverside, Greenwich Peninsula and areas in Woolwich and Thamesmead, as well as Erith and Belvedere, but it would also be an important support for growth within these areas. 5.157 In Creating Sustainable Communities: Delivering the Thames Gateway, the Government propose capacity for housing and employment growth by the end of 2016 of 40,000 homes and 40,000 jobs respectively within the two strategic development locations to the north of the Thames at Stratford, the Lower Lea and the Royal Docks and at London Riverside. To the south of the river, capacity is identified for a further 25,000 homes by the end of 2016 and 24,000 jobs by the end of 2020, within the strategic development location at Greenwich Peninsula and the Woolwich area. The TGB would both facilitate and be beneficial for the proposed housing growth within the surrounding neighbourhoods. 5.158 The Development Corporation also consider that the TGB would impart fresh impetus for the regeneration of East London by bringing about a major shift in image, substantially improving perceptions of the area. It would provide an opportunity for a landmark, which would raise and reinforce investor confidence in the sub region, attracting investment and revitalising local economic activity. 5.159 Moreover, the Development Corporation believe that, in synergy with necessary associated local social programmes for education, skills and training, the TGB would make a contribution to reducing social exclusion in the surrounding areas. Not only would it increase access to a broad spectrum of social amenities, allowing local communities to benefit from a wider range of education facilities, healthcare services, employment prospects and leisure pursuits, but its construction would enhance the effects of the considerable level of community development projects and programmes for the regeneration of the area. 5.160 The Rt Hon Nick Raynsford, MP for Greenwich and Woolwich, wrote to underline his strong support for the TGB. The Woolwich and Thamesmead areas have suffered disproportionately from economic decline, unemployment and deprivation in recent years. The lack of good transport linkages, particularly between the north and south banks of the Thames, has unquestionably hampered efforts to improve economic prospects and attract inward investment. Mr Raynsford considers that improving opportunities for people in South East London to travel across the river are long overdue. Currently the journey from Thamesmead to Beckton or other
175
locations immediately to the north of the Thames involves a massive detour, either via Dartford or Blackwall, or often a long wait for the ferry at Woolwich. 5.161 Mr Raynsford supports the proposal to combine public and private transport modes on the bridge and to introduce a differential tolling regime to favour residents in the areas adjoining the bridge, while discouraging disproportionate use by other traffic. 5.162 Jon Cruddas, MP for Dagenham, also wrote in support of the proposal. He considers the case against the bridge to be unarguable. 5.163 Dr Howard Stoate, MP for Dartford, makes the point that there are only three places where one can cross the Thames between the North Sea and Tower Bridge. The capacity of the Dartford Crossing is supposed to be 130,000 cars per day, but the number using the Crossing is currently 150,000 per day, and it has regularly risen to 180,000. If 70,000 new homes are to be built in the Thames Gateway area, the strain on the Dartford Crossing will become intolerable. Pollution from these vehicles means that there will be great difficulty in meeting air quality standards in the area around the A282, the tunnel approach road. Currently, traffic is growing at around 3% per year, and the number of HGVs using the Crossing is increasing faster still. 5.164 The TGB would offer the opportunity to remove the local element of this traffic, both cars and HGVs, from the Dartford Crossing. This would then reduce the queues which exist at the moment, with a corresponding increase in the chance of meeting air quality targets in the area. 5.165 The case for the bridge was also supported by Mr Nigel Beard, the former MP for Bexleyheath and Crayford. He echoes Mr Raynsfords point that, at present, residents south of the river are dependent on the Dartford Crossing or the Woolwich Ferry for accessing the north side of the river. This means that a workplace only 32km or so away as the crow flies requires a journey of two hours or more. Such journey times have continually restricted the employment choices for the majority of Bexleys residents. 5.166 Mr Beard contends that the bridge would provide an exceptionally high return of 5 to 1, and that it would generate new jobs at a cost to the public purse of 10,000 per job, rather than the more normal figure in regeneration cases of 12,000. 5.167 Mr Beard considers it essential, however, that the bridge should be primarily a connection for use by local people, to which end he argues that there must be cash available for necessary mitigation measures and a two tier tolling system, with flexibility to allow change as necessary. 5.168 In their written submission, the London Borough of Barking &
176
Dagenham make the point that the whole Thames Gateway area is due to grow in population by the equivalent of a city the size of Leeds. It is inconceivable that such a scale of growth could be accommodated without some new road infrastructure. Although the proposed TGB would not cross directly into the Borough, it would have strongly positive effects on the Borough by increasing accessibility, connecting with other transport networks, and assisting the economy through developing business and skills. 5.169 Barking & Dagenham support the bridge proposal because it is part of a managed package of transport and development, rather than the previous ELRC proposal, which they saw as a stand alone road crossing. Those who claim that the TGB proposal is a stalking horse for an eventual scheme to link the bridge with the A2 are misguided. There is no policy basis for that theory. Any future attempt to turn the route into a motorway would face great public and political opposition, as well as many practical obstacles. 5.170 In the next twenty years, Barking & Dagenham will undergo its biggest transformation since the Borough was first industrialised and urbanised. Its population will increase by some 80,000 people through the development of major sites in Barking Town Centre and Barking Riverside. Barking Riverside is the UKs biggest brownfield regeneration site. New and improved transport infrastructure is central to the realisation of the Boroughs growth in a sustainable way. 5.171 Employment today requires greater flexibility in travel. For Ford, a major employer in Barking & Dagenham within the Thames Gateway, the proportion of workers who work in shifts stands at 80%. This places a great pressure on potential employees being able to travel safely at any time of the day or night if they are to access jobs. The provision of a 24 hour integrated public transport system as part of the TGB would thus significantly enhance the opportunities available to local residents. 5.172 The Boroughs Agreement forms an important part of the arrangements for the TGB. It would enable key features of the project to be continually reviewed and refreshed in the light of actual experience. This would be done in partnership, and with clear political and democratic input and guidance. For that reason, it is to be preferred to the suggestion contained in Document INQ/23 for a fixed overall limit on traffic across the bridge. 5.173 The features of the Boroughs Agreement would give support to local planning authorities in negotiations with developers to insist that proposals accord with the guidance in PPG13, including reduced parking standards and travel plans aimed at encouraging employees and visitors or customers to use public transport. 5.174 Barking & Dagenham also make the point that the delivery of a successful 2012 Olympics is a key priority for the nation and for London. Whilst the TGB is not a component of the baseline transport strategy for the Games,
177
nevertheless it could be delivered in time to make a significant contribution (along with the Thames Gateway Transit network) to the transport facilities serving the Games. What is needed is an expedited positive decision so that delivery of the bridge can be secured for 2012. 5.175 This last point is supported (along with other arguments in favour of the bridge) by Dr C Prodromou of Plumstead. 5.176 The London Borough of Havering also welcome the bridge proposal because they consider that it will improve regeneration opportunities at London Riverside. The Council regard the public transport link across the bridge, linking the ELT and the GWT as particularly important. 5.177 The London Borough of Lewisham essentially support the representations to the inquiry of TGLP. Lewisham has the A2 and the A205 running through the Borough, and the Council would only support the TGB as a bridge for local people and business, not as part of a wider strategic road network. 5.178 Lewisham consider it important that the public transport network is linked not just to the immediately local Boroughs, but to the wider South East London catchment areas represented by the South East London Transport Strategy. Lewisham has a major development site at Convoys Wharf, which is poorly served by public transport, and is keen to see good quality public transport extended to serve both that site and the Thames Gateway as a whole. 5.179 Gallions Housing Association own and manage some 5,500 homes and the majority of the public estate in Thamesmead. They are embarking on a multi million pound regeneration of the area, with investment in social and economic development work as well as improvements to the built environment. 5.180 Thamesmead is a deprived area, in the worst 2% in the UK in the index of education, skills and training deprivation. Residents have more health problems than the national average. The standard mortality rate is above the national average, and 13% of the population is registered disabled. Unemployment is high at 35% within the Associations stock, and 25% of households are single parents. 5.181 The Association consider that Thamesmead has been blighted for years because the area has poor transport links. The majority of local employment opportunities are in manual work. It is no surprise that residents of Thamesmead have low aspirations for their futures. 5.182 The Association believe that the TGB would dramatically improve accessibility and opportunities for people in Thamesmead, especially for children still in the education system.
178
5.183 A dramatic and well designed TGB would also assist in putting Thamesmead on the map. If the bridge is built, the Association would request that Thamesmead should appear as a destination point on the bridge signage and promotion. The Association would also request that TfL consider a review of crossings over Eastern Way to improve pedestrian movement on that road and also the Green Chain walk. 5.184 London Ambulance Service NHS Trust support the bridge proposal because there are currently eight crossings between Tower Bridge and Dartford, but 27 over the same distance from Vauxhall to the M25 in the west. Of the eight crossings in the east, only two are road crossings. The Trust believe that this is severely limiting peoples access to jobs, education and other opportunities. Similar points are made by a number of major private sector employers and developers who are active in the area. The Metropolitan Police Authority are also supportive of the TGB proposals. 5.185 The CBI consider that the project would boost Londons position as a place to do business. Effective transport links are critical for business, and the TGB would play a key role in freeing up the labour market for the new jobs to be created and in enhancing and sustaining the new communities. 5.186 The London Chamber of Commerce and Industry underline the importance of public transport improvements to serve the new residents and the new businesses planned for the area. This will be helped by the DLR extension and by the possible Crossrail project, but the contribution which the TGB would make by linking the ELT and the GWT schemes should not be underestimated. In addition, however, LCCI believe that the TGB would have an important role to play in improving the existing cross river road capacity to the east of London. The weight limit at Tower Bridge and the height and width restrictions that are in operation on both the Rotherhithe and the Blackwall Tunnels and the Woolwich Ferry place restrictions on the type of vehicles which can use them. As a result, the vehicles operated by many businesses are forced to make long detours to cross the river. Moreover, the heavy use of the existing East London river crossings and the frequent overnight shutdowns result in delays and inconvenience which cost London businesses, particularly those located in the East and South of London, many millions of pounds each year. 5.187 Berkeley Homes Ltd support the proposals because of the positive impact they would have on the economic vitality of Greenwich. Another company supporting the bridge proposal is Silvertown Quays Ltd, a significant developer in the area south of the Royal Docks. They believe that the bridge would be a major catalyst to the delivery of higher quality, higher density regeneration. The Company underline, in particular, the importance in their view of the public transport lanes over the bridge, which they regard as essential for the long term sustainability of the local area. Similar views are expressed by the Royal Docks Partnership and by Barratt Homes Ltd, who have been major house builders in the area for more than 20 years, with 14,000 homes completed in East London since 1982.
179
5.188 London International Exhibition Centre plc, the owners of ExCeL, London, the new exhibition and conference centre built on the north bank of the Royal Victoria Dock at Newham, strongly support the case for the TGB. The Centre will receive about 2 million visitors during 2006. Within the site, there are six associated hotels, other leisure uses, dwellings, commercial uses and Londons newest public open space, Royal Victoria Square. It is estimated that ExCeL will have generated 14,000 full time equivalent jobs by the time it is completed. 5.189 ExCeL is one of five major regeneration projects in the Royal Docks which have improved, and continue to improve, the whole economic make up of East London. Over the last ten years, Newham has seen the construction of ExCeL itself, the University of East London and the Royals Business Park, the development of LCY and the initiation of the Silvertown Quays Urban Centre with its International Aquarium. 5.190 The next stage in this process of development in the Thames Gateway is that area to the east of the Royals, the exact site of the TGB. Provision of the bridge would initiate and underwrite the next phase of urban investment and development. 5.191 ExCeL would not have been possible and would not have attracted the necessary investment had there not been a supporting pattern of existing and proposed road and public transport infrastructure. The TGB represents the necessary next step in the continuum of transport improvements. ExCeLs activities would benefit greatly from the construction of the TGB. It would ease traffic routing and open up better access in the eastern half of ExCeLs local zone of influence. 5.192 ExCeL accept that the new bridge should primarily serve local interests. This would be helped by the flexible tolling proposals. Currently, over 60% of visitors to ExCeL arrive by public transport, and the target is for 80% to arrive in that way. For this reason, the emphasis and priority given to providing dedicated public transport lanes on the proposed bridge is supported. 5.193 Although it is noted that a pedestrian route across the bridge is proposed, ExCeL believe that the openness and length of the bridge would militate against pedestrian use. They would prefer to see improvements made to the foot tunnel at Woolwich alongside the bridge investment. 5.194 Much of the traffic to ExCeL travelling north across the bridge would have to follow through to the Winsor Terrace junction before turning back. If it is feasible, ExCeL would prefer a northbound exit from the new road to the A1020 near Gallions Reach. Such a link would also make public transport routes more direct, and therefore more attractive. 5.195 Development Securities plc are the developers of the Royals Business Park close to the proposed northern landing position of the TGB. They
180
consider that a confirmed decision to build the TGB would increase the speed of take up of accommodation on the Business Park; lead to the development of increased densities on the Park, thereby increasing the regeneration impact and the employment created; and improve the business opportunities of occupiers by widening the market place they would be able to address. 5.196 Kesslers International Ltd operate a 24 hour design and manufacturing facility at the International Business Park in the Lower Lea Valley. They currently employ some 350 people. 5.197 Kesslers say that without the TGB their costs of distribution and servicing will be unsustainable from their existing location. They would need to consider relocating outside East London. Those costs would, however, be reduced if the bridge were built. Reliability and operational efficiency would be improved, and the company would plan to expand and create new employment. With the bridge, it would be possible to recruit more staff from south of the river because of the quicker and more reliable journey to work which would result, with the availability of good quality public transport. 5.198 The Canary Wharf Group consider that the bridge is long overdue. They consider that the failure to build the bridge since it was first mooted in 1944 has inhibited the economic regeneration of the area. The same point is made by Mr J H Flynn, who says that the bridge should have been available when Thamesmead was being developed in order to facilitate delivery of building materials. 5.199 There is support from Lord Rogers, as Chief Adviser to the Mayor of London on Architecture and Urbanism, for the hybrid form of the main bridge planning applications. He considers that such an approach not only enables the key design parameters and criteria to be specified, but also allows as much flexibility as possible for the future PFI concessionaire to deliver a project of real design substance. From his experience as a designer and as an adjudicator of international design competitions, he considers that flexibility is an important factor in guaranteeing a high level response from bidders and their design teams, ensuring that creative solutions are found within the constraints set by the client. Lord Rogers suggests that it is essential that concessionaire bidders should be encouraged to submit proposals which improve on the initial design, and the hybrid nature of the planning applications provides a practical and appropriate solution which should deliver a more beautiful bridge.
6. THE CASES OF THE OBJECTORS
181
The material points are: London Borough of Bexley Council Introduction 6.1 Following the submission in 2004 by TfL of the planning application for the scheme, Greenwich Council consulted Bexley Council as a neighbouring local planning authority. Bexley Councils response, made by the Planning Control Committee on 11 November 2004 (Document 1774/1/B, Addition to Appendix 8), was that the Council supports the construction of the Thames Gateway Bridge, but remains concerned about the environmental impact of the traffic levels likely to be generated on the quality of life of residents of the Borough, and on the ability of the Borough road network to continue to function effectively. Therefore, the Council considers that planning permission should not be granted until:i) a full traffic impact assessment in relation to the Bexley road network, with reliable assumptions and traffic figures, has been published; and measures have been agreed and funded to control and mitigate increased traffic flows on residential roads.
ii)
6.2
The Committees resolution went on to suggest certain matters that should be secured by condition or agreement in the event that planning permission was granted. Those related to the need for further traffic modelling in order that an initial group of mitigation measures could be agreed and implemented prior to the opening of the new bridge; for a period of traffic monitoring thereafter with possible further mitigation measures; the involvement of Bexley Council in the setting of tolls; for public transport provision across the new bridge including some to serve Bexley; for the sole use of the proposed public transport lanes to be for public transport vehicles; and for Bexley Council to be consulted on any further applications or submissions relating to the scheme. Bexley Councils objection to the Toll Order is set out in a letter dated 30 September 2004 to the Secretary of State for Transport (Document 1774/1/B Appendix 9), in which concerns are expressed regarding: a. the effectiveness of the maximum toll level then discouraging long distance traffic from using the scheme; proposed in
6.3
b. the mechanism proposed for calculating future tolls, which it is feared would not be sensitive to use of the bridge by non-local traffic or to the traffic impact of the scheme;
182
c. the lack of information regarding the level of discounts for local people and the area to which they would apply; d. the proposal that tolls would be reviewed annually, and not as a result of changed circumstances; and e. the lack of a clear involvement for all the affected local authorities in the setting and reviewing of tolls. 6.4 This objection was repeated and added to by Bexley Councils letter dated 25 January 2006 to the Secretary of Sate for Transport (Document 1774/32). In addition to its previous objection, Bexley Council objected to the proposed modifications to increase the maximum toll as set out in the revised table for paragraph 4(1) (Document TfL/221), because the maxima suggested would be insufficient to manage traffic as intended. The new evidence submitted during the inquiry by the promoters fails to address the balance between the regeneration effects, the economic benefits, the environmental impacts and the financial costs. The tolling regime is not a firm proposal and so is unreliable. Nor can there be confidence that, if the scheme were to proceed, TfL would not decide that other, non-regeneration objectives should prevail. It is difficult to think of any situation where this should be permitted, and it makes a mockery of the planning process.
6.5
Compliance with planning policy in Bexley 6.6 The Development Plan in Bexley includes the UDP, which was adopted in April 2004 (Document TfL/19). Policy G22 expresses support for new and improved river crossings in the Thames Gateway, including in particular new public transport links, subject to measures to minimise adverse traffic and environmental impacts on the Borough. This reflects the similar caveat in paragraph 5.5.9 of RGP9A (1995) (Document D648), current at the time of preparing the UDP. Policy T9 supports the maintenance and improvement of public transport services, including links across the river downstream of Greenwich subject to an environmental impact assessment where appropriate. Policy T6 provides that development will be unacceptable if it would increase traffic on any road so that traffic flows would either newly or continue to exceed the design capacity of the road, unless sufficient improvements to the road are programmed and capable of implementation without environmental, planning or traffic objections. Policy G15 requires the Council to protect or enhance residential areas shown on the Proposals Map (Document 1774/3/A). Policy G18 of the UDP establishes that Bexley Council will manage or improve the Boroughs network of roads in accordance with their function in the hierarchy of roads in the Borough: an example of this is Brampton Road, an unclassified road yet a London Distributor Road providing for through traffic movements and links to more major roads (Document 1774/1/A1, 2.1 and 2.2.1; Document 1774/1/B appendix 2).
183
6.7
The traffic and environmental effects of the scheme have not been properly considered. Many of the roads affected by the scheme pass though residential areas identified on the Proposals Map. The promoters have not demonstrated compliance with Policy T6. Nor is it clear how Policy G15 would be satisfied (Document 1774/3/A, 6.1). Policy 3C.15 of the London Plan (Document D620) requires road schemes in London to comply with a number of criteria set out in paragraph 4.212 above. Where a scheme would worsen conditions when judged against any of those criteria, the scheme should not proceed unless benefits in other areas very substantially outweigh any disbenefits, and unavoidable disbenefits are mitigated. When the TfL Board considered the TGB scheme in March 2004, they were not directed to consider that test. Nor were the Members who considered the main bridge applications at either Greenwich or Newham. The failure to apply the relevant test is at odds with the whole basis of the Development Plan led planning system. In fact, the regeneration benefits of the scheme in Bexley cannot be shown to outweigh its disbenefits in Bexley in the other respects mentioned in the Policy. Bexley Council are also concerned that Policy 3C.2 of the London Plan would be breached, since the road network capacity is not enough to handle the traffic the bridge would generate (Document 1774/3/A/REB).
Existing traffic conditions in Bexley 6.8 The existing highway network to the north of the Thames is highly developed. The A13, A406, A102 and A12 are high capacity routes. South of the river, the quality road network includes the A2016, A206 and the A2, all of which run broadly east/west, and the A205 South Circular orbital route. Eastern Way (A2016) would clearly be a very important route from the bridge; but it is a high maintenance route, which is sinking into the marshes, and is the subject of a bid for expenditure on maintenance in virtually every year. There is also a lack of clearly defined quality north/south roads there; such routes as exist are local single carriageway roads with frequent junctions and passing through busy suburban centres. In Bexley, most of the north-south London Distributor Roads pass through residential areas. Bexley Council monitored traffic levels in the Borough during the period from 1993 to 2001. There was a general increase in east-west traffic, with flows stabilising in more recent years. Traffic between the northern and central parts of the Borough consistently increased, and traffic between central and southern Bexley remained generally stable. TfL has found that, although car and taxi traffic on Londons major roads fell in the period 2000 to 2003, the amount of traffic crossing the outer London boundary (within which is Bexley) continues to increase, although at a lesser rate in recent years; and average motor speeds have fallen for a number of years in Outer London (Document 1774/2/B3). These factors suggest that local roads in Bexley are congested during peak periods. Bexley Council do not seek further highway capacity to meet existing demand, but mitigation measures such as traffic calming must be
184
6.9
6.10
implemented to reduce the schemes adverse impact on congestion and safety. 6.11 Traffic in Brampton Road and Long Lane was surveyed in 2001, and it was found that AM and PM peak flows differed; the PM peak was somewhat more spread out than the AM peak. Therefore the AM and PM peaks cannot be directly transposed; they should be modelled separately. Section 16 of the Traffic Management Act 2004 (Document 1774/17) imposes on the Council a network management duty, and the Council are therefore particularly concerned over the ability of the Boroughs road network to continue to function effectively. The Council had not finalised their traffic management strategy at the time of the inquiry, but wished to encourage traffic to use the most appropriate routes available when travelling in Bexley. Local access roads should not be used by through traffic. Measures to improve traffic flow would be appropriate on the A2016; measures to help bus movement but not necessarily general traffic would be appropriate on Harrow Manorway; and measures to control and calm traffic would be appropriate on other residential roads such as Brampton Road, Heron Hill and the like (Document 1774/49). Such an approach is consistent with the Mayors Transport Strategy (D630, policies 4G.1 and 4G.2).
6.12
Bexley Councils longer term transport proposals 6.13 These include: a. Public transport improvements such as an extension of the GWT via Erith to join the Dartford Fastrack, or better bus services between the Belvedere Employment Area and Erith. Such decisions are made by TfL and neither of these proposals is so far supported. b. The removal of traffic from Bexley village, by building the Bexley bypass. c. Improvement of the A206/A2016 junction at Erith. Traffic model 6.14 The LTS model version 3.21, upon which the TGX model is very reliant, uses highway demand trip patterns based on 1991 London Area Transport Survey (LATS 1991) information. The DMRB (Document D522) advises that where a model is based mainly on data more than about 6 years old then the validation should be carried out on a forecast of the present day; but validation was carried out against the 2001 base year. More modern data, such as those from the 2001 LATS, the 2001 national census and the 1998/2000 National Travel Survey, were not included in LTS 3.21; but nevertheless those data should have been used as comparators with the
185
outputs of the LTS model. 6.15 The LMVR (Document D829) identifies that the update of the TGX to 2001 base year was limited to matrix estimation, whereby modelled flows are adjusted to ensure that the best match between model and observation is achieved. Such an approach cannot account for changes in trip patterns since the now out-of-date LATS 1991 survey. Yet there were major relevant changes in the area between 1996 and 2001, including major development in north Greenwich such as the Dome and the Millennium Village, growth in the working population in Canary Wharf and the Isle of Dogs from 13,000 in 1996 to 55,000 in 2002, the DLR extension to Lewisham and the Jubilee Line extension. All these may have materially changed the travel patterns in the area. Traffic surveys undertaken by third parties in support of recent transport assessments for various development proposals (Document 1774/13) have been compared on a site by site basis with modelled traffic flows from the original Reference Case model prepared by TfL. This process identified some very substantial differences between the modelled flows and the actual flows, sometimes of the order of 200% or 300%. Since the modelled flows form the basis of the assessment of need for future mitigation measures, it is important that the model should be reliable; but it is not, and it does not provide a true picture of the effects of the scheme. TfL subsequently undertook additional traffic surveys and modelling as described in their evidence, producing the revised Cordon model. However, there are serious shortcomings in TfLs Cordon Model. The model that is used to support the scheme should be validated to DMRB standards. The Cordon Model meets the DMRB requirement with regard to convergence, as did the initial model, but it still fails to meet the DMRB requirements in any other respect. The foundation of the modelling is therefore unreliable. Traffic surveys throughout the model area show major discrepancies, and even in the core study area of the Cordon Model, where the results should be best, many significant discrepancies remain. The differences between the forecast and observed flows greatly exceed any explanation based on growth. Positive and negative differences are found, showing the model is a poor predictor of traffic movement even in the base year. This is the case not only in Bexley; although the DMRB seeks a GEH of 5 or less on 85% of individual links, GEH values greater than 10 are produced by the Cordon Model at 27% of the links considered in the Calibration/Validation report for the Re-Based TGX Model. These include sites in Bexley, Dartford, Greenwich, Newham, Redbridge and Tower Hamlets. At 43% of those sites, the modelled flows are less than half the observed flows, and at 8% of the group of sites, the modelled flows are more than twice the observed flows.
6.16
6.17
6.18
6.19
186
6.20
Traffic flows are increasing in Bexley. There has been substantial development in recent years in neighbouring Boroughs and Districts. DfT figures (Document 1774/46, Appendix A) show overall annual traffic flows in Bexley, Greenwich and Kent (excluding the Medway towns) to have grown by 3.93%, 5.86% and 5.40% respectively during the period 2001 to 2004. This is at odds with TfLs evidence that traffic growth in parts of Bexley over the two or three year period ending in 2005 was significantly above the London average. There is no evidence to support the view that the causes of the models unreliability include growth. The use of 2005 traffic survey data as a proxy for 2001 flows means that an element of double counting of growth is introduced, and estimated traffic levels in the 2016 do-minimum case are higher than they would be if accurate 2001 flows had been used. Therefore: a. The estimated proportional increase in traffic due to the scheme in the assessment year will be less than it should be; and b. More junctions will appear to be over capacity in the do-minimum case, and therefore apparently not the responsibility of the promoters to resolve as a consequence of the scheme.
6.21
6.22
The DMRB recommends at least two forecast years one within about two years of the year of opening, and one 15 or perhaps 10 years after opening. Even though there may be difficulty now in modelling conditions in Bexley in 2027 (15 years after opening in 2012), junction performance should be considered over a longer period than is the case for the scheme, as would be done for normal transport assessments. Nationally accepted guidance on transport assessments recommends that the study area should include all locations where traffic to and from the development would exceed 10% of the existing two-way traffic, or 5% in congested or other sensitive locations (DTLR Circular 04/2001, Document INQ/7). Despite this, TfL rely on a figure of 30% as the test of significance other than at the 29 sites surveyed in September 2005. Many roads to the south of the river that would experience such flows are not, as TfL claim, purpose built high capacity roads; rather, many are urban single carriageway distributor roads with residential frontage access, incapable of adequately catering for the projected increase in traffic flows. The network of roads chosen by TfL for comparison purposes and identified by them as strategic does not match any road hierarchy in the London Plan, TfLs business plan, the Boroughs UDPs, the Traffic Management Act or material published by the DfT. The promoters conclusion about the percentage of traffic on strategic roads is therefore built on a false premise. The independent advice given to Newham and Greenwich Councils by Jacobs Babtie, that the general approach and methodology are appropriate, and no obvious errors are detected, is incorrect for the reasons stated in the previous paragraphs.
187
6.23
6.24
6.25
In any event, even if the model was satisfactory, insufficient modelling work has been provided to understand fully the effects of the scheme. With Scheme scenarios should be tested with and without the tolls, with and without the mitigation measures, and with and without both; but these are not all available. For the later stages of individual scheme appraisal, environmental assessment and scheme design, virtually all traffic models meet or nearly meet the DMRB criteria. Whilst it would be difficult for a model to comply with all the DMRB criteria, the local TGX model fails to comply with a significant number of those criteria. The DMRB (Document D522, Vol 12, section 1, Part 1, paragraph 11.1.6) states that To judge a model by its suitability for an intended use requires clear thinking about the intended use. The accuracy of any model, indeed even count data, cannot be expected to represent reality except within a range or tolerance. Moreover, in most cases it is not necessary to go to great lengths to reduce that range and seek greater precision. What is important is to ensure: i) that the degree of accuracy is adequate for the decisions which need to be taken; that the decision makers understand the quality of the information with which they are working; and that they take the inherent uncertainties into account in reaching decisions.
6.26
6.27
ii)
iii)
6.28
It is plain that the accuracy of the Local TGX highway model is not adequate for the decisions to be taken in this case. The TGB is a substantial scheme with widespread effects so it is important that the highest quality model should be used to predict those impacts. The DMRB provides guidelines for calibration and for validation of traffic models. Calibration is the comparison of model data with survey data and takes place during the preparation of the model. Validation is the comparison of data from the finished model with independent survey data. The Reference Case Local TGX highway model meets neither calibration nor validation guidelines. Of the 33 journey time routes, 18 in the AM peak and 24 in the inter-peak have modelled journey times faster than observed journey times, suggesting that the model generally underestimates journey times. The poor reliability of modelled journey times and the non-validation of journey times in the Reference Case traffic model will render unreliable the
188
6.29
6.30
economic assessment of the scheme, resting as it does on travel times throughout the whole modelled area. 6.31 The absence of a PM Peak model means that the mitigation measures cannot properly be modelled. The use of a mirror reversal of the AM peak flows to simulate the PM peak is inadequate where the real conditions do not match that approach. Examples of this in Bexley include the Knee Hill/Bostall Hill junction and the A206 Woolwich Road. The modelling for the scheme is not typical in this respect: of the completed studies cited by the promoters in justification of their approach, the majority carried out modelling for the evening peak as well as the morning and inter-peak periods (1774/45). The issues and errors found in the Reference Case Model are present in the Cordon Model and have not been resolved. The revised traffic forecasts by TfL are still not reliable. In conclusion, with regard to the traffic model: a. The model does not meet the DMRB criteria. b. There is no evidence that relaxation of the DMRB criteria would be acceptable or appropriate in this case. c. The traffic model is poorly calibrated and validated, and is unreliable for forecasting purposes.
6.32
6.33
Regeneration - Accessibility 6.34 On 17 July 2002, Bexley Council resolved to support the construction of four new river crossings: the DLR extension to Woolwich, a bridge or tunnel between Silvertown and the Greenwich peninsula, a heavy rail crossing east of the Greenwich peninsula as an extension of Crossrail, and a shared use TGB at Thamesmead to comprise a local highway link and a public transport connection. The Council considered these projects to be essential for sustainable regeneration and job creation in the north of the Borough and the rest of the Thames Gateway (Document 1774/1/B, App 3). The poor reliability of modelled journey times and the non-validation of journey times in the Reference Case traffic model will render unreliable the case for regeneration, resting as it does on travel times.
6.35
Traffic mitigation 6.36 Mitigation measures proposed to be considered by a local planning authority
189
in association with a development proposal such as the scheme should be sufficiently specific, available and unquestionably effective. But the more sophisticated the measures and the more doubt there is about their efficacy, the more difficult it will be to determine that the effects in question are not likely to be significant. In the case of the scheme, there is insufficient detail to assess the nature of the development, its impact on the environment and any mitigating measures. 6.37 TfL has carried out detailed assessments of the performance of several junctions in the 2016 with-scheme case. For the reasons given, these may be based on false premises. Even if the traffic forecasts are accurate, there are many locations where delays will increase significantly. The following are of specific concern to Bexley Council: a. Pettman Crescent junction is in Greenwich, but likely to affect Bexley. Traffic delays here are modelled to increase, and so traffic is likely to divert on to routes in Bexley. The adoption by TfL of the Western Way route for the GWT, announced during the inquiry (Document TfL/145), will further reduce road capacity at Pettman Crescent and the Thamesmead junction, and is likely to increase traffic further through Bexley resulting from the scheme. b. Traffic delay at the Harrow Manorway/Knee Hill junction would increase substantially, tending to cause traffic to divert to local roads such as New Road and so harm the environment there. c. TfLs suggestion that the congestion predicted by the model at the Brampton Road/King Harolds Way junction as a result of the scheme would be substantially reduced by local re-routeing of local traffic seems to rely on rat-running to reduce delays. This would not be acceptable to residents. Bexley Council seeks mitigation measures to prevent such movements. 6.38 The scheme would increase traffic on the non-strategic road network for which Bexley Council is the local highway authority and traffic authority. Measures to mitigate the traffic effects of the scheme in Bexley were the subject of a series of meetings between TfL and Bexley Council that started in early 2003. The purposes of the measures discussed were to improve access routes to the scheme and to minimise adverse traffic effects of the scheme. Agreement has not been reached. A suggestion was made during the inquiry by the Mayor of London in a letter to Bexley Council that they might consider a congestion charging scheme to mitigate local traffic congestion (Document TfL/112). The Leader of Bexley Council replied that such a proposal would need to be considered carefully, but that his initial view was that such a measure would be counter to the regeneration objective of the scheme (Document 1774/14).
6.39
190
6.40
If TfLs traffic model were to prove accurate and the original proposed discount area were to be operated, traffic mitigation measures would be needed at the Erith roundabout (the junction of several A roads A206, A220 and A2016 - where queues form daily in apparent contradiction of TfLs evidence that the scheme would have no adverse effect here) and the following other locations in Bexley (Document 1774/50): Harrow Manorway Knee Hill/New Road/ Brampton Road Sandgate Road area Brampton Road/Woolwich Road signals South Welling area South Blendon area Avenue Road and Pickford Lane Little Heath Road Picardy Manor Way Bedonwell Road area
Picardy Road/Brook Street area Brampton Road traffic calming Woolwich Rd to King Harolds Way Wendover Way Bexley Lane area Long Lane
Albert Road
6.41
The cost of these works (excluding the Erith roundabout) is estimated at 5.032m, of which 1.626m would be needed for Harrow Manorway. Due to the unsoundness of the traffic model, proposals for mitigation made now may be inappropriate, and the cost of other measures not now identified would therefore fall to be met by Bexley Council. If the money provided by TfL to pay for mitigation measures were limited, then an unacceptable risk would be imposed on the Council. If the scheme were to proceed, then its traffic effects should be monitored so that any further mitigation measures caused by the scheme can be identified and implemented.
6.42
6.43
Combined effect with Crossrail 6.44 Crossrail has recently published a transport assessment for Abbey Wood station, where Crossrail would terminate. This shows that traffic levels would rise significantly on six links near Abbey Wood station as a result of Crossrail: Harrow Manorway, Knee Hill (south), Gayton Road, Felixstowe Road, Knee Hill (north) and McLeod Road (Document TfL/129). The assessment takes no account of traffic from the scheme that would use
191
Harrow Manorway, even though TfL is a co-promoter of Crossrail as well as promoting the scheme and the GWT. Even though Bexley and Greenwich Councils sought one, there is no combined impact assessment for this critical part of the network, a location that will become a major transport node. Tolls 6.45 Bexley Council wrote on 25 January 2006 to the Secretary of State for Transport (Document 1774/32) regarding the Toll Order. Bexley request that the maximum toll for cars, motor cycles and motor caravans should be 10 rather than the 6 for which the Order (with the modifications proposed by the promoters) provides (Document D835 as modified by TfL/214), and that the maximum tolls for other classes should be increased accordingly. It is very important that the maximum toll is set high enough initially, since Section 11(4) of the New Roads and Street Works Act (D210) establishes that a variation or revocation of the Toll Order would require the consent of the concessionaire. This could prevent the Mayor increasing tolls to combat adverse environmental effects if too much traffic uses the new bridge. Errors in TfLs forecasts could require the toll to be set at the maximum proposed by TfL at an early stage, leaving no further flexibility for dealing with exceptional or unforeseen circumstances that may arise. The Boroughs Agreement (Document TfL/22C) should set out the criteria to be taken into account by TfL when fixing the actual tolls to be charged. There are several of these. For the most effective regeneration, tolls should be low; but environmental considerations encourage higher tolls. There should be commitments from TfL to take into account the level of tolls at Dartford and any other crossings, for the express purpose of seeking to minimise the environmental impact of traffic on local roads. Poor modelling might result in the concessionaire not achieving the expected income, in which case TfL might have to make compensation payments; so TfL might feel under pressure to set tolls so as to avoid triggering such payments. It is unclear how conflicts between revenue maximisation and traffic deterrence could be resolved.
6.46
6.47
Tolls - discount area 6.48 During the inquiry, TfL revised its proposal in respect of the toll discount area (Document TfL/202 paragraph 19b). There is no certainty that the reduced discount area would be recommended by the BCG or adopted by the Mayor. Bexley Council oppose the changed proposal because the change would undermine any claim that the scheme is a local bridge designed to promote regeneration. It would exclude more than half of the most deprived areas in Bexley, and would reduce the regeneration benefits across the Borough that improved access to jobs in the growth areas north of the Thames would bring.
192
6.49
Whereas the population of the originally proposed discount area in Bexley was 155,730 (on the basis of the 2001 National Census), that of the finally proposed discount area in Bexley would be only 29,418. The finally proposed area would exclude 5 of the Super Output Areas (SOAs) in Bexley that are among the 20% most deprived in England and Wales, the only SOA in Bexley among the most deprived 10% in England and Wales, and more than half of the SOAs in Bexley that are among the most deprived 30% in England and Wales. This would put residents of those areas at a disadvantage compared with residents of other South London Boroughs in the discount area in terms of access to jobs in the growth areas north of the Thames. Various economic and prosperity indicators suggest that Bexley should not be treated differently from other Boroughs in the discount area. Of the five Boroughs, average incomes in Bexley rank third, the proportion of knowledge workers ranks fourth, average gross weekly earnings are lowest, and Bexley is the only Borough in the group in which average gross weekly earnings were falling in the survey year (2004). Parts of Bexley have been identified as regeneration areas, including the Thames Gateway, an Opportunity Area identified in the London Plan and proposed by the Mayor to be extended, and a Zone of Change as identified by the GLA. These areas of greatest regeneration need in Bexley would be excluded from the toll discount area and so placed at a disadvantage in accessing jobs, training and other opportunities in the growth areas compared to other Boroughs close to the scheme. TfLs regeneration model has been unable to show significant benefits for Bexley. Whilst Bexley Council hopes that there would be regeneration benefits for the Borough as a result of the scheme, the reduction in the proposed discount area would seriously jeopardise that possibility. The southern boundary of the discount area in Bexley ought to align with that in Greenwich to avoid pockets of differential benefit on either side of the Borough boundary.
6.50
6.51
6.52
Public consultation 6.53 No public exhibition in Bexley about the scheme was planned by TfL until Bexley Council asked for one. Bexley Council helped TfL prepare for and conduct the event that followed the Councils request, and prepared and distributed leaflets in advance.
Public transport 6.54 The Boroughs Agreement (Document TfL/22C) should set out a minimum level of public transport provision across the scheme. This should include at least 6 transit buses per hour serving Abbey Wood and local bus services over the proposed bridge to serve Erith, Belvedere and Bexleyheath.
193
Overall 6.55 Bexleys position is therefore that, while the Council support the principle of a TGB crossing, planning permission for this scheme should not be granted. a. The traffic modelling is inadequate to provide any proper or reliable prediction of the effect the bridge would have in Bexley. b. It cannot therefore be said that the necessary mitigation has been adequately determined. c. It cannot be shown that there would be sufficient funding available from the promoters to carry out all necessary mitigation. d. There is no assurance that the level of public transport provision necessary to attract people away from using their cars on the bridge would be available. e. There are substantial doubts over the regeneration benefits likely to occur in Bexley. f. Both TfL and the Boroughs which voted to grant planning permission did so on the basis of a failure properly to apply Policy 3C.15 of the London Plan. g. The objectives put forward for the bridge are mutually incompatible. Regeneration, traffic management, revenue raising and environmental protection pull in opposite directions. h. There is no guarantee that other parts of the claimed package of river crossings (i.e. Crossrail and the Silvertown Link) will take place. i. On the other hand, there is no assessment of the combined impact which Crossrail and the TGB would have in Bexley of both were approved.
j. There is no guarantee that, if the bridge is built and the Boroughs Agreement comes into force, recommendations made by the BCG on the matters within its remit will be followed by TfL.
Response by TfL to the objection of the London Borough of Bexley Council Safeguard regarding network management
194
6.56
Notwithstanding Bexley Councils concern that changed priorities might in the future lead TfL to act in pursuit of other goals than regeneration, the Traffic Management Act 2004 establishes a duty on TfL and other local traffic authorities to secure the expeditious movement of traffic on its own road network and those of other local traffic authorities. In the event that a local traffic authority fails properly to perform this duty, the Secretary of State may appoint a traffic director. Such an intervention order may be made in respect of an individual road, for the reasons set out in document TfL/280, and so a safeguard is provided.
Compliance with planning policy in Bexley 6.57 The scheme complies with Policy 3C.15 of the London Plan as follows: a. It would contribute to Londons economic regeneration and development by improving accessibility, increasing potential jobs by between 34,600 and 53,300 and potential population by between 72,200 and 94,800 (Reference Case Model). b. It would increase total traffic capacity by a small amount, but this would be essential to regeneration. c. Its effect on Londons environment is summarised as a large beneficial effect on landscape and townscape and slight adverse effects on noise, air quality, heritage and historic resources, biodiversity and water. d. It would cause a small increase in road traffic accidents. e. Its effect on road users other than motorists would be to provide a new river crossing for pedestrians, cyclists, disabled people, public transport passengers and goods vehicles. It would increase traffic on some local roads which, in a few locations, would cause some moderate adverse severance effects for pedestrians. f. The scheme is supportive of regenerative land use and transport policies at national, regional and local levels. g. Overall, the worsening of conditions that the scheme would bring about is of a small order, substantially outweighed by the schemes likely contribution to Londons economic regeneration and development, to the enhancements of perceptions of the Thames Gateway and to the achievement of objectives of adopted national, regional and local planning and transport policy. 6.58 Explanatory text in the Bexley UDP (TfL/19, paragraph 4.50), adopted on 28 April 2004, indicates the key importance of the river crossings, including the scheme, to Bexley Council and to their regeneration strategies.
195
Existing traffic conditions in Bexley 6.59 TfL have undertaken a detailed assessment of all the key links in the Bexley road network, and that is incorporated in the Reference Case Model. A survey on 25 February 2005 at the A206/Knee Hill junction found no significant queuing. The traffic monitoring surveys that Bexley Council report show a downward trend for screenline 1 (east-west movement in Bexley), static for screenline 3 (between central and southern Bexley) and upward for screenline 2 (between northern and central Bexley). Traffic in the whole of London increased by less than 1% from 1999 to 2003, and traffic crossing the Greater London boundary increased by only 0.5% between 1999 and 2004. Although there is localised congestion in Bexley, it is not clear to TfL how Bexleys conclusion regarding congestion in the Borough is supported. TfL and the Borough Councils have similar statutory responsibilities concerning network management, and they will therefore be required to work together to ensure all duties are performed regardless of the scheme.
6.60
6.61
Traffic model 6.62 LATS 2001 data were not available in time to be incorporated into the traffic model. However, the patterns of travel in the LTS 2001 matrix used to develop the scheme, those in the TGX local highway model (Reference Case) and the new interim LATS 2001-derived travel matrix have been compared. There are only very small differences between the three matrices. The LTS forecast from 1991 data is therefore an appropriate basis for the TGB analysis. The DMRB regards convergence as the more fundamental characteristic of a traffic model: it is the key to robust economic appraisal (D522 Vol 12 Section 2 Part 1, 4.4.24). The model was principally calibrated rather than validated. This is not uncommon practice in modelling complex urban areas where data availability is limited, with most of the data sources highly correlated rather than independent, as is the case here. The available data has been used to help calibrate the Reference Case Model since that approach improves the robustness of the model. Although the DMRB does not necessarily apply to the scheme since it would not be a trunk road, it is the most appropriate guidance against which to consider the modelling for the scheme. But it is wholly unrealistic to expect, in the complex urban environment of the scheme, that modelling would fully meet the DMRB guidance. A range of traffic models has been unable to comply fully with the DMRB. One such is the M25 NAOMI model, which includes the entire area inside the M25 and for some distance beyond. NAOMI has no screenlines in the AM peak that meet DMRB
196
6.63
6.64
6.65
guidance (whereas the DMRB requires all or nearly all screenlines to do so), only 47% of validation counts achieve a GEH of less than 5 (the DMRB seeks 85%), 25% of validation counts achieve a GEH greater than 10, and the DMRB guidance is not mentioned in assessing many of the relevant results. Yet the NAOMI validation report, for which Bexley Councils expert traffic witness was project manager, states that the NAOMI model would provide a robust model for use at a public inquiry. Appendix W4 in TfL/REB/1774/2 sets out the performance of 20 traffic models at other locations, in which context the TGX model can be judged to have a reasonable performance in the inter-peak case, better than that for the AM peak. In the AM peak, the GEH statistics produced by the Reference Case Model are similar to, or better than, many other studies. 6.66 In the case of the model used for the scheme, figures 1 to 4 of Document TfL/REB/1774/3 show the locations of links on which various GEH values are obtained, and the dates of the traffic surveys. Low and relatively high GEH values appear across the area. The dates of the traffic surveys vary substantially, inevitably making calibration and validation more difficult. TfL does not have the data needed to reduce traffic surveys to a common base year. The advice of the DMRB (D522, Vol 12 Section 2 Part 1 paragraph 4.4.43) is that a model that does not meet the DMRBs acceptability guidelines may still be acceptable for appraisal of a scheme if the discrepancies are within survey accuracies and the larger discrepancies are concentrated away from the area of greatest importance to that scheme. Conversely, a model that passes the guidelines but has significant discrepancies on the most crucial links may be unacceptable. In this regard: a. At many locations close to the scheme, the GEH statistic is very good; but there are also many close to the scheme that are less good. The Cordon Model is better in this respect than the Reference Case Model. b. The most crucial links are the two one-way links at the Dartford Crossing and the two one-way links at the Blackwall Tunnel. 6.68 Traffic growth in Bexley was one of several factors that led to the recalibration of the Reference Case Model to produce the Cordon Model. The use of 2005 traffic counts as a proxy for 2001 data does not, in practice, result in more junctions appearing to be over capacity and therefore not the responsibility of the promoters to resolve as a consequence of the scheme. Nor would the estimated proportional increase in traffic due to the scheme in the assessment year be materially underestimated if, as Bexley Council claim, traffic growth was not great between 2001 and 2005. Ample resources would be available through the Unilateral Undertaking (TfL/22D) to meet the reasonable cost of mitigation works.
6.67
6.69
197
6.70
Document TfL/83 explains how the effects on the network of all traffic changes have been considered, and how a traffic change threshold of less than 5% has been applied. Of the scenarios suggested by Bexley Council as necessary to be modelled, those which are necessary have been provided. Modelling of the type envisaged by Bexley Council is not particularly helpful in developing local traffic calming and mitigation strategies and so is not generally adopted in such cases. There is no PM peak model, and so PM peak flows in the with-scheme case have been modelled by reversing the AM peak forecasts. This appears to be a reasonable approximation of the likely PM peak traffic situation, as illustrated for example by link flows in Brampton Road and Long Lane. Bexley Council made no comment which doubted this approach until 21 April 2005. Other than that the PM peak is longer, no evidence is presented that traffic conditions then are other than a reverse of the AM peak. The absence of a PM peak model is by no means unique to the scheme: ten out of twenty traffic models for projects elsewhere (TfL/REB/1774/2, Appendix W4) include a PM peak and ten do not. Bexley Councils use of the A20 and Greater North London screenlines to judge the validation and reliability of the Reference Case Model is inappropriate, and does not justify the conclusion that the model is unreliable for forecasting purposes.
6.71
6.72
6.73
Regeneration - Accessibility 6.74 Journey times as modelled in the Reference Case Model do not substantially under-state average journey times. In the critical AM peak, only some 55% of journey times are modelled to be faster than observed.
Traffic mitigation 6.75 The scenario modelled by TfL is the most likely. The mitigation measures proposed are appropriate, sufficient and funded. Closer to the opening of the bridge, it would be appropriate to carry out detailed assessments of the operation of junctions and of the scope for ratrunning in some parts of the Bexley road network. Traffic management and calming measures in the northern section of Brampton Road and the Picardy Road area could then be finalised. The TGX highway model is not the most appropriate tool to do this; a pragmatic assessment of local roads using traffic survey information, junction analysis software and detailed road geometry data would be appropriate. This should be done in an awareness of Bexley Councils own proposals for the area. Appropriate measures would then be implemented.
6.76
198
6.77
As to Bexley Councils concerns regarding traffic mitigation: a. The GWT would operate on a fully segregated alignment at Pettman Crescent that, by taking buses out of the junction, would improve conditions for other road users. b. The potential diversion of traffic to local roads such as New Road that may arise from increased delay at the Harrow Manorway/Knee Hill junction is reflected in the model. c. Greater delays at the Brampton Road/King Harolds Way junction might prompt transfer to other east/west routes such as the A206, or additional use by local people of local roads which should not be described as rat-running; such local journeys would choose between local roads on the basis of avoiding problematic locations.
Combined effect with Crossrail 6.78 There has been no assessment of the combined traffic effect of the scheme and Crossrail. The scheme would precede Crossrail, and would address only its own off-site traffic implications. There is a presumption that Crossrail would address the combined effects of both. The Crossrail proposals include a reduction in parking near Abbey Wood station (which would be the eastern terminus of Crossrail) in the expectation that the bulk of passengers expected to use Abbey Wood station would arrive there by bus (on the proposed GWT or otherwise) and that kiss and ride people dropped off at the station by passing cars would also increase there. Crossrail was being promoted by the DfT and TfL through a Parliamentary Bill at the time of the inquiry, and was the subject of various petitions by local authorities among others. Some of those petitions sought an additional station at Woolwich, an extension of Crossrail into Bexley, both of which would alter the likely traffic effect of Crossrail; and an assessment of the combined effects of Crossrail and the TGB.
6.79
Tolls 6.80 The scope for increasing the toll that the proposed Order would provide is designed to give TfL flexibility, including the ability to adjust the actual tolls in response to local traffic conditions. TfL would use the tolls to manage traffic. The concessionaires finances would be unaffected by any change in tolls made by TfL. The BCG would be consulted on TfLs proposals to change the tolls from time to time.
Tolls - discount area 6.81 The key factor in determining the revised tolling proposal was to manage traffic flows within available capacities. The particular constraint was the
199
Bexley screenline and Harrow Manorway. Since very little traffic from outside the originally proposed discount area was expected to approach the Bexley screenline from the south, traffic crossing it could be reduced only by increasing the discounted toll or by reducing the discount area in that part of Bexley. Given the limited nature of the constraint, it is more appropriate to increase the toll for only those living south of the screenline than to introduce a uniform increase for everyone in the discount area. Traffic approaching the screenline from the north can be reduced by increasing the non-discounted tolls. Without raising all (or more) discounted tolls, these two changes are essential to deal with the concerns of congestion across the Bexley screenline. A reduction in regeneration benefit would result, but not one so great as would occur if the generally available discount was reduced instead. Substantially different tolling options would not reduce potential pressure on the Bexley screenline. 6.82 The comparison of Borough-wide averages can be unhelpful when considering deprivation, since that is an issue relating by definition to the relative extreme which is better represented by the IMD. Nevertheless, the revision to the proposed discount area would exclude some areas of deprivation, and some slight fine-tuning of the discount boundary may be appropriate to maximise regeneration benefit from the scheme. The deprived area that the discount area revision would exclude is North End, a part of Bexley with relatively good access to the Dartford Crossing.
Public transport 6.83 Once the scheme was opened, the current bus network would be modified to take advantage of the new route options it would offer. It is envisaged that, in addition to the 20 bus transit movements per hour using the scheme on routes between Barking, Woolwich and Abbey Wood, other destinations would be served by orbital services as demand permits. But detailed planning of bus routes only need be undertaken two years in advance.
Overall 6.84 Despite the support to the TGB given in their UDP, Bexley now seek to defer the grant of planning permission until further modelling has been done, and a solution has been identified which can allow Bexley a discount area running as far south as the A2 without any more traffic using the A2041 corridor through Bexley. Further traffic modelling would cause several years delay to the project, and is entirely inconsistent with Bexleys approach to Crossrail, where the LTS model has also been used, but Bexley is not seeking to delay the scheme on that account. The Councils opposition to any planned reduction in the discount area within their Borough is not rational. They seek to maximise use of the TGB by traffic originating in Bexley, without recognising that the only way to manage the A2041 corridor is either to widen it (which nobody suggests) or to suppress use of it in the peak periods by imposing the standard toll on a wider range of drivers.
200
6.85
The final calculations of the economic benefit to Bexley of the TGB (after the planned tolling revisions) show a range for employment potential from zero to 500 (without Crossrail) or from 2,800 to 4,100 (with Crossrail in place). The range of potential population increase would be from zero to 1,100 (without Crossrail) and from 5,500 to 8,300 (with Crossrail). Regeneration (especially new jobs) outside but accessible from Bexley would also be beneficial to Bexley residents; and employers in Bexley would benefit from the new ability to service and to receive deliveries from markets north of the river across the TGB. The A2041 corridor, the route which has caused most concern to Bexley, is entirely comprised of London Distributor Roads, whose function (according to Policy G18 of the Bexley UDP) is providing through traffic movements and links to the national road network. Knee Hill and Harrow Manorway are classified as A roads. In the Harrow Manorway corridor, the traffic figures for 2016 without the TGB (whether the Reference Case figures or the revised figures) both show that there is a need for measures to address the consequences of growth in traffic, but Bexley produced no proposal to deal with this until the arrival of their Document 1774/50 on 26 April 2006, after their case had been closed. The second part of that Document lists some 1.02m of additional mitigation measures, of which work to the value of 0.2m is already listed in Part 1 of Schedule 3 to the Boroughs Agreement. Under the Unilateral Undertaking (Document TfL/22D), Bexley would be able to press the case for these additional measures. Given that they had not previously been mentioned at the inquiry, however, there was no opportunity for any other party to challenge the necessity for them within the inquiry.
6.86
Objectors Expert Witness - Mr Keith Buchan 6.87 Mr Buchan was called as a witness to give evidence on behalf of an alliance of objectors, but submitted some documents to the inquiry under his own Document number, 4982.
Traffic growth 6.88 Economic growth in Central London and, more locally, in parts of Greenwich, has taken place concurrently with traffic reduction. Therefore further regeneration in the area could be achieved without increased road capacity. The growth in traffic predicted in the area without the TGB would cause Mayoral targets to be exceeded, and such growth is contrary to the thrust of national and local policies on transport, the environment and climate change.
6.89
Compliance with policy 6.90 PPG13 has amongst its key objectives promoting more sustainable transport
201
choices; promoting accessibility to jobs, shopping, leisure facilities by public transport, walking and cycling; and reducing the need to travel, especially by car. While PPG13 accepts that London has its own arrangements for integrating land use and transport, this does not mean that national guidance on transport can be disregarded in London. 6.91 Reducing car travel is an essential component of achieving the Governments target for carbon emissions contained in Document D108 - a reduction of 60% by 2050, with significant progress by 2020. There is an argument that London, because of its comprehensive public transport system and the potential for the expansion of it, should achieve lower targets sooner. The proposed bridge, with its generation of additional traffic, would move London in the opposite direction. Turning to the London Plan, it supports economic growth, but in a sustainable form. The scale and phasing of development designed to achieve economic growth should be integrated with the capacity of the public transport system and accessibility of different locations. Policy 3C.1 provides that public transport capacity should be sufficient to meet the transport requirements of such development. Although it would represent the major piece of infrastructure spending in the local area, the TGB proposal would deliver 94% of its travel benefits to private vehicle users. It would facilitate a significant increase in traffic throughout the local area, while offering no improvement in the competitive advantage of public transport in the areas which it would serve. Significant increases in traffic in the area are envisaged between 2001 and 2016, much of it related to new development. This would be sufficiently car based to cause car journeys to rise by 13.3% in the study area and by 9.7% in the four local Boroughs. To meet the objectives of the London Plan, this increase should instead be met by public transport. Policies in the area for 2016 and beyond should therefore seek to address the failure to achieve objectives, presumably by boosting the use of public transport, walking and cycling relative to car use and by reducing the need to travel. The road element of the TGB would make any such demand management more difficult. The growth in traffic predicted without the bridge also means that the Do Minimum situation used for comparison by the promoters is unrealistic, and should include strong policies to improve public transport without catering for increased road traffic. The journey time comparisons show how public transport would become far more attractive if no road bridge were built. Linking the Areas of Opportunity (such as Thamesmead, Barking & Dagenham) by public transport, as required by Policy 3C.1 of the London Plan, would not be achieved by the bridge proposal. The TGB would do nothing to assist in the continuing move from car to
202
6.92
6.93
6.94
6.95
6.96
6.97
more sustainable modes, and would strongly encourage car use were it not for the tolls proposed to dampen demand. TfL argue that keeping development within the London boundary would make it more likely to be served by sustainable forms of transport; but if attracting such development requires a more road based approach, these sustainability credentials are undermined. Even if some car journeys become shorter, if there are more of them, overall car use would increase. In fact, the evidence is that the TGB would cause car journey lengths to increase. 6.98 Even with substantial tolls, the TGB would consolidate car use rather than deterring it. Using the vehicle occupancy figures produced by the promoters, only 6% to 7% of the car users deterred from using the bridge would transfer to public transport.
Tolls 6.99 In relation to the tolls, the predicted impacts of these: a. would be subject to changes in the level and area of application through commercial or political change. The BCG would only be involved in consultation; they would not have any decision making powers regarding the tolls. b. have not been established by direct market research into the reactions of people who live or would live in the area. c. cannot be modelled in a simple, unified way because of the structure of the transport model used. This is a further reason why a local market study should have been undertaken. d. appear to be sensitive to relatively small changes in discount area and price. 6.100 There is a real concern that, if the TGB were built, it would be used by long distance through traffic, and would quickly lead to pressure to create a high quality road link between the bridge and the A2. This would renew the previous ELRC threat to Oxleas Wood. Even using the promoters figures, there would be a major increase in total north-south traffic flow to the south of the bridge. 6.101 Even with tolls at the new level proposed by TfL and the smaller discount area eventually proposed, the flows on the Cordon to the north of Oxleas Wood show a 33% increase by 2016 (50% in the original model). Oxleas Wood would become very vulnerable if there were any weakening of the toll impact. Traffic growth beyond that predicted by the revised modelling for 2016 would only add to the pressure for such a link to be placed back on the agenda.
203
6.102 The relatively modest changes made to the base year in the new traffic modelling necessitated, in the promoters view, a dramatic change in the proposed discount area and in the level of the toll outside it. This, in turn, resulted in a substantial reduction in the benefit for the scheme in the revised economic analysis. 6.103 In fact, following the new traffic modelling, the revised AM peaks are far closer to the capacity of a single lane in each direction. Only the AM northbound flow would exceed the maximum capacity of a single motorway lane in each direction. Even the AM northbound flows could be accommodated in a single lane by extending the peak beyond an hour. This phenomenon of peak spreading is well known in London. Bus priority could be ensured by providing signal controlled bus gates at the two entry points to the bridge. This possibility has not been examined in detail, but it is mentioned to underline the point that there has been no realistic examination of alternatives. Public transport alternatives 6.104 TfL have alternately claimed that they have modelled public transport alternatives and then that they did not need to do so because the London Plan only mentions a multi-modal bridge, and the TGB could not be made multi-modal without a road for general traffic. 6.105 Multi-modal alternatives which do not include general traffic (especially those based on light or ultra light rail) have not been modelled to develop, and then give a fair assessment of the best possible non road solution to compare to the bridge. They could include rail and limited road access, walking and cycling (even though the last two might not be very attractive). Such an alternative would avoid the threat to Oxleas Wood. 6.106 The position of an alternative rail only crossing, for example further east between Thamesmead and Barking, would differ in its impact from the alternative road points which were considered. This could have significant implications for social inclusion and regeneration. 6.107 TfL have clearly not undertaken a full appraisal of a public transport based scheme (multi-modal or otherwise), and have consistently refused to do so. The lack of assessment of public transport options is not simply a matter of choice. The models being used are not validated for this purpose. 6.108 Without such testing, the current proposal cannot be proven to be the best transport solution for the area, and does not accord with Government guidance contained in WebTag. Without such a properly prepared alternative, TfL could not and did not give an opportunity to Boroughs or to local business to express a preference between a road based option or a public transport based option. 6.109 Where additional travel is being assumed as part of regeneration, a
204
combination of improving public transport relative to the car and creating more self sustaining communities offers the best way forward. This would be in accord with many Government and London policies on sustainable communities, promoting sustainable forms of travel and reducing carbon emissions. 6.110 It cannot be the case that the inquiry is only allowed to look at the scheme proposed by TfL in comparison to doing nothing. In accordance with the requirements of the Treasury Green Book (replicated in the WebTag guidance for transport schemes, an extract from which is contained in Document TfL/173) the inquiry must be able to investigate alternatives in the context of finding the best solution and value for money. This process has not been followed by TfL. This is unfortunate, because there are obvious alternative solutions to the problem of facilitating economic growth while avoiding traffic growth. The Appraisal Summary Table 6.111 A key requirement for scheme appraisal under the WebTag system is the production of an AST, which should be no more than one page long, for each option considered. It should include the option number and description, and provide a clear audit trail for the judgements on impacts contained in the summary statements. 6.112 Mr Buchan criticises the AST for the TGB scheme which, in its final form following the new evidence provided by the promoters in November and December 2005 is set out at Annex 1 of Document TfL/P/04/8. Mr Buchan considers the AST to be too long and too subjective. His criticisms are set out in full in Document 4982/9. The most important aspect of an AST is the base to which the impacts of the scheme are compared. In this case, the only comparison is with a future Do Minimum without public transport and other improvements to tackle the problems of increased traffic pressure in the local area. If the road based TGB is not built, the issue is whether it is reasonable to assume that nothing would be done to improve public transport and to provide local facilities, thereby reducing the need to travel and automatically encouraging walking and cycling, in line with PPG13 and the London Plan. The bridge should be compared with a realistic Do Minimum. 6.113 Mr Buchan argues that TfLs assessments against the following heads of the AST are wrong: a. Greenhouse gases - TfL assess a small increase as neutral, but the Government has a clear target for reducing greenhouse gases to avoid climate change. The AST should state this clearly and objectively. b. Landscape - TfL assess this impact as large beneficial, but the assessment seems to be based on the concept that any large landmark is better than none. There has been no conclusive evidence that any
205
significant contribution would be made to local landscape. c. Biodiversity - TfL assess this as moderately adverse, reduced to slightly adverse with mitigation. In fact, the gross effect should be presented prior to mitigation, the impact of which should be omitted. d. Physical fitness - TfL assess this as slightly beneficial. The statement seems to imply that because it would take so long to cross the proposed bridge on foot or on a bicycle, this would contribute to physical fitness. This is not correct. There is no direct contribution, and, insofar as car use is consolidated, there would be an adverse impact on people who might otherwise have cycled. Thus the impact should be slightly adverse. e. Accidents - TfL provide quantitative information, but should also provide an assessment, which should be either slightly or moderately adverse. f. Security - TfL assess this as slightly beneficial, but improved lighting away from the scheme should not be counted as part of the scheme. Lighting on the bridge is not an improvement unless it replaces a previous ill lit route. g. Reliability - TfL assess this as moderately beneficial, but the assessment should make it clear that it refers only to car use. The issue of public transport reliability is more difficult to assess and, without a comparable AST for a public transport based crossing, this statement is considered to be misleading. h. Land use policy - TfL assess this as strongly beneficial, but consolidating car use and leaving open the possibility of future road expansion does not support policy on sustainable communities, nor does it comply with PPG13 and the London Plan. i. Other Government policies - TfL assess this as broadly neutral, but improvement to choice (education, healthcare and jobs) for non car users would be diminished. The impact would therefore be moderately adverse.
6.114 Together with an AST for major options, WebTag Unit 3.9.3 also states that there should be a full risk analysis. This should have shown the problems of relying on the toll to dampen car demand and the subsequent pressure on local networks and calls for other network links, for instance to the A2. Instead, TfL have claimed that this risk would be eliminated by their ability to set the toll. Toll dependence is in reality a risk factor in its own right. Overall 6.115 At best, the case for the bridge has to be not proven.
206
The Secretary of
State should be advised that the development of a public transport based crossing, without general road traffic, should be tested as an alternative. Without proof that the proposed bridge is essential for regeneration, there is nothing which would very substantially outweigh any disbenefits in relation to the failure to meet the criteria of Policy 3C.15 of the London Plan. That Policy sets a stringent test, and the TGB scheme does not meet it. Response by TfL to the Objectors Expert Witness - Mr Keith Buchan Compliance with policy 6.116 The TGB would contribute to the sustainable development of London by facilitating the regeneration of the Thames Gateway. Mr Buchan may not be convinced of this, but the principal policy makers and economic agents whose actions will determine the regeneration outcomes (the Government, the Mayor of London, the London Boroughs concerned (with the partial exception of Bexley), business organisations, and developers) all consider that the TGB would assist regeneration. 6.117 It is accepted that PPG13 gives strong emphasis to promoting sustainable travel and the benefits of reducing the need to travel by car, but the TGB proposal is part of a major package of proposed transport investment for East London that is weighted heavily towards public transport. It also forms an element of the integrated policies of the London Plan, which will help reduce the need to travel by car, in particular by encouraging higher density development at locations well served by public transport. Alongside this, TfL consider that it is appropriate to make some provision for cars, and also for freight and servicing vehicles. After all, paragraph 5 of PPG13 recognises that the car will continue to have an important part to play; and the Government continues to promote and approve major road schemes. A recent example is the new Tyne Tunnel, which does not include any dedicated public transport provision. 6.118 The new Tyne Crossing will have 10% of trips by public transport. This is well below the 18% public transport share estimated for the TGB, let alone the 50% share for public transport crossings in the wider Thames Gateway area if the DLR Woolwich extension currently under construction is taken into account. 6.119 In light of the high priority attached in Government policy to regeneration in the Thames Gateway and the TGBs focus on increasing accessibility rather than simply capacity, the arguments for the TGB being in accord with Government policy objectives for sustainability, and in particular PPG13 appear to be stronger than those for the new Tyne Crossing. 6.120 TfL consider that the TGB is a case where a new road would support sustainability at the strategic level, by facilitating the development of East London and the accommodation of Londons growth within its boundaries
207
without encroaching on either the Green Belt or other open spaces. Whilst the TGB would cause some relatively minor local environmental disbenefits, TfL have proposed appropriate mitigation measures to address these. 6.121 TfL accept that PPG13 contains guidance which is relevant in London. The PPG recognises, however, that London has its own arrangements for ensuring the sustainable integration of land use and transport policy through the Mayors Strategies. The issue is not one of London being inconsistent with national policies, but rather of London having a definitive regional interpretation and application of national policies once the Mayors Strategies have been adopted. 6.122 The Secretary of State considered the London Plan as a whole, including its policy on the TGB, to be consistent with national policy. That is why the ODPM did not direct any amendment to the London Plan before adoption, as shown by the letter contained in Annex 2 to Document TfL/REB/4982/1. Traffic growth 6.123 Mr Buchan suggests that there are obvious alternatives for facilitating economic growth while avoiding traffic growth. TfL disagree. If regeneration is successful in the Thames Gateway, it will inevitably mean significant numbers of additional homes and jobs, and, with these, additional travel. TfL agree that there should be an aim substantially to increase the overall share of public transport compared to today; but this would be the outcome in the present case, both with TGB and without TGB. In both of those scenarios, public transport use in the local Boroughs is forecast to grow at more than three times the rate of car use. It is unrealistic, however, to expect all of the travel generated by new households and businesses in the area to be served solely by public transport. Appropriate provision for cars and business vehicles is justified in order to assist regeneration. 6.124 Certainly the TGB would provide additional road capacity across the river, but, because there would be no significant increase in capacity at either end of the TGB, the schemes major highway network impacts consist of improving overall connectivity and accessibility by joining up the existing networks on either side of the river rather than increasing overall network capacity. 6.125 It is not the case (as Mr Buchan argues) that the bridge proposal is inconsistent with traffic reduction targets contained in the Mayors Transport Strategy and the London Plan. Those targets are to keep traffic growth to no more than 4% in Inner East London or 6% in Outer East London from 2001 to 2011. TfLs projection of a 9.7% increase in traffic in the four local Boroughs from 2001 to 2016 is therefore broadly compatible with the Mayoral targets. 6.126 TfL agree that carbon reduction is an important objective. The TGB would
208
contribute by supporting a more sustainable pattern of development by helping to avoid the dispersal of Londons growth to areas beyond its boundaries where it is likely to generate higher car use. The Do Minimum assessment already includes a significant number of public transport schemes, and shows public transport use increasing by 35% compared to an assumption of only a 10% increase in car use despite growth in population. Tolls 6.127 There is no logical basis for the concern that long distance through traffic would use the bridge in substantial numbers, causing environmental or congestion problems. Trips which do not have at least one end in the local area would gain little or no time saving from the bridge, as well as facing higher tolls. For trips starting and finishing at a significant distance from the bridge, alternative river crossings would normally be faster to access than the TGB. If, contrary to TfLs expectations, use of the TGB by long distance traffic were to be higher than projected, then the level of tolls could be increased to address this. 6.128 Mr Buchan suggests that the London Plan and Transport Strategy policies supporting a multi-modal TGB could be interpreted as referring to public transport, walking and cycling provision only, with no provision for general traffic; and that there is no specific reference to a road. Taking the strategies as a whole, TfL do not consider that this view can be justified. Paragraph 5.58 of the London Plan refers to improving access by road. In paragraph 3.195 the need to improve access for people, goods and services across the Thames is stated to be a key priority. Paragraph 4Q.28 of the Transport Strategy refers to road crossings (that is the TGB and the Silvertown Crossing) and states that they will provide an improved level of access for road based modes. Moreover, the objections raised during consultation on the Transport Strategy and during the EIP on the London Plan by those against a TGB road crossing also make it clear that the general understanding throughout has been that references to the TGB incorporate both general traffic and public transport provision. The alleged threat to Oxleas Wood 6.129 Mr Buchan contends that increased traffic would increase pressure for a new north-south link from the TGB to the A2. He recognises that increased traffic would arise with or without the TGB. The fact is, however, that overall the TGB is predicted to reduce traffic between the north of Bexley and Greenwich and the A2. Currently many residents of areas such as Thamesmead, Abbey Wood and Bexley have little choice but to travel through the A2/Gateway Bridge corridor to reach employment and other services. With the TGB, other employment opportunities would be opened up across the Thames, and, as a consequence, overall traffic levels towards the south of the A2/Gateway Bridge corridor generally reduce. Even if TfL are wrong in their estimation on this point, the flexible tolling arrangements are designed to enable traffic levels to be controlled.
209
6.130 Additionally, there is no justification whatsoever in the Development Plan for an Oxleas Wood link. Such a route would not comply with Policy 3C.15 of the London Plan, and it is explicitly ruled out by the proposed modification to the text of Policy M13 of the emerging Greenwich UDP. Safeguarding for the Oxleas Wood link has long ago been removed, and property acquired to allow the route to be built has been sold. 6.131 Mr Buchan believes that specific research on values of time should have been undertaken, but he ignores the difficulty of doing so in an area of ongoing development, with even more dramatic changes in prospect. 6.132 It is entirely accepted that the proposed BCG would be, as its name makes clear, a consultative body. The eventual decision on issues coming before the BCG would be taken by TfL, notably in relation to the level of tolls. But TfL must explain their reasons for not following any recommendation of the BCG. They must operate within the requirements of the GLAA 1999 and the Traffic Management Act 2004. TfL must also act reasonably, and would be open to legal challenge if they did not do so. Public transport alternatives 6.133 As regards consideration of alternatives, in terms of Annex C to PPG13, the TGB is a proposal for a local road of sub regional significance, and it is necessary to look to the regional and planning strategy documents for the establishment of its priority, as required by paragraph 7 of PPG13. The TGB crossing was considered in RPG9A (Document D648), the Inter Regional Planning Statement (Document TfL/20), the Mayors Transport Strategy (Document D630) and the London Plan (Document D620). 6.134 In terms of the WebTag guidance, there is no requirement to consider alternatives unless they meet the local objectives for the scheme. A bridge with no road or with public transport only provision would not have done so. That is because the objective of the TGB was formulated in RPG9A as long ago as 1994, to include enhanced accessibility for road based business traffic. A multi-modal TGB was the subject of public consultation in 1995 (reported in Document TfL/180). Document TfL/185 sets out the history of the consideration of alternatives through a significant number of studies between the Governments decision to abandon ELRC and their announcement in December 1998 that the decision on the proposed river crossings would be left to the Mayor of London. Following further studies and consultation, which included consideration of alternatives, the draft Mayors Transport Strategy was published and the subject of consultation. 6.135 It would have been wholly inappropriate at any stage following the publication of the Mayors Transport Strategy in 2001 for TfL to have embarked on a full scale assessment of alternatives. Alternatives without a road element would not have complied with Policy 4Q.28 of the Transport Strategy to provide an improved level of access to the London Thames Gateway area for road based modes. Once the TGB was included in the
210
adopted Mayors Transport Strategy, it became TfLs duty to promote it. 6.136 It would be the very opposite of sound planning to consult on and approve a policy to build one thing, and then, at the implementation stage, to reconsult on the underlying approved policy because there might be some previously undiscovered merit in building something different. It reverses the statutory presumption in favour of the Development Plan . 6.137 TfL have, however, considered alternative options for the bridge suggested by Mr Buchan, and ASTs relating to those options are contained in Annex 5 to Document TfL/REB/4982/1. TfL conclude that the TGB proposal is clearly preferable to the alternatives suggested. Some potential alternative options are not worth analysing in detail because of obvious funding or value for money difficulties. There are many good schemes across London competing for TfLs limited funds, so alternatives to the TGB intended to serve a similar purpose but requiring very much greater resources from TfL would be unlikely to be funded for the foreseeable future. 6.138 A public transport only crossing in place of the proposed TGB would be less beneficial than the TGB because the public transport crossings recently completed (Jubilee Line and Woolwich DLR) reduce the need for further dedicated public transport only crossings. There would be, in any event, a public transport provision within the TGB, which would be fully integrated into the wider public transport network. A public transport only TGB would offer no benefit to commercial users. Nor would it offer the opportunity to gain the financial contribution from tolls which is necessary to meet the cost of the TGB. A public transport only crossing would therefore have higher net costs relative to benefits, and would be very unlikely to be fundable. 6.139 Because the TGB would be largely funded through its own toll revenues and earmarked Government PFI support, a decision not to approve the TGB would not release resources to take forward alternative projects to support transport and regeneration. The Appraisal Summary Table 6.140 TfL respond to Mr Buchans revised AST for the scheme (contained in Document 4982/9) in Document TfL/329. a. Greenhouse gases - The AST sets out clearly the effects of the scheme. Mr Buchans interpretation of Government targets is inappropriate, because they do not apply on a project by project basis. b. Landscape - TfL stand by their assessment, the basis for which is clearly set out in the AST. c. Biodiversity - The AST shows the effects of the scheme, and the mitigation works are an essential part of the scheme.
211
d. Physical fitness - The intention was not to suggest that the length of the cycling route was the reason for improved fitness. The bridge would connect a number of attractive routes for cyclists, and therefore encourage cycling. Similarly, it would connect attractive routes for leisure walkers. An assessment of slightly beneficial is therefore justified. e. Accidents - It is accepted that the overall assessment of slightly adverse should have been included. f. Security - The improvement of lighting along Royal Docks Road and the Thames footpath are integral to the scheme, and it is therefore appropriate that they should be included in the AST. g. Reliability - The new cross river public transport services would benefit from exclusive lanes, and would link into priority routes as part of the GWT and ELT schemes. Bus priority would assist in ensuring high reliability. h. Land use policy - Support for the TGB is clearly expressed in the land use and transport policies both locally and regionally. The TGB does not include any proposal for future road building. The support that the TGB would give to the policy of accommodating Londons growth within London has clear benefits in promoting lower car use. i. Other Government policies - Non car owners would have improved access across the river through the availability of new public transport links.
6.141 As regards risk analysis, WebTag Unit 3.9 relates specifically to Major Scheme Approval in Local Transport Plans. It does not therefore apply to the TGB. Objectors Expert Witness - Professor Phil Goodwin 6.142 Professor Goodwin was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4985.
Modelling - implications of TfLs modelling 6.143 TfLs forecasts and appraisal, if assumed to be entirely correct, find that in 2016 there will be very serious traffic problems, so widespread as to be ubiquitous.
212
6.144 The scheme would increase traffic by between 1% and 16% at the level of Borough averages. The scheme would shorten journey paths, facilitate and encourage private car use and increase the average length of trips. Taken together with other causes of traffic increases between 2001 and 2016, the scheme would cause a median traffic growth of 35% in 75% of the 270 named streets for which data were provided by TfL. In 10% of the streets, traffic would more than double. A further analysis by TfL of over 1,500 streets found over 75% of them to have traffic increases from 2001 to 2016 with the bridge, with 600 to 700 of those streets having a traffic increase of more than 25%. 6.145 As an example, Lakedale Road in Plumstead would experience traffic growth of 63% (to 12,859 vehicles per day) from 2001 to 2016 with the scheme, or 83% without it. That is daunting, particularly in view of the use of the street by pedestrians; but TfL comment that the increased traffic would be well within the capacity of the road, and not daunting at all. There would be many such streets. 6.146 Conversely, there are some streets which the forecasts predict would have had an increase in traffic without the bridge and would have a reduction in traffic with the bridge. But there are fewer of these, and the size of the change is also smaller. Overall, a large number of streets would have a large increase in traffic while a smaller number of streets would have a smaller reduction. 6.147 Correspondingly, the traffic speeds forecast for 2016, even with the scheme, are systematically lower than on 2001 in every Borough, on most streets, and for the area as a whole. Travel in 2016 would be slower than it is now, and would continue to worsen, according to the promoter, at least until 2021. 6.148 In that case, the question is, what happens to travel times? If TfLs forecasts are correct, the travel time per kilometre travelled in the simulated area in 2016 with the bridge would be 5 seconds shorter than that in 2016 without the bridge; and with the bridge in 2016 the travel time would be 17 seconds longer per kilometre compared with conditions in 2001. 6.149 If the bridge attracts population and generates jobs that would not otherwise exist, and if the traffic associated with those people and jobs is therefore attributed as an effect of the bridge, the effect on the scheme appraisal would be large. If the development associated with the bridge gives rise to 20% of the total traffic growth (as TfL say) then that proportion of the traffic growth should be attributed to the effect of the bridge and not, as TfL have, to the base forecast. This would reduce the 2016 do-minimum traffic levels and increase the effect of the bridge. In that case the estimated traffic effect of the bridge is increased by 80% overall, and by over 100% in Bexley.
213
6.150 Document TfL/49 extends TfLs traffic projections from 2016 to 2021, by an increase of 0.8% in traffic each year. This is equivalent to 4.1% over the 5year period. 6.151 Therefore traffic speeds in 2021 would be slower than those in 2016. By 2021, the overall traffic conditions in the with case would be as bad as the without case was in 2016. Such relief as is offered by the scheme would be lost in the first five years of the appraisal period. This is an inconsistency in TfLs evidence, which lacks sufficient detail to draw further conclusions. 6.152 In summary, if TfLs forecasts are accurate, they show that the traffic problems in the four Boroughs nearest the scheme in 2016 without the bridge will be substantially worse than today. Many streets are not capable of coping with such traffic. The bridge is expected to exacerbate that traffic growth. Modelling - claimed benefits 6.153 Less than half of one per cent of all journeys to work in the Thames Gateway would use the bridge. The promoters definition of a local trip one that only has one end of a journey in the area confuses understanding. The pattern of use would not consist primarily of local residents travelling to local work across the bridge; a large majority of commuters using the bridge would either be people coming in from outside the four local Boroughs, or those living in the area but now travelling further away for employment. Even considering trips with both ends in the area, the majority would consist of almost equal numbers of north Londoners travelling south to work, and south Londoners travelling north to work. About 800 net extra people would commute from south to north, while both living and working in the four Boroughs. While receiving a significant benefit individually, this group is too small to contribute materially to the overall benefit associated with the scheme. 6.154 The overwhelming majority of the calculated benefits would be received by people who either do not live in the area, or do not work in it, or are making car journeys which are largely not for work, and even then not staying in it. The balance of benefit to car users is such that the scheme would result in a significant shift from public transport, walking and cycling, to car use. 6.155 TfLs figures show that car and goods vehicle users would receive 94% of the benefits of the scheme, and public transport users only 6%. Each car user would receive a much greater benefit than each public transport user, although the exact amount is not clear. 6.156 Most of the asserted benefits would be enjoyed by car users including a great number who actually run against the intentions of regeneration car commuters from further away taking the local jobs, local residents taking their money out of the area by doing their shopping further away and
214
some who are less important such as people driving for leisure visits and so on. 6.157 While it is true that benefits to people making such trips are equally valuable to local travel to work trips in cost benefit terms, with the best will in the world they do not play the same role where the objective is regeneration. But if they were not included, then there would be too few intended beneficiaries to justify the project. 6.158 The proportion of the total benefit that accrues to local commuters is 6.5%. The proportion of the total benefit that accrues elsewhere is 93.5%. Thus, less than 10% of the estimated benefits of the bridge are expected to accrue to journeys to work by local residents. Modelling and the effect of transport policy 6.159 There are many reasons why the forecasts provided by TfL are unlikely to be correct, some of which relate to the problems of forecasting generally such as differences in economic growth, migration, birth rate, structure of employment or fuel availability. Others relate to the model itself and the differences between the outputs of the Reference Case Model and observed traffic flows in 2001. 6.160 All these reduce confidence in the appraisal. They are also mostly of a form that underestimates the range and complexity of behavioural responses to changes in travel conditions. This tends to overestimate the benefits of increasing capacity and the costs of reducing it. 6.161 One of the most important weaknesses in the model is its poor relationship with local and national Government policy. 6.162 Various policies are in place to reduce traffic levels, and these have produced limited but significant successes. The period from 2001 to 2005 is already on a track distinctly different from the forecasts for 2016; traffic is lower than predicted. If this trend continued, then congestion in 2016 would be lower than predicted by TfL, in which case the schemes forecast benefits would not be achieved. 6.163 TfL forecast AM peak traffic growth of 13% from 2001 to 2016; around 1% each year. TfL say that would be similar to growth in recent years. But in cross-examination TfLs witness said that there had not been significant traffic growth in London as a whole in the period since 2001. 6.164 Traffic reduction targets are important and practical, and they are starting to have an effect. But the model ignores them and the cumulative effect they might have. Therefore it is founded on erroneous views of traffic. TfL assert that, if congestion is worse than its forecasts, the scheme benefits would be greater. Although not necessarily true, if that were the case then
215
it would follow that if congestion is less than TfL forecasts, the scheme benefits would be less. 6.165 Although the traffic figures without the scheme are almost certainly exaggerated, those with the scheme will include an underestimation of the traffic induced by the bridge itself. The benefits it can offer will therefore be less than shown in the assessment. The combined effect is that the forecasts exaggerate initial traffic growth, underestimate induced traffic, and so exaggerate the benefits twice by an unrealistically bad view of the alternative, and by an unrealistically good picture of the bridge. These effects are substantial and short term, applying to the 2016 assessment year. 6.166 TfL argue that, in the absence of a scenario of committed schemes that would give some certainty to the basis for a different year forecast, this should not be the base case. Yet elsewhere, TfL lead the debate on the consideration of the effectiveness of other methods of solving traffic problems than building more roads. This does not rely on committed schemes; rather, it addresses the general policy context within which specific schemes should be considered. The absence of any consideration of reduced traffic growth is a fundamental flaw in TfLs case. 6.167 If, as a result of implementing traffic reduction policies, private car traffic reduced or reversed over the next few generations, then traffic congestion would be less, there would be fewer users of the bridge, and its benefits would be smaller. If such policies are not implemented or prove ineffective, then continued increases in incomes, car ownership and the value of time would lead to growing traffic: tolls on the bridge would need to increase faster than the assumed rate to deter long distance traffic, but congestion on the surrounding network would still get worse, eroding the benefits of the road infrastructure. Even if all London except the four Boroughs nearest the bridge introduced traffic reduction measures, the advantage of using other crossings would increase and the benefit of using the scheme would decrease over time. 6.168 Therefore in each instance departure from the assumptions in the appraisal weakens the case for the scheme. This means that the assumptions are not conservative, and the case is not robust. Tolls provide only a limited tool to resolve this, and one that is likely to alter the financial risk and compromise the proposed funding arrangement. 6.169 There is a sound body of relevant research, commissioned by DfT, TfL and others in recent years, that finds that a combination of pricing, re-allocation of road space and the so-called soft measures has already been started; it has the potential for making reductions in traffic levels of up to about 30%. Hence the more modest traffic reduction targets adopted by TfL (and which TfL are now pressing London Borough Councils to implement) are entirely realistic. Evidence suggests that these policies can have speedy and positive effects more quickly than the scheme could be implemented; in which case the basic case for the scheme would have disappeared before it
216
was even open. Modelling - Cost benefit Analysis 6.170 The scheme appraisal is further seriously flawed by its calculation of Net Present Value (NPV) for cost benefit analysis. The assumption is made that for the following 30 or 60 years incomes will increase but, nevertheless, car ownership and travel behaviour will not change. The time savings from the bridge would be repeated unchanged year after year, but their value would grow. This produces a huge estimated benefit:cost ratio, far in excess of usual experience. Although DfT guidelines allow such a forecast to be made, it should be only as a sensitivity test, and only after considering the factors that might make traffic and benefits grow or decline in the longer term; and there has been no such analysis. The DfT has not approved the method used by TfL; its practice is to consider the future profile of congestion. 6.171 Nobody has any idea of how to forecast traffic flows 60 years into the future, and so a NPV for the scheme cannot be calculated on that basis. Instead, TfL has assumed that the benefits calculated with the 2021 figures will be replicated, endlessly, unchanged. 6.172 This is misleading. Normally, future benefits are discounted so that they count less and less as we go into the future. But the value of time is expected to rise every year in the future, because incomes are expected to rise, and so a 5 second time saving in 2050 is modelled to be worth more than the same saving now. If incomes increase, then car ownership and car use will rise unless impeded by very strong policy intervention; but the model ignores that. The assumption that incomes are expected to increase is therefore perverse and internally inconsistent. 6.173 TfL justify their approach by reference to WebTag (D524). But the WebTag guidance considers the zero growth assumption to be a sensitivity test, to be applied after a more thoughtful consideration of what is really expected to happen in terms of an increase or reduction in benefits over time. TfL use it as their only appraisal. Modelling - Central London Congestion Charge 6.174 The model does not treat the pattern of origins and destinations as fixed when costs or other changes affect the relative attractiveness of travelling to different destinations. Therefore the inclusion in the model of a congestion charge of 8 rather than 5 would show large changes in traffic flow on a surprisingly large number of links, at greater distance from Central London than at first seems obvious. However, the congestion charge error would not on its own be sufficient reason for withholding approval of the scheme. Modelling - robustness of the model
217
6.175 It is worthwhile to consider the implications of different degrees of traffic sensitivity to the level of toll than assumed by TfL. 6.176 There are reasons to consider traffic might be more sensitive to tolls than TfL assume: a. Traffic models of the sort used here tend to underestimate the range of responses to conditions price, speed, reliability or anything else. This was found in the case of the Congestion Charge in Central London, where fewer charged vehicles enter the charging zone than was forecast. b. Recent research (Document 4985/1/A1/2, paragraph 112) suggests that values of travel time are skewed so that the proportion of the market prepared to pay a toll of a given value is less than suggested by consideration of the mean value of travel time. In that case, the proposed tolls would deter more traffic from using the bridge than TfLs model suggests, and the revenue would be less. 6.177 If sensitivity to the toll is high, there might be no toll level that would be consistent with the traffic forecasts and be financially viable. The tolls would need to provide sufficient income for the operator to cover costs and make a profit, to regulate traffic levels, to remain within statutory limits, to be consistent with London transport policy and to avoid any contingent liability on public funds if the company fails due to incompatibilities in the first four factors listed here. If the sensitivity of traffic volumes to the toll was higher than assumed, or traffic demand was less, then it would not be possible to draw up an agreement that would be reliable in all these respects. The viability of the funding arrangement would be compromised. 6.178 On the other hand, traffic might less sensitive to the toll than TfL assume. TfL consider the originally proposed toll sufficient to deter all the longer distance traffic, but the time saving that would be achieved by many users of the scheme would make a toll of even 5 worth paying. If road user charging becomes more widespread and the time savings are actually delivered, then too much traffic might use the bridge unless the toll were set so high as to be socially unacceptable, or in breach of the proposed formula, or both. 6.179 If TfLs assessment is exactly right then the use of the toll to control the level and type of traffic and to deliver a financial return is viable. But if it is not, then the transport and financial appraisals are not robust. 6.180 The evidence introduced by TfL in November and December 2005 clearly shows this lack of robustness: an apparently minor change in the base assumptions for the appraisal causes a disproportionately large reduction in the estimated benefit of the scheme. Furthermore, the scale of traffic increases shown in TfLs new evidence raises the probability that wider policy action should and would be taken before the scheme opened, which
218
would change the economic appraisal and reduce the apparent benefits. 6.181 The changes made in TfLs new evidence reduce the estimated NPV by 33%, in both the 30-year and the 60-year appraisals and reduce the cost benefit ratio from 5.9 to 4.2 in the 30 year case, or from 8.3 to 5.9 in the 60 year case; reductions each of 29%. 6.182 If the new forecasts are correct, then these new figures show a very substantial magnification from cause to effect. They arose from a review of traffic levels in one relatively small area, quite a long way from the bridge, five years previously. This affected the traffic forecasts, and so the forecast congestion, and so the tolls, and so the number and pattern of users. 6.183 As a result, peak charges on the bridge would be increased by 50%, residents of the affected area of Bexley would pay a 200% increase, and a third of all the estimated benefits would have disappeared. 6.184 Currently, nobody knows if there are other errors in TfLs assessment at locations outside Bexley. If there are, this would become apparent over the next few years and further changes, such as further withdrawals of the toll discount, would have to be made. Such a change has already caused a large reduction in the scheme benefits; if there were only one or two more changes of a similar scale, little or no benefit would be left. 6.185 A project that can lose a third of its estimated benefits as the result of one very small retrospective change in the starting assumptions five years ago may still be justified, but it is not robust. 6.186 It is now not the case that the benefit:cost ratio is still high enough to go ahead confidently: there cannot be confidence. It has been shown that the forecasting, policy assumptions and appraisal method, even if absolutely impeccable, are disproportionately sensitive to small errors. But there were very big errors in the original traffic model that TfL have sought to rectify, and that has also contributed to the changes in the forecasts. 6.187 Since the headroom of benefit is less, the size of other threats to that headroom needs be less in order to bring it down to zero or to 2.1. 6.188 Forty-two per cent of the present revenue value of the scheme is forecast and, because TfL did not know how to forecast beyond 2021, 58% is assumed. Similar considerations apply also to the cost benefit appraisal, but the year by year flow of costs and benefits is not available for this. Because the value of time goes on increasing after 2021, it is likely that the assumed proportion of the total NPV of benefits is higher than 58%. It seems likely that about two-thirds of the total NPV will occur after 2021. This is disproportionately subject to uncertainty, not just in the normal way due to distance in time, but also because it has not been forecast at all; merely assumed. Investors are not bound by Government guidelines in making forward projections, and will make their own risk assessment of the
219
case. 6.189 It may be that some sorts of uncertainty would increase the scheme benefits rather than reducing them. Scenarios in which traffic growth is lower than expected would reduce the benefit from the project. If traffic growth is higher, then the scheme benefits would increase. But, for the reasons given, reduction in traffic growth is the more likely scenario. This view is reinforced by the recently announced Transport Innovation Fund, intended to encourage local authorities to introduce congestion charging. 6.190 The main reason for the sensitivity that has now been revealed does not relate to the bridge itself, but to its context in a wider network, many parts of which would not be able to cope with the traffic it would generate. The result is that high tolls have to be applied to keep the use of the bridge at substantially less than its maximum capacity. If the capacity were already there, inherited from history, but at present uncharged, that would make sense - indeed, part of the case for road user charging depends on the proposition that one can get more efficient use of existing capacity by charging for congested parts of it. But the bridge is not 'existing capacity'. It is much less convincing to invest in a new piece of infrastructure which is larger than we can allow to be used. At the very least, these new figures prove that it has been designed to be bigger than it need be. And beyond that, they must surely give greater weight to the wider criticisms made by the objectors in terms of environment, accessibility, regeneration and social impacts, since the economic argument is a third weaker than it was, and what remains is looking less secure. Modelling - inconsistency between TfLs traffic and regeneration cases 6.191 There is an inconsistency between the traffic appraisal (which assumes the same number of jobs and residents with or without the scheme) and the regeneration appraisal (which suggests fewer residents and jobs if there is no bridge). If the traffic appraisals approach is correct, then there is no regeneration. If it is not correct, then the traffic benefits of the scheme are exaggerated. 6.192 This inconsistency affects the traffic appraisal, because the forecast conditions in the without case are made worse by the trips which will not be there; this exaggerates the difference in journey times resulting from the scheme and so is likely to exaggerate its calculated benefit. The inconsistency affects the regeneration appraisal, because that relies on the same estimate of journey time reduction arising from the scheme and so is likely to overestimate the population and jobs created. The problem is that there is no two-way interaction between the traffic model and the regeneration model. 6.193 It should be assumed, in accordance with the London Plan, that the jobs are either true additional jobs which did not previously exist, or they are taken by competition from outside London. The population changes are similarly
220
assumed to result from migration in and out of London, not by changes in the birth and death rates or by net transfer with other London Boroughs. Regeneration - development 6.194 A balance would be struck between the effect of transport benefits in attracting residents and employment, and the effect of additional residents and employment in increasing congestion and reducing transport benefits. 6.195 TfLs suggested relationship between travel time and employment is dubious. However, if, as TfL argue, increased travel speeds generate jobs, then reduced travel speeds must reduce jobs; and therefore extra jobs generated by the bridge must be more than offset by the loss in jobs caused by the general deterioration in traffic conditions expected in the area. If increased travel speeds do not generate jobs, then the entire presumption that the bridge would create extra employment is undermined. Regeneration - compliance with Government guidance 6.196 WebTag offers relevant guidance for such cases as the scheme: a. It will generally be appropriate for studies to consider a range of local planning scenarios. It is important that such scenarios are realistic (D524, Unit 3.1.2 paragraph 5.1.17). b. Some studies may require the use of a land use/transport interaction model rather than simply a transport model (D524, Unit 3.1.3, paragraph 2.1.1). 6.197 This allows, and arguably requires, TfL to consider the effects of transport projects on land use changes. 6.198 WebTag goes on to discuss different methods which are available to solve the difficulty in conducting a cost benefit analysis in which land use changes feed through into travel demand changes. It recognises the possibility that transport changes may influence land use in ways not consistent with the assumption that trip ends may be held constant; that there may be different land use patterns with or without a policy intervention; and that there is a partial way to address the implications of that. 6.199 All the methods discussed involve difficulties. But the overall balance is to encourage promoters to confront those problems and come up with solutions, not to rely on out-of-context quotations to justify ignoring the problem. 6.200 The quotations TfL offer to show it has followed DfT guidance are incomplete and misleading. Rather, DfT lays out quite stringent conditions which should be fulfilled, which TfL have not addressed. These include
221
allowance for feedback between land use and transport impacts, the demonstration of market failures which must be shown to exist before there can be additional regeneration benefits from a transport scheme, and the format and detail of the assessment of economic impacts, especially in demonstrating the specific locations, sectors of the economy, categories of employment and economic mechanisms which would enable the scheme to produce its claimed effects. 6.201 The result is that the regeneration argument for the scheme almost completely disappears. A valid case has not been made that there would be wider economic impacts beyond those in the cost benefit analysis; and, if there are benefits, no case has been made that they would be additional to the estimated transport benefits, for which the DfT requires a type of analysis that has not been carried out. Modelling - the special case of economic regeneration benefits 6.202 In the traditional pre-SACTRA view, the resource savings (primarily time savings) identified in the cost benefit analysis might appear as extra jobs or other wider economic benefits, but the value of that effect was already embodied in the time savings; the total value of the benefit remained constant. This resulted from the assumption of perfect competition which underpinned cost benefit analysis. In summarising this, SACTRA considered that in general, the value of direct transport benefits must decline if indirect economic benefits are to grow. (Document ADD/015, page 9 paragraph 23). 6.203 SACTRA pointed out that the conditions in which wider economic benefits might exist are where market failures cause departure from the assumptions of perfect competition. They found that the additional wider economic impacts of transport investments, not captured in cost benefit analysis, could be either negative or positive. It was quite wrong only to consider regeneration impacts as always (or even generally) being positive. 6.204 As to the location of the impact, such benefits that occur would not necessarily be in the intended place: they might be at the other end of the road. This has become known as the two-way street problem. 6.205 WebTag builds firmly on this approach, and continually stresses the need to assess potential negative impacts as well as positive ones; and suggests a way to do that. This approach seeks to identify the specific market failures which can lead to an expectation of any wider economic impact, and a geographical analysis to assess whether the location of the specific skills and extra jobs would produce the desired results. WebTag includes an analysis framework intended to ensure a rigorous and thorough approach. It is intended to be very testing because of the DfTs experience of the tendency for promoters to claim regeneration impacts without actually demonstrating detailed arguments and logical links which would bring them about.
222
6.206 That approach has not been followed by TfL. There is therefore no analysis that distinguishes between negative and positive effects the scheme may have. 6.207 Thus there is no evidence that the economy of the area concerned does not demonstrate perfect competition, or any of the mechanisms which would produce jobs in the stated places. 6.208 There is evidence of one departure from perfect competition: road users in the area as a whole are not charged prices set by reference to their external costs including congestion and environmental impact, identified by SACTRA as a case where the overall economic efficiency of the economy could reduce rather than increase. Walking and cycling 6.209 The most important point is whether or not the bridge would accelerate a general pattern of behaviour by which longer distance car journeys replace shorter walking trips. 6.210 The scheme would cause a shift, for example, of some short distance walk trips to long distance car trips to different destinations; and similarly for diversions from public transport. By far the largest part of the extra traffic due to the bridge will be extra vehicle kilometres, not extra journeys. 6.211 Future projection of the data in Document TfL/52 would allow the Secretary of States concern on this matter to be answered. TfL assert that walking, cycling, car use and public transport will all increase substantially. But no rationale is offered. More vehicle kilometres would be travelled with the bridge than without it, even though it shortens distances; the explanation for this most likely lies in the pattern of travel it encourages; it is difficult to reconcile this with its intended ability to shorten journeys by car. Transport policy 6.212 The central focus of TfLs policies is positive when compared with the Secretary of States expressed concerns. The scheme does not fit with those policies. 6.213 The scheme is out of key with the intentions of national and local government, and with most of what TfL is trying to do. 6.214 The bridge fails on at least three of the matters referred to in the Secretary of States call-in letter: a. The impact of the proposal on travel generation and overall travel patterns having regard to the desirability of achieving development that minimises the need to travel, particularly by private car;
223
b. Maximising use by non-car modes of travel, particularly pubic transport, cycling and walking; c. The impact of the development on traffic congestion in the surrounding area. Response by TfL to the Objectors Expert Witness - Professor Phil Goodwin Modelling - implications of TfLs modelling 6.215 The estimated traffic flow on Lakedale Road during the AM peak in 2001 was 8 vehicles two-way per minute. This is estimated to increase to just over 12 vehicles per minute in 2016 without the bridge, and just below 12 with the scheme. This is not regarded as daunting, and is within the physical capacity of the road. 6.216 It is right that TfL should consider the underlying traffic growth to 2016 as the base case. In the absence of a scenario of committed schemes that would give some certainty to the basis for a different forecast for the future year, there is no reason to adopt a base case different from that which TfL have used. 6.217 A Do Minimum case is necessary to judge the effect of a scheme. The effects of the scheme must be judged against what would or might have happened without it. This is a foundation of all guidance. 6.218 The basis for the economic benefits of the scheme is not the small overall increase in traffic speeds to which Professor Goodwin refers that is almost accidental. The reason for promoting the scheme is to achieve very large reductions in travel time across the river and to increase local accessibility as a result. 6.219 It would be wrong to attribute to the effect of the bridge the roughly 20% traffic growth associated in TfL/272 (paragraph 16) with extra jobs and population, because: a. A significant but unidentified part of traffic growth in the five Boroughs would be through traffic, unaffected by the scheme. b. The assessment presented by Professor Goodwin contains errors whose correction finds only a 60% increase in the traffic generating effect of the bridge, not 80% as he suggests. c. If one assumes that a quarter of the modelled base traffic is through traffic, then Professor Goodwins figure reduces further to a 45% increase, with the total traffic growth due to the scheme reduced to 5.9% of the 2001 base figure in the five Boroughs.
224
6.220 TfLs case forecasts past trends in traffic growth continuing to 2021: effectively an upper limit that represents a worst case for assessment of adverse impacts of the scheme. In the context of traffic on the proposed bridge, a higher traffic scenario was also developed in response to some objections. 6.221 Not all of the traffic using the scheme would experience the same level of congestion: most notably, peak traffic experiences more than off-peak traffic. 6.222 Different levels of overall traffic demand can affect forecasts for the scheme in two ways by varying the attractiveness of the alternative crossings, and by varying the attractiveness of the scheme itself. But use of the scheme would be regulated by tolls to concentrate its use to those trips which start or finish near the scheme, and consequently a much shorter journey to the river crossing (at the scheme) than if using other crossings. Hence, even as congestion generally increases, the benefit of this shorter journey would tend to increase. In addition, a benefit of the schemes tolls would be to help keep it clear, and hence maintain its advantage over other crossings as wider congestion increased. Modelling - benefits to local travellers 6.223 The Reference Case Model found that the proportion of all peak hour benefits to car users accruing to local residents making journeys to work would be of the order of 40%. This is the proportion of the total benefit that accrued to local commuters, rather than the 6.5% figure cited by Professor Goodwin (which represents the net difference between south-tonorth and north-to-south commuting). The full calculation has not been carried out for the Cordon Model, but the overall benefit accruing to local residents is expected to increase in that case. 6.224 The transport purpose of the scheme is to serve those who would use it. All users would benefit in transport terms. Some two thirds of the transport benefits associated with the scheme accrue to local trips, and almost one quarter of benefits would be to commercial vehicles. 6.225 It would be wrong to discount, as Professor Goodwin appears to, the value of all benefits other than those to northbound local users. 6.226 It would not only be the net northbound users of the scheme who would contribute to regeneration. The examples Professor Goodwin cites are not against the intentions of regeneration. The scheme, by improving accessibility, would help regeneration in three ways: a. By making more jobs and facilities accessible, and so improving the prospects of existing residents and making the area more attractive to live in.
225
b. Not all local jobs would have local residents able to fill them. c. Presumably local enterprises want visitors, as customers, and to make deliveries. 6.227 Professor Goodwin ignores the benefits of the scheme to public transport users and commercial vehicles. 6.228 The extra journeys to work that the new jobs would generate are included in estimates of congestion and hence in calculating the amount of the toll. 6.229 Professor Goodwins revised assessment ignores the key importance in scheme appraisal of comparison between the do-minimum and dosomething cases. Modelling and the effect of transport policy 6.230 Professor Goodwin argues that the traffic modelling work for the scheme underestimates the effect of current policies intended to reduce traffic levels. The Mayors Transport Strategy traffic targets are for 4% growth in Newham and 6% in Barking & Dagenham, Bexley, Greenwich and Redbridge during the period 2001 to 2011, whereas the scheme do-minimum assessment forecasts growth of 10% in that area between 2001 and 2016. 6.231 Assessment shows that the benefits per trip in the peak and inter-peak periods in the Reference Case Model are broadly comparable. This suggests that lower traffic levels do not seriously undermine benefits per trip, and supports the view that benefits principally relate to the opportunity for more direct journeys the scheme would offer. 6.232 In looking at lower traffic levels, a traffic level of 87% of the base traffic was estimated to reduce economic benefits per trip by 13%. For convenience, this was taken as a potential low traffic forecast. Extrapolated to the peak and the inter-peak periods, it would result in a benefit:cost ratio over 30 years of 4.1 rather than the 5.9 forecast. This remains a robust positive economic evaluation. 6.233 There are uncertainties over the scale of any traffic reduction. The 13% reduction was chosen for simplicity, but it is nevertheless appropriate for judging the scale of impact of lower traffic levels on the schemes case. However, even if highways benefits reduced by twice these levels and toll revenue reduced proportionately, the benefit:cost ratio would still exceed 2.5 for a 30-year appraisal using the Reference Case Model. The assessment is robust. 6.234 In such a low-traffic case, the scheme would still bring cross river time savings and accessibility benefits for the core local area. The environmental case would improve and the regeneration potential would remain.
226
6.235 Lower base traffic would not mean that the model would under-estimate the scale of induced traffic. If general traffic reduction measures were successful, they would apply equally to traffic using the scheme. But even if lower base traffic did result in more induced traffic, this would simply move usage and benefits back towards the base position. Modelling - Cost benefit analysis 6.236 The approach used in modelling the period after 2021 is the default option in the standard TUBA software, in that beyond the last forecast year, unless told otherwise, TUBA assumes a flat profile and inflates benefits with the value of time increasing in line with Gross Domestic Product (GDP). 6.237 WebTag (D524, unit 3.5.4) states that beyond the last forecast year, benefits should be estimated by extrapolation from benefits estimated up to the last forecast year by factors representing the growth in the value of benefits, the effect of the discount rate and the change over time of the magnitude of benefits. 6.238 The standard assumptions in WebTag are that the values of accident savings and values of time are assumed to grow in line with forecast growth in GDP per head; and that most schemes will adopt the standard discount rates. 6.239 The assumption in the scheme appraisal that values of time will grow proportionately to GDP per head is therefore consistent with WebTag. 6.240 WebTag 5.4.5, 5.4.6 and 5.4.7 notes that the magnitude of benefits requires more care, and suggests a number of issues including: a. It is not credible to assume that the magnitude (as opposed to value) of benefits will increase indefinitely (if at all) after the last modelled year b. Whether the magnitude of benefits will continue to grow c. Whether the magnitude of benefits will decline in the future d. A sensitivity test assuming zero growth from the last forecast year is recommended for most schemes 6.241 The last of these recommendations from WebTag is adopted in the assessment of the scheme (combined with the increase in values of time as already noted). 6.242 The scheme assessment assumes that benefits after 2021 would be replicated year on year. This does not imply that there would be no change
227
in policies or projects; they would continue to evolve, but the analysis suggests that their net effect would not significantly affect the benefits of the scheme. For example, many objectors comment on the potential impact of nationwide road pricing, which they expect to reduce traffic levels. But the Ministers announcement to Parliament on 5 July 2005 concerning road pricing made no suggestion that road pricing would reduce traffic. 6.243 The year 2021 was chosen as the forecast year because it is the latest date for which economic and demographic forecasts are available; because the schemes tolling strategy is intended to constrain traffic growth after 2016 in any case; and because the policy context for traffic suggests any further traffic growth would be relatively small. Tolls on the bridge would restrict growth there, so a flat profile of use and benefits was assumed. 6.244 TfLs choice of 2021 as the point at which traffic could be judged to stabilise is consistent with Professor Goodwins evidence that traffic reduction targets are important, practical and effective. 6.245 The sensitivity of the assessment findings to further traffic increase after 2021 has been considered. Overall, the benefits and toll revenues would increase. 6.246 A further sensitivity test examined the effect of ignoring guidance and not increasing the values of time beyond 2021. This would reduce the benefit:cost ratio of the Reference Case Model from 5.9 to 3.9. The effect of different assumptions of the future 6.247 By the period 2016 to 2021, the policies and measures being taken by TfL and others will result in a stable position where general traffic growth will not continue. 6.248 If traffic growth were unrestricted, then major infrastructure would be needed across London; but there is no proposal to provide that. Such a scenario of traffic growth is not realistic. 6.249 Professor Goodwin considers that, if traffic growth were lower, or negative, the benefits from the scheme would reduce. Benefits fell in the latest proposals because tolls were increased and the discount area reduced to make sure local roads would not be overloaded. With lower traffic levels, this would no longer be necessary, and the scheme could be made more easily available, restoring much of the economic and regeneration benefits previously forecast without adverse effect. Since its economic benefits do not principally result from congestion relief, the schemes benefits would substantially remain if the overall level of congestion in the wider network were less. 6.250 It is common ground that, even if future traffic reduced, delays for
228
remaining traffic would not necessarily lessen, because road capacity would be likely to be transferred to other modes. 6.251 It is not TfLs position that policy would allow traffic to grow without restriction. Greater traffic increases than expected are not possible. The basis of the forecast for stability beyond 2021 is that measures will be taken to prevent further traffic growth, including fulfilment of the Mayors Transport Strategy. Modelling - Central London Congestion Charge 6.252 The effect near the scheme of the change to the Congestion Charge is likely to be equivalent to a reduction in traffic of less than 1%. This is not a material difference in the assessment of the scheme. Modelling - robustness of the model 6.253 The 2021 forecasts were fully modelled using LTS. 6.254 The differences between the Reference Case Model and the Cordon Model are not small. The changes principally affect the Harrow Manorway corridor, a direct feeder to the scheme, forecast to be used by a significant proportion (14% in the Reference Case) of all users of the scheme in the AM peak hour. Secondly, the changes to the model are not small; the year 2001 modelled flows along Harrow Manorway are about 57% greater in the Cordon Model (confirmed by traffic survey) than in the Reference Case Model. 6.255 It is these substantial changes in traffic levels in this corridor that led to changes in the tolling proposals, which in turn result in a proportionate change in benefits. It is not the case that small changes in traffic levels prompted large changes in the benefits from the scheme; it is the decision to revise the tolling proposals including the changes to the discount area. Therefore it is not the case that further small changes could further reduce the benefits of the scheme. 6.256 It is not the case that the proportion of the NPV that would occur after 2021 would be disproportionately subject to uncertainty. However, even if 75% of the post-2021 NPV were lost, the scheme would still achieve a benefit:cost ratio of 2.1 high value for money in the DfTs terms. 6.257 No investor would accept any project sponsors forecast as a basis for bidding; investors would undertake their own assessment. Tolling issues 6.258 The proposed tolling regime would be attractive to a concessionaire. TfL would determine tolls and establish commercial arrangements with the
229
concessionaire as described previously. Suitable arrangements can be included in the contract to give TfL the control it needs, protect the concessionaire from TfLs actions, yet leave the concessionaire bearing the basic traffic and revenue risk. Croydon Tramlink, the DLR and recent bus contracts in London operate in this way. Such arrangements are attractive to the private sector. Modelling - potential inconsistencies between assessment of traffic and regeneration benefits 6.259 The draft London Plan (D610) population and employment forecasts are assumed in the do-minimum and do-something cases. 6.260 The assessment has identified the transport effects of the scheme using constant land use assumptions and has separately identified regeneration benefits. These appear in the AST. This approach accords with WebTag. 6.261 Departing from established guidance introduces uncertainty, since it potentially provides inconsistent results and comparisons with other projects. Inevitably, creating new untried methods (such as proposed by Professor Goodwin) creates a source of potential uncertainty. 6.262 The scheme proposals do not seek planning permission for additional development associated with it. Those must be the subject of future planning applications, demonstrating among other things the acceptability of the transport implications of those proposals. The policy context 6.263 The regeneration proposals for the London Thames Gateway are not isolated; they are part of the London Plan. They help achieve Plan objectives and they reduce the pressure on other parts of London. 6.264 It is not realistic to suggest, as Professor Goodwin does, that in a possible future the additional people and jobs would not exist in London. If growth is not encouraged in the Thames Gateway, it will happen elsewhere with potentially worse consequences for congestion. 6.265 If not in the Thames Gateway, the extra people and jobs would be located elsewhere in London or the South East. But the London Plan does not provide for such an outcome, although it establishes that Londons growth should be accommodated in London. Potential revisions to the London Plan to provide alternative locations for more people and jobs would be beyond the scope of this inquiry. The scale of the issue 6.266 TfLs estimates of the effects of the TGB (Cordon Model) are extra London
230
Thames Gateway population in a range centred on 61,750 and extra jobs in a range centred on 27,750. 6.267 TfLs estimates of the effect of the scheme are that it would support between 23% and 27% of the total population growth in the area between 2001 and 2016 (2% to 3% of the total population forecast) and between 16% and 20% of the total growth in jobs (2% to 3% of the total employment forecast). 6.268 This would result in some 2% to 3% increase in traffic, spread widely across East London, about 20% of the overall growth between 2001 and 2016. Such an increase would not normally trigger any need for a detailed transport assessment, which generally sets a threshold of 5%. 6.269 These small changes in traffic levels should be compared with the increased accessibility the scheme would bring. 6.270 The further changes in accessibility catchments due to higher numbers of people and jobs in the local area are not taken into account in TfLs regeneration analysis. This implies that the results are potentially conservative. 6.271 If, notwithstanding the provisions of the London Plan, an appraisal case were to consider the effect of locating the additional jobs and people elsewhere in London, there is no reason why the adverse impacts elsewhere would be less in the do-minimum than those which Professor Goodwin apparently considers to be omitted from the scheme analysis. 6.272 Any shortfall in the London Thames Gateway forecast population and jobs would be likely to result in additional population or jobs elsewhere in London, resulting in at least as great congestion and delay as they would in East London. Consequently the economic benefits would not be undermined. More congestion would be caused in West London. This strengthens the economic case for the scheme. Although he does not refute this, Professor Goodwin relies on his assumption (that the population and employment associated with the scheme would not be sourced from London) in asserting that the TUBA analysis would be undermined if lower population and employment were included in the do-minimum. 6.273 The planned extra people and jobs would have a very minor effect, not captured by the model, of increasing traffic and congestion, lessening the accessibility improvements that prompt the increase in potential jobs and population. This very minor effect would not mean that modelled traffic benefits are exaggerated. Regeneration - compliance with Government guidance 6.274 The full WebTag is an inquiry document.
231
It is wrong to criticise TfL for
being selective in its quotations from WebTag. 6.275 Professor Goodwin suggests the use of scenario or sensitivity tests. The London Plan is the central scenario. A range of possible outcomes has been addressed by allowing for variation in the effects, which do not rely on any specific planning scenario. 6.276 Paragraph 5.1.17 of WebTag unit 3.1.2 (D524) cited by Professor Goodwin does not refer to the land use effects of a scheme; it refers to testing a range of external policy scenarios. The context of that extract is clear that the intention of WebTag is not to compare between different land uses in the do-minimum and do-something cases, nor to any suggestion that the subject of the assessment might itself influence land uses. 6.277 WebTag emphasises that any scenario tested should be realistic. There is only one realistic relevant local planning scenario which derives from the Regional Transport Strategy included in the London Plan and the Mayors Transport Strategy. 6.278 The further scenarios suggested by Professor Goodwin would not allow comparison of do-minimum and do-something land uses. 6.279 Paragraphs 2.6.7 and 2.6.8 of WebTag unit 3.1.3 set out the process adopted by TfL. 6.280 Secondly, Professor Goodwin suggests the use of an integrated land use and transport model. No such model is available, and the development of one would have been a major task inappropriate to the scale of the issue in hand. Such a model would have great uncertainties associated with it, requiring the exercise of judgement if a decision is to be made. 6.281 It is because of these expected difficulties that TfL has taken the approach of identifying regeneration gains separately on the basis of experience particular to London, while the traffic analysis assumes that the gains will actually be made. Also, it is noteworthy that the leading integrated land use and transport models assume accessibility to be a determinant of development density.
Modelling - the special case of economic regeneration benefits 6.282 SACTRAs report of 1999 (ADD/015) concluded that, if market failures are present, then perfect competition does not obtain, and other costs and benefits, for example pollution and regeneration, ought to be included. 6.283 Such issues are considered in the AST. Market failures are endemic in any market economy, and so SACTRAs analysis, which would require complex
232
analysis with many substantial assumptions, has never been applied in practice to the quantification of scheme benefits and disbenefits. 6.284 The suggested trade-off between value of time and value of jobs might have a minor effect on regeneration, but is not of a significant order of magnitude. 6.285 As to the two-way street effect, the evident and specific market failure is the slow pace of the reuse of land, alongside persistent unemployment and low rates of job creation, to which the formation of the Thames Gateway and its associated policies is a response. 6.286 A geographical analysis to establish the locations of skills and additional jobs is not possible in the Thames Gateway, in which substantial changes across many areas are expected over the next decade. It would be spurious to identify where individual employers might employ individual workers in more than a decades time. The large size and long timescale of the Thames Gateway project makes such an approach incapable of providing reliable results. 6.287 The statistical analysis undertaken by TfL shows that accessibility generally has a positive effect on employment population densities. A description of the area and its workforce is provided in the Environmental Statement (D808) and the Regeneration Statement (D822). Changes in the accessible workforce and potential changes in unemployment have been assessed. Since there is considerable investment in skills at present, and since the resident population is changing, a skills description of the current workforce is not very relevant to the future. 6.288 The reporting framework of WebTag assumes a fixed population. Here, policy and accessibility changes encourage a larger population. This has a positive effect on retail availability and success and is likely to moderate the effects of competition. 6.289 The relevant WebTag worksheet (D524, unit 3.5.10) was published in February 2004, when the Regeneration Statement was already drafted. There was not enough time to recast all the material into the worksheet format. Much of the material sought by the worksheets is in TfLs case in any event. 6.290 WebTags assumption of a static population is entirely inappropriate for the Thames Gateway. 6.291 The effects of the two-way street phenomenon on regeneration would include: a. The advantages of the scheme would clearly be biased toward the local users by the tolls.
233
b. It is important to consider what is at the ends of the two-way street. The scheme would link two similar areas, thus enabling the intensification of use of both of them. c. Equally, those areas are parts of a city which is, in general, successful and growing. The scheme would enable both areas to participate in that expansion more effectively. Public transport, walking and cycling 6.292 The scheme should be considered not in isolation, but in the context of all the other measures being taken to improve transport in the Thames Gateway. Although the scheme would slightly reduce the growth in public transport use and increase car use, modal shares would be hardly affected, and the overall picture would remain one of growth in public transport use between 2001 and 2016. Combining the public transport forecast for use of the TGB services with that of the Woolwich extension of the DLR achieves a 50% mode share for public transport across this part of the Thames. 6.293 The scheme would reduce travel by walking and cycling by 0.8% in the four Boroughs, compared to the 2016 do-minimum. The vast majority of users of the scheme would previously have used cars. The Reference Case Model forecasts that, compared to the 5,550 peak hour car users and 1,875 public transport users, some 250 fewer slow mode trips would be made in the AM peak hour. Overall 6.294 The approaches suggested by Professor Goodwin would be unnecessarily complex and would provide only limited additional understanding of issues that would have a small impact on the assessment of the scheme. Objectors Expert Witness - Professor John Whitelegg 6.295 Professor Whitelegg was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4983.
Regeneration - accessibility 6.296 TfL consider regeneration to be the ability to provide more and higher quality jobs and houses in the Thames Gateway. But, although there is no formal Government definition of regeneration, various sources such as the Social Exclusion Unit, the ODPM and the Neighbourhood Renewal Unit suggest different dimensions of renewal and sustainability. Reduced unemployment and appropriate transport infrastructure are parts of
234
regeneration. Other parts include improvements relating to opportunities, skills, housing, quality public services, crime reduction, green spaces, improvements to the physical environment and narrowing the gap between deprived and other communities. 6.297 In particular, regeneration is about much more than creating jobs. A New Commitment to Neighbourhood Renewal (D701) notes that the Government does not accept that the main cause of low employment and high benefit receipt is lack of available jobs. Yet the scheme strategy is based on an assumption that lack of jobs is the problem and that, further, this lack is directly correlated with low accessibility. There is no evidence that this is the case; nor do TfL acknowledge that lack of jobs is the main cause of unemployment. 6.298 The scheme would impinge only very weakly on the factors that regeneration should seek to address. It would also make matters worse in some respects: the physical environment, health, and the gap between the deprived communities closest to the scheme and the less deprived further away. 6.299 The word accessibility is misused by TfL. Accessibility is defined by the DfT as whether people, particularly those from disadvantaged groups and areas, are able to reach the jobs and key services that they need, particularly health care, education and food shops, either by travelling to those services or by having those services brought to them. Access, not movement, is the true aim of transport. Accessibility can be poor because of cost, fear of attack, difficulty in crossing very busy roads or a local lack of facilities. It can be improved by improving public transport or making it cheaper to use, increasing safety on the streets and ensuring that local facilities such as shops, surgeries, post offices and employment sites are safeguarded and developed. 6.300 A strategy focussed on building a new bridge is not an accessibility strategy. It cannot deal with the local availability of services or guarantee the availability of timely affordable useful public transport. Rather, the bridge would favour car travellers, making it disproportionately easy for people who live further away to benefit in comparison with local residents. The Boroughs closest to the bridge are all in the lowest 10% of Boroughs in the country in terms of car ownership. The bridge ought to benefit public transport passengers more than car users, but the reverse would actually be the case. 6.301 TfLs evidence shows that car drivers would have at least a five-fold greater catchment of employment sites than public transport passengers. Additionally, car drivers from further away would be able to travel to jobs faster than public transport passengers who live closer to the jobs. People who live further from the bridge would be able to out-compete local residents in terms of ease of travel to jobs. So the bridge would not help many people who are in most need of employment.
235
6.302 As to cycling and walking, commuting in those ways over the bridge would be unattractive to most. Nor would a large bridge with busy access roads and more traffic improve conditions for cyclists or pedestrians; both groups are disadvantaged by increasing levels of traffic. 6.303 Thus the bridge would disproportionately favour people who live further from the bridge over local residents. The gap between deprived and other communities would be widened. By supporting car use, the bridge would reduce public transport patronage, which may in turn lead to service reductions, further affecting people who do not own a car. However, Professor Whitelegg agreed in cross-examination that it would be a relevant consideration for decision makers whether the scheme is proposed to be provided as part of integrated transport and land use strategies that balance the needs of motorists with wider scheme impacts. 6.304 During the inquiry TfL changed its traffic evidence. The increased traffic levels reported in TfL/202 damage the hypothetical regeneration effects of the scheme. Increased traffic worsens journey times and increases congestion. The information is presented in such a way as to underestimate the scale of the problem. Accessibility would be reduced, compared with that indicated by the Reference Case Model. TfL claim that accessibility can be straightforwardly converted into regeneration and, if so, any regenerative effect of the scheme must be reduced. TfLs estimate of the volume of traffic that would use the bridge is also reduced. The estimated regeneration benefits of the scheme are now reduced by between 13% and 22%, depending on the particular pattern of development, inward investment, job search and training provision to ensure that local people can compete fairly for jobs with people who commute into the area. The already weak regeneration case is further weakened. Reliability of the regeneration model 6.305 The re-basing of traffic forecasts and changes in tolling and discount areas are very clear indications that TfLs case relies on evidence that is subject to considerable uncertainty and risk. The changes in traffic flows and claimed regeneration benefits are at the upper end of changes in any major scheme appraisal, analysis or inquiry that Professor Whitelegg has encountered in the previous 25 years. 6.306 There are very specific reasons why the case for the scheme is especially prone to risk and uncertainty. Its central premise, as set out in TfLs regeneration evidence, is based entirely on modelling and modelled relationships. There is no validation, no empirical evidence and no assessment of the two-way street argument put in the SACTRA report Transport and the Economy (ADD/015). This strongly hypothetical base for claiming regeneration benefits is very sensitive to other changes: a 1% change in traffic has produced a 25% reduction in regeneration benefits. Such instability is not acceptable, and the modelling is not reliable. 6.307 The lack of validation and ex-post verification, which SACTRA identified as a
236
significant problem in its 1999 report, has not been addressed in any of TfLs regeneration evidence. Modelling is not a substitute for empirical evidence, and modelling that depends on heroic assumptions will always be subject to dramatic sensitivity to changes in the input data. Nor have changes to the input data finished; details of the tolling regime have yet to be agreed by the Mayor of London, and the configuration of the discount area is not settled. Regeneration - employment 6.308 The ability to travel to jobs does not equate to the ability to win and hold the jobs. Canary Wharf, for example, is adjacent to some of the most deprived communities in Britain. The residents of Boroughs further away from the bridge, who have more qualifications and more experience in higher-level jobs, would be in a better position to take up the newly accessible jobs than the less skilled residents of Boroughs nearer to the bridge. 6.309 The London Plan expects manufacturing and construction employment to fall over the next decade, and professional, administrative and personal service jobs to rise. Skills deficiency is likely to be as important as the lack of accessibility in preventing people from the Thames Gateway from getting jobs. A new bridge would simply improve accessibility to more, yet unsuitable, jobs. 6.310 Solid empirical evidence in favour of the basic proposition that new roads will inevitably lead to reversal of economic decline and more jobs has not been presented. There is no correlation, for example, between the public transport accessibility index and the unemployment rate in London. This is illustrated by the case of Bexley where, according to TfLs Regeneration Statement (TFL/61, paragraph 132), an increase of 41% in the accessibility index offers no significant potential for development. 6.311 There is no empirical link between increased accessibility and job creation in the TGB area. 6.312 Nor is there firm evidence from elsewhere in support of the general proposition that new road infrastructure will necessarily lead to a reversal of economic decline and more jobs. Many places that are well served by motorways have significant unemployment and structural economic problems. There is a substantial body of published work (4983/1/A1, tables 4.1 and 4.2), including the Inspectors report into the M74 motorway extension in Glasgow, that refutes the proposition of an unambiguous link between transport investment and local economic gain. 6.313 It would be perverse to proceed with the scheme on the unsubstantiated assumption that such an investment would lead inexorably and unambiguously to job creation in disadvantaged areas and to the removal of social exclusion.
237
Regeneration - development 6.314 As a car oriented development, the bridge would also make the type of high density development promoted by the London Plan more difficult to achieve. 6.315 The scheme would encourage car use and would induce traffic. This increased traffic would increase demand for road space and for parking. It would reduce patronage of public transport. Roads also support land uses such as warehousing that are land hungry and provide few jobs. For all these reasons the scheme would foster low density development. 6.316 If the scheme was not built, then there would be some transient slowing down of regeneration benefits, but these would recover and job losses from the two-way street effect would not arise. Alternatives 6.317 TfL has not considered appropriate alternatives to the bridge. The kinds of interventions that are likely to improve regeneration and accessibility in the area differ markedly from a large new bridge. 6.318 If the aim of the scheme is to improve accessibility and to support regeneration, as TfL claim, then alternative interventions that would achieve those aims should also have been considered. A range of Government documents in a range of contexts, including accessibility planning and achieving best value, propose the logical sequence: a. Problem definition b. Option identification c. Options appraisal d. Option selection e. Implementation f. Monitoring. 6.319 The case for the scheme is essentially based on a very partial problem definition stage, and then a direct leap to option selection. The problem is not really poor accessibility, but a new bridge has been identified as the preferred option. Key intermediate stages have been ignored. 6.320 This is very poor public policy, unlikely to deliver best value or sustainable development objectives.
238
6.321 There are many examples of accessibility focussed options that are very relevant to the disadvantaged areas near the scheme: bus services designed to help residents of deprived areas get to work, discounted travel, loans of mopeds to allow people to get to work, minibus services. These are all targeted on specific groups in specific places. 6.322 Such an approach in the context of the scheme would include: a. Skills training and education for low income groups and unemployed people; b. A job creation programme based on areas of disadvantage, providing jobs there to avoid the need to travel; c. Provision of affordable timely bus services between residential areas and employment sites; d. Environmental improvement, so that disadvantaged areas have more green space and parkland; e. Improvements to support walking and cycling; and, f. Better policing to produce safe streets and confidence that the neighbourhood is very safe indeed. 6.323 This approach would not involve carrying roughly equal numbers of people across the river to work every day in each direction. There is no intrinsic merit in moving people across a bridge and no known way to avoid the waste of time, effort and cash that 20,000 members of low income groups would expend crossing the bridge to get to work. 6.324 Instead, TfL promote, but do not justify, a very expensive, non-targeted and cause-and-effect unproven option. This represents a departure from the principles of transport appraisal and the principles of best value. 6.325 The scheme is unlikely to improve either accessibility or regeneration in the terms of their generally accepted, good practice definitions. It would certainly, however, lead to large increases in traffic on the roads leading to the bridge and to more noise, air pollution, accidents and severance. The neighbourhoods closest to the bridge would degenerate. The possibility of improving one aspect of sustainability (access) is not an adequate justification for certainly reducing other aspect health, and an attractive living environment. Long distance traffic 6.326 TfLs Regeneration Statement (D822, paragraph 129) notes that businesses
239
saw the scheme more in terms of a transport improvement than as an aid to regeneration, and that by making travel easier it would provide increased access to wider catchment areas. The developer of the White Hart Triangle makes a similar point. 6.327 TfL claim that there is enough demand for cross river trips to make the cost of the scheme worthwhile, but not enough to support a worthwhile rapid transit system. This inconsistency can be explained if the real purpose of the bridge is to make long distance car commuting easier. The bridge is a re-badged attempt to get the ELRC, a scheme that in 1985 was justified in terms of plugging a gap in the strategic road network. With the A406 and the A2/A20, it adds another loop to the M25. The scheme should not be labelled as a local regeneration project. Tolls - discount area 6.328 Fifteen wards in Bexley would be wholly or partly excluded from the discount area. Of these, Erith and North End wards are both in the top quartile of deprived wards in England, and Belvedere, Crayford and Northumberland Heath are in the second highest quartile of deprived wards; all five would be wholly excluded. The decision to exclude these wards from the regeneration effects of the scheme is evidence that the regeneration arguments are not as strong as TfL claim. If they were strong and wellfounded, it is not credible that five deprived wards could be excluded from the regeneration benefits. 6.329 On grounds of natural justice as well as value for money, a case based on regenerating deprived areas in East London that then excludes deprived areas in East London must be rejected as perverse and irrational. Traffic modelling - robustness of the model 6.330 There is a body of evidence on the robustness of traffic forecasts and other effects of large transport infrastructure projects. 6.331 The National Audit Office (NAO) report Road Planning (4983/3) reveals that there is considerable uncertainty in the kind of forecasting and planning that underpins the promoters case. For example, of 41 schemes analysed by the DfT in the study, the modelled traffic flows for the year after opening on 22 schemes were within plus or minus 20% of the actual flow for that year; but of the remaining 19 out of 41 schemes the variations between forecast and actual flows ranged from minus 50% to plus 105%. Of 137 schemes in England analysed by the NAO, 34 had traffic flows more than 20% higher than forecast and 39 had flows more than 20% lower than forecast. The NAO found the average difference between actual flows and those forecast for the same year was 28% in England. Furthermore, the NAO found that there are many cases where the presumed economic benefits and their associated traffic increase based on higher levels of economic activity are simply not realised.
240
6.332 The promoters have provided no evidence of confidence levels that could be applied to economic and environmental appraisal results. 6.333 The NAO report, published in 1988, has been updated by independent academic observers, principally by Professor Flyvberg of Aalborg University in Denmark. His paper Inaccuracy in Traffic Forecasts, published in 2006 (Document 4983/4), considered 210 transportation projects (including road and rail) in 14 nations. For 50% of the 183 road projects, the difference between actual and forecast traffic is more than 20% and for 25% of road projects it is 40%. 6.334 In summary: a. The regeneration arguments on which the promoters case relies are based on modelling with no empirical evaluation. b. The estimation of scheme benefits does not take into account the poor record of many other large projects. c. These intrinsic weaknesses have been compounded by the need to recalculate traffic forecasts, a process that has shown the instability of the modelled relationships. 6.335 This instability undermines the core of the case for the scheme. Response by TfL to the Objectors Expert Witness - Professor John Whitelegg Regeneration - accessibility 6.336 The scheme is part of a much larger package of national, regional and local policies on transport, other infrastructure and the social and economic development outlined in TfLs regeneration evidence (TfL/P/05/2). The case for the scheme in a nutshell is that an improvement in accessibility across the river is an essential part of that package; and the improved accessibility needs to be available in all modes. It is not TfLs case that the scheme would inevitably produce regeneration. 6.337 The scheme would be part of a package of measures to address a broad range of neighbourhood renewal issues. It would reduce any gulf between areas and groups in terms of prosperity and opportunity, by reducing the accessibility deficit in East London compared with West London, and by increasing job opportunities. By increasing the opportunity to reduce longterm unemployment, it would reduce the number of people on means tested benefits. By supporting higher incomes, it would help improve schools and improve the GCSE results of young people. It would help provide homes, and reduce the need for development in the South East. Local businesses would benefit from bigger markets and lower freight costs, and the two-way
241
street and resulting competition would not be a zero sum game because of Londons dynamism. By lowering unemployment, it would improve health. It would encourage skills programmes, because it would provide the opportunities necessary for those to be successful. By improving accessibility, it would encourage people to live in the area, leading to better housing. The jobs, incomes and residents associated with the scheme would lead to a better physical environment. 6.338 Transport is a key element in accessibility but not the only element. It is neither practical nor desirable, particularly in the context of a major world city like London, to ensure that all the facilities and opportunities local communities need are available locally. Successful parts of London need both local and wider opportunities. 6.339 Road based transport is crucial to economic activity and regeneration, since it provides a means of delivering goods and services. 6.340 It is not appropriate to conclude that car users would benefit disproportionately from the scheme, to the disadvantage of local people forced to compete with people from afar, because: a. The tolls would discourage non-local people from using the bridge. b. For many journeys, alternative routes would be much easier and more attractive than the scheme. 6.341 Nor would improved access to the area from distant places mean that local people would be out-competed for jobs, for these additional reasons: a. Attracting more residents would increase the number of jobs. b. Better accessibility would increase job opportunities, for example by allowing access to a wider range of jobs. To illustrate this, currently only 2% of the 1,600 or more employees at LCY are from Greenwich, whereas 31% are from Newham. c. Successful economies will be open ones with in- and out-commuting. 6.342 The kinds of trips made by public transport and by vehicles are likely to be different, including (as well as commuting) business, service provision, commercial and social purposes. Trip variety is wide in Outer London, and public transport would not be able to provide for all trips. Reliability of the regeneration model 6.343 Although the changes in economic benefits arising from TfLs new traffic evidence were substantial, they arose from a substantial change in traffic
242
flows. The changes in tolling and benefits are not disproportionate. TfLs rebuttal to Professor Goodwin explains this more fully. Regeneration - employment 6.344 There is a large body of work in the promoters case regarding the relationship between accessibility and the potential for population and employment. 6.345 The lack of a correlation between a locations public transport accessibility index and its unemployment rate is not relevant to the case, since it makes no allowance for non-public transport. Also, no case has been made that unemployment rates in a ward will be correlated with its accessibility. Unemployment in a small area will be the result of many factors. It would be perverse to argue that the prospects of an inner-city area with high unemployment would be improved if its accessibility was reduced. 6.346 The example cited of the effect in Bexley of a 41% increase in accessibility is inappropriate, because accessibility in Bexley is at such a low level, shown by TfL as demonstrating less responsiveness to changes in accessibility. 6.347 TfL does not seek to make the case that new roads will inevitably lead to reversal of economic decline and more jobs. Nor does it seek to draw general conclusions about the effect of transport on the economy. Rather, its evidence concentrates on the effect of such investment in London and not other places. The evidence from London shows that a link exists between transport and various activities. The decision of the Secretary of State in relation to the new crossing of the River Tyne supports the case that, in particular circumstances, the needs of a local area require investment in local roads. Regeneration - development 6.348 The scheme would enlarge catchments and so promote higher density and specialisation. Alternatives 6.349 The scheme is particularly geared to linking Boroughs and parts of the Thames Gateway. The local initiatives that Professor Whitelegg suggests would enable local groups to take advantage of the new infrastructure, complement it but do not obviate the need for it. There has been no specific study that has considered how East London might be regenerated without a new river crossing. Numerous studies, reported in Document TfL/185, have considered the regeneration of East London, and many of these have concluded that new river crossings have an essential part to play. There has been no breach of WebTag guidance including its question
243
Are there better ways to achieve the objectives?. In 1996 the Government publication A Transport Strategy for London: The second in a series about Government action in London (TfL/180) said that the scheme should have the potential to contribute significantly to local regeneration, and the scheme has since been the subject of consultation for the Mayors Transport Strategy and at the Examination in Public of the draft London Plan. The Mayors Transport Strategy establishes the local transport objectives, including the scheme, which then feed into the transport analysis process illustrated in WebTag (extract at TfL/173). 6.350 As to the disadvantages that Professor Whitelegg sees in the scheme, the improvements in accessibility will certainly be as real as any impact from pollution. Local people themselves are able to take a view of the likely effect of the scheme on nearby neighbourhoods, and high proportions of local residents have supported the bridge. Furthermore, it is the Borough Councils that are charged with ensuring the social, economic and environmental well-being of the area at the local level, and they (with the partial exception of Bexley) agree that the benefits likely to arise from the scheme outweigh any disbenefits. Long distance traffic 6.351 There is no evidence to support the view that the scheme would make long distance car commuting easier. In fact, the scheme would offer few benefits to longer distance through trips. Tolls - discount area 6.352 Even though the regeneration benefits of the scheme would be reduced if the revised proposal for the toll discount area was adopted, those benefits would nevertheless remain substantial. Almost all of the most deprived wards (in the lowest quartile in England) are included in the discount area. The principal exceptions are North End and Colyers in Bexley. The current and all previous proposals for the discount area have excluded small areas of high deprivation in all Boroughs, for reasons of practicality and remoteness from the scheme. The proposal could be reviewed further.
Traffic modelling - robustness of the model 6.353 The research cited by Professor Whitelegg, in support of his view that there are substantial risks in traffic modelling and forecasting, is dated (in that the most recent scheme included started in about 1990) and, in the case of Document 4983/4, largely drawn from Danish experience. The modelling for the scheme addresses the key causes of error highlighted in both the NAO report and that of Professor Flyvberg.
244
6.354 It is incontrovertible that there are uncertainties about modelling and predicting in the social sciences. Uncertainty applies to all decisions, whether to act or not. It does not mean that the model and its outputs cannot be relied upon, or that decisions cannot be made on the basis of that evidence. In the case of the scheme, the flexible tolling allows uncertainty to be addressed. Objectors Expert Witness - Professor Caralampo Focas 6.355 Professor Focas was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4984. 6.356 Professor Focass evidence relates solely to the consultation exercise which TfL undertook during the summer of 2003 in relation to the proposed TGB. This was between the original decision of the TfL Board to proceed with the TGB in 2002, and the decision of the Board to submit the planning applications, the Scheme and the Orders in 2004. Compliance with TfLs consultation policy 6.357 At the time the consultation was undertaken, TfLs consultation policy had not been adopted. It had, however, been prepared in draft, and was supposed to have been taken into account in the arrangements for the consultation on the TGB. 6.358 The consultation failed to comply with the draft policy in that: a. it did not offer the public options, save for the possible closure of the Woolwich Ferry. b. it was not balanced - it did not quantify the environmental consequences of building the bridge; it suggested that building the bridge would create economic prosperity; it suggested that the bridge would be built so that trains or trams could use it, but did not mention that this would force buses into the general traffic lanes; the fact that the bridge would be tolled was not mentioned prominently, and the fact that the toll would be higher than that at the Dartford Crossing was not mentioned at all. c. the result of the consultation was not reported back to the participants. Consultation or information? 6.359 The main problem in carrying out a consultation exercise in relation to the TGB was that the public had little awareness of the scheme. Even in the most affected areas, the level of pre consultation awareness was only 7%. A decision was therefore taken to make the consultation in effect an awareness raising exercise as well as a consultation. That was a mistaken
245
approach. Awareness raising and consultation should be kept separate. Evaluation of the response 6.360 There were 76,600 questionnaires distributed, of which 40,000 were distributed by post. It appears that 2,777 of those sent by post were returned, with 2,711 of them indicating a view in favour or against the bridge. Of the remaining 36,600 questionnaires, 685 were returned, with 664 people expressing a view for or against the bridge. The response rate of those expressing a view was therefore 6.8% of those who received the questionnaire by post; 1.8% of the others; and 4.4% overall. This is a poor response rate. Conclusions drawn from a questionnaire with such a response rate can only be dubious. 6.361 No attempt was made to establish how representative of the entire population of the area the response was. Presentation of the results 6.362 The results of the consultation were then presented without adequate warning of their shortcomings. For example, in the ES which was published in July 2004, it is stated that TfL undertook one of its largest ever public consultation exercises between May and August 2003, and that the results showed that 85% of respondents supported the proposal for a bridge at this location. TfL went on to say that this was consistent with independent market research findings that show around 80% of people in East London support the TGB. No mention is made of the fact that the figure of 85% is based on a very small response rate. Nor is any mention made of the fact that a considerable majority of the independent written responses received to the consultation (that is, those which did not use the questionnaire response form) were in fact opposed to the bridge. Moreover, support for a bridge at this location is translated into support for the TGB. Response by TfL to the Objectors Expert Witness - Professor Caralampo Focas 6.363 The TGB was included in both the Mayors Transport Strategy and the London Plan, both of which had previously been the subject of public consultation. There had been a proposal for a bridge in the area since 1944. Although the present proposal is different from the ELRC proposal considered in the 1980s and the 1990s, the crossing point proposed has largely remained in the same locality. It cannot have come as a great surprise to local residents that a new river crossing was still being pursued. There had been extensive discussions with a range of local consultees following the TfL Board decision of November 2002 before the public consultation commenced in May 2003. 6.364 The consultation questionnaire was supplemented by the distribution of 460,000 flyers door to door; advertisements in the local press which
246
achieved an estimated penetration rate of 73.3% in the target area; posters in Tube stations and at around bus shelters within the consultation area; 28 days of exhibitions at 11 different locations visited by more than 9,600 people; and more than 30 items of media coverage about the bridge and the consultation. 6.365 It would have been misleading to have consulted on options in relation to the bridge, since the nature of the bridge, within a package of river crossings, had been set, following the consideration of a number of alternative crossing types and locations, by the London Plan. 6.366 TfL are unaware of any major infrastructure proposal where the full ES has been made available at the stage of the preliminary public consultation. In this case, and interim ES was published on TfLs website three months before the submission of the planning applications. 6.367 TfL consider that the building of the TGB would bring economic advantage to the area of the bridge, and evidence has been produced to that effect. 6.368 While the extension of the DLR across the bridge would mean that buses would need to travel in the general traffic lanes, there is no reason why trams could not share the public transport lanes with buses. Compliance with TfLs consultation policy 6.369 There are three explicit mentions of tolling in the consultation brochure. The proposal has always been that local people would pay a toll at around the same level as the Dartford toll, but that longer distance traffic would pay roughly double that level. 6.370 The result of the consultation was reported back to local people by way of three editions of a local newsletter published in November 2003, April 2004 and May 2005. The issues raised in the 2003 consultation in fact led to a number of changes in the detail of the TGB proposal. Evaluation of the response 6.371 A return of 5,290 questionnaires, including those submitted on line, amounted to 5% of those distributed. Professor Focas could quote no public consultation exercise which had elicited a greater response (D55 P129 L912). Objectors Expert Witness - Professor Mark McCarthy 6.372 Professor McCarthy was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4986.
247
6.373 Professor McCarthy reviewed the treatment of health issues in the ES. 6.374 There is a growing recognition of the need to include health aspects in Environmental Assessments. It is to the credit of the ES in this case that health is considered. The policy setting 6.375 National transport policy has recognised in recent years that vehicle exhausts make an important contribution to greenhouse gases, and that transport and health are importantly connected. 6.376 Transport policy for London must balance the need for economic development and the sustainable development objectives of a cleaner environment and an improved quality of life. The health impact of different transport modes 6.377 While the number of cars nationally continues to rise, in recent years the total number of journeys has levelled off, and there has been a steep fall in cycling and walking. In London public transport journeys have been increasing, especially bus journeys since 2000. 6.378 There is a hierarchy of risks for travellers. Motor vehicles are dangerous not only to drivers and passengers, but also to other road users, especially walkers and cyclists. By contrast, rail has much lower risks per journey. Transport policy in London recognises these issues. Modal shift from cars to public transport has a double benefit; it builds exercise into the journey and promotes the form of transport with the lowest level of damage to the traveller and to other Londoners. The impact of the TGB on traffic 6.379 The TGB would represent an important transport structure. It would signal the car, rather than public transport, as the main method for crossing the Thames at this point, and it would create an extra burden of vehicle traffic. 6.380 The ES estimates that private car transport will rise by 13.3% between 2001 and 2016. This is contrary to the transport policies of the local authorities concerned, which prescribe increases in walking and cycling, and a reduction in car journeys. 6.381 Despite this, the transport model used by TfL assumes that some journeys which already take place would transfer to the TGB and therefore reduce journeys on other roads. This is not an obviously correct presumption, however. Traffic in London maximises use of available roads unless it is inhibited in some way. It is equally likely that the net effect of the scheme would be a new flow across the TGB and a steady state of use of other
248
roads. 6.382 The ES also assumes that almost all car trips over the bridge, and all goods vehicle trips, would either begin or end in one of the four local Boroughs. This seems unlikely. The scheme is, in fact, part of a longstanding ambition of transport planners to complete an inner ring road for London. It would prove impossible to stop goods vehicles making longer north-south journeys across the TGB, and this could bring pressure to improve other roads to increase this facility. The impact of the TGB on road safety 6.383 The ES predicts the future rate of accidents in the area at approximately half the present level, despite the increase in traffic. Accident figures have therefore been recalculated in this Health Impact Assessment, based on the most recent accident rates. 6.384 The health impact of the bridge has been calculated on a worst case basis, namely that all predicted 20 million journeys across the TGB would be new ones. This worst case assumption represents a different approach from that used in the ES, but it is an approach which is accepted as good practice in modelling. 6.385 Compared to the ES figures of one additional fatality, six serious accidents and 114 slight accidents arising from the scheme, Professor McCarthy predicts 2.4 extra deaths, 25 serious injuries and 213 slight injuries caused by road accidents. The impact of the TGB on air pollution 6.386 External air pollution causes respiratory deaths and disease. Respiratory health is considered to be at risk from any level of pollution by particulates. Using a traditional approach, the ES assesses whether the limit value for air pollutants is breached, and reaches a conclusion that overall the TGB would not give rise to noticeable changes. But if 20 million extra trips on the TGB contributed a proportionate number of the 8,320 deaths caused in UK each year by exposure to traffic air pollution, the deaths arising from this cause as a result of the TGB would be 5.8 per year. This is a larger result than that given by applying the DMRB method of calculation, which only has regard to increases of air pollution of more than 10% in roads with more than 5,000 vehicles per day. The impact of the TGB on regeneration 6.387 The ES proposes that the potential employment provided as a result of the TGB would considerably reduce the deprivation index in the area, and suggests that increased employment improves general health and wellbeing. In fact, the ES does not make a clear case for local regeneration
249
arising from the TGB. It is assumed that the increased car journeys generated by the bridge would contribute to the general economic development of the Thames Gateway. This is also not proven. If economic regeneration leads to employment mobility, it may not improve the health of local people. If it leads to low pay and poor quality jobs, it will not necessarily improve the health of poor people. The impact of the TGB on general fitness 6.388 Increased use of the car would draw people away from public transport, and also has negative health impacts. Use of public transport creates an exercise pattern (walking) within the normal daily routine. There could be up to 9.4 lives saved from cardiovascular disease and diabetes each year if TGB journeys were taken by public transport instead of by car. The impact of the TGB on noise 6.389 There are various health consequences of noise. Loud noise in industrial settings still contributes to thousands of cases of deafness and ear disorders annually. Environmental exposures are less severe, but more widespread. Acceptable levels in residential areas are higher in daytime than at night. 6.390 Noise at the levels indicated in the ES has been found to be borderline in increasing blood pressure and perhaps contributing to cardiovascular disease. Intermittent noise, such as aeroplane noise, has been demonstrated to hinder concentration on tasks. 6.391 The ES makes an assessment of noise levels at house facades. It suggests that some houses could be protected by sound insulation and by not opening windows. It is not good practice in environmental health to create extra burdens for people, and noise levels with windows open should be the default level. It should not be necessary to sound insulate peoples properties. 6.392 The ES also indicates that people are more concerned with new noise than with continuing noise; that is, they accommodate. This may be true, but their quality of life would still have been reduced. 6.393 The ES makes an assumption that road surface noise from traffic will decrease by 2.5dB during the next decade. While engines are generally quieter than before, much urban car noise is created by tyres, which have been increasing in size. Road surfaces need to have some roughness to maintain grip, and therefore safety. There is no evidence to support the assumption that reduced tyre noise would be achieved. 6.394 The EU is currently developing guidelines for urban noise which will have considerable implications for road noise.
250
Broader considerations 6.395 At present, the land to the north and south of the estuary where the TGB is projected has open potential. However, there is a zoning for retail parks. It would be damaging if the TGB led to car based retail developments which detracted form the character of the communities which would be connected by the bridge. 6.396 The land on either side of the estuary is estimated by the ES to be in a flood zone. Mitigation measures would be needed. It is of health concern that there should not be risky development of these estuarine areas. 6.397 While the main concerns of this assessment are the long term consequences of any decision to build the TGB, the proposed four year construction period would also give rise to heavy construction vehicles in residential areas, dust and noise for the local residents and risk to construction workers involved in bridge building. 6.398 A tunnel, narrower than the proposed bridge, and providing only a public transport crossing, would be preferable on health grounds, both in limiting the harm of motor vehicle journeys and maximising the benefits of public transport journeys. Response by TfL to the Objectors Expert Witness - Professor Mark McCarthy The policy setting 6.399 The most important greenhouse gas is carbon dioxide. Only 22% of carbon dioxide emissions are generated by transport. That figure includes all transport. The percentage of carbon dioxide emitted by road transport would be a smaller one. 6.400 Like most objectors, Professor McCarthy ignores the public transport provision included in the TGB. He also ignores the fact that the TGB is promoted as part of a package of public transport crossings of the river the DLR to Woolwich, Crossrail, the GLT and the ELT, following on from the Jubilee Line and the DLR Lewisham - which signal that public transport comes first, but that the provision of a road link across the Thames is also necessary. 6.401 It is not the case that relevant local policy guidance prescribes a reduction in car journeys. The Mayors Local Implementation Plans guidance provides for cutting traffic growth - by 4% in Inner East London and by 6% in Outer East London. The impact of the TGB on traffic
251
6.402 Existing journeys likely to switch to the TGB would be those for which the TGB would offer a saving of time or distance or both. The extent to which roads are filled depends upon a variety of factors, but use of them by motorists must fulfil a purpose. There are few roads that do not have some spare capacity even in peak periods, most obviously in the counter peak direction. 6.403 Commercial traffic would only use the TGB if it offered sufficient time saving to offset the toll. For long distance traffic, this would be extremely unlikely in normal circumstances. There is no policy support whatsoever for improvements to other roads to provide for increased long distance use of the TGB. The impact of the TGB on road safety, air pollution, general fitness and noise 6.404 Professor McCarthy works on the basis that all 20 million journeys across the proposed bridge (18.3 million with the revised traffic modelling) would be new journeys. This is wholly unrealistic. It is not the case that the purpose of an Environmental Impact Assessment is to make worst case assumptions; it is required to describe the likely significant effects of the development on the environment. The vast majority of trips forecast to use the TGB are already car trips. In the absence of the TGB, those trips would continue to be undertaken by car. The analysis presented in the TfL evidence is that some 13% to 14% of trips would indeed be new car trips (either generated or as a result of modal shift). All his assessments of impacts should be factored down to this 13% to 14%. 6.405 When this is done, the 2.4 extra people killed in road accidents becomes 0.34 (1 in TfLs analysis); the 25 people seriously injured becomes 8.5 (6 in TfLs analysis); the 213 people suffering slight injury becomes 30 (114 in TfLs analysis). The 5.8 deaths per year as a result of air pollution becomes 0.8; the 9.4 deaths from cardiovascular disease and diabetes becomes less than 1. It is clear that recalculating the figures provided by Professor McCarthy using only new trips makes the two sets of estimates broadly comparable. 6.406 The assertion that environmental exposures contribute to cases of deafness and ear disorders is misleading, since environmental noise is not high enough to cause either. Similarly, the assertion that noise levels indicated in the ES are borderline in increasing blood pressure and contribute to cardiovascular disease is misleading because there is no proven link between the two. 6.407 The noise from a steady stream of road traffic such as would occur with the TGB scheme is not intermittent, unlike aircraft noise, where each individual aircraft flyover creates a distinct noise event. 6.408 Low noise road surfaces would be used on the TGB scheme. They have to
252
meet all the usual safety standards for issues such as grip. 6.409 The assessment of the noise impact of the TGB shows that no single property would qualify under the Noise Insulation Regulations for sound insulation as a result of the scheme. If in time a person ceases to be bothered by an increased noise level, that persons perceived quality of life would not have worsened. 6.410 TfL are not aware of any forthcoming EU guidance which would have implications for the assessment of noise in connection with the TGB scheme. Objectors Expert Witness - Mr John Elliott 6.411 Mr Elliott provided evidence which was relied upon by a number of objectors. His evidence was delivered, however, as part of the case of the London Thames Gateway Forum. His evidence is therefore reported as part of the case of the Forum, and the rebuttal evidence is incorporated in the report of the response of the promoters to the case of the Forum. Objectors Expert Witness - Mr Philip Connolly 6.412 Mr Connolly provided evidence on air quality which was relied on by a number of objectors. He claimed technical expertise in the field of air quality (D38 P95 L9), but accepted that such expertise was on the basis of being a conscientious, committed amateur (D38 P159 L14), rather than on the basis of the holding of any recognised professional qualification (D38 P164 L17). Mr Connolly also appeared as an objector in his own right on the issue of design (from paragraph 6.1371 below), and he represented Greenwich Action to Stop Pollution (whose objection is reported from paragraph 6.831 below). Policy framework 6.413 Both at EU and national Government level, initiatives have been taken in recent years to improve air quality. A guiding principle of the National Air Quality Strategy is the precautionary principle, defined under the Rio Declaration as where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost effective measures to prevent environmental degradation. 6.414 In policy guidance issued to local authorities by DEFRA (Document D535), air quality is accepted as a material consideration in determining a planning application. The impact of a proposed development is stated as likely to be particularly important: a. where the development is proposed in or adjacent to an AQMA
253
b. where the development could in itself result in the designation of an AQMA or the extension of an existing AQMA c. where the development or associated traffic is likely to result in predicted levels of air pollution close to a breach (i.e. leaving little room for future developments) or d. where to grant planning permission would conflict with or render unworkable elements of a local authoritys air quality action plan. 6.415 The Mayor of London has committed the GLA to work towards the achievement of the National Air Quality Strategy in Policy 1 of his Air Quality Strategy (Document D625). Individual London Boroughs have declared AQMAs covering all or part of their areas, including Newham, Redbridge, Greenwich and Bexley. 6.416 The overwhelming thrust of EU, national and local government policy is to move towards the limit values set for individual pollutants. But the ES says that moving away from the limit values would be the consequence of the approval of the TGB planning application. The importance of local circumstances 6.417 There is a long history of serious air pollution in East London. The cause used to be the heavy industry in the area. In the modern era, however, traffic has overtaken industry as the major source of pollution. Poor air quality is a matter of concern to local people, as evidenced by the responses to local quality of life surveys carried out in 1994 and 1995. It is the reason for the existence of the local pressure group, GASP. TfLs air quality witness fails to acknowledge the existence of particular local circumstances in assessing the significance of a minor adverse air quality impact. Assessing the significance of air quality impacts 6.418 The ES for the TGB scheme states at Table 16.7 that particulate emissions for 2016 as a result of the scheme would only be 0.003% greater than the situation in 2016 without the scheme. But in fact this means that an extra 3.3 tonnes of particulates would be released into the atmosphere in the local area each year. The Committee on the Medical Effects of Air Pollution concluded in 1998 that each individual has a different threshold beneath which he or she would suffer no adverse health impact. But this logically means that there is no threshold below which it can be said with certainty that there is no harmful effect. Thus any increase in pollution is a significant increase. 6.419 Another method of assessing the significance of any impact on air quality has been produced by the National Society for Clean Air. This method is used by Greenwich. The TGB development would interfere with or prevent
254
the implementation of actions in Greenwichs Air Quality Action Plan. That Plan seeks to reduce emissions from road transport vehicles. The traffic generated by the TGB would undermine the commitment to traffic restraint in the Action Plan, so the additional emissions generated would amount to an overriding consideration, requiring a redesign of the proposal. 6.420 The TGB development would also lead to a breach or the worsening of a breach of an EU limit value. The 25% traffic flow sensitivity test described in paragraph 4.145 above predicts that receptor 1 would log nitrogen dioxide concentrations of 39.97 micrograms per cubic metre as against an EU limit of 40 micrograms per cubic metre. No margin of error is allowed, yet an error of only 0.04 on an increase of 1.07 micrograms per cubic metre would be needed to result in an exceedence. The scale of error in the model, according to the evidence of Mr Whittles, the Air Quality witness for Greenwich, could be as much as a third in either direction. If such a result occurred, again, under the National Society for Clean Air method, air quality would be an overriding consideration in determining the planning application. The value of mitigation measures to the test of significance 6.421 The method accepts, however, that if the impacts can be removed or sufficiently mitigated, then there is no reason why, on air quality grounds, the development could not proceed. 6.422 In relation to the proposed TGB, the chief measure relied upon by the promoters is the introduction of a Low Emission Zone; the reduction of emissions as a result of advances in vehicle technology and the use of road tolls to reduce through traffic have already been accounted for in the modelling and predictions of air quality. Schedule 5 to the Boroughs Agreement, however, only makes commitments to Euro III standards (save in relation to emissions of particulates by buses) for taxis and buses, and makes no mention of private vehicles. This is despite the fact that Euro IV standards for passenger cars and light commercial vehicles came into effect on 1 January 2006. 6.423 The Governments advisors, the National Environmental Panel on Air Quality Standards, have expressed concern that technology will not be adequate on its own for the attainment of air quality standards, especially in London. 6.424 There are therefore doubts as to the effectiveness of the mitigation proposed in delivering the objective of being within the 2010 EU limit values in London. The reliability of the air quality modelling 6.425 Neither the ES nor the promoters evidence on air quality makes any meaningful assessment of the range of error within the predictions put forward for the impact of the scheme on air quality. Emission projections
255
are currently being reviewed in the light of issues such as economic growth, taxation measures to promote the use of low sulphur fuels and the real world performance of new technology. The on road emission characteristics of vehicles meeting Euro II emission standards turned out to be rather different from those predicted. 6.426 But the most important uncertainty is the weather. The promoters have used weather data from 2002, even though the verified data from 2003 is available. The view has apparently been taken that 2003 was an exceptional year. Advice from the University of the West of England, however, contained in Section 25 of Document 4987/3, indicates that the values in 2003 should not be considered exceptional, and that they should be included in the review and assessment process. The Hadley Centre of the Meteorological Office consider that the conditions of 2003 are set to reoccur. They concluded that by 2040 there was a 1 in 2 chance of a repeat. 6.427 It is not simply the start date that introduces an error in the air quality modelling, but the end date as well. The argument is advanced by the promoters that 2016 represents the year of peak traffic flow, but traffic is set to grow beyond that date, at least until 2021. 6.428 The air pollution figures are also based on the projected traffic growth figures produced by TfL, but these have needed to be amended during the inquiry. Traffic in Bexley was underestimated. 6.429 The parameters set for the air quality modelling are therefore the wrong ones. The modelling should be undertaken again. The predicted concentrations of pollutants must be scaled up by at least a third, and likely exceedences must be reassessed. Cost benefit analysis of deteriorations in air quality and road safety 6.430 The ES should, but does not, attempt to estimate the costs as well as the benefits of the TGB proposal. 6.431 The TGB would have a detrimental effect on road safety. Each year, it is predicted that there would be one additional death, six serious injuries and 114 slight injuries arising from the additional vehicle mileage covered as a result of the building of the bridge. Applying the figures for the cost of accidents contained in Highway Economic Note 1 produced by the DfT (Section 28 of Document 4987/3), there would be a road safety cost of 3.3m per year arising from the scheme at 2002 prices. 6.432 There is a close relationship, however, between vehicle collisions and the speed of traffic. Evidence has been presented that the actual speed of traffic is greater than the predicted speed. This would mean that the cost of road casualties had to be revised upwards.
256
6.433 If the same costs were attributed to the injuries and deaths which Professor McCarthy estimates would arise as health consequences of the proposed TGB, the total annual cost arising from the scheme would be very much higher. If an attempt is then made to estimate the cost of the extra carbon dioxide emissions, the cost of additional noise impacts, and the cost of dust arising, in particular, during construction, the true cost of the TGB in each of the first ten years of its existence of those items on which it is possible to place a monetary estimate would be between 6.8m per year and 18.9m per year. Many of those costs would in fact continue beyond the first ten years. 6.434 PPS23 requires these costs to be set against wider economic and social benefits. It is accepted that regeneration measures are required to boost the economies of the Thames Gateway, especially for their disadvantaged residents. It is also accepted that there will always be some air quality impacts. But sustainable solutions are available. 6.435 There is widespread support for further public transport links across the Thames, but they could be provided by way of low pollution impact modes of travel, such as a zig zag ferry service connecting Greenwich with Barking & Dagenham (as suggested in the strategic guidance for Thames Gateway East) or a cable car crossing (as first mooted in the planning application for the Millennium Dome). A public transport rather than a private car link would directly address the dependency on public transport and walking of people on low incomes. 6.436 The contrasting economic performance of West London Boroughs and East London Boroughs is often suggested to be related to the greater number of river crossings to the west of Tower Bridge. It is just as possible to argue, however, that the regeneration measures needed to achieve the desired economic and social benefits are primarily ones of education and the provision of childcare facilities. East London Boroughs have a low proportion of people with higher level qualifications, and a high proportion of people with no qualifications. Greenwich has 10% lone parent households, the second highest proportion in London, and the fifth highest nationally. Childcare facilities would be important in allowing those people in particular to enjoy economically active lives. The section of the population which would suffer adverse environmental effects 6.437 In the Borough of Greenwich, it is the wards through which roads run which suffer high levels of pollution, which are the wards with higher than national average standard mortality rates. These are also the wards with the highest levels of deprivation. 6.438 Many people within the Thames Gateway are economically inactive as a result of long term sickness. The 2001 Census for Greenwich revealed that 8,845 people were economically inactive because of illness or disability,
257
compared with only 3,258 who were in this situation because of unemployment. In addition, many working days are lost through short term illness or through parents needing to take time off work to look after their sick children. These figures suggest that in Greenwich health is a more significant factor than unemployment in determining peoples standard of living. 6.439 Many of the very people the proposed TGB is supposed to benefit would be the ones to suffer the pollution induced health consequences that would prevent them from working. Response by TfL to the Objectors Expert Witness - Mr Philip Connolly 6.440 Mr Connolly holds no professional qualification entitling him to claim expertise in the subject of air pollution; nor has he any qualification entitling him to speak with authority on the health effects of pollution. Policy framework 6.441 The central Government duty under the Environment Act 1995 is to produce an Air Quality Strategy. This Strategy should set out standards and objectives. The Strategy makes clear that standards are set purely with regard to scientific and medical evidence on the effects as minimum or zero risk levels. Objectives are policy targets, and take account of economic efficiency, practicability, technical feasibility and timescales. The primary objective of the Strategy is to make sure that everyone can enjoy a level of ambient air quality in public places which poses no significant risk to health or the quality of life. The reference to significant risk is important, because there is a growing understanding that there is no zero risk level for many pollutants. 6.442 It is entirely accepted that air quality is a material consideration in considering the planning applications in this case. That is why a detailed air quality assessment was carried out. 6.443 Meeting the EU limit values is an obligation on central Government, not on local authorities or the GLA. The importance of local circumstances 6.444 Air quality has improved significantly since the quality of life surveys to which Mr Connolly refers were carried out in the 1990s and since GASP was set up. 6.445 Greenwich and Newham took local circumstances into account when they reached their decisions to approve the main bridge applications for planning permission.
258
Assessing the significance of air quality impacts 6.446 All Table 16.7 of the ES shows is that the bridge would increase emissions by 0.003 kilotonnes, not 0.003% as stated by Mr Connolly. Mr Connolly expresses this same figure in tonnes, which is 3 tonnes. This is not in fact a local impact, but applies to the change across the whole study area. It can only be interpreted in the context of total emissions from the study area, where the 3 tonnes increase represents a 0.6% increase in emissions. This would represent only about a 0.2% increase in concentrations, as local sources only contribute around a third of total PM10 concentrations. This is not a significant change. 6.447 The National Society for Clean Air guidance is not official guidance. NSCA is an environmental campaigning group. The
6.448 In the case of the TGB, the local authority officers have not directly used this unofficial guidance, but, as they have not recommended refusal, they appear to have accepted that the air quality impact of the proposed development does not constitute an overriding consideration, certainly after taking into account the mitigation incorporated in the scheme. This is entirely reasonable, given the scale of the impacts predicted in the ES. The objective value for particulates would not be exceeded, and the net changes in the areas above the objectives for nitrogen dioxide would be negligible in Greenwich (0.04%) and extremely small in Newham (0.4%). 6.449 Mr Connolly produced a number of articles indicating that air pollution can affect health, but he produced no evidence to demonstrate that the differential impact of the TGB on air quality in 2016 with respect to PM10 and nitrogen dioxide concentrations had any material significance for health in Greenwich and its environs. The value of mitigation measures to the test of significance 6.450 It is not the case that the chief mitigation measure relied on by TfL is the introduction of a low emission zone. Mitigation measures are built in to the design of the scheme. They include the lanes dedicated to public transport; the use of tolling; the discount for local users; and the provision in the Boroughs Agreement allowing tolling to be varied to encourage low emission vehicles. The reliability of the air quality modelling 6.451 There is no straightforward way to allow for uncertainties in modelling. The model results could be under or over estimates. To provide maximum assistance to the decision maker, they need to be the best estimate of what will happen, not the absolute worst possibility. 6.452 The advice on the University of the West of England website, which Mr
259
Connolly quotes, is based on work carried out by Professor Laxen, TfLs air quality witness, who is responsible for that website. Not surprisingly, the air quality assessment has taken into account that advice, as worst weather conditions have been allowed for. There is thus no need to model again using 2003 weather conditions, as these conditions have already been allowed for. 6.453 The ES makes clear the process by which the relevant pollutants for assessment were identified. Other pollutants were considered and screened out of any detailed assessment. This process was agreed with the local authorities and the GLA. 6.454 Mr Connolly concludes that predicted concentrations in the air quality assessment must be scaled up by at least a third. He provides no detailed assessment to support such a suggestion. The predictions set out in the ES are entirely adequate to assess the impacts of the proposed development. Cost benefit analysis of deteriorations in air quality and road safety 6.455 The costing of air quality impacts is very difficult, and still very much an area of research. At this time, there is no agreed methodology. Mr Connollys assessment of alleged costs of the TGB air quality impacts was based on no recognised methodology. He had based his costs analysis, however, on Professor McCarthys evidence, which had assumed, wrongly, that the 20 million annual trips across the bridge in 2016 would all be new trips, which would not otherwise have been made. 6.456 In relation to noise impacts, Mr Connolly suggests that 3,393 properties would require sound insulation. In fact, no property would qualify for sound insulation under the Noise Insulation Regulations 1975 as amended in 1988. The majority of homes that experience a noise increase would be well below the trigger level for the Noise Insulation Regulations. Transport 2000 (T2000) 6.457 T2000 is an independent national body promoting sustainable transport. It draws together the transport views of around 40 organisations, including environmental and transport bodies, representing many thousands of people. T2000 is divided into a campaigning arm, which operates as a non profit making limited company, and a charitable trust. The Board and the Trustees of T2000 have been kept fully informed about T2000s work on the TGB, and the Chairs of the Company and of the Trust sent written confirmation that the objection to the proposal had been fully authorised (Document 1995/5). 6.458 T2000 have supported many of the policies pursued by TfL over the last few years, particularly the introduction of the Congestion Charge and the major programmes of bus service improvements. T2000 also support the regeneration of the Thames Gateway area of East London. T2000 have,
260
however, for many years opposed the planned major road crossings of the Thames. Current roads policy 6.459 UK transport policy has changed substantially since the 1989 Government White Paper Roads for Prosperity hailed the largest road building programme since the Romans. Since the Transport Ten Year Plan of July 2000, it has been Government policy that building new roads is counter productive. 6.460 National policy has its equivalent in regional policy. The Mayors Transport Strategy of 2001 recognises that a major programme of new road schemes to provide substantial additional capacity would be environmentally unacceptable and financially unaffordable. An overall objective of the Mayors Transport Strategy is therefore to promote alternatives to the car. 6.461 The TGB is not consistent with the objective of promoting a transfer from the car. On the contrary, it will encourage car use and discourage travel by other means. The impact of the proposal on traffic generation and overall travel patterns 6.462 The accuracy of the traffic model and the traffic forecasts is crucial. If the forecasts are unreliable, TfLs predictions for the effect of the bridge on congestion and on a wide range of other social, environmental and economic factors would be unreliable, as would its benefit:cost analysis. 6.463 TfL present a reassuring picture of minimal traffic growth resulting from the bridge. That growth is alleged to be harmlessly accommodated on the main road network, with the exceptional needs in a few areas being met by TfLs package of mitigation measures. Unfortunately, that comforting picture is not confirmed by independent assessment. Professor Goodwin finds the forecasts implausible, and T2000 rely on his criticism of them. LB Bexley also challenge the forecasts, and this resulted in TfL producing new traffic figures during the course of the inquiry. Those new forecasts were significantly different from the ones which TfL originally produced. It is highly unlikely that the differences between forecast and actual traffic levels are confined to Bexley. New traffic counts should be taken in many more locations in other Boroughs and fed into a re run of the model. The re run should be based on the current 8 Congestion Charge, and not the out of date 5 charge. 6.464 The Mayors Transport Strategy adopted targets for 2011 of a 15% reduction in weekday traffic in Central London (already achieved), zero growth across the rest of Inner London, and reducing growth in Outer London by a third. These targets were adopted in the London Plan. However, Local Implementation Plan Guidance in 2004 (Document 2703/19) modified the targets, to limit traffic growth to 4% in the Inner London area
261
of the East Sub Region and 6% in the Outer London area of the East Sub Region over the period to 2016. 6.465 In fact, TfL forecast that there would be substantial traffic growth even without the TGB. London wide demand for highway trips is forecast by TfL to grow by 13.3% between 2001 and 2016 even without the TGB. Regardless of the impact of the bridge, large parts of London will fail, according to the forecasts, to meet the targets for traffic volumes in the Mayors Transport Strategy. In Newham and Greenwich, even without the bridge, traffic is predicted to grow by 17% and 7% respectively between 2001 and 2016. These two Boroughs will therefore be unable to meet even the raised targets of the Local Implementation Plan Guidance. TfL should therefore not pursue a development proposal such as the TGB, which would make the breach even more serious. 6.466 But TfL forecast that the TGB would generate additional substantial growth. The total of background traffic growth and growth induced by the TGB would be 35% in Newham and 14% in Greenwich by the year 2016. The figures for traffic growth with and without the bridge should be added together to produce the with TGB prediction for 2016. 6.467 But although TfL forecast a steady annual growth in traffic, including the years from 2001 to the present, resulting in a cumulative 13.3% growth in traffic by 2016, they have also given evidence that traffic volumes in London (except in the central congestion charging zone) have already deviated from this prediction, and have been largely static for the last four years. In fact, in Central London there has been at least a 15% fall in traffic, largely as a result of the Congestion Charge, while in the larger central area outside the charging zone, a 1% growth in traffic in Outer London has been offset by a 1% fall in traffic in Inner London. On the other hand, Bexleys comparisons of modelled flows of traffic for the 2001 AM peak with the actual observed flows show the latter to be much larger. These two pieces of evidence pull in different directions, but both of them cast doubt on TfLs predictions. 6.468 Those predictions of traffic growth also take no account of the potential for a range of policies and measures to contribute to effective traffic reduction before the proposed completion date of the TGB. Bus priority and improved bus services, congestion charging and soft measures such as work place and school travel plans, improved walking and cycling facilities, car sharing and car clubs could all make the traffic growth predictions unreliable. 6.469 The journeys made as a result of additional jobs and population generated by the bridge have been included in the prediction of traffic levels in 2016 without the bridge and in the claimed economic benefits of the bridge. 6.470 If the traffic that TfL now predicts for 2016 materialises, TfL would be required to introduce measures to bring that traffic level down. The Do Minimum traffic forecast for 2016 is thus also unrealistic in that respect.
262
6.471 If the forecasts are unreliable, the business case that TfL have made for the TGB cannot be relied upon either. The over estimate of the amount of traffic that will occur without the TGB by 2016 fundamentally affects the cost benefit analysis, and undermines much of the economic case for the bridge. The regeneration and economic case for the bridge 6.472 TfL claim that the TGB is necessary for the regeneration of the Thames Gateway, and that the achievement of regeneration is the principal purpose of building the bridge. But it became clear during the inquiry that the figures used by TfL for the base growth in traffic in the area from 2001 to 2016 included the traffic from the additional jobs and population said to be generated by the bridge. In effect, the figures assume that the jobs and people would be there whether the bridge was built or not. 6.473 There is no necessary connection between traffic growth and economic growth. In fact, recent evidence from Central London suggests that traffic reduction can be accompanied by economic growth. 6.474 TfLs forecasts maintain that those using the bridge would travel faster in 2016 than they would have done if the bridge had not been built. This comparison is the largest source of the benefits attributed to the bridge. But logically an increase in employment and population, relying to a large extent on the private car as a means of transport, would normally lead to slower travel times. 6.475 A large proportion of the assumed benefits of the scheme is deemed to occur after the last year for which any forecasting was carried out. During that period, TfL assume that trip patterns, employment, population, car ownership, household size etc would all remain constant at the same levels as in the last forecast year. So there would be no increase in congestion after that year. But incomes are assumed to go on growing, with no effect on travel patterns, and values of time savings are also assumed to go on growing. This means that the estimated benefit increases every year, even though the time difference remains constant. The estimated benefits are therefore exaggerated. Minimising the need to travel, particularly by car 6.476 The concept of reducing the need to travel is closely related to that of accessibility. The main objectives of PPG13 include both the promotion of accessibility and the reduction of the need to travel, especially by car. The general approach to delivering sustainable development set out in PPS1 is expressed in very similar terms. It is therefore not surprising that improving accessibility and reducing the need to travel have been incorporated as cardinal principles of the London Plan, reflected in Objective 5 and in Policy 3C.1, which links reducing the need to travel especially by car with seeking to improve public transport capacity and accessibility.
263
6.477 Policy 3C.3 of the London Plan indicates that there will be support for high levels of growth in the Thames Gateway supported by improved public transport. The overwhelming objective of national and regional planning policy is to improve accessibility by promoting development which can be reached on foot, by bicycle and by public transport and to reduce the need to travel, particularly by car. 6.478 Promoting accessibility is said to be the main aim of the TGB proposal, but accessibility is defined as the average of the number of people and the number of jobs that can be reached within 45 minutes by road or by public transport. Thus the version of accessibility applied to the consideration of the TGB scheme is not the same as that considered in the relevant planning guidance. It is not part of the purpose of the TGB to reduce the need to travel. Instead its aim is to enable people to travel further within a given journey time, whether by public transport or by car. The criterion of accessibility used by the promoters treats people travelling further to make 45 minute journeys by car as a benefit. The whole justification of the TGB is based not on reducing the need to travel, but on increasing it. TfL gave evidence that, without the TGB, employers in Thamesmead have a catchment of 350,000 workers within a journey time of 45 minutes; but with the introduction of the TGB, this would rise to a catchment of 1,750,000 workers within a journey time of 45 minutes. It is the explicit intention of the promoters of the TGB to increase catchment areas rather than to reduce them. 6.479 According to TfLs traffic model, the total number of trips in the AM peak will rise by just 0.1%, but the total length of journeys travelled by car in the peak will go up by 0.4%. Despite being only a small proportion of car trips in London, trips across the TGB are likely to contribute much more substantially to an increase in average car journey lengths. Car journeys across the bridge are likely to be longer than the average length of other journeys made by car. Obviously some journeys would be shorter, as a result of not having to travel so far to cross the river, but this benefit would be far outweighed by the increased number and length of other journeys that would be made using the TGB and by using space on other roads and river crossings freed up by the TGB. This is completely at variance with national and regional policy. 6.480 TfL claim that the TGB would be a local bridge, but that depends upon an unusual definition of the term local. TfL regard as a local journey one which either starts or ends in one of the four Boroughs local to the bridge. In fact, even the 36% of journeys which it is estimated would have both an origin and a destination in one of the four Boroughs could be up to 22km long; but the 64% of journeys also regarded as local by TfL (because they either start or finish in one of the four Boroughs) could be of any length at all. 6.481 The TGB would have many if not all of the characteristics of a major strategic route. It would connect the North Circular A406 and the A13, providing immediate access to the M11, and in the south it would connect to
264
the A2016, a dual two lane road providing access to the M25. It would also link almost immediately with the A205 South Circular. All the connections with these strategic roads would consist of grade separated junctions to maximise traffic volumes and minimise disruption to traffic flows. 6.482 The tolls proposed by TfL to discourage long distance through traffic would be likely to have a less inhibiting effect on long distance traffic than on short distance traffic. For long distance through traffic, the charge would only be a small proportion of the total journey cost, and would be insignificant in relation to savings in journey time and in other costs such as the cost of fuel. Maximising use by non-car modes of travel, particularly public transport, cycling and walking 6.483 The bridge would be much more useful for travel by car than for travel by public transport. It would actually reduce the use of public transport. The ES acknowledges that the bridge would encourage a transfer from public transport to the car, and not just for journeys across the river. Paragraph 14.6.30 of the ES indicates that in the absence of the TGB, Greenwich, Newham, Bexley and Barking and Dagenham are expected to experience a 35% growth in public transport between 2001 and 2016. With the easier traffic conditions offered by the TGB, this would moderate some of that growth, with use of public transport in the four Boroughs forecast to reduce by 1%. 6.484 The TGB proposal would place public transport at a disadvantage to the car and would fail to maximise the use of public transport as PPG13 requires. 6.485 If TfL had been serious about maximising the use by non car modes of travel, particularly public transport, cycling and walking, a greater range of options would have been appraised before the selection of a scheme. 6.486 As proposed, the TGB would have two dedicated lanes for buses and four lanes for general traffic. It would not be multi-modal. It would provide for general road traffic and for road based public transport. At best, it would be bi-modal. TfLs claim that the TGB would be multi-modal depends on the provision of facilities for pedestrians and cyclists, but the facilities provided would not be a feasible, everyday, useful route for either of those modes of travel. 6.487 A survey of the Woolwich foot tunnel undertaken on 1 July 2003 counted 408 pedestrians and 58 cyclists travelling northbound, and 433 pedestrians and 61 cyclists travelling southbound over a 14 hour period. But the Woolwich tunnel is only 370 metres long. The TGB would be 2km to 2.5km long. The ES explains that it would take an average, fit pedestrian approximately 30 minutes to walk across the 2km span of the TGB or 38 minutes to walk across the 2.5km span, and a cyclist some 7 to 15 minutes, depending on the level of fitness. Less than 10% of journeys between 2km
265
and 3km long are made on foot. The bridge would involve a walk of 2km to 2.5km to cross it plus further potentially substantial distances between the crossing and any likely origins or destinations. It is too long to be an everyday walking route. 6.488 So far as cyclists are concerned, they would face the steep 5% gradients of the bridge, high winds (on average Force 7 or above on 25 days of the year) and chicanes and bumps on the cycle track to discourage travelling at high speed on the descent. 6.489 The bridges claim to be multi-modal rests on its claim to be a walking and cycling route. In reality, it is neither of those things, and therefore it does not conform to the London Plan. 6.490 Travel on foot and by bicycle is not a peripheral, insignificant part of the urban travel picture. Though only about 2% of journeys are made by bicycle in London, in many other European cities the figure is 20% and more. Walking already accounts for 31% of single mode journeys in London. The potential for maximising walking and cycling, as required by PPG13, is considerable. But the TGB would push in the opposite direction. It would encourage travel by car, and longer distance trips, at the expense of shorter trips which could be made on foot or by bicycle. The traffic generated by the bridge in a wide swathe of East London would make conditions on the roads worse and more dangerous for pedestrians and cyclists. Traffic volumes are in important factor in peoples decisions about whether or not to walk or cycle. Cycling trips in Central London increased by 30% following the 15% reduction in traffic triggered by the Congestion Charge. 6.491 The TGB would also form a significant element in a land use or development pattern that discourages walking and cycling and promotes the use of cars. Aspects of such development that encourage the use of a car include new road infrastructure and road capacity; large centralised amenities with extensive catchment areas which involve longer journeys; and large areas of car parking. All three aspects are already evident in planning proposals in the Thames Gateway area. Over 70,000 car parking spaces have been approved in planning proposals in the Thames Gateway Boroughs in the last five years (counting only those schemes with more than 200 parking spaces). Document 1995/6 provides details of parking provision in outline planning permissions already granted in the Thames Gateway area, together with details of other applications currently under consideration. This is the basis of a development pattern that increases the need to travel, maximises car use and suppresses demand for walking and cycling. It would inhibit higher density development, and generate more low density urban sprawl. The extent to which the proposal would secure a high quality of design 6.492 PPS1 explains that good design is not just about aesthetic considerations; it
266
also involves meeting access needs. Planning authorities are encouraged to provide improved access by ensuring that new development is located where everyone can access services or facilities on foot, bicycle or public transport, rather having to rely on access by car. On the other hand, the TGB proposal would not maximise the use of public transport, walking and cycling. Conformity with PPG13 6.493 TfL claim that the TGB would be in conformity with PPG13 because development of the Thames Gateway would reduce the pressure to accommodate growth through low density development encroaching on the Green Belt and other open space beyond Greater London. In addition, reference is made to Annexe A to PPG13 which refers to Londons special arrangements for integration between planning and transport in the Mayors strategies. However, Section 41 (5) (a) of the GLAA 1999 requires that the Mayors strategies have regard to the need to ensure that the strategy is consistent with national policies. The proposal is required to comply with PPG13, and it fails to do so. 6.494 T2000 accept that PPG13 recognises that the car will still have an important part to play in transport in the future, but the PPG qualifies that opinion by suggesting that for some journeys, particularly in rural areas, it will remain the only option for travel. Clearly, PPG13 seeks to encourage much less travel by car in urban areas. 6.495 PPG13 and WebTag guidance both create an obligation on the promoters to consider alternatives, and to assess non road solutions. TfL have not discharged this obligation. The Inspector should recommend that a public transport crossing between Thamesmead and Beckton or Barking Reach should be properly appraised and tested. Conformity with the London Plan 6.496 The TGB proposal also fails to conform to Policy 3C.15 of the London Plan. It would increase the net traffic capacity along its road corridor. Because there was more traffic, it would have an adverse effect on air quality, and therefore not provide a net benefit to Londons environment. It would not improve safety for all road users, because it is accepted that additional accidents would be caused by the additional mileage run by vehicles if the bridge were to be constructed. It would not be in conformity with local and strategic land use planning policies. T2000 also contend, relying on the detailed arguments of Professor Whitelegg, that the bridge would not be effective in promoting regeneration. Deprived wards in Bexley would, under TfLs current proposals for the tolling discount area be ineligible for discounted tolls. There would thus be, by TfLs own admission, less regeneration promised by the bridge. There would thus be less regeneration to offset against the other criteria within Policy 3C.15 which are not met
267
6.497 Where a scheme would worsen conditions when judged against any of the criteria of Policy 3C.15, the Policy provides that it should not proceed unless benefits in other areas very substantially outweigh any disbenefits and unavoidable disbenefits are mitigated. TfL were ready to agree that this is a demanding test (D2 P68 L10). It is a test which the TGB scheme obviously fails, and it therefore does not conform to the London Plan. 6.498 During the inquiry, there has been some disagreement about what exactly comprised the package of river crossings referred to in the London Plan. TfL have referred to the Jubilee Line Extensions (completed many years ago) and to Crossrail (not yet funded or approved) as parts of this package. Policy 3C.14, which endorses new river crossings, refers only to three - the Woolwich crossing, the Silvertown Link and the TGB. Two of these are road crossings, and only one of them is exclusively a public transport crossing. Overall 6.499 A modern, progressive urban transport system consists of providing a high quality public realm, which constrains car use, has good facilities for walking and cycling, a network of local amenities which can be reached on foot and by bicycle, and is based on a framework of modern public transport services. This is not the model now being proposed for the Thames Gateway. Instead, in the UKs largest urban regeneration area, we are offered road infrastructure and access by car to remote, centralised facilities, with acres of car parking and continued social, environmental and economic damage from heavy traffic levels. 6.500 Should the Secretary of State allow this proposal, it is so blatantly in conflict with national and regional policy, and the business case for it is so poor, that it would be vulnerable to challenge in the Courts. 6.501 This inquiry has been notable because the objectors received some funding from the promoters to enable some of the claims made on behalf of the promoters in support of the scheme to be scrutinised by advisors with expertise in the professional area of activities concerned. The resources made available were massively less than those available to the promoters, but there has still been the opportunity for the shortcomings in the promoters arguments to be exposed by witnesses of substance and distinction. Objectors in public inquiries can play a vital role in ensuring that public projects are properly justified, and that public money is not wasted on projects which fall seriously short of the claims made for them. The Inspector should recommend that resources should in future be normally granted to objectors at public inquiries to redress the imbalance between promoters and objectors. The response of TfL to the objection of T2000 6.502 The TGB proposals for East London embody two of the measures which T2000 expressly support in Central London, differential tolling and bus
268
service improvements. Current roads policy 6.503 T2000 misrepresent Government policy on new road building. There are limits, but the Ten Year Plan does not rule out selective road projects. Nor does the Mayors Transport Strategy, even though it provides stringent tests for new road building to meet. 6.504 It is not the purpose of the TGB to increase traffic. That would be the consequence of the TGBs transport objective to improve accessibility to jobs and facilities, both locally and sub regionally. The TGB is a road proposal within a dominantly public transport package. TfL propose the TGB to increase accessibility in the Thames Gateway rather than to increase highway capacity. The bridge would support sustainability at the strategic level by facilitating the development of East London and accommodating Londons growth within its boundaries without encroaching on either the Green Belt or other open spaces. 6.505 Making some provision for the private car and business road freight and servicing movements within a package weighted towards public transport reflects the fact that the private car will continue to play a role, particularly in Outer London and areas where general population growth is expected. The impact of the proposal on traffic generation and overall travel patterns 6.506 TfL consider that the revised traffic modelling is adequate to make forecasts and assess impacts of the proposed scheme. It is not necessary to re run the modelling. TfL have forecast at the upper end of traffic growth in the modelling, and growth could turn out to be less than allowed for. In Bexley, however, it would be wholly unrealistic to forecast a lower rate of growth to 2016. 6.507 It has always been intended that the Mayors traffic targets for Inner and Outer London would be achieved through appropriate local targets. These are the targets now set by area, and they are specific to local circumstances. They are not modified or raised as T2000 claim. 6.508 It is not accepted that for the four East London Boroughs the differences in the targets result in traffic growth far in excess of the Mayors targets or that the TGB would make the breach even more serious. Traffic reductions will continue to be pursued, but these would not seriously undermine the case for the TGB. 6.509 T2000 suggest that the TGB proposal should be assessed on the basis of the combined impact of underlying traffic changes to 2016 and the impact of the TGB itself. In general policy development, it is appropriate to take both these factors into account, as they were in developing the Mayors Transport
269
Strategy and the London Plan. However, in judging the specific TGB proposal, the key issue must be the TGBs impacts set in the context of an appropriate forecast of underlying traffic changes. The primary cause of growth is unrelated to the TGB. 6.510 The four Boroughs traffic growth of less than 10% over 15 years is forecast (without the TGB) against a background population growth of over 11% and public transport growth of 35%. Although TfL would hope to restrain traffic growth further, the forecasts do not appear unrealistic. Lower traffic levels would not materially undermine the case for the TGB. 6.511 T2000 suggest that underlying traffic growth might be lower than forecast, but many of the factors they identify are allowed for within TfLs forecasts (new public transport projects and improved bus services), considered as sensitivity tests (Crossrail) or are reflected in the local traffic targets (soft measures). It is precisely because TfL recognise that traffic growth will be increasingly constrained that only a modest rate of growth has been allowed for until 2016 and none beyond that date. Even if T2000 are correct, and there is smaller growth, this does not remove the case for the TGB. It would simply mean that the TGB would be able to accommodate more than 4,525 vehicles in the AM peak without overreaching the capacity of the local network. TfL do not accept that any uncertainty fundamentally affects the cost benefit analysis. The regeneration and economic case for the bridge 6.512 TfL accept that alterations to the toll discount area affect the claimed regeneration benefits. No suggestion has been made of any realistic way of reducing flows in the 2016 Do Something scenario across the Bexley corridor other than by a combination of higher tolls and a reduced discount area. TfL consider that the revised AST set out in Annex 1 to Document TfL/P/04/8 fairly sets out the revisions to the traffic forecasts and the economic benefits of the scheme. Minimising the need to travel, particularly by car 6.513 TfL agrees with T2000 that the concept of reducing the need to travel is closely related to that of accessibility. The TGB would improve accessibility in East London. 6.514 TfL accept that the majority of users on the TGB would be in private cars, and that to this extent the TGB would encourage car use. But some 50% of predicted users of the TGB would divert from existing routes over the river to take advantage of the shorter route which the bridge would offer. Most of those trips would already have been made by car, with only a small element of modal transfer (14% with the original modelling; 10% on the revised modelling). 6.515 A public transport only bridge would not merely be unviable. It would also
270
do nothing to help goods vehicles which need to cross the river. The transportation of freight is also one of the statutory responsibilities of the Mayor and TfL. 6.516 Far from being a target in terms of assessment of accessibility, the 45 minutes journey time is seen as a maximum, with the expectation being that most journeys would be much shorter. 6.517 In terms of catchment areas, TfL believe that giving greater access to jobs and employees is critical to regeneration. The aim is not to create the possibility for very long journeys, but to make possible short cross river trips, which are currently outside local catchment areas because the lack of easy river crossings makes them difficult to achieve, even though the distance involved might be a short one as the crow flies. 6.518 Close to 80% of the AM peak TGB car trips would be made by local residents. Local businesses would also have the benefit of the possible use of the TGB for commercial traffic. 6.519 T2000s assessment that the TGB would prove attractive to long distance through traffic fails to take account of the fact that longer distance travellers would lose time in using the TGB as well as facing a higher toll. Moreover, there would be no direct link between the TGB and the A2. For those reasons, the TGB could not properly be regarded as part of a strategic route. Maximising use by non-car modes of travel, particularly public transport, cycling and walking 6.520 Since the TGB is the road based multi-modal component of TfLs river crossings package, it is not surprising that the benefits are focused on cars and commercial vehicles. However, new facilities for cycling and walking are included in the bridge design. 6.521 While a public transport only bridge would eliminate all the highway benefits to cars and commercial traffic, public transport benefits would not increase dramatically since the DLR link to Woolwich will already have improved accessibility for many of the public transport cross river journeys. 6.522 The average journey length of a cycle trip in London is 8km. Cyclists are likely to make use of the TGB cycleway in the context of trips of that average length. The proposed maximum gradient on the cycleway would be 5%. It would therefore conform to the relevant standards for cycling provision. There is already an extensive network of cycle paths in East London, and more are at the planning stage. The proposed cycleway over the TGB would link the routes north and south of the river. 6.523 The River Thames is approximately 650m wide at the site of the proposed
271
TGB. TfL are proposing to build lifts for cyclists and pedestrians on the north and south banks. The precise location of these lifts has not yet been determined. With the lifts located at the riverside paths, the walking distance across the bridge would be 750m. If the lifts were to be located at Armada Way and Barnham Drive, the walking distance would be 1,800m. 6.524 A substantial amount of development is under construction or committed on each side of the River Thames in the vicinity of the proposed TGB. These developments include the Royal Albert Basin, the redevelopment of the Beckton Gas Works site, Gallions Reach Urban Village and Tripcock Point. The path across the bridge would provide pedestrian access to these locations. 6.525 The application of car parking standards in areas which would be served by the TGB provides an indication of how the PPG13 guidance to reduce reliance on the private car is being implemented in practice. The London Plan requires Transport Assessments to be prepared where developments have significant transport implications. Public Transport Accessibility Levels have been adopted to produce consistent London wide public transport access mapping. Residential development at higher densities and with lower car parking provision is encouraged in areas with high Public Transport Accessibility Level scores or where sites are close to town centres. 6.526 In relation to developments close to the TGB, the public transport services over the bridge would help to improve the accessibility scores of adjoining areas. There would thus be a reduction in parking provision for dwellings with good access to public transport. Development would take place at higher density as a result, however, and that would lead to an increase in the number of trips by visitors and trips to supply goods and services. Even with a strategy which seeks to reduce reliance on the private car, therefore, the car would still have an important role to play in the Thames Gateway, and the TGB would make important provision for public transport, personal travel and the movement of goods and services. It is for the local planning authorities to determine the extent to which new developments should be provided with car parking. The London Plan gives a lead in seeking a downward trend in such provision. 6.527 T2000s argument that the TGB would be bi-modal rather than multi-modal entirely discounts the wholly new facilities which would be provided for walkers and cyclists. T2000 did not suggest any improvement which they would wish to see to those proposed facilities. The extent to which the proposal would secure a high quality of design 6.528 PPS1 does not rule out the development of new roads. The range of transport improvements needed to support regeneration in the Thames Gateway is not restricted to public transport. Conformity with PPG13
272
6.529 The overall package of measures which TfL propose to improve transport in East London is consistent with the guidance in PPG13. Making some provision for the private car and for business road freight within a package weighted towards public transport reflects the fact that the private car will continue to play a role, particularly in Outer London. A bridge which made no provision for the private car would deprive goods vehicles of the benefits of a river crossing in this area. Such a bridge would not meet the policy requirements of the London Plan, but nor would it provide an answer in terms of value for money, cost benefit or financeability. Conformity with the London Plan 6.530 The construction of the TGB would enable TfL, the Borough Councils and developers to promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling, by the various modes of private car, road freight vehicles, public transport, walking and cycling. The criteria set out in Policy 3C.15 are varied, and not capable of a mechanistic assessment based on the scoring of each individual criterion. It is a matter of judgement as to whether benefits in other areas outweigh any criterion which is not met. A detailed statement setting out TfLs analysis of compliance with this Policy is contained in Document TfL/81, which is summarised at paragraph 4.213 and 4.214 above. 6.531 TfLs position on the package of river crossings within which the TGB should be seen is clear. The TGB would complement the DLR cross river link to Woolwich, the Silvertown Link, the introduction of Crossrail and the GWT and ELT proposals. Friends of the Earth (FoE) 6.532 FoE is a company limited by guarantee. It is an environmental campaigning organisation, which has over 100,000 financial supporters. The objection of FoE to the TGB has been properly authorised by the London Group.
Sustainability 6.533 The five guiding principles of the Governments Sustainable Development Strategy 2005 (the SDS) (Document 1991/1/101A) are as follows: a. Living within environmental limits b. Ensuring a strong, healthy and just society c. Achieving a sustainable economy
273
d. Promoting good governance e. Using sound science responsibly. 6.534 The objective in the SDS is to achieve a strong, stable and sustainable economy whereas previously the economic objective was maintenance of high and stable levels of economic growth. It is the quality, not quantity, of economic growth that is now of most importance. 6.535 The SDS establishes that the identified economic, social and environmental objectives should all be met. They should not be traded off against each other in order to achieve a balance. This is reflected in PPS1 and in the Sustainable Development Framework for London (Document 1991/1/153) published by the London Sustainable Development Commission: We will make consistent economic progress not necessarily always growth to enable wider economic, social and environmental objectives to be pursued both in London and beyond. The Commission was appointed by the Mayor in 2002 to advise on sustainability issues in the capital. 6.536 PPS1 places importance on the need to manage patterns of urban growth to make fullest use of public transport and to avoid reliance on car travel for access to jobs, health, education, shops, leisure and community facilities, open space, sport and recreation. But the scheme would have that very effect. It would fail to minimise the need to travel. It would not maximise use by non-car modes. It would promote car-oriented travel with spread-out development, contrary to the aspirations of the Sustainable Communities Plan. Clearly the scheme would not promote such a pattern of sustainable development, which should be the way forward. 6.537 FoE suggest that there is considerable concern and criticism from various quarters about the sustainability of the Governments Sustainable Communities Plan (Document D609), in relation to the Barker proposals for even higher housing figures and in various other matters. As I explained at the inquiry, however, Government policy is not an appropriate matter to challenge at an inquiry into a specific planning application or road proposal. 6.538 Although development should to some extent be focussed on the Thames Gateway, to do so to the extent currently envisaged may be unsustainable; for example, with regard to the availability of water-related infrastructure. This would be tested through the regional spatial strategies for the East of England, South East England and, in due course, London. 6.539 TfLs evidence is that 45mins is the average travel to work time, resulting in an average trip length of 21km at the average traffic speed (D808 table 14.7). Comparison of that statistic with data from the 2001 National Census (Document TfL/82) that the average car trip to work in London was 9km long shows that the scheme would lead to travel behaviour that would be less sustainable than the present average.
274
Planning policy 6.540 Policy 3C.15 of the London Plan (D620) sets out six criteria against which road schemes should be tested. They are listed at paragraph 4.212 above. Having regard to these: a. The scheme would increase the traffic capacity of the corridor it would establish but, because other better ways to support regeneration could be found, is not essential to regeneration: and so the second criterion in Policy 3C.15 is not met. b. The scheme would provide no net benefit to Londons environment: and so the third criterion in Policy 3C.15 is not met. c. The scheme would provide no net improvement to safety: and so the fourth criterion in Policy 3C.15 is not met. d. The scheme would cause a deterioration in conditions for pedestrians and cyclists in particular: and so the fifth criterion in Policy 3C.15 is not met. 6.541 The scheme as revised by the promoters during the inquiry now fails the test of Policy 3C.15 in another way: the reduced regeneration benefit is such that there is now no very substantial benefit to the local economy as a result of the scheme. 6.542 It is therefore not the case that, in the terms of policy 3C.15, the benefits of the scheme would very substantially outweigh its disbenefits. 6.543 The Greenwich UDP Second Deposit Draft (2004) (D617) expresses, in the narrative text at paragraph 7.30, that first The Council does not support road schemes that lead to a generalised increase in road capacity, especially if they could be used for more radial, car based commuting. and secondly Schemes should also be designed to improve safety and convenience for pedestrians and cyclists... The scheme would satisfy neither of these tests. Alternative proposals 6.544 TfL have not followed advice in WebTag unit 1.1 which is to answer the questions Are there better ways to achieve the objectives? and Does the scheme provide value for money? The scheme therefore fails, in that it did not result from a process of evaluation and direct comparison with alternative policy measures or schemes (walking, cycling, public transport infrastructure); nor is there now any such alternative against which the schemes performance could be compared, or the extent to which it is essential to regeneration. This reveals an underlying bias in favour of highway schemes as opposed to public transport.
275
6.545 Had such an evaluation process been undertaken, the scheme should have been shown to produce the best results in absolute terms of regeneration, or to produce the best combination of regeneration benefits and disadvantages in other respects. In the absence of that, decision makers should consider who would be the main beneficiaries of the scheme, and whether the scheme benefits those who most need to benefit. 6.546 It would be wrong to invest substantially in new highways to support car use; rather, much more could be done to support public transport, walking and cycling in the area if the scheme was not being promoted. 6.547 In A Transport Strategy for London (Document TfL/180), published in 1996, the Government Office for London and DfT identified the consequences of not providing additional crossing capacity east of Tower Bridge. Those were considered to include continued or worsening congestion at existing crossings and their approaches, poor accessibility for local residents and businesses and the reduced competitiveness, longer journey times and higher transport costs. But the scheme would add traffic to the wider area, thereby tending to increase congestion. There would be other ways to improve accessibility for local people, and the importance to business of better accessibility would depend on the nature of the businesses attracted to the area; the area could be very competitive for some green technologies and for firms with sustainable travel behaviour. 6.548 FoE were unable, in cross-examination, to identify any additional nontransport measures that might address problems of deprivation in this area of South-East London beyond those proposed by the promoters and their supporters. Regeneration - development 6.549 A report commissioned by the ODPM, Relationship Between Transport and Development in the Thames Gateway (the Four Consultants Report) (Document 1991/1/110) found that major development growth in the Thames Gateway therefore implies some mix of the following: increasingly congested road network; substantial mode shift to non-car modes (from both existing and new development); substantial increase in both local and strategic road capacity. 6.550 The House of Commons Environmental Audit Committee published on 30 March 2006 a report Sustainable Housing: A Follow-Up Report which includes the view that The need to build new homes is seen as an absolute imperative and is used by the Government as a mandate to sweep aside any concerns that people may have about the environmental impacts of those plans. In an accompanying press release, the Environmental Audit Committee said We remain deeply concerned that ODPM is determined to build new homes first and then worry later, if at all, about how the supporting infrastructure (believed to be water infrastructure) can be created. The communities that are created as a result of such a short276
sighted policy will be anything but sustainable. It is therefore apparent that the amount of development that happens in the area affected by the scheme could be constrained. 6.551 Matters such as water availability and air quality are likely to impinge, through the SEA process, on the current revision of the London Plan. Currently planned increases in jobs and population are not necessarily fixed. Regeneration - employment 6.552 CB Richard Ellis, a leading real estate services firm, has published a report Transport Infrastructure: Changing the Face of the London Property Market (Document 1991/1/138) which considers the effects of the scheme, among other proposals. The authors consider that from a commercial property perspective the scheme offers potential, as yet unquantifiable, benefits to East London Boroughs; and that distribution and warehouse schemes are likely beneficiaries in the Eastern Corridor. FoE notes that these tend to be low density and low employment businesses, contrary to the goal of having a strong and diverse economy. Regeneration - accessibility 6.553 The Four Consultants Report (Document 1991/1/110) found that the schemes potential benefits to business locally would not be great in scale and could even be counterproductive because of added congestion, particularly in the north. 6.554 The promoters evidence is that the schemes regeneration benefits in Bexley may be nil. Improving accessibility can reduce employment among local people if local jobs are taken, as a result of the improved accessibility, by people living elsewhere. In Newham, accessibility is high and Canary Wharf is close by, but nevertheless Newham remains the third most deprived Borough in England. Issues other than accessibility must be at play. Thus there are many better ways to improve access to jobs locally than by building the scheme. 6.555 The report of the Social Exclusion Unit, Making the Connections, dated February 2003 (Document 1991/1/113, chapter 5) sets out a new approach to accessibility planning, whereby local authorities and other agencies might assess whether people facing social exclusion can get to key activities and then devise solutions. This includes a potential menu of 35 candidate solutions for improving accessibility, none of which includes road-building. The same report finds (page 2) that only two out of five jobseekers find lack of transport a barrier to getting a job (1991/1/113). Data from the National Census shows 49% of households in Newham and 41% in Greenwich do not own a car (Document 1991/1/145). 6.556 Regeneration is a more complex issue than suggested by TfL. Regeneration should improve deprived areas more than other areas; but the scheme
277
would not and so would fail those most in need. This would be contrary to the view taken by PPS1 in support of social inclusion and the reduction of social inequalities. 6.557 Research by Aalborg University on travel behaviour as reported in the 2001 Census for England and Wales has found that more people make lengthy journeys to work, particularly in the London area; that the average travel to work trip among the 25 million people studied was 11 km (about seven miles) as the crow flies and took 20 minutes; and that commuting journeys now tend to avoid the largest urban centres, especially London, as people try to miss congestion. 6.558 Tables 1 to 5 of Document TfL/175 show that, according to TfLs own calculations, less than 400 people would use the bridge to travel from home to work wholly within the local Boroughs if Crossrail were not built. 6.559 The main beneficiaries of the scheme, in Professor Goodwins estimation, would not be local people using the bridge to commute to local jobs. Such trips would account for only 6.5% of the (non-public transport) journeys across the bridge during the morning peak hour. Thus 93.5% of the peak hour trips by private vehicle over the bridge would benefit others. This is consistent with the finding that car ownership is low in the wards nearest the site of the bridge. 6.560 An increased choice of facilities and jobs through increased access may seem positive and beneficial, but may, through increased pollution and congestion, be to the detriment of others or of society as a whole. It may also increase competition for jobs or for customers. This was found to be the case in the M74 inquiry, the report of which (Document 1911/1/160) considered that Better accessibility would open up job opportunities for people over a wide area, to the possible disadvantage of local people. The SACTRA 1999 report (Document ADD/015) shows the two-way street argument, whereby improved access opens an area up to external competition, to be an important consideration for a scheme in a deprived area. 6.561 Information from the DfT, reported in Regeneration and Renewal magazine on 3 February 2006, identifies that the last decade has seen some uncoupling of traffic and travel growth from economic growth. Since 1992, GDP has grown by 42%, while national travel, measured in passenger miles, has increased by only 16%. Previously it was thought that transport growth and economic growth were linked. 6.562 Evidence submitted by LB Bexley (Map 3A, Document 1774/3/B) shows those wards in Bexley that were among the top quartile of deprived wards in England in 2004. Evidence for the same area submitted by TfL (Document TfL/REB/4983/2), copyrighted 2006, showing super-output areas in Bexley among the top quartile, identifies that North End and Colyers are no longer in the most derived quartile. This implies that
278
regeneration is happening anyway. Tolls - discount area 6.563 The revision to the proposed toll discount area, made during the inquiry, would exclude wards in the top quartile of deprived wards in England in 2004 which were previously included. The omission of key deprived wards from the discount area and loss of regeneration benefits as a result of the change in the proposed tolls is serious, and undermines the schemes stated purpose of helping local regeneration. Traffic model 6.564 Professor Goodwins evidence is that the traffic generation to 2016, as predicted in the model, need not occur. Rather, research (not presented to the inquiry) has shown that the application of best current practice in transport could cut travel demand by up to 33% in large urban areas. 6.565 Other factors which the model wrongly omits include: a. The recently approved widening of the A2 between Pepper Hill and Cobham, near Gravesend (Document 1991/1/142), which must bring more traffic towards the area. b. The Central London Congestion Charge was modelled by the promoters as 5, whereas it is now 8. The traffic model on which the scheme assessment is based should be re-run with the correct data. c. The effect of a possible planning condition to limit traffic on the bridge, such as set out in Document INQ/23. 6.566 The modelled effects of the change made to the proposed discount area during the inquiry show that the schemes regeneration benefits are sensitive to changes in the toll regime, whereas the environmental consequences of the scheme are not. 6.567 Table 3 of Document TfL/240 shows similar growth in traffic between 2003 and 2004 in Bexley, Greenwich and Newham, raising the possibility that the unexpected growth found in Bexley between 2001 and 2005 also occurred elsewhere. 6.568 The assessment year is 2016, but traffic would grow for a further 5 years. The adverse effects of the scheme would become worse than those identified in the ES. Tolling
279
6.569 The Technical Case Report (Document TfL/60) states at paragraph 21.3 that the largest impact of a toll increase of 1 would be to reassign traffic away from the scheme, rather than to cause a mode shift to public transport. Thus the changed toll whose effects are reported in Document TfL/202 (page 8) should show some trips to have transferred from the scheme to the crossings at Blackwall or Dartford, but this is not the case. Traffic congestion 6.570 TfLs evidence is that the scheme would increase traffic by 40,000 vehicle kilometres in the morning peak hour alone. There would be localised traffic increases. The scheme would have little effect on other river crossings. 6.571 The Four Consultants Report for the ODPM found that congestion on existing crossings east of Tower Bridge would be not significantly alleviated by the additional capacity provided by the Thames Gateway Bridge and Silvertown Link (Document 1991/1/110 section 3.4). Use of the scheme by long distance traffic 6.572 According to TfLs model, 64% of the traffic on the bridge during the AM peak hour would be making trips either starting or ending outside the local Boroughs. These trips would pass through the Boroughs to the north of the bridge, or to the south as the case may be, bringing adverse effects with no compensating benefit. 6.573 TfLs view that the scheme is not designed to be part of a strategic route is disingenuous in that it implies that only through traffic is long distance, and that trips that either start or end in one of the 4 Boroughs are local. Even journeys within the 4 Boroughs could be of considerable length up to 22 km. Journeys termed local by TfL are not necessarily short. 6.574 Most TGB users would be in cars. Tolls are unlikely to be effective in discouraging longer-distance travel, because the toll cost would be only a small part of whole trip cost. The scheme would disproportionately encourage longer distance travel and commuting, particularly by private car. Traffic mitigation 6.575 Mitigation measures to address traffic and congestion problems can cause loss of access, to the disadvantage of residents and local businesses. Form of the scheme 6.576 The possibility of all six lanes on the bridge being used for general traffic was a source of concern for David Begg, a Member of the Board of TfL, when considering the scheme at a TfL Board meeting on 24 March 2004
280
(Document 1991/1/159: FoE note of meeting). Public transport 6.577 Information from the 2001 Census (Document 1991/1/145) shows some 49% of households in Newham and around 41% of households in Greenwich to be without a car or van. The London Travel Report (Document 1991/1/136) shows that in the wards closest to the scheme the availability of cars is also low, with between three and four people to every car. The imperative to maximise public transport travel is all the more important. 6.578 TfLs evidence (Document TfL/60) shows that modal transfer from car to public transport is not sensitive to journey time savings; rather, improved public transport travel times resulting from the scheme would lead to a transfer of public transport passengers from other public transport routes but not to a substantial modal shift. Overall, the scheme would reduce the proportion of trips made by public transport. Non-car travel 6.579 TfLs evidence is that the scheme would reduce public transport travel in the four Boroughs by 1% overall. Furthermore, the scheme is likely to worsen conditions for cycling and walking due to extra traffic generated by the scheme. Because the scheme is so tailored to the private car, its effect in respect of matter 4(b)(ii) in the Secretary of States call-in letter (maximising use by non car modes of travel, particularly public transport, cycling and walking) is negative. Combined effect with Crossrail 6.580 If Crossrail were to proceed, an evaluation of complement and feed into Crossrail would seem TfLs evidence (TfL/60, paragraph 20.5) is that then public transport services on the TGB would 36%. how a bridge might best a sensible approach. But if Crossrail were in place drop off significantly by
6.581 There is no evidence of the change in traffic patterns that would take place at Blackwall if Crossrail were in place. Health implications of the scheme 6.582 The scheme would not be likely to reduce health inequalities, but would bring extra problems to people who already suffer environmental degradation. Poor people tend to live near busy roads. Noise
281
6.583 TfLs evidence regarding numbers of people disturbed by noise is that some would need to sleep with windows closed and that some schools would be adversely affected. Air quality 6.584 TfLs evidence is that with the scheme, four receptors would exceed air quality limits for nitrogen dioxide, with one new exceedence, and that some homes near three receptors would have significant increases in nitrogen dioxide when measured against criteria established by the Association of London Government. It is immaterial that much of the additional traffic generated by the scheme would be that using the scheme itself; additional emissions and air pollution would still result from that extra traffic. 6.585 Paragraph 19 of PPS1 establishes that development should avoid significant adverse impacts on the environment. Rather, alternative options which might reduce or eliminate those impacts should be pursued. It is not acceptable knowingly to breach air quality limits: schemes which would have such an effect should be rejected. PPS1 emphasises the importance of integration of environmental and other objectives. 6.586 It is misleading to express the increase in vehicle emissions associated with the scheme as a percentage of national figures, as the ES does (D808, 16.7.22) since this makes the schemes effect look relatively small, whereas its effect would not be small. Although TfL have sought to mitigate the local environmental disbenefits of the scheme, some such effects for example reduced air quality or increased noise - may not be capable of being fully mitigated. 6.587 The WHO holds that there is no no-effect level for PM2.5 particulates (Document 1991/149). In September 2005, the EU Environment Commissioner announced that new measures would be proposed to control concentrations of fine particulate matter (Document 1991/146). TfLs evidence does not identify the number of people or households that would be affected by nitrogen dioxide exceedences if the scheme were built. 6.588 Adverse environmental effects on air quality and noise associated with the scheme would not be minor, as TfL claim, because they would affect thousands of people, and because they would in some locations cause conditions to change from better than an acceptability threshold to worse. Such effects identified by TfL as moderate adverse should be considered to be very serious. Global warming and climate change 6.589 The possibility of climate change is increasingly recognised, for example by the EA (Document 1991/122) and the London Climate Change Partnership, which includes the GLA (Document 1991/133). The predicted effects in London include summer droughts, increased risk of flooding, more smogs
282
and more smog-related illness such as asthma. Carbon dioxide is a principal greenhouse gas, believed to cause climate change when present in the atmosphere. 6.590 The 2003 Energy White Paper (Document 1991/102) accepted the Royal Commission on Environmental Pollutions recommendation that the UK should put itself on a path towards a reduction in carbon dioxide emissions of some 60% from current levels by about 2050. This is reiterated in the Second Annual Report on the implementation of the Energy White Paper (Document 1991/103), published in 2005. PPS1 also notes the importance of climate change impacts. Nevertheless, carbon dioxide emissions have risen since 1997. 6.591 The DfT priorities for 2005 to 2008 include, jointly with DEFRA and the DTI, reduction in greenhouse gases in accordance with the Kyoto Agreement and other targets (Document 1991/126, target 7). The Transport White Paper of 2004 (D108) sets out Government targets for the reduction of carbon dioxide emissions by surface transport. 6.592 The issue of climate change has been seen as increasingly important in the time since the ES was published. This is illustrated by Document 1991/121.
6.593 The estimated proportion of all greenhouse gas emissions in the UK that comes from transport varies according to the views of different estimators, but is generally thought to lie in a range between about 21% and about 32% (Documents 1991/104 and 107). In the case of the inquiry into the proposed M74 northern extension, the Reporters noted that the scheme was likely to increase carbon dioxide emissions by about 86,600 tonnes in 2010 and about 134,800 tonnes by 2020. They considered this to be a significant step in the wrong direction, requiring an even greater effort to be made if international accords such as the Kyoto protocol are to be achieved (Document 1991/160, paragraph 11.43). 6.594 Other authoritative sources to advocate reduced carbon dioxide emissions from transport include the UK Sustainable Development Commission paper Climate Change Programme Review (2005) (Document 1991/117) and the Inter-departmental Analysis Groups paper Long-Term Reductions in Greenhouse Gas Emissions in the UK published by the DTI in 2002 (Document 1991/109). 6.595 In London, the seriousness of climate change and transports role in it is also realised, for example by the Mayors Energy Strategy the Mayor is working to deliver an exemplary sustainable transport system for the capital that contributes to reductions in carbon dioxide emissions. The Mayor wants to encourage people to switch from private vehicles to public transport, walking and cycling (Document 1991/127, page 13). Private cars account for about 10% of UK carbon dioxide emissions.
283
6.596 Recent work has shown that carbon dioxide reduction from transport is possible to the level required by national policy, but that it would require behavioural change. Even in the case of long-term goals, it is important that action is taken now to avoid dangerous climate change, rather than procrastinate in the hope that a future innovation will solve the problem. But TfLs evidence is that the scheme would result in the emission of an additional 55,000 tonnes of carbon dioxide in 2016 (D808, table 16.7). Public consultation 6.597 Planning decisions should deliver good governance. PPS1 refers to the importance of community involvement in planning. But the public consultation about the scheme was deficient in various ways: a. Consultation by TfL in 2001 on the then Draft Transport Strategy is reported in Document 1991/108. This identifies that almost half of respondents thought the proposal to construct new rail lines, new Thames crossings in East London, and new high quality tram or guided bus scheme was very important. But the way in which the relevant question was framed did not indicate that the new Thames crossings would include new road crossings; furthermore, the telephone questionnaire which formed a large part of the survey did not allow respondents to support the public transport river crossing proposals without also supporting the scheme. TfL confirm that at the time it had not been decided to include new road crossings in the proposals. The Mayors Transport Strategy is not specific as to whether the scheme should be road-based or not have a road element. It is therefore wrong to place any reliance on those consultation findings as expressing any specific degree of support for the scheme. b. Consultation by TfL during 2003 offered no options, did not make available proper information, and information was changed during the consultation period. This consultation was therefore flawed and invalid. c. Public awareness of the scheme was low during the planning application consultation period. d. It is likely that many people were unaware of the changes identified in TfLs changed traffic evidence, when responding to consultation before the inquiry. e. Changes to the toll discount area proposed by TfL during the inquiry have not been satisfactorily publicised. The parts of Bexley previously, but not now, proposed to be in the toll discount area should have been leafleted and further outreach work undertaken in that area. People living there who previously supported the scheme might now not do so if the new position was made known to them. f. Notwithstanding the findings of TfLs modelling of congestion with and
284
without the scheme, there is a wide public expectation that the scheme would relieve congestion, and this influenced the outcome of the public consultation in favour of the scheme. Response by TfL to the objection of FoE Sustainability 6.598 TfL consider 45 minutes to be the maximum reasonable travel time to and from work. If this can be achieved, then most such trips would take less than 45 minutes. There is no evidence before the inquiry that average journey to work distances for private cars with the scheme would significantly exceed the current London average journey to work distance. Planning policy 6.599 The consistency of the scheme with the development plan is dealt with in chief. Alternative proposals 6.600 Development of the scheme considered a number of alternative crossing types and locations, tolling regimes and options for the provision of public transport. Regeneration - accessibility 6.601 The Four Consultants Report (Relationship Between Transport and Development in the Thames Gateway, 1991/110) says that the case for the crossing between Beckton and Thamesmead does not just relate to releasing the potential of sites that would otherwise be constrained; it would also help develop economic and social links in this part of the Thames Gateway, and would be assisted by DLR Woolwich and by Crossrail. Its authors also consider that: a. Major development growth in the Thames Gateway implies a combination of an increasingly congested road network, a substantial shift to non-car travel, and a substantial increase in local and strategic road capacity. b. Notwithstanding the principles of PPG13, realistically there are few locations outside established centres where this can be achieved, and in reality few sites can achieve the density of access routes by non-car modes to limit car use substantively. c. Car use can be constrained by housing densities consistent with PPG3 in conjunction with good public transport routes.
285
d. Major new employment sites need car accessibility because employees are dispersed. 6.602 A report by Atkins Transport and Development in the Thames Gateway prepared for the Thames Gateway London Partnership (Document 1752/1/B, appendix 18) observed that the scheme and other transport improvements would in all likelihood generate jobs and thus encourage housing take-up. 6.603 Regeneration is not just job creation; it includes housing and population as well, and these in turn lead to increased employment. TfL promote a series of measures as well as the scheme to bring about regeneration, and FoE suggests nothing more. The PFI credits available for the scheme might not be available for other measures instead. 6.604 Notwithstanding the two way street argument regarding accessibility to jobs, up to a third of new jobs may be taken up by local people. It would be wrong to seek to provide only low skill jobs simply because the local population is currently low-skilled. Even if it were the case that two out of five people in East London find lack of transport a barrier to getting a job, rather than nationally as the Social Exclusion Unit reported, that would remain a relatively high figure. 6.605 The view presented in Regeneration and Renewal magazine is that high levels of traffic growth need not be the consequence of economic growth. This gives no reason to reconsider the potential regeneration benefit arising from better accessibility. Tolls - discount area 6.606 There is a strong regeneration case for the scheme, but certain deprived areas to the east of Bexley are not included in the proposed discount area. Traffic model 6.607 The TfL traffic forecasts represent very significant success in containing growth in car use compared with the National Trip End Model and the Trip End Model Presentation Program (TEMPRO) forecasts. The latter indicates growth significantly higher than the TfL forecasts. Tolls 6.608 Higher tolls on the scheme would not divert users to other crossings; rather, journeys will instead continue to be made to the destinations that would prevail without the scheme. Traffic congestion
286
6.609 The finding of the Four Consultants Report (1991/110) that the scheme would not alter congestion on existing crossings east of Tower Bridge is irrelevant, since the scheme is not intended to reduce congestion. Use of the scheme by long distance traffic 6.610 TfL accepts that some trips that start in one of the four nearest Boroughs and end either inside that area or outside it could be of considerable length. But it is wrong to assume that most such trips will be long. 6.611 The proposed tolls would not be incurred by public transport passengers across the bridge. Non-local residents would pay a higher toll than local residents, but would achieve proportionately smaller time savings if they used it. Apart from the scheme, measures are being taken to increase use of public transport, and those would be improved by the scheme with its public transport provision. Non-car travel 6.612 The scheme would be one of a number of measures. Crossrail and the DLR extension to Woolwich would increase the public transport modal share to around 50%. Health implications of the scheme 6.613 Air quality is expected to improve over the next ten years. The scheme would only defer that improvement by a small amount for some people. Even with the scheme, air quality will improve due to national measures to reduce motor vehicle emissions. The scheme would benefit people, poor or otherwise, who live near busy roads because noise levels would fall. Noise 6.614 FoE ignore TfLs revised assessment of night time noise. As to schools, the noise levels would remain below the WHO level of 50 dB for the onset of community annoyance.
Air quality 6.615 The scheme would not result in any new exceedence of air quality limits for nitrogen dioxide; it would defer the improvement of air quality to meet recommended limits at some locations. Public consultation
287
6.616 TfL published an Interim EIA for the scheme three months in advance of the planning application, and an ES accompanied the planning application. As FoE give no reason for their view that TfLs assessment of support for the scheme is unreliable, it is hard to respond; the consultation process was thorough and comprehensive and its findings were generally consistent. London City Airport (LCY) 6.617 LCY opened in 1987, and now serves 25 European and UK cities. In 2004, it handled just under 1.7 million passengers. It employs some 1,700 people. The Airport is growing rapidly, and has planning permission for 73,000 scheduled air transport movements per year. It is estimated that this will allow LCY to handle at least 3 million passengers per year by 2010. 6.618 LCY is subject to regulation by the CAA. Under Article 103 of the Air Navigation Order 2000, the CAA must be satisfied that the aerodrome is safe for use by aircraft, having regard in particular to the physical characteristics of the aerodrome and its surroundings. Safeguarding the airport 6.619 To protect the safety of aircraft and to ensure the continuing operation and development of airports, a system of safeguarding has been developed. This involves a series of surfaces or zones around the airport, which are delineated on a safeguarding map, and within which development proposals are considered as having the potential to cause an adverse impact on airport operations. 6.620 These issues are particularly complex at LCY, because it is surrounded by an ever expanding and demanding obstacle environment, given the scale of proposed developments within the City of London and in the Thames Gateway. 6.621 Safeguarding is dealt with by the airport operator, but is handled in close liaison with the CAA. The CAA has no planning powers. If it is not satisfied that an aerodrome is safe, for example because of the grant of planning permission for a development which would have a negative impact on the operation of an airport, the only course of action open to the CAA would be to withdraw the airport licence or to place conditions on the use of the airport. 6.622 LCY was formally consulted on the main bridge applications. Its position is that it does not object to the principle of the TGB, but must ensure that safety considerations are fully taken into account so that the licence of the airport to operate would not be prejudiced or limited. 6.623 The hybrid form of the applications means that there is no definitive information about the final height or design of the bridge and associated
288
structures. LCY has therefore discussed with TfL the way in which its concerns could be met by appropriate conditions on any planning permissions granted. 6.624 The first issue to be resolved concerns the height of the bridge and bridge furniture such as lighting columns and possible catenaries for any future tram system. These could present a physical obstacle to aircraft movements. A related issue concerns the height of cranes and plant which would be used in the construction of the bridge. 6.625 The next issue concerns the impact the bridge would have on the communication, navigation and surveillance systems. This would turn on the construction materials used in the building of any bridge. 6.626 There are also concerns about the external lighting in and around the bridge in terms of the confusion and distraction it could cause to pilots of approaching aircraft. 6.627 Finally, there are concerns regarding the attraction of birds to the development proposal arising from the choice and height of trees planted. If birds are attracted to the landscaping associated with the development, this could cause an increased threat of bird strikes to aircraft operating at LCY. Planning conditions 6.628 All of these matters could be addressed, however, by conditions in the form agreed with TfL which were discussed at the round table session on conditions at the inquiry on 7 October 2005. 6.629 LCY has secured as much technical detail as possible of the scheme at this stage, accepting that the hybrid nature of the applications means that final details cannot yet be provided. The detail available has been considered on a worst case scenario as to penetration of the safeguarded surface. Specialist technical reports have been obtained (Documents 2054/4, 2054/5 and 2054/9) which satisfy LCY that the proposal would not pose a safety issue for the airport, so long as the agreed conditions are imposed on any planning permission. Those conditions would provide for LCY to be involved in the agreement of the final detail on the issues identified above. Subject to satisfaction on the detail at that stage, LCY would be able to present the issue to the CAA with confidence that the airport licence would not be prejudiced. 6.630 That cannot be done at this stage, because the CAA would not agree to reach a conclusion until the final detail was available. That is why LCYs objection must technically remain outstanding, in order to secure the necessary conditions on any planning permissions, and to preserve LCYs right to make an input to the discussion of details at that stage.
289
Response of TfL to the objection of LCY 6.631 TfL understand the position of LCY. TfL would be content with the imposition of the agreed conditions on any planning permissions. London Cycling Campaign 6.632 The London Cycling Campaign (LCC) has existed for more than 25 years, and has more than 10,000 members. It is a company limited by guarantee, and is run by a Board of Directors. A letter authorising the objection was submitted by one of the Directors on behalf of the Company (Document 2714/1/A1/2). 6.633 LCC reported that their case was supported by the Cycling Tourists Club, who supplied one of their witnesses, and that due authority to that effect would follow. No such authority was received. Cycling 6.634 PPG13 requires that cycling should be maximised. The London Cycling Action Plan (Document TfL/326), published in February 2004, includes a Foreword by the Mayor setting out a long-term target of a 200% increase in cycling in London and an 80% increase by 2010. These targets are insufficiently ambitious. 6.635 The scheme was prepared with no systematic consideration of the needs of cycling. The addition of cycle facilities at a late stage in design tends to produce reduced benefits for cycling in comparison with that which could have been achieved if they had been included from the start. Consequently, the cycle facilities now proposed as part of the scheme have no appreciable utility for the encouragement of cycling. 6.636 This lack of utility is manifest in the following ways: a. Non-compliance with design standards for cycle facilities: The margin between the proposed cycle facility on the bridge and the public transport lane is proposed to be 0.5m but should be wider, because traffic in the public transport lane would travel at high speed (over 30 mph) and there would be the risk of gusts blowing cyclists into the path of buses. The cycle route across the bridge would be too steep for too long; Local Transport Note 1/89 (Document D536) recommends a 5% maximum gradient for lengths up to 100m and a 3% maximum gradient for lengths of over 100m. The new bridge would have a 5% gradient for over 100m. The combined effect of crosswinds and the long, steep section would make cycling difficult. b. Time penalties and loss of priority: Cycle and pedestrian facilities with Toucan crossings would be provided at each end of the scheme.
290
However, these would force users to wait for twice as many signals as drivers would. Such delays would reduce the comparative advantage of cycling and walking still further, and make them even less attractive. c. The effect of wind: TfLs evidence is that for 25 days each year the wind would be too strong for walking and cycling on the bridge. This would introduce an element of uncertainty that would not be acceptable for other modes, and would deter cycling or walking across the bridge for trips for which reliability is important. Even when winds are not at gale force, cycling would be difficult for much of the year; the combined effect, for example, of a crosswind and a 5% uphill gradient would probably force all but the fittest to dismount and push. d. Length of diversion to use the bridge: Cycle trips in London average some 3.6 km, although commuter trips are longer with an average maximum distance of 8 km. It is important to cyclists that they should have a convenient route between the start and finish of their journeys, but the cycleways associated with the scheme would cause a long diversion of up to a kilometre from the proposed road, near the Winsor Terrace junction, and so may actively discourage cycling. e. If, as suggested by TfL in cross-examination, speed-reducing measures such as barriers and chicanes were put on the cycle route across the bridge to constrain the speed of descending cyclists, then it is likely that some cyclists, would instead use the public transport carriageway to descend from the crest of the bridge. Police enforcement of the proposed Traffic Regulation Order that would forbid this is a matter of conjecture. 6.637 The scheme would also affect journey times and the relative advantage of cycling in the following ways: a. As there are few trip generators around the scheme, it would assist very few potential cycle journeys. b. Many cyclists in London use the road network, as opposed to off-road facilities, for example in Bexley which has few cycle facilities. Elsewhere too, on-street facilities for cyclists are often absent or inadequate. The scheme would increase motor traffic flow on a very significant number of on-street routes of high or medium impact for cyclists, thereby putting cyclists there at a relative disadvantage. The A206 Woolwich Road, for example, is a designated cycle route, where traffic would increase as a result of the scheme. However LCC were unable, in cross examination, to identify any further locations where this might happen or to identify the extent to which cyclists use any route affected by the scheme. 6.638 The London Cycling Action Plan confirms that social factors can be barriers to cycling as important as physical ones. Just as the Congestion Charge made many think about alternatives to driving, such as cycling, so the high
291
capacity new road bridge would make many people forget alternatives to driving. Road safety 6.639 The traffic increases that the scheme would cause are likely to increase the risk that cyclists perceive in using the roads, and so deter people from cycling. Traffic mitigation 6.640 TfL propose traffic management measures which may include traffic signals, one-way streets and traffic calming. Such measures can increase danger and discomfort for cyclists, and so are likely to discourage people from cycling. Furthermore, no measure is proposed to mitigate the substantial negative effects the scheme would have on cyclists. Regeneration - accessibility 6.641 TfL seek to draw parallels between the scheme and bridges in West and Central London. However, those are short in comparison with the scheme, with lower traffic speeds. Whereas the existing crossings are well-used by pedestrians and cyclists, this is unlikely to be the case for the scheme, which would therefore be less effective in reducing severance between communities near the river on either side. 6.642 There is no evidence that trips crossing the scheme, with substantially different length and mode characteristics, would have the same positive effects that TfL suggest contribute to the differences in wealth in different parts of London. TfLs case regarding regeneration and accessibility is based on a false premise. Therefore the scheme would not discourage lowdensity development in the green belt and green spaces, as TfL claim; thus it does not follow that, overall, the scheme is consistent with PPG13s objective, despite TfLs assertion to the contrary. 6.643 A report commissioned by the ODPM (Document 1991/1/110) notes that it has several times been found difficult to make a strong regeneration case for new road crossings of the Thames, because the benefits are thought to consist partly of improved image and perception - which is difficult to quantify. This casts doubt on TfLs evidence regarding regeneration and access. Form of the scheme 6.644 The scheme cannot be of great architectural merit because of the physical constraints on its form, and so the alternatives suggested by LCC could have a greater effect on image than the scheme would.
292
Global warming 6.645 The increased carbon dioxide emissions associated with the scheme would be reduced if more people travelled by cycle. However, the scheme could encourage motorised travel to an extent greater than considered in TfLs evidence, thus making carbon dioxide emissions far worse in the long run. Health implications of the scheme 6.646 Contrary to the view expressed in the ES (D808), the scheme would have a negative effect on cycling and walking, for the reasons given, and thus on health. Alternatives 6.647 The promoters use the notion that the scheme is part of a package of improvements to justify its very poor modal split. However, the package is particularly lacking in cycling proposals, and there are only indirect improvements for pedestrians. Those omissions should be rectified by the following measures: a. A series of combined cycle and foot bridges between Tower Bridge and North Greenwich with a cycle and foot tunnel at Silvertown, tying communities together across the river and giving cycling a great competitive advantage. b. Beyond Woolwich the river is too wide for fixed crossing which would be of benefit to pedestrians and cyclists. The increased population associated with the Thames Gateway would make viable new ferry services. River commuting is increasingly popular in Central London and is an asset to Londons image. Response by TfL to the objection of LCC Cycling 6.648 TfL have systematically considered the potential for cycling in London, as demonstrated by the London Cycling Action Plan (TfL/326). The cycle facilities which the scheme would provide are long-standing proposals, which would include not only those on the bridge, but also new or upgraded facilities in the Royal Docks Road and nearby streets. 6.649 The width of the margin between the proposed cycle facility on the bridge and the adjacent carriageway would comply with the London Cycle Network Design Manual (D537) because combined cycle and pedestrian flows would be low (less than 60 per hour per metre width) and because vehicle flows and speeds would be low in the adjacent bus lane. There is no design or safety requirement for a barrier in such circumstances. While LTN1/89
293
(D536) recommends a 5% cycleway gradient for a length of up to 100m, a shallower gradient is not practical for the scheme because of navigational constraints and the existing road levels on each side. The DMRB document BD29/04 Design criteria for footbridges (D522) gives 5% as the maximum gradient for a footbridge, with no length restriction. 6.650 The Toucan crossings proposed in association with the scheme would be at the Winsor Terrace and Thamesmead junctions, where they would cater for flows in addition to those across the new bridge. 6.651 The scheme would include various cycle routes north and south of the river, providing an extension to the existing cycle network. Opportunities for cycling will increase as a result. Road safety 6.652 Given the length of new carriageway involved, it is inevitable that the scheme would result in an increase of 1.4% in the number of road casualties in the study area. However, the provision of a dedicated cycleway on the bridge would reduce the incidence of cyclists coming into contact with road traffic. Regeneration - accessibility 6.653 The tolling regime would ensure that the bridge was a local crossing only. The scheme is part of a package of proposed measures for transport, other infrastructure provision and social and economic development aimed at transforming the area. Greenwich and Lewisham Friends of the Earth (GLFoE) 6.654 GLFoE is a voluntary group with about 30 members. TGB was authorised by the members. Increased road traffic 6.655 GLFoE notes with concern TfLs estimate that there would be approximately 20 million journeys across the TGB annually. TfL say that private cars would make up around 80% of these journeys. Many of them would be single passenger trips, which would waste resources, generate disproportionately high levels of pollution compared with public transport options, and create demand for more road and car parking space. Even between the peak hours, there would be increased noise from traffic for residents along affected roads, and there would be increased difficulty in crossing roads, causing severance. 6.656 TfL suggest that one of the reasons for promoting the scheme is to provide more reliable journey times for all modes of transport. More reliable
294
Its objection to the
journey times are better delivered by public transport systems, especially rail schemes. Traffic modelling 6.657 During the inquiry, TfL amended the traffic model. There was no confidence in the original model, and there is no confidence in the updated traffic information. GLFoE adopts the criticisms of the traffic model put forward by Professor Goodwin. Regeneration 6.658 There is no correlation between lack of accessibility and deprivation in the regeneration evidence for TfL. The evidence also suggests that the TGB would cause only a slight improvement in accessibility index levels. 6.659 TfLs Statement of Case suggests that the TGB is principally aimed at regenerating areas near the proposed crossing, directing the benefit of the scheme to local traffic as far as possible. But local traffic is not local people, because TfL have defined local traffic as that which either begins or ends in one of the local Boroughs. The other end of those journeys could be at great distance from the local Boroughs and have no connection with people living near the TGB. Both Greenwich and Newham have low levels of car or van ownership (40.8% and 48.9% of residents not having access to a vehicle at the 2001 Census). 6.660 The TGB would generate high levels of through traffic, blighting rather than regenerating areas near the bridge. Pollution 6.661 There would be considerable adverse effects from pollution for local people, both air pollution and additional noise. The TGB would add 55 kilo tonnes of greenhouse gas emissions, contributing to the long term problems caused by man-made climate change. Public consultation 6.662 The public consultation carried out by TfL in 2003 was flawed because it did not give respondents the opportunity to provide a range of responses, for instance whether they wanted a road crossing or a public transport only crossing. 6.663 It is clear that a disproportionate number of individual motorists responded to the consultation, because 74% of respondents said they would expect to drive across the bridge by car, but car ownership in the Boroughs between which the bridge would run is much lower than 74%.
295
Conflict with policy 6.664 The TGB would cause an increase in greenhouse gas emissions, rather than the reduction to which the Government is internationally committed. It would increase road accidents, rather than the reduction in such accidents demanded by Transport 2010: The Ten Year Plan. It would not satisfy Policy 4G.8 of the Mayors Transport Strategy and the parallel Policy 3C.15 of the London Plan, because the uncertain benefits of the scheme would be wholly outweighed by the definite disadvantages. It would not be consistent with one of the most important principles of sustainable development, in that it would not only compromise the ability of future generations to meet their own needs, but also impact on current generations, particularly those living near the proposed bridge. 6.665 GLFoE would wish to see other regeneration and transport options evaluated in order to see what would best help the quality of life for local people. Response of TfL to the objection of GLFoE Increased road traffic 6.666 The estimated 20 million trips across the TGB are not all new trips. majority of them will take place in 2016 with or without the TGB. The
6.667 The aim of providing reliable journey times extends to all modes of transport which would be provided by the bridge. The reliability of bus or tram journey times would be assisted by the physical segregation of two lanes for public transport. This would link the transit networks, as well as an interchange with the DLR. Traffic modelling 6.668 TfL have undertaken an analysis of traffic based on best practice in accordance with Government guidance. The modelling and appraisal methodology has been signed off by the DfT as being fit for purpose (Appendix 2 to Document TfL/P/04/4). Regeneration 6.669 While the proposed changes to the tolling regime following the revised traffic information would reduce the benefits, 75% of the potential increase in jobs is retained. Potential population increases are also reduced, but remain substantial. 6.670 Trips made by local people and businesses and trips to visit local people and businesses are all important, even if it is a delivery, for example, from a local business to a distant customer. Such trips can all contribute to local
296
regeneration, whereas through traffic contributes nothing. Public consultation 6.671 The TGB is one of a package of schemes to increase cross river capacity in East London. These schemes were assessed during the examination in public of the London Plan, quite apart from the 2003 consultation. Action Group Against the Bridge (AGAB) and St Michaels Residents Association (SMRA) 6.672 AGAB is an informal group of local residents opposed to the building of the TGB. Most of them live in Bexley. It was formed during October 2004, when the impact of the proposal on Bexley began to be realised by local people. 6.673 SMRA was formed in about 1935. It is an active community association, run by an elected committee, which meets once a month. It has a membership of over 900, but membership applies to properties located in St Michaels Ward of LB Bexley, rather than to the individuals who live in them. On the other hand, people who do not live in St Michaels Ward are allowed to become members of the Association, and roughly half of the active members of the Association live outside the Ward. 6.674 SMRA produce a monthly magazine, which has covered issues relating to the TGB since September 2004. The Committee of SMRA have authorised an objection to the TGB on behalf of SMRA. The Committee have also supported the objection of AGAB. 6.675 In addition, some 2,376 people had indicated in writing by the close of the inquiry that they wished the representatives of AGAB and SMRA to represent their views at the inquiry. Traffic congestion 6.676 TfL estimate that the traffic flow on the new bridge would be 60,000 vehicles per day. The Dartford Crossing carries about 85,000 vehicles per day but, unlike the scheme, is served by a motorway. 6.677 Visual comparison of the traffic flows at the Dartford Crossing with the newly built homes, other development and proposed schools and parks near the scheme and widespread residential areas beyond into all of which similar traffic flows would be introduced gives rise to horror. 6.678 The scheme differs from the Dartford Crossing, however, in that the scheme would introduce traffic into an existing residential area with a lack of understanding of the real long term problems this would cause. The existing infrastructure in Bexley and Greenwich would be unable to cope
297
with the predicted traffic flows. If traffic levels were higher than forecast, then the situation could be intolerable to residents and to existing businesses. 6.679 Residents in Bexley and Greenwich are concerned that increased traffic would affect roads that are already busy or congested. This would make conditions worse for all road users including public transport passengers, cyclists and pedestrians. There is also congestion on some roads to the north of the scheme. 6.680 As congestion increases, it will cause more delays, stress, accidents, disruptions to daily life and a diminished quality of life. Many residents and roads have poor environmental conditions at present. The scheme would make these worse. Congestion would cause motorists to divert to local residential roads. Appendix 21 of Document 2052/1/B lists some of the current rat runs in Bexley as well as congested junctions, all of which are likely to get worse if the scheme were opened. 6.681 Although the scheme is supposed to aid regeneration, traffic congestion would tend to have the opposite effect. 6.682 Car ownership in the deprived areas near the scheme is low, and so people there would be particularly reliant on the efficiency of the public transport system or the ability to walk or cycle safely. 6.683 In July 2003, the ODPM published a report it had commissioned: Relationship Between Transport And Development In The Thames Gateway (Document ADD/014). Section 5.2.5 of that report considers road crossings of the Thames, at the scheme site and at Silvertown. The authors concluded that There is a scenario in which it can be argued that the [Thames Gateway] Bridge would have a positive impact on development (particularly on the south side), but there is another scenario in which the trip making encouraged by the bridge is of relatively little value to the area, and could even be counter-productive (congestion on the north side). The overall judgement then has to be set against the cost of the Bridge. 6.684 Evidence submitted to the inquiry suggests that congestion would happen on the south side of the river as well as the north side. 6.685 In June 2003, TfL received a report from Halcrow Group Limited (Document TfL/68/1) which reviewed the integration of the scheme with the local road network. In that document, local authorities bordering the scheme were reported to have concerns that traffic associated with the scheme would make existing traffic congestion worse, and that it would cause environmental deterioration on local roads used to access the principal highway network leading to the scheme. 6.686 Dartford Borough Council, in a written representation to the inquiry (Representation 2031), state that Junction 1A of the M25 will be under
298
considerable pressure in future due to committed development; that extra traffic on the A206 to the west of that junction would be undesirable; and that it has declared the Dartford Tunnel Approach Road as an AQMA. 6.687 TfL predict traffic increases in Dartford and Sevenoaks as a result of the scheme, the effect of which is therefore wide-ranging. Traffic in Bexley 6.688 There are many examples of congestion in Bexley. Queues on Brampton Road (AM peak southbound) often extend from the Crook Log junction to the railway bridge, a distance of around 500m. Northbound queues on Brampton Road from its junction with Long Lane often extend around 400m to near Shakespeare Road. Northbound queues also form on the Long Lane approach to the Long Lane/Brampton Road junction, and any further congestion due to the scheme could hinder emergency vehicle response times from the Fire Service and the Ambulance Service depots in Erith Road. Environmental conditions in Brampton Road were better while it was closed to through traffic for road works at its southern end. The footway is too narrow at the railway bridge, and so pedestrians must cross there at a point well-used by children walking from Brampton School to the Crook Log swimming pool. 6.689 Normanhurst Avenue carries approximately 27,000 vehicles on an average weekday. It is used by parents and children. A zebra crossing has recently been provided, but pedestrian safety remains a concern. 6.690 A report commissioned by Greenwich Council, Review of Traffic Modelling (2703/8), suggests that traffic should be diverted from Brampton Road to A209 Wickham Lane. This would be unsuitable. Wickham Lane serves a school, houses and shops. Its junctions with Plumstead High Street and Kings Highway are both congested at peak times. Its continuation as Upper Wickham Lane gives access to further valuable local facilities. Diverting traffic in this way could cause adverse consequences, such as rat running, on surrounding roads. Even if such a change were made, some drivers would continue to use the more direct route via Brampton Road. The route that traffic would follow if passing between the scheme and the A2 via Wickham Lane (as suggested by Document 2703/8) is often congested and has several difficult turns. 6.691 The Reference Case Model shows a 93% increase in traffic in Westbrook Road, off Park View Road. This extra traffic would use Westbrook Road to bypass the signalised junction of Welling High Street and Upper Wickham Lane. Westbrook Road is a residential road with a school and is unsuitable for such an increase in traffic. 6.692 Eynsham Drive in Abbey Wood is predicted by the Reference Case Model to see an AADT increase of 115% as a result of the scheme. Surveyed peak hour flows on Eynsham Drive are much higher than the 2001 peak hour
299
flows suggested by the reference case model. Eynsham Drive serves many local shops, facilities and homes. It is shortly to be the subject of environmental improvements to the value of 783,700. The predicted traffic increase in Eynsham Drive would have adverse effects on road safety, the environment and local quality of life. Eynsham Drive is already traffic calmed. 6.693 Pickford Lane is another residential road with local facilities. Traffic there is forecast to increase by 22% with the scheme. 6.694 Traffic in Crayford town centre is often congested, and that discourages carbased shopping trips. Parking shortages at local shops encourage people to walk there instead of taking the car. 6.695 Generally, road safety is often prejudiced by increasing traffic. Parents are often particularly concerned in this respect for their childrens safety. Increasing traffic will tend to increase footway parking, which causes obstructions for pedestrians. Congestion causes delay to traffic, often making people late for appointments and often causing stress. 6.696 Traffic growth in Greenwich, Bexley and Redbridge has been higher than the average for London. Transport policy 6.697 AGAB supports the findings of the Mr Buchans report (Document 1995/1/B). Traffic model 6.698 Local knowledge should not be discounted as it reflects what a large number of people will do based on actual experience. 6.699 Consideration should be given to whether roads can accommodate the projected traffic increases. Some of the roads likely to be affected already operate at or above theoretical capacity. Extra traffic would therefore affect the surrounding roads. If the planning application for the Belvedere Incinerator is approved, this would add further very heavy large vehicles to the roads in Bexley. 6.700 The model suggests that the scheme would not alter the number of trips made in the area.
Traffic model - reliability
300
6.701 The errors in the original modelling work have been retained, not resolved, and so the revised Cordon Model is not reliable. 6.702 The revisions affect the traffic forecasts, congestion levels, the toll and its structure and the number and pattern of users. One third of all the estimated benefits have gone. The case for the scheme is based on areas of evidence that are subject to considerable uncertainty and risk. 6.703 If Bexley had not raised the matter of inaccuracies in the modelled flows, it would be unlikely that the forecasts would have been revised. 6.704 TfL should have undertaken the 12 further surveys requested by Bexley, because the model should provide reliable forecasts. 6.705 Nor did TfL undertake a survey at the Long Lane/Pickford Lane junction, claiming that none is necessary since the scheme would reduce all flows there. But Document TfL/270, page 6, shows an AADT increase of 11% to arise on that section of Long Lane as a result of the scheme. 6.706 Confidence in traffic predictions by proposers of road schemes must be in serious doubt. Mrs Browns counts (contained in Document 1732/4) are evidence that the model is wrong for Pickford Lane. 6.707 Redevelopment of St Josephs Annex to Bexley College is proposed, and planning permission has been granted for residential use (Document 2052/32). This change of use would reduce traffic at the Woolwich Road/Knee Hill junction. That reduction had already taken place at the time of TfLs traffic survey in September 2005, since the College was closed at that time. The traffic generated by the site when in residential use would differ from that generated by educational use of the site. TfLs traffic assessment does not allow for traffic associated with committed development at the site. 6.708 The DMRBs position on the acceptability of a transport model is that A model that does not meet these guidelines may still be acceptable for appraisal of a given scheme if the discrepancies are concentrated away from the area of greatest importance to that scheme. Conversely, a model that passes the guidelines but has significant discrepancies on the most crucial links may be unacceptable. Traffic modelling - interpeak forecasts 6.709 TfL say they have not revised the interpeak model because, when rebasing of the model was proposed, the concern to be addressed related to the peak period, not the interpeak. TfL agreed in cross-examination that it is probably the case that the interpeak model underestimates the base level of traffic. (Mr Smith, D61, P52, L17-19), and Mrs Browns counts support that view.
301
6.710 The likely outcome of not re-basing the interpeak model is that it would have similar discrepancies to those that were present in the original peak period model and, because there is a greater capacity for traffic growth offpeak, greater growth, congestion and delay is likely during the interpeak period. 6.711 The assessment of interpeak conditions produced by the model affects the estimated AADT. This in turn will affect the estimated environmental conditions with and without the scheme, and may mislead with regard to the effect of the scheme. 6.712 The uncorrected interpeak model may not recognise junctions where congestion would be higher in the interpeak than in the peak period. 6.713 Appropriate modelling work is therefore needed to produce reliable forecasts. 6.714 If traffic growth during the inter-peak period continued at a higher rate than during the peak, journey times for business trips during the inter-peak might be increased. This would lead to a loss of business efficiency and, in the case of the emergency services, an increased risk to life. 6.715 More pedestrians, including vulnerable elderly people and young children, use the streets during the interpeak than in the peak periods. They would be affected by any increase in severance, for example on Pickford Lane and Brampton Road. TfLs view that if severance is not an issue in the peak period then it would not be an issue in the interpeak period is therefore wrong. Traffic model - assignment between A2, Blackwall and the scheme 6.716 Despite TfLs evidence to the contrary, it is likely that destinations to the north of the bridge would be signed from the A2. Even if no such signs were put up, drivers would still be aware of the option of using the bridge by virtue of maps, the internet or satellite navigation systems. The scheme would provide an obvious choice of route. 6.717 TfL rely on the assumption that drivers would choose the cheapest route between origin and destination. But there is no empirical evidence specific to the scheme to support that view. 6.718 Many people would pay a higher toll to use the scheme rather than drive to the Blackwall Tunnel which, although free, would take more time. Many people consider time to be a precious commodity. 6.719 If tolls were introduced at Blackwall, and the scheme was built, then some traffic would transfer from Blackwall to the scheme. Greenwich Council Cabinet Committee resolved on 11 August 2003 to lobby to consider
302
whether to make representations to the Mayor of London to secure the tolling of Blackwall Tunnel when the Thames Gateway Bridge opens (Document D844, page 20, paragraph 5.16(v)). 6.720 Local knowledge leads to the view that the Reference Case traffic model does not show the true impact of traffic transfer from Blackwall on the scheme or on Bexleys road network. A toll would not be a disincentive to non-local traffic using the scheme. Traffic - long distance 6.721 Proponents of commercial development at Erith Marshes claim the site to be well-located for access to Kent, Essex, the rest of the UK, and Europe. The authors of the report commissioned by the ODPM Relationship Between Transport And Development In The Thames Gateway (Document ADD/014) considered the CTRL, Crossrail and the scheme to all be of undoubted strategic sub-regional significance. 6.722 The scheme would be a major strategic link, not a local bridge for local people. The traffic increases would have their worst effect on the very communities it purports to benefit. 6.723 Longer distance traffic and commercial vehicles would be proportionately less affected by a toll increase than would people from deprived areas near the scheme. The proposed tolls for light goods vehicles do not seem large enough to deter through traffic from using the TGB. 6.724 The modelling of traffic transfer from other crossings is unreliable. 6.725 As well as generating new traffic, the scheme would provide an alternative route for use when traffic is held up at the Dartford Crossing, the Blackwall Tunnel or on the A2. Dartford Borough Council (Document 2052/1/B, appendix 1) have noted that this might happen. Although TfL consider incidents at Dartford and Blackwall to be infrequent, Dartford Councils evidence is that the tunnels there were closed 19 times during 2004 for reasons such as the need to avoid stationary traffic in the tunnels. Such incidents would be likely to cause traffic to transfer to the scheme, often via unsuitable roads and giving rise to more traffic accidents. 6.726 The ES (D808, paragraph 14.6.24) shows negligible time savings to arise on the Dartford Crossing as a result of the scheme. TfL predicts slightly larger reductions in travel time through the Blackwall corridor. The revised traffic model shows smaller reductions in travel times on the Dartford Crossing than the original model. The differences are 18 seconds northbound and 10 seconds southbound. 6.727 There must come a point when congestion in and approaching the Blackwall Tunnel is so high as to divert traffic back on to the TGB. This would then
303
require traffic to head north towards the scheme instead of south toward the A2 (as suggested by TfL) increasing environmental impact on the area south of the A206. 6.728 If TfL chose to raise tolls on the scheme to counter transfer from other crossings, then the scheme would benefit local people even less than it otherwise would. 6.729 TfLs model does not reflect the possibility that non-local traffic would travel between the A2 and the scheme other than in exceptional circumstances, such as a closure of the Dartford or Blackwall Crossing. Therefore the model will always underestimate the amount, or effect, of traffic on Bexleys road network. Tolls 6.730 The Itchen Bridge at Southampton, cited by TGLP in support of the scheme, differs from the scheme in that it has higher charges for non-local HGVs than those proposed for the scheme (there are very high non-local HGV charges compared with the 2 to local HGVs), it has only two traffic lanes and it carries only about one-third of the traffic modelled by TfL to use the scheme. Tolls - residents discount area 6.731 Greenwich residents with a discounted toll would be likely to take short cuts to the bridge through parts of Bexley where no discount would be available. 6.732 A reduced discount area would reduce the number of Bexley residents who could benefit from the increased accessibility, and that this would be particularly unfortunate if those people also had to suffer the environmental consequences of bridge traffic passing their properties (1774/36, page 5). Reducing the discount area rather than increasing the toll for longer distance trips does not unequivocally support the principle of a bridge for local regeneration. 6.733 The reduced discount area would create inequity between the residents of Bexley and those of other Boroughs. A resident of the deprived area of north Bexley, who would now fall outside the proposed toll discount area, would see a three-fold increase in toll charges from 1 to 3, an increase from 10 to 30 per week for someone crossing the scheme every weekday by car. In stark contrast, Newhams proposed discount area remains unchanged at 1. One of the key aims of the scheme is to aid regeneration, and yet a third of all of Bexleys benefits have disappeared. The same fate may await the other four local Boroughs. In particular, some of Bexleys most deprived wards would now fall outside the discount area. Only two of the seven 20% most deprived SOAs in Bexley would fall inside the revised discount area.
304
6.734 TfL might further change the discount area, or change the tolls, in the light of operational experience. Such changes would be likely to affect the regenerative effect of the scheme. Further changes to the toll regime would not be subject to scrutiny at an inquiry. 6.735 Greenwich Council seek discounted tolls for all residents of the Borough (2703/53, page 2, paragraph 5.2). A further significant change in the discount area would give rise to a need for further modelling. 6.736 The bridge would be local to residents in Bexley, but they would not benefit from it as other local people would. It would not, as claimed by TfL, be a local bridge for local people. Knee Hill 6.737 Knee Hill is already heavily trafficked, and often operates at over 100% of theoretical capacity. Knee Hill is a road considered by many people to be unsafe. Twenty-five accidents were recorded as taking place over a tenyear period on Knee Hill other than at the A206 crossroads (Document 2052/38), but it was accepted in cross-examination that such a record is not exceptional. It is a two-lane carriageway of an almost country lane aspect, passing through Lesnes Abbey Woods and Bostall Heath. Its carriageway width varies between 6.5m down to 5.1m, as described in Document TfL/295. It might not be able to accommodate the additional traffic that would result from the scheme. Congestion would increase. This again emphasises the need for the model to be accurate and to properly reflect the effects of the scheme. 6.738 The mitigation measures originally proposed by TfL for Knee Hill would be likely to cause congestion. If congestion arose on Knee Hill, traffic would be likely to divert to New Road which runs parallel to Knee Hill or to McLeod Road and Eynsham Drive. Document TfL/208 shows McLeod Road with a 99% increase in two way AM peak hour flow. Knee Hill may require further constraints to be introduced to reduce traffic levels so that flows in the with-scheme case can be accommodated. 6.739 If the right turn from Knee Hill to Bostall Hill was banned as a response to lack of capacity at the junction, peak hour traffic on Brampton Road would increase by 200 pcus. Brampton Road is more sensitive to traffic than Knee Hill. 6.740 Any increase in capacity at Knee Hill would further encourage north-south traffic between the scheme and the A2 through residential Bexley. 6.741 Neither TfL nor Greenwich Council have any proposal to widen Knee Hill, yet many people today consider Knee Hill to be unsafe because it is narrow and steep. Danger arises from northbound and southbound traffic passing. This is graphically demonstrated in the video camera survey of Knee Hill which accompanies Document TfL/295. If traffic increased, then Knee Hill would
305
be less safe and there might be a desire to widen Knee Hill for safety rather than capacity reasons. 6.742 It would be unsafe to introduce more pedestrians on to Knee Hill. Increased traffic on Knee Hill would make it more difficult to cross the road. Traffic - mitigation measures 6.743 The recent traffic calming scheme in Brampton Road appears to have caused some traffic to divert to parallel side roads such as Berkeley Avenue. 6.744 So-called mitigation measures such as traffic calming merely displace traffic on to surrounding roads. If those are mitigated in turn then traffic tends to revert to the original route. Among the examples of this in Bexley are Church Road, Upton Road, Wrotham Road and Berwick Road. 6.745 It is widely accepted that traffic mitigation measures can improve things for some people but make them worse for others. Mitigation measures introduced in conjunction with the scheme would be to the disadvantage of some local people. 6.746 AGAB is not reassured that future plans will not include road widening. 6.747 Although Bexley Council do not want to increase road capacity generally, or to carry out highway improvements in Knee Hill, in future there might be no choice but to increase capacity. Bexley Council are seeking funds for capacity improvements at several places. 6.748 The model predicts that southbound and eastbound traffic from the scheme would disperse along the A2016 and the A2041. Regeneration schemes proposed by Bexley Council are likely to increase traffic on the A2016 route to the A206 Thames Road. Bexley Council want TfL to assess the effects of the scheme at the A206/A2016 Erith roundabout, so that they will know whether to seek funding for improvements there. The recent upgrading of the A206 Thames Road made no allowance for the traffic changes the scheme would cause. 6.749 The bridge would carry only 4,500 vehicles per hour and so would be bigger than necessary. 6.750 Increases in capacity at the Dartford Crossing have not prevented traffic delays; rather, the demand has increased.
Crossrail
306
6.751 It is wrong that the transport assessment for Crossrail, with its terminal station on Harrow Manorway, takes no account of traffic that would be on that road associated with the scheme. Public transport 6.752 Bexley College seek to relocate to Bexleyheath because their current site is poorly served by public transport. The Colleges main site at Tower Road, Erith, has planning permission for residential use. 6.753 This illustrates the importance of good public transport for a College intended to serve residents of a deprived area. Even with the scheme, access to Bexley College by public transport would still be difficult from north of the river without fundamental improvements. Access by car would increase traffic in Bexley, and in particular across the Bexley screenline. Cycling and walking 6.754 The scheme would encourage car travel. Congestion and parking restrictions already adversely affect local small businesses, and any extra traffic caused by the scheme would make this worse. Extra traffic arising from the scheme would also make conditions worse for pedestrians and cyclists, whereas such modes should be encouraged. 6.755 PPG13 advocates the adoption of measures to ensure safe and easy access, particularly by cycling and walking, but the scheme would do little to assist cyclists or pedestrians. Regeneration and training 6.756 Local residents do not have the skills for employment in the competitive environment the scheme would create. Training, not accessibility, is required. But funding for adult education appears to be haphazard, and management of adult training is uncoordinated. Regeneration and employment 6.757 The proposed tolls would be unaffordable for low-paid workers. High volumes of motor traffic associated with the scheme would deter cyclists, and few people would use the scheme on foot. The bridge would be of little benefit to low-paid local people, but it would benefit well-paid longer distance commuters. 6.758 The project is supposed to benefit the unemployed and disadvantaged, but, in an inquiry which has run for almost a year, not one unemployed person has appeared in support of the project
307
Regeneration and development 6.759 The Commission on Sustainable Development in the South East (CSDSE) in their 2005 paper Managing Water Resource and Flood Risk in the South East (2052/2/B Appendix 2) reported that 15% of existing development in growth areas in the South East is currently in the flood zone, and 30% of new development sites planned for 2016 to 2021 will be in flood zone areas. The Association of British Insurers (2052/2/B Appendix 3) estimate the cost of flood protection to be between 5,000 and 8,000 per property. This would reduce the claimed benefit of the scheme in promoting regeneration. 6.760 In later years the CSDSE expect the risk of flooding to increase and, because insurance companies might be unwilling to provide cover, the Government or local authority might become an insurer of last resort. This too would add to the cost of development associated with the scheme. Further expenses that should be included into the scheme costs are those of water supply: the CSDSE report that the Thames Gateway is water stressed, and measures to overcome that would be very costly, slow to implement and environmentally harmful. 6.761 Building on brownfield sites is more expensive than on greenfield sites. 6.762 The scheme is a car-oriented development, and so high density development might become difficult if it was built. It is more likely to lead to a low density, car dependent urban sprawl. New developments in the Gateway lack local facilities and are culturally sterile. 6.763 Bexley is a leading manufacturing location, with Belvedere being the second largest manufacturing area in London. Unemployment is well below the national average. Although there are areas of deprivation in the Borough, fifteen separate regeneration schemes are under way, bringing over 130 million of investment into the Borough, targeted at those areas. Bexleyheath is one of the most economically successful centres in London. 6.764 Bexley provides proof that a road bridge is not necessary for successful regeneration. 6.765 There are numerous examples of regeneration projects in East London that are succeeding without the scheme, including for example the Olympics (that will easily start the regeneration of East London), Stratford City, the Royals Business Park, London Riverside, Beam Reach, Dagenham Dock Sustainable Industrial Park, the White Hart Triangle and Dartford Park. The scheme is not necessary for regeneration; as TfL themselves say, it provides only an opportunity for incremental employment and growth. 6.766 Regeneration of the Thames Gateway lacks leadership and, therefore, coordination. TfL argue that the scheme is unlike any other; it is therefore without precedent and its effects cannot be foreseen.
308
6.767 Business interests should not take precedence over the well-being and quality of life of existing established communities. 6.768 Regeneration of the area is assured. But the shortage of resources may result in failure due to attempts to over develop the area. Public consultation 6.769 The consultation carried out by TfL in relation to the TGB in May to August 2003 was flawed. It involved a direct postal distribution to 40,000 addresses, perceived as those directly affected by the route of the proposed TGB. But it did not include the DA postcodes in Bexley, the areas through which traffic running to and from the bridge south of the river must pass. 6.770 In total, 500,000 leaflets and brochures were distributed, but TfL received only 5,290 responses. This can hardly be described as representative of the views of local people. 6.771 The largest number of those who indicated support for the bridge cited a reduction in traffic congestion at the Blackwall Tunnel or the Dartford Crossing as their main reason for support, but that is not the aim of the TGB. Many others indicated that their support for the bridge was based on their belief that it would decrease congestion in the area; but that would not be its result. 6.772 TfL state that market research after the consultation of mid 2003 showed that awareness of the bridge proposal had risen from 7% to 17%; but that still means that the vast majority of people was unaware of the proposal. People thought that, with the demise of ELRC, the plan for a bridge at Gallions Reach had been dropped. 6.773 Once the main bridge planning applications had been submitted in July 2004, publicity for them was again initially concentrated in Newham and Greenwich. TfL did not seem to appreciate that the major impact of the proposal would be felt in the Borough of Bexley. Maps produced in connection with the consultation showed the southern landfall of the bridge in Greenwich, but did not go on to show any part of the Borough of Bexley. Roadshows to publicise the applications took place in Newham and Greenwich, but it was only after intervention from Bexley Council that a roadshow was arranged in Bexley for 16 September 2004. This was only four days before any submission was required to be made to Bexley Council if it was to be taken into account at their Planning meeting. To make matters worse, many of the 3,000 properties in the immediate affected area of Bexley who were supposed to receive written notification of the Bexley roadshow did not do so. 6.774 Members of AGAB who attended the Bexley roadshow gave evidence that they were assured by TfL representatives at that event that the TGB would not affect Bexley. It was clear that the representatives of TfL had not
309
considered the impact of the proposal on the road network of Bexley. Despite that, of the 700 or so residents who attended the Bexley roadshow, 90% were apparently against the proposal. 6.775 The Gateway News, a monthly free newspaper circulating in Erith and Belvedere, conducted a telephone poll on the scheme. The most recent finding is that 29% of respondents support the scheme and 71% oppose it (Document 2052/37). This finding is at odds with information published in the GLA East Londoner newspaper (Document 5012/2). Health impacts 6.776 The evidence presented to the inquiry on behalf of the NHS was submitted as part of the case of TGLP. The evidence was given by a representative of SELSHA, who also submitted papers from representatives of the Care Trusts of Bexley and Greenwich. The writers of the papers from the Care Trusts did not give evidence at the inquiry, and were therefore not available for cross examination. Their papers (Appendices 1 and 2 to Document 1752/3/B) should therefore attract less weight than evidence which has been open to cross examination. 6.777 The NHS evidence assumed the correctness of TfLs traffic evidence. That traffic evidence was not checked. When it proved to be incorrect, the NHS assumed the correctness of TfLs revised traffic evidence. 6.778 The accuracy of the air quality and noise evidence depends upon the accuracy of the traffic evidence. The air quality and noise evidence has also been accepted without question by the NHS. 6.779 It is on this basis that the NHS has decided to support the case for the TGB. 6.780 Before the opening of the inquiry, in the face of concern expressed by members of AGAB, the SELSHA agreed to commission an independent health assessment of the validity of the ES and its related documents. This review was, however, commissioned from Professor Nigel Spence, a distinguished social scientist, rather than from a health expert. Like the papers from the representatives of the Care Trusts, his paper (Appendix 3 to Document 1752/3/B) was simply submitted to the inquiry. He was not available for cross examination. 6.781 The NHS supports the TGB because it is considered that a. it would improve accessibility in the area, which, it is claimed, would increase the number of jobs available. Compared with unemployment, employment generally improves health (though in some circumstances employment can have the opposite effect). b. it would offer benefits to pedestrians and cyclists using the TGB (though
310
even TfL accept that not many pedestrians and cyclists would use the TGB). c. it would offer easier access to leisure facilities, which would help local people to take up healthier lifestyles (though most people use local leisure facilities, and it is hard to believe that anybody is failing to adopt a healthy lifestyle because of the lack of a bridge). 6.782 The NHS supports the TGB despite the fact that a. the bridge would increase traffic, and therefore increase air pollution and noise. b. prescriptions issued for respiratory medicine have increased in Bexley by 1.1% between 2001/2 and 2004/5 (Appendix 33 of Document 2052/1/A1), and in the same period hospital admission rates for asthma have risen for all ages and for under 5s (Appendix 35 of the same Document). c. noise causes stress, and stress is a leading cause of illness and suicide. TfL suggest that people would get used to increased noise from traffic. In fact, they would not. They would have to put up with it, because many of them would have no other choice. d. the increase in road use would cause at least a proportionate increase in road accidents. e. it would put at risk various green spaces, which Bexleys Community Strategy (Document TfL/97) suggests play a major role in helping people to be fit and healthy. 6.783 Peak hour road conditions are important to local people. Many school children walk to school or use public transport during the morning peak period. Every additional car on the road at that time due to the scheme would have a cumulative adverse effect on public health and quality of life. 6.784 The Mayor of London has not yet replied to a request for confirmation that the scheme would not affect Lesnes Abbey Woods, Bostall Woods and Bostall Heath. It is hard to believe that there would be no worsening of air quality or noise increase at these locations if the scheme went ahead. For example, TfL forecast a 34% increase in traffic on Knee Hill. 6.785 In modelling air quality, TfL did not consider the effect of the Deptford to Dartford escarpment likely to make a significant difference, but the Bexley Health Report 1990-1992 (Document 2052/1/A2 appendix 34) states that the topography of the area adversely affects air quality. Greenwich Councils Borough Spending Plan (2052/29) refers to plume grounding of power station and incinerator emissions as a matter of concern. As the
311
inquiry drew to a close, LB Bexley were commencing a six week consultation on a Borough-wide AQMA. AGAB will write to the Secretary of State with details of the decision on that matter when the outcome of the consultation is known. Ecology 6.786 Bostall Heath lies adjacent to Knee Hill to the west. The area has a number of designations designed to protect it. It is Metropolitan Open Land, part of the Green Chain walk, a SNCI, and an Area of Special Character of Metropolitan Importance. The area would be put under increased pressure if planning permission for the TGB were to be granted. If Knee Hill had to be widened, there would obviously be a loss of part of this valuable ecological resource. Similarly, if the need for road works affected Clam Field Recreation Ground, to the south west of the junction of Knee Hill and Bostall Hill, this would damage an area of habitat for wildlife, because the field edge boundaries of the Recreation Ground are extensively planted with mature trees, which support a wide variety of wildlife. 6.787 The September 2005 issue of The Londoner (Document 2052/36) highlights a severe decline in the bat population in London, mostly as a result of human activity, principally development. The ES records bat activity in the area which would be affected by the TGB, but identifies no roost. The survey was carried out in 2003, however, and TfLs ecology witness confirmed in cross examination that roosting bats might have moved into the area since then. Bats were sighted during the summer of 2005 flying between the area of woodland at the junction of the A2016 Western Way/A2041 Central Way and the area of land by Lakeside Close next to the A2016 Eastern Way near Birchmere Park in Thamesmead. Trees in both these areas of land would be lost if the TGB were to proceed. TfL should carry out a further survey of these sites at the earliest opportunity. Other matters 6.788 Many people, including small local businesses, are extremely concerned that TfL have suggested the possibility of a congestion charge in Bexley to reduce traffic flows there. 6.789 Once a new road is built, permanent damage to the structure and fabric of the area would have been done that could not be undone. 6.790 More people have shown themselves to be against this scheme than those who are for it. That is demonstrated both by the written representations received by the inquiry and by the people who have attended the inquiry to give evidence. Democracy should be upheld, and the scheme should be rejected. Response by TfL to the objections of AGAB and the SMRA
312
Traffic congestion 6.791 The actual AADT at the Dartford Crossing is 170,000, and that on the scheme is expected to be 53,000. The visual comparison that AGAB make is therefore misleading. 6.792 In its proof of evidence, the London Borough of Redbridge does not use the term congestion; rather, it refers to significant increase in traffic flows. This does not necessarily equate to congestion. Additional congestion with the scheme would be limited, and is allowed for in the model. AGAB refer to no specific evidence in their description of traffic congestion, and there is no reliable evidence of the effect of the scheme other than that of TfL. 6.793 The comments of Dartford Borough Council to which AGAB draw attention are that extra traffic would be undesirable. This is not a comment on the traffic forecasts or that extra traffic is expected in Dartford as a result of the scheme. The scheme would reduce traffic flows at the congested locations in Bexley that AGAB highlight. The emergency services were consulted during the application stage of the scheme and raised no objection. Current conditions in Normanhurst Avenue suggest a possible illustration of poorly planned local traffic management measures by the London Borough of Bexley: TfL propose traffic mitigation measures as part of the scheme. Westbrook Road does not provide a continuous route as AGAB suggest; it is closed at two points near Fosters Primary School so as to prevent through traffic, a fact confirmed on one of the site visits. The increase in traffic on Eynsham Road that would arise as a result of the scheme would be large in percentage terms but, because the base flow is low, small in absolute terms. Traffic flows in Pickford Lane need to be considered together with those in Brampton Road and Belvedere Road, in which case the scheme would result in an overall reduction in the group; and the modelled flow in Pickford Lane would increase by 8% in the Cordon Model case rather than the 22% suggested by the Reference Case Model. Traffic model - reliability 6.794 Bexley Council provided neither rationale nor prioritisation for the 12 additional survey sites they suggested, and so it appears that the extra surveys were not particularly important to the Council. 6.795 TfL await details of the transport assessment for the redevelopment of the St Josephs Annex site. However, the proposed change of use is estimated to generate between 13 and 26 vehicle movements in the AM peak hour, an insignificantly small number in the context of the overall changes in traffic levels. Similarly, if the Belvedere Incinerator were to be granted planning permission, the traffic impact would be minimal. The proposal is that the majority of waste movements would be made using river access. Normal daily traffic movements to and from the site would be 192, of which 16 would take place in the morning peak.
313
6.796 In relation to the DMRB guidelines, a broad screenline of cross river movements is the most crucial. Of these movements, the two most crucial are the Blackwall and Dartford Crossings. Three of the four one-way GEH statistics for these two Crossings comply with the DMRB guideline and the other has a value of 5.1 compared to the guidance maximum of 5.0. Traffic modelling - interpeak forecasts 6.797 Although the interpeak model has not been re-based, the original Reference Case Model (with the estimates of changes due to the scheme in the interpeak) was used to forecast the likely effects of the scheme. 6.798 Even in the peak hour, traffic associated with the scheme would result in only small increases in journey time, where they occurred. Such peak hour increases would be very much fewer than the number of journey time savings in the same period. 6.799 The scheme would reduce overall traffic Lane/Brampton Road/Belvedere Road corridor. levels in the Pickford
Traffic model - assignment between A2, Blackwall and the scheme 6.800 Satellite navigation offers the option of excluding tolled roads and will tend to direct traffic along more major roads. 6.801 The Blackwall Tunnels are TfL roads, and any decision to introduce tolls there would be made by TfL. TfL are not considering tolling Blackwall. Traffic - long distance 6.802 Documents TfL/107 and TfL/130 present information about closures of the Dartford Crossing. Since the model predicts that the scheme would not increase traffic at the Dartford Crossing (or at Blackwall), there is no reason to think that the scheme would cause more closures at those locations. 6.803 If an incident at the Blackwall or Dartford Crossing was severe enough, then traffic would divert to the scheme, but such traffic is likely to use the A206 routes before local roads in Bexley. 6.804 Although time is a valuable commodity, and people will pay to save time, in the case of trips to or from the more distant locations, the scheme would not save enough time, compared with Blackwall and Dartford, to make it worth paying the proposed tolls. 6.805 It is implausible to imply that a useful route from Erith Marshes to Kent or Europe would pass over the scheme. Access from Erith Marshes to Essex would be more convenient via the Dartford Crossing. While the scheme is a
314
vital part of the strategy to develop the London Thames Gateway, and is therefore of sub-regional significance, it would not be a strategic road for long distance purposes. Tolls 6.806 The Itchen bridge, described in evidence by the TGLP, is a very good example of the use of tolls to deter non-local use. But, beyond that issue, it is very different from the scheme, and so it is not a useful comparator in the wider context. Tolls - residents discount area 6.807 Bridge users who would travel to the southern part of Greenwich via Bexley would be from areas in the discount area north of the river. 6.808 While the proposed discount area has been reduced in Bexley, the current proposal for the Borough remains broadly commensurate with those for Greenwich, Newham and Redbridge. In each case, the boundary would lie about 6 km from the bridge. In Barking & Dagenham it would extend further. Key areas in north Bexley such as Belvedere, Erith and Thamesmead, within this distance remain in the proposed discount area. 6.809 If traffic problems were to occur following opening of the scheme, modification of the discount area might be necessary. But there is no current consideration that this might be needed. In any event, the Borough Councils would have a key role to play through the BCG. Nor is it necessarily the case that traffic would be higher than estimated, and therefore need further control. It is much more likely that a lower traffic growth scenario would develop, as suggested by Professor Goodwin, in which case it may be possible to increase the discount area above that currently proposed. Knee Hill 6.810 Traffic flows in Knee Hill in 2016 during the morning peak would increase by 19% with the TGB compared to the Do Minimum situation, as indicated in Document TfL/273. TfL do not propose to widen Knee Hill or to provide any new footway there. 6.811 The additional modelled flow of 200 pcus per hour in the assessment of the A206/Knee Hill/Brampton Road junction was introduced to understand the overall effect on capacity of such an increase rather than because such an increase is expected.
Traffic - mitigation measures

315
6.812 Well designed traffic management schemes should allow for the potential effects of neighbouring schemes. The aim is to have traffic on the most direct route, but at lower speeds with better crossings, less severance and generally more safety. Techniques are available to achieve this which in most cases are wholly successful. Examples of exceptions to this are those where a lorry ban diverts lorries elsewhere on to local roads or where local road closures slightly increase the lengths of some peoples journeys. 6.813 Increased traffic capacity on the wider road network is not proposed as part of the scheme. The carriageway in Harrow Manorway would be widened to allow bus lanes to be provided. If there were a future need to increase the capacity of the road network, that need would arise from general traffic growth and not from the scheme. Cycling and walking 6.814 To omit pedestrian and cycling facilities from the scheme would be to miss an opportunity to open up a new crossing for those modes. Although few would be likely routinely to walk across the bridge, it would provide attractive journey options for many cyclists. Regeneration and employment 6.815 The theory that improved transport would enable people who live further from the bridge to out compete local residents for jobs is wrong because: a. The proposed tolls would discourage longer distance travel; b. Attracting more residents would increase the number of jobs; c. Better accessibility would also increase job opportunities; d. Local residents would be better able to access opportunities further away; and, e. Successful economies will be open ones with in- and out-commuting. 6.816 Transport infrastructure is a necessary precondition for regeneration, but more is needed to improve employment: employment provision, new housing and training. Up to one-third of all new jobs will be taken by local people. Regeneration policy should not aim to provide low-skill jobs simply because the population is currently low-skilled.
Regeneration and development
316
6.817 The London Plan (D620) aims to enable London to accommodate the population expected to want to live there, and their jobs. This is to prevent urban sprawl and greenfield development further away. The costs associated with the Plan approach are likely to be less than the alternative. The alternative would also be less sustainable. 6.818 The scheme is not a car-oriented development. The toll penalty for car users would not be incurred by public transport users, and longer-distance motorists would pay more than local motorists. The context of the scheme is one that will see an overall increase of 35% growth in public transport patronage. The scheme and the other large infrastructure improvements such as Crossrail will make the area more attractive to residents and development density will increase. 6.819 The ODPM advertised on 4 April 2006 its wish to appoint a Thames Gateway Chief Executive. Public consultation 6.820 Apart from the opportunities which existed for people to make an input to the preparation of the Mayors Transport Strategy and the London Plan, there were two separate consultations on the proposed TGB. The 2003 consultation was a non statutory public consultation, undertaken by TfL, prior to the scheme being presented to the TfL Board in March 2004. The 2004 consultation was the statutory consultation, undertaken by Greenwich and Newham on the main bridge planning applications, and by TfL in relation to the Scheme and Orders. 6.821 In relation to the 2003 consultation, consultation brochures were delivered to postcodes SE2 and SE28, parts of which are within Bexley, and flyers were delivered to postcodes DA1, DA6, DA7, DA8, DA16, DA17, DA18 and SE18. In addition, consultation was advertised in four editions of the Bexley News and Shopper; roadshows were held for six days in Bexley; exhibitions were held for 25 days at five different locations in Bexley; letters were sent to 35 Bexley stakeholder groups and meetings held with a number of them; consultation materials were sent to Bexley libraries for display; and local newspapers carried stories about the consultation. In fact, there were 169 responses to the consultation for DA7, where Mr and Mrs Wise of AGAB live, and there were 142 responses from DA16, in which St Michaels Ward is located. 6.822 Neither the consultation materials nor the resources used to carry out independent market research stated that the TGB would aim to reduce congestion on other Thames crossings or the road network. Evidence presented to the inquiry has reiterated this point. 6.823 Of the 5,194 people who ticked a box to show support (85%) or opposition (15%) to the proposal, 3,655 also made comments. In fact, the top response overall (from 857 respondents) was that people supported the
317
bridge because of the current lack of access in the area. There were also 415 respondents who stated that investment and regeneration in the area would increase because of the TGB. A total of 374 people out of the 3,655 who made comment stated that the bridge would reduce congestion or ease pressure on the Blackwall Tunnel. 6.824 In relation to the 2004 consultation on the planning applications, this was the responsibility of the two local planning authorities. TfL cooperated with their requirements, and also added a roadshow in Bexley at the request of that authority. No source is provided by AGAB/SMRA for the figure of 90% opposition at the Bexley roadshow. Despite the criticism of the information provided by TfL staff at that event about the impact of the proposed bridge on the Bexley road network, in fact (apart from information regarding Long Lane) it appears to have been generally accurate, and in any event there were officers from Bexley present who would also have been able to add the benefit of their local knowledge to supplement information from TfL staff. 6.825 The TfL Board have never approached the TGB as if it was a project on which everyone was agreed. In 2002, the decision turned on the casting vote of the Mayor. In 2004, the voting was less evenly split, but the case against the bridge was clearly appreciated and argued. Health impacts 6.826 TfL accept that air quality affects health, but action is being taken at international and at national levels to improve air quality. The detailed air quality assessment reported in the ES makes it clear that there are some locations where annual mean nitrogen dioxide concentrations are still expected to exceed the limit value in 2016, with or without the TGB. At some of those locations, concentrations would be a little higher with the TGB, and the effect would be to delay the date when the limit value would be reached. The TGB would not cause a breach of the limit value, but delay the date at which it would be achieved at a few locations close to busy roads. Exceedences of the limit value are a matter for central Government to deal with. The TGB would make no difference to whether or not there is a problem with meeting the limit value in the UK. In the case of PM10, there is no evidence that either the 24 hour or the annual mean limit values would be exceeded. The air quality analysis did not pay special regard to the meteorological effects of the Deptford escarpment, because it was not considered that it would make a significant difference to the concentrations which were being modelled across the study area. There might be some very local effects in the immediate vicinity of the escarpment, but it is some distance from the Thamesmead area. 6.827 The asthma figures for Bexley are well known to SELSHA and to the Bexley Care Trust. Both organisations are not merely not opposing, but rather supporting, the scheme. That position was confirmed in evidence after the revised traffic figures were introduced to the inquiry.
318
6.828 The noise assessment predictions for the TGB scheme were extended beyond the usual distance required for traffic noise impact assessment as reported at paragraph 4.248 above. The predicted noise levels for Tripcock Park would rise as a result of the TGB scheme, but, as a result of the elevated nature of the bridge and the use of noise barriers as it crosses the Park, the extent of the noise impact would be much less than would occur with a ground level road. The noise levels predicted for the Park would be lower than the levels found for most London parks. 6.829 As regards road safety, the traffic increases have been taken into account in the casualty estimates. Ecology 6.830 If it were the case that Knee Hill was to be widened, there would be ecological concern to weigh in the balance against the benefits of any widening. But no such widening is planned, and it would not fit readily with Policy 3C.15 of the London Plan. Greenwich Action to Stop Pollution 6.831 Greenwich Action to Stop Pollution (GASP) was formed in 1991 to protect the air quality in the London Borough of Greenwich. It has a membership of around 100, who pay an annual subscription. GASP has a record of successful engagement with the local authority and others on matters relating to air quality in the Borough. Regeneration - accessibility 6.832 The areas of East London close to either the Blackwall or Rotherhithe tunnels are not prosperous, nor do their residents earn more or enjoy higher levels of employment than the average levels for all London. The regeneration benefits that the promoters claim would be associated with the accessibility effect of the scheme are questionable. Road safety 6.833 Table 14.9 of the ES shows that an additional 121 people would be killed or seriously injured if the scheme were to proceed. Air quality 6.834 The ES indicates that a greater number of people would suffer worse air quality if the scheme proceeded than the number for whom air quality would improve. But the ES presents no assessment of the impact of a further deterioration in air quality in an already poor environment. Nor does it consider a comprehensive list of the most serious or harmful pollutants.
319
6.835 The Committee on the Medical Effects of Air Pollution (COMEAP) issued on 18 January 2006 an interim report (appended to Document 2069/1/A2) which reached the interim conclusion that particulate matter as measured as PM2.5 is the most appropriate measure of air pollution; but the promoters have based their assessment of particulate concentrations on PM10. COMEAP also concluded that toxicity levels associated with particulates are six times those previously held to be the case. These omissions have implications for the predicted mortality rates associated with air pollution. 6.836 The use of percentage figures to quantify the change in emissions arising from the scheme in 2016, for example by the use of 0.003% to represent the change in PM10 in table 16.7, shows the lack of understanding by the promoters of the significance of increases in air pollution. It is not acceptable for the local environment to become only a little worse each year without any consideration of the cumulative effect of such changes. 6.837 PPG23 embodies the precautionary principle. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing cost effective measures to prevent environmental degradation. This principle should be invoked where there is good reason to believe that harmful effects may occur to human, animal or plant health or to the environment, and the level of scientific uncertainty about the consequences or likelihood of the risk is such that the best available scientific advice cannot assess the risk with sufficient confidence to inform decision making. 6.838 The precautionary principle requires an benefits of action and also transparency demonstrated neither of these. There has out costs against benefits, and the ES has pollutants without any explanation. assessment of the costs and in decision making. TfL have been no assessment which sets discounted the impact of many
6.839 No allowance has been made for any margin of error in the air quality evidence from TfL. Noise 6.840 The ES refers to an additional 4,569 properties which would be affected by noise if the scheme were to be built. It goes on to propose that, in effect, people would simply become used to the noise. This is despite the principle of noise reduction being enshrined in the Mayors ambient noise strategy, and supportive policies in the Greenwich and Newham UDPs. Community impact 6.841 PPS1 and PPS23 require that social progress must be for everyone, and that the impact of development on the social fabric of communities should be considered and taken into account. TfL have failed to do this.
320
Response by TfL to the objection of GASP Road safety 6.842 The estimated figures for road casualties are quoted at paragraph 4.179 above. They are one additional fatality and six serious injuries. Mr Connolly has included the predicted 114 slight injuries in GASPs figures for deaths and serious injuries. Air quality 6.843 The scope of the ES was agreed with the relevant local planning authorities. It is not a requirement of the Environmental Impact Assessment Regulations that all pollutants are assessed, but only those which would give rise to likely significant effects, in this case, nitrogen dioxide and particulates. The air quality analysis presented in the ES (D808, chapter 16) was conducted according to the relevant guidance. The guidance followed had regard to objective emission limits laid down in regulations which were based on health considerations. The conclusion that the scheme would have minor adverse effects was arrived at by applying that guidance. The promoters view in that respect was shared by the environmental health professionals who appeared at the inquiry on behalf of London Borough Councils. 6.844 Although the recent paper by COMEAP reports that the change in toxicity levels associated with an increase of 10 micro grams of PM2.5 particulates per cubic metre of air are now considered to be six times higher than previously thought, the newly assessed risk of harm is significant but low. PM2.5 particles are included in PM10 measurements. For vehicles, most of the particles are in the PM2.5 fraction, so measures to reduce particles coming from road vehicles will affect the PM2.5 fraction more than they will the PM10 fraction in terms of the reduction in emissions of particulate matter from vehicles. 6.845 The assessment which has been carried out is based on the most likely outcome in the light of the understanding of air quality at the present time. This is the correct approach required by the 1999 Environmental Impact Assessment Regulations. The fact that there are uncertainties does not prevent the assessor from applying his knowledge and experience to the order of magnitude of those uncertainties. London Thames Gateway Forum (LTGF) 6.846 The London Thames Gateway Forum of Community and Voluntary Sector Organisations is a member and network based organisation with some 500 member organisations and additional individual members to a total of around 900. Its mission is to promote equality of access and full participation by all people of the Thames Gateway in all processes concerning their quality of life. It is a Company Limited by Guarantee. Its
321
evidence to the inquiry is the culmination of many meetings held since March 2001, and was authorised by the LTGF Board. 6.847 LTGFs position is as follows, in summary: a. The scheme would encourage extra car traffic. It would unbalance transport provision and the objectives of transport policy in East London and wider London. Therefore the scheme is inconsistent with the London Plan and the Mayors Transport Strategy. Without other aspects of a transport strategy being in place or guaranteed, the scheme is at least premature. b. The scheme is also against some core principles of local plans for Boroughs in East London and national policy, including the 1998 Integrated Transport Policy, the 10 Year Plan and PPG13. c. The extra traffic generated by the scheme on certain roads leading to it would overload the nearby strategic and minor road networks, harming the local environment. d. The scheme, relative to other possibilities to help deprived areas and improve employment, is totally unsatisfactory, certainly without having a range of other transport and environmental measures in East London. e. No alternative has been properly considered. TfL have not identified the problems of East London or even properly considered a range of alternative transport arrangements to meet some of the schemes objectives. Regeneration - accessibility 6.848 LTGF has no in-principle objection sustainable crossings of the river. to the provision of additional
6.849 There is little evidence to support the view that the River Thames restricts development in East London. Canary Wharf is a very major development that was substantially cut off (in all directions), and the Royal Docks are now developing rapidly. 6.850 Although accessibility across the Thames is better in West London than in the east, accessibility in East London can be very good compared with most places in the UK or elsewhere without the provision of more river crossings. Londons general high level of accessibility, together with the range of facilities on each side of the river, means that further improvements in accessibility need not be a priority. 6.851 Unemployment is worse north of the Thames, and so the expected larger proportion of accessibility improvements to the south of the river would
322
have less benefit. 6.852 The scheme is likely to have less effect than the promoters claim in addressing local problems: a. Access to job opportunities: the people who need the jobs most are to the north of the river, where most of the jobs would in any case be provided. b. Access to local facilities: It would be reasonable in such large areas north and south of the river to provide adequate local facilities on each side of the river. This would also be more sustainable in transport terms. c. Access by employers to workforces and markets: Good public transport is more important to employers than are high speed roads and so improved public transport should be provided. The workforce on each side of the Thames is quite extensive and should be properly educated and trained, in which case there should be no need for the scheme. d. High levels of unemployment the scheme could allow people from further away to take local jobs, thus reducing the employment of local people. 6.853 It should not be necessary to build a large road scheme, connected to the strategic or near-strategic road network, in order to maximise economic, transport, social, environmental and other benefits to local people. TfLs view that the scheme would support regeneration by providing links to the strategic road network conflicts with TfLs view that the scheme would be a local road. 6.854 The reduced traffic flows on the scheme in the Cordon Model result in a weakening of the regeneration benefits of the scheme. Regeneration - development 6.855 The 1986 ELRC inquiry heard evidence that that scheme was essential for business confidence, without which the Royal Docks development would proceed more slowly. That development is now very substantially complete, and so does not depend on the scheme. There are also good examples of development taking place regardless of infrastructure: Canary Wharf largely developed on totally inadequate infrastructure. 6.856 Public transport and environmental improvement are the measures that could most support redevelopment at Barking Creek; a major road scheme is not a good way to improve the environment.
323
Regeneration - employment 6.857 The areas of greater social inequality and opportunities for employment are to the north of the river. The scheme would allow outsiders to take jobs in those areas, to the detriment of local people. Planning policy 6.858 TfL cite RPG9A in support of their case. RPG9A was published before the New Deal for Transport White Paper (D105). It claims that additions to capacity may be the best way to support development in some locations, but that is not the case in London, where road capacity increases normally exacerbate rather than solve congestion problems. 6.859 None of the Key Policy Directions in Objective 5 of the London Plan (D620) relates well to the provision of extra road space. If the scheme was necessary to accommodate increased traffic, it would be inconsistent with the Mayors Transport Strategy. TfLs revised proposals remain inconsistent with policy 4G.8 of the Mayors Transport Strategy or the Key Policy Directions of Objective 5 of the London Plan. 6.860 There should be a land use and transport plan for the Thames Gateway. Such a model should be produced on a systematic and rational basis. Tolls 6.861 The proposed tolls and funding arrangements would not encourage traffic limitation measures on the scheme, as that would reduce the net revenue from the scheme either to the Mayor or the concessionaire. Rather, they would create an incentive for the concessionaire to maximise revenue by maximising traffic. 6.862 Experience from the M6 Toll Road, which together with the M6 has seen substantial induced traffic, indicates that reliance on a toll only, to control traffic volume, is unlikely to be effective. The over reliance on tolls to manage the traffic flows on this one link in the whole of East London would be a very serious weakness of the scheme. Long distance traffic 6.863 By virtue of its connections to the strategic road networks south and north of the river, the scheme would become a strategic route, rather than a local route. 6.864 The proposed tolls would be unlikely to deter long distance through traffic, since the cost would be a smaller proportion of the cost of the whole trip. The scheme would encourage longer distance traffic. Long distance and particularly expense account trips are very unlikely to be deterred to the
324
extent that TfL claim by the toll increase of 1. Long distance drivers would find the prospect of an uncongested crossing of the river well worth the proposed toll, and so would not be deterred by the toll. 6.865 The high-capacity road network outside the M25 facilitates car-based commuting which would be encouraged by the scheme. The scheme would encourage car-based commuting into Newham and Tower Hamlets. 6.866 The 3 toll now proposed would result in fewer long distance users of the bridge than would the previous proposal. Traffic congestion 6.867 Large, high capacity roads with limited junctions are more susceptible to traffic congestion than finer road networks. The scheme would also generate extra traffic that would overload other roads and reduce journey reliability. Alternatives 6.868 The Reference Case inter peak traffic flows on the bridge would be no more than equivalent to a single traffic lane in each direction. The extra lane in each direction is therefore provided for car commuters. A single traffic lane in each direction may be a way that the scheme could work and would regulate the traffic using it; but such an alternative is not promoted by the LTGF. The Cordon Model improves the case that more than a single traffic lane on the bridge in each direction would be unnecessary. 6.869 Research (Document 2691/9) has shown that road space reductions reduce traffic. There is a good case for an alternative scheme for reducing road space in Outer London to better balance with the existing road system in Inner London. 6.870 Other measures that might reduce traffic include more widespread congestion charging and travel plans. 6.871 The Opportunity Areas that TfL claim the scheme would serve are all further east than the proposed scheme, which is therefore poorly located to serve regeneration. 6.872 Options that might be considered include tram systems, foot tunnels, lifting bridges and a series of crossing points linked by flexible smallish ferries for foot passengers and cyclists only, linked by improved public transport networks to the north and south.
325
Alternatives - the first principles approach 6.873 TfLs assessment of alternatives only tests whether a high capacity standard dual carriageway road bridge could fit between alternative points. 6.874 TfL should have started from first principles, looking at the whole areas overall planning, the basic problems of the area, and the need to regenerate the area, help general employment, reduce congestion, provide better access and improve the environment. This should have led to consideration of packages of appropriate measures. But, even though the scheme is in London where the importance of exploring non-road options increases, TfL did not do this - to the detriment of sensible planning, good use of public funds and the full range of advice provided by European, national and local government. Such a clean sheet of paper option should have been put forward at the EIP into the London Plan, but was not. 6.875 Instead, the alternatives considered by TfL appear to have come from the idea that a high level dual carriageway road bridge connected to the strategic network was required in this part of East London; they are alternative positions for a road bridge. 6.876 The approach taken does not comply with Government guidance. For example, WebTag (D524, unit 1.4, paragraph 1.1.10) seeks a first principles approach which should incorporate the identification of problems, the setting of objectives and the generation of options at least two of which should be carried fully through appraisal. 6.877 It appears that, following the abandonment of the ELRC by the Government, the road schemes that were historically available were reinvestigated for their use. 6.878 The balanced strategy of RPG9A has gained such momentum that there has been no thorough review of what is really required to meet the transport needs, particularly of the unemployed in East London, or to study the best way of meeting the overall objectives of the planning and transport strategy for London. This very old scheme has continued under its own momentum, without a fundamental review of the best way of meeting the needs. 6.879 The scheme is, in the terms of the eponymous paper (Document ADD/003), a solution looking for a problem. The tinkering with the scheme that TfL have undertaken in producing the Cordon Model simply emphasises the need for a fresh look at the strategy. 6.880 Despite the revision of the model during the inquiry, it remains the case that a fundamental review is needed of the best way to meet the needs of the area.
326
Future baseline assumptions 6.881 Neither the DLR extensions to Barking Reach and Dagenham Dock nor Crossrail has been included in the do-minimum case. It is not sufficient to include the effects of public transport improvements only in sensitivity analysis, since such tests do not take into account the development or modal share aspects of the transport strategy. The promoters approach is road based. 6.882 The July 2004 White Paper The Future Of Transport (D108, page 6) reports that the Prime Minister anticipates road user charging. Comprehensive road user charging should therefore form part of the dominimum case. 6.883 Crossrail could cause changes in the use of public transport which may affect the scheme, and the schemes transport economics. It should be included in the do-minimum case. 6.884 The do-minimum case as presented by TfL is not an acceptable place to start making comparisons; perhaps it should be tuned to the Mayors targets before consideration of the scheme. The lack of a realistic dominimum case is a major weakness in the new analysis and in the scheme. Traffic modelling 6.885 TfLs traffic modelling is consistent with Government guidance. But the situation in London is very different from the average case, designed for the whole of the country. 6.886 The Reference Case Model produces apparently reasonable results for the bridge itself, but other roads would be completely full. In combination with zero tolls, it generates a modelled flow across the scheme that would be physically impossible. This sort of fallacious figure is fed into the economic assessment. 6.887 The Cordon Model shows less traffic on the bridge than did the Reference Case Model. More traffic would divert to Blackwall or Dartford. 6.888 If traffic diverted to the new route from the Blackwall Tunnel, as TfL suggest, more traffic would be attracted in turn to the Tunnel. The same would apply to the Silvertown crossing, which should therefore be considered at the same time as the scheme. 6.889 The maximum realistic traffic that can be carried on new high design standard road links is around 1,800 vehicles per hour. Higher peak flows have been recorded, but such flows are neither stable nor safe. Traffic on the Queen Elizabeth II bridge flows at a maximum of 5,600 vehicles per hour on four lanes. Any flows greater than 1,800 vehicles per hour per lane
327
should be unacceptable for design purposes. The foregoing describes a limiting situation for link flow. Once the junctions between links are full then congestion will occur. 6.890 Many of the roads linking the A2016 to the A2 and the South Circular would have very large increases in traffic as a result of the scheme that would be not realistic in terms of the local road layout. The rates of growth shown are much greater than the typical rate of growth of traffic in London. 6.891 The modelling process usually allows traffic to increase beyond theoretical and practical capacities. Some of the flows predicted in the Reference Case Model will not be achievable. TfLs claim for relief of existing traffic is thoroughly unrealistic. The model substantially under-predicts flows with the scheme, relative to the do-minimum case. The guidance of the DMRB regarding road capacity at peak times is unrealistic for a network with excess demand and large daily variation. Nor is the DMRB consistent in that respect with road safety guidance issued by the DfT. 6.892 Modelled flows on some strategic links assigned by the model show 24-hour flows of 130,000 on routes of much lower capacity. The modelled peak hour flows are unrealistically high, with flows greater than could be accommodated at any speed, for example on many minor roads in Plumstead and Bexleyheath. The economic assessment is therefore based on totally bogus figures. 6.893 Londons road network runs very full in the peak hour in the peak direction. Thus a small increase in traffic caused by the scheme would result in extra congestion to a disproportionate degree. This in turn would reduce the calculated benefits significantly. Modelling - claimed benefits 6.894 Traffic restraint is important in London. Tables 7 and 8 of TfLs Statement of Case (Document TfL/15) show that car users would gain more from the scheme than public transport users. This and the claimed reduction in cross river travel times for car drivers would encourage car use, and be contrary to the sustainable transport advocated by the Mayors Transport Strategy and Government policies. 6.895 Public transport, walking and cycling are important for travel in areas of low employment. Additional road transport would not help social inclusion and would be likely to be counter productive by allowing local jobs to be taken by car commuters from further away. 6.896 If improved car-based accessibility, such as the scheme would promote, is to be beneficial, then there should be sufficient parking at the trip end. This would reduce development density and viability.
328
Modelling and the effect of transport policy 6.897 The higher levels of do-minimum traffic in the Cordon Model are contrary to the Mayors Transport Strategy, and would not arise because policy measures would be brought forward by the Mayor in reaction to such growth, reducing it. Modelling - cost benefit analysis 6.898 The benefit:cost ratio claimed for the scheme is different from the benefit:cost ratios claimed at other times for other schemes at the same location. Such economic assessments are notoriously sensitive to various assumptions. 6.899 Although TfLs stated main objective in promoting the scheme is not congestion relief, such relief contributes to the transport economic benefits of the scheme. Any error in the assessment of congestion relief therefore affects the benefit:cost ratio. 6.900 The smaller than expected amount of induced traffic is modelled by TfL to give a higher than expected level of traffic benefit. The Cordon Model also neglects the extra traffic congestion outside the study area caused by the extra generated traffic, and retains the unrealistically high flow projections in the Reference Case Model. 6.901 The change in the toll regime has reduced the transport economic benefits. Modelling - robustness of the model 6.902 Traffic modelling such as that presented by the promoters is often unreliable in that: a. The 1990/1 ELRC inquiry scheme proposed a dual three-lane crossing, whereas the 1985/6 scheme proposed a dual two-lane crossing. The traffic predictions presented to the ELRC inquiries in 1985/6 and 1990/1 were inaccurate. Confidence in traffic predictions by proposers of road schemes must be in serious doubt. b. Calculations of benefit:cost ratios can assumptions made. be very sensitive to the
c. No traffic model has been checked retrospectively to see whether it produces reliable results. d. A note of planned research published by the DfT in 2004 (Document 2691/4) states that modelling under predicts journey times.
329
6.903 The modelling associated with the scheme is also questionable for the following reasons: a. The modelling procedure should choose routes on the basis of proportions of journey costs rather than on perceived costs, since the latter would show an artificial reduction in long distance traffic on the scheme. b. The claimed congestion relief associated with the scheme is not realistic. c. The Silvertown Link and the scheme would add to the traffic in the area and increase overall congestion in East London, even if there might possibly be some alleviation at Blackwall. d. The relative sensitivity of the model to changes in tolls suggests that other changes might be required if the scheme were implemented. e. TfLs need to rework their traffic forecasts emphasises the unreliability of the model. f. The changes to the model made by TfL in producing the Cordon Model reduce its ability to cope with changes in the modelled future. g. The do-minimum model indicates that substantially more traffic would be present in the future than would actually be the case. 6.904 The unreliability of the model suggests that the benefits of the scheme could reduce to less than its total costs. The benefit:cost ratio would be in the range of 0.5 to 5. Modelling - induced traffic 6.905 Published general research by Mr Elliott (Document 2691/3) gives confidence that whatever capacity is provided to cross the river, it would be filled within a very few years unless there is a large enough toll. Nor would there be lasting relief of congestion elsewhere. The detail of how this happens from scheme to scheme follows a similar general pattern. Where there is a natural barrier, such as the River Thames, the growth rate upon provision of a new facility is very marked, and there is little diversion from other routes. The work has been tested by SACTRA, and the findings it suggests are borne out in a number of studies including some in London. 6.906 The model does not allow adequately for induced traffic. Cycling and walking 6.907 The scheme would not provide attractive cross river facilities for pedestrians
330
and cyclists. There is no pedestrian or cycle link east of the Woolwich foot tunnel. The absence of such a facility should be addressed, but the length and exposed nature of the scheme will make it unattractive for pedestrians and cyclists. 6.908 The bridge would not be particularly helpful for pedestrians and cyclists. Speed limit 6.909 The proposed 40 mph speed limit on the scheme would be unenforced and abused, leading to a lack of safety. Traffic mitigation 6.910 In some locations TfL propose to solve problems of excess flows by means of mitigation measures. This may either a. Reduce the effective capacity of the system, for example by measures to prevent rat-running, and so add to congestion and delays and reduce the economic return; or, b. Increase the effective capacity of the system, for example by junction alterations, and so induce more car trips and congestion. 6.911 No effort has been made to address the problems of traffic on the strategic network north of the river. The section of the North Circular Road north of the A13 is now fairly full. The extra long distance traffic predicted from the scheme would limit the available road space for the local traffic the scheme is intended to help. Public consultation 6.912 The consensus in support of the scheme, to which TfL refer, is mainly among parties interested in promoting road crossings. The scheme has not so far been subject to public or other proper scrutiny. At the time of the public consultation, the public were unaware of the traffic implications of the scheme, and no environmental assessment was available. 6.913 It is sad that some essential features of the scheme (a speed limit and public transport routes) were added only after public consultation. 6.914 Most local residents are unaware of the changes made by TfL to proposals for traffic mitigation works, or of their implications. Nor is it clear how wellinformed local people are of the revised toll proposals, and whether that would reduce support for the scheme. The toll proposals might be changed again.
331
Existing transport networks 6.915 The A206/A2016 route connects the Blackwall Tunnel, the Woolwich Ferry and the Dartford Tunnel/M25 and would, if the scheme were built, become a strategic link. 6.916 The increase in traffic along the A2 bound for Blackwall that TfL predict (TfL/15, paragraph 6.20) would take place as a result of the increased capacity the scheme would provide, and would be contrary to the Mayors Transport Strategy and Government policy. The Woolwich Ferry 6.917 It is unlikely that the Woolwich Ferry would be maintained for very long after the scheme opened. This would be to the disadvantage of the north and south Woolwich communities, for whom it is a useful facility; and it is convenient for commercial vehicle traffic. LTGF has no evidence of the extent to which the Woolwich Ferry is used. Public transport 6.918 If, as TfL say (TfL/15), Tower Hamlets and Newham need to draw on a wide workforce, that need should be met by public transport improvements, which should be accorded a higher priority than the scheme. If high quality public transport is less available in the east, as TfL say (TfL/15, 7.5) then the scheme is in the wrong position. The real priority is for public transport improvements. 6.919 LTGF supports the dedicated public transport lanes proposed as part of the scheme. There is insufficient detail of the bus services that would use them, nor how those services would be provided. The modelling of public transport has been inadequate, in terms of its geographical extent and its detail. 6.920 It is disappointing that radial public transport journey times would largely be unchanged by the scheme. Canary Wharf could be a potential destination for people from Thamesmead and South East London. It is also regrettable that Thamesmead is left with very inferior public transport. Crossrail 6.921 There is currently no commitment that Crossrail will be built. Any permission to proceed with the scheme should be conditional upon the award of the main contract for Crossrail and start of works. This could mean only a further delay of about two years.
332
Air quality 6.922 Anything that makes achievement of national targets for carbon dioxide emissions more difficult should be reviewed in light of the UKs noncompliance. By increasing traffic, the scheme would reduce air quality. It would not be good planning to build a road that then had to be closed following the declaration of an AQMA. Comparison with the ELRC 6.923 The purpose of the scheme appears to be the same as that of the ELRC, but it lacks a direct connection to the A2. 6.924 The scheme would perhaps have worse long-term environmental implications than the ELRC proposals, since traffic south of the river would use residential roads. There would be pressure to extend its route further south. The traffic increases in the Cordon Model would, on residential roads between the A2016 and the A2, be unacceptable. However, it was agreed in cross-examination that no specific location has been identified where that would be the case. History and general policy issues 6.925 The history of previous proposals for a road crossing of the Thames, broadly at the scheme location, shows it to be an extremely old scheme no longer in line with any sensible transport or planning policy in London. 6.926 TfL promote the scheme as part of a balanced strategy. But the current strategy is strongly pro-road. The traffic model should incorporate the scheme, the Silvertown Link, the Congestion Charge and any other schemes that are envisaged to provide an overall picture of the development of the Thames Gateway area. 6.927 The New Deal Transport White Paper (D105) sets out matters to be considered in scheme appraisal: integration, safety, economy, environment and accessibility. But the scheme would not support any of these investment criteria particularly well. Form of the scheme 6.928 The Queen Elizabeth II Bridge is possibly the real gateway to the East London Thames Development Area. The scheme would not be a gateway in the same sense.
333
Response by TfL to the objection of LTGF Regeneration 6.929 East London clearly needs to become a more attractive location for business and developers if regeneration is to succeed, as sought by all the relevant levels of Government. Improved accessibility is vital to this. It is mistaken to suggest, as the LTGF does, that local self-containment of the areas north and south of the river is desirable, feasible or likely to benefit local people; or that to protect local residents from competition for jobs and services is to their long term benefit. TfL also disagree with the LTGFs unsupported assertions that improved access from the scheme would be mainly for longer distance car drivers from afar. The model shows the contrary, and tolling could be used to reduce longer distance travel should that be necessary. 6.930 The view of the LTGF that regeneration is happening or will happen anyway is not a perception shared by the development or planning agencies, or by TfL. Canary Wharf, to which the LTGF refers, was supported by major investments in, and commitments to, road and rail. 6.931 It is important that the scheme should provide for general traffic as well as public transport, since the important transport factors for business are employees, customers and suppliers all reliably within easy reach. Business needs both public transport access and general traffic access. 6.932 TfL do not accept that the scheme would not help disadvantaged people north of the Thames.
Policy 6.933 The LTGF takes a narrow view of planning policy. It does not relate the development proposed for the Thames Gateway to the development of the London Plan as a whole or to the wider south-east of England. It does not relate the scheme to its context as a multi-modal highway proposal in a group of public transport proposals. Overall, the balance of transport proposals is appropriate, and firmly prioritises public transport improvements, in accord with Government and Mayoral policies. 6.934 The scheme is part of the London Plan and the Mayors Transport Strategy. It would improve and expand public transport, and it would provide for public transport to be integrated. In these respects it therefore complies with at least three of the Objectives of the London Plan (D620). Few if any schemes would meet all of them. 6.935 The Mayors targets for traffic in London recognise that some traffic growth will continue overall in Outer London, although reduced by one third; and that circumstances vary between Boroughs, and so individual targets are
334
set for each Borough. The traffic growth projections in the scheme analysis are consistent with those targets and there is no inconsistency with the Mayors Transport Strategy. 6.936 The scheme accords well with Government and Regional policy.
Tolls 6.937 The concessionaire would have no control over tolls. Its actions to maximise revenue would be measures to ensure high reliability and availability; objectives of the management of any road. Reliance on tolls is a basis of the scheme, providing necessary flexibility. 6.938 The LTGF refers to the effects of the M6 Toll Road. There is no clear connection with the proposed scheme, for which tolls would provide an effective control on traffic.
Long distance traffic 6.939 The scheme would offer minimal time savings to longer distance users and require payment of the higher tolls charged to non-residents. These factors mean that the scheme would not be an attractive route for through traffic. 6.940 TfLs evidence is that long distance traffic would not be encouraged by the scheme, and the LTGF offers no evidence to the contrary.
Alternatives 6.941 The suggested single two lane carriageway option for the bridge has two major difficulties. One lane in each direction would not provide enough capacity. And there would be no resilience for responding to an emergency, such as a breakdown or an accident, which is an important consideration for a crossing such as the scheme. 6.942 Foot and cycle ferries as suggested by the LTGF have been considered in outline (TfL/REB/4982/1 annex 5), and in any case would not be precluded by the scheme. In practice, the delays and inconvenience of interchange to ferries make them unattractive and not a plausible catalyst for regeneration.
Future baseline assumptions 6.943 In considering the do-minimum case, uncertain schemes should not be presumed, particularly when they are likely to reduce any adverse impacts. The guidance of the DMRB (D522) is that Do minimum networks for each forecast year must be based on the base year network descriptions, and should include all schemes (other than the scheme being appraised) that
335
could reasonably be expected to be in place by that forecast year. Dealing with uncertain schemes through sensitivity analysis, as has been done in the case of Crossrail, is appropriate. 6.944 The Government commitment to road user charging currently extends only to support for debate and some pilot studies. It is not clear how widespread road user charging might apply in London. Given the uncertainties, road user charging should not be included in the base case. 6.945 There is no firm timetable for the Silvertown Link, and so it should not be included in the do-minimum case.
Traffic modelling 6.946 It is not TfLs case that use of the Blackwall crossings would be reduced as a result of the scheme; nor that use of the Dartford Crossings would reduce significantly. The principal component of the projected travel time savings arising from the scheme is for cross river traffic rather than changes in traffic speeds or congestion. 6.947 The scheme would help to provide reliable journey times but not as a result of it being a large road scheme; its segregated public transport lanes would reduce risk of disruption to public transport. By providing another river crossing, it would add resilience to the network. The tolls would provide another way to manage traffic and congestion. 6.948 Although the LTGF criticises the traffic forecasts, the bases of the criticism are not stated. 6.949 There is no evidence that the scheme would cause significant traffic increase to or from the A2; rather, such traffic would be reduced. 6.950 There is no basis for the LTGFs assertion that the revision of the model reduces its ability to predict the future. As to the retrospective checking of models, the evidence of Professor Whitelegg refers to various such studies. The causes of poor forecasts identified by the National Audit Office (Document 4983/3) have been addressed in TfLs modelling of the scheme. 6.951 Although traffic policy measures could result in lower traffic growth than currently forecast, this is less likely than the traffic scenario presented to the inquiry in support of the scheme. In any case, far from causing difficulties for the scheme, lower traffic would enable realistic consideration of other tolling options that would improve the regenerative effect of the scheme, including those that might allow higher levels of use without adverse effects elsewhere. 6.952 No basis is given for the LTGFs assertion that the do-something case does not allow adequately for induced traffic.
336
6.953 There is no error in DMRB, which the LTGF criticises in respect of its standards for road capacity. The DMRB is consistent in this respect with the road safety guidance issued by the DfT, which the LTGF considers to be correct. The Saturn modelling suite does not allow modelled traffic to increase beyond maximum saturation flows. Modelling - robustness of the model 6.954 The re-based model incorporates many more traffic counts in its calibration/validation, and the calibration/validation has improved. The results prior to the adjustment of the tolling proposals are very similar to the previous forecasts for use of the scheme, and this demonstrates a robustness of the modelling approach. Furthermore, the inclusion of a further level of detailed junction analysis adds to the rigour of the work. The new modelling provides a robust basis for making decisions on the scheme.
Cycling and walking 6.955 The LTGF ignores the benefits that would be provided by lifts on either side of the river. They would be provided, and the walking and cycling distances across the scheme would be as short as allowed by the width of the river. Given that width, it is unlikely that very large numbers of people would walk to work across the new bridge. But some may find it useful, for example between Thamesmead and Becton or the Royal Docks.
Speed limit 6.956 It is not TfLs position that the speed limit on the bridge would not be enforced. TfL are committed to minimising casualties.
Traffic mitigation 6.957 The mitigation measures are designed to ensure that traffic growth is maintained within the reasonable capacity of the road network, and that there is not excessive congestion which could otherwise result in increased traffic on residential streets. 6.958 North of the river, additional traffic counts were undertaken. The modelling there shows good achievement of DMRB screenline guidance. All links have been examined and more detailed junction analysis undertaken at a number of junctions.
Public consultation 6.959 The democratic involvement of the local Borough Councils is a vital part of the scheme proposals, and would be secured through the Boroughs Agreement (Document TfL/22C).
337
The Woolwich Ferry 6.960 TfLs proposals do not include closure of the Woolwich Ferry, which would in any case require an Act of Parliament. A reasonable very local demand for the ferry is envisaged regardless of the scheme.
Public transport 6.961 While the LTGF believes the scheme should be placed further east so as to improve public transport there, its proposed location is very well placed for the Royal Docks, Thamesmead, Belvedere, Erith and Barking Reach.
Crossrail 6.962 While TfL strongly support Crossrail, the scheme and the overall strategy does not depend on Crossrail and there is no case, in the LTGFs evidence or elsewhere, for linking the go-ahead for the scheme to Crossrail.
Comparison with the ELRC 6.963 The similarities between the scheme and the ELRC are that both would cross the Thames between Beckton and Thamesmead and both would link to the A406. The differences are that the TGB would have less general traffic capacity (two lanes in each direction rather than three); it would be a multi-modal crossing with one third of its capacity devoted to public transport (more in terms of moving people); it would have dedicated walking and cycling facilities (linked to the riverside by lifts); and it would be tolled to manage traffic, focus benefits on local people and manage environmental impacts. It would also respond to a quite different development context (higher levels of sustainable communities) for the Thames Gateway and to the recognised need to support local accessibility improvements cross-river. It would also (rather than being the only river crossing proposal as ELRC would have been) follow completion of two rail schemes (DLR Lewisham and Jubilee Line extension) with another under way (DLR to Woolwich) and a further (Crossrail) in prospect. This changed policy context was explicitly recognised by Government in 1995 (RPG9A, TfL/P/01/2, paragraph 4.2) The Simon Wolff Charitable Foundation 6.964 SWCF is a charitable trust which seeks to provide positive solutions to problems concerning transport, health and science. It is managed by a Committee of Trustees, who have authorised the Foundations objection to the TGB proposal. Oxleas Wood and Woodlands Farm 6.965 Oxleas Wood is an area of woodland on the south side of A207 Shooters
338
Hill. Woodside Farm is a working farm on the opposite, northern side of Shooters Hill. They form the largest amenity of this type in South East London, and one of only three or four such amenities in the whole of London. Such places are very important to local people and to people all over London. The ELRC, of which the scheme is an obvious relation, would have destroyed both these amenities by building through them a new road between the new Thames crossing and the A2. 6.966 The scheme is presented as a local crossing that would serve the areas to its north and south. However, it would lead to pressure to revive a north/south route between the new bridge and the A2, in particular through the Oxleas Wood corridor. This future pressure is the subject of an independent study by the consultancy MTRU set out in Document 2065/2/B. 6.967 The study considered traffic flows crossing an east/west cordon to the north of Oxleas Wood. Traffic figures from the promoters Reference Case traffic modelling were used. These show a 50% increase in north/south traffic to the north of Oxleas Wood, comparing the 2001 case with the 2016 with scheme case. It was established in cross examination of the MTRU witness that further comparison on the basis of the Cordon Model, and comparing the 2016 do minimum case with the 2016 with scheme case, identified that the scheme would slightly reduce north-south traffic to the north of Oxleas Wood (Document TfL/229; transcript D75 P207, Mr Buchan). Comparable findings arose from consideration of a longer east-west cordon. 6.968 Nevertheless, traffic conditions with or without the new bridge are predicted to worsen, and this must lead to pressure for further capacity increases. The Oxleas alignment remains attractive in engineering and traffic terms for a river crossing at the scheme location. The only options to avoid such significant traffic increases are that people should travel less; that they should make shorter trips that can conveniently be undertaken on foot or by cycle; or that public transport should offer a sufficient time and cost advantage to result in modal shift away from car use. Removing a major barrier to car travel and imposing a relatively small toll on the bridge would clearly be counterproductive in terms of all of those options. This would lead to increased pressure on the road network and would increase the potential threat to Oxleas Wood. Tolls 6.969 The promoters estimation of the effects of tolls has two shortcomings. First, the modelling shows general traffic to be either diverted to other routes or suppressed by tolls, but only 6% or 7% of bridge users transferring from car to public transport. And secondly, the estimates are that shorter distance traffic would use the bridge rather than longer distance traffic, even though the toll differential would be relatively modest, and even though it is likely that longer distance travellers value their time more highly than those making short trips. It is therefore essential that a local market study is undertaken to identify the real cost levels of deterring drivers and their likely reactions to tolls, especially mode transfer. The
339
modelled tolls would use price to suppress the journeys of the poorest motorists, who apparently then would not transfer to public transport: this must conflict with the regeneration objective of the scheme. Public consultation 6.970 There was no public consultation which was even remotely fair. The most widely distributed questionnaire with a question relating to the scheme was the response form (Document TfL/184/A) that referred to the Draft Transport Strategy and the Mayors Transport Strategy Highlights. This sought views on key elements of the Strategy, the only one of which to refer to the scheme was presented as The Strategys proposal to construct new rail lines, new Thames crossings in east London, and new high quality tram or guided bus schemes. If people supported this element, then that would be interpreted as support for the scheme. Those who opposed it would be opposing high quality public transport schemes, which in any event were largely imaginary. 6.971 Despite his previous emphasis that no new roads would be built in London while he was Mayor, the Mayor of London has promoted the scheme throughout his Mayoralty. The decision to pursue the scheme was made by the TfL Board as a result of a snap vote which turned on the Mayors casting vote. Regeneration and accessibility 6.972 TfLs regeneration case seeks to prove that the scheme is necessary for regeneration. The SWCF has reviewed the evidence before the inquiry as to the proposition that massive road infrastructure helps to regenerate the area around it. 6.973 First, TfL compares accessibility and disadvantage at the Borough level. TfLs data regarding accessibility and numbers of Job Seekers Allowance claimants for the ten Boroughs selected by TfL may be ranked in order of accessibility and stated as follows: Borough Accessibility and Job Seekers Allowance Claimants in East and West London Borough Location Accessibility JSA Claimants (London = 100) (thousands) Bexley East 55 2.6 Richmond Greenwich Hounslow Barking Ealing West
340
West East West East
65 70 72 83 91
1.7 5.7 2.9 3.4 5.6
Redbridge Newham Wandsworth Hammersmith Average Average West West West
East East
93 117 121 129
3.8 6.9 5.1 4.1 3.7 3.2
East
83 96
6.974 Use of the data in this way, to provide ten data points one for each Borough - provides more useful results than TfLs reduction of the data to two points (one for the west and one for the east) by averaging. 6.975 The table strongly suggests there to be no real difference in accessibility between the group of Boroughs in West London and those in the East. 6.976 The t-test is a standard statistical test devised to assess whether an apparent difference is significant or merely the result of having chosen a particular sample. It was developed for small samples, a point to which TfL agreed in cross-examination of their rebuttal evidence to the contrary (D49 P211). Application of the t-test demonstrates there to be no significant difference between the mean accessibilities of the East and West groups of Boroughs. The same conclusion is reached if the Mann-Whitney form of the Wilcoxon test, which does not assume the data to be normally distributed, is used. This makes without substance TfLs conclusion that differences in deprivation are related to accessibility, because there is no significant difference in accessibility when the East London group and the West London group are compared. The 13-point difference between the averages could well be created by the selection of the particular Boroughs chosen, and other chance factors. 6.977 Nor does application of the t-test to the job seekers allowance claimant data indicate any significant difference between the two groups of Boroughs. 6.978 Setting aside the matter of location, a correlation test can establish whether there is a connection between accessibility and the number of job seekers; and such a test has been applied. The finding is that accessibility does correlate with numbers of job seekers allowance claimants, to an extent that is significant at the 5% level. The correlation is positive: the higher the accessibility, the higher the number of claimants. Therefore, if the scheme were built and if the accessibility of the surrounding area were increased, then the promoters data show that unemployment would increase. 6.979 Similar analyses can be made using the IMD data. Bexley and Richmond score well for IMD but poorly for accessibility, while Newham has good accessibility and poor IMD. 6.980 Nor is it clear, at Borough level, that the scheme would significantly improve
341
accessibility. TfLs evidence is that the average accessibility in East London would increase by 6 points as a result of the scheme (TfL/P/05/2 table 6); but such a difference has already been seen to be not significant. 6.981 Secondly, TfL compares accessibility and densities of employment and of population at the ward level. Figure 1 of Appendix B of Document D822 (the Regeneration Statement), reproduced here with the consent of Volterra Consulting Ltd, illustrates the data on which TfLs employment analysis is based (each point on the diagram represents conditions in one ward):
6.982 At every level of accessibility (Access Index in the diagram), hugely varying employment densities can be found. At access index 60 (similar to Richmond and Bexley) employment density is anywhere between 100 to 9,000 jobs per square kilometre. At access index 120 (like Newham) employment density can again have almost any value. Correlation and regression analyses yield no usable result: they do not show a relationship between employment density and accessibility. 6.983 TfLs response to this problem is to use a form of multivariate analysis: cluster analysis with the use of fuzzy logic, using a combination of computer analysis and manipulation by the analyst. This finds six clusters of data, the centres of which TfL joins by straight lines. The results of this approach have the appearance of accuracy, but the actual accuracy is not established. 6.984 Comparing the potential employment ascribed by the promoters to the
342
scheme in Greenwich and Newham, suggests an increase of employment at Borough level of about 8% when based on the Reference Model or, for the five eastern Boroughs, 8% or less when based on the Cordon Model. Without an estimate of error, such forecasts have little meaning. But TfLs analysis is so complex, and of such a nature, as to make an error assessment impossible. Nor is the consideration of different scenarios each resulting in a different forecast in any way equivalent to assessing confidence intervals, as TfL suggest; the possible error caught by the confidence intervals comes after any such allowance for factors of which one knows. A simple manual sizing calculation (2065/1/A1, 5.7.14 to 5.7.17) suggests an error of 13% above or below the forecast - in which case the error is much greater than the forecast and no meaningful forecast is possible. Nevertheless, it was established in cross-examination that more often than not an improvement in accessibility will improve employment, although that would not necessarily apply to the effect of any particular improvement. It would be ridiculous to say, Because there is an upward trend, we will build the TGB. 6.985 It is often the case that spatial data exhibit dependence the value of a variable, x, in one location is often related to the value of x in nearby locations. In turn, spatial dependence affects the outcome of statistical tests, and this point should always be borne in mind when interpreting statistical results. Such spatial dependence is sometimes known as spatial autocorrelation, and is likely to be found in this case in the accessibilities and employment and population densities of neighbouring wards in London. Therefore the t-test finding presented by the promoters in their responses to SWCF (Documents TfL/187/A and TfL/REB/2065/1, paragraph 3.8), relating to the accessibility of every ward in the ten Boroughs considered in detail by TfL and finding a very strong positive relationship, leads to no useful conclusion, since the data are spatially correlated a point subsequently accepted by TfL (D49 P225 L2). 6.986 Later work by TfL (Document TfL/241, page 13) calculated, at the request of SWCF, a quadratic form of regression for employment density and accessibility data for all wards in London other than those in the City of London. TfL then seek to calculate confidence limits on this basis but, although there is agreement regarding some parameters in this work, TfLs assessment is flawed in two respects, which lead to a great underestimation by TfL of the forecasting error: a. It assumes that the scheme would result only in increases (but not decreases) in employment density in each ward. It is wrong to assume that the average line would be followed in every ward; a robust approach would assume the full power of error is operating and that will quite often wipe out any increase caused by the scheme. But TfL have only allowed an error to the increase in employment, not to the whole of employment. b. No account is taken of autocorrelation.
343
6.987 Thirdly, TfLs assessment investigates the wrong variable. Whereas they have investigated employment density, they should have investigated the variables which reflect things people need and want. Such an index is the IMD rating, in which a low score reflects desirable conditions. Employment density measures the number of jobs in an area, not the number of employed residents. Assessment at the Borough level of all 32 London Boroughs (but not the City of London, which is atypical in this respect) finds the following highly statistically significant correlations: a. High employment density is associated with high IMD rating. b. High employment density is associated with high unemployment as measured by IMD. c. Good accessibility is associated with high IMD unemployment. 6.988 TfL are promoting the very thing that causes damage. 6.989 In conclusion regarding regeneration and accessibility, nothing usable has been proved as to access being linked to regeneration. There is a weak upward trend on local employment, and another on unemployment and deprivation. The confidence intervals are so wide as to make the forecasts useless for assessing the value of a single project. Environmental effect of the scheme 6.990 UK experience is often that large roads exist in and near deprived areas which become places where people will only live because they are too poor to do otherwise. The Archway Road motorway scheme, now abandoned, would have exemplified this. An alternative approach 6.991 The promoters have made little attempt to assess the costs of linking roads that would be necessary in addition to the bridge. Yet such roads would be necessary to accommodate the additional traffic that the bridge would carry and which would make local trips, typically within about 3 km of the bridge on either side. Additionally, the scheme might become similar to the ELRC, with a link to the A2 via Oxleas Wood and Woodlands Farm. 6.992 Such an estimate has therefore been prepared (Document 2065/1/A2) on a sizing basis one that provides a reasonable upper bound to the cost, which is not certain but quite likely to happen and unlikely to be exceeded. It includes the bridge itself, the cost of link road provision and the loss in value, caused by reduced environmental quality, of households near the new roads. The sizing cost of the project, including these elements, would be 1,200m for the bridge and extra local roads and a further 140m to reflect losses in the values of homes. If the project were enlarged to
344
include a link to the A2, then the cost of the bridge and link roads would become 1,700m and the losses in values of homes would be 670m. These figures exclude the costs arising from increased pollution. 6.993 Other transport measures that could be taken instead might include a heavy rail link across the river, costing about 500m. A DLR crossing would cost much less. Together with a modest network of public transport routes this would provide a close approximation to a door to door link between all points in the area near the bridge. Such an approach, using trams as might be done here, has been taken in Zurich which is a successful city that has gone far in non-car-based transport. The TfL proposals resemble the approach taken in Liverpool, which has been destroyed by car-based road building, and is one of the poorest cities in north-western Europe. Their application would increase pollution and speed up a net 10% of trips, whereas a Zurich solution would reduce pollution and speed up a net 65% of trips. Cities such as New York, Geneva and Paris benefit from continuing improvements in public transport, whereas London does not. 6.994 Other and better ways to regenerate (than spending 1,200m on the bridge and new local roads) might include: giving the money to the 220,000 households in the area (5,500 each); improving the security of individual houses, installing CCTV in the streets and refurbishing (say) the 20% of households in most need; or spending 1m per kilometre on the 700 km of streets local to the scheme to make them look and feel better and cleaner. 6.995 The scheme should therefore be withdrawn, and alternatives such as these evaluated in detail and consulted on. The response of TfL to the objection of the SWCF Oxleas Wood and Woodlands Farm 6.996 The option of connecting the scheme to the A2 with a high speed highway link was rejected at an early stage by TfL in view of the adverse environmental effects that it would have, the traffic flows created and the land take required for new infrastructure. The Orders for the ELRC were revoked in 1997, with continuing safeguarding for bridge approaches for a short scheme which did not link to the A2. Subsequently, all but one of the properties bought on the route that the ELRC would have taken have been sold. Any pressure to build a road in the scheme/A2 corridor would not be a consequence of the scheme. The tolling regime is designed to minimise such pressure and is designed to be able to respond to any additional pressures. Tolls 6.997 Little through traffic would choose to use the scheme because such traffic would gain little time but pay twice the toll. The discounted local tolls would effectively achieve greater social inclusion in the target areas.
345
Public consultation 6.998 Public consultation was conducted through the planning process in relation to the Mayors Transport Strategy and the London Plan. Specific public consultation on the scheme was carried out from 31 May to 12 August 2003. In April 2004, the interim EIA was published. As part of the planning application process, the scheme was the subject of public consultation for ten weeks from July to September 2004. Three thousand neighbour notices were distributed in the Brampton Road area by Bexley Council. Every reasonable effort was made to publicise the consultation. The Mayor, elected in 2000 and 2004, has published all the strategies required of him by the Greater London Authority Act (D207). Those strategies consistently support the scheme. Regeneration and accessibility 6.999 The area has suffered persistent problems of multiple deprivation. Problems of deprivation are not amenable to simple solutions; if they were, they would have been resolved. Identifying the relationship between accessibility and an areas employment potential allows one to highlight what would be possible if the scheme were provided and a range of other measures implemented. But it is certain that providing childcare, skills or other measures would be of little consequence if those involved cannot physically reach jobs. 6.1000 The Borough level comparison of accessibility and numbers of Job Seekers Allowance claimants presented by TfL in chief is not the basis of the analytical results. Although valid statistical tests of difference can be made from this small data set, the data are not presented as the basis of the statistical argument, nor can they be used as such. Their purpose is to provide some illustrative comparisons of averages for a small selection of Boroughs, included to bring to life some of the differences between East and West London. They show that things are worse in the east than the west. 6.1001 The Borough level information is to an extent distorted by local features. Thus the presence of Richmond Park reduces the accessibility of that Borough, although its areas of high population and employment density have high accessibility. Newham has high accessibility near Stratford, and this skews the result for that Borough. 6.1002 TfL also analysed such data for all the wards in the five East London Boroughs and all those in the five West London Boroughs, and initially assessed as 99.999% the probability that the level of accessibility in the western boroughs is higher than in the eastern ones. But no conclusion can be drawn from that since it ignores spatial autocorrelation. 6.1003 The following is common ground. TfLs work on clustering and quadratic regression proves that, overall, more accessibility means more employment and more population. Whichever technique is employed, the result supports
346
the contention that an improvement in accessibility would more often than not improve employment. But the regression analysis results should only be used with some caution, since the data were spatially autocorrelated. For that reason, and because there are omitted variables, fuzzy clustering analysis is more useful. Although it is not possible to derive a confidence interval when using fuzzy clustering, that is no reason to lose confidence in its finding that employment and population densities are positive correlated to accessibility. The method used to compare scenarios is conservative. 6.1004 As to the uncertainty suggested by the cloud of results from individual wards, the model suggests an increase in employment of about 8% as a result of the scheme, whereas SWCF estimate the error band on either side of that forecast as about plus or minus 13%. If so, the change in employment arising from the scheme might be between a 21% increase and a 5% reduction. The error band is therefore plainly skewed towards the positive: a strong relationship which, on balance, would produce an increase in employment. An 8% increase in employment is the most likely outcome. It is unlikely that the scheme would lead to a reduction in employment density. 6.1005 The relationship identified from the cluster analysis is robust. There can be reasonable confidence that the potential it models will exist as a result of changing accessibility. The balance of probability is that increasing accessibility by providing the scheme would improve the willingness of people to come and live and do business in the area: they could do business, access labour markets, get jobs and visit their friends and relatives. Environmental effect of the scheme 6.1006 The Archway example is a false analogy. That abandoned road proposal was intended as part of a strategic, high capacity motorway network for London as a whole. This scheme would be none of those things. As to the attractiveness of the areas near the scheme, there is considerable developer interest in residential and commercial development near the scheme. Many of Londons bridges, such as at Putney, Wandsworth, Battersea and Hammersmith, have popular high-priced housing nearby. An alternative approach 6.1007 None of the additional construction or scheme enhancements referred to by the SWCF is necessary. 6.1008 The London Plan (D620) contains proposals for two major street tram systems, both of which are being progressed. The scheme would serve bus-based public transport on the ELT, GWT and road network and could be adapted to another transit system later. 6.1009 Non-transport measures are required to ensure that regeneration happens
347
in this area. People Against The River Crossing 6.1010 PARC is a transport and environmental organisation that grew from a group of objectors at the 1984-1986 inquiry into the ELRC. It has a constitution, a Committee and about 150 members. Its objection has been authorised by the Committee. Since 1985, PARC has led the campaign to protect Oxleas Wood and has contributed to statutory consultations on UDPs, the London Plan and the Mayors Transport Strategy. PARC also led objections to the proposed construction of a car park on Metropolitan Open Land at Woolwich Common as a car park for the Queen Elizabeth Hospital in 1996. PARC gave evidence at the inquiry held in 1990 into the ELRC. 6.1011 PARC objects to the planning application and the various draft Orders that were the subject of the inquiry on the following grounds: a. The proposal does not conform with the adopted Development Plan. b. The proposal does not accord with PPG13. c. The scheme would increase traffic congestion in the surrounding area, and would not lead to a maximising of use by non-car modes of travel. d. The effects of the scheme on noise and pollution over a wide area would be likely to be negative and significant. e. The design of the scheme is not yet finalised, but the designs so far put forward look extremely ordinary. A high quality of design would not be secured. f. The promoters assessment of the effect of the scheme on regeneration is extremely speculative. Previous schemes 6.1012 Previous proposals, including Ringway 2 (first proposed in 1944) and the two ELRC schemes, would have attracted and carried large volumes of traffic. They would have included substantial road infrastructure south of the Thames, including a road through Oxleas Wood towards the A2. Studies undertaken when the first ELRC was promoted had considered the alternative of terminating the ELRC at Thamesmead, but concluded that to do so would result in large volumes of extra traffic on local roads. Subsequent work between 1996 and 1998 on behalf of the Government Office for London resulted in the East Thames Appraisal Framework, a study that promoted the idea of three river crossings in the area (a road crossing at Gallions Reach with some public transport provision, a rail crossing at Woolwich and a third crossing at Blackwall) and introduced the concept of
348
tolling the Gallions Reach bridge to provide revenue and to regulate traffic. Oxleas Wood 6.1013 The modelled traffic flows, presented by the promoters as part of their original evidence, may be considered along a short east/west cordon between Upper Wickham Lane and Grand Depot Road. That cordon forms a boundary to the north of Oxleas Wood. Such consideration finds that traffic flows in the north/south directions to the north of Oxleas Wood would increase by about 50% from year 2001 to the 2016 with scheme case. Further analysis of the promoters initially modelled traffic flows suggests that this change would not be a result of traffic switching from parallel routes further east. There would be substantial demand for highway capacity increases on a north-south axis immediately north of Oxleas Wood. 6.1014 In highway engineering terms, the ELRC preferred route for a link between a bridge at Gallions Reach and the A2 passed through Oxleas Wood. There is no evidence that Oxleas Wood would no longer be on such a preferred route. A higher rate of traffic growth during the assessment period, or growth after the assessment period, would add to the pressure for a new road through Oxleas Wood to be built. 6.1015 Although the Mayor and TfL have said that they would vigorously oppose any plan to extend the scheme south through Oxleas Wood, this gives little reassurance in the long term, because the current Mayor will not remain in office indefinitely, and because TfL acts on instruction from its Board, whose membership changes from time to time. Evidence remains that, if the scheme were implemented, there would be pressure in future to reinstate the complete ELRC scheme, threatening Oxleas Wood and the nearby 89 acre Woodland Farm, together with over 200 homes in Plumstead. Air quality 6.1016 Air quality is a significant problem in London. Much of the area influenced by the scheme is currently subject to poor air quality, especially close to busy roads. Between 450 and 1,800 Londoners die prematurely each year due to poor air quality. Mortality associated with poor air quality is not a comprehensive indicator of the total impact of air pollution on health; clear evidence is emerging that long-term exposure to pollutants, especially particulates, even in low concentrations, can have adverse effects on the health of large numbers of people in large cities such as London. However, the promoters evidence concentrates on the short-term effects of these pollutants. 6.1017 It would be unreasonable to expect any model to predict traffic flows accurately on every link over ten years into the future. However, the Environmental Research Group (ERG) air quality model upon which the promoters rely is based on a traffic model apparently derived from several sources, some of which have been found unreliable. The promoters
349
predictions of air quality in future years should be treated with the greatest circumspection. 6.1018 The ERG model uses 1999 as a base year, but that was not a particularly high pollution year. Conditions were worse in 1996 and 2003, and TfL attempted to compensate for high pollution years. Although 2003 is arguably atypical, it is likely that climate changes in future will cause more frequent phenomena such as temperature inversions and changes in wind direction. Thus 2003 would not be an unusual or unreasonable year to choose as a baseline for the ERG model outputs. 6.1019 Notwithstanding the promoters argument that better vehicle technology will tend to reduce air pollution to a greater extent than that due to general traffic growth, it remains the case that in the 2016 assessment year air quality would be worse with the scheme than without it. There would be a noticeable deterioration in air quality both for nitrogen dioxide and PM10, and the full effects of this would fall disproportionately on those with reduced mobility, perhaps elderly people with existing cardio-respiratory disease. 6.1020 The promoters evidence is also lacking in other respects. There is no rigorous modelling of ozone as a pollutant. No assessment is presented of the effect of the scheme on the presence of ultra-fine particles (produced by petrol and diesel engines and less than 1 m in diameter), although such particles are increasingly thought to have long-term adverse health effects. No allowance is made for cold starts, in which vehicle engines running cold near the start of a trip produce dirtier emissions than when fully warmed up. There are likely to be particularly relevant here where over a third of the traffic on the bridge is expected to be making short trips. Moreover, the poor air quality predicted alongside the northern part of the scheme is at odds with the promoters proposal for a linear park in the same place the pollution making it a facility that few would choose to use. Noise 6.1021 London is becoming noisier. Road traffic is the major cause of human exposure to noise there. Noise is the only environmental problem for which complaints have increased since 1992. There is no doubt that there is a large rise in dissatisfaction and annoyance with noise when extra noise is introduced into an area, as would be the case with the scheme. The scheme would increase community annoyance with noise, disturb peoples sleep at night and adversely affect schools. 6.1022 The known inaccuracies in the traffic model reduce the reliability of the noise assessment prepared by the promoters. 6.1023 TfLs assessment includes the finding that the major noise increases associated with the scheme would occur south of the scheme, where current noise levels in Thamesmead and Greenwich are low. Residents of those
350
areas are likely to have become used to low noise levels, and so it may reasonably be assumed that they would be more affected by the sudden increase in noise when the scheme came into use than is suggested by the promoters assessment. 6.1024 The method for assessing noise nuisance set out in the DMRB and used by the promoters may be criticised as follows. The method is based on annoyance surveys carried out over a period among people living near to certain road schemes. The finding that people become acclimatised to traffic noise over time may also be explained by a change in the population in the affected area during the period in question those who are particularly disturbed by noise move away, if they have the means and opportunity and a more noise-tolerant population moves in. Those who lack the means or opportunity to move would remain, regardless of their sensitivity to noise. Furthermore, in mixed tenure housing developments, the turnover of population tends to be higher in affordable housing than elsewhere. An effect of this is that with regard to population exposure to an ambient noise level, the constantly changing population makes survey results very difficult to interpret. Therefore, it could be that the DMRB method overestimates the acclimatisation effect. 6.1025 The promoters assessment of night time noise in accordance with the DMRB finds more than 500 properties to experience a noise increase of more than 3 dB as a result of the scheme. But when considered against the WHO threshold of 42 dB LAeq,T above which residents would need to close their bedroom windows to enjoy sleep undisturbed by traffic, even more properties would be adversely affected by the scheme. Health implications of the scheme 6.1026 Although there is no statutory requirement to do so or standard framework for their preparation, health impact assessments (HIAs) have been undertaken on many occasions such as the Mayors Transport Policy and for schemes in Sheffield and Edinburgh. The HIA for the scheme (D808 chapters 15 to 17) is not consistent with good practice. It is too narrow in its scope, and was applied at a stage when it was too late to influence the major transport decisions that needed to be taken in East London. It is based on very little research evidence, instead depending on a single source of evidence provided by TfL and deemed by them to be correct. Although the promoters traffic model is fundamental to the HIA, no attempt has been made to assess the robustness of the traffic model, nor its range of errors, nor the effect that such errors could have on the overall health effect of the scheme. There has been no full or rigorous assessment of the health impacts of the Thames river crossings. 6.1027 The promoters claim that the scheme would promote access to health care facilities has no evidential basis. Over 85% of consultations and patient interactions with the NHS take place within primary care. Most general practices in London have closed lists and are full. Many practices will only take patients within 1.5 or 2 km from their surgery. Very few patients in
351
the four Boroughs closest to the scheme will be registered with doctors on the other side of the river. It is very difficult to see how the scheme would benefit access to primary care. 6.1028 Rather, the actual barriers to health care access in Greenwich, Bexley, Newham and Barking & Dagenham have nothing or very little to do with the scheme. There are many vacancies for general practitioners and other primary care staff in London, and particularly in its poorer areas. Bexley has the highest number of vacancies of any London Borough. The situation is likely to deteriorate further before the scheme is likely to open since during that period there will be a peak in the number of GPs reaching retirement age throughout London. Furthermore, many practices in deprived areas have a large turnover of patients (due to the relatively transient nature of the population in such areas) and this makes access to primary health care more difficult. 6.1029 The scheme would only marginally affect secondary and tertiary hospital services in Greenwich and Bexley. There is no evidence that there is significant cross river travel to hospital services elsewhere in London where there are more river crossings and so it is unclear how the scheme would affect access to secondary services in the four nearest Boroughs. Tertiary hospital services for Greenwich and Bexley are provided by Kings College Hospital in Brixton, St Thomass Hospital in Lambeth and Guys near London Bridge station, and the scheme would not affect trips to them. 6.1030 While it is the case that unemployment is bad for health, it is also the case that some types of employment are bad for health. Any argument that the scheme would, by increasing employment in the area, result in better health should be supported by reliable evidence of the extent to which local jobs would depend on the scheme, how many local people would work in those jobs, and the extent to which such employment would be beneficial to health. No such case has been put. There is no evidence that the scheme would redress current health inequalities; indeed, it is often the case that increased traffic as a result of projects similar to the scheme creates substantial negative health impacts, falling disproportionately heavily on the poorer sections of the community. 6.1031 The Interregional Planning Statement Growth and regeneration in the Thames Gateway (Document TfL/20) advocates timely provision of healthcare, education, public spaces and other facilities to meet existing problems and demand generated by growth. Had those been tackled in the past, such problems would not exist now. To rely on substantial transport infrastructure projects as means of reducing health inequalities is unlikely to be effective. Most of the Department of Health literature on this matter concentrates on Sure Start, neighbourhood renewal, reducing smoking, reducing high cholesterol diets and reducing teenage pregnancies which have very little to do with the scheme. Evidence given by Strategic Health Authorities for the Thames Gateway in London identify the service developments that would be needed to accommodate the projected increase in population, but contain very little about any need to connect those
352
services across the Thames via the scheme. The growth and regeneration plans for the area try to address health inequalities from an area which would not be of assistance. Regeneration - accessibility 6.1032 Access in the Thames Gateway to employment, in particular, should be targeted at people who have low incomes or no employment. Such people are particularly concentrated in Newham, Tower Hamlets, the northern part of Greenwich and some small areas of the northern parts of Bexley. They typically do not have use of a car. But the scheme would provide much greater accessibility for car users than for public transport users. 6.1033 The scheme would provide a crossing of the Thames with the largest capacity in the whole of Greater London. That amount of capacity for road vehicles is unnecessary; indeed, there is no need for another road crossing at all, although there may be a case for improving public transport crossings in this area even after the DLR Woolwich Extension and Crossrail are in place. 6.1034 There is also a difficulty with regard to the skills of the local population. The projected jobs in the Thames Gateway, particularly in the four Boroughs nearest the scheme, are office and service based, requiring skills and education at the equivalent of NVQ 4 or higher. This is far above the current skills and education level of the local population which, for example, has a lower GCSE pass rate, at grade C and above, than the London average. In the relatively short time before the programmed opening date for the scheme, it seems extremely unlikely that the skills level of the local population could be raised sufficiently to take advantage of new jobs resulting from the scheme. It is most likely that such jobs, if they did occur, would be taken by higher skilled and better educated longer distance commuters rather than the local population. Traffic model 6.1035 Since the outputs of the traffic model underpin the promoters economic and environmental evaluations and the assessment of the scheme economics, it is necessary that the model should perform well. However, the model findings given to the inquiry by the time of PARCs appearance on days 33 and 34 are not sufficiently robust to engender confidence that those critical matters are likely to be accurately assessed. The SACTRA report made in 1994 found that modelling had great difficulty when dealing with complex matters such as trip generation, particularly when modelling congested urban areas and estuarial river crossings both of which are the case here. Tolling 6.1036 The public consultation regarding the scheme has found the proposed toll to
353
be unpopular. It could therefore become politically expedient to reduce or remove the toll at some time in the future. Similarly, if the toll increased then the economic benefits of the scheme would fall. It would therefore be in the concessionaires interest for the tolls to be kept as low as possible, and they might seek to persuade TfL and the Government to allow that. 6.1037 The promoters offer no assessment of the different effects that changes in tolls would have on poorer motorists. Global warming and climate change 6.1038 The promoters evidence shows that the scheme would cause an increase in the emission of carbon dioxide, a greenhouse gas. The promoters argue that the increase would be acceptably small, but that is not the case, for two reasons. First, the traffic model on which the promoters case is based is not accurate enough to allow such a conclusion to be drawn. Secondly, no increase in greenhouse gas emission would be acceptable. Any such effect could be reduced or reversed if a local transport strategy was adopted in the TGB area with public transport only crossings. Alternative proposals 6.1039 TfLs approach to assessing alternatives to the scheme does not comply with the recommendations of the Treasury Green Book, nor the New Approach to Appraisal recommendations (encapsulated now in WebTag) on transport appraisal. NATA recommends the following process: a. The establishment of an agreed set of objectives. b. Analysis of current and future transport problems in the area. c. Exploration of potential solutions. d. Detailed appraisal of the proposed solution. e. Selection of the preferred solution, taking account of the views of the public and transport providers. 6.1040 That process has not been followed. There has been no attempt to make a critical and valid analysis of the transport problems. There has been no attempt to provide a range of solutions, including public transport only solutions. Whereas NATA requires that the process should avoid leading to a particular outcome simply by virtue of the method adopted, all the alternatives were tested against a single model which had to include a dual 2 lane carriageway road as the starting point.
354
Public consultation 6.1041 The public consultation carried out by TfL does not show what the promoters claim. The material presented to the public was biased in favour of the scheme, with no detailed explanation of its disbenefits or the uncertainties involved in predicting its outcomes. Response by TfL to the objection of PARC 6.1042 The schemes compliance with planning policy in general and with PPG13 in particular are described in the promoters evidence in chief. Previous schemes and Oxleas Wood 6.1043 Since the abandonment of the ELRC scheme in 1993, the Jubilee Line Extension and the DLR extension to Lewisham have been completed, and the Woolwich extension of the DLR is under construction. The Crossrail Hybrid Bill is before Parliament. The ELRC would have had no tolls or any dedicated provision for public transport. Since the objective of the ELRC was to link to the A2, it is only to be expected that terminating a non-local crossing in Thamesmead would have been inappropriate. 6.1044 The forecasts for the scheme provide no basis for believing that it would increase pressure to build a new road from Thamesmead to the A2. It has been clearly demonstrated by the promoters that there is no policy platform for such an extension, nor any moves to purchase any property outside the boundary of the Compulsory Purchase Order that was before the inquiry. The scheme has been subject to examination through the Mayors Transport Strategy (D630), the London Plan (D620) (including an examination in public (D613)), and the local Borough UDP processes in Newham, Greenwich and Bexley (D634, D617 and D667). Nowhere in these policy documents is an extension from the scheme to the A2 proposed or supported. Air quality 6.1045 There is expected to be a substantial improvement in air quality for people living in the study area by the time the scheme would open, and this would be hardly affected by the very small increase in exposure to pollutants caused by the scheme. 6.1046 Although there is some uncertainty in the air quality modelling, the findings present the most likely outcome on the basis of current knowledge. It is not clear how it would help decision makers to know that the concentrations could be 20% higher or lower than the values presented. 6.1047 Air quality modelling was carried out using 1999 weather conditions, but, since 1999 was not a high pollution year, allowance was made in the
355
modelling to simulate the unusual conditions experienced in 2003; actual data for 2003 were not available at the time the modelling was carried out. 6.1048 Ozone is not a local pollutant. It was considered in the ES (table 16.5, D808), and the effect of the scheme in that respect would be negligible. Noise 6.1049 London is not becoming noisier. There was no statistically significant change in noise level between 1990 and 2000. Complaints in London about noise levelled off in 1998 and do not normally relate to traffic noise. 6.1050 The assessment of the noise effect of the scheme as slight is reached after a thorough examination of the noise predictions. The lay objector may find the process hard to follow and so, to ensure transparency and equity, the Government issues guidance based on scientific consensus. If it were the case that the area affected by the scheme had a higher population turnover than the rest of the UK, then it is likely that the degree of annoyance with that noise would reduce even faster than predicted by the DMRB since people moving into the area would accept the noise climate as is. 6.1051 Of the properties that would experience a rise of more than 3 dB at night, all but 26 would be below 40 dB and the remainder in the range 40 to 50 dB. The WHO sleep disturbance criteria have not yet been accepted as the basis for UK assessment. Health implications of the scheme 6.1052 A HIA is not a requirement of the assessment of a proposal such as the scheme, and so the health assessment in the ES (D808, sections 15-17) cannot be said to be deficient. In addition to the air quality effect of the scheme described previously, that assessment refers to a correlation between affluence and health, and finds that with an increase in potential employment, health would be likely to improve too. 6.1053 PARCs view of access to health care is current and takes no account of the scale of development and the increase in population envisaged, both of which are likely to mean more primary health facilities in the area. The scheme would allow better health service planning in the area, perhaps including providing facilities on one side of the river to serve people on the other. Regeneration - accessibility 6.1054 There are numerous public transport crossings of the river in East London, already built, under construction or planned. The capacity of the scheme for general traffic would be provided by four lanes, a similar provision to that on a number of other bridges across the Thames in London.
356
Traffic model 6.1055 The SACTRA finding of 1994 to which PARC refers relates to modelling at that time, which would have used a fixed matrix, allowing little if any trip generation or mode split, whereas the modelling for the scheme allows for both. Tolling 6.1056 The economic benefits to which PARC refers, and which would fall if the tolls were increased, relate principally to the travel time savings the scheme would bring. Toll revenue, however, would increase with higher tolls. But both points are irrelevant, because the concessionaire would be compensated for changes in the tolls made by TfL outside inflation-matching increases, and so he would be indifferent about toll level. 6.1057 The effect of rising tolls would depend on how they were increased. If local resident tolls were held down, then the key beneficiaries in the local areas would be no worse off. Global warming and climate change 6.1058 PARC considers the traffic model insufficiently reliable properly to predict changes in carbon dioxide emissions arising from the scheme, but even if the increase was twice that predicted it would remain extremely small at 0.8% of the total across the study area. The Mayors Transport Strategy has been adopted for the area (D630) which prioritises public transport, but does not exclude all road proposals. Alternatives and consultation 6.1059 These matters are addressed in the promoters responses to Mr Buchan (Document TfL/REB/4982/1) and to the Hamilton/Focas report (Document TfL/REB/4984/1). Friends of Danson Park 6.1060 Friends of Danson Park is a voluntary group, formed in 2001, to promote and protect the interests of Park users, to promote the environment, and to protect and enhance the wildlife in Danson Park and its environs. It has around 180 members, and is managed by a Committee, who have authorised the objection to the TGB applications. 6.1061 Danson Mansion, located within the 78.5ha Park, which is listed grade 1, was built in 1766, and has recently been restored by English Heritage. It was reopened by HM The Queen during the time that the inquiry was sitting.
357
Unsuitable roads 6.1062 The roads south of the bridge would be very different from those to the north. Roads on the north are generally dual carriageways with grade separated junctions and very little residential frontage. On the south, traffic to and from the bridge would travel extensively along residential streets not designed for large traffic flows. 6.1063 In particular, local knowledge makes it clear that the A221, which runs alongside Danson Park, would be used as a direct route from the TGB to the A2. Traffic on the A2 would use the TGB to cross the Thames rather than the Dartford Crossing, because it would save time, and the extra toll would be covered by the saving in fuel arising from the reduced mileage. Any vehicle with satellite navigation would undoubtedly be directed to the A221, because it would be the shortest and most direct route. Then, as traffic built up on the A221, drivers would rat run the quieter residential streets nearby to find their way to the bridge. 6.1064 If the TGB is to be allowed, Friends of Danson Park would ask, as a minimum, that there should be no signage at the Danson Interchange indicating that as a route to the bridge. Consultation 6.1065 Residents who would be most affected by the proposed bridge did not receive details about it until a very late stage. There was no consultation with them. It was only when objector groups such as AGAB began to make information available that people in the area even began to have any knowledge about the bridge. Even in May 2005, when members of the Friends of Danson Park were engaged in a local awareness campaign in the Broadway Shopping Centre in Bexleyheath, very many people to whom members spoke had no knowledge at all about the bridge proposal. Traffic modelling 6.1066 TfLs original traffic modelling underestimated current traffic levels in Bexley. There is no greater confidence in the revised figures. There is a direct route from the proposed TGB to the A2 using Danson Road, and whenever there was any problem at Blackwall Tunnel or the Dartford Crossing, the TGB would be used to avoid the problem. Environmental considerations 6.1067 The air and noise pollution generated by the extra traffic that the bridge would engender would be detrimental to park users. It is already difficult to cross Danson Road to gain access to the Park. Increased traffic would make that more difficult.
358
6.1068 The recent grant of permission for the new P&O London Gateway Port, planned for Thurrock, would create further additional traffic. Some 3.5 million containers would be handled there each year, and it is estimated that a quarter of them would have destinations within 40km of the London Gateway. Response by TfL to the objection of the Friends of Danson Park Unsuitable roads 6.1069 AM peak flows on Danson Road would in fact decrease as a result of the TGB. Further to the north, decreases are also shown on Brampton Road. For this reason, TfL do not consider that the scheme would generate a rat running problem in the Danson Park area. If any problem did arise on inappropriate residential streets, mitigation measures would be taken under the Boroughs Agreement/Unilateral Undertaking procedure. 6.1070 The TGB would not be signalled as a through route, and any through traffic would be subject to higher tolls. Satellite navigation would not overcome the cost and time penalty to through traffic of using the TGB. Consultation 6.1071 There was extensive consultation including in Bexley in 2003, involving brochures, flyers, local newspaper advertisements, roadshows and exhibitions. Among the roadshows was one in Danson Park at the Danson Park Festival in 2003, where the Friends of Danson Park were also represented. Traffic modelling 6.1072 TfL have always made it clear that the underlying forecasts are for growth in traffic levels between 2001 and 2016. The A221 is classified as an A road and a London distributor road within the Bexley UDP. Long Lane and Brampton Road are also classified as London distributors, that is roads providing for through traffic movements and links to strategic roads, as defined in Policy G18 of the Bexley UDP. 6.1073 It may be that, if the Blackwall Tunnel or the Dartford Crossing were closed, traffic would divert to the TGB, but transport planning does not take place with exceptional events in mind. Environmental considerations 6.1074 In terms of pollutants at the nearest receptor to Danson Park (in Brampton Road) there would be a slight reduction with the TGB. In terms of traffic noise, overall in the long term very few more people would be bothered by noise as compared with the situation without the TGB. That would
359
particularly be the case where, as here, traffic flows would be lower with the bridge than without it. 6.1075 Long distance through goods vehicle traffic which did not have business in the area of the TGB would be deterred from using it (and therefore from using roads connecting with it) by the toll structure. Bexley Civic Society 6.1076 Bexley Civic Society was formed in 1971 to develop and protect the amenities of the London Borough of Bexley. It has a membership of just over 300. Its objection to the scheme was properly authorised by the Societys Planning and Conservation Committee. 6.1077 The Society has never opposed the building of the TGB in principle. It is desirable to improve communication between East London and the South East, both for the economy and for social interchange. The river does separate north from south. But a six lane bridge is inappropriate because of the traffic congestion which would inevitably occur on the south side of the crossing. Roads north of the proposed crossing are largely in place, but this is not the case on the south. A large volume of traffic heading south would come from the bridge and cause major congestion. 6.1078 The traffic system in Bexley, and, to a lesser extent, in Greenwich, is inadequate, and there are minor roads in Bexley which would become rat runs for traffic heading for the A2 and the M25. One such route which would be taken is Knee Hill, which is narrow and runs through protected woodland. While it is classified as an A road, it could not be improved without causing significant environmental damage. 6.1079 One solution to the problem would be to build a special new road from the bridge to the A2, but this solution has been explored already through the ELRC proposal, and it was overwhelmingly rejected by local people. The Civic Society do not suggest that that battle should be re-fought. 6.1080 The Society believes instead that a bridge providing accommodation only for rail, cyclists and pedestrians would be the best solution. The rail provision should link up with the DLR. North of the bridge, that would not be difficult. There are DLR stations at Gallions Reach and at Beckton. To the south, the line could link with the North Kent Line at or near Plumstead Station. Ideally, there could also be a rail link to the DLR to Woolwich and Lewisham, and even a link eventually with Crossrail. The rail link could carry both passengers and freight. It is Government policy to promote rail as against road usage. TfL should work on the practicability of this alternative solution.
360
Response by TfL to the objection of the Bexley Civic Society 6.1081 Document TfL/238 shows that the TGB scheme would marginally improve traffic congestion in Bexley in 2016 compared with the situation without the TGB. A contributory factor to that improvement would be the introduction of tolls to control traffic levels on the bridge. Documents TfL/202, TfL/208 and TfL/210 demonstrate that traffic changes resulting from the TGB with the revised tolling proposals can be accommodated on the network. 6.1082 Much of the traffic travelling on Bexley roads as a consequence of the TGB would be local in nature, with either an origin and/or a destination in the Bexley area. Through traffic would be discouraged from using the TGB as a result of unattractive journey times compared to using alternative river crossings at Blackwall and Dartford. The differential tolling regime would also discriminate against non local traffic. 6.1083 The Boroughs Agreement and the Unilateral Undertaking provide for mitigation measures to be implemented where there would be a material adverse traffic impact on any highway arising from the TGB. Measure which would be implemented before the opening of the TGB would include proposals to deal with problems foreseen in the area of Knee Hill. An area wide strategy would be developed in consultation with officers from Bexley. This could include restrictions on particular vehicles (such as lorries), traffic calming, additional pedestrian crossings or low speed limits. 6.1084 There is no proposal for a link from the TGB to the A2. 6.1085 The Bexley Civic Society was able to quote no evidence to support its view that there is no need for a road bridge. In fact, the necessary investment in industry and services would include a need for road access to the industrial and service developments created. Woolwich and District Antiquarian Society (WDAS) 6.1086 WDAS is a local history and conservation society. It was founded in 1895, and it currently has between 150 and 200 members. WDAS was an objector to the ELRC scheme, and the terms of its objection to the TGB have been approved by the Council of the Society. 6.1087 The TGB would bring additional traffic to unsuitable local roads, particularly to the south of the river. That traffic would bring with it noise and pollution. Knee Hill and New Road are close to Lesnes Abbey, an historic monument of national importance. New Road, in particular, lies within 300m of the Abbey. Pollution from motor vehicles causes decay in the fabric of buildings, especially old ones. The increased noise and pollution from the traffic would also reduce the enjoyment by the public of Lesnes Abbey Woods.
361
6.1088 The proposed TGB would be on the site of the Princess Alice disaster of 1878. The pleasure cruiser was in collision with a collier at Tripcock Point, and 500 people lost their lives, mainly as a result of river pollution from sewage contamination. Now there is to be a new village at Tripcock Point, with 2,000 units of residential development, commercial and retail development, with a school and a hotel. Thousands of people would be living and working near the new contamination of noise and air pollution. People may become accustomed to noise, as TfL claim, but they do not become accustomed to atmospheric pollution. Asthma and chest problems are already prevalent in this part of the Thames area because of the low lying land, where pollution is trapped, and where the prevailing winds carry pollution from other parts of London to this area. 6.1089 WDAS is concerned that the build up of traffic if the TGB were constructed would lead to pressure to consider again the former ELRC scheme to join up to the A2 with a motorway level road. The ELRC scheme would have damaged the setting of the Parish Church of St Nicholas at Plumstead, a Roman burial site at Kings Highway and passed through Woodlands Farm at Shooters Hill and Oxleas Wood. If the proposal for a link to the A2 were to reappear, these sites would again be at risk. 6.1090 The TGB would not be a local crossing of the Thames. Differential tolling would not deter long distance traffic 6.1091 Government guidelines stress the importance of reducing road traffic and encouraging public transport as a means to combat global warming caused by road traffic. The Thames in this area is already crossed by the DLR, the Woolwich Ferry, and the Greenwich and Woolwich foot tunnels. The Crossrail proposal is also currently under consideration. These call into question the need for another road based crossing. 6.1092 The alleged benefits of the bridge in terms of jobs and regeneration seem vague and uncertain. The provision for buses across the bridge also seems vague and only provisional. 6.1093 Existing road bridges and the supports for elevated lengths of road seem to attract graffiti and general squalor. WDAS is not convinced that the TGB would be any different if it were built. Response by TfL to the objection of WDAS 6.1094 The TGB would lead to increases in traffic on some roads and to decreases on others, but, overall, the level of traffic on roads in the area would increase in the period to 2016, whether or not the TGB was built. 6.1095 The plans for the TGB are well known to residents moving into the area. The developers of Tripcock Point have included visualisations of the TGB in their promotional material.
362
6.1096 The proposed bridge would have a 40mph speed limit. The scheme would in no way reflect the design standards for a motorway. There is no proposal to link the bridge to the A2; nor is there any national, regional or local policy which would support such a link. 6.1097 No evidence is adduced by WDAS to support the claim that long distance through traffic would not be deterred by differential tolls. 6.1098 The TGB is part of a package of cross river schemes outlined in the Mayors Transport Strategy and the London Plan. These schemes would provide the additional capacity required to allow for the level of growth outlined in the London Plan. The majority of the additional capacity to be provided is for increased public transport. Formal commitment to a particular level of service by buses across the TGB cannot legally or practically be made by TfL at this stage, but an indication of the minimum level of service envisaged has been given to the inquiry. Saints Residents Association (SRA) 6.1099 The SRA represents the views of people who live in the 150 or so houses in the streets adjacent to Yarnton Way in Bexley. Qualifying households are automatically members of the Association. The SRA has a formal constitution, and is managed by a Management Committee, which has authorised the objection. A local link 6.1100 A public transport system which would connect the communities on each side of the river would be generally welcomed, but a road crossing of the size proposed by the TGB does not generate the same enthusiasm. People find it hard to believe that it is genuinely intended as a local link. 6.1101 The Blackwall Tunnel was originally a single bore, with no direct link to the A2 or the A20. It attracted more and more traffic, so the second bore was constructed in the 1960s. By that time, people living in the immediate area of the tunnel found it difficult to drive to and from their own houses at all times of the day and night. There is real concern that the same thing would happen on residential roads in Bexley if the TGB were built. 6.1102 The north side of the bridge would be well served by major trunk roads, but the south side would be connected to the A2016/A206. The A2016 at Eastern Way is in an appalling condition, and seems to be in permanent need of repair. Traffic congestion occurs frequently at Erith Town Centre. Those factors would cause much traffic from the bridge to use smaller, mainly residential roads in Bexley. Some of these may be classified as A roads, but that would not make the houses along them any less vulnerable to environmental damage, or the community to either side of them any less susceptible to problems arising from severance.
363
6.1103 Many Thamesmead children go to school in Bexleyheath, and most travel by bus. The journey would take much longer and be unpredictable if the TGB were to be built. There is no road space for dedicated bus lanes to be created on the roads concerned. 6.1104 TfL claim that the TGB would maximise economic, transport, social, environmental and other benefits and opportunities for local people; but there are ways of doing this without the construction of a large, road based, strategic river crossing. Crossrail and the DLR would satisfy the vast proportion of local requirements without causing unnecessary traffic congestion, poorer air quality and other environmental impacts. Pedestrian and cycle facility 6.1105 Although the TGB is promoted as a 650m crossing with a pedestrian and cycle lane, in reality the actual distance between pedestrian and cycle access points is over 1.8km. The bridge would also be 50m high. Pedestrians would compare this with the Woolwich Foot Tunnel, which is 370m long and only 15m deep, and decide not to use the TGB on any regular basis. I visited the Woolwich Foot Tunnel on a site visit. It was reasonably clean and well lit, but the CCTV system was defective, and the lifts were not working. Its use would therefore involve the descent and ascent of a considerable number of steps. Traffic forecasts 6.1106 After pressure from LB Bexley, TfL provided new traffic figures to the inquiry. There were marked differences between those figures and the original figures, which led to a significant revision of the toll discount arrangements in Bexley in order to deal with the traffic changes which were shown to be likely. 6.1107 Those changes to the traffic figures for only 20% of the study area led to a loss of 33% of the NPV of the whole scheme and 29% of the positive cost benefit ratio. 6.1108 If the traffic figures for the other Boroughs are equally incorrect, subsequent revisions of the toll charge and discount areas might make the NPV and the cost benefit ratio for the whole scheme close to negative. 6.1109 The SPA rely on Professor Whiteleggs Document 4983/3, which compared traffic outturns with traffic forecasts on several completed schemes. Of the 41 schemes analysed by the NAO, nearly 50% were outside the 20% plus or minus margin of acceptable error, varying from minus 50% to plus 105%. Thus, not only the present traffic forecast, but traffic forecasts generally appear not to be reliable.
364
Regeneration 6.1110 TfL claim that the scheme would help to address four local problems: a. Limited access to job opportunities - but the people who need jobs most (comparing unemployment levels on both sides of the river) are north of the river, where most of the jobs would be provided. They do not need a bridge to access those jobs. b. Limited access to education, training, health care and other facilities but people on each side of the river have been using local services of this sort for hundreds of years. The Thames Gateway should be developed in a sustainable way. Building an expensive bridge is not the most obvious response to a lack of important local facilities. c. Limited access to workforces and markets for employers - but the real need is for excellent public transport links. These can allow workers to meet up with jobs. Strategic road crossings already exist to connect products to markets. d. High levels of unemployment - but Greenwich and Bexley are at or below the national average for unemployment. It is the Boroughs on the north of the Thames which have a greater problem with unemployment, despite their excellent road infrastructure. The bridge would simply open up to greater competition from people living on the south of the Thames the jobs which exist and which would be created on the north of the Thames. It is hard to see how this would help unemployed people living on the north of the Thames. 6.1111 Professor Whitelegg also referred the inquiry to evidence that road building is not necessarily the key to economic growth, and that roads can sometimes speed the decline of less prosperous areas by allowing their needs to be met conveniently from sources outside the area. Again, the SPA rely on this evidence. Traffic speeds 6.1112 If increasing traffic speeds generates jobs, logically reducing traffic speeds must cost jobs. The steady deterioration in traffic speeds which would be caused by additional traffic arising from the bridge would, in time, nullify any initial advantage that the bridge would create. A package of crossings 6.1113 The TGB comes as part of a package of new river crossings which include Crossrail and the DLR. The inquiry is concerned with only one part of the package, however, the TGB. It is right that it should be able to take into account any impact that these other crossings might have on the TGB.
365
6.1114 Crossrail is to terminate at Abbey Wood Railway Station. While a fair percentage of travellers would arrive by train and change at Abbey Wood, a large number of people would also arrive at Abbey Wood by private transport. GWT is also intended to terminate at Abbey Wood. But these two welcome additions to the local transport infrastructure would cause a degree of congestion on their own, without being exacerbated by TGB traffic using Knee Hill, Picardy Hill, Basildon Road and Eynsham Drive. Delaying the TGB 6.1115 Mr Chapman, the President of SRA, who appeared at the inquiry on the Associations behalf, expressed his personal opinion as not wholly opposed to a road crossing of the Thames at Gallions Reach, so long as it is proportionate to the needs of the communities it is truly intended to serve, appropriate to the infrastructure in place, and fully complemented by a wide range of public transport alternatives which have had the chance to prove their worth before such a road crossing is authorised. 6.1116 Mr Chapman considers that the DLR, Crossrail, GWT and ELT should have at least a decade to prove their worth in creating employment and regeneration. If that has happened, then a road crossing could be considered, on a par with the Rotherhithe Tunnel or the Woolwich Ferry, in order to maintain a local function without the need for more strategic roads to connect to the major trunk routes. Response by TfL to the objection of the SRA A local link 6.1117 TfL have no intention that the TGB would form a strategic link to the A2 and the A20. There is no national, regional or local policy to support this. 6.1118 SRA suggests that the TGB scheme would lack sufficient infrastructure to accommodate the traffic it would generate. This is not the case. The TGB scheme has always included a tolling mechanism designed to regulate the amount of traffic passing over the bridge. The revised tolling regime now proposed would place the majority of new traffic (59%) in the four Boroughs, including Bexley, on the new TGB infrastructure, with 32% on the key A roads. Roads that would experience an increase in traffic in excess of 30% and might therefore suffer increased severance are predominantly purpose built high capacity roads, where pedestrian access is limited. Where this is not the case, the absolute increase attributable to the TGB would be small. Mitigation measures would be undertaken where reasonably required. 6.1119 A road crossing is needed to meet the requirement contained in Policy 3C.14 of the London Plan for improved accessibility across the river for goods and services. This requirement would not be met by Crossrail and the DLR.
366
Pedestrian and cycle facility 6.1120 The Design Statement for the TGB has regard to the DMRB and the London Cycle Network Design Manual. Lifts would be provided on both banks of the Thames as required by the suggested planning conditions. The distance to travel on the bridge for pedestrians and cyclists would therefore be 650m. Traffic forecasts 6.1121 The new traffic figures referred to by the SRA resulted from counts taken across the area affected by the TGB. While it is correct that they focussed particularly on Bexley and the adjacent areas, the exercise did not demonstrate that the traffic figures in the model in other affected Boroughs would be materially different. 6.1122 The revised traffic modelling carried out by TfL indicates that, with the revised tolling proposals, the traffic changes which would result from the TGB could be accommodated on the road network. 6.1123 It has always been accepted that the underlying forecasts are for significant growth in traffic levels between 2001 and 2016. 6.1124 The benefit:cost ratio for TGB, taking into account the rebasing of the traffic model, remains good value for money at 4.2:1. Traffic speeds 6.1125 It is correct to say that the forecast for 2021 indicates that traffic speeds would fall marginally. However, this is a consequence of general traffic growth, not the result of any additional TGB traffic on the network. The journey time advantages of using the TGB over alternative cross river routes are not significantly affected. A package of crossings 6.1126 The TGB is just one element in a package of schemes that will provide crossings of the Thames. The package includes the extension of the DLR to Woolwich and the Silvertown Link. It now also will include Crossrail. The DLR and Crossrail would obviously be public transport links, and the TGB would include a public transport element through the provision of its dedicated public transport lanes. Delaying the TGB 6.1127 Mr Chapman accepted that his suggested re-phasing of the TGB scheme is not supported by the London Plan.
367
The Bexley Federation of Residents Associations 6.1128 There are 23 or 24 Residents Associations in membership of the Federation. In total, the affiliated Associations serve some 20,000 of the 92,000 houses in Bexley. The Federation has a formal constitution, and is managed by a Management Committee. The Management Committee has authorised an objection to the TGB scheme. This was done following the issue of an information leaflet during 2004 to all 20,000 properties covered by the Federation. Before preparing that leaflet, members of the Management Committee attended a number of the public meetings and consultations at which details of the proposed scheme were provided. 6.1129 The main concern of the Federation is the effect which the bridge would have on the living conditions of the people of Bexley as a result of the traffic and environmental consequences of the proposals. 6.1130 To the north of the heavy industry which the river, however, proposal was made. found there. Thames, there are major roads, appropriate to the used to exist in that area. The infrastructure south of cannot have been properly considered before this It is not adequate to take the existing levels of traffic
6.1131 This was an arable farming area in the past. It became an increasingly residential area, when many houses were built just before and after the Second World War. But many of the roads which remain in the area today are the same narrow roads which were created at that time. In the same way, many of the garages attached to the houses were built for the cars of fifty or sixty years ago, and they are not large enough to take the cars and vans of today. The result is that there is a considerable amount of on street car parking in the area, which, in turn, makes it difficult to drive around the Borough. It is increasingly difficult to offer a reliable estimate for the time it will take to complete a car journey in the Borough because of the extent of the traffic and parking on the roads of the Borough. 6.1132 The addition of the traffic which would be generated by the bridge would make this situation much worse. If planning permission is also given for the proposed new incinerator at Thamesmead, this would generate further substantial HGV traffic. 6.1133 The extent of traffic in the Borough at present is causing increasing environmental problems. Many more people in Bexley than in the past suffer from respiratory problems because of the fumes from traffic. 6.1134 The ELRC proposal to link a bridge to the A2 was preferable to the present scheme. At least the road proposed would have been capable of dealing with the traffic which would have been generated.
368
Response by TfL to the objection of the Bexley Federation of Residents Associations 6.1135 The volume of traffic generated by the proposed bridge on the local road network and its environmental impact would be controlled through the operation of the tolling regime and the provision of local mitigation. As noted in Document TfL/210, the overall conclusion of the revised modelling exercise is that the traffic changes resulting from the TGB with revised tolling proposals could be accommodated on the local road network. 6.1136 In relation to pollution and fumes from cars, particulates are the pollutant responsible for most health effects, and it is exposure over the long term which is most significant. Table 16.3 of the ES shows an average reduction in the annual mean exposure to PM10 of 30.8% for the 27 receptors close to the roads which would be affected by the TGB. This would be reduced to a 30.2% improvement with the TGB. In Bexley, some overall improvement is expected from current conditions. 6.1137 For the Federation, Mr Hudson acknowledged that the Federation were not against the proposed bridge, subject to the Bexley road network being able to cope with the traffic generated by it (D76 P27 L10-15). It must follow that, subject to the Secretary of State being satisfied on TfLs evidence that the road network in Bexley, with appropriate mitigation, can accommodate bridge traffic, there would be substantial support in Bexley for the scheme. Manor House Neighbourhood Residents Association, Sidcup (MHNRA) 6.1138 MHNRA has about 40 members. It is an informal organisation, which does not have a constitution. It exists to put a point of view on behalf of its members regarding development proposals which might have an effect on them. It was originally set up to oppose the development of a superstore in Sidcup. When the MHNRA is considering taking a position on a proposal, it seeks authority from its members by a referendum of the whole membership. That is what was done in this case, and the objection was authorised. 6.1139 Sidcup lies to the south of Bexley, about 9.6km from the proposed bridge. 6.1140 MHNRA is concerned about the lack of adequate highways to the south of the proposed bridge. Highway improvements should be planned to deal with the increase in traffic to and from the bridge which would arise to the south of the Thames. Without such provision, traffic would use the local residential roads, which would quickly become congested. That congestion would cause a rise in toxic pollution and ill health. 6.1141 Inevitably, motorists would gravitate towards the A2 via Knee Hill and Brampton Road. Knee Hill is a narrow two lane road, which does not appear to have been improved since it was dedicated centuries ago. Vehicular traffic on Knee Hill would deter cyclists and pedestrians contrary to PPG13.
369
6.1142 The congestion would lead to traffic jams, and would generate more noise and pollution contrary to PPG24. 6.1143 As far as people living in the south of LB Bexley are concerned, such congestion arising from the lack of road improvements would negate any attempt by TfL to introduce high quality bus services, because the buses would be caught up in traffic jams. People would therefore use their cars in preference to public transport, because at least then they would be able to choose an alternative, less congested route, depending on the circumstances on the day. Again, this is therefore promoting a result which would be contrary to PPG13. 6.1144 MHNRA would ask that, if the applications are recommended for approval, a condition is imposed on the permission requiring that radical new roads infrastructure should be constructed at the same time as the bridge in order to prevent congestion occurring on the existing narrow local residential roads. Response by TfL to the objection of MHNRA 6.1145 Sidcup is south of the A2, and TfL are not seeking to provide the TGB to facilitate cross river trips for people from that area. 6.1146 So far as the area of Bexley closer to the bridge is concerned, it is not envisaged that any further measures to increase general capacity would be taken. While there would be some increase in traffic on some of the roads, much of this will be local, with an origin or destination in the Bexley area. The traffic forecasting does not indicate a significant amount of long distance through traffic in this area. Through traffic would be discouraged from using the TGB by the unattractive journey times compared to using the river crossings at Blackwall and Dartford and by the differential tolling regime, which would discriminate against non local traffic. 6.1147 Knee Hill is classified as an A road (A2041), and Brampton Road is classified as a London distributor in the Bexley UDP. 6.1148 While the Boroughs Agreement and the Unilateral Undertaking do not provide for any significant highway improvements in Bexley (or in any of the other Boroughs), they do provide for mitigation measures, some of which would be implemented prior to the opening of the TGB, and others which would be considered in the light of operational experience once the bridge was opened. 6.1149 Bus priority measures in the area would be implemented as part of the GWT scheme, which provides for direct bus services from the TGB to Abbey Wood station via dedicated bus lanes along Harrow Manorway. For routes further south, TfL are committed to improving bus priority and the attractiveness of bus services compared to trips made by car. Currently bus services do not operate on Knee Hill, but are routed along the parallel New Road. As part of
370
their obligation for bus service planning, TfL will continue to monitor bus services in the area, and develop new routes as appropriate. Belvedere Community Forum 6.1150 The Belvedere Community Forum was set up to benefit the residents of the Belvedere area and to act as a channel of communication within the community and with agencies providing services in the area. Membership is open to all residents aged 16 or over. Tolls - discount area 6.1151 When considering the proposals, including the originally proposed tolling arrangements, the Forum was in favour of the scheme by a small majority. Subsequently the Forum considered the revised tolling proposals (those currently before the inquiry) and reached a clear majority view that it does not support the scheme. The reduced discount area is unreasonably small. Long distance traffic 6.1152 The Forum has reservations about the likely traffic effect of the scheme, and suspects that little would be done to prevent traffic filtering through Bexley on its way to the bridge. It proposes that a monitoring arrangement is made, and funds set aside to improve or build new roads in Bexley should the need arise. It is a moot point whether the tolls would effectively deter long distance traffic, since the toll is likely to be only a small consideration in route selection, alongside overall cost, speed and the need to reach ones destination punctually. Traffic mitigation 6.1153 Traffic mitigation measures such as pinch points and roundabouts prevent vehicles from running at optimum speeds, and so lead to increased exhaust emissions and poorer air. Traffic in Bexley 6.1154 There are several large developments proposed in the Borough that will each have substantial traffic implications: a large incinerator, spoil removal from Crossrail tunnels, an enlargement of the sewage works and the removal of more sludge by road, and a truck/rail terminal at Slade Green. These will all add to the need for road improvements. Response by TfL 6.1155 No specific response was made by TfL to the objection of the Belvedere Community Forum.
371
Bexley LA21 Traffic and Transport Focus Group and the A2 (Bexley) Environmental Campaign Committee 6.1156 Mr Ian Lindon is the Chairman of the LA21 Traffic and Transport Focus Group (Bexley) and also the Chairman of the A2 (Bexley) Environmental Campaign Committee. Both Groups had considered the scheme and authorised his appearance at the inquiry to object to the traffic lanes proposed to be provided on the new bridge. Traffic in Bexley 6.1157 People in Bexley already suffer from noise and pollution caused by traffic on roads such as the A2 and the A20, both of which carry more traffic than their originally estimated capacity, and both of which suffer daily accidents and hold-ups. Some noise remedial measures have been provided near those roads, but they are not enough. This scheme would cause similar problems elsewhere, and also bring congestion to local roads. Regeneration - employment 6.1158 TfL claim that the scheme would bring new jobs to the area, but there is no guarantee of that. 60% of Bexley people work outside the area, and the local labour force is not well-trained. Alternatives 6.1159 The Mayors transport policy and local Council policy both support the use of alternatives to the car. The scheme would encourage car use as currently proposed, and so a new bridge should provide only for public transport. 6.1160 The vast amount of money that would be spent on the scheme could alternatively be spent on measures that would more directly support the local economy on both sides of the river. Flooding 6.1161 Roads leading to the new bridge are likely to be submerged if the Thames floods, as is expected. Tolls 6.1162 The proposed tolls would be ineffective in deterring business traffic, since businesses would write off the toll charges against tax, and would in any case be prepared to meet any extra cost if any saving of time or distance resulted. The tolls would deter poorer people from using the bridge, thereby excluding them from jobs. Tolls at the Dartford Crossing have not alleviated traffic.
372
Response by TfL to Bexley LA21 Traffic and Transport Focus Group and the A2 (Bexley) Environmental Campaign Committee Traffic in Bexley 6.1163 The traffic flows on the TGB would be significantly less than those on the A2; 56,723 in an 18 hour period, compared with 100,000 on the A2. The TGB scheme would also include noise barriers and low noise surfacing as part of the design. The noise assessment for the TGB assumes traffic flow would be at the 2016 level on the originally assumed opening of the bridge in 2012. In the revised traffic model, no growth in traffic flows is envisaged after 2016. The management of traffic on the bridge through the tolling regime would place a control on traffic flows which is not available on the A2. Bexley LA21 Natural Environment Focus Group (NEFG) 6.1164 NEFG is a group set up during the 1990s to provide advice to LB Bexley on matters concerning the natural environment and, where possible, to stimulate action. Its constitution was in the process of change during the inquiry, but the objection, and indeed the evidence given, had been approved by the Group. In fact, NEFG had also opposed the TGB at the Bexley UDP inquiry in 2002. Badgers 6.1165 There is evidence that badgers have habitats south of the Thames in the area which would be affected by the scheme. Badgers are a protected species. They have notoriously poor sight, and are among the species most likely to be affected by extra traffic volumes. Lesnes Abbey Woods and Bostall Heath and Woods 6.1166 These are important sites for wildlife habitat. They are well used, popular and strongly valued by the public. They act as a reservoir from which mobile species spread out over the surrounding area to the benefit of people living over a substantial range. As well as birds, bats roost in the woods, and come out to hunt over Thamesmead. Ground living mammals and insects do the same over different distances. 6.1167 The effect of the TGB would be to increase the amount of traffic using Knee Hill. This would increase the severance effect in the short term, but also create pressure to widen Knee Hill and to straighten it, possibly to dual carriageway standard. Before that happened, congestion would divert part of the traffic flow on to New Road, creating a double severance between the main part of Lesnes Woods and Bostall Heath. This would discourage walkers from using Knee Hill or from attempting to cross it.
373
6.1168 The revised traffic information submitted by TfL during the course of the inquiry confirms the view that traffic generation had been underestimated by TfL. Neither the proposed tolling arrangements nor the planned mitigation measures would prevent extra traffic using roads in the local road network such as Knee Hill, Brampton Road and New Road. 6.1169 As well as the direct impact of vehicles, there would also be environmental effects. Additional traffic would affect the attractiveness of the open spaces by adding to the air pollution and the noise pollution which people would experience while visiting the area. The air pollution would also adversely affect flora and fauna. 6.1170 Noise barriers would be completely inappropriate on Knee Hill and New Road, while noise bunding would destroy valuable habitat on both sides of the roads. Effects on other sites of wildlife importance 6.1171 The A2016/A206 would also face additional traffic as a result of the building of the TGB. These roads run through a number of other sites of wildlife importance. 6.1172 Erith Marshes and the Crossness Nature Reserve adjoin the A2016. Like all land in Thamesmead, this road is underlain by chalk, but with variable depths of gravels, sand, silts, clays, peats other organic beds, and mixtures of one or more of each. This affects the stability of the road, which frequently needs attention. In fact, the road was reduced to one lane in each direction at the time of the accompanied site visit because of repairs which were being carried out at that time. Increased traffic would increase the need for works of improvement. Improvement works could affect the water table and drainage. On sites where water levels are absolutely critical, this would have an immediate and obviously adverse effect. 6.1173 The most important species affected would be the water vole, now under threat of extinction in Great Britain. The populations in this area are amongst the few with hopeful long term prospects. Additional traffic on the A2016 would increase the risk to voles crossing that road between the Crossness Nature Reserve and the Crossness Southern Marshes. 6.1174 The marshes also form an important area of public amenity. Parts are being managed to increase access by the public. That work is being supported by funds of around 1m committed by ODPM over the first two years of a three year programme. The value of that work would be reduced by the increased levels of noise and air pollution which would result from increased levels of traffic on the A2016. 6.1175 This inquiry should recommend refusal of planning permission for the TGB; but, if it does not, conditions should be imposed on any permission to require noise barriers to protect the Crossness Nature Reserve and the
374
Crossness Southern Marshes from increased noise levels arising from increased traffic on the A2016. I note, however, that these sites were visited as part of the site visit programme. I cannot say that I found the existing level of noise intrusive, and I do not believe that any increase in traffic on the A2016 would have a significant effect on the noise environment of the sites. 6.1176 Southmere Park and Crossways Park also lie to either side of the A2016. The main nature conservation interest in Southmere Park is concentrated around Southmere Lake, which is almost completely shielded from the noise of the A2016 by the noise bund formed by the Southern Outfall Sewer. The two Parks lie at a similar distance from the A2016. The different noise environment experienced in each of them underlines the need for major noise protection of Crossways Park to be made a condition of any planning permission for the TGB. 6.1177 In the same way, Franks Park, which lies further to the south east, between the A206 and the A2016, would suffer an increase in noise levels and air pollution in addition to severance caused by the increased traffic levels. 6.1178 Further to the south east again, access to Crayford Marshes would be adversely affected by additional traffic on the A2016 and the A206. 6.1179 During the course of the inquiry, the Managing the Marshes strategy was launched (Document 1183/4). This is intended to support a bid for further funding for work on the Marshes at Erith, Dartford and Crayford. The bid was submitted during March 2006, but the outcome of the bid was not known by the close of the inquiry. If the bid is approved, maximum effort should be made to prevent the value to the public of the three Marshes being further compromised. Further extra traffic 6.1180 Crossrail and the GWT would also generate extra traffic which would have an impact on the road network in Bexley. Especially if Crossrail, like the GWT, terminates at Abbey Wood, this would generate even more demands on Brampton Road, Knee Hill and Harrow Manorway. Other environmental impacts 6.1181 The most important of these are climate change and the flooding risk. The East London Strategic Flood Risk Assessment has been completed, and has been circulated to the eleven London Boroughs concerned. It has not yet been made public, however. If adequate information is not available before the close of the inquiry, the attention of the Secretary of State should be drawn to that fact. 6.1182 Running at the same time as the TGB inquiry was an inquiry into the
375
proposed Belvedere Incinerator. It opened on 6 September 2005. NEFG was an objector to the incinerator proposal. If the incinerator application is refused, it will have no significance for this inquiry. But if the incinerator is approved, it would have implications for assessing the increase in air pollution as a result of the multiple developments proposed for this part of the Thames Gateway. Other matters 6.1183 In closing the case for the GLC at the 1985/6 ELRC inquiry, Mr George contended that the burden of proof for a highway scheme rested with the promoters, not with the objectors. As he said at that time, road construction . is a peculiarly irreversible form of development (Document 342/5 at page 8E). NFEG adopts that argument, and quotes it back to Mr George now. 6.1184 NEFG also adopts the argument advanced by Mr George at pages 9 and 10 of the same Document on the weight to be placed on environmental disbenefits as against benefits in other areas, and the tests to determine how the balance is struck. 6.1185 The argument that habitat creation or landscape improvement north of the river can justify habitat destruction or major damage to landscape south of the river is not an argument which anybody south of the river can accept. 6.1186 With regard to wildlife, the argument is even more fundamental. The destruction of or damage to a long established area of habitat will involve the loss of rarer, slower colonising species. Any compensation land will provide a habitat for commoner, faster colonising species. Any such attempt at a trade off will therefore involve a net loss of species, and of the rarer species at that. 6.1187 In the Statement of Matters, the Secretary of State asked to be informed about (amongst other things) (d) The extent to which the proposed development is likely to have an impact on the local flora and fauna and any conservation sites, having regard to the Governments policies in PPG9 - Nature Conservation on conserving the diversity of wildlife and their habitats. 6.1188 PPG9 has now been superseded by PPS9 (Document 2059/5). PPS9 is itself guided by ODPM Circular 06/2005 (Document 2059/6). If the Secretary of States request for information is to be answered in terms of PPS9, rather than PPG9, the information before the inquiry is inadequate to deal with this. The evidence presented by TfL only attempts to meet the requirements of PPG9. TfL could have used the time when the inquiry was barely sitting during the winter of 2005 and the adjournment of the inquiry between 22 December 2005 and 21 February 2006 to bring their evidence
376
more closely in line with the requirements of current policies, but they chose not to do so. 6.1189 Paragraph 12 of PPS9 specifically includes guidance for the maintenance of natural habitats because they provide routes or stepping stones for the migration, dispersal and genetic exchange of species. This is why NEFG has raised issues concerning, for example, water voles and badgers. 6.1190 There is a further problem regarding the adequacy of the ecological information put before the inquiry by TfL. The ecological data search of the TGB safeguarded area for the purposes of the ES (Document D713) was carried out in March 2003. The response provided by Greenspace Information for Greater London should not be used more than 12 months later than the date on which it was provided, in order to ensure that the information remains current when it is used. 6.1191 In this case, it was used in the ES, which is dated July 2004. That is more than 12 months after the information was provided. But by the time a decision is taken on the matters before the inquiry it might be 2007, four years after the base data was provided. No attempt has been made by or on behalf of TfL to establish whether the data contained in the ES remains current. 6.1192 For TfL, Dr Hughes suggests that data sets can be checked during the course of a public inquiry against the evidence of local objectors with local knowledge. This is out of the question in the present case, because much of the area where the bridge would land on the south side of the river is closed to the public. 6.1193 Moreover, the data collected by Greenspace Information for Greater London should not be regarded as comprehensive. That is spelt out on the face of any response provided, as can be seen from Document 2059/4. The database amounts to an assemblage of whatever information individuals choose to make available. It is not the sort of comprehensive data which permits an authoritative answer to question 4(d) of the Statement of Matters. Only a systematic survey could provide that data. 6.1194 For all of those reasons, it is not possible to provide a reliable answer to the question posed in 4(d). Response by TfL to the objection of NEFG 6.1195 NEFGs opposition to the TGB has not been supported by LB Bexley, in the sense that Bexley have not sought to challenge the TfL evidence that the TGB scheme would only have a slight adverse effect on biodiversity and nature conservation.
377
Badgers 6.1196 TfL do not doubt that badgers are found in the area, or that some of them are killed crossing roads. NEFG produces no evidence, however, to demonstrate that this is a particular problem in the area or that the differential in traffic volumes on the network with and without the TGB would materially affect matters. Lesnes Abbey Woods and Bostall Heath and Woods 6.1197 The TGB proposals do not include the widening of Knee Hill. Existing traffic levels on Knee Hill will increase in the future whether or not the TGB goes ahead. The extra traffic appearing on Knee Hill as a result of the TGB would be controlled through the tolling mechanism. 6.1198 The revised traffic forecast submitted to the inquiry uses information provided by, amongst others LB Bexley. This information has been used to provide the inquiry with an updated position on traffic generation. 6.1199 So far as animals are concerned, Knee Hill already has a severance effect by being hard standing. Any increase in traffic would not cause a significant increase in the effect on wildlife. There was no substantial challenge to Dr Hughes professional view that the TGB scheme would not cause a material loss of bats, song bird species or more sensitive plants. 6.1200 It is accepted that noise barriers or noise bunds would be inappropriate on Knee Hill or New Road. Effects on other sites of wildlife importance 6.1201 The presence of the A2016 and its planned role in serving development in the corridor through which it passes means that (quite apart from the TGB) there will be considerable severance for the areas to either side of the road. It is hard to see how additional TGB traffic would make a significant difference in ecological terms. Mr Cotton did not produce any evidence that water voles were crossing the A2016 at Erith Marsh, and therefore that increased traffic would be a problem for them. 6.1202 As regards the investment in the area made by ODPM under the Sustainable Communities Fund, increased accessibility provided by the TGB would make the various sites of wildlife importance identified by Mr Cotton more easily reached by more people, particularly by those living to the north of the Thames. Rather than a reduced return, this would deliver an increased return on the central Government investment. 6.1203 Managing the Marshes (Document 1183/4) contains no indication that the A2016 is seen by its numerous partners and contributors as either a threat to wildlife or to the enjoyment of the marshes by visitors. The
378
Opportunities Plan for Erith Marsh indicates proposals for an increased water vole habitat area, for increasing existing culvert crossings of the A2016, and for a new earth bund at the north western boundary of the site. The report is otherwise silent on any need for noise barriers to protect the amenities of the Marsh. TfL do not accept the need for any additional noise mitigation measures. Further extra traffic 6.1204 The impact of Crossrail was assessed in an ES for that scheme (Document TfL/129). The TGB would be entirely complementary to the GWT. Other environmental impacts 6.1205 NEFGs concerns particularised. Other matters 6.1206 The ES predated PPS9. It took into account the Mayors Biodiversity Strategy and the London Plan, both of which take a similar line to that of PPS9. The methodology and assessment of biodiversity issues in the ES were not challenged at the inquiry by the local planning authorities, by LB Bexley, by EN or the EA. That was not surprising, because the methodology used was agreed with the various stakeholders, including EN and the Greater London Biodiversity Team at the outset. Subject to planning conditions which have been picked up in those put before the inquiry, none of these parties sought to challenge the conclusion that the bridge would have overall a minor adverse effect on biodiversity and nature conservation. 6.1207 The assessment methodology adopted in preparing the biodiversity section of the ES is that set out in WebTag and the DMRB. The value of the resource affected is not high. Two locally important sites are affected - the River Thames SMI and the Beckton Ditches and Grassland SBI. The latter site is allocated to a large extent for development as a Major Opportunity Zone in the Newham UDP. 6.1208 The predominant habitat in the safeguarded corridor is man made urban wasteland grass dominated vegetation which has colonised formerly developed or brownfield land of low to medium importance. The urban wasteland which would be lost supports invertebrate species and potentially supports red data book and nationally scarce species of terrestrial vertebrates. The invertebrate species are almost exclusively those associated with the wasteland habitats, which can relatively easily be recreated. The TGB scheme would involve both the recreation of wasteland habitat and the retention and management of existing urban wasteland. TfL acknowledge, however, that there would be a net loss of habitat. The loss would be principally on the north of the river, and would be compensated by a payment of 500,000 to Newham for biodiversity measures.
379
on
climate
change
and
the
flood
risk
were
not
6.1209 The Green Space Information form information was used within twelve months - for the ES. TfLs ecology witness then re walked the area just before the opening of the inquiry, and updated her evidence, for example to indicate that an area of wasteland on the north side of the Thames had changed significantly since the ES was prepared. When the inquiry opened, it was only 15 months after the date of the ES. Despite his general familiarity with the ecology of the area, Mr Cotton (who appeared for the NEFG) produced no evidence to show that the data supporting the ES was actually out of date or no longer relevant. Nor did he ask for the relevant surveys to be carried out again. Greenwich Wildlife Advisory Group (GWAG) 6.1210 The GWAG was set up in 1975. It provides advice to Greenwich on wildlife and nature conservation issues, and acts as a channel of communication between the Borough and relevant organisations. GWAG gave evidence to the 1985/6 inquiry, opposing the bridge and associated roadworks proposed at that time. Opposition to this application has been authorised by the Group, including the terms of the evidence given at this inquiry. Effects on wildlife, wildlife habitat and access by the public 6.1211 GWAG shares the belief of NEFG that traffic generated by the proposals would have a significant impact on wildlife, wildlife habitat and access to various wildlife sites by the public. GWAG also shares the view that, if the bridge is built, congestion arising from the proposal could lead to pressure to reinstate the full ELRC scheme. 6.1212 Access to most of the land between the Thames and the A2016 road in Greenwich is restricted, and GWAG is not therefore able to offer any evidence in relation to it. West Thamesmead is, however, known to be the only part of Greenwich with a population of water voles. This is a nationally threatened species, protected since 1997 under the Wildlife and Countryside Act 1981. 6.1213 In Greenwich, most of the sites along the A2016 are not of the highest value as wildlife habitat, but they do represent public open spaces. Any adverse effect of noise from increased traffic would be damaging to the public use of those sites. Gallions Hill would be overshadowed by the bridge itself, and would be subject to a serious noise problem. 6.1214 The impact of the bridge proposal on Lesnes Abbey Woods and Bostall Woods is also of concern in Greenwich, because the Borough boundary with Bexley runs down Harrow Manorway and Knee Hill. GWAG shares the view of NEFG that there should be an absolute ban on any widening or straightening or increased lighting on Knee Hill. Increased lighting might have an adverse effect on the number of bats in the area because of a reduction in the population of night flying insects.
380
The Greenwich Biodiversity Action Plan 6.1215 The Greenwich Biodiversity Action Plan was about to be published for consultation as the inquiry came to a close. The main issues of relevance to the inquiry will be the Species Action Plans for the water vole and the black poplar and the Habitat Action Plan for acid grassland. 6.1216 The Species Action Plan for the water vole is likely to propose the commissioning of a new survey of West Thamesmead to confirm the current distribution of the species. The Species Action Plan for the black poplar may or may not proceed, given the questions which have arisen during the inquiry about whether there are any native black poplars (as opposed to hybrids) in Greenwich. The Habitat Action Plan for heath and acid grassland will assess the potential for extending the relict populations of heather which occur on Bostall Heath. 6.1217 GWAG proposes to submit a copy of the Biodiversity Action Plan to the Secretary of State when it is available. Other environmental impacts 6.1218 GWAG shares the concern of NEFG regarding the impact of climate change and the risk of flooding, although the exposure of Greenwich to that risk is less than that of Bexley. Response of TfL to the objection of GWAG 6.1219 Although GWAG advises Greenwich, Greenwich has not objected to the TGB on nature conservation grounds, and is in fact a supporter of the applications. Effects on wildlife, wildlife habitat and access by the public 6.1220 The premise of unacceptable disruption arising from the TGB is not accepted. The updated traffic information suggests reduced flows on the TGB and a generally smaller increase on the existing network than was originally forecast. Moreover, TfL would address the issue of traffic levels using the TGB through the tolling mechanism. TfL therefore see no reason to anticipate pressure for the restoration of the ELRC scheme, which would be entirely contrary to existing planning policies. 6.1221 On 16 April 1998, the water vole received legal protection through its inclusion in Schedule 5 to the Wildlife and Countryside Act 1981 in respect of Section 9(4) only. This preserves the voles place of shelter, but does not protect the voles themselves. The nature of the protection reflects the fact that habitat loss and destruction has played a much greater part in the species decline than direct persecution.
381
6.1222 Extensive lengths of noise barrier are already proposed on the bridge, which would protect the open space on either side of the TGB. 6.1223 There is no proposal to widen, straighten or increase the lighting on Knee Hill. The Greenwich Biodiversity Action Plan 6.1224 TfL had been unable to find any native black poplar trees in West Thamesmead. They therefore asked Mark Spencer, who had provided the report of a finding in 2002 for assistance. Mr Spencer is now Curator of the British and European Herbariums at the Natural History Museum. Mr Spencer stated that his identification in 2002 was a tentative one, carried out at a time when he was not familiar with the plant. Mr Spencer revisited the site in January 2006 and confirmed that there was no sign of any native black poplar, although there were several hybrids that could be confused for it. The exchange of correspondence with Mr Spencer is attached to Document TfL/REB/2059/1. Mr Jeremy Cotton 6.1225 As well as representing NEFG and GWAG, Mr Cotton appeared as an objector in his own right. He is a local resident who lives in Thamesmead. He has been much involved in public service in the area, and served between 1986 and 1994 as a member of the Board of Thamesmead Town, the company limited by guarantee set up to take on the assets and responsibilities of the former Greater London Council in Thamesmead following the dissolution of the GLC on 31 March 1986. The history of the present scheme 6.1226 When the M25 was built, salami tactics were used to overcome local opposition authority was obtained to deal with part of the route, and then this was put forward as part of the justification for seeking authority for the next section of the overall scheme. 6.1227 An effort was made to secure permission for ELRC using the same approach. When the SWBRR route went to public inquiry in the early 1980s, an objection was made on the basis that it would pre-empt the ELRC inquiry. This was rejected, because it was said that there was no connection between the two inquiries. Subsequently, however, at the opening of the ELRC inquiry, the fact that the SWBRR had been approved and was under construction was prayed in aid to make the case for approval of ELRC. 6.1228 There is concern that the same process is being followed now seeking to secure a commitment to build the bridge, following which there would be new pressure to build a road to connect it to the A2. Much political manoeuvring was involved in securing a bid to build the TGB following the
382
decision not to proceed with ELRC. The inquiry should see all the different consultants reports and traffic forecasts produced between 1992 and the present in order to compare the various different conclusions reached. Transport in the area affected by the proposal 6.1229 North of the river, all the land lies below the 10 metre contour for a distance of 4km to 5km from the Thames. This has allowed unrestricted development, including the building of roads which run in all directions. South of the river, the situation is quite different. There is an escarpment running from Deptford to Dartford, parallel to the river and to the south of it, and land between the escarpment and the river has, until comparatively recent times, been regarded as suitable only for low level grazing or for bad neighbour uses. The major road systems have always run east-west rather than north-south. 6.1230 In the nineteenth Century, the Blackwall Tunnel was dug to provide a local crossing to facilitate the operation of the Docks. As it was the only crossing for some distance, it became a strategic crossing, and was enlarged in the 1960s to allow for this. 6.1231 The reason why there are more river crossings in the west of London than in the east is the result of the different nature and history of the Thames upstream and downstream of London Bridge. The Romans chose a site within a few metres of the present London Bridge as the lowest point at which they could usefully bridge the Thames with reasonably firm ground on both banks. This automatically became the highest point to which sea going ships could travel. Upstream, the non tidal Thames could only be used by river craft. 6.1232 This meant that the bridges upstream of London Bridge only needed to clear the rigging of river craft (often designed to be lowered), so that they could be built at grade, relatively cheaply and relatively frequently. So frequently, in fact, that most of them served only a local hinterland, and as traffic built up the effects were limited. 6.1233 Downstream of London Bridge, any crossing had to accommodate sea going ships. Crossings were therefore a lifting bridge (Tower Bridge), tunnels (Rotherhithe, Blackwall and the foot tunnels at Greenwich and Woolwich) or a ferry (the Woolwich Ferry). The costs involved in building and/or operating these are so high that only the minimum number was created. All of them were strategic crossings, as the Dartford Crossing became when it was built, and as the TGB would inevitably become if it were built, regardless of the intentions of the promoters. It would generate enough traffic to make the provision of a proper road network feeding it from the south, and particularly from the A205 South Circular and the A2, an overwhelming political necessity.
383
The transport needs of the area 6.1234 The Abercrombie Report and Plan from the 1940s and the ELRC proposal from the 1980s addressed a perceived need for a strategic crossing and a link between the North Circular and the South Circular. The TGB attempts to provide the crossing, but to deal only with local transport needs. The two aims are incompatible. It was suggested by an objector at the 1985/6 inquiry that the ELRC bridge should be built only as far as the Thamesmead Spine Road A2016. The DfT stated in their rebuttal that this would be unworkable. But it is what TfL propose now. 6.1235 The real unmet transport need of those in Greenwich and Bexley is to be able to travel efficiently within the area, for example from Thamesmead to Sidcup. It is easier to travel into the centre of London and out again on a different line than it is to travel within Bexley. People in Thamesmead need more efficient and accessible connection to the public transport system rather than a bridge across the Thames primarily for cars. At present, the two roundabout connections from Thamesmead to the A2016 are congested, and the building of the TGB would make that congestion worse. This would also have an adverse impact on the bus route serving Thamesmead. In addition, extra traffic on the A2016 would make it more difficult for pedestrians to cross that road. The development, regeneration and employment needs of the area 6.1236 To encourage development, regeneration and employment opportunities in Bexley and Greenwich what is needed is action to make it easier to travel within the area than it is to travel to Central London. As Appendix 9 to Document TfL/P/05/3 makes clear at page 4-13, rail public transport accessibility seemed to be the best determinant of employment density, and highway access had little relevance. Issues of prematurity 6.1237 The inquiry has had no evidence of the combined impact of Crossrail and the TGB on the area. If Crossrail terminates at Abbey Wood, it will generate additional traffic movements during peak hours as commuters converge on Abbey Wood station. On the other hand, if Greenwich are successful in their campaign in relation to Crossrail, and secure a further station at Woolwich, this would spread the traffic generated to some extent. And if Bexley are successful, and Crossrail is extended to Dartford and/or Ebbsfleet, this would greatly reduce problems on the local road network. There should be traffic figures for the impact of the TGB both with Crossrail and without Crossrail, and covering the various possible termination points south of the river. Either the inquiry should be closed and reconvened when there is evidence available about Crossrail and which option is to proceed, or no decision should be taken on these applications now and a new inquiry should be convened when all the necessary evidence is available. 6.1238 A decision should not be taken regarding the TGB without the benefit of the
384
EAs study on climate change and the risk of flooding. 6.1239 The inquiry should also receive authoritative evidence regarding the possible extension of the Congestion Charge, which was covered in a newspaper article during the course of the inquiry (Document 342/7). Response by TfL to the objection of Mr Jeremy Cotton The history of the present scheme 6.1240 There is no proposal to carry out further and later extensions to the TGB scheme before the inquiry. There is no policy support at national, regional or local level for any such extension. 6.1241 Although the location proposed for the TGB is the same as that proposed for ELRC, the schemes are completely different and have different aims. The case for the TGB has been put forward to this inquiry using models and forecasting techniques which were not available at the time ELRC was examined. Because of this, there would be no point in revisiting historic reports and traffic forecasts. Transport in the area affected by the proposal 6.1242 The TGB scheme is being promoted to facilitate regeneration, not as a strategic road scheme. The transport needs of the area 6.1243 The current TGB scheme proposed by TfL, apart from the obvious similarity in the location for the bridge, is very different from the previous ELRC scheme, and is designed to serve a local rather than a strategic purpose. Because the schemes are so different, compatibility is not an issue. Because the ELRC was designed as a strategic route to link through to the A2, it would have been unacceptable for it to stop at the junction with the A2016. The TGB is, however, designed as a local scheme, and this issue therefore does not arise now. 6.1244 TfL have accepted that, with the TGB, traffic levels on some roads would increase. Mitigation measures through the Boroughs Agreement would, however, address some key links. In addition, traffic levels over the TGB could be addressed through mechanisms in the Toll Order. 6.1245 Planning for bus routes and bus priority measures is an ongoing process. TfL have invested heavily in public transport improvements in London, specifically on bus priority schemes and consequential improvements to services. No route would be left to deteriorate to a much lower standard, as Mr Cotton fears.
385
The development, regeneration and employment needs of the area 6.1246 The TGB would provide new links between Boroughs north and south of the river. In addition, it would link the GWT and the ELT. Issues of prematurity 6.1247 The overwhelming likelihood is that, if the TGB is permitted, it would open well in advance of Crossrail, and possibly even before the commencement of the construction of Crossrail. 6.1248 The newspaper article (Document 342/7) which spoke of the possible extension of the Congestion Charge was inaccurate. There is no present proposal for any further extension of congestion charging, other than to Kensington and Chelsea, and any further extension is likely to be preceded by a further revision of the Mayors Transport Strategy. TfLs position on this matter is set out in Document TfL/254). London Region Liberal Democrats 6.1249 Ms Susan Kramer is the MP for Richmond Park. From July 2000 until May 2005, she was a Member of the Board of TfL. Ms Kramer appeared for and gave evidence on behalf of the London Region Liberal Democrats, and her evidence is summarised below. There was also a written representation from the London Region Liberal Democrats (Representation 2698). It does not raise any matter which is not covered in the objections which were sustained by appearances at the inquiry. 6.1250 The TGB represents an unusual project for TfL, in that it was the subject of a split vote at the Board meetings at which it was considered. When it was originally approved in 2002, it was passed only on the casting vote of the Mayor of London. When the submission of the Orders was approved in 2004, there was also a split vote, approval being given only by 7 votes to 3. 6.1251 The TGB is also an unusual project, because, contrary to the normal process of developing a project and then needing to seek the funding to carry it out, in this case there was substantial funding available from the Government in the shape of PFI credits of 200m more or less at the same time as the Board of TfL heard about the project. These credits are not part of the normal funds of TfL, and could not be diverted to any alternative approach to crossing the Thames in East London. 6.1252 Although the TGB project is supported by the Mayors Transport Strategy, it is in conflict with many of the key principles of that Strategy. The Strategy provides that road crossings should maximise regeneration benefits while minimising encouragement of car use. This proviso seems to have been forgotten in the current plan for the TGB. The bridge proposed is essentially a six lane motorway bridge. While two lanes are said to be reserved for public transport use, the design is one which would allow them easily to be
386
converted to lanes which could be used for all vehicles. 6.1253 While TfL has agreed to design the two bus lanes in such a way that they could be used for trams or the DLR, by the time Ms Kramer left the Board of TfL, there was no inkling of a plan to use the bus lanes in that way. 6.1254 TfL claim that the rationale of the TGB is regeneration for local people. In fact, the motivation is much more complex. 6.1255 At the time the project was first in discussion, there was consideration about the future of airports in London. The Government was examining the potential for a major new airport for London in the Thames Estuary at Cliff. The TGB would be critical in creating a motorway network to bring traffic from across London to such an airport. While the estuary airport idea has been set aside for the moment, the bridge has remained, and in the form which would have suited such an airport. 6.1256 Big business has also campaigned for the project. Developers at Canary Wharf and in the Thames Gateway would prefer to maximise the recruitment pool of white collar talent from outside London. The difficulties of driving in and out, and being forced to take the train as an alternative, were seen as serious negatives, which could influence internal assessments of the business potential of the area. American institutions in particular were said to be dismissive of the idea that public transport could be the backbone of travel rather than motorways. There is nothing wrong with these arguments, but it is arguments of that sort, rather than regeneration, which have shaped the character of the bridge which is proposed. 6.1257 The primary users of the TGB would be long distance commuters with no origin or destination in Thamesmead or Beckton. They would travel from Kent to jobs in Canary Wharf or the City. Many presently take the train, but the TGB would see them switch to car travel. The sort of tolls proposed by TfL for use of the bridge would not deter such users. TfL should have surveyed train commuters to see how many of them would switch to car travel if the bridge were built, but they have resisted all requests to carry out such a survey. 6.1258 London Region Liberal Democrats do not oppose the idea of river crossings in East London; it is the motorway style crossing which they do not support. West London has a series of small road bridges. There is an impact on their local communities, but it is reduced and spread. When there has been a proposal to create a motorway style bridge in West London (as at Hammersmith in recent years), this has excited fierce opposition from local residents. 6.1259 It is extraordinary that TfL have planned a bridge which then needs extensive road control schemes to limit access to it in order to prevent rat running through residential areas.
387
6.1260 The regeneration of the Thames Gateway is a huge opportunity to deliver for some of Londons most deprived communities a high quality area in which to live, which is sustainable in the full sense of the word. From a transport perspective, this means a public transport backbone, with facilities for the car to be used on those occasions when public transport is not available or suitable, events which the design of the community should reduce to a minimum. Response by TfL to the objection of the London Region Liberal Democrats 6.1261 Conversion of the public transport lanes on the proposed TGB to ordinary highway use would be neither simple nor cheap. It would require planning permission and variation of the Orders before the inquiry, as well as involving considerable costs. These are outlined in Document TfL/224. 6.1262 The bridge has been designed so that it could carry the DLR, and changes were made during the inquiry to facilitate possible use by trams. Planning for the Thames Gateway Transit has advanced since Ms Kramer left the Board of TfL. 6.1263 There is no basis for the claim that the TGB took on motorway characteristics to serve a possible new airport at Cliff. No evidence has been produced to support this claim. 6.1264 TfL do not regard ensuring essential road access for business and maximising the recruitment pool of white collar talent as being in conflict with regenerating the area. 6.1265 It is not TfLs case that any bridge must, by definition, help regeneration. But the common sense view (supported, as it is, by the views of businesses and investors, the local authorities and the modelling by Volterra) is that this proposed bridge, in its proposed location, would be likely to help regeneration in this part of the Thames Gateway. 6.1266 The combined effect of relatively high tolls and the absence of significant journey time savings would make the TGB an unattractive route to or from the A2 and the A20. It is fanciful to assume that a commuter from Kent would choose to reach Canary Wharf, much less the City, via the TGB in preference to the much more direct route through the Blackwall Tunnel or by using the train and Underground. 6.1267 The aim of the tolling process is to minimise long distance through traffic, not all long distance traffic. TfL consider that trips made by local people and businesses, and trips to visit local people and businesses are important, even if it is a delivery, for example, from a local business to a distant consumer. The tolling mechanism would operate to deter the use of the TGB by through traffic. Time travel savings with the TGB would be proportionately larger for those drivers who begin and end their journey in the area local to the bridge. They would avoid the previous need to travel to
388
Blackwall or Dartford. Those who are at some distance from the TGB would see much less benefit from using the TGB rather than other crossings, particularly if their destination was not close to the TGB. 6.1268 It is accepted that most of the bridges in West London are smaller in capacity than the proposed TGB, but there is no policy support anywhere for a series of small new bridges to replace the proposed TGB. This would be a complex and extremely expensive proposal. 6.1269 Traffic levels in the area will increase between now and 2016 with or without the TGB, and this will demand the provision of traffic mitigation measures in Bexley whether the bridge in built or not. The Boroughs Agreement and the Unilateral Undertaking provide for mitigation measures to be implemented where there would be a material adverse traffic impact on any highway as a result of changes in traffic patterns caused by the opening of the TGB. There is also provision for such mitigation measures to be in place before the opening of the TGB. Mr Clive Efford MP 6.1270 Mr Clive Efford is the MP for Eltham. 6.1271 There has not been proper or adequate consultation with local people. Only one option has been offered to them. There has been no consideration of a public transport option. 6.1272 This is perhaps because there is such a long standing plan for a road bridge at Gallions Reach. But our understanding of new roads and traffic generation has moved on since a bridge in this location was first proposed, more than half a century ago. In particular, it is now recognised that new roads do not automatically deliver regeneration. 6.1273 There is no evidence that the bridge proposed would create any jobs over and above those which would be delivered by a public transport bridge. Nor is there any evidence that the bridge proposed would tackle social exclusion. 6.1274 Without significant investment in improved transport links, the bridge would be likely to cause a modal shift from public transport to the car. The thrust of current policy is to reduce traffic growth. The TGB would cause a move in the opposite direction. Along with Vauxhall Bridge, it would be one of the two largest bridges in London in terms of traffic capacity. It is hard to believe that this sort of capacity is necessary for what TfL insist would be a local bridge for local people. 6.1275 The existing road network south of the river would not be able to cope with the volume of traffic which would cross the bridge. This would lead to demands for the resurrection of the link to the A2 proposed as part of ELRC.
389
This should be borne in mind in assessing the current scheme. The 1999 SACTRA Report concluded that Routes should be assessed in their entirety for environmental reasons decisions on schemes in one part of a corridor should not pre-commit environmentally sensitive decisions elsewhere in the corridor without a thorough economic environmental appraisal of the overall strategy. A link to the A2 would involve crossing Oxleas Wood, a designated SSSI. If this is to be the inevitable result of accepting the present proposal, it needs to be taken into account in deciding the outcome of the present proposal. 6.1276 The TGB proposal would add to the problems of air quality in the area, caused largely by the existing quantities of traffic. 6.1277 There are no details of how the tolling mechanism would be policed to ensure that people were unable to register their vehicles within a discount area in order to avoid paying the higher level of toll envisaged for non local traffic. Response of TfL to the objection of Mr Clive Efford MP 6.1278 Alternative crossing options were considered at an early stage of the projects development, but a multi-modal crossing was assumed in all options. Given the existing commitment to the DLR extension and the planned Crossrail project, it was not considered necessary to countenance a further public transport only crossing. The TGB includes, however, provision for public transport, private vehicles, cyclists and pedestrians. Public transport trips across the bridge would not attract a toll. 6.1279 Alternative sites were considered between Erith and the Thames Barrier (Document TfL/P/04/2 paragraph 6.2.1). The criteria against which the proposed site was chosen included the ease with which proposed development sites could be served; the connection with the current and proposed road network; and the connections which would be available with public transport. Road and tunnel options were considered. 6.1280 Quite apart from public consultation and discussion of the Mayors Transport Strategy and the London Plan, there was public consultation on the emerging TGB proposal, together with market research, both of which demonstrated overwhelming support for the proposal. 6.1281 The area immediately around the proposed bridge is the focus of national, regional and local policies aimed at transforming the area by increasing substantially its population and the job opportunities available. The TGB would be part of a package which includes many other investments and strategies. It would not by itself reduce unemployment, but it would help to create favourable conditions for regeneration. It would also break down the
390
significant barrier between North and South London which the Thames creates. 6.1282 The proposed bridge would facilitate local freight movements which could not be achieved on a public transport only bridge. 6.1283 The ELRC proposal has been formally abandoned, and the authorising Orders have been revoked. There is no policy support and there is no intention to resurrect the ELRC proposal. 6.1284 There has been extensive examination of the air quality implications of traffic on the TGB, including the implications of a higher level of traffic across the bridge than is now anticipated, and that suggests that there is no reason for concern regarding air quality. 6.1285 The tolling proposals finally put into operation would be discussed with the local Boroughs through the BCG. The tolling strategy is integral to delivering the projects overall objectives, striking a balance between promoting local regeneration and social inclusion objectives and minimising environmental impact. If higher levels of longer distance traffic than anticipated choose to use the scheme, there would be the possibility of increasing general tolls, but retaining low discounted tolls for local residents. Mr David Evennett MP 6.1286 Mr Evennett is the MP for Bexleyheath and Crayford. 6.1287 He supports the regeneration of the Thames Gateway in principle, but considers it very important to look at how aspects of the proposals would affect the residents of the area in practice. 6.1288 There has been no real thought for the consequences for Bexley which would flow from the building of the TGB. It would cause an increase in traffic, particularly lorries, juggernauts and vans; it would cause an increase in noise and air pollution; and it would lead to gridlock on the unsuitable, mainly residential roads of Bexley. The people making the development proposals do not live in this area. They do not know the conditions in the area. They work in offices away from the area, and they plan from maps. 6.1289 Many roads in the area are already beset with traffic problems, particularly during the peak hours, for example the junction of Brampton Road and Crook Log in Bexleyheath or Perry Street in Crayford. 6.1290 Tolling would not restrict or discourage traffic. Time is money, and drivers would be prepared to pay to use the TGB, particularly if there were problems at Dartford or Blackwall. This would divert them on to unsuitable roads, such as Brampton Road and Knee Hill.
391
6.1291 The traffic figures produced by TfL initially had to be revised when they were found to be wrong. There is no guarantee that the predictions which replaced them will be any more accurate. 6.1292 There is no guarantee of the number of jobs which would be created by building the bridge. The positive case for the bridge is completely unproven. The Thames Gateway would still develop without this bridge. 6.1293 Additional crossings could be created at Blackwall or to the east of the Dartford Crossing. Another rail crossing could be created by extending the DLR. This would cause much less pollution. 6.1294 TfL have themselves given evidence that some people would experience an increase in noise of 5dB; but they say that the level at which a change in noise level is noticed is 3dB. 6.1295 Similarly, TfL have themselves given evidence that pollution would be increased by the bridge. They say that this would only be by 0.6%, but any increase should be avoided. 6.1296 The people of Bexley would face the worst of the adverse consequences of the bridge, but receive few of the benefits in return. Response of TfL to the objection of Mr David Evennett MP 6.1297 TfLs traffic modelling shows relatively small increases in traffic arising from the TGB. TfL accept that local traffic management measures should be undertaken to minimise the impact of the traffic increases. This would be done under the Boroughs Agreement. It could include measures such as enhanced crossing facilities, traffic calming and lower speed limits. The various reports prepared by Halcrow, in discussion with the local authorities, in 2003-4 show that the potential significance of the Knee Hill corridor was always appreciated and addressed by the proposed mitigation measures (Document TfL/68/1). Mr Evennett does not identify any further mitigation measures that are needed. The proportion of goods vehicles using the bridge is predicted to be 20% of the total traffic. Of these, 12% would be light goods vehicles and 8% other goods vehicles. 6.1298 When there are problems at Dartford or Blackwall, TfL have always accepted that there would be some diversion of through traffic from those crossings. But there is no evidence that this would be the norm. It would not just be the higher tolls, but also the longer journey time which would deter commercial traffic from using the TGB. 6.1299 The revised traffic figures have been produced because the base has changed - traffic in Bexley has been growing faster than anticipated - not because of any defect in the original modelling.
392
6.1300 TfL have presented evidence which seeks to make the best possible prediction of the number of potential jobs which would be created as a result of the building of the TGB. Improved accessibility arising from the building of the TGB has an important part to play in the regeneration of North Bexley, as LB Bexleys Regeneration Framework (Document 1774/42) recognises. 6.1301 The economic case for a DLR extension is slight. A bridge east of Dartford falls outside the responsibilities of TfL and the Mayor of London. The Silvertown Link has been programmed in the London Plan to succeed rather than to precede the TGB. 6.1302 TfL accept that, on the introduction of the scheme, there would be a marked increase in the number of people bothered by road traffic noise. In the long term, however, the number of people bothered would fall to a marginal increase over the number who would be bothered if the scheme were not introduced. 6.1303 A 0.6% increase in emissions would represent only a 0.2% increase in concentrations, as local sources only contribute around a third of total PM10 concentrations. This would not be a significant change. Air quality is expected to improve substantially by 2016 compared with current levels. Exceedences of the statutory air quality objective for nitrogen dioxide, currently seen at three receptors in Bexley, would no longer be expected in 2016, with or without the TGB. The statutory objective for PM10 would also not be exceeded with or without the TGB. 6.1304 It is impossible to construct a new stretch of road without some disbenefits in terms of noise and air pollution. It is important to look at these matters in the round, and without assuming that any increase anywhere is significant. Mr John Austin MP 6.1305 Mr Austin is the MP for Erith and Thamesmead. 6.1306 It is accepted that there was consultation about the bridge proposal, but it was on a very narrow basis, simply asking people whether they wanted a bridge at Gallions Reach. It did not offer alternative locations, or a bridge solely dedicated to public transport. Whilst these issues could have been raised by members of the public at an earlier stage when the Mayors Transport Strategy and the London Plan were under discussion, there is great difficulty in engaging the general public in discussion on strategic policy documents. People only become really energised when they see detailed proposals, and understand the impact which such proposals would have on their lives. There has been a groundswell of opposition to the bridge since the planning applications were published and people began to realise the full implications of the proposal.
393
6.1307 In Thamesmead, you would probably find a higher proportion of people supporting the building of a bridge, because they have a very poor transport infrastructure, and feel isolated. Once you move further south, the people in those areas feel that they were not involved in the early stages of the consultation. 6.1308 Whatever the intentions of TfL to build a local bridge for local people, the TGB would become a major strategic link. In terms of capacity, the TGB would be a six lane bridge, with two lanes dedicated to public transport, like Vauxhall Bridge. But Vauxhall Bridge has appropriate feeder roads and exit roads. South of the river, the TGB would rely on small local roads like Plumstead Road, where the bus lane has had to be suspended to avoid gridlock. Inevitably, once the TGB was opened, there would be pressure for a relief road to connect to the A2. 6.1309 The TGB is part of a package of three proposals in the Mayors strategy, the others being the Woolwich Rail Tunnel and a third road crossing at Blackwall. The crossing at Blackwall would clearly be a relief for the existing congested tunnels and tunnel approaches. The north bound tunnel cannot take all types of HGVs, which currently use alternative routes. For them, the TGB would be an attractive proposition. 6.1310 There is clearly a problem at Blackwall. There is an imbalance in capacity between the approach roads and the tunnels themselves, which leads to bottlenecks and tailbacks on the approach roads. This would worsen with the predicted growth and regeneration in the Thames Gateway. If the TGB is built first, lorries caught in the Blackwall tailbacks would inevitably seek alternative routes, and use the TGB, with devastating impact on local roads. 6.1311 Any increase in the capacity of the highway system will increase traffic, but building a new road link where none exists now would not just lead to diversion of existing traffic or anticipated increased traffic flows, it would also generate new traffic that would otherwise not be there. It would also encourage a modal shift from public transport to the private car. 6.1312 Even a toll at the maximum level which TfL are requesting (4 for cars, at the time Mr Austin appeared at the inquiry) would not deter people trying to find an alternative to the congested crossings at Blackwall and Dartford. 6.1313 Existing levels of pollution would be increased by the traffic which would be generated by the bridge. There are parts of the area which would be affected where pollutant levels are higher than elsewhere because of the topography of the area, which makes it more difficult for pollutants to disperse. Levels of respiratory illness and asthma are significantly higher in Erith and Thamesmead than in London as a whole. 6.1314 It is accepted that being employed can create a sense of wellbeing which offers a benefit to health, but that is not a reason to ignore the damage to health which can arise from increased pollution.
394
6.1315 There is no indication of where the jobs which it is claimed would arise from the construction of the TGB would be located or what those jobs would be. It is assumed that improved accessibility would create jobs. But, as Professor Whitelegg has shown, building roads does not produce jobs in the area where the road is built. The TGB could, in reality, encourage people to travel further to work or to shop, increasing car usage and damaging the local economy. 6.1316 More river crossings would enable more people from the south of the river access to the increased employment opportunities in Newham and Tower Hamlets. But increasing access for people from Greenwich and Bexley does not necessarily increase employment. It means that they will be competing for jobs with people from those areas. What is needed is a strategy to create local jobs in Greenwich and Bexley for local people, reducing the need for long journeys to work. 6.1317 There has been no analysis of the local skills base and the need for education and training. If jobs are created locally which cannot be filled locally, this would encourage the transfer of people with the necessary skills, perhaps commuting over long distances. 6.1318 Low tolls for local people would not produce much toll income. Tolls sufficiently high to deter other people from using the bridge would not produce much toll income. It is therefore difficult to see what type of use would produce the income from tolls to pay for the bridge. 6.1319 The impact of Crossrail has not been fully taken into account in the proposals for the TGB. Much of the job creation in the area would in fact occur because of improvements to public transport rather than improvements to private transport. There should be a revisiting of the economic analysis of the TGB, taking into account the likely increase in jobs and regeneration that Crossrail would bring. 6.1320 TfL also say that Crossrail was modelled on the basis that it would continue from Abbey Wood to Ebbsfleet. The proposal before Parliament at the moment does not continue the line beyond Abbey Wood. Abbey Wood would be the major terminal and the junction with the North Kent Line. That has traffic and transport implications for the area, in that more people would want to drive to Abbey Wood to connect with Crossrail. 6.1321 TfL refer to several existing public transport crossings of the river, but the Jubilee Line extension, the DLR to Lewisham and the East London Line have no relevance to the people of Erith and Thamesmead. It takes someone from Welling an hour on a bus to reach the Jubilee Line at Greenwich, and it is therefore not a sensible north-south public transport crossing for such a person to use.
395
Response of TfL to the objection of Mr John Austin MP 6.1322 The TGB is included in both the Mayors Transport Strategy and the London Plan, both of which have been the subject of public consultation, the former in January 2001, and the latter in September 2002. The London Plan was also the subject of an Examination in Public in March and April 2003. Specific public consultation on the scheme before submission of the planning applications was carried out by TfL between May and August 2003. This last mentioned consultation was carried out throughout Bexley north of the A2, and not just in Thamesmead. 6.1323 In developing the TGB scheme, a number of alternative crossing types and locations, tolling regimes and options for the provision of public transport were considered by TfL. By 2003, however, the public were not given the option of voting for a public transport only link, because by then that was not the proposal. The Mayors Transport Strategy and the London Plan had already opted for a multi-modal link, and had prioritised the provision of the TGB ahead of the Silvertown Link. 6.1324 While the proposed bridge would have six lanes, two of them would be dedicated for public transport. The public transport lanes would be on a separate structure, have their own separate access roads, would be clearly designed for public transport, and could not be converted for use by ordinary vehicles without some expenditure, the approval of new Orders, and an amendment to any planning permission. 6.1325 It is accepted that the junction of Pettman Crescent and Plumstead Road will be significantly more congested by 2016, but this is only marginally as a result of the TGB. It indicates the need to consider traffic measures to ease potential pressure on this junction with or without the TGB. 6.1326 TfL have no intention that the TGB should become a strategic national link, and there is no national or regional policy support for such a proposal. 6.1327 TfL accept that some people would divert from using other river crossings to reach their destination because the TGB would offer the quickest route for them. But the tolling regime would be designed to favour local traffic and to discourage longer distance through movement. 6.1328 There is expected to be a substantial improvement in air quality for people living within the study area by the time the TGB is opened. This would be hardly affected by the small increase in exposure as a result of the TGB. 6.1329 The provision of transport infrastructure is only a necessary condition for regeneration. It will not by itself address unemployment amongst local residents. But, without accessibility, businesses will not locate in an area and residents will not be able to access jobs. The Bexley Regeneration Framework (Document TfL/96) indicates at page 16 that Bexley consider that there is a need for better transport links, with the proposed three
396
Thames Crossings, including the TGB, being mentioned as necessary. For people who do not have access to a car, the TGB would offer improved public transport access to jobs. Public transport trips would not be subject to a toll. 6.1330 The LSC have carried out a Thames Gateway Skills Audit (Document TfL/148) to inform the future provision of education and training to equip local people to take advantage of employment opportunities which could arise if the bridge were constructed. 6.1331 The economic evaluation of the scheme (the COBA) does not take into account the number of jobs which might be created. The numbers are, however, included in the AST provided as part of the New Approach to Appraisal. 6.1332 The impact of Crossrail on regeneration has been considered, including the proposed termination of the service at Abbey Wood. Details are set out in Document TfL/199. The effect of both Crossrail and the Silvertown Link would be to reduce traffic using the TGB. With Crossrail, the effect would be very small and not significant. For the Silvertown Link, the reduction would be more significant, but still only a reduction of 5%. Mr Robert Neill AM 6.1333 Mr Neill is the London Assembly Member for Bexley and Bromley. 6.1334 He does not object to the principle of a further river crossing, but he objects to the specific scheme put forward by TfL. To avoid unacceptably high disbenefits in traffic and environmental terms, the scheme needed to have either a link to the A2 or a more robust series of mitigation measures to prevent rat running through residential roads in Bexley. Those mitigation measures needed to be agreed in advance, rather than waiting until after the scheme was developed. 6.1335 TfL should be prepared to fund in full the mitigation shown to be necessary as a consequence of the TGB for a period of ten years after the scheme was fully in operation. It could not be certain that the amount allowed for in the Boroughs Agreement would be sufficient to cover the cost of all the work which proved to be necessary. 6.1336 The modelling which TfL had done in preparing the scheme was out of date and unreliable. It had been shown that traffic growth in Bexley had been higher than the average in London even without the TGB. 6.1337 Greater certainty was also needed in relation to the level of public transport which would be provided in Bexley. The Transport Strategy and other planning documents should guarantee the integration of the GWT and the ELT to form the Thames Gateway Transit and to link with the Dartford
397
Fastrack. The level of public transport across the bridge should be guaranteed. Response of TfL to the objection of Mr Robert Neill AM 6.1338 There has never been any intention to delay mitigation measures until after the scheme has been developed. Those which could be shown to be clearly necessary would be put in place before the scheme was opened. TfL would be providing a contingency sum in addition to the costs of those works in order to meet the price for works the need for which could not be clearly anticipated in advance. Nobody has been able to quote an example of a scheme in relation to which an uncapped, unlimited financial provision has been made for mitigation measures. 6.1339 The revised modelling carried out by TfL should meet Mr Neills concerns regarding reliability. It shows that the local road network in Bexley can cope with the traffic likely to be generated by the TGB. 6.1340 The Mayor of London has indicated in Document TfL/112 that a reasonably generous level of public transport services is intended to be provided across the bridge, but it would be legally inappropriate for TfL to enter into any more binding commitment in that regard. Councillor Ian Clement 6.1341 Councillor Clement is a Member of Bexley Council. He is the Leader of the Conservative Group on the Council, and objected to the scheme both on his own behalf and on behalf of the Members of his Group, who had authorised the objection. At the time of the inquiry, the Conservatives held 31 of the 63 seats on Bexley Council. 6.1342 There is a need for regeneration in Bexley, but regeneration which will deliver long term, sustainable, quality jobs for the young people of the area. 6.1343 The proposed TGB would not certainly achieve that end. The traffic forecasts cannot be relied on; the tolls would not deter traffic so as to avoid adding to congestion; the funds proposed for mitigation measures would not be adequate. Bexley badly needs improved public transport facilities. Without that need being addressed, more and more people will try to use their private cars. This will add to congestion throughout the whole of the Borough, and add to the poor air quality which is already suffered in the Borough because of its geographical location and its topography. Response by TfL to the objection of Councillor Ian Clement 6.1344 Long distance traffic would not achieve journey time savings by using the TGB, and the toll on the TGB would be three times that at the Dartford Crossing. At the very least, these matters would deter traffic and assist in
398
preventing the TGB from becoming a key strategic route. 6.1345 The proposed discount area in Bexley has been reduced in size in order to reduce traffic flows, which were of concern to people in Bexley. 6.1346 The Boroughs Agreement and the Unilateral Undertaking assure certain mitigation measures to Bexley, and the total sum of 14.5m would be available under those Agreements to deal with necessary mitigation. By any standard, this is a significant level of provision. TfL recognise that not all necessary mitigation can be identified in advance of the opening of the proposed bridge, which is why a contingency sum of 6.2m has been offered within the overall provision which would be made. 6.1347 The GWT will improve public transport for many people in Bexley, but, in TfLs view, there is also a need to improve accessibility from Bexley to the north of the river by both public and private forms of transport, and this is what the bridge would achieve. 6.1348 There is no evidence that air quality is particularly bad in Bexley, and no evidence that the TGB would adversely affect health. Councillor Peter Catterall 6.1349 Councillor Catterall is a Member of Bexley LB Council. He appeared at the inquiry to make a personal objection. 6.1350 The new arrangements for local government in London, with the creation of the office of Mayor of London were intended to create an opportunity for (amongst other things) strategic transport planning. One of the first fruits of this process was a consultation document on improving orbital transport around the whole of London. But the plan has not been followed through with the energy which might have been expected. Instead, we have this plan for a bridge which, so far as the southern end of it is concerned, would be a bridge to nowhere, a bridge which would not serve the overall strategic purpose because it would not link into a further developed transport infrastructure. 6.1351 Knee Hill may be an A road by historic designation, but it is also a road which was removed from a bus route some years ago because the bus stop at the top of the road was considered to be too dangerous to continue to be used. It is therefore difficult to regard it as a sensible strategic relief road for any traffic generated by the bridge. 6.1352 The bridge has been proposed on the basis that it would improve employment. But in Bexley the potential range of additional jobs is said to be between nil and 700. These are not figures which would outweigh the disadvantages which the bridge would cause in the Borough. Moreover, any extra jobs could well be in warehousing, which currently accounts for 50%
399
of the planning applications for employment received in the Borough. If tolls on the bridge were to be set too high, this would in any event discourage people who might benefit from any additional employment created. 6.1353 If the proposed bridge would really be a local bridge, as TfL suggest, it is difficult to see why four lanes are necessary for private traffic. 6.1354 So far, the Governments progress towards hitting the Kyoto targets for reducing emissions has depended almost entirely on reducing emissions from electricity generation. Despite the introduction of catalytic converters and other technological improvements, emissions from transport have increased. There is bad air quality already in the north of Bexley, and the proposed bridge would simply add to that problem. Response by TfL to the objection of Councillor Peter Catterall 6.1355 The majority of the TGB traffic from and to the south of the river would use the Thames Spine Road (A 206/A2016), not Harrow Manorway/ Knee Hill (A2041). Only 20% of traffic would use the latter corridor. The TGB would not be intended in any event to function as a route for through traffic. 6.1356 There is no evidence that Knee Hill has a bad accident record. The figures contained in Document 2052/38 do not support the concern expressed about the dangers of this route. Neither Bexley nor Greenwich wishes Knee Hill to be widened or improved. In fact, if such action were to be taken, this would only serve to increase its attraction to traffic, particularly to HGVs. As an A road and a London distributor road, there is no reason why Knee Hill should not carry the small (9%) peak hour increase predicted by the modelled figures over the Do Minimum situation. 6.1357 The existing employment available in Bexley requires good accessibility to survive and develop. The aim is to upgrade and diversify the existing employment opportunities. This depends on a number of initiatives to attract investment, of which the proposed bridge is one element. Tolls would be set to discourage longer distance traffic. 6.1358 The forecast levels of traffic with origins or destinations (or both) within the four adjacent Boroughs could not be accommodated on a two lane TGB. 6.1359 Air quality in the north of Bexley is in fact not unusual for any urban site in the UK, as indicated by Document 2052/1/A2 Appendix 24 (House of Commons Hansard 31.1.96 column 961). Any worsening of air quality as a result of the TGB would not be significant. Councillor John Waters 6.1360 Councillor Waters is a Member of Bexley Council.
400
6.1361 His prime concern regarding the proposed bridge is that, while the road system to the north of the bridge is good, on the south the roads could not cope with the traffic which would use the bridge. Particularly when the Blackwall Tunnel and the Dartford Crossing are closed or restricted, the TGB would be used as an alternative route between the A2 and the M11. The increasing use of satellite navigation systems in vehicles (including systems which offer real time traffic information) would encourage this situation. By the time the bridge opened, satellite navigation systems would have become even more common. 6.1362 At times of restrictions in the use of other river crossings (or, indeed, generally when people used the TGB) extra traffic would run along the roads such as Brampton Road and Danson Road in some of the most attractive parts of Danson Park Ward, which Councillor Waters represents. This would have an adverse impact on the historic 250 years old Danson Park, and on Danson House, recently opened to the public by HM The Queen. 6.1363 The proposal to restrict the discount area for tolls in Bexley would mean that the very residents who would suffer most from increased traffic and congestion would have the planned benefit of the discounted toll removed from them. 6.1364 When Bexley were consulted by Greenwich on the TGB planning application, it was elected Members who firmed up the Councils position from one of guarded approval, as suggested by officers of the Council, to opposition unless a full Traffic Impact Assessment had been carried out and any necessary mitigation measures had been agreed and funded. As things stand, it is not clear that the funds offered by TfL for mitigation measures would be adequate to carry out all the necessary work. 6.1365 Councillor Waters originally suggested that one possible improvement which could be carried out to improve the capability of the road system in Bexley to cope with traffic from the proposed bridge would be to create grade separated junctions at two existing bottlenecks in Erith - the roundabout at Erith Town Hall and the junction to the east with James Watt Way. On it being put to him that this was not a solution advanced on behalf of Bexley Council, however, Councillor Waters subsequently effectively withdrew the suggestion by way of Document 2068/2. It was not a matter which Bexley wished to pursue in the context of the TGB. On my site visit, it was clear that there would be considerable difficulties in achieving a junction involving further grade separation at the Erith Town Hall roundabout. The space for development is significantly constrained by the existence of the Town Hall, a church and the railway line in close proximity to the roundabout, and by a pedestrian underpass which lies beneath it. The response of TfL to the objection of Councillor John Waters 6.1366 It is accepted that, if Blackwall or the Dartford Crossing were to be closed,
401
there would be some diversion to the TGB, but closure is rare, and the consequence of closure or restriction at those crossings is not a reason for not building the TGB. 6.1367 Satellite systems identify routes which are subject to a toll, and this would provide a disincentive to the use of the TGB. 6.1368 The proposed reduction in the discount area for tolls in Bexley is a response to the concern expressed by people in Bexley at the impact of projected traffic flows on their roads. The original discount area in Bexley was much larger than that proposed for any other Borough, extending outside a 6km radius from the centre of the proposed bridge. 6.1369 The evidence that Bexley Councillors went against the advice of their officers is significant. It underlines the fact that the officers judgement was to negotiate with TfL, rather than to come to the inquiry seeking additional unidentified mitigation measures and an unlimited contingency fund to pay for them. 6.1370 A case can obviously be made for road improvements in Erith, but it is noted that such proposals do not have the support of Bexley Council, because they do not want too much traffic to be encouraged to use the Bronze Age Way (A2016) route. Mr Philip Connolly Form of the scheme 6.1371 Although he has very substantial experience of architecture and urban planning in the London area, TfLs expert witness on the form of the bridge admits he is not an expert on bridges. He seeks to comment on the bridges contribution to the London skyline before the bridge has been designed. A scheme 4.5 km long is much more than a feature in Londons townscape, but that is how TfL describe it. If it was part of the townscape it should have commonplace facilities such as bus stops, toilets or benches but none is proposed. 6.1372 A four lane trunk road or six lane motorway carrying 19.9 million vehicles a year cannot be considered to be part of a green grid. Nor would it be an open space that might form part of the Cross River Park; or an urban lung comparable with Epping Forest, Hampstead Heath or the Royal Parks. Rather, it would be a source of traffic-related air pollution. 6.1373 There is no evidence to support TfLs view that the scheme would contribute to the social landscape of East London. 6.1374 The views of CABE, set out in their written representation to the inquiry (Representation 1998), must be given serious consideration and possibly
402
even greater weight than those of TfLs witness, an advisor to the Mayor of London. 6.1375 PPS1 states that planning should facilitate and promote sustainable and inclusive development by . ensuring high quality development through good and inclusive design. The scheme would induce extra traffic, reduce air quality, increase carbon dioxide emissions and do little for pedestrians. This is inconsistent with PPS1. Nor would the scheme make London a better place for people to live in, although this is an objective of the London Plan. 6.1376 The illustrative design is functional and lacks any design merit. But the design quality strategy proposed by the promoters has merit, and some weight should be given to the local planning authorities witnesses confidence that a good design will be achieved. Response by TfL to the objection of Mr Philip Connolly Form of the scheme 6.1377 TfLs expert witness on the form of the bridge, although not an expert on bridges, has considerable expertise in the field of high quality design in respect of a range of architectural and urban design projects. The general form of the scheme is dictated to a large extent by the flight path and navigation requirements of LCY and the PLA, and so the likely effects of the bridge are well capable of description. A major piece of infrastructure, such as the freeways linking Manhattan to up-state New York, may be an integral part of the landscape without toilets, benches or bus stops. 6.1378 A role of the scheme is its potential to act as the central spine of an extended north-south infrastructure of open space that serves Londons urban communities. It could become the centrepiece of a large-scale open regeneration corridor linking open spaces and existing structures that are currently used as a civic amenity. Although not an urban lung itself, it would provide the catalyst for the creation of one. 6.1379 As the to schemes contribution to the social landscape, it has the potential to act as a social resource and would remove severance. 6.1380 The comments of CABE (Document 1998) were taken into consideration by TfLs witness in assessing the design quality of the bridge. Mr Kenneth Hobday 6.1381 Mr Hobday is a local resident, who lives in Abbey Wood. He is much involved in wildlife conservation in the area, and makes a contribution to a number of Greenwich Council Committees on environmental matters. He runs a small informal wildlife group in the area (the Abbey Wood Wildlife
403
Group), but his objection is essentially a personal one. Increased traffic 6.1382 The TGB would generate massive amounts of additional road traffic, which would flood local roads unsuitable for such traffic flows. The bridge would not simply be a local bridge. The tolling regime would not dissuade drivers from using the bridge as a link to the A2 or the M25 south of the Dartford Crossing. Nor would drivers use only the A2016/A206 to reach the M25 from the bridge. Traffic would use the local roads at Knee Hill and Brampton Road to link with the A2 at the Danson Park Interchange, and then on to the M25. 6.1383 Local roads would not be able to cope with this traffic. They are already heavily congested. The proposals put forward by TfL include no effective measures to address this problem. Environmental damage 6.1384 The result would be pressure to widen Knee Hill. This would be environmentally damaging to Lesnes Abbey Woods and to Bostall Woods, which lie on either side of Knee Hill. 6.1385 These pieces of woodland are ecologically significant, containing many species recognised in the Mayors Biodiversity Action Plan, such as bats, stag beetles and tawny owls. They are both Metropolitan Open Space, and they form part of the Green Chain of open spaces in the metropolitan area. An alternative approach 6.1386 Economic and transport policies should seek to exclude vehicle movement and road use as much as possible, and to move people and goods around using rail, trams and light railways. Any new river crossings over the Thames should be public transport/rail/pedestrian/cyclist only. Communities become divided by major roads and noise. Response by TfL to the objection of Mr Kenneth Hobday Increased traffic 6.1387 Use of the TGB itself is estimated to be some 20 million vehicles a year, but only 14% of that total would be new journeys stimulated by the scheme. The majority would be trips that would have been made anyway within the area. 6.1388 Mitigation measures proposed to be implemented under the Boroughs Agreement before the opening of the TGB would include measures on Knee
404
Hill, Bostall Hill and Brampton Road. 6.1389 TfL have no intention that the TGB should become a strategic national link. There is no national, regional or local policy support for such a proposal. Environmental damage 6.1390 Knee Hill passes in an embanked cutting through Lesnes Abbey Woods and Bostall Woods SMI, and causes some severance effects to the SMI. The increase in traffic predicted for the scheme would be unlikely to increase significantly the level of this severance. TfL do not consider that there is a need to widen Knee Hill between the two woodlands, and Greenwich confirmed at the inquiry that they had no plan to widen the carriageway of Knee Hill, though they could give no assurance that such a proposal might not arise from the Crossrail scheme (D88 P109 L24). An alternative approach 6.1391 Given the public transport crossings which have already been created in the area, limited mode crossings perform comparatively poorly in any economic test, and would be difficult to finance. They would also not offer a crossing of use to goods vehicles. Mr Roy Carrier 6.1392 Mr Carrier is a local resident who lives in Abbey Wood. 6.1393 He objects to the proposed development because it is not known what the environmental impact would be on the quality of life the residents of the London Borough of Bexley as a result of the traffic levels likely to be generated by the use of the bridge; and it is not known whether the road network of Bexley could function effectively if the bridge were to be built. Traffic impact 6.1394 The additional traffic generated by the bridge on local roads in Bexley should be established with greater certainty before any decision is taken regarding the TGB. 6.1395 Local users might divert from using other river crossings to reach their destination because the TGB would offer a quicker route for them. In fact, some people would adapt their travel patterns or possibly their living or working arrangements to take advantage of the change in accessibility provided by the TGB. It is possible that trips between the TGB and the A2 at the Danson Interchange would be made by way of Danson Road, Crook Log, Brampton Road, Knee Hill, Harrow Manorway and Eastern Way. Traffic might also be attracted to the TGB from the Black Prince Interchange via Gravel Hill, Erith Road and Long Lane. Both of these routes currently carry
405
high peak hour vehicle flows as well as higher vehicle flows during the day than nearby streets. Consideration must be given to whether the roads can accommodate the increase in traffic which would arise from the TGB. Some of the roads likely to be affected are believed already to operate at or above their theoretical capacity. Increased vehicular demand would therefore also impact on the surrounding roads, because, to avoid queuing, drivers may try to navigate the surrounding residential road networks. 6.1396 Further modelling and sensitivity testing are required to provide a greater confidence in the predicted impact of the roads likely to be affected. There is a need for TfL to reassess the traffic impact over a more comprehensive network in Bexley. 6.1397 It is not appropriate to finalise proposals for mitigation works before that is done, especially having regard to the other traffic changes which might occur over much of the area before then. It would be inappropriate to grant planning permission now if these concerns cannot be addressed at this time. The LTS model needs to be refreshed, a process which it is understood would take in the region of two years. 6.1398 It was suggested on behalf of TfL that the roads serving the TGB would not be signed as a route from the M25 to the North Circular, but that would not achieve much in the way of relief, because satellite navigation systems, website route planners, A to Z maps and word of mouth would soon make the TGB a favoured route for all modes of transport. Although lorries could be precluded from using Knee Hill, New Road and Picardy Manorway, in the absence of inhibitions, the drivers of other vehicles would no doubt make full use of the Bexley road network. 6.1399 The present Crossrail proposal would terminate south of the Thames at Abbey Wood, and that is also the termination point for the GWT. Added to the traffic in that area generated by the TGB, this would create a major bottleneck. Yet the traffic assessments have not allowed for Crossrail traffic. Traffic mitigation measures 6.1400 Traffic mitigation measures should be settled in detail before a decision is taken whether or not to grant planning permission, but they cannot be prepared if there has not been a full traffic impact assessment in relation to the Bexley road network. The sort of traffic mitigation measures likely to be necessary would themselves be substantial, and they should therefore be the subject of public consultation. 6.1401 According to Document TfL/212, the latest list of mitigation measures to be implemented before the opening of the TGB would involve four schemes in Greenwich, two in Newham and fourteen in Bexley. The reason why the share of the works is so disproportionately high in Bexley is clearly because the major adverse effects of the TGB would be felt there.
406
Public transport 6.1402 Indicative information regarding bus networks should be provided in order to allow the impact of buses on the road system to be assessed in determining whether planning permission for the scheme should be given or not. Whilst insufficient commitment has been offered as to how Bexley would be served by public transport beyond Abbey Wood, it is also necessary to consider what impact any extension of the bus service would have on the Bexley road network. Toll charges 6.1403 Even the maximum tolls are far too low, and would encourage use of the TGB by drivers from outside the local area. 6.1404 The initial level of tolls chargeable and the discount area should have been resolved before the application for planning permission was made. Those issues should also not be within the absolute discretion of TfL, but should be agreed by all of the relevant local Borough Councils. 6.1405 TfL insist that they would be able to control overall levels of traffic with mitigation measures and tolling, but that does not appear to be a view which is shared by business representatives who have given evidence to the inquiry. Mr Stuart Robinson states in Appendix B of his evidence (Document 1987/1/A2) that London City Airport currently handles two million passengers per year. The Government has identified the airport as being capable of increasing its capacity to five million passengers per year by the year 2030. London City Airport believes that it could reach 8 million passengers per year in the same timescale. 6.1406 At paragraph 4.13 of the same Document, Mr Robinson says, when remarking that since he originally prepared his evidence the 2012 Olympic Bid has been successful, that the close proximity of the TGB to the Lower Lea Valley would open up South East London to the many benefits of the Olympic Games themselves in 2012 and to the legacy proposals which are planned for the area in the future. 6.1407 TfL have made an application for planning permission on the basis that the bridges capacity for traffic would never be fully utilised, but it is clearly the intention of others to use the capacity of the bridge, if it is built, to the maximum. Overall 6.1408 Having regard to Policy 3C.15 of the London Plan, the TGB scheme should not be allowed to proceed because, so far at least as Bexley is concerned, benefits in other areas do not very substantially outweigh any disbenefits.
407
Response by TfL to the objection of Mr Roy Carrier Traffic impact 6.1409 There would only be minor adverse effects on Bexley in terms of air quality and noise. With the revised tolling arrangements, the traffic changes resulting from the TGB could be accommodated on Bexleys road network. 6.1410 The refreshment of the LTS model would not produce a model which was perfect. It would continue to have the same difficulties that any model of this nature for the whole of London must of necessity have. The 2001 matrix which would go into the new LTS model looks very similar to the synthesised 2001 matrix which has already been used. At the end of the day, a model is a predictive tool; it cannot deliver certainty. 6.1411 The approval procedures and the construction timetable for Crossrail run behind those for the TGB. TfL therefore do not consider it appropriate to make a presumption as to the outcome of those processes in assessing the impact of the TGB. Traffic mitigation measures 6.1412 Traffic mitigation measures are widely recognised as a conventional means of controlling the speed and flow of traffic in London. The rebasing of the traffic model, and the greater certainty which that has brought with respect to the works likely to be required, has led to the definition of those works in Document TfL/212. That has been published as an Addendum to the ES to allow any public response to the proposals. No adverse response has been received. Public transport 6.1413 It is not practical to set public transport timetables and targets six years or more before those arrangements would become operational. If the bridge is approved, it would be built with substantial public transport infrastructure. There can be confidence that an appropriate transit service serving Barking, Woolwich and Abbey Wood (expected to be twenty buses each hour in each direction) would be run over the TGB on its opening. In addition, it is expected that other destinations would be served by orbital services as demand dictates. 6.1414 The Mayor of London has offered reassurance regarding the minimum level of service in Document TfL/112. TfL consider that it would be unreasonable to refuse planning permission because of the absence of a legally binding commitment on initial bus service levels. Toll charges 6.1415 While it is the case that there would be flexibility as regards the setting of
408
tolls, the tolling regime placed before the inquiry by TfL is considered to be the appropriate one that is likely to be implemented. TfL would act responsibly in relation to the setting of tolls in accordance with their duty under the Traffic Management Act 2004 and having regard to the commitments contained in the Boroughs Agreement and the Unilateral Undertaking. These set out the matters which TfL would be required to take into account in determining the tolling regime. They include regeneration, maximising the benefits of the TGB to local people and minimising adverse traffic impacts, as well as recovering costs. Mrs Ida Brown 6.1416 Mrs Brown is a resident of Bexleyheath in the Borough of Bexley. Regeneration 6.1417 Bexley does not have a high incidence of employment shortages, housing shortages or associated deprivation. No ward in the Borough is among the worst 10% nationally in respect of any of these. Conditions are much worse in Newham, Greenwich and Tower Hamlets. Bexley is the least deprived London Borough in the Thames Gateway. 6.1418 The Mayor of London wants to see sustainable communities in London, and Bexley is one such. People there who can work do so; they are independent, contribute to society, pay Council Tax from their honestly earned income and are decent, considerate citizens. But many such people would leave the Borough if it became a polluted, congested corridor. 6.1419 The scheme would disadvantage Bexley by virtue of noise, traffic congestion, pollution and associated health hazards. But its benefits would lie elsewhere. It cannot be wise or intelligent to improve one Borough to the severe detriment of another. Nor would it be fair to the residents of Bexley. 6.1420 Nevertheless, there are five wards in the Borough which rank among the lowest 10% in respect of income. This figure is still better than those for Greenwich, Newham or Tower Hamlets, but a well-known need remains in some small areas of the Borough. The need should be addressed by the local authority through training, education and motivation. Bexley Council has an excellent record here. The need should not be addressed by providing an escape route via a bridge. When Thamesmead was planned, the river was considered an asset. Traffic in Bexley 6.1421 TfLs Reference Case Model predicts an increase in traffic on Pickford Lane if the scheme goes ahead. The traffic using Pickford Lane already exceeds the capacity of the road, which serves many houses and shops together with
409
other premises, all of which attract traffic. Four bus services currently run along Pickford Lane, and the scheme might result in more, since the Lane serves the railway station. Pickford Lane is a Borough Distributor Road, unsuited for use by long distance traffic. In fact, however, it is used by large commercial vehicles at all times of the day. 6.1422 If the TGB were built, the whole of Bexley would be worse off due to traffic associated with the scheme. Bexley would change from a pleasant residential area to a congested, polluted corridor, linking the M11 to the A2 and A20 and thus becoming a relief road to ease the problems of the M25.
Traffic model - reliability 6.1423 The following table compares TfLs traffic flow predictions for Pickford Lane with the results of a traffic survey undertaken by Mrs Brown during the period November 2005 to February 2006: Comparison of actual and modelled traffic flows, Pickford Lane Period 2005/6 Survey Reference Case Model, 2016 Do Min AM Peak Interpeak 1200+ Varies: 500 to 1000 1000+ 703 258 Scheme 780 325 Revised Prediction, 2016 Do Min 1078(a) 255(b) Scheme 1014 (a) 319(b)
PM Peak
No data
No data
Note (a) Cordon Model Note (b) Reference case model with revised tolls 6.1424 The differences (of up to 50%) between the Reference Case Model and the revised predictions give no reason for confidence in the modelling. 6.1425 The present-day figures recently observed are greater than the predicted figures for 2016, whereas an increase in traffic during that period might be expected. Long distance traffic 6.1426 Time is money, and according to the CBI time savings could save
410
businesses billions of pounds each year through reducing wasted man hours, greater fuel efficiency and a renewed commitment to delivery times. Although road use is sensitive to cost, the proposed tolls would be no deterrent for many road users, with the exception of those the scheme purports to help: local deprived people who would need to spend 6 each day in tolls to travel to a job. 6.1427 It is likely that satellite navigation equipment would direct motorists from the A2 to the bridge via Danson Road, Brampton Road and Knee Hill. Such systems always show which route is the shortest, even on unclassified roads; and some can be programmed to avoid congestion on major roads. 6.1428 The scheme would create an alternative route for traffic using the M25, between the A2 and the M11. If the M25 were flowing freely then the M25 would provide the better alternative. But the M25 is very frequently congested, and on such occasions traffic would be likely to divert to the scheme. For example, people approaching the M25 from the northern M11 and aware, through traffic reports, of slow-moving M25 traffic at junctions 29, 30, 31, 32 or the Dartford Crossing would seriously consider continuing south along the M11 to the A406, the new bridge and then via about two miles of difficult roads in Bexley to the A2. 6.1429 Document 1732/11 lists all incidents at the Dartford Crossing between 16 April 2004 and 9 March 2006 and, separately, major incidents from February 1997. Between 16 April 2004 and the end of that year, about 117 incidents were recorded. Around 152 incidents were recorded in 2005, and some 18 in 2006 up to 04:45 on 9 March. Some reports in Document 1732/11 include a note of the resulting queue lengths. Incidents during the day often result in queues more than 1.6km long. Queues of 8km or longer are not exceptional, and on at least one occasion a queue approximately 32km long resulted. The record for 14 October 2004 includes the comment No additional queue to that usually seen in rush hour (3 miles). 6.1430 Closures of scheme. restrictions information the Blackwall Tunnel would give rise to increased use of the Traffic announcements on the radio frequently mention at Blackwall. TfLs South Tunnel Team provided the following about closures of the Tunnel:
Blackwall Tunnel Closures: Annual Numbers 2004 Northbound Tunnel Maintenance Emergencies Southbound Tunnel 48 266 48 221 2005
411
Maintenance Emergencies
140 226
140 136
Note Emergency closures are generally of a very short duration. Maintenance work is often undertaken during night closures. Air quality 6.1431 The promoters expect the scheme to give rise to small increases in the pollutant PM10. The WHO believes there to be no safe limit for exposure to PM10. No increase should be acceptable, particularly to those such as the Mayor of London who advocate improvements in air quality. Human rights 6.1432 The scheme would increase traffic on Pickford Lane, and thus contravene Mrs Browns human right to peaceful enjoyment of her possessions. Response by TfL to the objection of Mrs Ida Brown Regeneration 6.1433 Despite development in Thamesmead, there are still substantial areas of deprivation in north Bexley. The implications of the revised discount area in this regard are considered in TfLs response to Bexley Council. 6.1434 From its earliest days, access to Thamesmead has been a concern, with proposals for an Underground line to serve it a recurrent theme. While the residents of Bexley may not need an escape route, they should be provided with means of accessing jobs outside the Borough. 6.1435 As to the need to tackle deprivation by local action, the scheme is proposed as one of a number of measures, which also include those identified in chief by TfL in the regeneration evidence. But the scheme is an essential element of those. The scheme would benefit Bexley. Its importance to development opportunities in the Thames Gateway remains, even though the proposed discount area has been reduced. Traffic in Bexley 6.1436 Any increase in peak hour traffic flows in Pickford Lane between 2005 and the 2016 assessment year would not result from the scheme. Peak hour traffic flows there would be lower with the scheme in 2016 than without it. 6.1437 The scheme is not proposed to reduce congestion. Rather, it would provide more direct routes for some trips, and so allow time savings for some journeys that are currently difficult. Congestion in Bexley is forecast to
412
worsen with or without the scheme, and it is for Bexley Council to address that. In the area of most concern, traffic is forecast to lessen as a result of the scheme. Traffic model - reliability 6.1438 TfLs revised traffic prediction for Pickford Lane in the AM peak case substantially matches Mrs Browns own surveys, and so should be seen as an improvement over the Reference Case Model. 6.1439 TfLs modelled inter-peak flows for Pickford Lane in 2001 are for 542 vehicles per hour (sum of both directions), which closely matches Mrs Browns surveys. The inter-peak forecasts for Pickford Lane in 2016 show a very substantial reduction from 2001, which is principally a consequence of transfers between the parallel roads of Brampton Road, Pickford Lane and Belvedere Road. On each of this group of roads there would be a net reduction in traffic due to the scheme. Long distance traffic 6.1440 The scheme would not become a fast bypass for the M25 or an escape route. It would be a short link joining two relatively congested areas. Traffic speeds on the M25 would be much higher than they would be on local roads, and so diversion from the M25 to routes via the scheme would not be attractive (TfL/211). 6.1441 People would only choose to pay a high toll where they were afforded substantial journey time savings as a result. The high non-local tolls, double those at Dartford, would be enough at all times to deter people from using the scheme for through trips when the journey time saving would be very small. Experience from the M6 Toll road shows that routes chosen by heavy goods vehicles are very substantially affected by tolls (TfL/89). 6.1442 The information provided to Mrs Brown regarding closures of the Blackwall Tunnel was incorrect, in that the figures reported as Emergency Closures are in fact the number of police reports of incidents that would not necessarily involve closures. A record of closures due to incidents during 2005 is shown in Document TfL/289. Further details are given in Documents TfL/303, TfL/312, TfL/321 and TfL/322. On average, there are roughly two closures per month of the northbound tunnel and roughly one per month southbound. Half of the closures are for less than 20 minutes. About the same proportion result from broken down vehicles, and are likely to be spread throughout the day. Mr Brian Baker 6.1443 Mr Baker is a local resident who lives in Bexleyheath.
413
Use of the scheme by long distance traffic 6.1444 When a bridge at the site of the scheme was previously proposed, the then promoters expected it to be attractive to long distance through traffic, and so, at that time, a link from the bridge south to the A2 was proposed. The current proposal would build a bridge in exactly the same place, but would make no new connection to the A2, even though general traffic has increased since the previous scheme was promoted. This is difficult to understand. 6.1445 TfLs position, that current widening and strengthening works to the A2016/A206 route would provide a direct dual carriageway link to the southern end of the Dartford Crossing, is unsound. M25 traffic frequently queues back south from the Crossing so as to block direct access to the A2016/A206 route frequently extending to junction 2, sometimes to junction 3 and less frequently to junction 4. On such occasions, some M25 traffic would be likely to divert to use the scheme, approaching it via either the Black Prince A2/A220 intersection or the A2/A221 Danson interchange and local roads in Bexley such as Knee Hill and Brampton Road. Such rerouteing would be encouraged by the growing use of satellite navigation. Tolling would have no effect. Carrying some 20 million to 30 million vehicles each year as it would, the scheme would not be a local bridge. Combined traffic effect with Crossrail 6.1446 The proposed Crossrail terminus at Abbey Wood station would intensify traffic nearby. The flyover near the station would be demolished and rebuilt, linking to Knee Hill; a change that would also accommodate extra traffic associated with the scheme. The Mayors suggestion that a congestion charge should be introduced at Bexley illustrates his expectation that through traffic in Bexley will increase. Regeneration - training 6.1447 The reliance placed by TfL and some others on training as a way to equip local people for new jobs is unrealistic, since employers normally advertise for employees with experience as well as training. Staff with the required qualities would therefore be drawn from a very wide area. Local people would not benefit, and long distance commuting would increase as a result of the scheme. The construction workforce would be unlikely to be drawn from the local area; to do so would be contrary to normal practice in the industry. Other matters 6.1448 The scheme is associated with the Thames Gateway proposals to build extensively on a floodplain where treated water is in short supply. It is not intended merely to meet local needs. There is no need for the urban expansion proposed for the Thames Gateway.
414
6.1449 Alternatives, such as a scheme to replace the Woolwich Ferry with a bridge or a tunnel, should have been considered. Response by TfL 6.1450 No specific response was made by TfL to the objection of Mr Brian Baker. Mr Phil Hawkes 6.1451 Mr Hawkes is a local resident who lives in Bexleyheath. Use of the scheme by long distance traffic 6.1452 The scheme would increase traffic flows in the Borough of Bexley, providing a short cut to allow the rest of the country to cross the Thames a little more easily. Knee Hill 6.1453 The scheme would have an adverse effect on ancient woodland near Knee Hill. Public consultation 6.1454 Information regarding the traffic effects of the scheme in Bexley was not available at an exhibition arranged by TfL at St. Andrews Church Hall during 2004. Residents of the Borough have still not been given any definite information on the effects there of the scheme. Response by TfL 6.1455 No specific response was made by TfL to the objection of Mr Phil Hawkes. Mr Roger Butler 6.1456 Mr Butler is a local resident who lives in Bexleyheath. 6.1457 Should the bridge go ahead, pollution and congestion would increase. Peoples health would suffer. Property values would decrease. Those who could afford to move away would do so. Council revenues would fall. Roads and the foundations of some houses would deteriorate. There are no factual arguments for a bridge.
415
Traffic congestion 6.1458 The scheme would give rise to increased traffic congestion, contrary to the Mayors declared intention of reducing congestion. The problem of traffic flows south of the river has not been addressed. The response times of emergency services would increase. Response by TfL 6.1459 No specific response was made by TfL to the objection of Mr Roger Butler. Mr Dave Reynolds 6.1460 Mr Reynolds is a local resident who lives in Bexleyheath. Traffic Congestion 6.1461 Unlike the area to the north of the scheme, Bexley Borough has no Underground or DLR. Mainline rail services run east-west across the Borough, as do the majority of bus services. The road network in Bexley is also primarily east-west in orientation, providing radial routes to London broadly parallel to the River. 6.1462 Experience at the Dartford Crossing shows that, as the capacity of the river crossing increased, so did the traffic using it. Now the Dartford Crossing is often congested. Congestion at the Blackwall Tunnel has also increased over recent years. It is clear that cross river traffic would divert to the scheme, if it were available. This would give rise to a substantial extra demand for north-south transport in Bexley, necessarily largely by road or road-based public transport. The north-south roads in Bexley Knee Hill, Brampton Road, Long Lane, Erith Road and Gravel Hill are ordinary residential roads that could not cope with additional traffic. Traffic congestion would result, delaying road-based public transport. But the promoters claim the scheme would increase the use of public transport. Tolls - discount area 6.1463 The modification of the discount area proposed during the inquiry by TfL would remove from the residents likely to be most inconvenienced by the scheme those living in Bexley between the A206 and the A2 the benefit of cheaper tolls to cross the bridge. Given that residents many miles north of the scheme (where the road infrastructure is better than in Bexley) would continue to benefit from the discount area, this proposal is particularly perverse. If the bridge were built, then all Bexley residents should be allowed to benefit from discounted tolls.
416
Response by TfL 6.1464 No specific response was made by TfL to the objection of Mr Dave Reynolds. Mr Robert Watson 6.1465 Mr Watson is a local resident who lives in Bexleyheath. Use of the scheme by long distance traffic 6.1466 The scheme would open up a new route for through traffic, via Harrow Manorway, Knee Hill, Long Lane and Erith Road. The proposed toll would be ineffective in preventing the use of that route by traffic between the area north of the bridge and Bromley, Croydon or Orpington particularly when the Blackwall Tunnel and Dartford Crossing are congested. Tolls - discount area 6.1467 The revised discount area proposed by TfL would remove the small benefits for Bexley residents that the previously proposed discount area would have provided. Other matters 6.1468 The bridge was originally proposed as part of Ringway 3, a post-war orbital route that was not built. Subsequently, transport planning has recognised the induced traffic effect. The scheme is outdated and should not proceed. Rather, such public funds as are available should be spent on Crossrail, the GWT and the Kent Thameside Fastrack, a part-segregated, bus-based transport system in the Thames Gateway in Kent. Response by TfL 6.1469 No specific response was made by TfL to the objection of Mr Robert Watson. Mr Gordon Winbourne 6.1470 Mr Winbourne is an Architect, who lives in Surrey. Alternative proposal - River Tram Transit 6.1471 The scheme would concentrate cross river traffic at one point, creating traffic problems on either side. That disadvantage would be avoided if, instead, the River Tram Transit was available. This would consist of a number of vessels 50m long and of variable geometry, capable of carrying either 500 foot passengers or 9 HGVs or buses. They would ply between
417
purpose built roll-on roll-off landing stages distributed on either side of the river, potentially serving the area between the estuary and Teddington Lock. Mr Winbourne holds a patent for this multi operational multi mode urban ferry system, and has discussed a possible landing stage site with one riparian London Borough Council. He approached the Mayor of London about the River Tram Transit in 2001, and the Mayor requested further details including funding, proposed performance levels and the operation of the roll-on roll-off facilities. There is no prototype vessel. Tidal surge 6.1472 In the event that a severe surge tide arrived at the Thames Barrier and rebounded back downstream, the points of contact at ground level with the bridge might be flooded. Planning policy 6.1473 The case for the scheme is based on old, obsolete figures of population growth. Current Regional Planning Guidance is based on projections to 2016, whereas projections by the Office for National Statistics for the period to 2026 indicated further problems would arise; the current planning framework does not address the known problem. Response by TfL 6.1474 No specific response was made by TfL to the objection of Mr Gordon Winbourne. Mrs Brenda Caymen 6.1475 Mrs Caymen is a local resident who lives in Bexleyheath. 6.1476 The scheme would be likely to give rise to increased air pollution in Longleigh Lane, Bexleyheath. 6.1477 Public transport to the south of the river is not as good as that to the north, and should be improved. Response by TfL 6.1478 No specific response was made by TfL to the objection of Mrs Brenda Caymen.
418
Mrs Margaret Cowell Public consultation 6.1479 Consultation about the scheme should have been conducted in the DA15 Sidcup area, where Mrs Cowell lives, but was not. Traffic increase in Sidcup 6.1480 Traffic on the A222 Hurst Road and nearby is often heavy, and will get worse as a result of extra housing being built in the area. Noise, pollution and severance caused by traffic already cause difficulties for residents. It is not possible to sleep with the bedroom windows open, and it is not possible to work downstairs with the windows open. (Mrs Cowell works from home.) Traffic in the area would further increase if the scheme were built, as would the problems associated with traffic. Although Hurst Road is an A road, it is also a residential road. Site visit 6.1481 At the request of Mrs Cowell, I visited her home during the afternoon as part of my accompanied site visit of 4 May 2006. In the front room facing the A222, there was some traffic noise with the window open. In the downstairs room used by Mrs Cowell as an office, with the window closed there was no appreciable traffic noise. I found that there was more intrusive noise in the bedrooms of the property. There is a railway line at the bottom of the rear garden, some 60m from the rear faade of the house. There was some noise from traffic on the A222 in the rear garden, but at the end of the garden furthest away from the house (and therefore from the road) it was barely perceptible. Response by TfL 6.1482 No specific response was made by TfL to the objection of Mrs Margaret Cowell. Mrs Zo Harris 6.1483 Mrs Harris is a local resident who lives in Bexleyheath. Alternative proposal 6.1484 Improved river crossings in this part of London are to be welcomed, since they would shorten journeys between East London and South East London and improve conditions for residents. However, before a road crossing is considered, the current public transport proposals for the DLR extension, Crossrail, GWT and EWT should have time to bed in and prove their worth in
419
creating employment and regeneration in the area. Only then should a new road crossing be considered. Response by TfL 6.1485 No specific response was made by TfL to the objection of Mrs Zoe Harris. Mrs J Cowell 6.1486 Mrs Cowell lives at Sidcup. 6.1487 There is insufficient information about the scheme. Traffic in Bexley has already increased alarmingly, and the scheme would make that worse, adding more than 17% to traffic flows. Any benefit to employment as a result of the scheme would be short-lived. Pollution in Bexley would increase as a result of the scheme. Response by TfL 6.1488 No specific response was made by TfL to the objection of Mrs J Cowell. Mr and Mrs G R A Holt 6.1489 Mr and Mrs Holt are local residents who live in Bexleyheath. In August 2004, they received a letter from LB Bexley advising them of the planning application for the TGB which TfL had made to Greenwich, and inviting their comments. They made comments to Greenwich and to Bexley Council. Mr Holt also visited the exhibition regarding the planning application held in Bexley on 16 September 2004. Traffic concerns 6.1490 The feeder road to the TGB south of the river ends at the Thamesmead junction with the A2016, without any suitable road provision for access to the A2. 6.1491 Currently, the A2 at Bexley feeds traffic to and from the Dartford Crossing, and in the other direction the A2 feeds traffic to and from the Blackwall Tunnel. The road congestion at these crossings is substantial, and at certain times of the day the traffic is almost at a standstill. 6.1492 If the TGB is built, the general public and especially HGV drivers will soon realise that they can cross the Thames over the TGB without queuing at Dartford or Blackwall. 6.1493 Roads in Bexley such as Gravel Hill (A220), Upton Road, Danson Road
420
(A221), and Welling Way will become the A2 feeder roads to the TGB. Apart from Gravel Hill and Danson Road, these roads are not built to take heavy traffic. When these roads become choked with heavy traffic, drivers will start to search for shortcuts, which will mean that the small back roads of Bexley in this area would become rat runs. 6.1494 Most of these roads will ultimately lead to Woolwich Road (A206), and, to reach the TGB, traffic would then need to take roads like Knee Hill (A2041), Heron Hill, and Picardy Road (B250). These unsuitable roads in turn lead to Abbey Road (B213) and Harrow Manorway (A2041) and on to the TGB through Thamesmead. 6.1495 Increasing levels of traffic using these roads in Bexley would expose the public to increased levels of air pollution. 6.1496 TfL suggest that traffic modelling indicates that the roads in Bexley would be able to deal with traffic travelling to and from the bridge. Modelling, at best, provides only an approximation of the real impact. If modelling delivers an answer which is contrary to common sense, it should be disregarded. Anybody using common sense in this situation can see that, if another bridge across the River Thames is built, then traffic will use that bridge, and in a very short time roads leading from the A2 to the bridge would become as congested as the M25 and the A2. Response of TfL to the objection of Mr and Mrs Holt Traffic concerns 6.1497 There is no proposal for a link from the TGB to the A2. There is no national, regional or local policy which would support such a link. 6.1498 Apart from situations in which the Dartford Crossing or the Blackwall Tunnel was closed, there would be no incentive for through traffic to use the TGB. To do so would add to the time spent on the journey, and would involve the payment of a toll approximately double that which would be charged at Dartford. Blackwall is a free crossing. 6.1499 The TGB would result in a small increase in road traffic. Local traffic management measures, implemented before the opening of the bridge, would minimise the impact of these traffic increases. 6.1500 Modelling the traffic implications provides the best available advice or estimation as to the impact of the scheme. 6.1501 Even where there would be traffic increases, this would not lead to significant effects in terms of air pollution.
421
Mr and Mrs A Ruddell 6.1502 Mr and Mrs Ruddell are local residents who live in Bexleyheath. They have lived in Brampton Road for 35 years. During that time, traffic levels have increased considerably and disproportionately as a result of the expansion of Thamesmead; the widening and strengthening of Brampton Road rail bridge to accommodate multi-axle lorries; changed priorities, with the addition of roundabouts, making the road even more accessible to traffic; the addition of new swimming pools to the leisure centre at Crook Log; and the traffic curbing measures introduced to residential side streets which run off Brampton Road. Brampton Road is, however, home to a primary school, close to Mr and Mrs Ruddells house. Traffic congestion 6.1503 The TGB would cause traffic congestion on Harrow Manorway, Brampton Road, Knee Hill and Danson Road. Traffic on Brampton Road is already relentless. Brampton Road would be on the most direct route between the TGB and the A2 if the bridge were built, and thousands of extra vehicles would therefore seek to use the road. Like Knee Hill, Brampton Road is a single carriageway road, but Brampton Road is also a residential road. 6.1504 Unlike Knee Hill and Danson Road, Brampton Road is not an A road or even a B road. It was not designed as a main thoroughfare. 6.1505 If the TGB were built, many drivers would use it in preference to the Blackwall Tunnel or the Dartford Crossing to cross the Thames. 6.1506 When the ELRC was put forward many years ago, it was considered necessary to have a six lane motorway connecting the bridge to the A2. Yet now, nothing at all is proposed, even though there have been vast increases in traffic volumes in the intervening period. A strategic link rather than a local bridge 6.1507 Inevitably, the TGB would become a strategic national link, just like all the other road bridges across the Thames in London. Tolls would make no difference to the status and use of the bridge. Tolls do not remove demand at Dartford. Public consultation 6.1508 Local residents were not consulted about the proposal to build a bridge without any provision to deal with the traffic from it on the south side of the river. Traffic management measures 6.1509 TfL expect local residents to wait until after the bridge is built and the
422
impact of additional vehicles is felt before deciding what road management measures may be required. Environmental damage 6.1510 It is necessary for the windows of properties in Brampton Road to be kept closed, but even then residents can hear the sound of traffic in every room in their houses and in their back gardens. 6.1511 A bridge would cause breaches of UK and EU air quality limits. Bexley already has the highest childhood asthma rates of any London Borough. Site visit 6.1512 At the request of Mr Ruddell, I visited his home during the afternoon as part of my accompanied site visit of 4 May 2006. With the windows of the property closed, I could detect a very slight traffic noise inside the house. With the windows open, the noise was more noticeable. The property is double glazed. There was audible traffic noise in the rear garden of the house, but not sufficient to prevent enjoyment of the garden in my view. Response by TfL to the objection of Mr and Mrs Ruddell Traffic congestion 6.1513 Brampton Road is classified as a London Distributor Road, one which is described in the Bexley UDP as providing for through traffic movements and links to strategic roads. There would be major changes in traffic flow along Brampton Road by 2016 with or without the TGB. In fact, the TGB would deliver a slight reduction in traffic flow in the part of Brampton Road in which Mr and Mrs Ruddells property is situated. A strategic route or a local road 6.1514 TfL have no intention that the TGB should become a strategic national link. There is no national, regional or local policy support for such a proposal. The analysis conducted by Halcrows, who are expert in traffic forecasting, demonstrates that the tolling strategy which would be applied by TfL would be successful in deterring through traffic from using the TGB. Public consultation 6.1515 Public consultation was carried out in relation to the Mayors Transport Strategy and the London Plan. Specific public consultation on the TGB scheme was carried out prior to the submission of the planning applications. This included the delivery of a leaflet to Mr and Mrs Ruddells address. They have, in any event, had an opportunity to present their objections to the scheme to the inquiry.
423
Traffic management measures 6.1516 The proposed mitigation measures to be carried out in (amongst other roads) Brampton Road would be implemented prior to the opening of the TGB. They could include enhanced crossing facilities, traffic calming and lower speed limits. Environmental damage 6.1517 In the section of Brampton Road where Mr and Mrs Ruddell live, the predicted change in traffic noise levels with the TGB would offer them a reduction in noise level of between 3dB and 1dB. The prediction of change in air quality is for a 0.2% increase in concentrations of particulates. This is not a significant change. Mr Paul Berry 6.1518 At the time he made his objection to the scheme, Mr Berry was a local resident, living in Thamesmead. Before the close of the inquiry, he had moved (still locally) to Bexleyheath. The house in Thamesmead in which Mr Berry used to live would be very close to the route of the TGB, as the road from the bridge would join Eastern Way (A2106) close to Birchmere Park. When the property was purchased in 2002, Mr Berry states that no indication of the safeguarding of the land for the TGB scheme was given in response to his Solicitors local search. It was only after completion of the purchase that Mr Berry discovered the road widening and TGB proposals. 6.1519 Mr Berry therefore complains that Greenwich did not deal properly with the reply to his local search. I indicated that in my view this was not a material consideration in relation to the merits or otherwise of the TGB scheme, but I promised to attach Mr Berrys submissions on the issue to my report. They are contained within pages 3 to 14 of Document 340/1/A1/2, Appendices 2 to 38 of Document 340/1/B, pages 1 and 2 of Document 340/3, and pages 1 to 4 of Document 340/4. 6.1520 Mr Berry has other complaints regarding developments which took place in the immediate area of his former house at Thamesmead. They are also dealt with in the Documents mentioned above. Again, however, in my view they do not relate to the merits or otherwise of the TGB scheme. Public consultation 6.1521 TfL have held no public meeting for local residents who would be most affected by the TGB proposal. People living in Thamesmead and Newham have not been given a choice of different transport schemes that could provide the improved access to jobs and services that the areas need. 6.1522 The publicity material put out by TfL was unbalanced, in that it made no reference to increases in pollution levels and traffic levels. It did not
424
provide an environmental assessment. Most of the exhibitions which were held in relation to the scheme took place between 9am and 5pm, which excluded people who were working at those times. 6.1523 One of the items available at the exhibitions was a computer simulation of a vehicle driving along the bridge. A copy of that is available accompanying Document TfL/318. Document TfL/318 indicates that the simulation gives a reasonable indication of the proximity of the proposed bridge and its viaducts to existing buildings, but identifies a few minor changes which have taken place to the scheme since the flythrough was prepared. Human rights 6.1524 Newham, Greenwich and TfL have breached the human rights of people living near the proposed TGB. Local residents should have been made aware of a new safeguarding direction issued by the Secretary of State on 4 May 2001 (Document 340/1/B Appendix 30). The building of the bridge and associated road works would increase levels of noise and air pollution in the area. This would interfere with the private and family life of those residents, and the residents should therefore have been advised about it in writing. Availability of documents 6.1525 Certain documents in connection with the bridge planning applications were deposited at local libraries, but on two occasions staff at the local library were not aware where those documents were kept. 6.1526 The core inquiry documents were deposited in Central London, at some distance from the proposed development, and were available only during limited hours which were not convenient for people with working or caring responsibilities. If the TGB is a local bridge for local people, the core documents should have been held locally. Compliance with policy 6.1527 The Mayors Transport Strategy has a number of objectives: a. To improve the quality of life - If the TGB is built, residents quality of life would be reduced by sleepless nights because of traffic noise, and their health would be worsened by pollution. b. To promote economic development If the TGB is built, people on higher incomes would move out of the areas through which traffic would run, removing spending power from the local economy. c. To bring derelict sites back into use This could be achieved in a variety of ways without building a bridge.
425
d. To promote social inclusion and equality of opportunity If people with more disposable income move out of the area, this could lead to social exclusion. e. To improve and protect the environment The TGB would have the opposite effect. f. To promote walking and cycling The TGB would start in the middle of nowhere and end in the middle of nowhere. It would not offer a route to any place of interest. It would be neither a pleasant walk nor a pleasant cycle ride. 6.1528 The Greenwich Local Implementation Plan (LIP) response to the Mayors Transport Strategy suggests that the LIP will have among its aims improving bus journey times and reliability and relieving congestion and reducing car use. Both of these aims would not be assisted by the increase in traffic on local roads which would arise from the building of the TGB. Pollution 6.1529 An Environmental Search report in the area of Eastern Way, Thamesmead carried out in September 2002 showed that nitrogen dioxide, particulates and lead were already at moderate to poor levels (Document 340/1/B Appendix 66). These would be increased if the TGB were built. This is contrary to the policies of Greenwich Council, which claim that the Council is planning for a better future, with the UKs first Low Emission Zone (Document 340/1/B Appendix 72). Road issues 6.1530 Thamesmead is a new town. Most of the houses are built in culs de sac off the main roads. Those main roads are predicted to take considerable increases in traffic. The TGB would therefore make access to and from the residential roads of Thamesmead more difficult. 6.1531 The traffic consultants who acted for Greenwich pointed out that bus movements had not been properly included in the traffic model; that the bridge approach would be over capacity with any more traffic in 2016 than the 25% sensitivity test applied; that A2041 Harrow Manorway would be over capacity in 2016 with or without the bridge; that flows on Woolwich Church Street and Beresford Street would be at capacity with the bridge and near capacity without it; and that there would be unacceptably high queue lengths at Pettman Crescent in 2016 both with and without the bridge. 6.1532 During construction of the TGB, local diversions and lane closures would be needed along Eastern Way (A2106). But this is a road with no hard shoulder and with many roundabouts and traffic lights. The construction period would see much congestion and potential interference with an
426
important route for emergency vehicles. Journey times 6.1533 TfL state in their Interim Technical Summary that it is possible to travel from Erith to Woolwich by car in rush hour in about 9 minutes. This was attempted by Mr Berry on 27 July 2005. A recording of the whole journey is contained on a DVD recording (340/1/B1). It took 24 minutes on a day when traffic was lighter than usual because some schools had already closed for the summer holidays. 6.1534 TfL accept that this journey would take longer if the TGB were built. They say it would then take 12 minutes. This would be just as inaccurate as their original estimate. If TfL have underestimated congestion, they will also clearly have underestimated pollution. Blackwall Tunnel 6.1535 The Blackwall Tunnel is the worst traffic hotspot in London. TfL should address that before increasing traffic in the area by building the TGB. Charging a toll for using the Blackwall Tunnel would reduce demand by encouraging people to use public transport instead. Tolling 6.1536 A toll of 2 on the TGB would not be a deterrent, however, to long distance through traffic. 6.1537 Motorbikes should be charged for using the TGB at the same rate as cars. They generally make more noise than cars. 6.1538 Local vehicles should be allowed to use the TGB free of charge. Economic benefits 6.1539 No attempt has been made to balance the claimed economic gains against the long term detrimental effects of the proposed bridge. Any benefits available could be better obtained by creating jobs near to where people live. Mitigation 6.1540 The only mitigation which would have any appreciable benefit for houses near the bridge in Thamesmead would be not to build the bridge.
427
Impact of related developments 6.1541 The impact of the traffic which would be generated by the Crossrail proposal should be looked at alongside the traffic forecasts for the TGB. If both developments proceed, this would have serious implications for the level of congestion affecting Abbey Wood. 6.1542 At the same time, the Strategic Rail Authority plan to reduce trains on the Sidcup Lines. This is likely to increase car use in the area. LCY has ambitious plans to increase passenger numbers. The achievement of these would also increase car use to and from the airport. 6.1543 Plans to build a 140 megawatt combined heat and power generating plant at Purland Road, Thamesmead, together with plans for a new Belvedere Incinerator would add to the pollution in the area already caused by Crossness Sewage Works. Again, regard should be had to the impact of these developments alongside the impact of the proposed TGB. Response by TfL to the objection of Mr Paul Berry Public consultation 6.1544 Public consultation was conducted through the planning process in relation to the Mayors Transport Strategy and the London Plan. Specific public consultation on the TGB scheme prior to submission of the main planning applications was carried out between 13 May and 12 August 2003. Roadshows were held at twelve locations for a total of twenty eight days. The dates were publicised through advertising in the local press, on posters displayed in local Tube stations and bus shelters, and via the flyer, which was distributed to 460,000 homes and businesses across the area. 6.1545 In planning the roadshow dates, times and locations, TfL tried to arrange times which allowed for as many people as possible to visit the roadshows. Some extended into the early evening, and some were held at weekends. 6.1546 The material on display at the roadshows indicated that the TGB would join existing dual carriageways on the north and south side of the proposed bridge. There was also a panel providing details of how the bridge would affect the local environment. This indicated that TfL were conducting a detailed Environmental Impact Assessment, and promised that this would be made available as soon as it was completed. 6.1547 The interim Environmental Impact Assessment was in fact made available not only to stakeholders, but published on TfLs website three months before submission of the planning applications. This goes beyond the requirements of the 1999 Environmental Impact Assessment Regulations. TfL are unaware of any major infrastructure proposal in the London area where the full ES has been made available at the stage of preliminary public consultation.
428
6.1548 In relation to the offering of a choice of types of river crossing, it must be acknowledged that the TGB had gone through public consultation in relation to both the London Plan and the Greenwich UDP. The TGB would be part of a package of river crossings, some of which are dedicated entirely to public transport. Human rights 6.1549 Mr Berry received sufficient advance information about the proposed project to enable him to object to the planning applications and the Orders, and to enable him to appear before the inquiry. Mr Berrys rights under the European Convention on Human Rights with regard to respect for his private and family life and the protection of his property are protected by the procedures which are required under statute to be carried out before the proposed works can be authorised. Those procedures have been fully complied with by TfL, and include Mr Berrys right to call evidence and make representations at the inquiry. Compliance with policy 6.1550 The list of objectives quoted by Mr Berry is not to be found in the Mayors Transport Strategy. Apart from the last objective, it appears to have been taken from the Consultation Draft of Greenwichs LIP, where these objectives are stated to be overarching objectives for Greenwich. 6.1551 TfL consider that the TGB would support achievement of these objectives. It would assist in the promotion of economic development and help in the maximisation of the use of brownfield land in East London. It would help improve social inclusion, equality and quality of life by supporting increased housing and employment opportunities in the area. Whilst the bridge would cause some minor adverse local environmental effects, by assisting regeneration within East London it would support overall sustainability and environmental improvement by encouraging growth to take place within the urban area, avoiding the spreading out of development into surrounding regions, which would generate a higher share of travel by car. Pollution 6.1552 Details of the various impacts of the scheme are included within the ES. Evidence from TfLs expert witnesses has indicated that changes to air quality and noise would constitute only minor adverse impacts. Road issues 6.1553 The exclusion of buses on the carriageway in the model is not significant. The modelling for the scheme includes full modal split, changes in home/job distribution as a result of the TGB and trip generation.
429
Journey times 6.1554 The journey time estimates between Erith and Woolwich were included in the TGB Interim Technical Summary published in June 2003. These forecasts were based on interim results from the traffic modelling undertaken at that time using an interim traffic model which provided forecasts for 2011. Subsequently, the more detailed Local TGX Traffic Model was developed, specifically to assess the TGB scheme. It was constructed in accordance with guidelines issued by the DfT. This model was the basis for the traffic forecasts produced for 2016, which were reported in the full Traffic and Transport Report published in July 2004 (Document D838). 6.1555 The current model estimates the without bridge journey times between Erith and Woolwich to be twenty two minutes in 2016 during the morning peak. This is not particularly different from the twenty four minutes actual journey time recorded by Mr Berry on 27 July 2005. Blackwall Tunnel 6.1556 According to TfL traffic surveys, traffic in the Blackwall Tunnel was approximately 92,000 vehicles per day in 2002. This is some 60% higher than the equivalent daily flow on the TGB forecast in 2016. 6.1557 Mr Berry suggests that tolls should be introduced on the Blackwall Tunnel to encourage modal shift as well as negating the need for the TGB. However, it is difficult to see how introducing tolls at Blackwall would provide the impetus for regeneration needed in the Thames Gateway area, since tolling the Blackwall Tunnel would decrease rather than increasing accessibility into the deprived areas on both sides of the river. 6.1558 Tolling the Blackwall Tunnel would also be likely to result in traffic diversion away from Blackwall, and a consequential increase in traffic levels in the Bexley area, as traffic would seek alternative routes, particularly via the Dartford Crossing. Tolling 6.1559 Under current proposals, the toll charge would actually be 3 for cars from outside the local area. 6.1560 The Toll Order allows for motor cycles to be liable to pay the tolls. At this stage, no decision on exemptions has been made. It is envisaged that a range of exemptions would be allowed, however, and these would be likely to include motor cycles. A decision on that matter would be taken nearer to the date of the bridge opening. 6.1561 As regards the suggestion that people living nearest to the scheme should
430
be exempt from paying the toll, this would be neither affordable nor would it provide TfL with the flexibility to manage traffic in order to ensure free flow conditions were maintained on the bridge. In the morning peak, approximately 75% of cars using the bridge would be local. If they were allowed to use the bridge without charge, there would be substantially more traffic attracted to the bridge, which would create congestion in the local road networks. Mr David Black 6.1562 Mr David Black is a local resident who lives at Welling. He appeared as an objector at the 1990/91 ELRC inquiry, and was one of the nine local people who sought to challenge the Governments decision taken following that inquiry in the Courts. That action was withdrawn before the appeal was heard in the Court of Appeal, after the Government decided to withdraw the ELRC scheme in July 1993 and the powers under the made Compulsory Purchase Orders lapsed in 1994. TfLs suggestion that there was one legal challenge from Greenwich and another from the European Commission is over simplistic and therefore incorrect. Further details about the history of the objection to ELRC and the course of the High Court challenge are contained in Documents 1944/1/C, 1944/1/B and 1944/1/D, which should be read in that order. Historical perspective 6.1563 ELRC was the precursor of the TGB. The TGB would follow the same line from the A13/A406 north of the Thames to the A2016 in Thamesmead. It is now put forward as a shortened scheme, but the shortening would only be temporary. There would inevitably be pressure, once the TGB was built, to extend the route to join up with the A2. The proposed TGB would be a direct extension of the A406 from the A13 to the A2016. It is difficult to see how its nature and function can be separated from that of the A406. The TGB and traffic generation 6.1564 Developers of major road schemes rely heavily on traffic forecasts to promote road projects at public inquiries. These are then used to produce a cost benefit analysis, which places a value on time savings, often of only a few seconds, but multiplied by millions of trips, to justify a financial case for the road proposal. 6.1565 Traffic forecasts are, however, only predictions. They are not factual. If the forecasts of traffic generated by the TGB proved to be under estimates, and if the tolls proposed to be charged on the TGB failed to regulate traffic, the result would be varying degrees of chaos on the local road network. 6.1566 Transport strategy and planning logic indicate that the TGB would be extended to the A2. It is part of the C Ring envisaged in the Greater London Plan of 1944. TfL say that there is no policy backing for such a link
431
in current planning policy documents, but that assertion has no legal significance. Such documents can be changed. If that happened, the link to the A2 would either raise again the issue of adopting the ELRC line for the link, (which would severely disrupt the community of Plumstead; destroy a large area of public gardens, open space and community trust farmland; and impact on Oxleas Woodlands SSSI), or, alternatively, it would involve traffic running through Bexley via Knee Hill, Brampton Road and Danson Road to the A2 at the Danson Interchange. This would also involve considerable destruction of property, and affect the Lesnes Abbey/Bostall Woods ancient woodlands, sections of which have been designated as an SSSI because of its geological significance and the rare fossils found there. In the meantime, the bridge would be connected to the major trunk road network north of the Thames, and would be perceived by drivers as a serviceable link to or from the A2 south of the Thames. 6.1567 The SACTRA report of 1994 confirmed that new road capacity generates traffic, and this was accepted in the Transport White Paper of 1998. 6.1568 By increasing road space through the TGB, TfL would create competition for the DLR crossing at Woolwich, increasing journey costs for both modes. The possible link between Silvertown and Greenwich would have a similar impact on the Jubilee Line. Where public transport links already exist, it is illogical to provide additional road space in the vicinity, because competing modes would increase the cost of travel. 6.1569 The new traffic analysis presented by TfL during the inquiry underlines the fact that traffic forecasts are unreliable. They are based on computer models of virtual traffic flows, and do not necessarily correspond with reality. Local residents are well aware of current problems on link roads and junctions. They know where congestion and accidents would occur in the future. They appreciate which junctions would become clogged and where jams would occur. This local knowledge has a closer correspondence to reality than traffic forecasts. 6.1570 Traffic increases of 36% are predicted across the Bexley screenline; 14% of this would be as a result of the TGB. That 14% is predicted to reduce to 7% as a result of the revised tolling strategy. TfLs approach is, effectively, to endorse the predicted increases on the local road network, and to permit an increase in the volume of traffic by constructing the TGB. That approach and attitude is regressive. But the strategy of containing traffic increases by revising the tolling regime is dependent on the reliability of the traffic flow predictions. The forecasts for Bexley from 2001 to 2005 are now accepted as having been unreliable. The estimates for 2016, with or without the TGB, must be treated with extreme caution, as should the efficacy of a revised tolling regime to contain increased flows. The TGB and regeneration 6.1571 As SACTRA pointed out in 1994, there is no firm evidence of the claimed regenerative effect of new roads. TfL argue the case for a link between
432
accessibility and growth in population and what they refer to as potential employment. But many other variables come into play, including the wider economic situation and the availability of sites. Moreover, if additional jobs were created, there is no guarantee that they would be suitable for the skills of the local workforce, or that local people would be recruited by the employers. If the TGB is built, it is likely that many jobs would be taken by people travelling from further afield by car. Accessibility is just one factor involved in generating development. 6.1572 The regeneration case put forward in support of the TGB is critical to the validity of the project. The new traffic evidence produced by TfL has led to a review of the regeneration evidence. This accepts that the claimed regeneration benefits would reduce. The original increase in potential employment claimed for the scheme of between 32,900 and 41,000 without Crossrail and between 44,000 and 55,600 with Crossrail has been downgraded to the range 24,800 to 30,700 without Crossrail and 33,500 to 41,900 with Crossrail. In Bexley, the figures are now 0 500 without Crossrail and 2,800 to 4,100 with Crossrail. 6.1573 These figures are produced by a modelling approach which, it is claimed, is derived from an identified mathematical relationship between observed levels of accessibility, employment and population density in London. Accessibility is defined as the average number of people and jobs that can be reached within 45 minutes by road and public transport in 2001. Yet the ten Boroughs chosen to illustrate relationships between accessibility and the indices of multiple deprivation produce anomalies in the cases of Bexley, Newham and Richmond. A causal relationship has not been established between improving accessibility and creating potential employment or increasing population density. 6.1574 In fact, research by Colin Buchanan and Partners, on which TfL purport to rely, indicates that rail public transport accessibility seems to be the best determinant of employment density, and highway access has little relevance (Document TfL/P/05/3 Appendix 9, page 7-1) the same Document suggests (at page 2-4) that if labour supply is not a constraint, then improved access to labour is unlikely to add to the number of jobs. 6.1575 TfLs claim that the TGB is a key infrastructure development in improving the attractiveness of the Thames Gateway area and enabling investors to unlock the opportunities for investment which exist in the area is an assertion rather than a proven fact. The evidence provided is speculative, in that causal links are not established. The equation in which the provision of improved access will lead to increases in potential employment and population densities, which in turn will mean more jobs and more people, has not been established. Environmental impact 6.1576 An Environmental Impact Assessment of alternative modes or options is essential, so that environmental considerations are at the heart of the
433
decision making process, and not added on after a preferred course of action has already been chosen. 6.1577 The environmental appraisal for the TGB project is defective. Air quality is poor, and noise levels are high in East London, so that policies and projects should be concerned with improving this situation. The impact of the TGB would be to exacerbate present negative trends. A rail link would not suffer from this defect. 6.1578 The re-based traffic model estimates that there would be very small differences in the number of vehicle kilometres which would not materially change the conclusions of the ES that the scheme would not have a significant impact on the UKs overall pollution burden. But the production of negligible amounts of greenhouse gases must become in total at some point a contribution that ceases to be negligible, locally, nationally and globally. 6.1579 The general assessment of air quality depends entirely upon the reliability of the traffic forecasts. Failure to produce reliable estimates for traffic flows would be reflected in the emissions profile. The assessment assumes that the predicted increases in traffic flows are acceptable and manageable. The intention of TfL is not to reduce traffic volumes and emissions, but to allow them to increase. In effect, the line is taken that, because air quality is poor and likely to remain so in 2016, a further minor deterioration would not make much difference. However, the Mayor of Londons Air Quality Strategy requires a significant reduction in air pollution emanating from car emissions, by reducing traffic volumes and individual car emissions. The TGB project is not in keeping with those stated objectives. 6.1580 Noise is also detrimental to human health. The noise and vibration analysis, like the air quality assessment, is dependent upon the traffic forecasts. If the traffic forecasts prove to be unreliable, again there could be no confidence in the noise and vibration analysis. 6.1581 The results of the noise analysis assume that people become accustomed to increases in noise, which, over time, would cease to worry them. This approach may be accepted methodology, but it does not take account of normal human variation in the range of individual sensitivity to noise. Some individuals who are more sensitive to disturbance would not adjust to noise increases in their surroundings. 6.1582 The environmental impact of the TGB would be adverse. TfL have assessed this as minor, but in view of the unreliability of the traffic forecasts, it would be unwise to rely on this assessment. 6.1583 The detrimental impact of the TGB in terms of nature conservation and biological diversity is also described as minor adverse and acceptable for a major road scheme. But the scheme would offer a threat to native species of importance like the water vole, pipistrelle and noctule bats, the
434
grass snake, the palmate and smooth newts, and various invertebrates, together with the disturbance of the teal population. These are distinctly adverse environmental impacts. Moreover, it is only by temporarily decoupling the TGB from the inevitable onward link to the A2 that TfL are able to claim that the TGB project would not affect sites of national importance such as the SSSIs at Lesnes Abbey/Bostall Woods or Oxleas Woodlands. Public transport alternatives 6.1584 The proposal for a crossing at Gallions Reach does not permit a choice amongst alternative modes. No case has been made for the superiority of the TGB in comparison with a rail link to serve the needs of East London. No figures are available for light and heavy rail crossings, specifically to measure the environmental impact, the effects on traffic flows locally and further afield, the effects upon other public transport systems, and the reductions in journey times, in order to calculate an appropriate NPV for such schemes. 6.1585 The only existing public transport crossing in the Thames Gateway area is the Jubilee Line Extension between North Greenwich and Canning Town. A bus service exists via the Blackwall Tunnel. There is no main or minor public transport crossing to the east of the Blackwall Tunnel. The Thames Gateway is crying out for improved public transport, preferably via a major Thames rail crossing. The case for a heavy rail link has not been properly assessed or presented for public consultation. The DLR extension at Woolwich lies close to the northern approach to the proposed TGB. It could cross the river at that site, to reach Thamesmead and points south. 6.1586 Time savings have been used to justify the TGB project, but no comparative study has been made for rail links. The project has been justified by a cost benefit analysis based on the monetary value attributed to savings in journey times calculated from traffic forecasts. Heavy and light rail schemes have been rejected on cost grounds, but, unlike the TGB, no detailed analysis of journey times, environmental impact and NPV has been provided for public consultation. The assertion of TfL is all that is available. 6.1587 TfL have made only one attempt to analyse a public transport alternative to the TGB, a rail crossing at or near Gallions Reach. This was made in response to evidence from Mr Keith Buchan, and it is contained in Document TfL/REB/4982/1 Annex 5. This represents only a brief analysis, and does not permit a detailed comparison with the TGB proposal. TfL concede, however, that demand could be 25% higher than that for the TGB. The appraisal period is thirty years, and the benefit:cost ratio is given as between 1.3 and 1.5 to 1. The analysis does not appear to allow adequately for modal shift to rail; there would be no overall loss of public transport users to the TGB; and in the absence of a road crossing, it seems likely that demand for the DLR would be higher. Over a sixty year appraisal period, the benefit:cost ratio might well exceed 2 to 1.
435
6.1588 The analysis contained in Annex 5 of Document TfL/REB/4982/1 was produced belatedly, in response to Mr Buchan, not as a result of a project appraisal carried out before the preferred option was chosen. Unit 3.2 of WebTag indicates that a single separate page should be provided for all rejected options, explaining why they were rejected. It should be prepared at the stage of making a final choice between alternative strategies or plans. A complete description of the rejected options and their appraisals should be included in the supporting documentation. Unit 3.3 indicates that the assessment and subsequent appraisal should be undertaken at a level of detail sufficient to compare options and inform decisions. 6.1589 Appraisals may have moved on since the days of the ELRC inquiries, but this is of little value if the appropriate guidance is not followed. A decision on the TGB project should not be made before public transport alternatives have been properly assessed and the assessments have been made available for public scrutiny. The Appraisal Summary Table 6.1590 The following assessments in the AST are questioned: a. Heritage and historic resource - It is not clear how the impact can be assessed as slightly adverse when the issue being addressed is the potential disturbance of remains which have not yet been discovered. b. Biodiversity - A permanent loss of valuable habitat might be better assessed as moderately adverse. c. Accidents - This is assessed quantitatively, but should also be assessed qualitatively as adverse. d. Reliability - This has been assessed as moderately beneficial, but this does not allow for adverse impacts as a result of unreliable traffic forecasts, induced traffic and failure of the tolling regime to control traffic flows. e. Wider economic impacts - These have been assessed as strongly beneficial, but it has not been proven that jobs would be available or suitable for local people. The TGB cannot be regarded as highly beneficial when the alleged benefits are theoretical and not empirically substantiated. The impact would not be strongly beneficial in Bexley. f. Access to the transport system - This is assessed as neutral, but that judgement does not appear to take into account non local traffic or induced traffic using the TGB and local road networks. g. Lands use policy - The assessment under this head of strong beneficial does not take into account the encouragement to use cars and other
436
private vehicles, induced by the TGB, or the stimulus to travel, which is negative in terms of transport policy. Overall 6.1591 The TGB proposal is not consistent with the provisions of the London Plan. It would worsen conditions under a number of the criteria listed in Policy 3C.15. It cannot be said that the benefits of the proposal would be substantial, because the regeneration case for the TGB is weak. The proposal is not consistent with Policy 3C.16 in that construction of the TGB would impede the reduction of traffic growth in the affected Boroughs. It is in conflict with Policy 3D.12 because it has not been established that the benefits of the TGB would outweigh the significant harm to the nature conservation value of sites which would result from its construction. 6.1592 The TGB proposal is not consistent with the guidance given in PPG13, because it would generate traffic rather than reducing the need to travel and reducing the use of the car. It would facilitate long distance car and goods vehicle trips, rather than promoting more sustainable transport choices both for people and for moving freight. 6.1593 The TGB would have an adverse environmental impact on air quality and ambient noise levels, while contributing to global warming. 6.1594 The proposal is in conflict with guidance on nature conservation because its impact would be detrimental in ecological terms. It would represent a potential threat to species of national and international significance, and there would be a failure to provide replacement habitat of equal area and advantage. 6.1595 The planning applications should be refused. Response by TfL to the objection of Mr David Black Historical perspective 6.1596 While the TGB would follow the same line as ELRC from the A13/A406 to the A2016 in Thamesmead, there is no local, regional or national basis in planning policy to support the extension of the TGB scheme to the A2. The statutory safeguarding of the route of that extension has long been abandoned. Properties once purchased to accommodate the scheme have been disposed of. In order now to provide for any extension of the TGB to the A2, large numbers of properties would need to be acquired. Any proposed extension would also be subject to in depth public scrutiny, because of the need for applications for consent, which would inevitably include a public inquiry. 6.1597 Mr Black has submitted no evidence to demonstrate that proposals would be brought forward to create a new or improved road linking the TGB to the
437
A2. The TGB and traffic generation 6.1598 Mr Black asserts that the traffic forecasts are unreliable, but he offers no evidence to support this opinion. TfL have undertaken an analysis of traffic based on best practice in accordance with Government guidance. The modelling and appraisal methodology have been signed off by the DfT as being fit for purpose. This was confirmed in a letter sent by the Government Office for London in January 2004 to TfL. A copy of that letter is contained in Appendix 2 to Document TfL/P/04/4. 6.1599 Mr Black claims that the TGB would carry additional longer distance traffic over and above the level of traffic forecast by TfL. This ignores the planned use and flexibility of the tolling regime, which has been developed to control flows across the TGB, and to discriminate against longer distance through traffic in favour of local traffic, in order to meet the regeneration objectives of the scheme. If, as Mr Black fears, the traffic forecasts turn out to be inaccurate, then the tolling regime could be adapted to manage traffic to sustainable levels. 6.1600 Mr Black ignores mitigation measures associated with the scheme, for which legal provision is made in the Boroughs Agreement and the Unilateral Undertaking. 6.1601 In relation to SACTRAs view in 1994 that roads generate traffic, it should be borne in mind that this scheme is about regeneration and is not a congestion relief scheme. The final SACTRA report, which was published in 1999, is more measured in its conclusions concerning the effect of new transport infrastructure on traffic. TfL believe that the modelling methodology applied to the TGB includes the main impacts of new infrastructure, from simple reassignment between alternative routes, through changes in mode choice, to more fundamental changes in the pattern of traffic as people choose different employment or home locations to take advantage of new infrastructure. 6.1602 TfLs approach is not to endorse predicted increases in traffic on the local road network, but to accept that current trends (in Bexley at least) are going in that direction. TfL welcome progress in containing or reducing traffic growth. The TGB providing for distinct local benefits is not inconsistent with that policy. 6.1603 TfL are seeking to reduce traffic growth overall, but do not consider that this means that local cross river access cannot continue to be improved. 6.1604 The traffic model in its revised form is robust, and traffic flows will be controlled using the tolling regime.
438
The TGB and regeneration 6.1605 Apart from TfLs own evidence, the latest analysis of the question whether investment in transport will contribute to regeneration in the Thames Gateway is contained in a report by Atkins Transport and Development in the Thames Gateway. This report summarises various recent analyses, and concludes that, collectively, these studies show that transport investment is a necessary, if not sufficient, agent for growth, and in the Thames Gateway can be expected to contribute to sustainable communities, economic regeneration and transport and economic efficiency. The document comprises Appendix 18 to Document 1752/1/B. 6.1606 While SACTRA advise that caution is necessary in drawing conclusions in relation to social and economic benefits accruing from new infrastructure, the link is not ruled out. Environmental impact 6.1607 There is no proposal to extend the TGB south of the A2016 Western/Eastern Way. It is therefore not the case that land would need to be taken from Lesnes Abbey/Bostall Woods or from Oxleas Woodlands. 6.1608 Mr Black makes reference to the Mayors Air Quality Strategy, and quotes what he says are objectives of the Strategy, which he claims would not be met by the TGB. Mr Black provides no reference as to where in the Strategy the objectives are expressed in the way he sets them out. The objectives of the Strategy are actually set out in chapter 3 of that document. They are supplemented by 87 proposals to minimise the adverse effects of air pollution on human health, the majority concerned with minimising road traffic emissions. The TGB is in keeping with the actual objectives of the Mayors Air Quality Strategy, and it is a statutory requirement on the Mayor to ensure consistency between his various strategies. 6.1609 TfL propose to provide noise barriers in appropriate locations along the scheme corridor, and to use low noise road surfacing. The noise effects of the scheme in the long term would be minimal, and should prove acceptable to the majority of residents in the surrounding area. Public transport alternatives 6.1610 Mr Black criticises TfL for not considering heavy and light rail bridge crossings as alternatives to TfLs preferred scheme. This is not the case. TfLs Assessment of Public Transport Options is contained in Document TfL/REB/2703/2. It includes an assessment of a light rail option compared to bus transits. The analysis indicates that passenger demand would be insufficient to justify the significant additional cost of this option. 6.1611 In addition, TfL also assessed the feasibility of running the DLR over the TGB. The DLR had a worse business case compared to bus transit, as it
439
would cost an additional 50m. Given the poor business case for light rail and DLR options, heavy rail would represent an even worse option because of the additional costs. Quite apart from the business case arguments, there would also be no prospect of funding a heavy rail option. 6.1612 An important function of the TGB is to provide for goods vehicle movements essential to existing and proposed employment in the area. That function could not be achieved by public transport. It requires a road facility. 6.1613 In fact, TfL have made their commitment to improved public transport clear. The DLR extension to Woolwich is under way; the Crossrail Bill is in Parliament; the TGB would create a segregated public transport corridor across the river; TfL is pursuing Transit schemes north and south of the river, developing a DLR scheme to extend to Dagenham, continuing to transform the attractiveness of bus services in London, and working with Government and the rail industry to improve rail services. Given this programme and previous investment in major cross river public transport schemes (DLR Lewisham extension and the Jubilee Line extension), it is clear that TfL are placing a very high priority on the development of improved public transport. The TGB would be the first cross river road project to be carried out since 1991, and it is a multi-modal crossing with one third of its capacity devoted to public transport. 6.1614 Mr Blacks comment that there is no main or minor public transport crossing to the east of the Blackwall Tunnel is incorrect. The Jubilee Line crosses from North Greenwich to Canning Town to the east of the Blackwall Tunnel. The DLR Woolwich Extension is under construction and scheduled for completion in 2008/9. Crossrail is currently before Parliament. The CTRL is under construction and scheduled for completion in 2007. 6.1615 In the view of TfL, it is not a question of the need for either improved road access or improved rail links. There is a need for both. A key role of the TGB would be to provide for better orbital communications in East London. 6.1616 Mr Black asserts that the DLR crossing cost benefit ratio may well exceed 2 over a sixty year appraisal period. The assessment of a rail scheme over a sixty year period actually has fewer benefits, because most of the costs are ongoing operational costs. 6.1617 There is nothing in the 1999 Environmental Impact Assessment Regulations requiring an ES to consider all possible alternatives. What is required is an outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects. The Appraisal Summary Table 6.1618 TfL stand by the assessments contained in the AST. On reliability, Mr Black provides no evidence that adverse impacts would arise. On access to the
440
transport system, it is confirmed that non local traffic and induced traffic have been taken into account in reaching the conclusion that this would have a neutral effect. Overall 6.1619 There is no recognition in any of the papers produced by Mr Black of the weight which should attach to the statutory Development Plan, which provides the context within which the TGB proposal has been produced. The proposal is consistent with policies at each level of the Development Plan and with all other relevant policy guidance. Mr Glen Cook 6.1620 Mr Cook is a local resident who lives in Bexleyheath, just off Brampton Road. Public consultation 6.1621 Few people in his area actually know about the bridge proposals. No formal notices have been issued on a house by house basis. Articles appeared in the local press, however, during the summer of 2004, and there was a public exhibition concerning the proposal. Traffic concerns 6.1622 North of the Thames, the infrastructure is in place to deal with traffic to and from the proposed bridge. South of the river, that is not the case. Traffic to and from the bridge would use the side streets and residential roads of Bexley. This would cause traffic congestion and air pollution. 6.1623 TfL suggest that traffic from the bridge would largely be short distance traffic in connection with local employment created as part of the regeneration assisted by the bridge. But in reality much of the traffic would be long distance through traffic, which would work its way towards the A2. Through traffic would not be discouraged by the proposed toll and a few no left and no right turn signs. 6.1624 Traffic would use Knee Hill, Long Lane and Brampton Road, plus numerous side roads, all edging towards the A2, eventually clogging up the whole of this part of Bexley. These roads are already running above capacity at peak times. 6.1625 Fairly recently, a road safety scheme has been completed in Brampton Road. It was carried out because of the accident rate along this road. It cannot be sensible to introduce more traffic into this location. But that would be the inevitable consequence of building the TGB.
441
6.1626 Mitigation measures introduced after the event would not be acceptable. By then, local people would have suffered years of construction traffic; the area would be blighted and split by roads too busy to cross; air quality would suffer, and with it the health of residents. 6.1627 The bridge proposal should be rejected. Response by TfL to the objection of Mr Glen Cook Public consultation 6.1628 As Mr Cook indicates, he became aware of the TGB proposal in summer 2004 from a newspaper article, which caused him to attend an exhibition. It may be assumed that other people in his area were similarly aware of the bridge scheme. The number of objections from this part of Bexley to the planning application suggests that there was a high level of local awareness. Traffic concerns 6.1629 TfL do not accept that Brampton Road is unsuitable to carry the modelled flows of traffic. In any event, for most of its length a traffic reduction is forecast, rather than an increase, for both the peak and inter peak hours. The southbound flow in 2001 was 7,895 AADT. In 2016 with no TGB that would become 19,283; but with the TGB it would be 10,077. The comparable figures for northbound flows are 13,944 in 2001, with an increase to 15,208 in 2016 without the bridge, but 14,203 with the bridge. 6.1630 The nature of the local network would itself discourage through traffic. Knee Hill, Long Lane and Brampton Road are unlikely to be perceived or used as a convenient route south to the A2. Mr Matthew Scott 6.1631 Mr Scott lives in Sidcup. 6.1632 The suggestion that people in Bexley, and indeed around London, are supportive of the TGB is inaccurate. The project would be bad for residents in terms of quality of life, pollution, noise, traffic and road safety. 6.1633 Regeneration is something which should be encouraged if it would make life better for all. But this project would not. Just as Tfls traffic figures have been shown to be wrong, their emissions forecasts could be wrong as well. As far as the evidence on noise is concerned, Bexley is not mentioned at all. 6.1634 There are many examples already of traffic congestion in Bexley - around the traffic lights at the new Crook Log Leisure Centre, on Welling High Street, at Bourne Road, Gravel Hill and Perry Street in Crayford - all of
442
these would become much worse if the bridge were built. When someone breaks down on roads such as these, it makes the situation worse again; and if there were a problem at Dartford or at Blackwall, the roads through Bexley would certainly be used. Bexley could be used to access the TGB from the A20 or the A2. Roads such as Brampton Road, Knee Hill and Bourne Road are all possible short cuts which drivers would take. 6.1635 Information recently published by the Road Users Alliance suggests that Britain has some of the worst traffic problems in Europe, despite having below average car ownership. Motorway traffic was up by 37% in the years between 1994 and 2004, while overall traffic was up by 20%. Rail still only carries around 6% of travellers. 6.1636 TfL should invest in public transport in Bexley. The Borough has no Underground service, no DLR and no inclusion in Crossrail as yet. Response by TfL 6.1637 No specific response was made by TfL to the objection of Mr Matthew Scott. Mr Michael Winship 6.1638 Mr Winship lives in Sidcup. He has been Head of two schools in the north of Bexley; he is a member of Local Agenda 21 bodies in Bexley; and he has been involved in the production of five year traffic proposals for the Sidcup Town Centre Partnership, which were unanimously accepted by representatives of Bexley Council. Impact on Sidcup 6.1639 Sidcup is on one of the north-south routes in Bexley, and is gridlocked already at rush hours and at other times when there are problems on other major roads. Sandwiched between the A2 and the A20, it, too, suffers from the air quality problems which are found in the north of Bexley. 6.1640 The Sidcup Town Centre Partnership made twelve points to LB Bexley on the bridge proposal. a. The increase in traffic which would arise from the bridge would be insupportable. Road and junction capacities are already exceeded. b. Precious woodland would be lost at Oxleas Wood, and also possibly at Knee Hill. c. The provision of a bridge would be contrary to Bexleys and Londons policies of reducing and then reversing traffic growth.
443
d. In line with Bexleys policies on reducing reliance on the private car, if a bridge is to be built, public transport crossings should be introduced first in order to establish patterns of use of public transport. Later, it could be considered whether or not private vehicle crossing provision was necessary. e. There is no explanation of how the concept of a local bridge could be enforced. If the criterion is starting or ending in one of the adjacent Boroughs, this could include within the definition journeys starting in a different country. f. Statements that road tolls would be needed to fund the bridge mean that there would be a fundamental vested interest in maximising the number of vehicles using the crossing. g. Air quality continues to be a problem in Bexley, and the extra traffic engendered by the bridge would make this worse. h. Health figures show that Dartford and Bexley have the countrys worst figures for under-5 asthma, and Bexleys strategic document rightly shows concern for cancer incidence, which has been directly linked to vehicle emissions. i. More traffic related deaths in London result from pollution than from road traffic accidents.
j. Any new jobs provided as a result of the building of the bridge would probably benefit commuters from Essex, Kent or from across London. There would be no guaranteed jobs for Bexley residents. k. Traffic generation would bring reduced quality of life for all Bexley residents with no guaranteed benefits for anybody, and no possibility of benefits for the vast majority. l. The introduction of Congestion Charge zones in Bexley might be necessary if the bridge were to be built.
Response by TfL 6.1641 No specific response was made by TfL to the objection of Mr Michael Winship. Mr John Davey 6.1642 Mr Davey is a local resident who lives at Abbey Wood. He is much involved in the community life of the area, serving as a governor of three schools and an Adult Education College, as well as being Chairman of the Bexley
444
Arts Council. He is also politically active, having canvassed throughout Bexley during the run up to the GLA and London Mayoral elections in 2004 and the General Election of 2005. 6.1643 On the basis of all this activity in the community, Mr Davey states that the vast majority of local people in Bexley are not in favour of the TGB. He considers that the subject matter of the inquiry had a large effect on the outcome of the General Election in Bexleyheath and Crayford, because the sitting pro-bridge MP was defeated by the present anti-bridge MP with one of the largest swings in the country. 6.1644 Air quality in Bexley would be made worse by the additional traffic generated by the TGB. This would be an absolute disaster for the children of the area, where already schools have to make provision to store the inhalers of pupils who are affected by asthma. 6.1645 TfL claim that the TGB would regenerate the area. This would be a good thing if it delivered high-tech businesses, good quality housing, a restored river frontage and good hospitals and schools. Bexley needs more good quality professional jobs for the young people of the area. But the reality is that many of the brownfield sites which have already been redeveloped have produced only low quality flats and houses, with jobs created in warehousing, which produces few jobs per hectare and generates more traffic. 6.1646 Although a specific example cannot be quoted of where this has happened, the suspicion is that roads are sometimes built along a part of a route which is relatively uncontroversial, with the balance of the line being completed later, by which time the case for that part of the route seems much stronger. That is what seems to be envisaged here. If the bridge is built, it would be followed by traffic gridlock in Bexley, and then an application to create a motorway style link to the A2, which would necessarily involve road building across Oxleas Wood. Response by TfL 6.1647 No specific response was made by TfL to the objection of Mr John Davey. Mrs Jacqueline Barter 6.1648 Mrs Barter is a local resident who lives in Welling. She is involved as a volunteer in conservation projects in Lesnes Woods, and also at Woodlands Farm on Shooters Hill. Impact on use and potential use of the River Thames 6.1649 Mrs Barter has always lived close to the Thames, and wishes to see the river maintained as a fully working river, not relegated to the status of a
445
pretty view from a luxury apartment or a riverside walk. She is not against the principle of a bridge, but believes it to be important that the river is seen as an asset rather than as an unfortunate barrier. The Thames is the reason why London is where it is, a fact which should not be forgotten. 6.1650 The height of the proposed bridge would limit the size of vessels able to travel upstream of it. Mrs Barter contacted the PLA, who told her that The footprint of the bridge is not yet known, and in future it may restrict some larger ships, but these are not ones that can be identified now. Mrs Barter infers that this means that large cruise liners would no longer be able to travel upriver of the bridge to Greenwich, where a cruise liner terminal is planned. There would be a consequent loss of job prospects, both on the river and in tourism. 6.1651 By agreement with Mrs Barter, Greenwich subsequently provided a copy of the planning permission for the proposed cruise liner terminal (part of a larger mixed development) on around 3.25ha of land at Greenwich Reach East, Creek Road, Deptford (Document 2703/43). The terminal would be capable of taking vessels up to 50,000 tonnes. As at November 2005, the planning permission had not been implemented, but it would be extant until 30 July 2006. More recent applications for the site, however, do not include a cruise liner terminal. 6.1652 Mrs Barter supports the objections of AGAB, SMRA, PARC and the Friends of Danson Park in their representations regarding additional traffic, noise and air pollution. Impact on Lesnes Wood, Oxleas Wood and Woodlands Farm 6.1653 Lesnes Woods, an important public amenity, could be damaged by a greater volume of traffic using Knee Hill and New Road. There would be increased air pollution, and the roads would become more difficult to cross, making public access to and from one part of the Woods to the other more hazardous. Road widening could encroach on the Woods. Even though no widening is planned at present, if the extra traffic arrives because the bridge is built, pressure to widen the road would inevitably follow. The photograph included in Document 264/1/A1 shows how narrow Knee Hill is. Knee Hill might be classified as an A road, but it is barely wide enough for one vehicle to pass in each direction. There is no separate provision for pedestrians, but that does not mean that nobody wishes to walk there. It is a sensible route between West Heath and Abbey Wood Station. 6.1654 Although there might be no plan now to link the proposed TGB with the A2, the pressure caused by increased traffic and road congestion would mean that this issue would be raised again. Such a road would inevitably run through one of the few remaining areas of ancient woodland in the vicinity (Oxleas Wood) and Woodlands Farm. Woodlands Farm straddles the
446
boundary between Bexley and Greenwich. It is a community asset which is greatly valued, welcoming educational visits from many schools, as well as daily family visits. It had over 5,000 visitors on its last open day in May 2005. A leaflet describing the work at the Farm is contained in Document 264/1/B. 6.1655 Some years ago, the ELRC was proposed specifically to provide a link road between the M11/A406 North Circular and the A2. The present proposal represents a return to the ELRC by the back door. Response by TfL to the objection of Mrs Jacqueline Barter Impact on the use and potential use of the River Thames 6.1656 The Royal Navy has indicated that the bridge as proposed would not prevent passage for any ship they wished to sail up the Thames. The PLA have also withdrawn their objection to the scheme. In Document 264/3, the PLA state that All vessels currently able to navigate to Woolwich Reach and beyond, with the exception of some tall sail training vessels, will still be able to do so. Impact on Lesnes Wood, Oxleas Wood and Woodlands Farm 6.1657 There would be traffic increases in Bexley between now and 2016 with or without the bridge. Long distance through traffic would be discouraged from using the bridge, however, by the tolling regime and by the unattractive journey times which would be experienced compared to alternative river crossings at Dartford and Blackwall. Local traffic management initiatives taken under the Boroughs Agreement and the Unilateral Undertaking would seek to minimise traffic impacts in the Boroughs adjoining and affected by the bridge. 6.1658 Air quality and noise level impacts in Bexley would not be significant. 6.1659 Lesnes Woods operates successfully now with roads passing through the Woods, which shows that roads and nature conservation are not necessarily incompatible. 6.1660 There is no proposal for a link from the TGB to the A2. There is no policy support for such a link at national, regional or local level. Property acquired in the past to facilitate the creation of a link between the bridge and the A2 has subsequently been sold. Mrs Joyce Weston 6.1661 Mrs Weston is a local resident who lives at Welling. She has lived in Bexley since 1967. There have been many changes during that period. Some of them have been for the better; some have not. The building of the bridge
447
would be the worst change that had happened during that time, and it would be irreversible. 6.1662 Parts of Bexley have already been damaged by the noise and fumes of the additional traffic caused by the improvement of the A2. The extra traffic through Bexley generated by the bridge would make this very much worse. Response by TfL 6.1663 No specific response was made by TfL to the objection of Mrs Joyce Weston. Mrs Sue Routner 6.1664 Mrs Routner is a local resident who lives at Thamesmead. She supports the environmental objections to the proposed bridge. 6.1665 Building the bridge would have an adverse effect on biodiversity. It would adversely affect local wildlife. That is an important consideration, even if no endangered species is involved. 6.1666 There is also a path along the Thames from Thamesmead to Woolwich. That stretch of wilderness would be lost forever, and the quality of life for local residents would be damaged if the bridge were built. Response by TfL 6.1667 No specific response was made by TfL to the objection of Mrs Sue Routner. Mr R Pudney 6.1668 Mr Pudney is a local resident who lives in Abbey Wood. 6.1669 His concern is the impact which the proposed bridge would have on the living conditions of the people of Bexley. The Borough is bounded by two major roads, the M25 and the A2. Both of them are purpose built to take large volumes of traffic, both north and south of the river. The TGB would be built, however, without a purpose built road system to serve it, and this would have serious implications for the residents of Bexley. Not only the roads leading directly to the bridge, but also all available side roads would be taken up by traffic trying to reach the bridge. The benefits in terms of increased employment prospects would be far outweighed by the misery the increased traffic would cause in Bexley. 6.1670 Those employment prospects might in any event prove to be illusory. Canary Wharf was supposed to deliver major employment benefits for the Isle of Dogs, but recent studies have shown that only 15% of the people who work at Canary Wharf live on the Isle of Dogs. The vast majority of
448
the people who work there come from outside the area. If the same thing happened with the TGB, there would be an increased volume of traffic coming in to the Borough to take up the new job opportunities. 6.1671 There is now concern at the possibility that Thamesmead could be an area subject to severe flooding in the future. Much of the proposed building associated with the desire for regeneration would take place on marshland and flood plains. Experts believe that it will only be a matter of time before there are major problems caused by rising sea levels and surge tides. 6.1672 There has not been enough examination of alternatives to the bridge. There could be a tunnel or a bridge in the Woolwich Ferry area, because that is already served by the South Circular, and has good connections to the A2; or there could be another two tunnels at Blackwall, possibly supported by toll charges. Either of those approaches would remove the threat of the dire consequences for Bexley which the TGB would produce. Response by TfL 6.1673 No specific response was made by TfL to the objection of Mr R Pudney. Mrs Ann Hutchinson 6.1674 Mrs Hutchinson lives in Charlton, and is a primary school teacher in Greenwich. She finds that increasingly children at school need to have access to inhalers because of respiratory problems. The fact that schools now have formal asthma policies indicates how serious the problem has become. 6.1675 The community needs more river crossings such as Crossrail, the DLR or even the extension of the Jubilee Line, but not another bridge which would facilitate road traffic. Response by TfL to the objection of Mrs Ann Hutchinson 6.1676 It is wrong to associate increasing traffic directly with deteriorating air quality. Traffic is projected to increase in London, while at the same time air quality is projected to improve. This is largely because measures are being implemented to reduce emissions from new motor vehicles. As Document 2703/38 (a document produced by DEFRA in June 2005) shows, between 1990 and 2003 car kilometres driven in Great Britain increased by 17%, but emissions of particulates and nitrogen oxides from private cars both fell significantly, by 41% and 65% respectively. Cars are now less polluting than they used to be, so that you can have rising car numbers but falling pollution. 6.1677 There is no evidence to link the inhalers which children need to have at school with the effects of traffic.
449
6.1678 The proposed TGB is one component of a package of transport schemes in the London Plan which provides for increased public transport provision. The TGB scheme includes two lanes of dedicated, segregated public transport provision across the Thames. Mrs Joan Glastonbury 6.1679 Mrs Glastonbury is a local resident. She has lived in Bexley for 25 years, and, before that, lived in Abbey Wood for 22 years. 6.1680 She is concerned at the potential effective loss of Cooperative Woods and Lesnes Abbey Woods, both of which are classified as ancient woodland, and both of which are part of SMI 15 in the classification system devised by the London Ecology Unit. 6.1681 Woodland and parkland in the metropolitan area have always been regarded as the lungs of London. Continuous traffic (up to 60,000 vehicles per day) to and from the TGB along Knee Hill and New Road would have a detrimental effect on the two Woods. There would be heavy pollution from vehicle exhaust fumes and continuous noise in the immediate vicinity of the roads. Even if pollution would disperse quickly as you moved away from the roads, the actual access to the Woods would be hazardous. With traffic levels approaching the scale of those found on the approaches to the Dartford Crossing, people would be dissuaded from using the Woods at the very time when their residential area would be even more polluted than it is now, and the respite offered by the Woods would be of particular benefit. Response by TfL to the objection of Mrs Joan Glastonbury 6.1682 Knee Hill is an A road, and should therefore be expected to carry more than local traffic. It is embanked as it runs up the hill, and has been so for 35 or more years. There is no proposal to alter it as part of the TGB scheme. Ms Janet Mackinnon 6.1683 Ms Mackinnon now lives in Worcester, but between 1985 and 1987 she was Coordinator of what is now PARC, and she also represented FoE at the 1985/6 ELRC inquiry. During 1994/5, she helped to develop the project which led to the transfer of Woodlands Farm (which had been on the route of the proposed road between ELRC and the A2) to a charitable trust. Her objection to the TGB is a personal one, but based on professional experience in development and regeneration. Project presentation 6.1684 TfL frequently use the term Thames Gateway, and the proposed bridge is referred to as the TGB. Its former title, ELRC, would be a more appropriate description of the proposed bridge, particularly at the planning stage, when
450
facts should be presented in an objective way. 6.1685 Design issues are all but excluded from this inquiry, despite the fact that the symbolic value of the proposed structure is a key component of the cases of the promoters and their supporters. Present context 6.1686 During the inquiry, Londons success in securing the 2012 Olympics has taken on an overriding importance, particularly in relation to facilitating the relocation of existing businesses from sites required for Olympic facilities. But the TGB was not identified as part of the core transport investment package for the London Olympic Bid. 6.1687 It has been argued at the inquiry that investment in cross river transport connections, particularly by road, is essential to the removal of economic inequalities between East and West London. Within the wider community of London, however, particularly amongst key business decision makers, it is clear that the greater priority is to secure a cross river link via Crossrail. This was demonstrated by a letter published in the Financial Times on 18 July 2005, signed by a number of major business leaders. 6.1688 The integration of the CTRL with Crossrail, along with other rail and dedicated public transport facilities, would seem the most obvious means, in transport terms, of creating the kind of cross river and east-west accessibility and geographical cohesion which TfL seek for the Thames Gateway. 6.1689 The significance of the Thames Gateway initiative is linked to the perceived ability of the sub region to accommodate growth within the South East Region. In order to accommodate these development aspirations, the Thames Gateway initiative needs a comprehensive and coherent Strategic Environmental and Sustainability Appraisal. No decision on the TGB should be made until such time as a Strategic Environmental and Sustainability Appraisal for the Thames Gateway exists. Thames Gateway issues 6.1690 The fact that the alignment of the proposed TGB is supported by the statutory plans for London and the Boroughs of Newham, Redbridge, Greenwich and Bexley is one of the main pillars in the case of TfL. But all the planning documents supporting the TGB identify provisos as to the impact the bridge would have, which must be met before planning permission is given. This is true of RPG9A, the Mayors Transport Strategy, the London Plan and the various UDPs. They do not give blanket approval. There are conditions which must be met. In addition, the Greenwich and Barking & Dagenham Plans are currently under revision or review. 6.1691 Another key argument in TfLs case is the importance of the proposal for the
451
development of the Thames Gateway area. The geographical extent of the TGBs development influence is, however, questioned. In fact, the development value of the TGB seems relatively local and small. Its significance for the development of the White Hart Triangle, for example, is open to challenge. 6.1692 The one developer who has been a consistent supporter of the ELRC/TGB on development grounds is the developer of the Royal Docks. At earlier inquiries, the Inspectors have reported that a road crossing was an important confidence factor for the private sector developers then linked to the Royal Docks. Notwithstanding the lack of a bridge, development has proceeded in the Royal Docks area since that time. 6.1693 At present, Berkeley Homes appear to be reluctant to proceed with stage two of their development at Woolwich Arsenal. But it is the case that Berkeley Homes have recently become involved in the redevelopment of a substantial site in Worcester. This may well be what has caused them to reduce their immediate interest in proceeding at Woolwich. Transport issues 6.1694 There is an imbalance in the Thames Gateway and wider area between dedicated public transport provision and road provision, with the latter dominating. In order to redress this imbalance, further substantial measures to limit traffic growth are necessary before the introduction of any new road capacity. Public transport services in the area should be improved, particularly for orbital journeys. 6.1695 Greater use should also be made of the River Thames, both for public transport and the movement of goods. The greater integration of transport services and the creation of a coherent identity for the Thames Gateway would assist this process. Similar issues apply in relation to the development of rail freight. This is one of the reasons why a comprehensive environmental assessment and sustainability appraisal for the Thames Gateway needs to be carried out. 6.1696 There is little attraction in the TGB from a pedestrian or cycling perspective. The foot tunnels at Greenwich and Woolwich and the Woolwich Ferry provide adequate connectivity between north and south of the river. Strategic environmental assessment and prematurity 6.1697 The Government maintains that it is committed to the principle of sustainable development. It is therefore proposed that a cross river SEA is undertaken with regard to the plans of the five Boroughs supporting the TGB (whether in principle, as in the case of Bexley or in practice) in addition to the ES for the scheme already produced by TfL. 6.1698 The TGB planning applications are both premature and a distraction from
452
more important issues. 6.1699 The East London Sub Regional Development Framework is still evolving. Environmental sustainability is identified as an area where additional work may need to be undertaken, for example in relation to the potential impact of rising sea levels and flooding. Containment, and indeed reduction, of air pollution levels is another important issue having regard to the health consequences of increased levels of pollution and other negative impacts of increased road traffic. 6.1700 The transport context for the development and regeneration of East London also raises important questions, such as the possible extension of the Congestion Charge. An Integrated Sub Regional Transport Network Plan is in preparation. This will inform the East London Transport Plan, which provides the context in which the Thames Gateway river crossings package can be properly understood. Until that East London Transport Plan has been prepared, the promotion of the TGB is premature. 6.1701 The preparation of an East London Sub Regional Development Framework emphasises the need for a SEA, which will be a statutory requirement for the Sub Regional Plan. 6.1702 The regeneration case for the TGB needs to be examined critically by a regeneration specialist, rather than a business economist, such as TfL have commissioned. It needs to be reviewed by somebody with a good understanding of sustainability issues. It should be borne in mind that evidence in support of TfL from both London First and the London Development Agency was not open to cross examination. It should therefore only be given the weight attached to written representations. The TGB performs poorly against standard economic appraisal criteria. 6.1703 The main concern of economists at the present time should be the state of the UK economy as the key determinant of what happens in the Thames Gateway with regard to regeneration, economic activity and employment as well as the fate of deprived areas nearby. 6.1704 TfL should withdraw the present TGB scheme, and consider other options for providing a multi-modal or public transport only crossing in the vicinity of Gallions Reach or further east. No doubt this proposal will be criticised for causing delay, but major developments for which the strategic context and the various options have been inadequately prepared invite delay. Response by TfL to the objection of Ms Janet Mackinnon Project presentation 6.1705 TfL consider that the use of the terms Thames Gateway and TGB is entirely consistent with Government policy and guidance. The terms are
453
used in national policy documents such as Sustainable Communities: Homes for All of January 2005 (Document D671) and in the London Plan. Present context 6.1706 Ms Mackinnon is wrong to say that Londons success in securing the 2012 Olympics has taken on an overriding importance during the inquiry. TfL have not made a great feature of the Olympics. The latest estimate is that the bridge would, if approved, open after the conclusion of the Olympics. It would certainly not be open in time to assist with the relocation of businesses from the Lower Lea area. 6.1707 TfL support both Crossrail and the TGB as part of a package of infrastructure projects which includes also the DLR and the Silvertown Link. The role of Crossrail is principally to improve east-west access for people to Central London and Canary Wharf. The role of the TGB would be to provide orbital access for people, goods and services in East London. It would be very difficult to make local deliveries via Crossrail or the CTRL. Thames Gateway issues 6.1708 Since the PCPA 2004, the Development Plans for London Boroughs comprise their local planning documents and the London Plan. Since the UDPs of the Boroughs in the area of the TGB and the London Plan support the development of a bridge such as the TGB, the scheme accords with the Boroughs Development Plans. 6.1709 The role of the TGB would not be to provide infrastructure to support simply the development of the Greenwich Peninsula. The TGB would support development and regeneration in Woolwich, Thamesmead, Belvedere and Erith, together with sites north of the Thames, including the Royal Docks and Beckton. 6.1710 The development of Stage 2 at the Royal Arsenal is not delayed because of development opportunities which Berkeley Homes have in Worcester, but because the Secretary of State has called in the planning application for his decision. Berkeley Homes support the TGB because it is one of a series of measures intended to improve access to Woolwich. Transport issues 6.1711 TfL have made their commitment to public transport clear through extensions to the DLR, support for Crossrail, improved bus services and the Transit schemes north and south of the Thames. The TGB would also include segregated public transport lanes. 6.1712 Ms Mackinnon argues that a key priority for London should be the introduction of measures to limit future traffic growth before the introduction of any new road capacity. TfL contend that this is exactly what
454
has been proposed in the Mayors Transport Strategy and subsequent LIPs as targets for the London Boroughs. For local Boroughs close to the TGB, traffic growth targets are limited to a 6% increase from 2001 to 2011 (4% for Newham). 6.1713 TfL recognise the role of river services in providing transport in London. On 3 July 2000, London River Services transferred to TfL. This organisation owns and manages the key Central London piers, and coordinates river services. TfL are working to ensure the continued growth and development of river piers and services and to see that all river boat services are integrated with Londons other public transport services. 6.1714 In January 2005, the Mayor published Safeguarded Wharves on the River Thames London Plan Implementation Report. That report identifies those wharves which should be safeguarded for cargo handling uses in the context of Policy 4C.15 of the London Plan. Angerstein Wharf in the Borough of Greenwich has a rail connection to the Dartford Line, and is safeguarded for cargo handling. TfL are proposing two new temporary wharves to enable the transport of construction material for the TGB to take place by water. 6.1715 TfL can demonstrate a commitment to increasing the role of the River Thames in both passenger and freight transport. This does not, however, provide a substitute for the TGB in improving cross river links and orbital transport in East London. 6.1716 The foot tunnels at Greenwich and at Woolwich would remain open if the TGB were built. The Woolwich Ferry would also continue to operate. Strategic environmental assessment and prematurity 6.1717 The London Plan is the adopted Regional Spatial Strategy for the London region. TfL do not accept that implementation of development in London Thames Gateway should be delayed until the Regional Spatial Strategy for the East of England and South East regions are adopted. The London Plan is for the period to 2016, whereas the East of England Plan is for the period to 2021, and the South East Plan is for the period to 2026. The Mayor will have regard to the content of these new Regional Spatial Strategies for adjoining regions in future reviews of the London Plan. The London Plan does not, however, fall within the provisions of European Union Directive 2001/42/EC. It does not require a SEA. 6.1718 The Mayor did, however, consider environmental matters in the preparation of the London Plan, which was subject to a sustainability assessment. 6.1719 The adequacy of environmental policies for the Thames Gateway was raised during the Examination in Public of the London Plan. The Inspectors concluded that issues relating to water resources and quality, air quality, waste, contaminated land, flood risk and power supply could be adequately dealt with through the London wide policies on these subjects set out in the
455
Plan. 6.1720 The TGB proposal is subject to a comprehensive ES, and the documentation that has been submitted with the planning applications shows in detail how the TGB would contribute towards wider social, economic and environmental objectives. 6.1721 Ms Mackinnon is wrong to say that there was no opportunity for cross examination of the witnesses from London First and the London Development Agency. She is also wrong to say that the TGB performs poorly against economic appraisal criteria. Ms Jo Thomson 6.1722 Ms Thomson lives in Wimbledon. 6.1723 She argues that the regeneration evidence submitted to the inquiry on behalf of TfL is not soundly based. The regeneration model relies on a strong relationship between the level of accessibility in an area and the density of population and jobs that exist there. From this relationship, it is suggested on behalf of TfL that, by increasing accessibility, a higher number of jobs and population could be supported. 6.1724 If TfLs figures are analysed, however, it becomes clear that the relationship relies almost entirely on rail accessibility. Highway access has little or no relationship with jobs and population. In fact, TfLs figures show that the link between jobs, population and rail transport is ten times stronger than the link between jobs, population and highway access. It is therefore quite wrong to put rail access and highway access together as if they were interchangeable. In fact, TfLs figures show that the reverse is true for access to population. The figures show that if highway accessibility is increased, it leads to a reduction in the number of jobs or population that can be supported. The model therefore appears to be fundamentally flawed, and the conclusions derived from it should be discounted. Response by TfL to the objection of Ms Jo Thomson 6.1725 It is accepted that rail access is most strongly associated with higher employment densities. The highest accessibilities are recorded for Central London, and this is where the highest employment densities occur. These are achieved by the operation of the public transport and the Underground system. 6.1726 Accessibility at that level is not achieved for the places which would be affected by the TGB, and, in estimating the relationship, it was modified downwards to reflect this. This is explained in the Technical Report, Appendix B to the Regeneration Statement (Document D822).
456
6.1727 It is agreed that public transport accessibility rises more strongly across the clusters than highway accessibility does. That is why allowance has been made for this factor. Highway accessibility also increases, however, but not as steeply. 6.1728 In the statistical analysis, Volterra took all forms of accessibility together. This is because in practice the transport system and its effects have to be taken as a whole. Choices of mode will vary according to the trip desired and also the availability of different modes. Thus, if there is less public transport, the road system will probably be more congested, and this will affect the measurement of accessibility for the road system. The systems interact particularly strongly where there is more of a balance in availability, which is the case in Outer London. Thus it is accessibility overall which it is appropriate to investigate as the driver of performance. The change in accessibility in the area of the bridge would be driven by changes largely in highway access, because that is what would be provided by the TGB. 6.1729 TfL do not agree that it is inappropriate to make rail and highway access equivalent, as the transport system in Outer London in particular includes a range of services which interact. Accessibility in most areas of London in fact cannot be separated in practical terms because of the interaction of different modes of transport. Ms Jannette Graham 6.1730 Ms Graham is a local resident who lives in Beckton. She has lived in the area for twelve years. Throughout that period, there has been constant building, particularly with improvements to the A13. This work has caused disruption to her children at school. She is concerned that there would be five years of further disturbance if the bridge were built. Five years is a school life time at primary school level. In those five years, the building blocks for a childs whole future education are put in place. 6.1731 There would be disturbance from noise and, during construction, from dust. As regards noise, TfL say that people would become accustomed to it. That shows a real lack of concern for the wellbeing of the residents of the area. As regards dust, there is concern because most of the land in the area is contaminated land. When people moved in to the houses in the area, they were given leaflets advising them not to eat anything which they had grown. Digging the land up again would cause contaminants to be released into the air, which would be added to the pollution caused by the extra vehicles which the bridge would bring to the area. 6.1732 Many people in Beckton are members of minority ethnic groups, and do not have English as their first language. They do not find it easy to take part in a process where any opposition has to be set down in writing or people have to book a pre arranged appointment to state their opposition. 6.1733 Ms Graham had spent a few days distributing a leaflet prepared by FoE in
457
her area. Many of the people to whom she gave that leaflet had not realised how close the bridge would be. The thought, however, that there was nothing they would be able to do to stop the bridge being built. Response by TfL 6.1734 No specific response was made by TfL to the objection of Ms Janette Graham. Written submissions objecting to the scheme 6.1735 Many of the written representations opposing the TGB make points covered in the cases of the objectors which have been outlined above. To the extent that these points have already been covered in the report, they are not repeated here. 6.1736 Jean Lambert MEP, raised issues concerning Knee Hill and noise and air quality impacts on local schools. She also stated that the EUs 2005 Strategy on Air Quality indicates that air quality standards might be further tightened to include smaller particulates. In this scenario, projects undermining air quality standards would be even less acceptable. Greenwich have eight active air quality monitoring sites. For 2005, only one of these showed levels of PM10 and nitrogen dioxide that met EU air quality standards. The other seven monitoring sites recorded breaches of air quality standards for PM10, ozone and nitrogen dioxide. The situation in Bexley in 2005 was similarly poor. Of the five active air quality monitoring stations, four recorded breaches of EU air quality standards for PM10, ozone and nitrogen dioxide. In Redbridge, all air quality monitoring sites active in 2005 recorded breaches in EU air quality standards. 6.1737 Traffic projections show that there would be an increase in motor traffic as a result of the TGB. TfL admit that traffic would continue to grow for an additional five years after their projections to 2016, that is up to 2021. From this it can be concluded that negative air quality impacts would be likely to be even greater. 6.1738 In terms of the negative air quality impact which would be caused by the bridge, the flagship air quality policy of the Mayor of London, the proposed Low Emission Zone, would not help to address this problem. It seeks to limit the number of high emission vehicles in London, but the proposals relate to HGVs, buses, coaches and vans. Cars would be unaffected by the Low Emission Zone proposals. In this context, proceeding with the TGB would undermine the achievement of the task of meeting EU air quality standards. 6.1739 Similar points were made in a written objection from the GLA Green Group.
458
6.1740 Councillor Ron French of Bexley Council objected because of the proposed reduction in the toll discount area, which he felt would make the TGB much less of a bridge for local people. His colleague, Councillor John Wilkinson, made the point that those who would bear the burden of the greatest disruption from the bridge would no longer be given the benefit of the toll concession. 6.1741 Councillor Spencer Drury of Greenwich is concerned that traffic from the TGB would exacerbate existing traffic congestion in Greenwich. This could lead to a demand to build more roads, which could impact on green spaces in the area. He considers that Greenwich would be much better served by the Crossrail scheme than by the TGB, 6.1742 The British Motorcyclists Federation object to the Toll Order because it would allow the charging of the same toll for motorcycles as would be charged for cars and motor caravans. This is virtually unprecedented in the UK. At the Dartford Crossing, cars are charged at 1, while motorcycles are free; the Congestion Charge in Central London is 8 for cars, but motorcycles are free; on the Humber Bridge, the charge for a car is 2.50, but motorcycles are 1.10. Motorcycles are also free on the Erskine Bridge, the Forth Bridge, the Mersey Tunnel, the Severn Bridge, the Second Severn Crossing, the Tamar Bridge, the Tay Bridge and the Whitchurch Bridge, while in all of those cases a charge is made for cars. The promoters have adduced no evidence to support charging for motorcycles at the same rate as for cars. Indeed, they have suggested that, when final decisions are taken about charging levels (if the bridge is approved), motorcycles would be likely to be exempt from charging; but as matters stand there is no certainty that this would be the case. TfL have already included buses amongst the vehicles exempted from the toll by Article 5 of the Toll Order, so the existing exemptions go beyond those statutorily prescribed. There is therefore no reason why the position of motorcycles in relation to tolling cannot be resolved now. Exemption from toll for motorcycles should be recommended to the Secretary of State. 6.1743 This would be in line with Government policy, which is broadly supportive of motorcycles. The Governments Motorcycling Strategy (Document ADD/002) recognises that motorcycles have a positive contribution to make to reducing traffic congestion and associated pollution. Motorcycles provide a valuable means of transport for low income individuals, which would allow them to take advantage of the economic and social advantages which the TGB would provide. 6.1744 The objection of the British Motorcycling Federation is supported by the Greater London Motorcycle Action Group, by Mr J P OHara, in a personal capacity as a local resident, and by the Creekside Forum. The Creekside Forum also contend that, while the proposed tolls would be insignificant in the context of long distance journeys, they would be prohibitively high for people making regular local journeys, perhaps on a twice daily basis.
459
6.1745 The Albion Residents Association of Bexleyheath believe that the TGB is being promoted for the benefit of the haulage industry, to offer an alternative to the Dartford Crossing. South of the bridge, HGVs using the TGB would need to use the overloaded and unsuitable roads through Bexley, which are already in a bad state of repair through overuse. It is not the case that the TGB would bring homes, industry and employment to the south of the Thames, because the land which is currently undeveloped is not usable. It is downstream of the Thames Flood Barrier and at risk from flooding. 6.1746 Greenlands in Trust (GLIT), a voluntary environmental group, originally intended to give evidence to the inquiry. In the event, they were unable to do so, but their proof of evidence (Document 2683/1/A1) has been treated as a written representation. GLIT contend that to build the TGB with provision for two way car traffic would increase car use and resultant air pollution. This would contribute to global warming, contrary to the Rio Convention Protocol adopted by the UK in 1992. GLIT argue that the scheme is being pursued by TfL without the necessary SEA required under the Environmental Assessment of Plans and Programmes Regulations 2004. GLIT argue that the applications for the TGB are premature, because the London Plan and RPG9A will shortly be under review. The change from PPGs to PPSs following the PCPA 2004 also means that the case put forward by TfL in the Statement of Case for the TGB is no longer appropriate or adequate. Work currently being undertaken by the EA in relation to increased flood risk as a result of climate change is likely to mean that it would no longer be appropriate to build the TGB in the form and at the location currently proposed. Any bridge built should only be a local public transport bridge. 6.1747 The Shooters Hill Branch of the Eltham Labour Party are concerned that a proper HIA has not been undertaken. They believe that the consequences of the road for respiratory or other illnesses should be a material consideration. 6.1748 Ms Gillian Meyer, the Coordinator of FoE in Newham, is concerned at the prospect of extra traffic in Newham. A further representation from the group adds the point that Newham has relatively good access to jobs as measured by travel times to places of employment. The problem is more a lack of skills rather than excessive travel times. A written objection was also received from Kingston FoE, but this raised no additional point of objection. 6.1749 Mr Basil Clarke, who lives to the north of the Thames, questioned whether there is any evidence that the communities on either side of the Thames in this area have any strong desire to cross the river. He was also concerned that extra traffic on the A406 would add to noise and air pollution, which would affect residential properties in Ilford and public open spaces such as Wanstead Park. At his request, I visited that area, and noted the existing traffic noise adjacent to the A406. It is the case that, at the grade separated junction with the A118, the North Circular runs past residential
460
properties, sometimes at second and third floor level. There is traffic noise from vehicles on the A406, but, despite that, some new residential properties appear to have been built recently in the area. There is traffic noise also in Wanstead Park, but within the Park it was possible to hear birdsong above the noise of the traffic. It is difficult to believe that additional traffic arising from the TGB would make the traffic noise different in kind. 6.1750 Mr D S Garfield supports the idea of a series of ferry crossings using zero emission hydrogen fuel cell power in place of a fixed bridge. He argues that this would favour local traffic and discourage through traffic. It would not interfere with navigation along the river, and would help to bring the river to life. Other world cities take a pride in their ferry services and make them a feature of the place. 6.1751 Mr Aidan Stanger also favours the creation of ferry services. He believes that they could be funded by deleting the public transport lanes from the TGB. He considers that those lanes would never in fact be used by trams or light rail services, and the creation of special lanes solely for buses is in his view only justified where general traffic is slow moving. He believes that traffic on the TGB would be free flowing, and that buses could perfectly well travel in the general traffic lanes. 6.1752 Mrs L A Boulton and Mr J A W Dexter, who own property in the area, make the points that any development on Erith Marshes would be at risk from flooding, and that the proposed landfall of the TGB on the southern side of the river adjoins an SSSI where there are natterjack toads, a nationally endangered species. 6.1753 Mr B Martin, who lives in Sydenham, objects to the inclusion of seventy specific plots in the Compulsory Purchase Order on the basis that they provide habitat for wildlife and green spaces which can be appreciated by the local community. 6.1754 Ms C Neligan, who lives in Brampton Road, Bexleyheath, believes that traffic should be reduced in radical ways, such as raising the age for holding a driving licence to 21. 6.1755 Mrs H Joyce, who also lives in Bexleyheath, is concerned about the impact of the proposals on the emergency services. There are both Fire Brigade and Ambulance stations located at the junction of Erith Road and Long Lane, and increased traffic on the roads would hamper their response to emergency calls. She is also concerned as to where additional buses would be routed in the area. She feels that people in Bexley would not necessarily receive any benefit from the proposed bridge, but would have to contend with the daily impact of substantial quantities of additional traffic. Mrs Joyce attended the inquiry regularly, and spoke at it from time to time, mainly on procedural matters; but her actual evidence was given in writing rather than orally. It is therefore included in this section of the report.
461
6.1756 Mr D G Martin, another local resident in Bexleyheath, is concerned about the effect additional traffic might have on the roundabout in Erith Town Centre, which is already congested. He is also troubled by the adverse impact which he feels extra traffic at the Danson and Black Prince Interchanges would have on access to Queen Marys Hospital, the principal emergency hospital for the Borough of Bexley. 6.1757 Mr J Healy considers it amazing that a bridge is proposed without allowing for roads on the south side of the river to deal with the traffic which would use it, and which would therefore need to travel through residential areas. 6.1758 Mr R Goulton is not against the principle of a river crossing, but he is also concerned that the TGB would be provided without any improvement to the road infrastructure on the south side of the Thames. He believes that there should be a tunnel to link the A 2016 with the A2. 6.1759 Mr and Mrs J Lintorn, who live near Crook Log, have breathing problems, and both use inhalers. They are concerned about the possibility of increased air pollution arising from increased traffic. 6.1760 Mr J and Mrs P Carpenter question whether the new sports centre at Crook Log has been taken into account when assessing traffic levels along Brampton Road and Crook Log. 6.1761 Ms J Short lives at Abbey Wood, near the beginning of the flyover in Harrow Manorway at its junction with the Knee Hill roundabout. She is concerned about the noise from the existing traffic on the flyover, which she believes would increase, along with air pollution, if the bridge were built. She believes that no decision should be taken on the TGB until the decision on Crossrail is known, with its implications for traffic in the area. Ms Short asked if I would visit her property. Despite a number of attempts, the Programme Officer was unable to make contact with Ms Short to arrange for this to be done at a mutually acceptable time. I did, however, visit the property on 4 May 2006 from 2.15pm to 2.50pm and viewed conditions from the outside of the house. I noted the proximity of the flyover, which involved some noise and overlooking of the property. Overlooking will be more of a problem when traffic is stationary on the flyover, which did not occur during my visit. 6.1762 Among other matters already covered in the report, Mr and Mrs A L R Taylor suggest that, in place of a new bridge, the Blackwall Tunnel should be improved to take advantage of its existing connections with the strategic road network. 6.1763 Raymac Plumbing Services, who have premises on Brampton Road, Bexleyheath, are concerned that increased traffic on Brampton Road would make it more difficult for them to receive deliveries, and that customers who find that it would take longer to reach their premises would go elsewhere. Debbie Bell of Cake Tops in Bexleyheath is similarly concerned
462
that customers would have difficulty in reaching her shop and in parking. The same potential problems are of concern to Vanessa Henry of Bramptons Hair Gallery in Brampton Road. 6.1764 Mr M Sheehan lives in Edenbridge, Kent, and has a printing business in Paddock Wood, which he has operated for twenty years. If the TGB were constructed, he would use it when travelling from the north of the Thames to, for example, a conference at the Black Prince Centre on the A2, rather than using the M25 and the Dartford Crossing. He believes that many thousands of motorists would do the same, and that this would be the route advised by satellite navigation systems, which generally provide the shortest route to a destination. The response by TfL to the written objections 6.1765 Professor Duncan Laxen has carried out a detailed assessment of the air quality impacts of the proposed bridge, and shown that they would be no more than minor adverse. The Environmental Health Officers of Greenwich and Newham both agree. In addition, there are likely to be significant improvements in air quality across the study area as a result of national and international measures to reduce emissions. Any deterioration caused by the TGB would be very small in relation to such improvements. 6.1766 The review of the traffic modelling carried out for TfL was based on a more pessimistic view of traffic conditions in 2016 than are likely to occur. TfL therefore suggest that the modelled impact of the bridge is unlikely to be met or exceeded in reality. 6.1767 TfL maintain that the TGB would be a local crossing, aimed at helping local people, and focusing on areas of regeneration and relative deprivation, while at the same time aiming to limit traffic growth across the Bexley screen line. The revised tolling measures proposed are designed to ensure (together with the mitigation measures for which provision would be made) that the traffic effects of the TGB could be accommodated in Bexley. 6.1768 Nearer the likely opening of the proposed bridge, it may well be considered appropriate not to impose a toll on motorcyclists, but this should be a matter for discussion within the BCG. It would not be appropriate to amend the Toll Order at this stage. 6.1769 Long distance commercial traffic would only use the TGB if there were a significant time saving to offset what would be a substantial toll for HGVs. Experience of the M6 Toll Road demonstrates that, even where there is a time saving, tolls will stop commercial traffic using a route. 6.1770 The land either side of the River Thames is protected against flooding by a river wall 7.2m AOD. The Thames Strategy East Policies RG4.32-33 (Document ADD/012 page 88) address flood risk management and climate change. The proposed risk management strategy does not include a
463
suggested review of the TGB design or the integration of the proposed bridge in a flood alleviation scheme. 6.1771 The overall increase in car use on the network as a whole as a result of the TGB would be 0.2%, and in the simulation area, 1.9%. These increases are very small. 6.1772 The SEA Directive and the Environmental Assessment of Plans and Programmes Regulations 2004 regulate plan and programme making. They have no application to the making and determination of planning applications. 6.1773 In relation to GLITs allegation that the planning applications are premature, ODPM guidance The Planning System: General Principles (Document D665 paragraph 18) requires that planning applications should be considered in the light of current policies. The TGB has been brought forward in accord with and against the background of up to date UDPs and Mayoral Strategies. 6.1774 Providing a public transport only bridge in place of the TGB would simply replicate other facilities in existence or planned; it would not offer a crossing for commercial vehicles; and it would not be fundable. 6.1775 A HIA is not a requirement for the assessment of a proposal such as the TGB, though health issues are covered to some extent in the ES. The scheme is supported by relevant local and strategic health bodies. 6.1776 With regard to noise levels generated as a result of the TGB, TfL accept that, on the introduction of the scheme, there would be a marked increase in the number of people bothered by road traffic noise. In the longer term, however, the number of people bothered would fall to a marginal increase over the number who would be concerned by traffic noise if the scheme were not to be introduced. Overall, the noise impact of the scheme would be slight, and should prove acceptable to the majority of residents in the surrounding area. 6.1777 Natterjack toads are protected under Schedule 2 to the Conservation (Natural Habitat &c) Regulations 1994 and Schedule 5 to the Wildlife and Countryside Act 1981. They are now found at fewer than 40 sites in the UK, and have been reintroduced to a further 13 sites. They are monitored closely. TfL have found that there are no natterjack toad records for London. It is not considered that the scheme would have any impact on the species, because the habitat at Tripcock Ness is not suitable for natterjack toads. 6.1778 No site of international or national importance to wildlife biodiversity would be affected by the scheme. Small strips of land from two locally important sites would be included in the development, namely at the Beckton Ditches and Grassland SBI and in the River Thames SMI. Overall, there would be a
464
net loss of around 2.5ha of wildlife habitat to the scheme. The Boroughs Agreement provides funding for compensatory works in Newham. The majority of the habitat lost in Newham is urban wasteland, and in Greenwich it is planted woodland. Both are man made habitats that can be replaced. 6.1779 In relation to the suggestion that the number of drivers should be reduced by raising the age at which it is possible to obtain a driving licence, this is a matter of Government policy, which is not a subject appropriate for consideration at an individual public inquiry such as this. 6.1780 As regards the position of the emergency services, supportive representations have been made by the London Ambulance Service NHS Trust, and no objection has been received from the Fire Brigade. The traffic increase in 2016 along Erith Road to the junction with Long Lane with the TGB would be only marginally higher than that without the TGB. On Long Lane, there would be likely to be a slight reduction in traffic as a result of the TGB during the 2016 AM peak. It is not proposed to provide any further bus routes along Long Lane as a result of the TGB. 6.1781 The Erith roundabout has been subject to additional traffic counts and modelling work as shown in Document TfL/200. TfL accept that there would be an increase in traffic overall at the Erith roundabout. In relation to Queen Marys Hospital, however, both the Danson Interchange and the Black Prince Interchange would have fewer vehicles in both directions in 2016 with the TGB than without the bridge. 6.1782 The remodelled counts for the Brampton Road/Crook Log junction were carried out in mid-September 2005, and therefore took into account the traffic generated as a result of the opening (in July 2005) of the Crook Log Leisure Centre. The remodelling shows that during the AM peak hour the observed 2005 flows were lower than the 2001 Reference Case Model flows. 6.1783 As regards suggestions that there should be improvements to the Blackwall Tunnel, the Silvertown Crossing, intended to supplement capacity in the Blackwall area, is already proposed in the Mayors Transport Strategy and the London Plan. 6.1784 In relation to the concerns expressed by various businesses in the Brampton Road area of Bexleyheath, traffic in 2016 in Bexley will have increased regardless of whether or not the TGB is built. Inter peak flows along parts of Brampton Road would in fact reduce in 2016 with the TGB as compared to the situation without the TGB. In addition, there would be a reduction in journey times during the AM peak. As regards the junction of Brampton Road and Long Lane, both Long Lane and the junction would have reduced flows with the bridge than they would have without it. Any traffic effects which reduce trade in the area would not be brought about by the TGB.
465
7. REPRESENTATIONS CONCERNING THE PROPOSED DEVELOPMENT The material points are: 7.1 All of the representations covered in this section of the report were made in writing. None of these representations has therefore been tested by cross examination.
London Transport Users Committee (LTUC) 7.2 This Committee is appointed by the GLA. It has a statutory duty under the GLAA 1999 to consider and make representations on any matter affecting the users of services provided or procured by TfL. In response to concerns which LTUC had previously expressed, the Committee welcomes the fact that the TGB would now be provided with a dedicated public transport lane in each direction, physically segregated from ordinary road traffic. LTUC also welcomes the fact that vehicles qualifying for reduced rate tolls would be genuinely limited to those operated by local residents and businesses, and that the future of the Woolwich Ferry has been de-coupled from the case for the TGB. LTUC still believes, however, that construction of the TGB has the potential to do serious environmental harm by encouraging additional flows of private road traffic over large areas of East and South East London. LTUC would therefore wish to see any permission granted for the TGB to be linked with: a. A guarantee of the minimum frequency of public transport links to be operated. Although some of the new development in the Thames Gateway which the proposed bridge is intended to serve may not be complete by the time the bridge opens, and the initial level of demand for public transport services across the bridge may therefore be less than would normally be required to justify the desirable frequency, it is important for services to operate from the day of opening at an adequate level in order to demonstrate TfLs commitment to maximising public transport use. It would be much more difficult to achieve a modal switch away from cars retrospectively, if the build up of public transport occurs only after a pattern of car use has been established. LTUC therefore believes that a minimum frequency of not less than twenty crossings per hour in each direction during week day peak periods and not less than ten at other times is justified. b. Incorporation of tram infrastructure in the public transport lanes from the outset. This should include foundations adequate to carry the weight of trams, rails to guide the trams and provision for an appropriate power supply. Retrofitting these to the public transport lanes on the TGB would result in prolonged disruption to the pre existing bus services on the
466
7.3
7.4
7.5
bridge. c. An unbreakable commitment to manage the differential tolling regime in such a way as to ensure, as far as practicable, that the use of the road is limited to local traffic, irrespective of the impact of this on toll revenues. This end could best be secured by vesting the responsibility for fixing tolls in a joint authority on which both TfL and the local Borough Councils were represented. d. Appropriate measures to lock in the traffic reduction impact of TGB on adjacent Thames crossings in order to ensure that the capacity it releases on those routes is not immediately negated by the generation of additional private vehicle movements which are currently suppressed by the levels of congestion experienced. e. Suitable measures on the roads used by public transport in the vicinity of the bridge to protect public transport from the impact of the additional traffic flows to which the construction of the TGB would give rise. An area wide traffic management scheme is required to assist buses or trams to reach the TGB unhindered by other vehicular traffic on the approach roads. The response by TfL to the representations of LTUC 7.6 TfL are not legally able to give a guarantee of a minimum level of public transport service across the proposed TGB. Nor would it be sensible to do so at this distance of time. Actual service frequency would be determined in the light of a range of factors, including consultation, between one year and two years before the bridge was to open. The bridge design incorporates public transport lanes that could be upgraded to tram or light rail use. Until the precise form of tram or light rail system has been selected, however, it would not be possible to incorporate specific infrastructure without the risk of its becoming obsolete before being brought into use. The tolling regime would provide a discount for local residents. Without a toll, there would be no bridge. The Toll Order provides that TfL rather than the Boroughs would determine the level of toll, although the BCG would provide an opportunity for the Boroughs to make an input to decisions on the level of toll. TfL have no plan to toll the river crossings at Blackwall or Rotherhithe. The tolling regime at Dartford is not the responsibility of TfL. TfL are progressing plans for the GWT and the ELT. These are transit schemes, and therefore separated from the highway network and the associated traffic flows. With regard to traffic management generally, TfL will be working with the Boroughs on traffic mitigation measures through the
467
7.7
7.8
7.9
7.10
BCG. The Civil Aviation Authority 7.11 LCY is the statutory consultee for safeguarding purposes in accordance with ODPM Circular 01/03. The CAA support LCY in having proposed and agreed conditions to deal with all safeguarding and aerodrome licensing issues which, subject to one outstanding matter, are satisfactory to the CAA and also the local planning authorities. The outstanding matter concerns penetrations of the obstacle limitation surfaces.
Response by TfL to the representation of the CAA 7.12 The outstanding matter has been resolved with LCY, and the conditions discussed at the conditions sessions during the inquiry incorporate the necessary safeguards.
The Commission for Architecture and the Built Environment (CABE) 7.13 CABE consider that the importance of a crossing of the River Thames at this location cannot be underestimated. The new infrastructure would provide the opportunity to transform the former industrial areas and the communities on either side of the river. It is essential that the process allows for a standard of design quality that will lift the spirits. CABE welcome the fact that a Design Statement and Landscape and Urban Design Statement have been produced to form part of the planning application. CABE find the illustrative material produced uninspiring, however; it does not match up to the ambitions set out in the written material. The Quality Statement suggests that design quality will be one of the important determining factors in the selection of the concessionaire. CABE understand, however, that the final selection would be on an economic basis. CABE recognise the proposed hybrid planning application is intended to allow for the key constraints to be addressed, while giving the preferred concessionaire as much flexibility as possible in developing the detailed design. CABE are concerned, however, that the limitation in the vertical alignment of plus or minus one metre would significantly limit the structure. CABE hope that landscaping element will be seen as a key component of the design as it develops, and will not be compromised as part of a cost cutting exercise. CABE welcome the inclusion of a public transport route, cycle route and footpath as part of the TGB. In reality, they doubt whether many cyclists or pedestrians are likely to wish to use this route to cross the bridge on a regular basis. They believe, however, that the pedestrian and cycling
468
7.14
7.15
7.16
7.17
provision could well become a leisure route. Given that possibility, it would be sensible if facilities for visitors were provided at both sides of the bridge and an attractive route to gain access to the bridge were created. 7.18 The bridge would become one of the key landmarks of the Thames Gateway. Obviously it should meet the functional requirements of the brief, but it should also be elegant. The principles of quality and consistency of the detailed design should extend to the ancillary parts of the bridge such as the handrails, edgings and lighting. Provided that design, vision and quality are central to the procurement process, there is no reason why a successful outcome could not be achieved. CABE are concerned that such outcomes have not been achieved through PFI processes in the past, and they therefore urge those responsible to prioritise design quality and innovation over lowest cost. Unless there is scope for the selected scheme to improve significantly on what is illustrated in the planning application, CABE would be unable to support the project.
7.19
Response by TfL to the representations of CABE 7.20 The representations from CABE were made in October 2004. Since that time, mechanisms have been put in place to ensure that design quality is given significant emphasis. This is the thinking behind the setting up of the Design Panel. Only schemes which are considered acceptable in terms of design would be allowed to go through to consideration on financial grounds. The design which emerges would not be the same as that shown for illustrative purposes at the inquiry, but it would need to comply with the technical constraints which are the basis of the planning applications. There are examples of PFI projects which have been nominated for and achieved architectural awards for design (Documents TfL/53 and TfL/86). A number of the useful points raised by CABE have been picked up in the way in which TfL are proceeding with the project now, and one of the members of the Design Panel to assess submissions by potential concessionaires is in fact a member of the Design Review Panel of CABE.
7.21
7.22
Dartford Borough Council 7.23 Dartford Borough Council do not oppose the TGB in principle. They raise two issues about traffic. Junction 1A of the M25 (A282) will be under considerable pressure in future years through permitted development. Significant additional volumes of traffic on the A206 to the west of junction 1A would be undesirable. TfLs traffic modelling suggests that there is a watershed point on the A206. East of that point, people would tend to use the Dartford Crossing, and west of it, some would use the TGB. But this assumption relies on the differential tolling regime. Without that, traffic would be likely to divert away from using
469
7.24
the Dartford Crossing and to use the TGB. Similarly, the traffic modelling suggests that use of the TGB from Dartford itself would be minimal. Those results are what Dartford Borough Council would wish to see. The proposed differential toll would encourage those results, and the Council therefore support the use of differential tolling, and would wish to see the toll set in a manner that would deliver the modelled traffic pattern. 7.25 Dartfords second concern relates to the situation when incidents occur at the Dartford Crossing. In 2004, the tunnels had to be closed on nineteen separate occasions for operational reasons, for example because of an accident on the Essex side, to avoid stationary traffic in the tunnels. With the TGB in place, traffic would be able to divert there when there was an incident at the Dartford Crossing. Such a diversion would result in increased stress on both the A206 within the Borough and on the routes across Dartford town centre. Whilst the impacts of such incidents can be quite severe on the local road network at present, this situation would be significantly worsened with the TGB in place.
Response by TfL to the representation of Dartford Borough Council 7.26 The TGB would not cause additional traffic along the A206 to the west of junction 1A. TfLs traffic modelling shows very little change in either direction with or without the TGB in the 2016 AM peak. TfL agree that differential tolling would protect Dartford against significantly more traffic using roads in the Borough. The flexibility of the tolling regime proposed under the Toll Order would allow a response to be made should any problem arise. TfL accept that, during incidents at the Dartford Crossing, some traffic would inevitably divert via the TGB or the Blackwall Tunnel. The addition of the possibility of diverting by way of the TGB, whilst it would be a relatively isolated event, could be considered an advantage, as it would at least provide traffic caught in the congestion with an opportunity to proceed via a different route.
7.27
CPRE London 7.28 CPRE London offer conditional support for the concept of a road bridge in the location identified for the TGB, but do not support the current TGB proposal. The critical question is whether or not the bridge would be conducive to sustainable development in London and the surrounding regions. The answer to that question depends very largely on whether the journeys which the bridge would facilitate would be made by local or long distance traffic. In order to encourage local traffic and to discourage long distance commuter traffic, CPRE London consider that there should a single lane rather than a double lane over the bridge in each direction for road traffic other than public transport; but local residents using their private cars should be exempt from the toll rather than simply qualifying for a lower rate; and that non local
470
7.29
7.30
people in cars should be subject to a prohibitively high toll such as 20 per day. 7.31 CPRE London would be ready to support a modified bridge proposal which contained those safeguards. Such a bridge would help to promote the optimal development of land in the Thames Gateway while discouraging long distance commuting traffic.
The Highways Agency 7.32 The Highways Agency commissioned Faber Maunsell to consider the impact of the TGB on the trunk road network. One of the issues investigated by Faber Maunsell was the attraction to traffic of diverting from the M25 to use the TGB to cross the Thames. Their assessments showed that there would be an increase in distance from about 30km (M25 route) to 37km (TGB route), leading to an increase in journey time of around 15 minutes. That assessment is based on an M25 journey time of around 21 minutes (at an average speed assumption of 55mph) compared to an estimated journey time of 36 minutes via the TGB. In normal circumstances, there would therefore be no benefit to vehicles rerouting across the TGB, particularly in the light of the proposed toll levels on the TGB. The Highways Agency therefore do not raise objections to the TGB project, but make the following comments: a. the proposed toll levels on the TGB should be set to at least the same level as the toll levels on the Dartford Crossing. b. the Highways Agency do not necessarily endorse the transport modelling work carried out for TfL with respect to the impacts of the operation of the TGB. c. development proposals which may follow the TGB proposals would need to provide full and detailed assessments of their impact on the trunk road network, whether or not the proposals concerned were included in the transport modelling and assessment work for the TGB.
7.33
The Environment Agency 7.34 The EA originally objected to the planning applications in this case. Following discussion between the EA, TfL and Greenwich and Newham, however, the objection was withdrawn. At the inquiry, the EA participated in the conditions sessions. On 18 January 2006 the EA wrote to indicate their support for the conditions in the form which emerged from the discussions at the inquiry.
471
Mr Matthew Porter 7.35 Mr Porter considers that the proposal addresses very well the needs for all types of transport user. He is concerned to emphasise, however, the importance of the Landscape and Urban Design Strategy providing effective noise and sight screening for local residents, thereby minimising the impact of the road structure on their daily lives. Mr Porter considers that the more natural the screening can be, by using banking and tree screens, the less will be the intrusive impact on the local area.
SELTRANS 7.36 SELTRANS, the South East London Transport Strategy, was established in 1998 as a partnership between the South East London Boroughs of Bexley, Bromley, Croydon, Greenwich, Lambeth, Lewisham and Southwark, transport providers and operators, and groups representing the interests of business and passengers. The role of SELTRANS is to identify strategic transport and development issues beyond individual Borough boundaries, to develop projects and discussions addressing issues for the benefit of the region. SELTRANS submitted a written representation headed Objections to Planning Application and Side Road Orders. In a covering letter, however, it was stated that SELTRANS have no formal position on the merits of the proposed TGB as an overall proposal. Their comments are only directed at the limitations of the present arrangements for public transport access. It is in the light of that comment that the written representation from SELTRANS is reported in this section of my report. The area covered by the SELTRANS authorities accounts for 26% of Londons population, but only 19% of its jobs. Over half the working population travel outside the area each day, but 40% of households in much of the area have no access to a car. The Underground network is very sparse in South East London, and residents and workers rely heavily on the rail network, which is largely radial in nature, and is relatively infrequent compared with the Tube. In 2003, SELTRANS proposed two major new orbital express bus services around South London, which could be extended over the TGB. SELTRANS note, however, that the proposed public transport lanes across the TGB have been designed in such a way as to restrict access to TfLs bus transit services connecting the proposed GWT with the proposed ELT. They would not provide convenient access for other bus and coach services (including the proposed orbital services) catering for medium and longer distance journeys from within and outside the sub region. SELTRANS propose that the public transport lanes on the south side of the TGB should be extended further southwards alongside the main traffic lanes for approximately 300m to a junction with the A2016 Western Way near the proposed new TGB Thamesmead Junction, to cater for all other coach and bus services, whilst retaining the proposed ramp specifically for Transit services. The advantage of such a proposal would be that other bus or coach
472
7.37
7.38
7.39
7.40
services (including the proposed orbital services) could readily access the public transport lanes and gain benefit and priority over other traffic, with access directly from the main road network. This could speed up journey times considerably, and avoid the necessity of long and medium distance services using the approach Transitways and ramp through residential areas of Thamesmead, or sharing the regular traffic lanes with other vehicles and losing the benefit of bus priority across the TGB. 7.41 Modifications to the Side Roads Order and an amendment to the main bridge planning application to Greenwich were submitted by TfL to the Secretary of State on 22 September 2005, which altered the proposed ramp at Thamesmead intended for use by Transit services. The application did not, however, contain any proposal to extend the public transport lanes southwards as proposed by SELTRANS. On the north side of the bridge, it would be possible to retain an existing ramp to provide an additional and more direct exit for other bus and coaches to the A1020 Royal Docks and to the Winsor Terrace and A13 junctions. Such proposals would maximise the use of public transport lanes over the bridge by offering the possibility of their use by a wider network of bus and coach services than is currently proposed. SELTRANS therefore seek amendments to the scheme as proposed by TfL in order to achieve these changes.
7.42
7.43
Response by TfL to the representation of SELTRANS 7.44 TfL have no current proposals for the orbital routes suggested by SELTRANS. They are not in the London Plan or the Mayors Transport Strategy. On the other hand, the ELT and the GWT are included in both the London Plan and the Mayors Transport Strategy. However, TfL have not closed the door to orbital bus services using the TGB in the future, and will review the operation of public transport over the TGB at regular intervals and consult with local Boroughs.
8. OVERALL RESPONSE BY TRANSPORT FOR LONDON The material points are: Scheme aims 8.1 The overall aim of the TGB scheme is to improve accessibility to and within the Thames Gateway area and to support the regeneration of East London, particularly in the Boroughs immediately adjacent to the proposed bridge, regeneration of this area being a priority for both national and local government. The distance between the existing road crossings of the Thames at Dartford and Blackwall is 19km. The scheme seeks to enhance accessibility by reducing the barrier to the movement of people and goods that is formed by
473
8.2
the river, by attracting more people to live and work in the area, and by bringing largely derelict areas back into more appropriate forms of use, to the benefit of existing and new residents. 8.3 That immediate aim plays an important part in the Mayors strategy for Londons development set out in the London Plan. In short, this is to accommodate Londons growth sustainably, within its existing boundaries, and without either encroaching on the Green Belt or on open spaces. In order to achieve this, it is necessary to ensure that the most efficient use is made of space within Londons boundaries. The TGB is an important element in achieving this policy approach, supporting the development of an area identified as a priority at national, regional and local levels. A logical framework for determining whether the scheme aims have been met is provided by answering five questions: a. Would the scheme improve accessibility to and within the Thames Gateway area? TfL say that it would, without any doubt, and the contrary has not been argued at the inquiry. b. Would the scheme support the regeneration of this part of East London? TfL say that it would, though the contrary has been argued, and the extent of the regenerative potential is in issue. c. Would the scheme be good value for money and is it fundable? TfL say that on both counts the answers are positive. d. Are there viable alternative ways of achieving similar accessibility and regeneration benefits? TfL say that no alternative has been suggested which would achieve comparable accessibility benefits. Since accessibility is a key element in achieving regeneration, it follows that none of the alternatives would be likely to support regeneration to a similar extent. In any event, there is no policy support for any of the alternatives suggested, and no evidence that they would be fundable. e. Have potential disbenefits of the scheme been sufficiently identified and mitigated, or would implementation of the scheme give rise to such seriously adverse consequences as to outweigh the accessibility and regeneration benefits? In TfLs submission, the benefits substantially outweigh the minor disbenefits, and unavoidable disbenefits are mitigated. Traffic modelling 8.5 8.6 Before addressing those five questions, it is appropriate to say a word about the traffic modelling carried out to assist in the evaluation of the scheme. It would have been possible, in theory, to promote the TGB without any traffic modelling, or at any rate without computer modelling. But that would have been to deprive the inquiry of the advantages of modern technology and best practice. The output of the model is the basis on which the traffic impact of the scheme has been assessed, together with the benefit:cost analysis and the environmental appraisal.
474
8.4
8.7
The starting point for modelling has been the use of LTS version 3.21, run to incorporate 2001 planning data and network characteristics, to determine the matrix of origins and destinations, which has then been used for 2016, having input new forecasts for employment, population and economic factors such as car ownership. A refreshed LTS, version B5.20, will shortly become available, incorporating the results of the 2001 household data and traffic surveys. But though the refreshed LTS output is being trialled at the present, the advice received is still that it would not be appropriate to use version B5.20 at this stage as a basis for assessing the impact of the TGB. That advice came from staff developing the new version of LTS (Document TfL/128 paragraph 9). There was also independent evidence from Newhams consultant that further testing and development is likely to be required before the rebased LTS can reliably be used for scheme evaluation (first paragraph 3.6 of Document 2687/13). Short of delaying the start of the inquiry until 2007 (which nobody requested), the existing LTS had to be used. In fact, the Government is using the same version of LTS for the modelling in connection with the Crossrail Bill. Secondly, TfL constructed (for highway traffic) a local TGX model for the AM peak and for the inter-peak, using the LTS matrix of origins and destinations, but with a much denser network of links than in LTS. In July 2005, LB Bexley produced evidence of traffic counts on Bexley roads, submitted by consultants who had been acting for developers on a number of projects in the period 2003 to 2005, which appeared to indicate higher flows on certain roads in Bexley than would be consistent with the TGX model base flows. TfL therefore undertook to review the modelling which had been done, and, in particular, to take further counts. This was done at the first suitable time, after the conclusion of the holiday period in September 2005. As TfL reported to the inquiry in November 2005, the new counts largely confirmed the Bexley figures. In December 2005, TfL therefore presented to the inquiry revised modelling for the 2016 Do Minimum and Do Something scenarios. These revised forecasts were the subject of an Addendum to the ES and of revised economic and financial estimates. Without revision of the proposed tolling arrangements, the new traffic figures showed that the AM peak flow on the TGB would rise from 5,550 vehicles on the TGB itself to 5,736. This would cause unacceptable congestion across the Bexley screenline. After adjustment for the revised tolling arrangements which TfL brought to the inquiry, however, the revised figure for the AM peak would be 4,525 vehicles on the TGB itself. On the A2041 at Knee Hill, the traffic would increase from 1,399 pcus with the Reference Case Model to 2,164 pcus with the Cordon Model. Knee Hill would be by no means the most used or most important link in the highway network, but it is one on which attention has concentrated during the inquiry. To put the flow over the bridge into perspective, in the absence of tolling, and ignoring the capacity of the road network on either side of the crossing, the TGB could, if traffic was evenly balanced in both directions, carry 8,000 vehicles an hour (4,000 in each direction).
8.8
8.9
8.10
8.11
8.12
475
8.13
Tolling is an essential component of the TGB scheme. The intention would be for the precise level of tolls and the extent of the discount area and the discounted tolls to be set nearer to the opening of the bridge. It would remain possible to vary each of those items to achieve the aims of tolling, which are not merely to finance the construction of the TGB, but also to ensure that the road network to either side of the bridge can continue to operate satisfactorily and with proper regard to environmental conditions. While the Reference Case tolling arrangements envisaged a toll of 2 for cars, with a reduced toll of 1 for local cars, no differential between peak and inter-peak periods, and a discount area extending to the A2 in Bexley, the revised tolling arrangements would involve a 3/1 toll in the peak period, a 2/1 toll in the inter-peak, and an unchanged discount area except in Bexley, where the southern boundary of the discount area is now proposed to be along the A206 Woolwich Road in Bexley. The aim of the changed tolling arrangements would be to ensure that traffic levels in the A2041 corridor (Harrow Manorway/Knee Hill) were constrained within the capacity of the existing roads and junctions, it being common ground between TfL, Greenwich and Bexley that Knee Hill should not be widened. TfL do not contend that the traffic modelling in this case is perfect. Traffic forecasting can never be precise, and should not be presented as such, because it involves assumptions about the future and about the behaviour of people. But the revised modelling is fit for purpose and adequate to assist the inquiry by illustrating the sort of flows which might be predicted on the highway network in 2016. TfLs strategy includes the managing of traffic and monitoring and mitigation of problems which arise through the Boroughs Agreement/Unilateral Undertaking. It does not rely simply on forecasts. Turning to the five questions set out in paragraph 8.4 above, each is now considered in turn.
8.14
8.15
8.16
8.17
8.18
Accessibility 8.19 The TGB would improve accessibility in two principal ways. First, for road based traffic, it would provide a more direct alternative to the Blackwall and Dartford Crossings for trips with an origin or destination or both within the four nearby Boroughs. Secondly, the TGB would improve accessibility through use of the public transport lanes to be provided as part of the multimodal bridge. This increased public transport accessibility, which would complement the DLR to Woolwich and the Jubilee Line Extension, would be beneficial to the large numbers of people in the nearby Boroughs who have no car, but who would wish to work in the new employment areas proposed north and south of the TGB. The LSC has also emphasised that transport access is a major influence on the availability of learning to young people and adults, and the TGB would enable greater mobility (and therefore increase the choice of
476
8.20
courses) to residents on both sides of the river. Regeneration 8.21 The concept of regeneration in the Thames Gateway includes achieving the objectives of increasing the population of the area, increasing the number and quality its employment opportunities, increasing the average level of incomes, improving educational standards and the provision of services, removing severance caused by the river, and bringing underused land into use. Successive planning policy documents have set in train and sustained the Governments strategy for the regeneration of the Thames Gateway area, beginning in 1995 with RPG9A, and recently reaffirmed by the ODPM in the Inter Regional Planning Statement: Growth and Regeneration in the Thames Gateway (Document TfL/20). A thread running through TfL/20 is the recognition that, if the planned growth and regeneration are to be achieved in the Thames Gateway, housing and economic development must be matched by transport infrastructure and environmental improvement. Although the Cordon Model and the proposed amendments to the tolls and the discount area in Bexley would reduce the regenerative effect of the TGB, the benefit from the bridge would still be substantial. The increase in potential employment due to the TGB would still be between 24,800 and 30,700 jobs, with a potential increase in population of between 57,500 and 66,000. It is not possible in social sciences to conduct an experiment to predict future changes with precision or certainty. But it is important to bear in mind that the conclusions reached in the Regeneration Statement submitted with the planning applications are supported by the evidence of businesses with first hand knowledge of the area and the challenges faced there. The evidence from the business community in the area all indicates that the TGB would be crucial in addressing the development problems found in East London. Whilst improved accessibility would help to deliver increases in potential employment and potential population density, the delivery of regeneration would clearly require more than just the construction of the TGB. Favourable planning policies to allow appropriate development which would serve regeneration must be in place, and the business community must be willing to become engaged in the process. In this part of East London, the bridge is brought forward in a national, regional and local policy context which gives express support to the development and regeneration of East London. The bridge would also serve an area where development sites are available, and where developers are keen to become engaged in the redevelopment of the area. This provides a substantial foundation for confidence that the bridge would achieve regeneration. The London Plan and the UDPs of the local Boroughs give pro-active support to growth and regeneration. London First point out that, despite the need for growth and regeneration
477
8.22
8.23
8.24
8.25
8.26 8.27
being identified in RPG9A in 1995, rates of development have not met policy aspirations, and major development opportunities remain unrealised. Lack of improved accessibility is identified as an underlying problem. Existing transport links are perceived to be poor, and an inhibition to residents and businesses achieving adequate access north and south across the river. In particular, companies located to the south of the river experience difficulties in reaching markets to the north. Labour pools are restricted by the limited options across the Thames. 8.28 Improved accessibility delivered by the TGB would bring with it a number of benefits improved access to employment, leisure and housing opportunities; increased access to labour pools; the ability to service markets in different parts of London; and a boost to the image of the area. These are benefits that accord with planning policy and with the objective of bringing regeneration to the Thames Gateway through growth. They are identified by the business community, which has direct experience of challenges presented by the opportunity sites around the bridge. This evidence therefore provides a helpful reality check for the regeneration evidence submitted by TfL. The LSC for East London identified the trend towards increasing specialisation by Colleges and supported the bridge as a means of allowing a wider range of high quality, specialised provision that would help local residents succeed in a competitive labour market. After careful consideration of the relevant evidence, the NHS similarly supported the bridge. The TGB would therefore be a piece of transport infrastructure that the experience of the business community indicates to be crucial to addressing the development problems evidenced in East London; it is embraced by relevant agencies as ensuring a better skilled population, able to succeed in new high quality jobs, and as contributing consequentially to the improved health of the population. It is these likely outputs of the scheme that are expressly welcomed by the majority of the local Boroughs.
8.29
8.30
Value for money 8.31 TfL say that the scheme would be good value for money, with a benefit:cost ratio of 4.2:1 over 30 years and of 5.9:1 over 60 years. DfT guidance is that a benefit: cost ratio in excess of 2:1 represents high value for money. No challenge has been made to TfLs evidence that the scheme is fundable through a PFI contract.
Alternatives 8.32 No objector is promoting a specific alternative. Instead, some objectors complained that TfL have not themselves complied with WebTag guidance for the exploration of potential solutions for solving the problems and meeting the objectives. This criticism is misconceived for three reasons. First, as demonstrated by the Alternative Options Assessment (and the AST) in the Appendix to Document TfL/REB/4982/1, there has been an assessment of five other options for crossing the river. Secondly, there has
478
8.33
been no breach of WebTag guidance including its question Are there better ways to achieve the objectives. The objective for the TGB was formulated in RPG9A as long ago as 1994, to include enhanced accessibility for road based business traffic. There is no requirement under WebTag to consider alternatives unless they would meet the local objectives of the scheme, which no alternative based on public transport only or which did not provide for road traffic would have done. Thirdly, once the TGB was included in the adopted Mayors Transport Strategy in 2001, it became, and still is, TfLs statutory duty to promote it under Section 154 (3) (c) of the GLAA 1999. It would be inconsistent with this statutory duty for TfL to have consulted as if the TGB were simply one of a number of alternatives, or as if, regardless of the requirement of the Mayors Transport Strategy, any other alternative could be adopted. The balance of benefits and disbenefits 8.34 Disbenefits in terms of increased traffic flows, leading to additional noise, air pollution and loss of amenity in some areas have been identified. Appropriate mitigation and control measures have also been identified. The disbenefits, after mitigation, would not be seriously adverse, and would be substantially outweighed by the accessibility and regeneration benefits.
Local or long distance traffic? 8.35 TfL accept that some of the trips on the TGB would be relatively long, but the fact that they would virtually all either start or finish in the local area demonstrates that the TGB would be serving an important local function, rather than merely easing the movement of traffic generally. Objectors have expressed concern that the accessibility benefits of the TGB would be such as to make it an attractive route for through traffic. The principal route envisaged was from or to the M11 via the A2. If the M25 were closed between the M11 and the A2, there might be such diversions, though normally the A2/Blackwall Tunnel would remain the obvious alternative for diverting traffic rather than the TGB. But in normal circumstances the journey time via the M25 would be considerably shorter (37/39 minutes) compared to the trip via the TGB (61/69 minutes). That being so, quite apart from the 2 additional toll on the TGB, there would be no reason why drivers should want to travel through the congested area of central Bexley. Monitoring and tolling would provide the vital mechanism to ensure that through traffic was discouraged.
8.36
8.37
Public consultation 8.38 Since the 1995 public consultation on the cross river package, there have been four separate rounds of public consultation on the proposal to construct a multi-modal bridge in this locality. These are the public consultation in 2001 on the draft Mayors Transport Strategy; the public consultation in early 2003 on the draft London Plan, which included an Examination in Public; the public consultation carried out by TfL during the summer of 2003
479
regarding the TGB; and the statutory consultation carried out by the local planning authorities, with the help of TfL, after submission of the main bridge planning applications in July 2004. 8.39 The 2003 public consultation was described at the time as one of the largest consultation exercises ever undertaken by TfL. The 2004 public consultation was described by Greenwichs planning witness as the most widespread and comprehensive consultation that I have witnessed . the response was significant and covered a broad spectrum of community interest. The 2003 public consultation showed that supporters of the TGB were in a substantial majority. Since then, it is clear that in parts of Bexley the number of opponents has grown. There is no indication that this has also happened in any of the other Boroughs affected by the TGB.
8.40
Environmental Statements 8.41 The original ES has been supplemented by three Addenda. All of these documents have been widely publicised. They include the relevant information reasonably required to assess the environmental effects of the development, bearing in mind that the applicant is merely required to act reasonably having regard in particular to current knowledge and methods of assessment. If planning permissions are granted, the Secretary of State would need to provide a statement specifying the main measures to avoid, reduce and, if possible offset the major adverse effects of the development. The main mitigating measures are the tolling mechanism; the traffic mitigation measures and monitoring proposals set out in the Boroughs Agreement; and the noise barriers described as forming part of the scheme in the noise section of the ES.
8.42
The Statement of Matters 8.43 TfL consider that the issues raised in the Statement of Matters have been addressed in the way set out below.
Conformity with the adopted Development Plan 8.44 The scheme is in accordance with Policy 3C.14 of the London Plan, paragraph 5.58 of which makes it clear that the package of three new river crossings is to provide vital links between economic activity and residential areas north and south of the river; improve regional and local movements by road and rail; and stimulate regeneration without encouraging long distance commuting by road. In TfLs submission, the scheme also complies with Policy 3C.15, since the benefits substantially outweigh the minor disbenefits, and unavoidable disbenefits are mitigated. The proposal complies with the Newham UDP (2001). It is in partial conformity with the Greenwich UDP (1994). The partial non conformity has
480
8.45
8.46
to be resolved in favour of the London Plan having regard to Section 38 (5) of the PCPA 2004. In any event, there is total conformity with the emerging Greenwich UDP. It is anticipated that, by the time this report is received by the Secretary of State, the new Greenwich UDP will have been adopted, with its support for the bridge. 8.47 The extent of compliance with the Newham and Greenwich UDPs is particularly relevant, given that, under Section 38 (6) of the PCPA 2004, the determination of the planning applications must be made in accordance with the Development Plan unless material considerations indicate otherwise. Although the London Plan is currently under review, there will be many areas where the Plans existing policies will remain substantially unaltered. These include the commitment to regeneration of the Thames Gateway and the provision of the infrastructure necessary to support this, including the TGB. Indeed, Document TfL/287 makes it clear that Reviewing the London Plan, December 2005 reiterates support for the TGB. There is no question of prematurity in relation to the emerging Greenwich UDP, because the TGB is in complete conformity with the proposed modifications to that document in their post-inquiry form (Document TfL/260). The content and the advanced stage of the proposed modifications are such that, applying paragraph 17 of the guidance given in the Planning System General Principles of 2005 (Document D665), refusal could not be justified on grounds of prematurity. Among the material considerations in this case are Government and regional policy supporting the TGB proposal, including RPG9A, which referred to a multi-modal river crossing at Gallions Reach; Sustainable Communities (Document D609), which recognises that improved transport links, including road links, are essential in the regeneration of the Thames Gateway; the Interregional Planning Statement by the Thames Gateway Regional Planning Bodies (Document TfL/20), which describes the TGB as a key cross river link and a vital cross river link; and Sustainable Communities: Homes for All (Document D671), which refers to the TGB as part of the new infrastructure in the Gateway. There is also the Mayors Transport Strategy and the London Plans Sub Regional Development Framework East London (Document TfL/21), which indicates that Realisation of development capacity and sustainable regeneration of Opportunity Areas is particularly dependent on transport investment, including new north-south cross river linkages by both rail and road.
8.48
8.49
8.50
8.51
Conformity with PPG13 8.52 The policy of PPG13 to extend choice in transport and secure mobility in a way that supports sustainable development, is recognised and embraced by the London Plan (Document D620). The Plan forecasts substantial growth in both employment and population in the period to 2016, but, in keeping with the overarching policy of sustainability, that growth is to be accommodated within the urban area of London itself. This policy is consistent with the
481
guidance in paragraph 6 of PPG13, which advises that local authorities should actively manage the pattern of urban growth to make the fullest use of public transport; accommodate housing principally within existing urban areas; and ensure that development comprising jobs, shopping, leisure and services offers a realistic choice of access by public transport, walking and cycling. 8.53 Applying this guidance successfully in London entails not only focusing new development within the metropolitan area, but also maximising the use of available development land by promoting high density mixed use development. The strategy adopted to overcome these challenges is set out in Chapter 5C of the London Plan. Policy 5C.1 identifies particular priorities for improved transport infrastructure, improved bus services, GWT and ELT schemes and new river crossings. The rationale of the new river crossing scheme includes linking economic activity and residential areas, improving local movements by road, and stimulating regeneration without encouraging long distance commuting by road. The commitment to public transport is central to Policy 5C.1, but at the same time the reality is that road transport has and will continue to have an important part to play for journeys in East London. The multi-modal bridge at Gallions Reach accommodates the road movements to north and south across the river by public and private transport. The success of the sustainable policy of containing Londons growth within the metropolitan area requires the maximisation of the use of available development land in East London for intensive high quality employment and residential development. Where realistic forecasts indicate that the majority of journeys in the suburbs would continue to be by car, and where what is being looked for is (amongst other things) improved access for people, goods and services between north and south of the Thames, the conformity of the TGB proposal with PPG13 objectives and guidance is clear.
8.54
8.55
Noise and air pollution 8.56 Professional officers from Greenwich and Newham have indicated their general satisfaction with the methodologies employed and with the conclusions drawn that the TGB would have a minor adverse effect on air quality and that, in the long term, the noise impact of the scheme would be minimal and should prove acceptable to the majority of residents in the surrounding area. The analyses upon which these findings are based have not been challenged by professional evidence called by any party. In particular, LB Bexley called no evidence on air quality or noise; and, for the objectors, neither Mr Connolly nor Professor McCarthy had expertise in noise or air quality assessment. Objectors found it hard to accept that people become used to steady state noise over time, but this is based on studies recognised as authoritative by the DMRB.
8.57
Flora and Fauna
482
8.58
PPG9 was replaced in August 2005 by PPS9. The broad aim of the new guidance is that planning, construction, development and regeneration should have minimal impact on biodiversity and enhance it wherever possible. While the ES predated PPS9, the section on ecology and nature conservation took into account the Mayors Biodiversity Strategy, and Policy 1 of that document, together with Policy 3D.12 of the London Plan are drafted very much in terms of the new guidance contained in PPS9. The methodology followed in the ES in relation to biodiversity and nature conservation was not challenged by the local planning authorities, by LB Bexley, by EN or by the EA. Subject to the acceptance of agreed planning conditions being imposed on any planning permission, none of these parties sought to challenge the conclusion that the TGB scheme would have an overall minor adverse effect on biodiversity and nature conservation. Although TfLs witness on ecology was asked many questions in cross examination, no substantial evidence was produced by any objector to challenge the central conclusion that the scheme would have only a slight adverse effect overall on biodiversity and nature conservation. The data underlying the ES was produced in March 2003 so that the ES would be available in 2004, but TfLs ecology witness has since rewalked the scheme corridor and drew attention in evidence to the significant changes which had taken place to the wasteland on the north side of the river since the ES was produced. Mr Cotton, who queried the use of data produced in March 2003, provided no evidence to show that the data was actually out of date or no longer relevant; nor was he asking that surveys be carried out again.
8.59
8.60
8.61
High quality of design 8.62 The final design for the TGB would be determined by the local planning authorities under conditions attached to the main planning permissions if these are granted. This is a consequence of the hybrid nature of the planning applications. Procedures have, however, been put in place to secure a high standard of design. The Design Quality Strategy would be backed up by the deliberations and contribution of the TGB Design Panel; but at the end of the day the local planning authorities (both of whom have a good record in securing buildings of quality) would need to be satisfied before any specific design was approved.
Regeneration 8.63 This issue has already been addressed in detail. In so far as the Secretary of State seeks information relating to other deprived areas Redbridge indicated that the three wards of Loxford, Clementswood and Valentines are all likely to be in the discount area. TfL gave evidence that there is potential for additional employment and population in Hackney, Havering, Lewisham, Tower Hamlets and Waltham Forrest as a result of the TGB, quite apart from the jobs and employment potential in the five most local Boroughs.
483
Conditions 8.64 Following round table inquiry sessions on conditions, complete agreement has been reached between TfL and the three local planning authorities (Newham, the Development Corporation and Greenwich). There is also agreement with the EA, the PLA and LCY. The conditions which the Secretary of State is invited to impose are set out in Documents TfL/24S, TfL/24T and TfL/24U. These conditions meet the tests contained in Circular 11/95. For the reasons set out in Document TfL/279, it would not be appropriate to impose a condition limiting the amount of traffic on the TGB. The local planning authorities agree.
8.65
Other relevant considerations 8.66 The Boroughs Agreement and the Unilateral Undertaking contain provisions all of which are material considerations. An analysis of those provisions which can strictly be regarded as essential for the grant of planning permission is contained in Document TfL/323. The Boroughs Agreement, together with the Unilateral Undertaking which guarantees the benefits of the Agreement to Bexley, provides the mechanism by which four key matters are dealt with. First, the question of monitoring of traffic and its environmental implications. Secondly, the question of mitigation measures, both before and after the opening of the bridge, and the provision of a fund of 14.5m (index linked) to finance those mitigation measures. Thirdly, the provision to the Boroughs of information about, and their participation in formulating policy concerning, the public transport services that would use the bridge. Fourthly, the participation of the Boroughs in the formulation and revision of tolling policy. On tolling, the statutory power would remain with TfL, and could not be delegated or shared. But the Boroughs Agreement would ensure that local views were represented, and TfL would be bound to take into account views expressed by the Boroughs. If and in so far as LB Bexley still require an indemnity from TfL in respect of unspecified additional mitigation measures beyond those specifically provided for in the Boroughs Agreement, this is considered by TfL to be a novel and wholly unjustified position, and the Secretary of State is requested so to find.
8.67
8.68
8.69
The matters before the inquiry 8.70 There are seven matters before the inquiry, the two main bridge applications, the construction site application, the Special Roads Scheme, the Side Roads Order, the Compulsory Purchase Order and the Toll Order. There is considerable overlap between these seven items, and, in particular, the TGB proposal is entirely dependent for control and funding on the making of the Toll Order. If the planning permissions are refused, it is accepted that it would be virtually inevitable that the Scheme and the Orders would also not
484
be confirmed. The main bridge applications 8.71 The main bridge applications are in accordance with the Development Plan. National planning policy, a material consideration in relation to the applications, also offers support for the scheme. The proposals offer benefits for the local area which substantially outweigh any disadvantages arising from the scheme. Such disadvantages are, in any event, substantially mitigated by actions proposed by the promoters. Subject to the agreed conditions, and having regard to the commitments undertaken by the promoters in the Boroughs Agreement and the Unilateral Undertaking, the promoters submit that the main bridge applications should be approved.
The construction site application 8.72 The construction site application is also in accordance with the Development Plan. There has been no objection to it. The conditions which it is suggested should be imposed on it are agreed. The promoters submit that the construction site application should be approved.
The Special Roads and Bridge Scheme 8.73 No specific ground of objection has been raised to the Special Roads and Bridge Scheme. No modification to it is sought by TfL.
The Side Roads Order 8.74 The objection which Greenwich originally made to the Side Roads Order has been withdrawn. TfL ask for it to be confirmed, as amended by Document D859 and by Document TfL/159.
The Compulsory Purchase Order 8.75 All the statutory objections to the Order have been withdrawn. The Secretary of State is requested to confirm the Order in the modified form set out in Document TfL/313C/1.
The Toll Order 8.76 TfL still consider it improbable that it would be necessary to levy a toll higher than 4 at todays values for cars. In TfLs view, however, it would be prudent to modify the highest permissible toll for cars from 4 to 6 to retain flexibility with the revised tolling arrangements. Some consider that the maximum toll should be even higher. TfL do not believe that a sufficient case has been made for a higher maximum toll than 6, but would not have in principle an objection to a higher figure. Some objectors consider that the precise level of the actual tolls should be prescribed in the Toll Order, together with the precise boundaries of the actual discount area. But these are control tools, intended to be capable of variation from time to time in the light of traffic flows, regeneration needs
485
8.77
8.78
and environmental conditions. To fix the arrangements with precision now would remove the essential element of flexibility on the arrangements. 8.79 There are objectors who believe that the affected local authorities should be given responsibilities in connection with the setting of the toll charge and the discount review procedures. TfL contend that the Boroughs Agreement provides an appropriate consultation mechanism. As a matter of law, it is necessary that the relevant determinations should be made by TfL. Then there are those who are opposed to the Toll Order as part of an in principle objection to the TGB, recognising that tolling is an integral part of the proposal. If planning permissions are granted, then these objections fall away. Finally, there are objectors who seek an exemption from tolls for motor cycles using the bridge. TfL believe that this should be a matter for discussion within the BCG, and that it would be inappropriate to amend the Toll Order at this stage. TfL therefore request the Secretary of State to confirm the Toll Order in the modified form sought by TfL, with the amendments requested in Documents TfL/214 and TfL/332.
8.80
8.81
8.82
Support for the project 8.83 The TGB project has the positive support of Newham, Greenwich and the Development Corporation, the three relevant local planning authorities. It is also supported by LB Barking & Dagenham and by LB Redbridge. It is supported by TGLP, the body which represents all the local authorities in the local area including Dartford Borough Council and other stakeholders; by the PLA; LCY; by the EA; and by a wide range of commercial enterprises with business or development interests in the area.
486
9. CONCLUSIONS 9.1 Bearing in mind the submissions and representations I have reported, I have reached the following conclusions, references being made in square brackets to earlier paragraphs where appropriate.
Structure of conclusions 9.2 I deal first with the various legal submissions made, which are recorded in paragraphs 3.28 to 3.73 above. They will require detailed legal consideration, but I set out my own views on them below. I then deal with the three called in planning applications, reviewing the evidence in relation to the matters in connection with the main bridge applications on which the Secretary of State particularly wished to be informed. I deal with the issues raised by objectors and supporters on a topic by topic basis in order to avoid constant repetition, since many of the same issues were raised by a variety of different parties. I identify what I consider to be the main determining issues in relation to each of the applications, and I then set out my conclusions on those issues and the reasons for my recommendations on the applications. Next, I deal with the Scheme and the Orders before the inquiry, setting out the tests which must be satisfied if each of them is to be confirmed. I then reach a conclusion on the Scheme and each of the Orders, relating that conclusion to the tests which each of them must meet.
9.3
9.4
Legal submissions Deposit documents 9.5 I find it strange that TfL were apparently using as a working copy of Document D801 a version which had just the same pages missing from it as were missing from the copies supplied to the Inspectors, but that at the same time the deposit copy of that document was at all times complete. That is, however, the unchallenged evidence which was presented to the inquiry [3.30]. It is clear that the deposit documents were not in fact held at the address specified by the promoters, but that address was identified so that contact could initially be made with the relevant staff of the promoters. The actual location of the deposit documents was nearby [3.32]. I accept the reasons quoted for this arrangement, and I do not believe that anybody could have been prejudiced by it. I do not consider that the promoters complied with Rule 16(2)(b) of the Highways (Inquiries Procedure) Rules 1994 in the arrangements which they made for the deposit documents relating to the Special Roads Scheme and
487
9.6
9.7
the Side Roads Order. The Rule requires that a copy of every document to which reference will be made in evidence shall be deposited within each area in which the proposals would have effect (or as close as reasonably possible to such area). 9.8 I do not accept that the whole of Greater London can properly be regarded as the area in which the TGB proposals would have effect, as the promoters contend [3.35]. No evidence was given that the proposal would have such a widespread effect. Nor do I accept that the area in which the proposals would have effect for the purposes of the Rule is limited to the land physically affected by the Scheme or the Side Roads Order [3.36]. In the absence of a definition of area in the Rules, the word should be given its natural meaning in its context. I consider that the proposals would certainly have an effect in Newham and Greenwich and also in Bexley. In my view, copies of the relevant deposit documents should have been made available in the areas of those Boroughs. There were clearly plenty of public buildings in those areas in which sets of deposit documents could have been located, since a limited range of documents was deposited at different times at various locations in Newham, Greenwich and Bexley [3.38]. I accept the promoters submission that, given the view I have taken in relation to Rule 16(2)(b), the question to be asked is what it is just to do, having regard to all the facts and circumstances of the case [3.37]. There were only six statutory objectors to the Scheme and a similar number to the Side Roads Order. No additional objector was required by the Secretary of State to serve a statement of case under Rule 16(3)(b) of the 1994 Rules. No action therefore fell to be taken by the promoters under Rule 16(5). Very few people were therefore strictly speaking entitled to view the documents deposited under Rule 16(2)(b); and, indeed, very few people asked to see them [3.32]. One non-statutory objector who was interested in seeing the deposit documents mentioned at the inquiry that the deposit arrangements made it difficult for him and for other people to consult them [3.40]. This was, however, an inquiry which continued for a period of almost eleven months [1.37]. Many of the deposit documents were available from 7 March 2005 on the inquiry website [1.48], which was mentioned at the Pre Inquiry Meeting on 4 April 2005, and at the 28 April Procedural Meeting. From 6 June 2005 onwards, the full range of deposit documents (together with proofs of evidence and inquiry documents) was available in the inquiry library, and access to that library was available not just while the inquiry was sitting, but also during periods when the inquiry was not sitting [3.38]. Objectors did not have to deliver their proofs of evidence until 16 August
488
9.9
9.10
9.11
9.12
9.13
9.14
2005. There was thus a period of ten weeks during which the full range of necessary documents was available to objectors to assist them in preparing their evidence for the inquiry. 9.15 In that situation, I do not consider that any party has been prejudiced by what I regard as the promoters failure to comply fully with Rule 16(2)(b) of the 1994 Rules in relation to deposit documents. I note that this was not an issue pursued strongly by any of the objectors at the inquiry. In relation to the point raised by Mr J P OHara regarding what he viewed as the failure of the promoters to put on deposit a concession statement concerning the Toll Order, I agree with the promoters that paragraph 1(3) of Schedule 2 to the New Roads and Street Works Act 1991 does not apply in this case, because the Order is not one which is subject to a concession agreement as defined in Section 1(1) of the Act of 1991. Under the Toll Order, the right to charge a toll on the TGB would remain with TfL, the highways authority for the special road; it would not be passed on to any third party concessionaire [3.41, 3.42].
9.16
The availability to objectors of information obtained under the Statistics of Trade Act 1947 and the Employment and Training Act 1973 9.17 I accept that, under the terms of the notice issued to the promoters consultant, it was not open to her to share with the SWCF the information obtained under the Statistics of Trade Act and the Employment and Training Act upon which her calculations relating to accessibility and employment density were based. This problem was overcome, however, by obtaining a licence for Mr Stern of SWCF to have access to the information he wished to see [3.43 to 3.45]. It was therefore possible for him to make informed criticism of the process followed by Professor Rosewell in producing her evidence on this matter. The SWCF was the only objector to raise this issue.
The extent to which TfL can commit to a minimum level of public transport service across the proposed bridge 9.18 A public bodys basic statutory functions, whether powers or duties, are inalienable. Such bodies should not fetter their discretion by over committing themselves in advance to a particular course of action. A public body is able to enter into a commercial contract, but only one which is compatible with the due exercise of its powers or duties. TfL have a duty under Section 181(1) of the GLAA 1999 to determine which London local services are required for the purpose of providing safe, integrated, efficient and economic transport services in Greater London. I understand the motives of LB Bexley and the LTUC in seeking assurance regarding a minimum level of public transport service across the proposed bridge for a minimum period [3.46, 6.54, 7.5]. I accept, however, that if
489
9.19
9.20
TfL were to commit themselves now to such a minimum level of service, this decision would be taken, of necessity, unrelated to the circumstances prevailing at the time the need to reach a conclusion on the issue might arise. In that situation, it seems to me that by committing to a minimum level of service now, which would apply only at some unspecified time in the future, TfL would be fettering the future exercise of their discretion, an action which it is not legally open to them to take. Legal issues concerning the Environmental Statement 9.21 The length of new, widened or realigned road of four or more lanes involved in the proposals before the inquiry amounts to some 4.8km [4.26]. This is less than the figure of 10km, which would make it a Schedule 1 Development for the purposes of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999. I therefore consider it to be a Schedule 2 Development, as the promoters contend [3.52 and 3.53]. There was no proposal before the inquiry to extend the proposed route from the TGB on the southern bank of the River Thames to either the A2 or the A20. I do not accept that such an extension is inevitable, as Mr David Black claims [3.54]. Such an extension would require a further planning process, and would not be supported by existing planning policy documents. I therefore do not accept that the ES is defective in terms of Article 3 of the European Directive 85/337/EEC as amended by 97/11/EC in failing to examine the environmental implications of an extension of the proposed route to the A2 or the A20. For the same reason, I do not accept that the ES is defective in terms of Article 5 in failing to countenance a future connection to the strategic highway network [3.56]. As regards the reliability of the traffic forecasts for the scheme [3.58 and 3.59], I deal with this issue in some detail below. It has implications for a wide range of topics which were matters of contention at the inquiry. In effect, it goes to the heart of what I regard as the determining issues in relation to the main bridge planning applications, and I therefore return to it when I consider my conclusions on those applications. In relation to the consideration of alternatives in the ES [3.60], I agree with the promoters that all that is required by Article 5(3) of the Directive is an outline of the main alternatives studied by the developer and an indication of the main reasons for his choice, taking into account the environmental effects. I accept that there is no obligation under the Directive to assess alternatives. It is left to the developer to decide what, if any, alternatives he will study. If he does study alternatives, the main alternatives should be referred to in the ES [3.61]. I consider that this was done in the present case. Heavy rail was not considered to be a main alternative, and was therefore not included in the ES, but the extension of the DLR and tram
490
9.22
9.23
9.24
9.25
options were considered at paragraph 4.6 of Document D808 [3.61]. 9.26 I do not accept that Article 6 of the Directive requires that the public should be given the opportunity to choose between alternative options [3.62]. It requires that the public should be given a chance to comment on the ES (including any alternatives considered in that document) [3.63]. That has happened in this case [1.24 to 1.26, 6.366]. Article 8 requires that the result of that consultation should be taken into account in the development consent process, as it has been at this inquiry. As regards the environmental impact of the mitigation measures envisaged, I consider that such measures have been sufficiently identified in the ES and its Addenda, and their impacts have been sufficiently identified, to allow the environmental issues to be debated in an informed, meaningful and sensible way, both by the public and at the inquiry. In this case, a sum of money has been provided in addition to that which would be necessary to fund the scheme in order to finance any further mitigation measures which might prove to be necessary. An attempt has been made to identify the environmental impact of measures which can presently be listed as possibilities. I do not see anything likely to be carried out as part of this work as having significantly adverse environmental implications sufficient to render the ES and its Addenda inadequate [3.64 to 3.68]. I have been assisted in reaching these conclusions by the decision in Humber Sea Terminal Ltd v Secretary of State for Transport [3.67]. I have placed no reliance on the approach taken in relation to mitigation measures planned as part of the proposed Crossrail development, since this is being progressed through a Parliamentary Bill rather than through a planning application [3.67]. Although I have criticisms of the traffic model used in this case, I do not accept that it is impossible to assess the ability of tolls to suppress demand for use of the TGB without an improved traffic model [3.69]. Any traffic model would only provide an estimate of traffic over the bridge, and the toll arrangements proposed in this case would offer a considerable degree of flexibility to respond to actual levels of use in the light of experience [4.135]. I can find no support in the 1999 Regulations for the suggestion that the worst possible case must be assessed in terms of environmental impact [3.69]. Paragraph 4 of Part I of Schedule 4 to the Regulations requires a description of the likely significant effects of the development on the environment. That suggests to me that it is a realistic assessment of the effects which is required. I was not referred to any authority supporting the suggestion that the worst possible case must be assessed.
9.27
9.28
9.29
The need for a Strategic Environmental Assessment 9.30 I do not consider that the Environmental Assessment of Plans and Programmes Regulations 2004 require an SEA in relation to an individual
491
planning application. Those Regulations are therefore not relevant to the proposals before this inquiry. In any event, the main bridge applications were submitted before the Regulations came into force, and the London Plan was adopted five months before the Regulations became operative [3.71 to 3.72]. THE MAIN BRIDGE APPLICATIONS Background 9.31 The proposed TGB would provide a new crossing of the River Thames between Beckton and Thamesmead, with the aim of reducing the barrier to the movement of people and goods which the river currently forms in that area. In doing so, the scheme would seek to support the regeneration of East London within the Thames Gateway [1.1, 4.20]. The Thames is a major barrier to movement in the Thames Gateway. For road users, the Woolwich Ferry, which is capable of dealing with a maximum of 150 vehicles per hour in each direction, is the only crossing on a 19km stretch of river between the Blackwall Tunnel and the Dartford Crossing [4.87, 4.92]. The idea of providing a bridge in this area has been under discussion for many years [4.1]. In the 1980s, the ELRC was proposed by the Government. This would have been part of the national strategic road network [4.3]. But that proposal was dropped, and the Orders made to bring it into effect were revoked in 1997 [4.4 to 4.8]. The actual bridge now proposed would be approximately 650m long and about 33m wide [1.4, 4.62]. It would have a maximum height at road level of 58m AOD [4.32]. It would provide a four lane dual carriageway road (with two lanes in each direction) for general traffic. There would be two segregated public transport lanes (one in each direction) across the bridge and on sections of the approach roads to the north and the south [1.3, 4.25]. The use of the public transport lanes would be controlled by a Traffic Regulation Order [4.43]. A separate route across the bridge would be provided for pedestrians and cyclists [1.3, 4.25]. The main bridge planning applications are full applications which are hybrid in form [1.6 to 1.11]. Minor amendments were made to those applications both before and during the inquiry [1.12, 1.18, 1.19, 4.44, 4.45]. The construction site application is a full application [1.17]. All three applications were called in for decision by the Secretary of State [1.16, 1.17]. Before the call in decision was taken, Greenwich and Newham (the two relevant local planning authorities at the time) had resolved to grant planning permission for the main bridge applications, subject to
492
9.32
9.33
9.34
9.35
9.36 9.37
conditions and a legal agreement [1.14]. The London Thames Gateway Development Corporation is also now a local planning authority with responsibilities in relation to the main bridge application in Newham and the construction site application [1.23]. Traffic model 9.38 It is a significant feature of this case that the promoters revisited the traffic modelling for the scheme during the course of the inquiry. This was done in response to criticisms of the initial modelling work from the LB Bexley [4.96]. Bexley argue that it was inappropriate for TfL to base their traffic modelling on version 3.21 of the LTS model, which relies to a large extent on highway demand trip patterns derived from 1991 information [6.14]. This was validated against a 2001 base year, but more up to date information was available, and Bexley argue that it should have been used [6.15]. TfL respond that the later data were not available in time to be incorporated in the traffic model, but that patterns of travel have been compared, and only very small differences have been revealed [6.62]. The emerging version B5.20 of the LTS was still not at a stage where it could reliably be used as the inquiry was closing. TfL claim (and I accept) that, short of delaying the start of the inquiry until 2007 (which nobody requested), the existing LTS had to be used [8.7]. It must be accepted, however, that there were major relevant changes in the area between 1996 and 2001, including significant growth in the working population of Canary Wharf and the Isle of Dogs, major developments in north Greenwich, the DLR extension to Lewisham and the Jubilee Line extension [6.15]. Bexley also raised the issue that traffic surveys, undertaken by third parties and submitted to Bexley in support of various development proposals, suggested that the modelled traffic flows delivered by TfLs Reference Case Model at specific locations in Bexley were substantially less than current observed flows [6.16]. It was in response to this criticism that TfL decided to carry out further traffic counts during the course of the inquiry, which led to the development of the Cordon Model [4.96]. An opportunity was given to other parties to suggest additional locations for new traffic counts. LB Bexley suggest that there are still shortcomings in the rebased Cordon Model [6.18 to 6.32]. Before turning to the items listed in the Statement of Matters, I therefore begin by considering the traffic modelling evidence which was available to assist me in reaching conclusions on a number of those items.
9.39
9.40
9.41
9.42
9.43
493
Reliability of the model 9.44 The transport model includes in the Do Minimum and other future cases development assumptions from the draft London Plan (the version current at the time the model was prepared), public transport proposals which are committed or in the TfL Investment Plan, and various major highway proposals [4.93]. It incorporates the Central London Congestion Charge as introduced in February 2003, but no amendment or extension to it [4.94]. The traffic model excludes the effect in the area of the more recent increase in the Central London Congestion Charge from 5 to 8. The evidence is that the effect of this on future flows in the study area would be small [6.252], and it seems to me that the changed charge need make no difference to my conclusions. The DMRB (D522) applies to trunk roads, and the roads provided by this scheme would not be trunk roads, but I consider that the DMRB is the most appropriate guidance against which to consider the traffic modelling for the scheme [6.65]. a. It establishes calibration and validation guidelines [4.99] to allow the objective assessment of the accuracy with which a traffic model replicates traffic conditions in the base year. It is common ground that, in nearly all respects, the scheme model does not meet those guidelines in either the AM peak case or the interpeak case [4.100, 4.104, 6.19]. b. The DMRB further recommends that the AM and PM peak hours should normally be separately modelled [4.105], but in this case there is no PM model. c. Traffic models prepared in accordance with the DMRBs recommendations include at least two forecast years, one within two years of the scheme opening and one perhaps 10 or 15 years after opening [6.22], but this has not been done in this case. d. At District (or Borough) level, aggregated trip end growth should (according to the DMRB) match that derived from the National Trip End Model (TEMPRO), but the scheme forecast is lower than either the TEMPRO policy model or the TEMPRO trend model over most periods [4.130]. 9.47 The extent of the traffic models compliance with DMRB guidance was discussed by the promoters with ITEA in 2003, and accepted for the DfTs purpose at that time [4.98]. TfL claim that it performs as well as those used in many other studies [6.65]. The reasons for the lack of compliance with the guidance of the DMRB are explained by TfL on the basis that the DMRB guidance was drawn up for inter-urban corridor models, and not for congested city models, with multiple routeing options. There was insufficient data to allow full independent validation [4.98]. Previous
494
9.45
9.46
inquiries have accepted the lack of a PM peak model [6.72], and 2016 would offer a more representative year for assessment of traffic flows over the bridge than a forecast within one or two years of opening [4.123]. The DMRB recognises that traffic modelling can never be precise [4.108], yet reminds us that modelling should be accurate enough for the decisions that need to be taken; that the quality of the available information should be understood by decision makers; and that inherent uncertainties should be taken into account in reaching decisions [6.27]. Accuracy of the model 9.48 The accuracy of a model is established by comparing its representation of base year conditions with the actual base year conditions. The DMRB sets out a standard method for doing this. As well as applying the DMRB method, the promoters have devised their own tests for assessing the performance of the model [4.101], but those are less rigorous than the tests set out in the DMRB. I base my considerations here on Government guidance contained in the DMRB. The AM peak model and the interpeak model satisfy the DMRB convergence criterion, but no other [4.100, 4.104]. In the context of link flow criteria that fall considerably short of DMRB guidance, it does not seem to me that screenline flow compliance in 15 (or fewer) rather than 18 cases can robustly be argued to be equivalent to nearly all. Among the reasons cited by the promoters for the models failure to meet DMRB calibration/validation guidelines other than convergence are: the complexity of the network [4.108]; the lack of traffic flow data [6.64]; and substantial variation in the dates of the traffic surveys that were available [6.66] for which the promoters lacked sufficient data to correlate. Network complexity undoubtedly and unavoidably contributes to the difficulty of producing a reliable traffic model for the scheme. Such difficulty could have been addressed by applying unusual effort and resources to the modelling, which approach might also incorporate the development of an integrated land use/transportation model as suggested by WebTag [6.196], but such an approach would have required a very detailed knowledge of travel behaviour in the area [4.111] and, for the integrated land use/transportation model, a significant investment. The difficulty is not addressed. Events during the inquiry [4.96] demonstrated that additional traffic flow data could readily be collected although that which was collected and used to create the Cordon Model (the revised model produced as a result of the new traffic information collected during the inquiry) resulted in only a partial improvement in the calibration of the model [4.100], which remained largely non-compliant with the DMRB guidelines. Examples were given at the inquiry of traffic models that did not meet the DMRB guidelines being used to assess schemes elsewhere in the UK [6.65].
495
9.49
9.50
9.51
9.52
Studies of the reliability of further traffic models in terms of their ability to predict future traffic flows found wide variations between forecast and outcome [6.331, 6.333], but the relevance of those studies to the scheme model was not direct, since the scheme model uses methods intended to address the key causes of the errors highlighted [6.353]. In any event, I must have regard principally to the case before me and the implications for it of the modelling approach taken here. 9.53 In common with several traffic models prepared for other schemes [6.72], there is no PM peak model for the scheme. This lack is explained as resulting from the view that none was necessary (given the ad hoc arrangements made to model individual junctions in the PM peak case), the views of stakeholders, the availability of previous work, the material used at the ELRC inquiry, the availability of only an AM model from which to build the scheme model and the similarity of traffic conditions, apart from direction, in the AM and PM peaks [4.105, 4.107]. At first sight this last point seems to be at odds with the evidence that, in the PM peak period, congestion north of the river was more extensive than in the AM peak [4.89]; but the promoters survey of traffic congestion was made at a time when there was atypical congestion associated with roadworks on the A13, and so I attach less weight to that than I otherwise would. Whether or not it is the case that the promoters justification is as rigorous as the DMRB guidance suggests it should be [4.105], there can be no doubt that the absence of a separately modelled PM component detracts from the overall reliability of the scheme traffic model. In lieu of the DMRB recommendations, the modelled years are 3 and 8 years after opening. These are determined from the end of the London Plan period (2016), which is the last year for which forecasts are available for population and employment in London, and a date which was once expected to be 10 years after opening (2021) [4.123]. The use of 2016 as the earliest year in which the full effect of the scheme would take place [4.122] was not challenged and appears reasonable. The choice of 2021 to represent the effect of the scheme in a longer term context differs substantially from the DMRBs 15 year guideline, but the significance of this will depend in large part on the change in traffic conditions expected to take place during the intervening seven year period. Tolls could regulate traffic on the new bridge, and so the promoters view that the 2021 forecast robustly represents all years after 2021 [4.123] appears reasonable insofar as it applies to traffic using the new bridge. As regards other traffic in the area affected by the scheme, the promoters rely on future measures that they expect will be taken to prevent traffic growth after 2021 [6.251]. Professor Goodwin challenged this view on the basis that the effect of traffic reduction targets is underestimated in the modelling [6.230]. I consider elsewhere the effect of this on the transport economics of the scheme. Apart from those matters, I note that no party put the case that the promoters view of traffic flows after 2021 is such as to underestimate those flows, and I consider the use of the 2021 assessment date to be a reasonable basis upon which to proceed.
9.54
9.55
496
9.56
The scheme forecast of car traffic growth for the five Boroughs is based on a validated higher tier model and the London Plan. Numerically the scheme forecast is of the same order, though a little lower, than the TEMPRO trend model predicts for the period to 2031 [4.130]. This departure from the DMRB guidance is, in my view, well within survey accuracy [6.67], and unlikely to give rise to less reliable conclusions than would derive from strict adherence to the DMRB guidance in this respect. It seems to me therefore that the model does not meet the most appropriate available guidance, as set out in the DMRB, in respect of its accuracy. Nor does it represent the PM peak in a way consistent with the DMRB. For both of these reasons, it is less reliable than it otherwise would be. Other than the DMRB criteria, indicators of the degree of accuracy achieved by the Cordon Model include substantial discrepancies those where modelled and observed flows differ by a factor of 2 or more - at over half the sites in the five Boroughs nearest the scheme that were considered in the calibration/validation report for the Cordon Model [6.19]; and the large adjustments applied to flows in junctions on the A406 [4.160]. These also suggest a lack of reliability in the model. Some objectors make the point that, if the traffic model originally produced information that did not accord with current reality in Bexley, it is likely to have done the same elsewhere [6.1108]. However, no other highway authority challenged the evidence provided by the traffic model, and all had the opportunity to do so. Some objectors also argue that, if the traffic model produces predictions which do not accord with local opinion, local opinion should be preferred, because it is grounded in every day experience of the issues concerned [6.1496, 6.1569]. Local opinion is not, however, based on any supporting evidence, whereas the modelling undertaken by TfL has been prepared to some extent in the light of Government guidance, and has been signed off as fit for purpose by the DfT [6.1598]. TfL accept that traffic forecasts are predictions, and not factual [6.1565]. It would have been possible, in theory, to promote the TGB without any computer traffic modelling, but that would have denied the inquiry the benefit of worthwhile information [8.6]. TfL do not contend that the traffic modelling is perfect, but that it is fit for purpose and provided to assist the inquiry [8.16].
9.57
9.58
9.59
9.60
9.61
The quality of the available information 9.62 In addition to the considerations in the previous paragraphs, I consider that whether or not the model is sufficiently convincing to have reliance placed upon it will depend on the purpose for which its findings are used. Although it is important to distinguish between the precision of modelling individual
497
link flows and the overall reliability of the model [4.108], in some cases the individual link flows are important and have a direct bearing on the matters before me. 9.63 I now consider the matters in which outputs from the traffic model are important considerations, and the effect of the quality of the available information on subsequent considerations: a. The adequacy of the scheme itself to meet the demand for traffic to use it. It is likely that variation in the level of the tolls actually charged could provide adequate regulation of demand [4.134], and so it is likely that a model of limited reliability could be sufficient in this respect, providing the tolls can be varied sufficiently. b. The effect of the scheme in changing travel times, particularly in the peak periods, and so its effect in changing the accessibility of individual areas throughout a wide area. The journey time validation of the Cordon Model is poor, and that of the Reference Case Model, though better, remains weak [4.100]. Findings which are sensitive to errors in assessed journey times will therefore be of limited reliability. c. The various and widespread changes in traffic conditions that are summarised in the transport economic assessment of the scheme. The extent to which uncertainty in the validity of modelled outputs reflects on the qualitative conclusion in this regard [6.465 to 6.471 and 6.506 to 6.511] will depend on the margin for error in the overall transport economics of the case. d. The assessment of the environmental effects of the scheme such as its effects on air quality, noise and severance. These are relatively insensitive to changes in traffic volume [4.267, 4.297], and so a traffic model of limited reliability would be unlikely to give rise to a substantially different finding in these matters. e. The need, caused by the scheme, for traffic mitigation measures on the wider network. Cases in which the application of data from a traffic model of limited reliability have to be fed into a junction assessment provide results which are close to the limit of acceptability and provide little confidence that an acceptable situation would result. 9.64 My subsequent considerations therefore take these uncertainties into account.
Issues raised in the Statement of Matters 9.65 I now consider in turn the eight specific issues raised by the Secretary of State in the Statement of Matters concerning the main bridge applications.
498
Issue a - Compliance with the Development Plan 9.66 The Development Plan for the area includes the London Plan, the Newham UDP 2001 and the Greenwich UDP 1994 [4.186, 4.187]. An emerging review of the Greenwich UDP is at an advanced stage of preparation. I deal with it at paragraph 9.134 below. Policy T12 of the Newham UDP provides that the Council support in principle a package of crossings of the Thames, one of which is a multimodal bridge crossing at Gallions Reach [4.192]. Paragraph 7.69 of the supporting text acknowledges that the scheme might have some adverse effects on the environment of Newham and adjoining Boroughs, which would need to be minimised through sensitive design and other appropriate measures. Newham consider this to have been achieved [5.20]. It is a matter to which I return at paragraph 9.415 to 9.418 below. Policy T11 of the UDP indicates that Newham will only support the construction of new roads when they will bring net economic or environmental benefit and any adverse effect has been minimised [5.21]. Again, Newham consider this has been achieved in this case, given that the TGB would improve access to three UDP designated Major Opportunity Zones [5.18, 5.22]. The supporting text at paragraph 7.64 explains that the TGB is one of two links needed to complete Newhams road network [5.21]. Again, the issue of compliance with the Policy is one to which I return at paragraph 9.415 to 9.418 below. The current Greenwich UDP dates from a time when safeguarding for the ELRC was still in force [4.196]. Policy M9 safeguards the line of the ELRC, but Policy M21 makes it plain that Greenwich opposed the ELRC scheme [4.197]. When Greenwich considered the current TGB proposal, Policy M21 was not referred to in the report to the Planning Board, because the present proposal does not extend to the A2 [4.198]. The TGB is expressly supported in Policy M13 of the emerging review of the Greenwich UDP. Policy M14 of that emerging plan seeks to keep new road building in the Borough to a minimum, but accepts road building or improvement where the primary purpose is to facilitate development or regeneration, a condition which Greenwich believe is met in this case [4.200, 4.201]. That is a judgement with which I agree. Because of the stage which the emerging UDP has reached, I consider that substantial weight should be attached to it [4.199]. The policies supportive of the TGB were retained in the second deposit draft of the emerging UDP following consideration of objections to them [4.205]. The reviewed UDP is likely to have been adopted before a decision is taken on these applications [4.203]. The London Plan 2004 represents the spatial development strategy for Greater London [4.186]. The London Plan is currently under review, but that review is at an early stage. I therefore attach little weight to it. The
499
9.67
9.68
9.69
9.70
9.71
current version of the emerging review in any event reiterates support for the TGB [8.48]. The adopted Plan identifies the key issue for London as accommodating growth in housing and employment sustainably within its borders, without encroaching on the Green Belt or on Londons other open spaces [4.207]. The achievement of that objective would, it is argued, reduce long distance travel and encourage greater use of public transport, but the level and quality of infrastructure is seen as needing to be improved in order to deliver those aims [4.207]. 9.72 An objector argues that the current London Plan is based on population projections to 2016, but that the Office of National Statistics now has projections for the period to 2026 [6.1473], and that these should now be used. The London Plan is, however, part of the adopted Development Plan for the area, and, under the PCPA 2004, it is the starting point for my consideration of the applications. Objective 5 of the London Plan seeks to achieve improvements to Londons transport through increased investment in services and infrastructure; minimising the need to travel; integrating development with public transport; tackling congestion through restraint of car use and improved facilities for walking and cycling; and improving the sustainable movement of freight, including the use of water and rail [4.208]. The London Plan notes that the River Thames restricts development in East London, and that improving access for people, goods and services between the north and south of the Thames is a key priority in the regeneration and development of the Thames Gateway region [4.209]. Policy 3C.14 of the London Plan supports in principle the new Thames River Crossings in East London designed to achieve regeneration benefits [4.210]. One of these is the TGB. An alternative rationale for the building of the bridge was put forward by a former member of the Board of TfL [6.1255, 6.1256]. This involved providing access to a proposed new airport in Kent, and facilitating the recruitment of workers from outside London, able to travel to and from London by car. There is no support in policy or in evidence for the claim that the bridge is designed to serve a new airport. As regards access to an increased labour pool, I share the view of the promoters [6.1264] that this would be a legitimate element of regenerating the area, subject to the application of policy in relation to car borne commuters. The TGB also involves a new road scheme, and the London Plan sets out criteria for judging new road schemes in Policy 3C.15. They provide in effect that all road schemes in London should: a. Contribute to Londons economic regeneration and development
9.73
9.74
9.75
9.76
500
b. Not increase the net traffic capacity of the corridor unless essential to regeneration c. Provide a net benefit to Londons environment d. Improve safety for all users e. Improve conditions for pedestrians, cyclists, disabled people, public transport and business f. Integrate with local and strategic land use planning policies. Where schemes worsen conditions when judged against any of these criteria, the scheme should not proceed unless benefits in other areas very substantially outweigh any disbenefits, and unavoidable disbenefits are mitigated. UDP policies should incorporate these criteria for assessing road scheme proposals [4.212]. 9.77 Surprisingly, Policy 3C.15 was not mentioned in the reports to the Planning Board at Greenwich and the Development Control Committee in Newham when each of them considered the main bridge application within their area in December 2004 [6.7]. Nor was it referred to in the report to the TfL Board which authorised the making of the applications in March 2004, though the TfL Board were referred to Policy 4G.8 of the Mayors Transport Strategy, which is drafted in similar terms [4.222, 4.440]. The failure to consider the issues raised by a crucial Development Plan policy in my view takes some supportive value away from the decisions of Greenwich and Newham to grant conditional planning permission for the main bridge applications, but any defect in their conclusions on the applications will be made good by the fact that the policy was fully discussed at the inquiry and is addressed in this report. The contribution which the TGB and its associated roads would make to Londons economic regeneration and development (criterion (a) of Policy 3C.15) is considered below from paragraph 9.274 in relation to issue (f) of the Statement of Matters. No figure for the increase in the net traffic capacity of the corridor (criterion (b) of Policy 3C.15) was provided at the inquiry, but the estimated increase in annual vehicle kilometres covered in the modelled area with the TGB compared with the position without the TGB was estimated by the promoters as plus 0.47% [4.179]. The scheme would therefore increase the net traffic capacity of the corridor. It is argued that this extra capacity would be essential to regeneration [5.23, 6.57], but objectors contend that better ways could be found to support regeneration [6.540]. The potential net benefit to the environment (criterion (c) of Policy 3C.15)
501
9.78
9.79
9.80
9.81
is considered below in the light of my conclusions on issues (c), (d) and (e) in the Statement of Matters. 9.82 In relation to road safety (criterion (d) of Policy 3C.15), the new road would be safer than the local network average, but would increase traffic flows [4.163]. Despite interpretations to the contrary [6.385, 6.833], the evidence is clearly that the scheme would give rise to an increase in road traffic accidents, causing in each year 1 fatality, 6 serious injuries and 114 slight injuries [4.179]. This estimate has been prepared in accordance with Government guidance [4.178]. I do not accept the calculation of road safety (and general health) impacts based on an assumption that all 20 million journeys across the TGB annually (or 18.3 million on the rebased traffic figures with the proposed amended tolls and amended discount area) would be new journeys [6.384]. This would not accord with reality in my view. I accept the evidence from TfL that some 14% of car journeys across the bridge would be new car journeys [6.404]. The promoters estimate that the number of additional casualties caused by the scheme would be 1.4% of the number of casualties in the study area [6.652]. Although the LCC is concerned that such an increase would deter people from cycling [6.639], it seems to me that any such deterrent effect is likely to be proportionate to the change in conditions and, since the relative change would be small, so would any associated deterrent effect. Notwithstanding the promoters use of a traffic model of limited reliability to assess the effect of the scheme on numbers of accidents, their conclusion in this regard is robust [4.179], and it is unlikely that a more reliable traffic model would give rise to a materially different conclusion in respect of the overall numbers of additional accidents that would arise as a result of the scheme. I conclude that in 2016 and each subsequent year the scheme would cause about 1 additional fatality, 6 additional serious injuries and 114 additional slight injuries. It would therefore not improve safety for all road users. Turning to the possible improvements to conditions (criterion (e) of Policy 3C.15) which the scheme would deliver for, first of all, pedestrians and cyclists, clearly the TGB would provide a new cross river route. However, the usefulness of that route would be affected by conditions on the bridge. Pedestrian and cyclists would both be affected from time to time by high winds, which would cause discomfort for them at wind speeds of Gale Force 7 and above, expected by the promoters to occur for about 730 hours each year, about half of which would occur at times when there would be few such users of the bridge [4.33]. There are 8,760 hours in a year, and so this rate of occurrence of high winds equates to one-twelfth of the time. Such conditions would not therefore be exceptional on the bridge. For pedestrians, the new bridge would be too long to be a useful component
502
9.83
9.84
9.85
9.86
9.87
9.88
of many regular walking trips [4.177]. Some objectors claimed that the bridge would involve pedestrians and cyclists in a cross river trip of 2km or more [6.487], but the promoters intend to provide lifts for use by walkers and cyclists to each side of the river. Possible locations for the lifts could mean that the trip across the bridge would be no more than 750m, although if alternative locations were chosen, this would involve a walk or a cycling trip of 1.8km [6.523]. 9.89 Even with the lifts, however, the cycle route over the bridge would retain a long, steep section that would make cycling difficult. It would not comply with the guidance in Local Transport Note 1/89. Headwinds or crosswinds would also hinder progress [6.636]. A shallower gradient would be impossible to provide because of other design constraints [6.649]. In support of their proposal, the promoters cite DMRB design criteria for the gradients of footbridges over roads [6.649] but, since such bridges are likely to be less high than the scheme and so involve shorter climbs, this is not wholly relevant. If, as the promoters suggest [4.34], barriers and chicanes were included in the footway/cycleway to discourage speeding by descending cyclists, those would also tend to impede the progress of ascending cyclists. It therefore seems to me that the potential usefulness of the bridge in providing a new route for pedestrians and cyclists would be in large part offset by its exposure to the wind, its length and its design. Although the connections between cycle and pedestrians routes on the scheme would in some places rely on multiple toucan crossings, delaying cyclists and pedestrians to an extent and at more locations than motorised road users [6.636], no alternative arrangement was suggested, and the main junctions have been designed in accordance with the DMRB [4.56]. The design accords with Government guidance in this respect. I do not agree that the cycle routes to and from the scheme would be so inconvenient as actively to discourage cycling [6.636]; the off-line cycleways north of the river would be broadly parallel to the scheme, would connect with it at various points, and would connect frequently with the local cycle networks [4.31, 6.651]. There is no dispute, however, that overall the scheme would reduce travel by cycling and walking [6.210, 6.293]. AGAB consider that extra traffic arising from the scheme would make conditions worse for pedestrians and cyclists on roads in the areas around the bridge [6.754], and identify some sites where that might happen [6.715]. The promoters have used the traffic model to identify locations where traffic increases arising from the scheme would be so large as to create potential severance [4.151] and, as previously described, I am satisfied that a model of limited reliability is likely to provide sufficiently accurate results for this purpose. At many such locations the likelihood of
503
9.90
9.91
9.92
9.93
9.94
severance is in fact small, due to the current absence of opportunities for pedestrians or cyclists to cross the roads in question at grade. At others, a mechanism is established by the Boroughs Agreement and the Unilateral Undertaking (TfL/22C and TfL/22D) for the provision of crossing facilities should the need arise as a result of the scheme. Although the LCC consider that traffic increases caused by the scheme might deter cycling on the wider network, they were unable to substantiate that view [6.637]. It seems to me that changes in traffic conditions on the wider network that are likely to arise as a result of the scheme and its associated mitigation measures are unlikely to have a significant effect on walking and cycling on the wider network. 9.95 By virtue of the changes to the cycleway and footway networks it would bring, particularly to the north of the river, and by virtue of the provision of an additional crossing of the Thames (although of limited utility, for the reasons given), the scheme would result in a small improvement in the extent and connectivity of the cycleway and footway networks in the area. The effect to which that improvement would affect conditions for cyclists and pedestrians would depend on the extent to which it would meet the needs of such travellers. The evidence is that fewer people would choose cycling or walking as a transport mode if the scheme were built than if it were not. From this I conclude that the scheme would not improve conditions for cyclists or pedestrians. For people with disabilities which involve the use of an invalid carriage of a type which would be allowed in the proposed lifts and on the footway, there would be improved conditions by way of an additional route to cross the Thames, subject only to the problems of wind and weather referred to in relation to cyclists and walkers above [4.136, 4.213]. For many, I consider that use of the bridge with an invalid carriage would represent a daunting prospect. People with disabilities who use cars, however, would have the benefit of an additional river crossing [5.81]. For some of them, it would no doubt be more convenient than existing crossings. On that basis, it seems to me that the scheme would provide a marginal improvement of conditions for people with disabilities. In relation to public transport, in the area served by the scheme, many households have no car and many people do not have the use of a car [6.555]. Public transport is therefore important in the area [6.753]. Some objectors pointed to what they considered to be shortcomings in public transport provision in East London [6.753, 6.1477], but such matters were not before me. Nor was the relative priority of transport measures that might be taken there [6.918].
9.96
9.97
9.98
9.99
9.100 The scheme would make largely segregated provision for bus based public transport, capable of modification to light rail later if the need arose [4.31, 4.170] and integrating with the separately proposed ELT [4.29, 4.171,
504
4.172] and GWT [4.37, 4.171, 4.172]. There was no fundamental challenge to this proposal. In a written representation, LTUC argued the case for tram infrastructure to be built into the TGB from the outset, because retrofitting would require disruption to what would by then be the established bus public transport services over the bridge [7.5]. TfLs response was that, while the bridge would be designed to accept tram or light rail use, until the precise form of any such system has been selected, it would not be sensible to incorporate specific infrastructure. To do so would incur the risk that it would be obsolete before being brought into use [7.7]. I consider TfLs position on that matter to be a reasonable one. 9.101 The scheme would make significant improvements to public transport journey times and to reliability [4.175], and would offer scope for increasing public transport capacity to match the pace of future development in the Thames Gateway [5.44]. 9.102 Despite that, the promoters evidence is that, while public transport use would increase substantially in the period to 2016 in the do-minimum case [4.129], the implementation of the scheme would very marginally reduce public transport travel and increase car use [4.163]. There is no evidence to the contrary. 9.103 The LTGF expressed the opinion that the public transport model is at fault, but gave no evidence to support that view [6.919], whereas the promoters evidence that the public transport model had been the subject of a satisfactory validation report [4.117] was not questioned. I conclude that the public transport model is satisfactory for the uses to which it was put in connection with the scheme. 9.104 The promoters provide an indication of the broad level of bus services they expect to see using the scheme. They would make firm proposals one or two years before the bridge opened [4.173]. There would subsequently be regular review, in consultation with the Borough Councils [4.174], an arrangement for which Newham and Redbridge Councils expressed support [5.45, 5.63]. Bexley Council feel that a minimum level of service should be specified now [6.54]. For the reason given in paragraph 9.20, I consider the promoters to have acted reasonably in regard to planning future public transport service provision relating to the scheme and, indeed, they could have given no greater commitment. 9.105 Although the building of the TGB would in effect reduce the public transport mode share slightly [6.483], I consider that the separate provision for public transport included with the bridge would offer such benefits for public transport in terms of improved travel times and reliability that, on balance, the scheme would improve conditions for public transport. 9.106 As regards the position for business, the scheme would provide an improvement in access to a larger workforce and increased markets [4.162, 4.213, 5.4, 5.26, 5.80]. The need for road access for supplies and to make
505
deliveries cannot be supplied by public transport [5.80]. The bridge would offer reduced journey times for local businesses [4.162]. I consider that it would therefore improve conditions for business. 9.107 TfL contend that the TGB would integrate with local and strategic land use policies (criterion (f) of Policy 3C.15) by supporting such policies enunciated at national, regional and local levels applying to the London Thames Gateway [6.57]. I have identified issues concerning regional and local land use policies above. I shall turn to transport policies in dealing with issue (b) from the Statement of Matters (from paragraph 9.138 below). 9.108 In relation to national land use policies, I consider that there is substantial support for the TGB scheme. The Governments Strategic Guidance for London Planning Authorities of 1989 identified the need to increase growth in the east of London. This was reinforced in 1994 by statutory guidance in RPG9, which identified the area of the Thames Gateway for significant levels of housing and employment development, supported by improvements to the transport infrastructure [4.13]. In 1995, RPG9A specifically mentioned the need for new and improved cross river links to remove the barrier effect of the Thames [4.14, 5.122]. One of these was seen as a river crossing at Gallions Reach [4.15]. 9.109 The crucial role to be played by development in the Thames Gateway was again recognised in the Governments Sustainable Communities Programme [4.17]. The five year plan of January 2005, which indicates how that programme is to be achieved identifies the TGB as relevant new infrastructure in the Thames Gateway supporting the programme [4.17]. The joint inter-regional planning statement Growth and Regeneration in the Thames Gateway of August 2004 indicates that the TGB is one of four transport projects critical to success in delivering the Sustainable Communities agenda [4.19]. Achievement of the housing and employment figures included in the planning statement assume that the TGB will be open by 2013 [4.18]. 9.110 TfL do not say that building the TGB would alone ensure the success of the London part of the Thames Gateway, or that, without the TGB, the Thames Gateway project would necessarily fail. They contend, however, that it is essential if the high quality, dense development envisaged for the area is to be achieved within the timescale currently planned at national, regional and local level [4.24]. 9.111 In summary, therefore, I consider that the TGB scheme complies with criterion (f) contained in Policy 3C.15, but that it does not comply with criterion (d); and that it does not comply with criterion (e) in relation to pedestrians and cyclists. It increases the net traffic capacity of the corridor (criterion (b)), and the extent to which it is essential to regeneration therefore needs to be examined. Its contribution to economic regeneration also needs to be assessed in relation to criterion (a). This will be done in dealing with issue (f) of the Statement of Matters below. The extent to which the scheme would provide a net benefit to Londons environment
506
(criterion (c)) needs to be examined in the context of issues (c), (d) and (e). 9.112 Because I have already concluded that the scheme does not comply with the criterion (d) and to some extent with criterion (e), it will clearly be necessary to carry out the balancing exercise envisaged by Policy 3C.15 when conclusions have been reached on compliance with the outstanding criteria. 9.113 Environmental and design issues also need to be considered to determine compliance with Policy T12 of the Newham UDP, and environmental and economic issues need to be considered to determine compliance with Policy T11 of the Newham UDP. 9.114 At this stage, I reach an interim conclusion that the scheme complies with the Greenwich UDP, and I return below (from paragraph 9.408) to the issue of overall compliance with the Development Plan. Other material considerations in relation to planning policy not otherwise identified in the Statement of Matters 9.115 The London Plan is part of a series of statutory policy documents produced by the Mayor of London [4.220]. 9.116 The Mayors Transport Strategy places a strong emphasis on better public transport facilities, but also recognises the importance of the private car for travel, and of road freight. Policy 4G.8 of the Strategy sets similar criteria for the approval of new road schemes to those contained in Policy 3C.15 of the London Plan [4.222]. The question of compliance with the requirements of that Policy therefore raises the same issues as are raised by Policy 3C.15 of the London Plan. 9.117 The Strategy acknowledges the significant difference between Central London, where development densities and public transport provision and use are all exceptionally high, and Outer London, where it is accepted that the car plays, and will continue to play, a very significant role even after implementation of the Strategys planned improvements to alternative means of transport. In East London, the Strategy recognises the need to improve transport access, to reduce the north/south barrier caused by the river, and to support regeneration [4.223]. 9.118 The Transport Strategy outlines a balanced package of new river crossings within East London to improve rail and local road based travel opportunities. In my view it is worth clarifying just what is included in this package, and the extent to which regard has been and should be paid to different elements of it in assessing the TGB scheme. In the order of priority given in the Mayors Transport Strategy, the river crossings package includes a rail crossing at Woolwich, the TGB at Thamesmead, and a road bridge or tunnel between Silvertown and North Greenwich (the Silvertown
507
link) [4.224]. 9.119 The rail crossing will run as an extension to the DLR under the Thames from LCY to Woolwich Arsenal. It was under construction at the time of the inquiry, and it is planned to be in operation by early 2009 [4.225]. 9.120 The Silvertown link would join the Greenwich Peninsula and the Silvertown/Royal Docks areas. It would aim to ease traffic congestion around the Blackwall Tunnel. It could take the form of a tunnel, but this will only be decided after a further process of assessment and consultation. The Silvertown link is not in TfLs business and investment plan for 2005 to 2010, but it is envisaged that it would follow the planned implementation of the TGB [4.227]. If implemented, it is estimated that it would reduce traffic flows on the TGB by almost 5% in each direction [4.148]. 9.121 Since the publication of the London Plan, a proposal has been developed for a south eastern branch of Crossrail, the major project to link Londons mainline stations by heavy rail. The south eastern branch would cross the Thames in tunnel to provide a major new link between the North Kent Line and the Central London core section of the scheme. Crossrail is currently the subject of a hybrid Bill in Parliament, seeking powers for the scheme [4.228]. 9.122 The TGB, the Silvertown Link and Crossrail (although referred to as part of a package) are therefore being progressed as separate schemes, using different powers and processes. If all were completed as planned (including the committed DLR Extension), the public transport element of the additional crossing capability created through the four schemes would exceed 80% [5.76]. 9.123 The case for the TGB has been assessed without Crossrail, but sensitivity tests assuming that both the TGB and Crossrail are built have also been covered in the evidence in support of the TGB scheme [4.94, 4.229]. Crossrail is presently planned to terminate at Abbey Wood Railway Station. The GWT is also intended to terminate there [6.1114]. Abbey Wood Station lies close to the Harrow Manorway/Knee Hill corridor, where there is concern amongst objectors as to the impact the TGB scheme would have on congestion. 9.124 I share the concern of objectors that there is no means of assessing the overall effect of these different and separately considered elements of what is put forward as a package of measures to improve accessibility and public transport with a view to achieving regeneration. 9.125 The statutory London Economic Development Strategy, prepared by the LDA on behalf of the Mayor of London and published in January 2005, clearly identifies the TGB as important to delivering regeneration and development in East London [4.230].
508
9.126 The strategic contribution which the TGB would make to supporting a more sustainable future pattern of development for London, together with TfLs commitments to mitigate negative environmental impacts as set out in the ES, are consistent with the Mayors Environmental Strategies, which address air quality, noise and biodiversity issues [4.231]. 9.127 PPS 1 deals with Government policy guidance on Delivering Sustainable Development. The principle of sustainable development is a common theme throughout recent Government policy documents. It acknowledges that development should continue, but it implies that it should only take place where it does not use natural resources or pollute the environment to an extent that it leaves future generations unable to continue to develop or to meet their needs [4.234]. 9.128 TfL contend [4.235] that the sustainable development by: TGB scheme embodies principles of
a. providing a bridge that will meet the economic and social needs of existing and future generations to cross the River Thames in East London; b. including a range of transport modes by means of lanes dedicated for private vehicles, public transport, walking and cycling, with the opportunity of introducing rail based transport in the future; c. reusing former industrial land for the route of the scheme; d. enabling the regeneration of brownfield sites located north and south of the river; e. incorporating measures to protect existing biodiversity; and f. providing an ecologically diverse landscape framework for the proposed highways. 9.129 Objectors claim that PPS1 places importance on the need to manage patterns of urban growth to make the fullest use of public transport and to avoid reliance on car travel for access to jobs, health, education, shops, leisure and community facilities, open space, sport and recreation. But they consider that the scheme would have that very effect. It would fail to minimise the need to travel. It would not maximise use by non-car modes. It would promote car-oriented travel with spread out development, contrary to the aspirations of the Sustainable Communities Plan. Objectors argue that the scheme would not promote a pattern of sustainable development, which should be the way forward [6.536]. 9.130 Traffic restraint is important in London, but objectors argue that the claimed reduction in cross river travel times for car drivers would encourage car use,
509
and be contrary to the sustainable transport advocated by the Mayors Transport Strategy and Government policies [6.894]. 9.131 Objectors therefore argue that the scheme would induce extra traffic, reduce air quality, increase carbon dioxide emissions and do little for pedestrians. This would be inconsistent with PPS1 [6.1375]. 9.132 TfL counter that the TGB would contribute to sustainability by supporting a pattern of development which would help to avoid the dispersal of Londons growth to areas beyond its boundaries, where it would be likely to generate significantly higher car use. The Do Minimum assessment includes a number of public transport schemes, and shows public transport use increasing by 35% compared to an assumption of only a 10% increase in car use despite growth in population [6.126]. 9.133 I consider that the encouragement of the containment of development within Londons boundaries is a strong point for the scheme in relation to sustainability. The extent to which it would encourage car use is a matter to which I turn in considering issue (b) below. Prematurity in relation to the emerging Greenwich UDP 9.134 Paragraph 17 of The Planning System: General Principles 2005 sets out the circumstances in which it might be justifiable to refuse planning permission on grounds of prematurity where a Development Plan document is being prepared or under review [4.204]. Those circumstances do not apply in this case, because approval of the TGB would not predetermine decisions about the scale, location or phasing of development which is being addressed in the emerging UDP [4.205]. The principle of the river crossing is established by Policy M9 of the adopted Greenwich UDP [4.197]. 9.135 Policies supportive of the TGB were retained in the review of the Greenwich UDP despite objections [4.205], and the emerging UDP is likely to have been adopted by the time a decision is reached on these applications. 9.136 I conclude that the main bridge application to Greenwich (ref: 04/1800/F) is not premature having regard to the establishment of the principle of a river crossing in the adopted UDP and the progress towards adoption reached by the emerging Greenwich UDP. 9.137 Overall on issue (a), it is necessary in my view to consider other issues listed in the Statement of Matters before reaching a conclusion. I therefore return to issue (a) below from paragraph 9.408. Issue b - Compliance with national planning policy on transport - PPG13 The impact of the proposal on traffic generation and overall travel patterns having regard to the desirability of achieving development that minimises the need
510
to travel, particularly by private car 9.138 Paragraph 4 of PPG13 (D637) establishes that the PPG seeks to integrate planning and transport in order to achieve three objectives. The third of those is to reduce the need to travel, especially by car. 9.139 The promoters evidence is that, if the scheme were built and the land uses in the study area kept common to both cases, the average amount of traffic in the whole area affected by the scheme would, throughout 2016, be about 610,000 vehicle-kilometres per day more than if the scheme were not built. This would be an increase of about 1.75% throughout the area [4.163]. Over eighty per cent of the traffic on the bridge would be cars [4.141]. 9.140 For the reasons given elsewhere in this report from paragraph 9.38 above, it seems to me that the traffic modelling that led to this evidence is of limited reliability. Nevertheless, there is no evidence that the model overestimates traffic flows to such an extent that it could be argued that there would be no traffic increase, and no such argument was put at the inquiry. 9.141 The promoters argue that the scheme would encourage a form of development that would be less car dependent than the likely alternatives [4.16]. The application of car parking standards in areas which would be served by the TGB provides an indication of how the PPG13 guidance to reduce reliance on the private car is being implemented in practice. The London Plan requires Transport Assessments to be prepared where developments have significant transport implications. Public Transport Accessibility Levels have been adopted to produce consistent London wide public transport access mapping. Residential development at higher densities and with lower car parking provision is encouraged in areas with high Public Transport Accessibility Level scores or where sites are close to town centres [6.525]. 9.142 In relation to developments close to the TGB, the public transport services over the bridge would help to improve the accessibility scores of adjoining areas. There would thus be a reduction in parking provision for dwellings with good access to public transport. Development would take place at higher density as a result, however, and that would lead to an increase in the number of trips by visitors and trips to supply goods and services. Even with a strategy which seeks to reduce reliance on the private car, therefore, the car would still have an important role to play in the Thames Gateway [6.526]. 9.143 TfL also point out that, according to their estimates, much of the traffic increase associated with the scheme would be on the new bridge and the approaches to it, and about a further one third would be on the A13, A406 and A2016 [4.141]. Such roads are predominantly purpose built, high capacity roads [4.152]. However, I note that PPG13 (D637) seeks to reduce reliance on the car, and does not distinguish in that regard between
511
car use on roads of different types. 9.144 Certainly, PPG13 recognises that the car will still have an important part to play in transport in the future, but the PPG qualifies that opinion by suggesting that for some journeys, particularly in rural areas, it will remain the only option for travel. Clearly, PPG13 seeks to encourage less travel by car in urban areas such as the area which would be affected by the TGB [6.494]. 9.145 The evidence is that if the scheme were built, then there would be more traffic than if it were not built. In fact, the aim of the TGB is to enable people to travel further within a given journey time, whether by public transport or by car. The criterion of accessibility used by the promoters treats people travelling further to make 45 minute journeys by car as a benefit. The whole justification of the TGB is based not on reducing the need to travel, but on increasing it. It is the explicit intention of the promoters of the TGB to increase catchment areas rather than to reduce them [6.478]. 9.146 T2000 identifies that trips classified by TfL as local (because they would be made wholly within the four Boroughs) could be as long as 22 km, and that other trips so classified (because they would either start or end in the four Boroughs) could be of any length at all [6.480]. Car journeys would form the majority of trips across the bridge [6.514] and such trips would be likely to be longer than the current average length of car trips in London [6.479]. The evidence is that total annual average daily traffic on the whole modelled network in 2016, measured in vehicle kilometres per day, would increase by about 1.75% as a result of the scheme [4.163]. The scheme would facilitate commuting by car. 9.147 The promoters evidence is that the aim of the scheme is not to assist very long journeys, but to make possible short cross river trips [6.517]. They say that its aim is to improve accessibility, not to increase traffic [6.504]. Whatever the aim, it seems to me that an effect of the scheme would probably be to accommodate more long distance travel than predicted by the promoters, both in routine circumstances [6.479] and additionally when congestion occurs at the Blackwall Tunnel or the Dartford Crossing. 9.148 The evidence is that traffic delays due to incidents at the Dartford Crossing or at the Blackwall Tunnels often occur. Incidents during the day at Dartford often result in queues more than 1.6km long, queues of around 5km are common in the rush hour and 8km queues or longer are not exceptional [6.1429]. Traffic announcements on the radio frequently mention restrictions at the Blackwall Tunnels, where (despite evidence which originally conflicted wildly) it was eventually established to my satisfaction that there are about three closures per month [6.1430, 6.1442]. 9.149 Traffic on the M25 between the M11 and the M20 (other than on the
512
Dartford Crossing) usually travels faster than 30 mph and so, in the usual case, would out-pace traffic travelling between the same two roads via the scheme [4.180], thereby removing an incentive for M25 traffic to divert via the scheme. 9.150 Since traffic on the M25 is expected to increase [4.182], since there is no evidence of proposals to increase the capacity of the Dartford Crossing, and since changes in the width of the M25 to either side of the Crossing [4.182] would have no effect on traffic delays caused by exceptional events at the Dartford Crossing, it seems to me that the exceptional traffic delays that arise there are likely to continue and perhaps increase during the period up to the 2016 assessment year. Such delays are not reflected in the traffic model, and yet are likely to increase the propensity of drivers to divert from the M25 to routes that use the scheme. 9.151 It therefore seems to me that the balance of probability is that, from time to time, long distance through traffic would transfer to the scheme from the Blackwall Tunnel and the Dartford Crossing as a result of atypical conditions at those locations. 9.152 Hence my conclusion that the scheme would probably accommodate more long distance travel than predicted by the promoters, both in routine circumstances [6.479] and additionally when congestion occurs at the Blackwall Tunnel or the Dartford Crossing. 9.153 I conclude that the scheme would not reduce the need to travel, especially by car, and so it would not contribute to the third objective in paragraph 4 of PPG13. Maximising use by non car modes of travel, particularly public transport, cycling and walking 9.154 The second objective identified in paragraph 4 of PPG13 is to promote accessibility to jobs, shopping, leisure facilities and services by public transport, walking and cycling. 9.155 The scheme would provide a new cross river corridor for public transport, initially buses, that would connect to further busways on either side of the river [4.29, 4.37]. It would significantly improve public transport journey times and reliability [4.175]. Yet it would result in a marginal reduction in public transport patronage [4.163]. The evidence is that the areas public transport system with the scheme would be less well used than it would without the scheme [6.579]. 9.156 TfL argue that the full impact of the proposed river crossings for public transport in East London can only be seen when the DLR Extension to Woolwich and Crossrail are taken into account [4.147 to 4.149, 4.242, 6.117], but in my view there is no certainty that Crossrail will proceed. The TGB therefore needs to be considered on its own merits, a conclusion
513
reached at the Examination in Public of the draft London Plan in 2003. 9.157 On that basis, although (as indicated at paragraph 9.105 above) I believe that the scheme would improve conditions for public transport, I consider that it would not successfully promote the use of public transport. 9.158 The scheme would also provide a new river crossing for cyclists and pedestrians, and would provide connections between the cycleway and footway networks on either side of the river [4.28, 4.31]. But, for the reasons I give from paragraph 9.86 above, its potential usefulness for those purposes would be small. If the scheme were built, walking and cycling in the four nearest Boroughs would fall [6.293]. The scheme would therefore not successfully promote walking or cycling. 9.159 I therefore consider that the scheme would not contribute to the second objective in paragraph 4 of PPG13. The impact of the development on congestion in the local area 9.160 Paragraph 3 of PPG13 refers to the Governments overall approach to addressing the needs of motorists, other road and public transport users, and business, by reducing congestion and pollution and achieving better access to development and facilities. 9.161 Objections were made that the scheme would in fact increase traffic congestion because of the impact of induced traffic [6.905] and because of the failure to recognise that, given the extent of congestion on the M25, the TGB would prove to be an attractive alternative for long distance traffic to the existing river crossings at Blackwall and Dartford, even when those crossings are not subject to disruption [6.718]. Objectors believe that, even if the route crossing the Thames via the scheme were not signed from the A2, drivers would be aware of the possibility of following that route by virtue of maps, the internet or satellite navigation systems [6.716]. 9.162 TfL respond that lower base traffic would not mean that the model would under estimate the scale of induced traffic [6.235]. They contend that satellite navigation systems offer the option of excluding tolled roads and tend to direct traffic along more major roads [6.800]. I note that setting a satellite navigation system to exclude tolled roads would, however, also exclude the Dartford Crossing. Quite apart from satellite navigation systems, people using maps or the internet to discover route options would see the possibility of using the TGB. 9.163 TfL also state that Document TfL/211 shows that, with the exception of the Dartford Crossing, traffic on each link of the M25 between the M11 and the M20 travels at more than 30 mph at nearly all times. For much of any route to or from the scheme, 30 mph would be the maximum achievable, and speeds would generally be much lower. According to TfLs assessments of travel time, longer distance travellers using the new bridge would lose
514
time as well as paying a higher toll than at Dartford [4.180, 4.181]. In normal circumstances the journey time between the M11 and the A2 via the M25 would be considerably shorter (37/39 minutes) compared to the trip via the TGB (61/69 minutes). That being so, quite apart from the 2 additional toll on the TGB, there would be no reason why drivers should want to travel through the congested area of central Bexley [8.36]. 9.164 This is also supported by the Highways Agency in a written representation [7.32], though the point is made that this is based on the traffic model prepared for the scheme, which the Highways Agency do not necessarily endorse [7.33]. 9.165 I recognise these points, but it seems to me that, in view of the likely wide awareness of the scheme as providing a long distance route option, the balance of probability is that more long distance through traffic would routinely transfer to the scheme than the promoters evidence suggests, quite apart from that which would transfer when there were delays at the crossings at Blackwall and Dartford. 9.166 To the north of the site for the TGB, there is existing congestion on roads in Newham [5.28] and Redbridge [5.59], but the roads concerned are mainly dual carriageway, high capacity routes [6.8], and the Boroughs concerned are prepared to accept the impact of the scheme given the availability of tolling as a control mechanism and the provision for mitigation measures contained in the Boroughs Agreement. The A13 in Newham is to be improved at relevant locations before the TGB would be built [4.93], and the particular problems in Redbridge are to be the subject of a study by TfL during 2006/7 [4.161]; the A118/A406 junction is already identified for monitoring in the Boroughs Agreement. 9.167 The LTGF made the general observation that large, high capacity roads with limited junctions are more susceptible to traffic congestion than finer road networks [6.867]. The largest such road affected by the scheme is the A406 and, notwithstanding the objection of the LTGF [6.911], the evidence is that the A406 north of its junction with the A13 would have sufficient capacity to accommodate the additional traffic the scheme would introduce during the AM peak [4.160]. The LTGF also expressed the opinion that the scheme would generate other traffic that would overload other roads and reduce journey reliability [6.867], but no basis is given for that view, and so I assign little weight to it. 9.168 To the south of the Thames, the bridge would deliver traffic to the A2016, a dual carriageway, but a high maintenance route, which is sinking into the marshes, and is subject to a bid for expenditure on maintenance in virtually every year [6.8, 6.1172]. Some 4km further along that road is the Erith roundabout, which is an existing bottleneck, which would be difficult to improve [6.1365]. Objectors have concern, therefore, that some of the traffic using the TGB would approach it and leave it to the south of the river by way of Harrow Manorway and Knee Hill (A2041), or by other local residential roads unsuitable for heavy traffic [6.37 to 6.40, 6.683 to 6.693],
515
which would bring poorer living conditions for residents there [6.678]. Objectors from Bexley also make the point that, when the traffic model was rebased, TfL chose not to revise their assessments of traffic in the interpeak period [6.797]. The objectors contend that people who live in the area affected by the scheme use the roads between the peak periods, and would be affected by increases in traffic at those times [6.715]. 9.169 The promoters respond that additional congestion with the scheme would be limited and is allowed for in the model. They consider there to be no reliable evidence of the effect of the scheme other than that provided by TfL [6.792]. TfL also state that the A2041 corridor is entirely comprised of London Distributor Roads, whose function (according to Policy G18 of the Bexley UDP) is providing through traffic movements and links to the national road network. Knee Hill and Harrow Manorway are classified as A roads [6.86]. LB Bexley would be able to press the case for any necessary improvement measures under the Unilateral Undertaking. 9.170 There is, however, no proposal before me to widen or alter Knee Hill [6.810]. 9.171 Despite the concerns expressed by objectors, there is evidence that Knee Hill technically has sufficient capacity to accommodate the traffic flows likely to use it in 2016 with the scheme in place [4.157]. Its accident record is not exceptional [6.737]. Its junction with the A206 would if necessary be modified (by banning some movements in the junction) in response to increased traffic flows [4.156]. It is clear that AGABs concern about a consequent traffic increase on Brampton Road [6.739] is the result of a misunderstanding of the promoters evidence [6.811]. 9.172 Congestion at the junction of Knee Hill with Harrow Manorway would, however, increase as a result of the scheme [4.157]. Knee Hill itself is a two lane, single carriageway with the character of a country lane. There is no footway along most of its length, and the width of the whole carriageway varies from 6.5m down to 5.1m [6.737]. It was removed from a bus route some years ago, because it was considered too dangerous to maintain a bus stop on the road [6.1351]. The video camera survey which accompanies Document TfL/295 graphically illustrates the potential problems of driving in Knee Hill [6.741]. Regardless of its designation, its status or its theoretical capacity, Knee Hill is not a road in which, in my view, the arrival of additional traffic could be viewed with equanimity. 9.173 As regards rebasing the traffic model for the interpeak period, TfL argue that the concern raised regarding the traffic model in the early part of the inquiry was the level of traffic in the peak periods. TfL agreed, however, that it is probably the case that the interpeak model underestimates the base level of traffic [6.709]. 9.174 One objector, Mrs Ida Brown, who was concerned about the impact of traffic congestion in Bexley, carried out her own traffic counts in Pickford
516
Lane, Bexleyheath [6.1423], because she did not accept the figures for traffic along that road predicted by TfLs Reference Case Model [6.1421]. She established that the present day figures for traffic along the road are greater than the predicted figures in 2016 [6.1425], which she considered to demonstrate that there could be no confidence in the predictions of the model [6.1424]. TfL respond that the revised traffic prediction for Pickford Lane delivered by the Cordon Model closely matches Mrs Browns surveys [6.1438, 6.1439], and that peak hour flows on Pickford Lane would be lower with the scheme in 2016 than without it [6.1436]. I consider that, if anything, Mrs Browns traffic counts offer a small measure of support for the Cordon Model. 9.175 AGAB cited a written representation by Dartford Borough Council that an increase in traffic on the A206 to the west of the M25 would be undesirable [6.686]. But there is no evidence that such an increase would arise as a result of the scheme; rather, the evidence of the traffic model is that traffic there would be reduced [6.793]. 9.176 Objectors claim that the granting of planning permission for the Belvedere Incinerator (which was the subject of a public local inquiry running while the TGB inquiry was in session), would add many further very large vehicles to the roads in Bexley [6.699]. Objectors also argued that residential redevelopment of the former St Josephs Annex to Bexley College had recently been permitted, and that this would also add traffic to the Knee Hill/ Woolwich Road junction [6.607]. 9.177 I do not consider that these are matters of significance in relation to congestion. If the Belvedere Incinerator were to be built in accordance with the planning permission now granted by the Secretary of State, the traffic impact on the overall network would be minimal. The proposal is that the majority of waste movements would be made using river access. Normal daily traffic movements to and from the site would be 192, of which 16 would take place in the morning peak. Similarly, the proposed change of use at St Josephs Annex is estimated to generate between 13 and 26 vehicle movements in the AM peak hour, an insignificantly small number in the context of the overall changes in traffic levels [6.795]. 9.178 The need for traffic mitigation measures has been established systematically, so far as the model allows, on the basis of defined intervention levels, an approach which the promoters consider analogous to that of nationally recognised guidance for transport assessments [4.151]. The intervention levels used, which are a 2% traffic increase at junctions where the ratio of traffic volume to capacity would exceed 85% or a significant increase elsewhere, seem to me to bear comparison with the thresholds of 10% or 5% at sensitive locations set in DTLR Circular 04/2001 and cited by Bexley Council and others [6.23]. In considering the need for mitigation of possible severance, the promoters have used a 30% traffic increase threshold, and that is consistent with the advice of the DMRB [4.151].
517
9.179 The promoters and four of the five Borough Councils nearest the scheme (but not Bexley Council) propose that mitigation of the traffic effects of the scheme, where necessary, is addressed through the mechanism which the Boroughs Agreement and Unilateral Undertaking would establish [1.64 to 1.66, 4.155,4.156, 4.433]. 9.180 General objections were made that typical urban traffic mitigation measures can cause loss of access or other disadvantage to frontagers [6.575, 6.1153], merely displace traffic to surrounding roads [6.744], or that they can increase danger and discomfort for cyclists [6.640]. No evidence was given to support these views, or to show that they would be directly relevant in this case. Nor was any need demonstrated by the LCC to support their objection that no mitigation measure is proposed specifically to help cyclists [6.640]. I attach little weight to these objections. 9.181 At some locations, the model shows that traffic congestion would reduce as a result of the scheme [4.157]. Elsewhere, for example at the Harrow Manorway/Yarnton Way junction with the proposed mitigation measures [4.53] and at the Harrow Manorway/Knee Hill junction [4.54], it shows that congestion would increase. At times, the A13/A406 junction as modified by the scheme would have difficulty in accommodating the peak period traffic that the traffic model indicates would seek to use it, as it does today [4.150]. But the model has limited reliability, and so the findings of the performance modelling of the junction cannot be regarded as robust. Therefore the possibility would exist for increased congestion at these locations as a result of the scheme. Although the promoters might respond to such a situation by raising the tolls a suitable amount above the levels they proposed at the inquiry (providing the Toll Order allowed that), such an increase would be likely to reduce any regenerative effect the scheme might have. 9.182 The position regarding Crossrail adds a further complication. If approved in the form described to the inquiry, a branch of Crossrail would terminate at Abbey Wood station. Parking provision near the station would reduce, but TfL expect that more people would travel there by bus and that more would be dropped off there by passing cars [6.79]. TfL assume that any traffic effects that Crossrail might have on Harrow Manorway would be addressed as part of the Crossrail project, and the traffic assessment for the TGB makes no allowance in that respect [4.49]. There has been no assessment of the combined effect of the scheme and Crossrail [6.78]. 9.183 The transport assessment for Crossrail takes no account of the traffic arising from the TGB that would use Harrow Manorway [6.44]. Without Crossrail, congestion in Harrow Manorway would increase as a result of the scheme and its associated mitigation measures [4.53, 4.54], and the Crossrail transport assessment finds that Crossrail would increase traffic further, there and on nearby roads [6.44]. It seems to me that this would worsen traffic conditions there to an extent that has not so far been considered.
518
9.184 LTGF argued that any permission for the TGB scheme to proceed should be conditional on the award of the main Crossrail contract and the start of works [6.921]. That is not a position I would support, because I do not believe such a condition would be relevant to the development for which permission is sought in this case, namely the TGB. Other objectors also argued that no decision should be taken on the TGB without a decision being reached on Crossrail [6.1237]. 9.185 It seems to me to be likely that a decision will be reached on the TGB well before there would be any question of letting a contract for Crossrail, even if Crossrail were to be approved. Should the situation arise in which Parliament approves Crossrail and the Secretaries of State are minded to authorise or that they have authorised the TGB, however, I consider that an arrangement would need to be made to identify and if necessary mitigate the combined traffic effect of the two schemes at that stage. 9.186 The scheme proposal includes bridge tolls which could be used to manage congestion, perhaps at the expense of regeneration. Nevertheless, the promoters traffic model indicates that there would be limited additional congestion as a result of the scheme [6.792]. The models assessment of journey times is of limited reliability. I consider that there would probably be more long distance traffic on the bridge than the promoters estimate, adding uncertainty to the assessed need for traffic mitigation measures. And, because the mitigation funding would be limited and the traffic model unreliable, there would be a risk that the funding for traffic mitigation measures would be insufficient, which could lead to further congestion. 9.187 For the reasons set out above, I have concluded that, on balance, the scheme would be likely to cause increased congestion. 9.188 Overall, therefore, I conclude that the scheme would not accord with national planning policy on transport in relation to minimising the need to travel, particularly by private car; maximising non car modes of travel; and in relation to the impact of the proposed development on traffic congestion in the local area. Issue c - Effects of noise and pollution Noise general 9.189 The noise impact assessment for the scheme has been prepared in accordance with relevant guidance [4.248]. The noise predictions have been extended beyond the basic distances from the scheme required by the guidance [4.248, 4.249, 4.251]. The assessment of operational noise was based on predicted traffic flows in 2016 in order to allow for traffic on the proposed bridge to build up to a properly representative level [4.252]. In those respects, it therefore represents a robust assessment of the noise impact.
519
9.190 The assessment is based, however, on traffic predictions produced by a traffic model which I consider to be of limited reliability. I indicate at paragraph 9.63 (d) above that the assessment of the environmental effect of the noise impact of a scheme is relatively insensitive to changes in traffic volume, so that a model of limited reliability is unlikely to give rise to any crucial adverse impact on the validity of the noise assessment. Construction noise 9.191 TfL are committed to using the proactive approach to controlling construction noise involving the consent procedure under Section 61 of the Control of Pollution Act 1974, and suggest the imposition of appropriate planning conditions to achieve this [4.253]. The actual construction programme (estimated to extend for four years) would be finalised only after selection of the contractor, but an indicative schedule of works set out in the ES has been used to estimate the effects of construction noise on the basis of a worst case scenario [4.256]. I consider this to provide a robust assessment. It demonstrates that there is no residential property where the contractor would be required to provide noise insulation during construction under the arrangements TfL would offer as part of the consent procedure [4.255, 4.257]. 9.192 As regards schools, however, there is a real concern that noise levels at the site of the proposed Gallions Reach School would for a significant period be above the 65dB level at which the contractor would be required to aim [4.258]. It is not clear to me for how much of the planned construction period for the bridge the school would be operational; but, if it were to be open while construction was going on, I do not consider the fact that the school would be occupied for only part of the working day, part of the working week, and part of the working year to be an acceptable answer to this problem. The local education authority is exploring with TfL methods of achieving the best possible internal noise conditions within the school [4.272]. The significance of this as an issue was underlined by an objector from Beckton, who complained that her childrens education had been disrupted by construction noise, particularly from work associated with improvements to the A13. Five further years of disruption if the bridge were built would mean that the whole of her childrens school lives had been affected by noise from construction projects [6.1730]. Operational noise 9.193 The final impact assessment of operational noise is based on the use of low noise road surfaces throughout the scheme and the installation of barriers to reduce the noise impact on all sensitive properties which would otherwise face a noise increase of 5dBA as a result of the scheme [4.262]. 9.194 The normal approach has been followed of regarding a change of 3dBA as the minimum change in noise level which would be noticed, but regarding a change of 1dBA as perceptible in the immediate aftermath of the completion of a development [4.263]. On that basis, 7,260 properties
520
would experience a long term increase of traffic noise of 1dBA, while 3,867 properties would experience a similar decrease [4.264]. The absolute value of the resulting noise levels would be below the WHO limit for the onset of moderate community annoyance. Contrary to the claim in paragraph 6.456, I am satisfied that no property would qualify for noise insulation under the Noise Insulation Regulations 1975 as a result of the scheme [4.265]. 9.195 Applying the DMRB method of assessing noise impact, immediately following the implementation of the scheme, there would be an increase of 4,569 in the predicted total of people bothered by traffic noise, but this would fall to 85 people when the response to traffic noise returned to a steady state [4.266]. In my view, this is a small number in what is, overall, a densely populated area. Objectors say that this means that people accommodate to a change in circumstances, but that their quality of life is still reduced [6.392, 6.782]. TfL counter that it is perceived quality of life which is important to an individual [6.409]. 9.196 The effect of a 25% increase in predicted traffic was assessed as a sensitivity test. This would indicate that an additional 124 people would be bothered by traffic noise in the short term, with an additional 20 (making a total of 105) bothered in the long term. Again, no property would qualify for noise insulation [4.267]. 9.197 Both the test contained in PPG24 and that contained in the DMRB would indicate that no property should experience a change in levels of sleep disturbance as a result of the TGB scheme [4.269, 4.270, 6.1051]. 9.198 There would be increases in traffic noise as a result of the operation of the scheme at Woolwich Polytechnic School and at the proposed Tripcock Park and Gallions Reach Schools [4.271]. The significant increases which would arise are the result, however, of current background noise levels being so low [4.271]. Again, the local education authorities concerned are discussing with TfL methods of achieving the best possible internal noise levels at the schools [4.272]. 9.199 Objectors argue that, if planning permission were to be given for the TGB, conditions should be imposed to require noise barriers to protect the Crossness Nature Reserve and Crossness Southern Marshes from increased noise levels from additional traffic on the A2016 [6.1175]. As noted at paragraph 6.1175, following a site visit, this is not a view which I share. TfL do not accept the case for any additional protection [6.1203]. I note that the Managing the Marshes document (which was a bidding document) did not argue for any additional noise protection of these sites. 9.200 Objectors also claim that the lack of noise around Southmere Lake in Southmere Park (because it is shielded from the A2016 by the bund formed by the Southern Outfall Sewer) underlines how noisy Crossways Park and Franks Park are [6.1176, 6.1177]. Noise levels in public open spaces
521
affected by the scheme would, however, be typical of the levels within parks in London [4.273]. 9.201 Objectors argue that noise at the levels described in the ES has been found to be borderline in increasing blood pressure and perhaps contributing to cardiovascular disease [6.390]. I was referred to no source to support this contention. TfL respond that there is no proven link between noise and these conditions [6.406]. 9.202 None of the site visits which I carried out to an extensive range of properties and locations led me to believe that noise would be a particular problem as a result of this proposed scheme. Air pollution general 9.203 The proposed TGB would be located in the Thames valley at a point where the valley is wide and open. The air quality assessment has therefore covered a much wider area than the immediate surroundings of the TGB and its approach roads [4.282]. 9.204 London has some of the worst air quality in the UK. Between 450 and 1,800 Londoners die prematurely each year as a result of poor air quality [6.1016]. 9.205 Nitrogen dioxide and particulates are the key pollutants [4.288]. They would also be the key pollutants arising from traffic during the operation of the proposed TGB. Dust and particulates would be the key pollutants during construction [4.290]. 9.206 Objectors argue that there is an emerging international recognition that concentrations of fine particulate matter are a particular problem [6.587, 6.835, 6.1736]. TfL respond that although a recent paper by COMEAP reports that the change in toxicity levels associated with an increase of 10 micro grams of PM2.5 particulates per cubic metre of air are now considered to be six times higher than previously thought, the newly assessed risk of harm is significant but low. PM2.5 particles are included in PM10 measurements. For vehicles, most of the particles are in the PM2.5 fraction, so measures to reduce particles coming from road vehicles will affect the PM2.5 fraction more than they will the PM10 fraction in terms of the reduction in emissions of particulate matter from vehicles [6.844]. 9.207 Under the Environment Act 1995, the Government produces an Air Quality Strategy. This sets standards and objectives for pollutants. Objectives are policy targets for the Government [6.441]. There is a statutory objective for nitrogen dioxide and a non-statutory provisional objective for particulates [4.284, 4.285]. 9.208 Existing air quality across the study area was established from local
522
authority monitoring data from 2002. Objectors say that verified data from 2003 should have been used [6.426], but TfL respond that allowance was made to simulate the unusual conditions of 2003. Actual data for that year were not available when the modelling was carried out [4.293, 6.452, 6.1047]. I consider that it is clear that the conditions in 2003 were adequately taken into account in the overall assessment. 9.209 The impact on air quality of changed traffic flows due to the TGB was then assessed, taking account of typical and worst case weather conditions [4.291]. Construction impacts were assessed based on distances from sources of dust and particulates [4.291]. Future baseline air quality was defined by modelling, using a model developed specifically for London at Kings College, London. Some objectors claim that this model has been found to be unreliable [6.1017], but no supporting evidence is provided. The model has been used widely by London authorities [4.295]. 9.210 A considerable improvement in air quality is expected by 2016, partly as a result of lower emissions from new motor vehicles and partly as a result of actions taken in AQMAs. But predicted increases in baseline traffic must also be taken into account [4.296]. 9.211 As with noise, the traffic predictions prepared by TfL are produced by a traffic model which I consider to be of limited reliability. Air quality impact is, however, also relatively insensitive to changes in traffic volume of the level associated with the TGB, so a model of limited reliability is unlikely to give rise to any crucial impact on the validity of the air quality assessment [4.297]. 9.212 It is common ground that the impact of the scheme on air quality is a material consideration in this case [6.414, 6.442]. Air pollution during construction 9.213 Dust emissions during construction can increase dust soiling and PM10 concentrations. From the most important sources, haul routes, there is a residual risk, after mitigation, of soiling effects out to about 100m, whilst for PM10 and vegetation effects may arise out to about 25m. A number of residential properties, allotments, commercial activities, a school and a proposed school, may be affected by dust soiling, with only a few of these also at risk of PM10 effects. Care would also need to be taken to reflect the fact that some of the land which would be affected by excavation and construction is former contaminated land [6.1731]. Construction vehicles would be likely to have a very small temporary impact on pollutant concentrations along the A406, Royal Docks Road and Central Way [4.298]. 9.214 Mitigation would be applied through the CEMM. A range of measures would be used to minimise the potential for dust. A programme of monitoring would be agreed with the local authorities [4.299]. I regard these arrangements as satisfactory.
523
Air pollution during operation 9.215 At present, there are many places in the study area where concentrations of nitrogen dioxide and particulates exceed air quality objectives [4.294]. Without the TGB, it is predicted that the objective for particulates would be met throughout the study area by 2016. The objective for nitrogen dioxide might still be exceeded in some locations [4.296]. With the TGB, on the basis of the Cordon Model traffic flows, there would be a small increase in emissions over the position in 2016 without the TGB [4.297, 4.302]. The increase would be 0.04% above the objective for nitrogen dioxide in Greenwich and 0.4% in Newham [6.448]. 9.216 These are small increases, but, as objectors contend [6.1019] they indicate that air quality would be worse in 2016 with the scheme than without it. Objectors characterise TfLs line as suggesting that, because air quality is poor now and likely still to be so in 2016, a further minor deterioration would not make much difference [6.1579]. 9.217 However, the local authorities whose areas would be affected by air pollution arising from the scheme raise no objection to the scheme on that account. Newham and Greenwich considered this issue before voting in favour of granting planning permission [1.14], and both authorities are now satisfied with the arrangements made to deal with air pollution (amongst other matters) through the Boroughs Agreement [5.8, 5.46 to 5.49]. Both authorities were advised on this issue by professionally qualified officers, who played an active part in the inquiry. In fact, Newhams draft Air Quality Action Plan positively endorses the TGB proposal [5.48]. Redbridge are content that any minor adverse impact on air quality would be outweighed by the overall benefits of the scheme [5.68, 5.69], and Bexley did not raise air quality in evidence as a basis of objection to the scheme. 9.218 As indicated above at the scheme, I reject pollution prepared on new car trips [6.386]. paragraph 9.81 in relation to road safety impacts of the calculations of the impact of the TGB on air the basis that all car trips across the TGB would be I do not regard that as a realistic assumption.
9.219 Objectors refer to a conclusion of COMEAP that each individual has a different threshold beneath which he or she would suffer no adverse health impact. They contend that this means that there is no threshold beneath which it can be said with certainty that there is no harmful effect, and therefore that any increase in pollution is a significant increase [6.418]. 9.220 Objectors argue that the promoters have not provided evidence covering a comprehensive list of the most serious or harmful pollutants [6.834], for example, there has been no rigorous modelling of ozone as a pollutant [6.1020]. TfL respond that the Environmental Impact Assessment Regulations do not require that all pollutants are assessed, but only those which would give rise to likely significant effects, in this case nitrogen dioxide and particulates. Ozone is not a local pollutant, and so its effect would be negligible [6.1048]. This conclusion was supported by the
524
relevant local planning authorities [6.843]. I also agree. 9.221 Objectors argue that respect for local circumstances is important in assessing air quality. There is a long history of serious air pollution in East London, and it is a matter of concern to local people [6.417]. It continues to the present, with children at schools in the area needing to have access to inhalers because of respiratory problems, and schools having to adopt inhaler policies [6.1674]. TfL respond that Greenwich and Newham no doubt took local circumstances into account when they voted to grant planning permission for the TGB [6.445]. Increasing traffic does not necessarily mean increasing pollution. Between 1990 and 2003, car kilometres driven in Great Britain increased by 17%, while emissions of particulates and nitrogen oxides from private cars fell by 41% and 65% respectively [6.1677]. 9.222 Mr Connolly claimed that a reference in the ES to particulate emissions as a result of the scheme being only 0.003% greater in 2016 disguised the fact that this meant some 3 additional tonnes of particulates would be released into the atmosphere in the local area each year [6.418]. TfL respond that the ES actually says that the bridge would increase emissions by 0.003 kilotonnes (which is the same as 3 tonnes), not by a percentage figure. This is the case. In percentage terms, it represents an increase of 0.6% in emissions and an increase of 0.2% in concentrations [6.446]. 9.223 Mr Connolly also claimed that the chief mitigation measure relied on by TfL to address air quality problems was the introduction of a Low Emission Zone, but that the Boroughs Agreement only provided for this to address taxis and buses, not private cars [6.422]. TfL respond that the introduction of a Low Emission Zone is not the chief mitigation measure relied on by TfL. The level of tolls could also be varied to favour low emission vehicles [6.450]. 9.224 A method of assessing the significance of any impact on air quality has been produced by the National Society for Clean Air [6.419], but this has not been used by TfL [6.447]. Neither has it been used by the local authorities in the area to assess the TGB. It is unofficial guidance produced by an environmental campaigning group [6.448]. I consider that the air assessment in this case has been carried out on a different, but perfectly proper, professional basis. 9.225 Objectors next make the point that PPG23 embodies the precautionary principle. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing cost effective measures to prevent environmental degradation. This principle should be invoked where there is good reason to believe that harmful effects may occur to human, animal or plant health or to the environment, and the level of scientific uncertainty about the consequences or likelihood of the risk is such that the best available scientific advice cannot assess the risk with sufficient confidence to inform decision making [6.837].
525
9.226 The precautionary principle requires an assessment of the costs and benefits of action and also transparency in decision making, and objectors contend that TfL have demonstrated neither of these [6.838]. 9.227 Objectors say that the ES should estimate the costs as well as the benefits of the TGB proposal, including the costs arising from reduced air quality [6.430 to 6.434, 6.838]. I agree with TfL, however, that there is no agreed methodology for assigning a monetary value to air quality impacts at present [6.455]. I would certainly not accept a cost evaluation which worked on the basis that all trips over the TGB were new trips which would not otherwise have been made. 9.228 Objectors contend that the promoters evidence on air quality makes no assessment of the potential range of error which might attach to the predictions [6.425, 6.839]. TfL respond that there is no straightforward way to allow for uncertainties in modelling. The air quality evidence simply amounts to the best estimate of what will happen, provided by a very well qualified and experienced witness [6.451, 6.452]. I accept that that is the case. 9.229 Objectors questioned whether the assessment had taken into account the impact of the escarpment which runs from Deptford to Dartford [6.785, 6.1313, 6.1343]. This had been a matter of concern in the past to the local health authority and the LB Bexley [6.785]. TfL confirmed that the air quality analysis did not pay special regard to the meteorological effects of the Deptford escarpment, because it was not considered that it would make a significant difference to the concentrations which were being modelled across the study area. TfL accepted that there might be some very local effects in the immediate vicinity of the escarpment, but it lies at some distance from the Thamesmead area [6.826]. It appears to me to have little relevance to the air quality issues raised by the TGB proposal. 9.230 Objectors also raised the issue of the lack of any consideration of the in combination effects of emissions from the Belvedere Incinerator with the increased traffic which would arise from the proposed TGB [6.1182, 6.1543]. TfL confirmed that this had not been included in the model, but their expert witness stated that it would have only a very small impact on the nitrogen dioxide concentrations. The air quality impacts of the Belvedere Incinerator proposal were no doubt be considered carefully in reaching a decision on that scheme. They do not seem to me, however, to raise any issue with direct relevance to the TGB proposal. 9.231 Objectors claim that the areas in Greenwich through which roads with a high level of pollution run are the areas of greatest deprivation in the Borough. The people the proposed TGB is supposed to benefit by delivering regeneration would thus be the very people to suffer the increased pollution which would arise from the scheme. This might prevent them, through illness, from taking advantage of any employment opportunity which might be created [6.437 to 6.439].
526
Summary of views on noise and air quality 9.232 The noise assessment and the air quality assessment are based on a traffic model of limited reliability, but both noise and air quality are relatively insensitive to changes in traffic volume. 9.233 The assessment of construction noise is based on an indicative schedule of works, but one which assumes a worst case scenario, and that therefore provides a robust assessment. 9.234 There is concern about the level of construction noise at the site for a planned school. This has not been resolved. Further work is also needed to address the impact of operational noise at three schools (two of them still at the planning stage). I am less concerned about this because in absolute terms the predicted level of impact would be much less than the noise during construction. 9.235 For a densely populated area, I consider that the evidence suggests that the number of people bothered by increased operational noise in the long term would be small. 9.236 The air quality assessment has considered a wide study area, but did not include consideration of the interplay on meteorological conditions with a particular aspect of the topography of the area, namely the Deptford escarpment. The view of the promoters expert witness was, however, that this would have made no significant difference to the overall air quality assessment of the issues raised by the TGB proposal. There was no professionally qualified challenge to that evidence. 9.237 I note, however, that it is accepted that air quality would be worse in 2016 with the TGB than it would without the bridge. Despite the equanimity with which the local authorities in the area greet this, it is a matter which causes me concern, which I draw to the attention of the Secretary of State. It is a matter to which I return when considering issues raised by objectors to the proposal concerning health. 9.238 I conclude that the effects of the scheme relating to noise raise no particular difficulty, but that there are some concerns regarding the impact of the scheme in relation to air quality. Issue d - Impact on flora and fauna and on conservation sites 9.239 PPG9 has now been replaced by PPS9 [4.303], and it is against the latter document that the TGB scheme will be judged. The ES predated PPS9, but took into account the Mayors Biodiversity Strategy and the London Plan, both of which take a similar line to that of PPS9 [6.1206]. The methodology used in the ES was agreed with various stakeholders, including EN and the Greater London Biodiversity Team at the outset. It
527
was not challenged at the inquiry by the local planning authorities, by Bexley, by EN or the EA [6.1206]. 9.240 An environmental assessment for the scheme was carried out in accordance with the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999, together with the guidance given in DMRB and in WebTag [4.308, 6.1207]. Baseline conditions were established by a desk study, supplemented by new fieldwork agreed with key consultees including EN, the EA and the Biodiversity Division of the GLA [4.303a, 4.308]. 9.241 Alternative sites for the proposed bridge were considered on the basis of minimising the potential harm to biodiversity [4.303c, 4.306]. Once the preferred route had been chosen, potential land take from sites and habitats of nature conservation significance was reduced during the development of the engineering design [4.303c, 4.307]. 9.242 No internationally or nationally important site would be affected by the TGB scheme. The development would, however, cross two locally important sites, the River Thames and Tidal Tributaries SMI, and the Beckton Ditches and Grassland SBI. Much of the SBI is identified in the Newham UDP as part of a Major Opportunity Zone, however, and the SBI is therefore likely to have been reduced in size and developed before the planned construction period for the proposed TGB [4.303b, 4.313, 4.315]. There are four further SBIs adjacent to the scheme boundary and two further SMIs approximately 1.5km to the east and to the south of the south easterly extremity of the scheme, the Erith Marshes SMI and the Lesnes Abbey Woods and Bostall Woods SMI [4.313, 4.314]. The part of the Beckton SBI affected by construction of the viaduct over the A13 and the realignment of the A406 would amount to around 3ha, which represents about 9% of the current area of the SBI [4.329]. 9.243 The nature conservation value of drainage features such as the three attenuation ponds and the drainage ditch adjacent to the SBI would be maximised by appropriate detailed design and planting [4.331]. The landscaping of the new road corridor would also provide the opportunity for large areas of habitat creation [4.332]. In addition, there is the possibility of reed bed habitat being created within a newly exposed area of shoreline [4.333], and areas of degraded urban wasteland amounting to around 2ha in total being conserved and managed for nature conservation [4.334]. 9.244 Within Newham, a net loss of land of recognised value for biodiversity would be compensated by a payment to Newham under the Boroughs Agreement to spend on work for the benefit of biodiversity within the Borough [4.303c, 4.330]. 9.245 In terms of habitats, there are small areas of reed bed and scattered salt marsh plants on both sides of the River Thames. These are poor examples of habitats of national importance [4.317]. There would be a loss of 19.3ha
528
of habitats during construction of the TGB scheme. After reinstatement following construction, a net loss of approximately 2.5ha would remain [4.325]. 9.246 In terms of species, seven species afforded full or partial protection under the Wildlife and Countryside Act 1981 were identified within the scheme corridor [4.303b, 4.319, 4.320]. All site clearance and construction work would be required to be carried out in such a way as to avoid any impact on protected or priority species [4.303c, 4.326]. 9.247 Objectors raise concerns about the impact of the scheme on the Lesnes Abbey Woods and Bostall Woods SMI arising from the increased traffic which would travel on Knee Hill (estimated by TfL at 19% compared with the Do Minimum) as a result of the construction of the TGB [6.810]. In part, these concerns relate to the suspicion that Knee Hill would need to be widened [6.786, 6.1653]; in part they arise from anxiety regarding the impact of additional traffic and possible extra street lighting on the SMI as a habitat [6.1166, 6.1214, 6.1653]; in part they are caused by fears regarding the potential impact on species in the SMI [6.1166]; and in part they stem from the view that increased traffic would increase severance between Lesnes Abbey Woods and Bostall Woods [6.1167, 6.1653]. 9.248 TfL respond that there is no plan to widen Knee Hill, and that extra traffic appearing on the road would be controlled through tolling [6.1197]. Nor is there any plan to provide additional street lighting there [6.1223]. 9.249 So far as animals are concerned, Knee Hill already has a severance effect by being hard surfaced. Any increase in traffic would not cause a significant effect on wildlife [6.1199]. The SMI operates successfully now with roads passing through the woods, which shows that roads and nature conservation are not incompatible [6.1659]. There was no substantial challenge to the view of TfLs expert witness that the scheme would not cause a material loss of species or habitat [6.1199]. 9.250 I have indicated above my concern that Knee Hill is not really suitable to take additional traffic. I accept that TfL would be able to limit total traffic over the bridge by tolling, but I cannot see that they would be able to influence by tolling what route was taken by traffic which had crossed the bridge. It remains a matter of concern to me that additional traffic would use Knee Hill if the bridge were built. Having said that, if Knee Hill were not widened, then I do not consider that the additional traffic from the proposal would do any substantial damage to the SMI. If Knee Hill were to be widened, it clearly would. 9.251 Objectors raised concerns about the impact of the proposed scheme on bats in Thamesmead [6.787] and at Lesnes Abbey Woods [6.1214], badgers [6.1165], water voles at Crossness [6.1173, 6.1212] and natterjack toads on land outside the scheme area [6.1752].
529
9.252 When the ES was prepared, no bat roost was found in the area. It is possible that bats might have moved into the area since the ES survey took place in 2003, or that they might do so before any planning permission granted in this case was implemented. If evidence of bat roosts were then found, I have no doubt that TfL would comply with their legal obligations. No evidence was produced of an existing problem in relation to road kills of water voles or badgers. The locations concerned would not involve new roads, but additional traffic on existing roads. While logically additional traffic would generate an additional risk, the fact that there is apparently no evidence of a problem at the moment does not lead me to regard this as a high risk. As regards natterjack toads, they are closely monitored, and there is no existing record of their presence at the site specified by the objectors [6.1777]. That site is in any event outside the footprint of the scheme, and there is no suitable habitat for the species within the area affected by the scheme on the proposed southern landfall of the TGB. 9.253 Objectors argued that work to increase access to the marshes south of the river, supported by funds from ODPM, would be put at risk by increased levels of noise and air pollution [6.1174]. I cannot see that recreational use of the marshes would be prejudiced by the scheme. In fact, I share the view of TfL that the proposed bridge would increase ease of access to the marshes by a wider range of people, and would therefore potentially deliver an increased return on the Governments investment [6.1202]. 9.254 I make a similar response to objectors contention that habitat creation north of the river would not effectively replace any damage to or destruction of habitat south of the river [6.1185]. If the bridge is built, it would make sites on one side of the river more accessible to those who live on the other side of the river. 9.255 Finally, objectors raise the issue that the ecological information provided to the inquiry by the promoters was prepared in 2003, and could be out of date by the time a decision on the scheme is made [6.1190 to 6.1194]. The promoters ecology witness revisited the area just before the opening of the inquiry and updated her evidence [6.1209], but that takes the issue forward only to May or June 2005. With a major scheme and a long running inquiry, this is always a potential problem. I note that no substantial new evidence on ecology was produced by any objector during the inquiry. There is therefore no basis on which I can find that the situation described in the ES has changed other than in the respects pointed out by the promoters witness. 9.256 I conclude that, so long as Knee Hill is not widened, the extent to which the scheme would be likely have an impact on the local flora and fauna and on conservation sites is limited. It would be much more substantial if Knee Hill needed to be widened.
530
Issue e - Possibility of securing a high quality of design Detailed issues of scheme design 9.257 I deal first with a number of detailed issues of scheme design, rather than with the design of the bridge itself. 9.258 I consider that the proposals which have been prepared make satisfactory arrangements for surface water drainage [4.39], street lighting (subject to conditions to address the concerns of LCY, the CAA and the PLA) [4.40] and the public utilities [4.41]. 9.259 The parts of the applications which have been designed in detail [1.7] comply with the relevant technical requirements [4.56 to 4.59], save that the proposed cycleways include gradients of 5% which run for more than 100m, contrary to the recommendations of DfT Local Transport Note 1/89, though DMRB gives 5% as the maximum gradient of a footbridge with no limit on length [4.56, 6.649, 6.636]. In particular, the public transport lanes (in the form following the revision of the Barnham Drive Public Transport Loop [1.19, 4.44]) would meet the standards necessary to permit use by trams should a decision be taken at a later stage to provide this form of transport [4.57]. The potential for reconfiguration of the carriageways on the bridge 9.260 I deal next with an issue concerning the design of the scheme which was of particular concern to a number of objectors. The scheme would provide a triple carriageway crossing of the river one for busway use and two for general traffic [4.25]. The busway would be a separate structure with separate access [6.1324]. Objectors raised the possibility of this arrangement being rapidly and readily changed so as to remove the special provision for public transport and to provide three general traffic lanes in each direction [6.576, 6.1252]. 9.261 I agree with TfL that such a change would be complex and costly [4.46]. It would require planning permission and variation of the Orders that were before the inquiry [6.1261]. It seems to me that such an objection that the development proposal could subsequently be materially changed is one that could be made against a wide range of development proposals. If such a change to the scheme were subsequently proposed, then it would be for decision makers to consider all the evidence available to them at that time. But there is no such proposal before me, nor any evidence that such a proposal would be made, and I therefore proceed to consider the matters which are before me on their merits.
531
The extent to which the proposal would secure a high quality of design for the bridge 9.262 Although constraints on the form of the bridge, imposed by navigation, air traffic and other requirements, are described by the promoters [4.61 to 4.72], the final form of the bridge remains a matter to be dealt with by condition. Various parties referred to aspects of the illustrative design submitted with the applications, but that matter is not before me. Here I consider the likely effectiveness of the consideration of design issues within the procurement process in securing a suitably high quality of design [4.430 to 4.351, 4.457]. 9.263 In a written representation, CABE underline the importance of securing design quality in the final form of any bridge to be built in this location [7.13, 7.18]. They welcome the fact that a Design Statement and a Landscape Design Statement (now incorporated in a single document [1.25]) have been produced in connection with the scheme [7.14], and they express the hope that the landscaping element will not be compromised as part of any ultimate cost cutting exercise [7.16]. CABE are not impressed by the illustrative design, and would be concerned if the final selection of the scheme were to be made by TfL on purely economic grounds [7.14, 7.19]. Subject to these points, CABE recognise that the hybrid form of the planning applications is designed to offer design flexibility [7.15], a point also underlined in a written representation by Lord Rogers [5.199]. That last point is at odds with the views of objectors who find it hard to accept that an actual design is not before the inquiry, despite the fact that the symbolic value of the proposed structure is a key component of the promoters case [6.1371, 6.1685]. 9.264 In response, TfL make the point that the representations from CABE were made in October 2004. Since that time, it has been made clear that only schemes which are considered acceptable in terms of design would be allowed to go through to consideration on financial grounds [4.351, 7.20]. A member of the Design Review Panel of CABE is a member of the Design Panel which would assess submissions made by potential concessionaires wishing to design, build and operate the proposed bridge [7.22]. There are plenty of examples of cases where a design competition has resulted in the achievement of a highly successful design solution [4.344 to 4.347]. 9.265 In my view, the success of the procurement process would depend on the degree of priority given by the promoters to the quality of the design, on the quality of the advice available to them, and on the attitude of the local planning authorities who would determine the matters covered by the suggested planning conditions. I have had regard to the general advice in PPS1 (D662) and By Design urban design in the planning system: towards better practice (D664). 9.266 The scheme would be procured through the appointment of a private sector concessionaire to design, build and operate it [4.450]. The promoters identify several successful designs procured through design competitions
532
and variations of design and build contracts, including some with private finance [4.344 to 4.346]. Only design proposals signed off by the Design Panel set up as part of the arrangements for the procurement of the bridge would proceed to the submission of commercial tenders [4.351]. It seems to me that the funding mechanism need create no barrier to good design, and that the promoter would assign a high priority to achieving a good quality of design. 9.267 The promoters would be advised by the Design Panel, the members of which are widely experienced, with backgrounds in architecture, engineering and landscape design [4.350]. The evidence is that the panel would include individuals well suited to the role, and able to offer appropriate advice to the promoters during the selection procedure and design evaluation. 9.268 Greenwich Council and Newham Council gave evidence on the scheme design process [5.13, 5.52]. They welcome the proposed establishment of the Design Panel and the intentions expressed in the Design Statement. They would co-operate in determining the outstanding matters covered by the suggested planning conditions concerning the form of the bridge. Greenwich Council referred to their record of achieving excellent design outcomes [5.13], and this was borne out in my view when I visited sites which they highlighted in their evidence. 9.269 On 31 October 2005 the London Thames Gateway Development Corporation became the local planning authority for the bulk of the scheme to the north of the Thames [1.23]. Newham Council acts as the agent of the Development Corporation in development control matters [1.23] 9.270 In determining the matters covered by the suggested planning conditions, the local planning authorities would base their decisions on the Development Plan. The London Plan and the two UDPs all seek a high quality of design at this location [4.341, 5.13, 5.52]. 9.271 It therefore appears to me that, by virtue of the policy framework established by the Development Plan, the mutual co-operation that would take place between the local planning authorities and their support for the intended design process, there is no reason to suppose that the local planning authorities would act in any way other than one which would lead to a successful design outcome for the scheme. 9.272 I consider that the evidence is that the procurement process, the advice available to the promoters and the approaches being taken by the local planning authorities are all conducive to a high quality of design. 9.273 I conclude that the proposal would, if granted planning permission, be very likely to secure a high quality of design.
533
Issue f - Implications for regeneration 9.274 Government guidance for the appraisal of the wider economic impacts of a transport scheme is set out in the DfTs Transport Analysis Guidance (WebTag) (D524) Unit 3.5.8, which was published in June 2003. By that time TfLs analysis, using its own methodology which it devised for the scheme, was complete. TfLs evidence to the inquiry does not directly apply the WebTag guidance to the scheme, but indicates the extents to which the two different approaches overlap [4.377]. 9.275 Creating new, untried methods creates a source of potential uncertainty [6.281], and this was considered at the inquiry. I therefore consider first, on its own terms, the approach devised by TfL. As the inquiry opened some two years after the publication of the relevant Government guidance, it does not seem to me that circumstances precluded the application of the WebTag method to this case, and I note that the promoters traffic evidence incorporates WebTag guidance [4.81]. I therefore also consider the extent to which the adopted approach on regeneration accords with Government guidance and the significance of any departures. The promoters assessment of potential regeneration benefits associated with the scheme 9.276 The promoters assessment method compares the accessibility of individual wards with their population density and employment density, correlates accessibility with each, and then uses those correlations to establish the potential changes in employment and population density in each modelled ward in London [4.375] that would arise from the accessibility changes caused by the scheme. This approach was challenged on several grounds: a. That hugely varying employment densities can be found at every level of accessibility; that the promoters method has an incorrect appearance of precision and includes no error assessment; and that, without an assessment of the degree of error in the modelling, there is no indication of the reliability of the models findings: although more often than not an increase in accessibility will improve employment [6.981 to 6.984]. The promoters agree with this final point, and have reasonable confidence that the potential modelled by their method would exist if the scheme were carried out [6.1004]. b. That the wrong variables had been modelled; modelling IMD rather than employment density and population density finds good accessibility to be associated with high (poor) IMD ratings at the Borough level [6.987]. TfL did not dispute this. c. That there is a positive correlation at the Borough level between accessibility and the number of job seekers. If so, and if the scheme were built and accessibility improved as a result, the number of job seekers would be likely to rise [6.987]. The promoters reply that the
534
Borough-level data provided in their case are not intended to be used in this way and are distorted by local features [6.1000, 6.1001]. d. That the poor reliability of modelled journey times in the traffic model renders unreliable the assessment of accessibility changes consequent on the scheme, upon which the regeneration case rests [6.35]. e. That the model, whose central premise is based entirely on modelled relationships, is not validated or verified [6.306, 6.307]. The promoters response to this is twofold: that it is commonly accepted by academics and practitioners that a relationship exists between, on the one hand, accessibility and, on the other, population and employment densities; and that in London the available evidence supports the approach [4.375]. Such a consensus is reflected in the opinions of CB Richard Ellis, who considered the commercial benefits of the scheme to be substantial, though unquantifiable [6.552], and several supporters of the scheme, including Newham Council (who considered that the bridge would bring forward the development of sites) [5.26, 5.27], Greenwich Council (who argued that previous links had led to regeneration) [5.4], Redbridge Council (who regard a link from their area to South London as a matter of prime importance) [5.61], the TGLP [5.86, 5.87], GTL (who say that the bridge would help retain existing employers as well as attracting inward investment), London First [5.125], the London Development Agency [5.147] and the London Thames Gateway Development Corporation [5.156 to 5.159]. f. That there is no assessment of the possible two-way street effect [6.306]. But TfL reply that the toll regime would favour local users; that the areas at each end of the scheme would be similar and so neither would have a particular advantage; and that both areas linked by the scheme would be better able to participate in the success and growth of the area [6.291]. It seems to me that any such effect that might arise from the scheme would be likely to be small. g. That the model is sensitive to changes in the tolling regime, which has yet to be confirmed and which might change again in future [6.306, 6.307]. 9.277 The promoters model relies on a uniform travel to work time of 45 minutes as the average for London [4.380], and bases its assessment of accessibility on that [4.372]. But the Mayors Transport Strategy reports that the average travel to work time is not uniform throughout London; it varies between Central, Inner and Outer London [4.380]. Much of the area affected by the scheme would be in Outer London. In 1999, people in Outer London travelled, on average, for only 31 minutes to get to work. But it seems to me that, as the model assumes that they will travel for 45 minutes, the number of locations they can reach (or would be able to reach if the scheme were in place) within their average travel time is likely to be substantially overestimated. If so, the accessibility effect of the scheme would also be overestimated, and hence, according to the model, its
535
regenerative effect too. The remainder of the area affected by the scheme would be in Inner London, where a travel to work time of 42 minutes was the average; and so, to a lesser extent, the schemes benefits to Inner London are also likely to have been over optimistically modelled. If this were not so, the implication would be that people would be willing to travel for longer as a result of the scheme, for which there is no evidence, and the amount of travel associated with the scheme would be increased. 9.278 TfL quite clearly do not suggest there to be a causal link between accessibility and the densities of employment and population [4.376]. What the proposition does offer has a number of components: a. That there was an association between accessibility and the densities of employment and population in 2001, which the model represents adequately. The evidence is that such an association existed. But the evidence of the reliability of the modelling of that association is only that of a sizing calculation by the SWCF [6.984] which the promoters then adopt [6.1004] in their conclusion that the balance of probability is that the scheme would remove a constraint from the realisation of the regeneration benefits identified [6.1005]. The evidence also indicates an association in 2001 between accessibility and deprivation, but this does not feature in the promoters assessment of the effects of the scheme. b. That the accessibility/population and employment densities relationship that will exist in 2016 will have characteristics sufficiently similar to the model of the 2001 relationship to allow reliable predictions of potential regeneration to be made on the basis of projected accessibility changes. There is no analytical evidence to support this, for 2016 or any other year [4.376]. Rather, the promoters rely on consensus among academics and practitioners that there is an accessibility/people and jobs relationship. c. That the projected accessibility changes associated with the scheme have been modelled with adequate reliability. I have previously concluded, for the reasons given, that findings which are sensitive to errors in assessed journey times will be of limited reliability, and this is such a case. For the reason given in paragraph 9.277, it seems to me that the modelling of accessibility is based on a premise inconsistent with evidence in the Mayors Transport Strategy, and is therefore unlikely to be reliable. Nevertheless, the evidence is that the scheme would improve accessibility [4.386]. d. That no changes to the toll regime would be made that would prejudice the modelled regenerative effects of the scheme. The changes made to the tolling proposals during the inquiry showed the regeneration model to be sensitive to such changes [6.304], and further changes are countenanced by the promoters [4.145], by Redbridge Council [5.67] and by Greenwich Council [6.735]. This introduces an element of uncertainty into the model.
536
e. That other measures, necessary to realise the potential for regeneration that the scheme would create, would be implemented successfully. The evidence is that programmes of such measures are in place and would continue [4.396 to 4.399; 5.142, 5.143]. 9.279 The promoters drew a comparison, at Borough level, between economic conditions in East London with its few river crossings and West London, which has more bridges [4.374]. Since accessibility does not significantly differ between the East London group of Boroughs and the West London group [6.976], and since the promoters explain that the comparison was intended to be merely illustrative and did not form the basis of the analytical results [6.1000], I assign very little weight to that comparison. 9.280 In summary, the scheme would increase accessibility, and, in the opinion of the promoters and several supporters of the scheme, such an increase would be likely to lead to consequential increases in population density and employment density. There is also evidence that a consequence of better accessibility would be more deprivation, and it seems to me that this is not necessarily inconsistent with high densities of population and employment. But the promoters assessment gives no reliable measure of the changed accessibility the scheme would bring or of its consequences in the economy. Claimed inconsistencies between TfLs traffic and regeneration cases 9.281 Professor Goodwin identified what he considered to be an inconsistency between the promoters traffic assessment and their regeneration evidence [6.191]. 9.282 TfLs do-minimum and do-something cases each assume the regeneration which they ascribe to the scheme to be independent of the scheme. The two cases are [6.259]: a. A future situation in which the scheme would not be present, and the regeneration said to rely on it would have occurred (the do-minimum case); and, b. A future situation in which the scheme would be present and the regeneration said to rely on it would have occurred (the do-something case). 9.283 TfL support their position with reference to Government policy in the WebTag that the transport effects of transport schemes should be assessed using constant land use assumptions, and that regeneration benefits should be identified separately: and they have indeed done both of these things. Their constant land use assumption is that which the London Plan predicts [6.259]. But their reference to the WebTag is incomplete; Government policy does not proscribe all alternative approaches. It encourages the use of alternative planning scenarios and land use/transport interaction modelling [6.196].
537
9.284 It seems to me that in this case there is agreement that land use and transport will interact. That is a commonplace. If the promoters estimate of the scale of the land use change were correct, there would be more than 60,000 more residents and over 27,000 more jobs in the London Thames Gateway [6.266], which they estimate to represent population and traffic increases of up to 3% averaged across the whole of that area [6.267, 6.268]. They consider these changes in population and traffic to be relatively small scale [6.269], even though they also consider the scheme to be critical to the development of the Thames Gateway, having one of the four largest effects on increasing the capacity of the region [4.19]. The promoters have not modelled that interaction, because no land use/transport model is available, and because they consider the preparation of one would have been too great a task in comparison to the scale of the issue [6.280]. They have not tested any alternative scenarios to the London Plan outcome, because any scenario tested should be realistic and, in their view, the scenario in which the goals of the Regional Transport Strategy, the London Plan and the Mayors Transport Strategy are fully achieved is the only realistic one [6.277]. They also consider that if growth were not encouraged in the Thames Gateway, it would happen elsewhere [6.264], either in London [6.272] or in the South East [6.265]. 9.285 I have already noted that the promoters regeneration model cannot be relied upon to any extent to predict changes in employment density or population density that might arise from the scheme. It appears that the absence of any assessment of the nature of the interaction between future land use changes and transport further reduces the models usefulness as a tool to help assess future conditions. 9.286 In considering the traffic model, I have identified its lack of reliability when assessed against the guidance of the DMRB. Those considerations did not include the matters I have set out in the immediately preceding paragraphs, which detract further from the reliability of the promoters predictions. Toll discount area 9.287 When the promoters revised their traffic evidence, at the same time they amended their proposals for the toll discount area, which they made less extensive by excluding an area of the Borough of Bexley so as to make acceptable, in their view, the expected traffic levels in Bexley when the scheme was in place [4.135, 4.139]. Various parties objected to this change on the grounds that it would remove any benefit that the scheme would bring to Bexley, although some traffic from the scheme would continue to travel through Bexley [6.736, 6.1463, 6.1467]; that the revised discount area would be unreasonably small, that some of the newly excluded parts of Bexley rank among the most deprived quartile of wards in England or the most deprived ten per cent of super output areas in England and Wales and that the regeneration objective of the scheme was therefore undermined [6.49]; that a regeneration led project that could exclude deprived areas in East London was perverse and irrational [6.329]; and that
538
the promoters might subsequently change the toll regime again [6.733]. Greenwich Council [6.735] and Redbridge Council [5.67] both said they might seek further changes to the discount area. 9.288 In my view, it is not necessary for a regeneration scheme to benefit the whole population; there are likely to be limits to the area within the UK affected by any particular scheme. Nor is it necessarily the case that those who benefit more will live in the same area as those who benefit less or who are disadvantaged by a scheme. The balancing of such localised inequities against one another is a commonplace in infrastructure and development proposals, which the AST addresses. 9.289 A large proportion of the objections to this scheme arise from its traffic effects, and the promoters evidence is that, had the proposed discount area remained larger in Bexley as originally proposed, that would be likely to give rise to excessive levels of traffic congestion in that area [4.139]. There was no evidence to the contrary. 9.290 I therefore attribute little weight to arguments that had the proposed discount area been bigger, greater regeneration benefits might arise from the scheme or more people in a particular Borough might benefit, and that the scheme is therefore not acceptable. The promoters proposals for the extent of the discount area are clear, and my recommendations relate to those proposals. 9.291 However, I note elsewhere that the discount area might be changed in future, and that this adds to the uncertainty about the regenerative effect of the scheme. I allow for that uncertainty in making my recommendations. Accordance with Government Transport Analysis Guidance 9.292 Transport Analysis Guidance on the wider economic impacts sub-objective addresses the stimulation of economic activity in regeneration areas in terms of jobs and employment [4.377], but not in terms of population growth resulting from transport schemes. Since the regeneration that the scheme would seek to support includes population growth as well as employment growth [4.389], it seems to me that, in this case, application of the WebTag alone could result in only an incomplete assessment of the schemes likely success in those two respects. However, that would not of itself mean that the Guidance should be set aside; and the promoters have sought to comply with the WebTag so far as was relevant in their view [4.377]. 9.293 The WebTag sets out an analysis framework intended to ensure a rigorous and thorough approach [6.205]. This requires a description of how the regeneration areas economy operates, the role transport plays in it, why improved transport would contribute to regeneration by leading to new jobs and/or reduced unemployment, and what the risks are that the
539
employment effects will not arise or may even turn out to be damaging [4.377]. Taking these in turn: a. Although there is piecemeal evidence in respect of some individual Boroughs, there is no coherent overall statement of how the areas economy operates. b. There is a broad description of transport in the area [4.86 to 4.92] and piecemeal evidence in respect of the relevance of transport to some individual businesses [5.138]. Some transport-related goals are set in the Mayors Transport Strategy [4.222], the London Economic Development Strategy [4.230] and the London Plan [4.208]. And work for the ODPM [6.553] considers the relationship between transport and development in the Thames Gateway. But there is no coherent statement of the role transport plays in the local economy. c. The promoters evidence regarding the contribution that improved transport would make to regeneration is based on modelling, and so should be reported in the AST as falling only into Band 1 of Table 1 in WebTag Unit 3.5.8 [4.377]. TfL also cite [4.383] the survey work carried out by London First and Gateway to London. London First asked two broad questions of its 276 members [5.137] and conducted interviews with 14 businesses active in the area. The reported interview responses [summarised at 5.138] do not reflect the range of issues set out in the relevant WebTag unit [4.381]. Gateway to London reported the views of five businesses [4.384]. I assign less weight to assertions made in interviews than I would, for example, to evidence of planning applications rejected on the grounds of poor transport provision. As to the sample sizes, the WebTag suggests that in many cases a sample of a few tens of businesses would constitute an adequate sample, if their relevance to the scheme in question is first established by a prescreening exercise; and the survey results should be re-weighted to reflect this. There is no evidence that this was done. d. The promoters assessment of the risks that the claimed employment effects will not arise is limited to acceptance of the SWCFs approximate sizing calculation regarding modelling uncertainty. There is no consideration of the proposition that the scheme may turn out to be damaging in terms of deprivation and unemployment, notwithstanding the objectors evidence to the contrary [6.978 and 6.987]. e. However, the promoters case meets the WebTag in respect of the assessment of costs [4.378] and, to an extent, accessibility; although in the case of the latter the matter of travel times is handled in a less detailed way by the promoters than is suggested by the WebTag [4.380]. 9.294 Had the WebTag been followed rigorously, it might have added substantial confidence to the employment assessment outcome. But it was not, and
540
the promoters assessment using their own method stands alone. Other matters regarding the regeneration model 9.295 Several objectors raised the matter of the so-called two way street effect, which considers that improved accessibility exposes an area to external competition for jobs, markets and so on, to the detriment of the newlyaccessible area [6.203, 6.554, 6.560, 6.852]. The promoters do not rely on the WebTag assessment method in this regard [6.206], but they instead refer to the effects of differential tolls, the similarity of the areas at either end of the bridge, the general success of Londons economy, and the positive effect they consider the scheme would have in that context for both areas [6.291]. Since the WebTag method addresses only the employment component of any such effect, this is a reasonable approach. TfL have estimated the local take-up rate of new jobs at, variously, one-third [6.604] and two-thirds [4.391] of such jobs, using comparable reasoning to that of the WebTag. 9.296 As to the juxtaposition of affluent Canary Wharf and nearby deprived areas [6.308, 6.554], it seems to me that the programmes, which the scheme would complement, to improve the skills of residents of the deprived areas are to be preferred to an approach which would seek to provide low-skill jobs in such areas [6.604] in the fear that better jobs would be taken by outsiders [6.308, 6.1034]. But this would be so with or without the scheme. 9.297 The identified departures from Government guidance are reflected in the wider economic objectives element of the AST (TfL/P/04/8), in that the strength of any claims of new jobs is not indicated, and there is no indication of the change (attributed to the scheme) in the number of residents of the regeneration area in employment in the forecast year. The assessment column in this part of the AST is wrongly completed. Findings regarding the regeneration model 9.298 A model has been developed to simulate accessibility, population density and employment density in London in 2001 and correlations have been identified. Among other things, the model relies on the traffic models assessment of travel time, the accuracy of which does not comply with Government guidance. 9.299 The use of those correlations as predictive tools has not been verified. The predictive model relies in very large part on the view of some practitioners and academics that there is likely to be a positive correlation between accessibility and the densities of employment and population. 9.300 It therefore seems to me that the regeneration model developed by the promoters cannot be relied upon to any substantial extent to predict changes in employment density or population density that might arise from
541
the scheme. 9.301 The potential for changes to the toll regime adds to the uncertainty about the regenerative effect of the scheme. 9.302 Contrary to Government guidance, the potential of the scheme for giving rise to negative economic effects has not been assessed by the promoter. The evidence is that it would be likely to be associated with an increase in deprivation. 9.303 In the ways identified, the AST incorrectly reflects the promoters evidence. 9.304 In the absence of a reliable predictive model of the regenerative effect of the scheme, it remains to consider the weight which should be attributed to the promoters claim that the scheme would support regeneration. 9.305 On one hand, several supporters of the scheme opine that there can be no sensible doubt that increasing accessibility through the creation of a new river crossing would stimulate regeneration to a significant extent. This view is supported as well by a number of independent studies of the likely effect of transport improvements in the Thames Gateway [5.88]. Additionally, the opinion survey among employers conducted by London First finds that most of those employers expect to benefit from the scheme, but gives no information about the expected extent of such benefit. I have commented on the relative weight I attach to assertions made in interviews (conducted by London First or Gateway to London) in contrast to factual evidence. There is no evidence of the ability of those questioned to predict accurately the effect of transport changes. 9.306 Against this body of opinion is that of Professor Whitelegg [6.312] who cites various cases in which transport improvements have been found not to lead to economic development or regeneration. Among these is the reported view of the OECD of the importance of non transport initiatives, such as are proposed here and to which I have already referred. That view was not in dispute at the inquiry. But there is no evidence before me of the extent to which such measures were in place in the examples cited by Professor Whitelegg, and I therefore attribute less weight to those examples than I otherwise would. 9.307 A programme of non transport measures is in place to support regeneration in the Thames Gateway area. The effect of the scheme would be to add to those measures a transport component that would improve accessibility, although by an amount not reliably determined. I weigh the locally-based anecdotal evidence that supports the proposition that improved accessibility would benefit the local economy against the evidence from elsewhere that, in unknown circumstances, some transport improvements did not lead to regeneration. 9.308 As regards other deprived areas, TfL contend that parts of Redbridge,
542
Hackney, Havering, Lewisham, Tower Hamlets and Waltham Forest would all benefit from the regenerative effect of the TGB [4.389, 8.63]. 9.309 I conclude that it is likely that the scheme would give rise to increased regeneration, but that there is no reliable evidence of the likely degree of that regeneration. Issue g - Conditions on any planning permission 9.310 Should the Secretary of State decide that the main bridge applications should be permitted, the conditions which I consider should be applied to the permissions are set out in Appendix C to this report as regards application ref: P/04/1170 and in Appendix D as regards application ref: 04/1800/F. The conditions in those Appendices are acceptable to TfL, and are supported by the three local planning authorities concerned as well as by the EA, the PLA and LCY [4.403]. I consider that they comply with the guidance on conditions provided in Circular 11/95. 9.311 Each set of conditions defines the local planning authority or local planning authorities concerned, the sets of plans which would be approved, and defines various terms in order to avoid confusion [4.405, 4.407]. The conditions provide for an extended life for the planning permission compared with the normal statutory provision, given the complexity of the scheme [4.406]. They set out the process for securing approval from the local planning authorities of matters dealt with in the conditions, again to provide certainty as to the processes to be followed [4.407]. 9.312 Because the detailed design of the bridge would be determined through the letting of a DBFO concession, the conditions would require the design of the works to be in accordance with the provisions of the Design Statement [4.407], and provide for approval of the detailed design [4.408]. Consideration of the design would require detailed assessment of the implications for safety at LCY and for vessels navigating on the River Thames [4.409]. It would also be necessary to consider the implications for tidal flows in the Thames, flood defences, delivery and removal of materials by river, and drainage issues in order to avoid damage to existing installations or contamination of the river or other water courses [4.410]. 9.313 Restrictions to reduce the impact of the works on occupiers of nearby properties would be covered by conditions on working methods [4.411 to 4.418], and conditions would also seek to minimise ecological impacts [4.418, 4.419]. Tree planting and the protection of existing trees would be the subject of conditions designed to protect and enhance the amenity of the area [4.420], and a programme of work would need to be approved designed to protect any archaeological remains which might be encountered during construction [4.418]. 9.314 During the inquiry, I invited the parties to consider the possibility of a condition being imposed to limit the number of vehicles on the TGB to a
543
level of 4,525 per hour, the level which TfL considered on the basis of their revised traffic model would be likely to be produced in the peak hour [4.421, 4.422]. This was not a proposal which achieved wide support. In fact, it was the subject of reasoned opposition from many quarters [4.423 to 4.430, 5.11, 5.53 to 5.55, 5.71, 5.83, 5.172]. On reflection, I accept many of the points made against the proposal, and I have not included such a condition in Appendix C or Appendix D. 9.315 For the reasons set out in paragraph 9.183 above, those Appendices also do not contain the conditions suggested by LTGF delaying the start of works on the TGB until after a contract had been let for the construction of Crossrail. Issue h - Other material planning considerations The Boroughs Agreement and the Unilateral Undertaking 9.316 The Boroughs Agreement made between TfL, Newham, Greenwich, LB Barking & Dagenham and LB Redbridge and the Unilateral Undertaking offered by TfL to LB Bexley are briefly described at paragraphs 1.64 to 1.66 and at paragraphs 4.432 to 4.434 above. 9.317 The Boroughs Agreement would [4.433]: a. Set up the BCG as a forum to discuss the tolling regime, related public transport provision, traffic and environmental impacts of the TGB, and monitoring and mitigation measures to manage those impacts. b. Provide for the monitoring of use of the bridge so that information on volumes and patterns of traffic could be provided to the BCG. c. Provide for the maintenance of two air quality monitoring stations, one to the north and one to the south of the TGB to make information available to the BCG. d. For ten years after the opening of the bridge, monitor the impact of traffic on the highway network, and report on it to the BCG. e. Provide a sum of 14.5m (uprated by a formula to cover inflation) to meet the costs of surveys, monitoring and highway and traffic mitigation measures agreed to be necessary. f. Provide dedicated public transport lanes over the proposed bridge. g. Provide Public Transport Service Development Statements for discussion with the relevant Boroughs to increase patronage of public transport. h. Prepare an Education Plan, to allow local schools and colleges to learn
544
from the construction of the TGB. i. Give consideration to sustainability measures in letting any contract for the construction and operation of the bridge.
j. Develop a low emissions strategy for vehicles using the TGB. k. Construct a Riverside Walk and Cycle Track in Greenwich. l. Fund a bursary scheme for residents of Newham to attend courses in civil or structural engineering.
m. Provide up to 200,000 to promote employment and training of local people and businesses in Newham. n. Require the concessionaire to prepare an employment strategy which would be designed to promote the employment of local people and to operate a training scheme for new employees. o. Require the concessionaire to operate a procurement strategy to encourage local businesses to bid for contracts to supply goods or services. p. Create a public open space in Greenwich. q. Fund off site mitigation measures in Newham at a cost of up to 500,000 (uprated by a formula to cover inflation). r. Fund noise mitigation measures at Gallions Primary School. 9.318 The Unilateral Undertaking would commit TfL to provide those benefits of the Boroughs Agreement appropriate to the Bexley area to LB Bexley [4.434]. 9.319 There are differences between TfL and some of the local authorities as to which of the provisions of the Boroughs Agreement should be taken into account in reaching a decision on the main bridge applications. TfLs position is summarised in paragraph 4.435; Newhams in paragraph 5.56; and the position of LB Redbridge is summarised in paragraph 5.72. 9.320 I consider that weight should be attached to the obligations described in sub paragraphs b, c, d, e, f, i, j, p and q above, which in my opinion meet the tests set out in paragraph B5 of Annex B to ODPM Circular 05/2005. 9.321 I share the views of Newham and Redbridge that the provision for air quality mitigation both during construction and operation should attract
545
weight, but I do not regard the provisions concerning employment, training and procurement (as Newham contend) or the provisions regarding consultation and the Public Transport Service Development Statements (as Redbridge contend) to be essential to the grant of planning permission. I consider that weight should attach to the provision regarding a low emission strategy not just during construction (as TfL contend) but also during operation. The adequacy of the mitigation funds provided through the Boroughs Agreement and the Unilateral Undertaking 9.322 LB Bexley argue that, because of the limited reliability of the traffic modelling undertaken in this case, TfLs commitment under the Boroughs Agreement should be to fund mitigation costs necessary as a consequence of the scheme in full, without the overall limit on funds available for mitigation contained in the Boroughs Agreement, and therefore in the Unilateral Undertaking [4.433, 6.42]. This position is supported by various objectors [6.1335, 6.1364]. TfL respond that nobody has been able to quote an example of a scheme where unlimited financial provision has been made for mitigation measures [6.1338]. TfL ask the Secretary of State to find that Bexleys request represents a wholly unjustified position [8.69]. 9.323 In a sense, the argument is academic, because the Boroughs Agreement is executed, and the matters with which it deals are agreed between the parties to it. The Unilateral Undertaking in effect makes the same offer to Bexley. The commitment those documents contain is limited both in time and in total cash terms. I support the limit in terms of time, because it seems to me sensible that the consequences of a development can be identified within the period of ten years as provided here. But the limit in terms of cash appears to me to mean that, once the total fund available under the Boroughs Agreement has been expended, the risk of the cost of further mitigation measures would fall on the local highway authorities concerned. So far as Bexley are concerned, this means that part of the cost of mitigating the effects of a scheme which TfL promote, but which Bexley oppose, could fall on Bexley. Whether any more generous approach is unprecedented or not, the existing provision of a limited fund does not seem to me to represent a fair division of risk. 9.324 If the mitigation funds that would be provided through the Boroughs Agreement and the Unilateral Undertaking were to prove insufficient, then necessary traffic mitigation measures arising from the scheme might not be provided. A consequence of that would be increased congestion, leading in turn to reductions in accessibility and some reduction in the regeneration benefits that might result from the scheme. 9.325 For the reasons given, I consider the traffic model to be of limited reliability. Indeed, although they consider the modelled scenario to be the most likely one [6.75], the promoters do not consider the traffic model reliable enough to assess in detail the mitigation measures that would be necessary at any particular location in Bexley, and propose a different
546
approach for that purpose, which they would take at a later date [6.76]. It seems to me that the same view should be taken for mitigation at any other location. The promoters would provide 1.83 million for mitigation in Harrow Manorway [4.50] and some 14.5 million for measures elsewhere which they can foresee now would or might become necessary [4.155, 4.156]. Recognising the uncertainty, this figure includes a contingency of between 5.6 million and 6.7 million for measures arising from the scheme that they have not foreseen [4.159]. This contingency allowance would be between 38% and 46% of the foreseeable expenditure on mitigation. It would also increase by any saving made from the 8.9 million component of the budget, should that arise. 9.326 Bexley Council identify a number of measures that they consider would be necessary if the traffic model were accurate and the original discount area proposal implemented [6.40]. But that is not the promoters intention, and so the list of measures Bexley Council propose gives no clear insight into the extent of measures that might be needed beyond those TfL set out. Nor was any other reasoned evidence given of the need for such additional measures. Yet it seems to me that there may be some additional works; for example, the A13/A406 junction might need to be modified, for the reason given in paragraph 9.181 above. There was no evidence of the possible cost of unforeseen measures throughout the study area (nor could there be), and therefore no basis on which to conclude with certainty on the matter of the sufficiency of the contingency that would be provided. 9.327 However, in my view a contingency allowance of the order of 40% of all the mitigation expenditure that can reasonably be foreseen would be likely to be sufficient to cater for many of the possible outcomes. If it proved insufficient, the consequence might well be a permanent increase in congestion at some locations as a result of the scheme. If the mitigation fund were unlimited, then I could conclude that there would be no reason to suppose that congestion would arise as a permanent result of the scheme; but it is not, and so I cannot. Cost Benefit Analysis 9.328 The scheme benefits are assessed by the promoter, using the Cordon Model, to result largely from travel time savings for highway users (1,758m contribution toward a net benefit of 1,779m) [4.165]. I have noted that, in my view, findings which are sensitive to errors in assessed journey times will be of limited reliability. The transport economic assessment is presented by the promoters as robust, with a benefit to cost ratio of 4.2 to 1 over 30 years [4.165], or 5.9 to 1 over 60 years [4.166]. This is tempered somewhat by the promoters in response to cases put by objectors: a. If the value of users time were constant after 2021 (a proposition which would, in the promoters submission, be contrary to national guidance), then the modelled benefit to cost ratio would fall to 3.9 over 60 years [6.246].
547
b. Traffic reduction policy measures might reduce the highway benefits by 13%, or perhaps twice that [6.232, 6.233]. The latter case would reduce the benefit to cost ratio to 2.5 for a 30-year appraisal using the Reference Case Model, but it is the Cordon Model with its lower traffic volumes and hence lower highway user benefits that forms the basis for the promoters case. 9.329 Objectors argue that if congestion is greater in 2016 than in the base year, then travel will be slower, and travel times will be greater. Therefore time savings would be reduced [6.147, 6.148]. This would be a likely result if the TGB were successful in attracting population and jobs to the area [6.149]. 9.330 On the other hand, if traffic growth were lower than assumed in the cost benefit analysis in future years, this would reduce the benefit of the project. If traffic growth were higher, then the scheme benefits would increase. But reduction in traffic growth is the more likely scenario, since it is the aim of national, regional and local policy [6.189]. 9.331 The evidence is that benefit to cost ratios of 2 or more are indicated by DfT guidance as being high value for money [4.167]. 9.332 In view of the lack of reliability of the traffic model and the other uncertainties I have identified here, it seems to me that the proposition that the benefit to cost ratio reliably shows the scheme to offer high value for money is not robustly supported by the evidence. Conflict between different objectives of the TGB arrangements 9.333 LB Bexley argue that there is a tension between the claimed regeneration and economic benefits of the scheme on the one hand, and the environmental impacts and financial considerations on the other [6.5]. The more traffic which uses the bridge, the greater the economic activity, and the greater the toll income. But increased traffic would also increase the environmental impact of the proposed bridge. The more that increased tolls were used to reduce the environmental impact, the smaller the regeneration benefit, and the smaller the income from the bridge. This would therefore involve a greater subvention which TfL might be called upon to pay to make good any revenue shortfall in toll income to the concessionaire [4.453, 4.456]. 9.334 TfL respond that the Traffic Management Act 2004 establishes a duty on TfL and other local traffic authorities to secure the expeditious movement of traffic on its own road network and those of other local traffic authorities. There are default powers available to the Secretary of State to ensure that this duty is performed [6.56]. 9.335 I recognise the potential conflict between these different consequences arising from the manner in which the proposed bridge would be operated.
548
It seems to me, however, that it is simply an example of the type of balancing exercise which local authorities are frequently called upon to make. Ministerial default powers may be a very long long-stop, but they represent a final line of defence nevertheless against a failure to discharge a duty. 9.336 I do not regard this issue as a justifiable basis of objection to the applications. The possible need for a future connection to the A2 9.337 A number of objectors fear that, if the bridge were built, congestion to the south of the river would be such that pressure to reinstate the idea of an ELRC style connection to the A2 would become irresistible [6.100, 6.965 to 6.968, 6.1013 to 6.1015, 6.1275, 6.1563]. Some, indeed, suggest that this could be the deliberate hidden intention of the promoters [6.1226 to 6.1228, 6.1566, 6.1646]. This would put at risk once again Oxleas Wood, an ancient woodland and an SSSI, and Woodlands Farm, a community farm which is a much valued resource for local people [6.965]. 9.338 TfLs response is that, overall, the TGB is predicted to reduce traffic between the north of Bexley and Greenwich and the A2, as a result of opening up employment opportunities north of the Thames to residents in those areas who now travel to work via Bexley and the A2 [6.129]. There is no justification in the Development Plan or in any other current planning document for a link to the A2 via Oxleas Wood. Such a route would not comply with Policy 3C.15 of the London Plan, and is explicitly ruled out by the text of Policy M13 of the emerging Greenwich UDP. Safeguarding of the formerly planned Oxleas Wood link has long ago been removed, and property acquired in the past in order to build that road has been sold [6.130, 6.1044]. The Orders originally made in relation to the ELRC route were revoked in 1997 [6.996]. There is no proposal to carry out further and later extensions of the TGB scheme [6.1240]. Any such proposal would involve new Orders and a new public inquiry. No evidence has been produced by objectors to show that there is any intention to link the TGB with the A2 [6.1596, 6.1597]. 9.339 I consider that it is certainly the case that there would be no policy backing for a new road to extend the TGB to the A2, and that any such proposal would fall to be considered against a hostile policy background. I can understand the fears of the objectors who raise these issues. It really does not seem to me to be credible, however, that there would be a further attempt to build a link through Oxleas Wood given the history of the attempt to build a road there in the past and the policy protection which the area now enjoys. I do not regard this as a sustainable basis of objection. Public consultation 9.340 During the development of the scheme for the TGB, there was consultation by TfL with a long list of local and national stakeholders [4.443]. Members
549
of the public also had an opportunity to express an opinion on the proposal in commenting on the Mayors Transport Strategy in 2001, the London Plan in 2002, a specific and very extensive public consultation on the scheme in 2003, a ten week consultation on the main bridge planning applications, organised by the local planning authorities concerned but supported by TfL, in 2004, and a further consultation in relation to the revised construction work site application in 2005 [4.444]. TGLP carried out an extensive parallel consultation in 2003, which led to that organisation seeking amendments to the scheme (which were accepted by TfL) before offering their support [5.117]. 9.341 Objectors challenged in particular the value of the scheme specific consultation in 2003 [6.356]. They argued that the material issued did not offer the public options, was not balanced, and confused the provision of information with the seeking of a response [6.358, 6.359, 6.597, 6.769 to 6.775, 6.970, 6.1041]. The response rate was limited [6.360], and no attempt was made to establish how representative of the whole population it was [6.361]. It was clear, for example, that a disproportionate number of individual motorists had responded to the consultation [6.663]. The results were then presented without adequate warning of their shortcomings [6.362]. 9.342 In relation to other consultation processes, there was criticism of the failure initially to extend the 2004 consultation on the planning applications to Bexley [6.773] and of the perceived lack of understanding by TfL staff at the presentation eventually arranged in Bexley of the extent to which the scheme would impact on that area [6.774]. There was also criticism of the failure of TfL to publicise their revised toll discount area proposals, which were introduced to the inquiry following the presentation of the rebased traffic evidence [6.597]. 9.343 A telephone poll organised by a local free newspaper circulating in Erith and Belvedere during 2005 and 2006 indicated that some 70% of respondents opposed the scheme [6.775]. 9.344 It was also argued that the majority of the people who had appeared at the inquiry or sent written representations had opposed the scheme, and that this democratic expression of opinion should be upheld [6.790]. 9.345 In response, TfL emphasise the number of opportunities which the public have had to react to the proposals [6.820 to 6.824, 6.998], the scale of the consultation [6.364], and the length of time for which there has been outstanding a proposal for a further Thames crossing in this area [6.363]. They say that it would have been misleading to offer options to the public once the Mayors Transport Strategy had been adopted [8.33]. The return of questionnaires used in the 2003 consultation amounted to 5% of those distributed. The objectors expert witness could not quote a similar public consultation exercise which had elicited a more substantial response [6.371].
550
9.346 TfL accept that not everybody agrees with the TGB proposal, particularly in the Bexley area [8.40]. It was contentious even within the TGB Board [6.825]. But it is also clear, both from the consultations and from the representations to the inquiry outlined in section 5 of this report, that there is a good measure of support for the scheme. 9.347 A process of public consultation which escaped all criticism would be rare in my experience. Equally, a process more extensive or more lengthy than that which has taken place in this case would be extremely unusual. I note that Greenwichs very experienced planning witness described the 2004 statutory consultation alone as the most widespread and comprehensive consultation he had witnessed [8.39]. 9.348 Public consultation on planning applications is worthwhile and important. In this case the public have also had the opportunity to express views, whether in writing or in person, at a lengthy public inquiry. 9.349 In the final analysis, a decision will be reached by a judgement being made on the planning merits of the case, having taken into account all the representations made, against the provisions of the Development Plan and any other material considerations. 9.350 I do not consider that the way in which public consultation has been carried out in this case offers any justifiable basis for objection to the applications. Alternatives 9.351 No alternative route for the scheme was submitted to the inquiry [1.44]. Evidence put to the inquiry regarding potential alternatives to the scheme dealt with three broad issues, as follows: a. That the process by which the scheme proposal was chosen does not comply with Government guidance [6.318, 6.544, 6.876] b. That, since the purpose of the scheme is to increase regeneration, more consideration should have been given to non transport based alternatives to the scheme which would achieve the same objective [6.874, 6.994, 6.1160]. c. That further transport based alternatives to the scheme should have been considered [6.647, 6.872, 6.993, 6.1471, 6.1672]. Scheme selection process and non transport based alternatives 9.352 The promoters evidence is that the purposes of the scheme are to improve accessibility to and within the Thames Gateway area and to support the regeneration of East London, particularly in the Boroughs immediately adjacent to the scheme [4.20]. There has been an extensive range of
551
studies carried out between 1993 and the adoption of the Mayors Transport Strategy into the potential to aid regeneration of a river crossing in the area [4.400 to 4.402]. There has been no specific study that has considered how East London might be regenerated without a new river crossing [6.107, 6.349]. But the Mayors Transport Strategy (D630) recognises the need in East London to improve transport access, to reduce the north/south barrier caused by the river, and to support regeneration [4.223] and goes on to include the scheme for implementation [4.224]. That local objective in the regional transport strategy feeds into the study method of the WebTag [6.349] and in that way TfL argue that the question Are there better ways to meet the objectives?, as posed by the WebTag, has been addressed. It seems to me that the promoters claim to have satisfied the WebTags study approach rests in large part on their identification of the provision of the scheme as an objective of the Mayors Transport Strategy [6.134]. 9.353 On the other hand, Professor Whitelegg refers to the broadly expressed view of the Government that actions should result from a process including, among other things, problem definition (which he considers to have been done partially in this case), the identification and evaluation of options (which he considers not to have been done at all) and the selection of a preferred option for implementation (which he considers to be the result of a direct leap) [6.319]. The LTGF take a similar view, referring to the WebTag recommendation that a first principles approach should be taken and that at least two options should be taken fully through appraisal, suggesting that instead the road schemes that were available at the time of appraisal were reinvestigated in the new context [6.876]. LTGF argued that such a first principles option should have been considered at the Examination in Public into the London Plan, but was not [6.874]. T2000 draw attention to the need, identified in PPG13, to explore a full range of alternative solutions to problems, including solutions other than road enhancement [6.495]. 9.354 The evidence is that, although a regeneration option exists that would not involve crossing the Thames (which Professor Whitelegg presented in outline to the inquiry as being capable of satisfying the stated objectives of the scheme) [6.321, 6.322], no such option has been evaluated [6.349]. But this non crossing option lacks detail and has much in common with some of the complementary measures already in place in the area [4.396]. To that extent, it resembles the do-minimum case developed by the promoters. Against this, there is the promoters assertion that the noncrossing option would not obviate the need for the scheme [6.349], and their evidence of the regenerative effect they expect the scheme to have. 9.355 Other objectors also suggested that non-transport measures could be substituted for the scheme. These either lacked all detail [6.1160] or, where measures were proposed, offered no evidence that those measures might be successful in achieving the schemes objectives of improved accessibility and regeneration [6.994]. They assumed that finance earmarked for the scheme (including PFI credits, toll income and private equity) could be switched to very different alternatives such as the improvement of residential properties. This is manifestly not the case
552
[6.139]. 9.356 On the issue of WebTag compliance and the consideration of alternatives, I accept the argument of the promoters. It seems to me that, once Policy 4Q.28 of the Mayors Transport Strategy adopted a commitment to provide an improved level of access to the London Thames Gateway area for road based modes the time for considering alternatives which did not at least include improved access for road based modes had passed [6.135, 6.136, 8.33]. Further transport-based options 9.357 The promoters considered alternative locations for the scheme, a tunnel instead of a bridge, alternative highway layouts and alternative forms of public transport provision on the bridge [4.124 to 4.128], and concluded that the scheme proposal is preferable. 9.358 No alternative scheme was proposed by objectors in any detail. suggestions that were made included: The
a. A heavy rail link across the river at the scheme site [6.993] or elsewhere [6.106]. The evidence is that this would be too costly, because of the extent of the works needed to connect to the national rail network and to climb at heavy rails shallower maximum gradient to the necessary height above the river [4.128]. It would not provide for goods vehicle movement [6.1612]. Additionally, Crossrail would provide such a connection [4.228], although not at the scheme site. b. A DLR crossing of the river, which would cost much less than the scheme [6.993]. But a DLR crossing to Woolwich is already under construction [4.225] and a further extension of the DLR, over the scheme, would be more costly, less convenient and no more beneficial than the proposed bus-based public transport over the new bridge [4.128]. It would not provide for goods vehicle movement [6.1612]. c. Tram systems [6.872]. But these would not attract enough passengers to be economically justified, although they could be accommodated later on the new bridge if the demand should grow sufficiently [4.128]. Tram systems would not provide for goods vehicle movement [6.1612]. d. A bridge providing a single traffic lane in each direction. Objectors suggest that this would be all that was required to deal with interpeak traffic flows, and that anything more would simply encourage car commuters [6.868]. This alternative is also supported by the CPRE [7.30]. TfL respond that a single lane would not provide enough capacity, and that it would offer no resilience to cope with a breakdown or accident [6.941].
553
e. Foot tunnels [6.872]. It seems to me that foot tunnels if used for walking trips only would bring very small increases in accessibility. If used as part of longer multimodal trips (perhaps incorporating public transport to and from the tunnels) their effect could be less small, but interchange delays would remain. Foot tunnels would be less effective than the scheme proposal in achieving the objectives of the scheme. They would not provide for goods vehicle movement [6.1612]. f. A series of combined cycle and foot bridges between Tower Bridge and North Greenwich with a cycle and foot tunnel at Silvertown, tying communities together across the river and giving cycling a great competitive advantage [6.647]. Again, such provision would be less effective than the scheme proposal in achieving the objectives of the scheme. They would not provide for goods vehicle movement [6.1612]. g. Lifting bridges [6.872]. The specified navigation channel should be at least 230m wide [4.63]. There was no evidence that a lifting bridge could be provided of the required span. h. Ferries for pedestrians and cyclists, linked by improved public transport networks to the north and south [6.435, 6.647, 6.872, 6.1750] or a cable car crossing (as first mooted in the planning application for the Millennium Dome) [6.435]. The scheme would not preclude these but, in any event, the delays and inconvenience of interchange makes ferries largely ineffective as a catalyst for regeneration [6.942]. Neither of these proposals would provide for goods vehicle movement [6.1612]. i. The river tram transit proposal of Mr Winbourne [6.1471]. This proposal as presented to the inquiry lacked evidence of sufficient capacity, viability or achievability.
j. A new tunnel or bridge near the Woolwich Ferry or additional tunnels at Blackwall, connecting with the South Circular Road at Woolwich or the Blackwall Tunnel Approach road [6.1672]. Additional tunnels near Blackwall are to be promoted separately from the scheme as the Silvertown Link [6.1783]. The proponents of the Woolwich fixed link suggestion submitted no detail of their proposal; nor did TfL reply. It seems to me that such a scheme would have substantial implications to the north and the south of the river, many of which would be adverse. 9.359 For the reasons given in each case in the preceding paragraph, I conclude that these suggested alternative options do not warrant further consideration. Proposal for a detailed amendment to the TGB scheme 9.360 London International Exhibition Centre plc [5.194] and SELTRANS [7.42] both seek an additional northbound exit from the TGB for general traffic, north of the river, but south of the proposed grade separated junction at
554
Winsor Terrace. This proposal was not worked up in detail by TfL, but it does not seem to me to be achievable. There is a need to provide an on and off slip road for vehicles on the public transport route following the northern landfall of the bridge, and this would commence just as the route crosses Armada Way. At that stage, the route would still be 20m above Armada Way. The proposed off slip for northbound general traffic to the Winsor Terrace junction would commence about 150m further north, having first needed to cross the access track to the Beckton DLR Depot. It seems to me that there would only be a very small envelope into which a further exit would need to be fitted. It would need to cross the DLR main line in order to link with Royal Docks Road, and the distance which it would save for traffic compared with travelling to the Winsor Terrace junction would not seem to me to justify the expenditure which would be involved. I do not regard the proposal to be one which justifies further examination. Health 9.361 Health (read more widely than simply the impacts of noise and air pollution) is raised as a material consideration by the promoters, by supporters and by objectors. 9.362 Health is considered as an issue in the ES [6.374] but not by way of a formal HIA [6.1026, 6.1747]. A HIA is not a requirement for the assessment of a proposal such as the TGB [6.1052]. 9.363 The promoters claim that the scheme would have the effect of reducing unemployment, and that reductions in unemployment lead to improvements in health [4.395]. The scheme would also improve access to health care facilities [4.81, 5.159]. 9.364 Supporters such as Newham [5.49] and Redbridge [5.68] consider that the scheme, despite its potential negative air quality impact, would offer improvements in the overall wellbeing of residents in their areas. 9.365 As part of the case of the TGLP, SELSHA gave evidence in support of the scheme on behalf of the NHS in South East London [5.95 to 5.107]. That was a carefully studied and balanced position, adopted only after evaluation of the potential positive and negative impacts of the scheme [5.98], and confirmed following the commissioning and consideration of an independent evaluation of the supporting evidence [5.105]. 9.366 SELSHA share the view of the promoters that employment and access to jobs are key determinants of good health [5.96]. The impact of air quality on health is also important, but some issues can have a significantly greater impact on health and wellbeing [5.97], such as employment and higher disposable income [5.100]. 9.367 Objectors argue, however, that, while it is the case that unemployment is bad for health, it is also the case that some types of employment are bad
555
for health. Any argument that the scheme would, by increasing employment in the area, result in better health should be supported by reliable evidence of the extent to which local jobs would depend on the scheme, how many local people would work in those jobs, and the extent to which such employment would be beneficial to health. No such case has been put. Objectors claim that there is no evidence that the scheme would redress current health inequalities; indeed, it is often the case that increased traffic as a result of projects similar to the scheme creates substantial negative health impacts, which fall disproportionately heavily on poorer sections of the community [6.1030]. To rely on a substantial transport infrastructure project as a means of reducing health inequalities is unlikely to be effective [6.1031]. 9.368 In cross examination, it was accepted by the SELSHA witness that the NHS evidence assumed the correctness of TfLs traffic evidence. When the traffic evidence was recast, its correctness was again assumed [6.777]. The air quality and noise evidence depend on the traffic evidence. The air quality and noise evidence have also been accepted by the NHS in reaching their position in relation to the TGB [6.778] 9.369 In relation to physical access to healthcare services, objectors state that over 85% of patient interactions with the NHS take place within primary care. Most primary care is provided very locally. Very few patients would be registered with doctors on the other side of the river, and it is therefore difficult to see how the scheme would benefit access to primary care [6.1027]. As regards secondary and tertiary care, objectors say that there is again no evidence of significant cross river travel to access these services [6.1029]. In response, TfL say that this is does not allow for the implications of planned population increase in the area [6.1053]. 9.370 Objectors underline the fact that national transport policy has recognised in recent years that vehicle exhausts make an important contribution to greenhouse gases. There is a need to balance the desire for economic development against the sustainable development objectives of a cleaner environment and an improved quality of life [6.375, 6.376]. Moreover, if economic regeneration leads to employment mobility, it may not improve the health of local people. If it leads to low pay and poor quality jobs, it will not necessarily improve the health of poor people [6.387]. It was claimed that poor people tend to live near busy roads [6.582]. 9.371 On the other hand, objectors claim that modal shift from cars to public transport has a double benefit; it builds exercise into the journey, and uses the form of transport with the lowest level of danger to passengers and other road users [6.378]. But the TGB would signal that the car, rather than public transport, should be seen as the main method for crossing the Thames at this point [6.379]. It would reduce cycling and walking, and further reduce health benefits as a consequence [6.646]. 9.372 TfL respond that the TGB would include dedicated public transport provision; and that, viewed as part of the overall package of cross river
556
proposals for East London, it is clear that priority is given to public transport [6.400]. 9.373 Objectors state that Dartford and Bexley have the countrys worst figures for under 5 asthma, and that there is concern in Bexley regarding the incidence of cancer, which has been directly linked to vehicle emissions [6.1640]. It is also suggested that more traffic related deaths in London result from pollution than from road traffic accidents [6.1640]. 9.374 TfL respond that the position regarding these matters is well known to the NHS in the area, yet SELSHA and the Bexley Care Trust are supporters of the TGB scheme [6.827]. 9.375 I accept TfLs point that a formal HIA was not required in this case. I also accept that the studied, informed and balanced position which NHS bodies have taken in relation to the TGB scheme offers an important insight into the relative weight to be attached to the positive and negative health aspects of the proposal. I note, however, that that position has been taken in reliance on noise and air quality assessments which depend upon a traffic model of limited reliability. That reduces slightly the weight which I feel able to attach to SELSHAs support for the scheme. Global warming and climate change 9.376 Objectors contend that the possibility of climate change is increasingly recognised. The predicted effects in London include summer droughts, increased risk of flooding, more smogs and more smog-related illness such as asthma. Carbon dioxide is a principal greenhouse gas, believed to cause climate change when present in the atmosphere [6.589]. 9.377 The 2003 Energy White Paper committed the UK to put itself on a path towards a reduction in carbon dioxide emissions of some 60% from current levels by about 2050. PPS1 also notes the importance of climate change impacts. Nevertheless, carbon dioxide emissions have risen since 1997 [6.590]. 9.378 The DfT priorities for 2005 to 2008 include, jointly with DEFRA and the DTI, reduction in greenhouse gases in accordance with the Kyoto Agreement and other targets. The Transport White Paper of 2004 sets out Government targets for the reduction of carbon dioxide emissions by surface transport [6.591]. Thus the issue of climate change has been recognised as increasingly important in the period since the ES was published [6.592]. 9.379 The estimated proportion of all greenhouse gas emissions in the UK that comes from transport varies according to the views of different estimators, but is generally thought to lie in a range between about 21% and about 32%. Private cars account for about 10% of UK carbon dioxide emissions [6.593, 6.595].
557
9.380 Carbon dioxide reduction from transport is possible to the level required by national policy, but it would require behavioural change. TfLs evidence is that the scheme would result in the emission of an additional 55,000 tonnes of carbon dioxide in 2016 [6.596]. 9.381 TfL respond that this is only an increase of 0.4% across the study area [6.1058]. Even if it were doubled, it would be less than 1%. 9.382 It seems to me that even a small increase offers no assistance in achieving a reduction to which the Government has made a commitment. Flood Defence 9.383 Objectors raise the issue of possible flood risk in the areas which are intended for regeneration surrounding the bridge [6.1671], in relation to the roads leading to the proposed bridge [6.1161], and in relation to points of contact at ground level with the bridge [6.1472]. 9.384 The inquiry was advised that the East London Strategic Flood Risk Assessment had been completed, and had been circulated to the eleven London Boroughs concerned. It had not yet been made public, however. I was asked to draw the attention of the Secretary of State to those facts [6.1181, 6.1746]. 9.385 The promoters respond that the land to either side of the River Thames is protected against flooding by a river wall 7.2m AOD. The Thames Strategy East Policies RG4.32-33 address flood risk management and climate change. The proposed risk management strategy does not include a suggested review of the TGB design or the integration of the proposed bridge in a flood alleviation scheme [6.1770]. 9.386 I note that Greenwich suggest that the review of the flood defence structures can be expected to alleviate any long term increase in flood risk, and that the engineering design of the TGB would allow for possible future raising of the defence level [5.5]. I also note that the EA, having withdrawn their objection to the scheme, participated in the conditions sessions [7.34], which produced recommended conditions which would address (amongst many other things) the issue of flood defences. 9.387 Clearly consideration would need to be given to any further information on this subject, but it does not seem to me to provide a sustainable basis of objection to the scheme. Emergency services 9.388 A number of objectors claimed that increased congestion arising from the bridge would hamper the response of the emergency services throughout the area [6.688, 6.714, 6.793, 6.1458, 6.1755, 6.1756]. In fact, however,
558
the London Ambulance Service NHS Trust and the Metropolitan Police Authority sent supportive written representations in connection with the proposal [5.184]. I therefore discount this basis of objection. Impact on access to business premises 9.389 The owners of some small businesses in Bexleyheath expressed concern that increased congestion in the area would damage the viability of their businesses [6.1763]. TfL responded that the traffic model showed that there would be less traffic in the area concerned with the TGB than without it [6.1784]. Any traffic effect reducing trade in the area would therefore not be brought about by the TGB. Impact on use and potential use of the River Thames 9.390 An objector claimed that the height of the proposed bridge would limit the size of vessels able to travel upstream of it. This would that mean that large cruise liners would no longer be able to travel up river of the TGB to Greenwich, where a cruise liner terminal is planned. There would be a consequent loss of job prospects, both on the river and in tourism [6.1650]. 9.391 It transpired, however, that the terminal for which planning permission had been given (as part of a larger mixed development) would be capable of taking vessels of up to 50,000 tonnes. The design of the proposed bridge would therefore not inhibit passage by any vessel capable of using the proposed terminal. The Royal Navy had also indicated that the bridge would not prevent passage for any ship they wished to sail up the Thames, and the PLA had withdrawn their objection to the scheme [6.1656]. 9.392 I do not consider that this ground of objection is sustainable. Human rights issues 9.393 Two objectors claimed that allowing the proposed bridge to be built would involve infringement of their human rights. 9.394 Mrs Ida Brown considers that the scheme would cause a change in traffic conditions near her home in Pickford Lane, Bexleyheath, to the extent that her right to peaceful enjoyment of her possessions, established by Article 1 of the First Protocol of the Convention on Human Rights would be infringed [6.1432]. 9.395 Mrs Brown is not a statutory objector to the scheme. She would not be deprived of any possession by the scheme. The evidence is that the scheme would reduce peak hour traffic in Pickford Lane from 1078 vehicles per hour (2016 do-minimum case) to 1014 vehicles per hour (2016 withscheme case), and that it would increase hourly traffic during the interpeak period from 255 per hour to 319 per hour [6.1423]. Although recent traffic
559
surveys carried out by Mrs Brown in Pickford Lane differ from the predicted flows there in 2016 [6.1423], it would be the change in flows caused by the scheme rather than the absolute flows that would give rise to any change in conditions there. Those changes are expected to be small of the order of about one vehicle per minute. The evidence is that traffic noise levels are relatively insensitive to changes in traffic volumes [4.267] and so such a change would be unlikely to affect noise levels in Pickford Lane significantly. Although the traffic model is of limited reliability, this would be unlikely to give rise to a substantially different finding with regard to the effect of the scheme on noise in Pickford Lane for the reasons given in paragraph 9.63(d). 9.396 It therefore seems to me that the scheme would have no significant effect on noise levels in Pickford Lane, and therefore no significant impact on the peaceful enjoyment of Mrs Browns possessions. 9.397 Mr Paul Berry claims that Newham, Greenwich and TfL breached the human rights of people living near the proposed TGB by failing to make them aware of a new safeguarding direction issued by the Secretary of State on 4 May 2001. The effect of that direction would, in Mr Berrys view, increase levels of noise and air pollution in the area to such an extent that it would interfere with the private and family life of those residents, thereby violating Article 8 of the European Convention [6.1524]. 9.398 In response TfL argue that Mr Berry received sufficient advance information about the proposed project to enable him to object to the planning applications and the Orders, and to enable him to appear before the inquiry. Mr Berrys rights under the European Convention on Human Rights with regard to respect for his private and family life and the protection of his property are protected by the procedures which are required under statute to be carried out before the proposed works can be authorised. Those procedures have been fully complied with by TfL, and include Mr Berrys right (which he exercised) to call evidence and make representations at the inquiry [6.1549]. 9.399 I do not consider that Mr Berrys rights under Article 8 would be violated if planning permission for the TGB were to be granted, because in my view he would not be personally and directly affected. This means that he does not have standing as a victim. He was not the owner of an affected property at the time the safeguarding decision was made (he did not acquire his former property until 2002), and he is not the owner of an affected property now [6.1518]. Appraisal Summary Table 9.400 The original AST has been varied in the light of the rebased traffic evidence [4.85]. The final form of the AST put forward by the promoters is contained in Annex 1 to Document TfL/P/04/8.
560
9.401 Two objectors raise questions or make specific challenges to judgements in the final form of the AST [6.111 to 6.114, 6.1590]: a. Greenhouse gases TfL say the impact here is neutral. Mr Buchan argues that the correct judgement is slight adverse. TfL respond that the national targets do not apply to individual schemes. Whilst that is correct, I consider that, since the item is included in the standard AST table, an appropriate judgement should be made. To my mind, an outturn which moves in the opposite direction from the national target can hardly be regarded as neutral. I agree with Mr Buchan that the correct judgement should be slight adverse. b. Landscape TfL consider this to be a large beneficial impact. Mr Buchan asks how that can be said when there is not an approved design. I consider that the process which has been set up should deliver a good design. I therefore do not quarrel with TfLs assessment. c. Heritage and historical resources TfL consider the impact here to be slight adverse. Mr Black asks how that can be said when the potential resource has not yet been discovered. In my view TfL have acted properly in recognising the potential for an adverse impact. I agree with their assessment. d. Biodiversity TfL consider the impact here to be moderate adverse, which would be reduced to slight adverse with mitigation. Mr Buchan argues that mitigation should not be included in the assessment. Mr Black argues that the permanent loss of habitat should be regarded as moderate adverse. TfL reply that the mitigation is an essential part of the scheme. I regard it as fair to include the impact of known and funded mitigation. I therefore do not quarrel with TfLs assessment. e. Physical fitness TfL regard the impact here as slight beneficial. Mr Buchan points out that car use would be consolidated by the scheme, and therefore argues that the impact should be slight adverse. TfL respond that the TGB would connect cycle routes and open the way to leisure walking. I note that the evidence is that the bridge would be little used for cycling and walking, but that it is clear that people would transfer from those modes and indeed from public transport to use of the car. I agree with Mr Buchan that the judgement should be slight adverse. f. Accidents TfL originally made no qualitative assessment under this heading, but subsequently agreed that a slight adverse impact would result. Mr Buchan argued that the impact would be moderate adverse. Given the scale of the additional PIAs, I agree that a moderate adverse judgement is justified. g. Security TfL regard the impact here as slight beneficial. Mr Buchan contends that the benefit of lighting installed close to the scheme should
561
not be included as part of the impact of the scheme. TfL counter that the lighting is integral to the scheme. I agree with TfL that it is fair to include it, and I do not quarrel with their judgement under this heading. h. Reliability TfL argue that the impact here is moderate beneficial. Mr Buchan says that it should be made clear that that such benefit only applies to private cars. TfL disagree. They say that public transport reliability would also improve. I agree with TfL, and with their judgement. i. Wider economic benefits TfL consider the impact here would be strong beneficial. Mr Black asks how that can be claimed when it is not possible to prove that actual jobs would be produced for local people. I agree that a judgement of strong beneficial is not robustly supported, as I have indicated at paragraph 9.303 above.
j. Access to the transport system TfL argue this is neutral. Mr Black contends that such a judgement does not take into account non local traffic or induced traffic using local road networks. I take Mr Blacks point, but balancing that with the improvement of access for public transport, I would support TfLs assessment of an overall neutral impact. k. Land use policy TfL argue that this is a strong beneficial impact. Both Mr Buchan and Mr Black disagree, on the basis that consolidating car use and leaving open the possibility of future road expansion does not conform with the guidance given in PPG13 or in Policy 3C.15 of the London Plan. I do not agree with TfL that a strong beneficial impact has been shown. As indicated above, I consider that the TGB proposal conflicts with PPG13, and I return below to the issue of compliance with the London Plan. l. Other Government policies TfL claim a neutral impact here. Mr Buchan argues that the impact is moderately adverse on the basis that improvement to choice for non car users in relation to health, education and jobs would be diminished. TfL disagree, claiming that people without access to cars would still have the benefit of public transport links across the proposed bridge. I agree with TfL that the impact is neutral.
9.402 The responses made on these points by TfL are contained in paragraphs 6.140, 6.141 and 6.1618 above. 9.403 In summary, I consider that the judgements shown in TfLs AST should be amended in the following respects greenhouse gases should be slight adverse; physical fitness should be slight adverse; accidents should be moderate adverse; and I do not agree that strong beneficial impacts have been convincingly shown in relation to wider economic benefit and land use policy.
562
Delaying the TGB 9.404 Two objectors contended that a conclusion regarding the building of the TGB should be delayed until a decision had been taken regarding Crossrail, at which stage a judgement could be made as to the combined traffic impacts [6.1116, 6.1484]. Mr Chapman in fact argued that a decision should not be taken in relation to the TGB until the DLR Woolwich Extension, Crossrail and the GWT and the ELT had been operational for ten years [6.1116]. 9.405 Ms Mackinnon believed that the TGB proposal should be reviewed in the context of the emerging Sub Regional Development Framework, which would then involve its consideration by way of a SEA [6.1698 to 6.1704]. 9.406 TfL respond that there is no Development Plan backing for delaying the TGB [6.1127]. The London Plan has been drawn up for the period to 2016, and represents the current properly adopted regional strategy [6.1717 to 6.1720]. 9.407 I take these points. I do not consider that there is a case for delaying a decision on the TGB scheme. Compliance with the Development Plan 9.408 Having considered all of those matters, I return to the fundamental issue of compliance with the Development Plan, issue (a) of the Secretary of States Statement of Matters. 9.409 The traffic model ultimately used (the Cordon Model) complies with few DMRB criteria and includes substantial discrepancies [9.57, 9.58]. It feeds into the economic case for the scheme, the regeneration case and the environmental case (in particular, through the noise and air quality assessments). Those are all key issues when considering the compliance of the scheme with the Development Plan. 9.410 I consider that the proposal complies with the adopted UDP for Greenwich and with the emerging UDP. I consider that substantial weight should be attached to the emerging UDP. Having regard to the stage that emerging document has reached, I do not consider the TGB application to be premature. 9.411 In relation to the Newham UDP, there is a need to consider the net effects of the scheme on the economy and the environment of the area. Those issues also arise (amongst others) in connection with the question of compliance with the London Plan. I therefore consider the issues at the same time in relation to both plans. 9.412 TfL have not used the WebTag guidance on appraisal in their consideration
563
of the economic impacts of the TGB scheme. They have used their own methodology. They argue that increased accessibility will improve employment and population density. Yet the same figures also suggest that improved accessibility increases the number of job seekers. The promoters model relies on an average travel to work time in London of 45 minutes, but that is at odds with the average travel to work times quoted in the Mayors Transport Strategy. Thus the accessibility effect of the scheme could be over estimated, and with it the regenerative effect. The promoters then argue that their conclusions on regeneration are supported both by developers in the area and by academic research. Few developers gave evidence at the inquiry and were open to cross examination, and the academic work on which reliance was placed (save for that of the promoters own witness) was again not open to cross examination. 9.413 At its highest, it seems to me, it can be said that the economic case suggests that the scheme would improve accessibility and lead to increases in employment and population density; but there is no reliable measure of the changed accessibility the scheme would bring, or of its consequences for the economy. Indeed, the do-minimum and do-something cases each assume the regeneration which they ascribe to the scheme to be independent of the scheme. They assume it would happen anyway, either in London or elsewhere in the South East. 9.414 Moreover, tolling is seen as an essential measure to control the amount of traffic able to use the scheme. But proposed changes in tolling arrangements discussed during the inquiry made a significant change to the prediction of the traffic model, and therefore reduced the prediction of the regeneration effects of the scheme. 9.415 For all of these reasons I question the extent to which the proposed development would bring net economic benefit to Newham (Policy T11 of their UDP) or contribute to Londons economic regeneration and development (Policy 3C.15 of the London Plan). It seems to me that there may be a benefit, but it is hard to determine how substantial it would be. 9.416 Turning to environmental impacts, the noise and air quality assessments are based on a traffic model of limited reliability. Subject to that, the noise effects of the scheme seem to me to be limited. I also have no difficulty regarding the impact of the scheme on flora and fauna or the issue of design. But I have concerns about air quality. It is accepted by the promoters that air quality would be worse in 2016 with the bridge that without the bridge. In an area in which air quality has historically been low, and where it is identified as a current problem, I do not regard that as acceptable. 9.417 It does not seem to me that this brings a net benefit to Newhams environment, or (in terms of the London Plan) a net benefit to Londons environment.
564
9.418 Given the possible economic benefit in Newham and the extent to which mitigation has been provided for, on balance, I consider that the scheme would comply with Newhams UDP. 9.419 This leaves Policy 3C.15 of the London Plan. 9.420 Accepting that the TGB would offer some contribution to Londons economic regeneration and development (criterion (a)), it would certainly increase the net traffic capacity of the corridor in a way which (on the evidence produced) cannot be claimed to be essential to regeneration (criterion (b)). I do not consider that it would provide a net benefit to Londons environment (criterion (c)), and I have indicated that I do not believe that it would improve safety for all road users (criterion (d)). Equally, I do not believe that it would improve conditions for pedestrians or cyclists (within criterion (e)). I consider that it would comply with the criterion (f) (integration with local and strategic land use policies) set out in Policy 3C.15 9.421 Given my conclusion that the second, third and fourth criteria would not be met, and that the fifth criterion would be only partially met, it is necessary to consider whether the scheme is in overall compliance with the policy. For this to be found, benefits in other areas must substantially outweigh any disbenefits, and unavoidable disbenefits must be mitigated. 9.422 In my view, the key to this is the economic regeneration benefits claimed for the scheme. If they had been robustly shown, they might have been sufficient to tip the balance. But I do not consider the evidence to be strong enough or reliable enough to outweigh substantially the disbenefits of the scheme in terms of increased traffic, reduced safety, increased air pollution, and a shift against walking, cycling and public transport, in favour of the private car. 9.423 Despite the very specific endorsement of the TGB in a variety of national and regional policy documents, I do not consider that the scheme now produced complies with Policy 3C.15 of the London Plan. The policies support a bridge in this area, but the proposed bridge does not in my view meet the policy requirements, given the adverse impacts which I find it would inevitably (and despite the proposed mitigation) cause. 9.424 I conclude that Development Plan. The determining issues 9.425 The determining issues in relation to the main bridge applications are, to my mind, very simple. They are: a. Do the applications conform to the adopted Development Plan?
565
the
proposal
does
not
conform
to
the
adopted
I have concluded that they do not comply with Policy 3C.15 of the London Plan. b. If not, are there relevant material planning considerations which indicate that the applications should be approved? 9.426 On this, I find few positive benefits flowing from the scheme. It could achieve a noteworthy design under the arrangements made by the promoters. It would appear to offer a good return on investment, though this is uncertain because of the limitations of the traffic modelling, which delivers the largest positive input. It could assist regeneration, but again the extent of the positive contribution is difficult to assess, and there is evidence that much of the positive result would occur with or without the bridge. There could be benefits to the health of the local community through reduction in unemployment, but, once more, the scale of the benefit is suspect, and this needs to be balanced against health disadvantages through air pollution. 9.427 On the other hand, I consider that the proposed TGB would not comply with national planning policy on transport, and it would result in a negative contribution to the Governments commitment to reducing greenhouse gases. 9.428 I do not consider that there are material considerations which indicate that the applications should be approved, notwithstanding their failure to conform to the adopted Development Plan. 9.429 I conclude that planning permission should be refused for applications ref: P/04/1170 and ref: 04/1800/F. 9.430 Should the Secretary of State reach a different conclusion from mine on the applications, I have set out at paragraph 9.320 and 9.321 above the issues dealt with in the Boroughs Agreement and the Unilateral Undertaking to which I consider weight should be attached in considering the applications. 9.431 I have also set out in Appendices C and D the conditions which I consider should be attached to any planning permissions. Other matters 9.432 One objector argued that Londons success in securing the 2012 Olympics had taken on an overriding importance during the course of the inquiry, particularly in relation to the relocation of businesses from the Lower Lea Valley, despite the fact that the TGB was not identified as part of the core transport investment package for the London Olympic bid [6.1686]. In response, TfL state (correctly, in my view) that they have made no great feature of the Olympics in their case. The latest estimate is that the bridge, if approved, would open after the conclusion of the 2012 Games; and it
566
would certainly not be open in time to assist with the relocation of businesses from potential Olympic sites [6.1706]. 9.433 In fact, two supporters of the scheme argue in written representations that there should be an expedited positive decision in relation to the TGB to allow the bridge and the Thames Gateway Transit network to make a contribution to the transport facilities serving the Games [5.174, 5.175], but this is not an argument adopted by the promoters. 9.434 T2000 ask me to recommend, on the basis of my experience at this inquiry, that the provision of resources for objectors to engage professional assistance to present their cases should become the norm at public inquiries. Such a recommendation is beyond my remit, but it was certainly helpful at this inquiry to receive the evidence of the expert witnesses engaged by the objectors with the benefit of funds provided by the promoters. 9.435 I attach to my report Documents 340/1/A1/2, 340/1/B, 340/3 and 340/4 which contain details of Mr Paul Berrys complaints regarding the processing of a Local Land Charges Search by Greenwich and regarding developments which took place in the immediate area of his former home at Thamesmead. I explained to Mr Berry at the inquiry that I did not regard these matters as material considerations in connection with the determination of the main bridge applications, but I promised to bring them to the attention of the Secretary of State [6.1519, 6.1520]. 9.436 The suggestion that traffic should be reduced by increasing the age for holding a driving licence to 21 [6.1754] raises a matter of policy which is not for me to consider at a public inquiry into one particular scheme [6.1779]. 9.437 SELTRANS referred to proposals for two major new orbital bus services around South London [7.39], but TfL have no current proposal for the services suggested, which, unlike the ELT and the GWT, are not mentioned in the Mayors Transport Strategy and the London Plan [7.44]. 9.438 An objector considered that, if the TGB were built, the Woolwich Ferry would be closed [6.917], but TfL responded that their proposals did not include the closure of the free ferry. Any closure or significant amendment to the ferry service would require the authority of an Act of Parliament [4.92, 6.960]. 9.439 The LCC expressed dissatisfaction with the London Cycling Action Plan [6.634], but it is not my function to conclude on that document or any other expression of established policy.
567
THE CONSTRUCTION SITE APPLICATION 9.440 The construction site in its revised location [1.17] would be close to the proposed bridge between Armada Way and the Thames, on the north side of the river [4.75]. 9.441 It is the subject of Addendum 1 to the ES, which provides a summary of the likely effects of the proposed use [4.78]. 9.442 It is in accordance with the Development Plan [8.72] and there has been no objection to it [1.51]. 9.443 Conditions designed to minimise the impact of what would be a temporary use are set out in Appendix E to this report [4.79, 4.326, 4.431]. 9.444 If the Secretary of State accepts my recommendations that planning permission is refused for the main bridge applications, then it is unlikely that any planning permission given for the construction site would be actioned. There is, however, no basis on which it is appropriate for me to recommend against the construction site application. 9.445 Subject to the conditions set out in Appendix E to this report, I conclude that planning permission should be granted on the construction site application ref: P/05/0428. THE SPECIAL ROADS SCHEME 9.446 The purposes for which the Special Roads Scheme is promoted are outlined in paragraph 1.27 above. Sections 16, 17 and 106 of the HA 1980 do not provide criteria for confirmation, though the Secretary of State is required to give due consideration to the requirements of local and national planning, including the requirements of agriculture. I do not consider that any issue regarding agriculture arises in this case. 9.447 The Special Roads Scheme would provide the authority to build a bridge over the navigable waters of the river. Its confirmation is also essential if tolls are to be charged under the Toll Order for crossing the proposed bridge. The ability to charge a toll is essential to the system for controlling the extent of the use of the bridge and the impact of traffic on the surrounding area [4.460]. 9.448 It is clear from the conclusion I have reached in relation to the main bridge applications that I do not consider that the requirements of local and national planning would be served by the granting of planning permission for the main bridge applications. If the Secretary of State agrees, then I do not see that confirmation of the Special Roads Scheme would be justified. The promoters themselves stated that if planning permission for the TGB is refused, it would be virtually inevitable that the Scheme would not be
568
confirmed [8.70]. 9.449 I conclude that the Special Roads Scheme should not be confirmed. 9.450 If, however, the Secretary of State disagrees with my conclusion in relation to the main bridge applications, then I note that no ground of objection specifically relating to the Special Roads Scheme remains outstanding [4.462]. The many general objections to the overall TGB proposal which include an objection to the Special Roads Scheme do not identify any particular ground of objection to that Scheme. 9.451 In that Special forward inquiry, event, it seems to me that there would be no reason why the Roads Scheme, with the incorporation of the amendments put by the promoters on 26 April 2005 before the opening of the which are set out in Document D859, should not be confirmed.
THE SIDE ROADS ORDER 9.452 The purposes for which the Side Roads Order is promoted are set out in paragraph 4.464 above. The details of the highways which would be improved, stopped up or created, together with the details of the new private means of access which would be created, are set out in the schedules to the Side Roads Order, as amended by Document D859 and by Document TfL/159. 9.453 The promoters ask for the Side Roads Order to be confirmed, incorporating the amendments contained in both those documents [4.465]. 9.454 The Side Roads Order is made under Sections 14, 18 and 125 of the HA 1980. Again, the Act does not provide criteria for confirmation of a Side Roads Order. Before stopping up any highway or private means of access under the Order, however, the Secretary of State must be satisfied that reasonably convenient replacement sections of highway would be provided under the Order for all highways which would be stopped up as required by Section 14(6) of the HA 1980; for all private means of access to be replaced or unnecessary under Section 125(3) of the Act; and for reasonable alternative provision to be available under Section 18(6) of the Act for any class of traffic excluded from a special road. 9.455 No existing private means of access to any premises would be affected by the Order [4.468]. Compliance with the other points listed above has not been challenged by any objector. 9.456 Subject to those points, the relevant test for confirmation is whether it is appropriate to confirm the Order, balancing any public or private disadvantages against any public benefits. 9.457 It is clear from the conclusion I have reached in relation to the main bridge
569
applications that I do not consider that it would be appropriate to confirm the Order, balancing public and private disadvantages against public benefit. If the Secretary of State agrees, then I do not see that confirmation of the Side Roads Order would be justified. The promoters themselves stated that if planning permission for the TGB is refused, it would be virtually inevitable that the Order would not be confirmed [8.70]. 9.458 I conclude that the Side Roads Order should not be confirmed. 9.459 If, however, the Secretary of State disagrees with my conclusion in relation to the main bridge applications, then I note that no reasoned ground of objection specifically relating to the Side Roads Order remains outstanding. The many general objections to the overall TGB proposal which include an objection to the Side Roads Order do not identify any particular ground of objection to that Order. 9.460 In that event, it seems to me that there would be no reason why the Side Roads Order, with the incorporation of the amendments put forward by the promoters on 26 April 2005 before the opening of the inquiry which are set out in Document D859 and those contained in Document TfL/159 should not be confirmed. THE COMPULSORY PURCHASE ORDER 9.461 The legal tests against which the Compulsory Purchase Order falls to be considered are, first, whether all the land is required for the proposed construction or operation of the TGB; and, secondly, whether the acquisition falls within the statutory powers under which TfL seek to acquire the land. These are Sections 239, 240, 245, 246, 249, 250 and 260 of HA 1980. They cover the acquisition of land and rights over land for the construction or improvement of a highway, land to provide buildings or facilities in connection with a highway, mitigation land, and land to be provided in exchange for open space land acquired. 9.462 ODPM Circular 06/04, the current Government guidance on compulsory purchase, does not apply to this scheme, because of the transitional provisions contained in paragraph 4 of that Circular and paragraph 9 of Part 1 of the Memorandum to the Circular. TfL have indicated, however, that they would accept the recommendation contained in paragraph 4 of Part 2 of the Memorandum to Circular 06/04, in that TfL would offer back to any dispossessed freeholder or long leaseholder under the revised Crichel Down Rules land acquired compulsorily if, in the longer term, continuing ownership of the land was not necessary for the scheme [4.471]. 9.463 The guidance which does apply to this scheme is contained in ODPM Circular 02/03 [4.472]. That Circular requires that there is a compelling case for compulsory acquisition of the land covered by the Order in the public interest; that this justifies interfering with the human rights of those with an interest in the land affected; that the acquiring authority have a
570
clear idea of how the land covered by the Order would be used; that all necessary resources to carry out the plans are likely to be available within a reasonable timescale; and that the scheme is unlikely to be blocked by any impediment to implementation. 9.464 If the Secretary of State accepts my conclusion that planning permission for the main bridge applications should not be granted, then it would not be possible for the proposed bridge to be built. The scheme would therefore be blocked by the most fundamental possible impediment to implementation. 9.465 I conclude, therefore, that the Compulsory Purchase Order should not be confirmed. 9.466 If the Secretary of State were to take a different view in relation to the main bridge applications and to grant planning permission, then the other tests in relation to the Compulsory Purchase Order would fall to be considered. I therefore express an opinion on them here. 9.467 The promoters seek to acquire the freehold interest and all subsidiary interests in the land required for the footprint of the road infrastructure which is not already within their ownership. In addition, the Order covers a 5m strip of land adjacent to the bridge in order to provide access for its future maintenance and repair. The extent of the land covered by the Compulsory Purchase Order is therefore determined primarily by the design of the road [4.474 to 4.479]. 9.468 In addition, however, [4.477] sufficient land has been included within the Order: a. to permit some design flexibility in the position of the bridge piers for the main bridge over the River Thames. b. to provide exchange open space land to replace public open space on the south eastern bank of the river in Greenwich required for the scheme. c. to provide reasonable temporary work sites for the contractor. These are necessary to avoid foreseeable delay to the construction programme which might arise if a landowner found it possible to seek ransom payments from a contractor for working space. d. to provide mitigation of the impact of the scheme, for example by landscaping. 9.469 I consider that all the land and interests in land covered by the Compulsory Purchase Order as now put forward for confirmation by the promoters would be required for the proposed construction or operation of the TGB
571
including the purposes listed above, and the acquisition of all of it would be within the statutory powers upon which the promoters rely. 9.470 During the course of the inquiry, the promoters continued to negotiate with owners of land within the Compulsory Purchase Order, and, as a result, some amendments to the Order are sought by the promoters which would reduce the total land covered by the Order as indicated at paragraph 1.29 above. Document TfL/313C/1 shows the Order in the form in which TfL now ask for it to be confirmed. This includes some small parcels of land which were not covered by the Order as originally drafted. In each case, the consent of the owner of the land to its inclusion in the Order has been obtained. The detailed reason for each variation from the original Order is set out in Document TfL/313B. That Document also includes the agreement of the owners of additional parcels of land to their inclusion in the Order [4.479]. 9.471 If planning permission is granted for the bridge, it could not be built without the compulsory purchase of the necessary land. 9.472 The Order would necessitate the acquisition of some private interests in land, but, by negotiation, its impact on individuals has been minimised. All statutory objections to the Order have been withdrawn [4.481]. The only remaining reasoned objection to the Compulsory Purchase Order comes from Mr B Martin, and is reported at paragraph 6.1753 above. Given the conclusion I have reached regarding the potential impact of the proposed scheme on flora and fauna and conservation sites at paragraph 9.256 above, and given the provision that the promoters would propose to make for replacement open space, if the Secretary of State were to grant planning permissions for the construction of the proposed bridge, I do not consider that Mr Martins objection to the Compulsory Purchase Order should be sustained. 9.473 There would be no acquisition of residential property under the Order, nor would any commercial building be acquired. Only one small building would be demolished, a derelict World War II pill box [4.482]. 9.474 If the Secretary of State were to conclude that planning permission for the main bridge applications should be granted, it would be necessary to consider the question whether there was a compelling case for the compulsory acquisition of the land covered by the Order in the public interest, and whether this justified interfering with the human rights of those with an interest in the land affected. 9.475 Subject to those points, I consider that the acquiring authority would have a clear idea of how the land covered by the Order would be used; that the resources to carry out the scheme would be likely to be available within a reasonable timescale [4.448 to 4.454]; that the scheme would be unlikely to be blocked by any impediment to implementation [4.484]; and that the scheme could be resourced and completed within a reasonable time
572
[4.483]. 9.476 There was no substantial challenge to the evidence of the promoters on these points. THE TOLL ORDER 9.477 The New Roads and Street Works Act 1991 does not set out any criterion for the making by TfL or the confirmation by the Secretary of State of the Toll Order. It is sufficient if the Secretary of State is satisfied that it is appropriate to confirm the Order [4.493]. 9.478 If (but only if) the Special Roads Scheme is confirmed, so that the TGB becomes a special road, then the Secretary of State must also confirm the Toll Order. Section 6(5) of the New Roads and Street Works Act 1991 provides that The Secretary of State shall not make or confirm the scheme or the toll order unless he makes or confirms them both. [4.494]. 9.479 Given that I have concluded that the Special Roads Scheme should not be confirmed, it follows that I conclude that the Toll Order should also not be confirmed. 9.480 Against the possibility that the Secretary of State might reach a different conclusion in relation to the Scheme, however, I go on to consider the Toll Order and the objections to it in greater detail. 9.481 The Toll Order would empower TfL to charge tolls for the use by specified vehicular traffic of the scheme up to maxima established by the Order in terms of 2004 prices, adjusted by a formula set out in the Order. TfL propose two modifications to the Order. That set out in TfL/214 would raise the original maximum tolls (that is, the 2004 prices). The modification set out in TfL/332 would rectify a drafting error in the Order. The purposes of the tolls are to regulate traffic on the bridge and to contribute towards its cost [4.134], and it seems to me that both would be necessary parts of the scheme proposals. TfL expect in practice that the tolls set would be lower than the maxima provided by the Order, and they would monitor and if necessary vary the tolls from time to time following consultation with the BCG [4.135]. 9.482 Those who objected to the tolls did so for various reasons, and I consider each in the following paragraphs. There were also issues raised by objectors regarding the proposed toll discount area, which I have dealt with in considering the regeneration case. 9.483 The objection that tolls would discriminate particularly against poorer people, contrary to the regeneration objective of the scheme [6.969,
573
6.1037]. Residents of the discount area who used the bridge to drive to work would pay 1 per crossing at 2004 prices [4.140], equivalent to 10 per 5-day working week. It is indisputable that this would weigh more heavily on lower paid motorists. But the regenerative effect of the scheme would probably include some new jobs on each side of the river [4.390], and this would offset such disadvantage to a degree. 9.484 The objection that the tolls may be removed at some time in the future, and the control on traffic they would provide would be lost [6.1036]. Since there is no power in law to include a minimum toll in a Toll Order [4.135], this objection could not be met by modification of the Order. But it seems to me that the network management duty imposed by the Traffic Management Act [4.135] introduces an appropriate control on TfLs future actions in this regard. 9.485 The objection that the Boroughs Agreement (TfL/22C) should set out the criteria to be considered when tolls are set [6.47]. In its executed form, the Boroughs Agreement does contain in clause 6.2 and Schedule 9 a list of matters which would be considered (along with all other relevant matters) in determining the tolling regime. It seems to me improbable that a completely comprehensive and exclusive list of circumstances that would remain appropriate until about 2053 could be formulated now. I do not consider that the absence from the Boroughs Agreement of an definitive list of criteria is an obstacle to confirmation of the Toll Order. 9.486 The objection that the tolls would create an incentive for the concessionaire to maximise revenue by maximising traffic on the bridge [6.861, 6.1640]. Tolls would be set by TfL following consultation with the BCG [4.433, 4.451]. The concessionaires actions to maximise revenue would be the same as the good management of any other road, by maintaining availability [6.937]. This is not at odds with the objectives of the scheme. 9.487 The objection that a toll alone could not effectively control traffic volumes [6.862]. Parallels were drawn with the M6 toll road, objectors arguing that experience there shows tolls to be an unreliable demand management tool [6.862] and the promoters arguing that it does not [4.142]. But the promoters assessment of the effect of tolls at the scheme relies on equivalences of travel time and cost produced by Transport Research Laboratory for general use in such cases [4.119], and I therefore attribute considerable weight to its method and to the consequent proposition that tolls are an effective instrument to control traffic volumes. This view is implicitly accepted by those who argue that the change in the proposed discount area made during the inquiry would affect use of the bridge. 9.488 The objection that, since low tolls would generate little income and high tolls would deter traffic, tolls would generate insufficient revenue to fund the scheme [6.1318]. The promoters evidence on the financing of the scheme [4.451] illustrates, on the basis of a considered analysis, that tolls would contribute adequately to its overall cost and there is no evidence to the contrary.
574
9.489 The objection that the formula in the Order would not be sensitive to use of the bridge by non-local traffic [6.3]. The formula in the Order would establish the maximum toll, but would not establish the actual toll or the amount or application of any discount for local traffic. Those would be set by TfL following consultation with the BCG [4.135] and could allow for differential charges for long distance and local traffic on the bridge. Registered local traffic would be routinely identified by the toll collection system [4.139], and it seems to me that this would allow the collection of sufficient information to establish adequately the degree of use of the bridge by unregistered, non-local traffic. Provided that the maximum toll was set high enough, if an unexpectedly high level of non-local traffic was found to use the bridge, then that situation could be addressed by raising the toll for such users. 9.490 The objection that the proposed tolls would operate unfairly on motorcyclists [6.1742 to 6.1744]. TfL wish to wait until just before the proposed bridge opens before deciding whether to impose a toll on motorcycles, and, if so, at what level [4.491]. As presently drafted, the Toll Order would impose the same level of toll on motorcycles as on cars and motor caravans [4.135, 4.140]. The Order would allow, however, for different levels of toll to be imposed on different classes of traffic [4.488]. Motorcycling interests claim that it is almost unprecedented in UK for motorcycles to be charged at the same level as cars, and that, in many situations in which tolls apply, motorcycles are exempt from any charge at all. The Central London Congestion Charge is a case in point, as is the toll regime at the Dartford Crossing [6.1742]. Government policy is broadly supportive of motorcycles [6.1743], and no evidence has been adduced to support making the same charge for a motorcycle as for a car [6.1742]. I understand the concern of those representing motorcyclists to resolve this issue now. I do not accept, however, that it should be resolved in the way they seek (by exemption from the toll). I consider that it is important to allow the promoters of the TGB scope to react to any situation which might apply in the future of a charge being made for motorcycles at Dartford. If a charge were to be introduced there, and if there were no possibility of charging for motorcycles on the TGB, this could lead to many more motorcyclists deciding to use the TGB in preference to the Dartford Crossing, with consequent loading of motorcycle traffic on the TGB and the roads serving it to a much greater extent than currently envisaged or predicted. With some reluctance, therefore, I conclude that no amendment should be made to the Order to exempt motorcycles from the toll. I consider that the issue should be left to be determined as the promoters suggest. 9.491 The objection that the proposed tolls would be too low [6.45, 6.1162]. Bexley Councils proposal for the maximum toll for cars etc. and its pro rata application (as Bexley Council suggest) for other types of vehicle are compared in the following table with the promoters original proposals set out in the Order and the promoters modified proposals:
575
Comparison of toll proposals (July 2004 prices) Description of traffic Original Maximum Toll Promoters proposed initial peak period nondiscounted toll
TfL original (published Order) Motor cars, motor cycles and motor caravans Small goods vehicles Any other vehicles 4.00
TfL current [4.135]
Bexley Council [6.45]
6.00
10.00
3.00
5.40
8.10
13.50
4.00
8.70
13.05
21.75
6.50
9.492 The promoters derive their tolling proposals from their assessment of traffic behaviour, for which they use the traffic model. But the traffic model is in my view of limited reliability, as I indicate above. The promoters intend that errors in the modelling would be addressed by use of the tolls to regulate traffic, but the scope to do that would be limited by the maxima allowed by the Toll Order. If 25% more traffic sought to use the bridge than the promoters expect, then TfL expect that the maximum tolls they propose would be just adequate to regulate traffic [4.145]. 9.493 If such a case arose and the model were to prove insufficiently reliable, or if an increase in demand greater than 25% above TfLs expectations arose, then the view that acceptable conditions could be maintained might be confounded. There would then arise the need for a revision of the Toll Order, requiring statutory procedures and possibly a local inquiry. This would take time, and detract from the flexibility which such circumstances could demand and which the promoters and Bexley Council consider necessary. It would also offer the opportunity for a concessionaire to block any revised maximum toll not considered to be acceptable [6.46]. 9.494 The possibility of such a loss of effective flexibility arising would be markedly reduced if the Toll Order were made in such terms as to provide greater ability to accommodate the unexpected, which might be necessary in view of the lack of reliability of the traffic model. This would not prevent
576
the charging of actual tolls as proposed by the promoters, should that be sufficient; but it would provide additional scope for traffic control if the need arose. It therefore seems to me that, if the Order were to be made, the modification to the Original Maximum Tolls in the Toll Order suggested by Bexley Council should be incorporated in the Order. 9.495 Paragraph 7(2) of Schedule 2 to the New Roads and Street Works Act (D210) refers to cases in which substantial changes to an advertised Toll Order would be incorporated in the made or confirmed Order. The modification proposed by the promoters would increase the maximum allowed tolls by 50%, and that proposed by Bexley Council would do so by 150%. It seems to me that either of these changes would be substantial. 9.496 If it is considered that the Toll Order should be confirmed, it would be necessary to weigh the need for the traffic regulation and income generation that the tolls would allow in the context of the scheme against the disadvantage that the proposed toll regime would have for those poorly paid motorists who would need to drive their cars across the bridge to work. Whatever the overall degree of regeneration facilitated by the scheme, it seems to me that such disadvantage would be likely to be small in comparison to the need that the tolls would satisfy. 9.497 I consider that, provided the Special Roads Scheme is confirmed, and it is concluded that the A2012 GLA Road (Thames Gateway Bridge) Toll Order 2004 should similarly be confirmed, the Toll Order should be modified as set out in the following table and as requested by the promoters in Article 4(3), and then confirmed, subject to the requirements of paragraph 7(2) of Schedule 2 to the New Roads and Street Works Act. In Article 4(1), leave out the table and insert the following table: Description of traffic (1) Original maximum toll for one way use of the new road at July 2004 prices (2) 10.00
a) Motor cars, motor cycles and motor caravans b) Small goods vehicles c) Any other vehicles
13.50 21.75
Environmental information 9.498 In coming to conclusions on the applications, the Scheme and Orders before
577
the inquiry, I have had regard to the environmental information contained in the ES and its three Addenda [1.24 to 1.26], to the comments on it from the statutory consultees and members of the public, to the mitigation measures proposed [8.42], and also to the environmental information derived from evidence given at the inquiry and contained in representations to the inquiry.
10 RECOMMENDATIONS 10.1 I recommend that planning permission be refused for application ref: P/04/1170. I recommend that planning permission be refused for application ref: 04/1800/F. I recommend that planning permission be granted for application ref: P/05/0428, subject to the conditions set out in Appendix E to this report. I recommend that the A2012 GLA Road (Thames Gateway Bridge) Special Roads and Bridge Scheme 2004 be not confirmed. I recommend that the A2012 GLA Road (Thames Gateway Bridge) (Side Roads) Order 2004 be not confirmed. I recommend that the A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 be not confirmed. I recommend that the A2012 GLA Road (Thames Gateway Bridge) Toll Order 2004 be not confirmed.
10.2
10.3
10.4
10.5
10.6
10.7
Michael Ellison
INSPECTOR
578
579
APPENDIX A THAMES GATEWAY BRIDGE INQUIRY - LIST OF APPEARANCES FOR THE PROMOTER Transport For London Mr Charles George QC and Mr Timothy Comyn of Counsel instructed by Rees and Freres, Solicitors and Parliamentary Agents, 1 The Sanctuary, Westminster, London SW1P 3JT They called: Mr Henry Abraham MA MSc Mr George Kennedy MSc CEng MICE Mr Stephen Ellison CEng MICE MIHT Mr Richard Smith BA MSc Professor Bridget Rosewell MA MPhil Dr Stephen D Allen BA PhD Professor Richard Burdett BA (Hons) MSc Dip Arch FRIBA Mr Ralph O Cobham BA MSc Mr Michael C Clarke CEng MICE MIMM Mr Michael J Adams BA Dip TP MRTPI MIHBC Professor Duncan Laxen PhD MSc BSc Dr Michael E Fillery BSc MSc PhD FIOA Dr Jo C Hughes BSc PhD MIEEM Mr Adrian C Maher BSc MRICS Mr Chris A Swiderski BA
FOR THE SUPPORTERS The London Borough of Greenwich Mr Timothy Jones of Counsel, instructed by the Solicitor to The London Borough of Greenwich, Peggy Middleton House, 50 Woolwich New Road, Woolwich, SE18 6HQ. He called: Mr Frederick Brown BA MRTPI Mr John H Hopkins MSc BSc MICE FIHT Mr Andrew Whittles BSc (Hons) Mr Bob Chard MPhil (Arch) MA BA DipTP MRTPI The London Borough of Newham Mr Hereward Philpott of Counsel, instructed by the Solicitor to The London Borough of Newham, Town Hall Annexe, 330-354 Barking Road, East Ham, London, E6 2RT. He called: Mr Andrew P Merritt BSc MSc MIHT Mr Peter Minoletti BA (Hons) MRTPI Mr Ian Fines MSc DipTP MRTPI Mr Robin Whitehouse MCIEH The London Borough of Redbridge Ms Jenny Wigley of Counsel, instructed by the Solicitor to the London Borough of Redbridge, 128-142 High Road, Town Hall, Ilford, Essex, IG1 1DD and subsequently Mrs C Goodman (Solicitor) They called: Mr Billy Parr BA (Hons) AMIHT The Thames Gateway London Partnership, Anchorage House, 2 Clove Crescent, East India Dock, Leamouth, London, E14 2BE Mr Stephen Joseph MSc and Mr Peter Morley They called:
Ms Vivien Cutler BA (Learning and Skills Council, London East) Mr Peter Gluckman BA MSc (South East London Strategic Health Authority) Mr Aman Dalvi MSc MCIH (Gateway to London) Mr Joseph also gave evidence himself London First, 1 Hobhouse Court, Suffolk Street, London, SW1Y 4HH Mr. Stuart Robinson Dip TP MRTPI The London Development Agency, 58-60 St Katherines Way, London, E1W 1JX Mr. Tony Winterbottom Mr S Borella, 39A Pembroke Road, Erith, DA8 1BY
FOR THE OBJECTORS The London Borough of Bexley Mr Richard Humphreys of Counsel, instructed by the Solicitor to The London Borough of Bexley, Legal Services, Bexley Civic Offices, Broadway, Bexleyheath, Kent, DA6 7LB He called: Mr Terry Wang BSc MSc (Soils) MSc (Transport) CEng MICE FCILT Mr Richard Hawkins MSc CEng MICE MIHT MCIT
The following witnesses gave evidence on behalf of an informal alliance of Objectors, funded by grants from the Mayor of London and the Promoter Mr Keith Buchan, MSc MIHT, Director, Metropolitan Transport Research Unit, 4 Netheravon Road, London W4 2NA Professor Phil Goodwin, University of the West of England, Bristol Professor John Whitelegg, University of York Liverpool John Moores University and
Professor Caralampo Focas, Visiting Professor of Engineering and Economics, University of Budapest
Professor Mark McCarthy MA PhD, University College London Mr John Elliott, CEng MICE MCIM FIHT Mr Philip Connolly, 39 Derrick Gardens, Anchor and Hope Lane, Charlton, London SE7 7TA Transport 2000 Mr Richard Bourne, 12-18 Hoxton Street , London, Friends of The Earth, Ms Jennifer Bates. 26-28 Underwood Street, London, N1 7JQ London City Airport Ms Pat Thomas, Solicitor, Partner, SJ Berwin LLP, Planning and Environment Group, 222 Grays Inn Road, London, WC1X 8XF She called Mr Robert Grafton BSc (Hons) London Cycling Campaign Mr Ralph Smyth, 2 Newhams Row, London, SE1 3UZ He called Mr Roger Geffen MA, Campaign and Policy Manager, Cycling Tourists Club Mr Richard Lewis BA (Hons) Greenwich and Lewisham Friends Of The Earth Mr Dominic Clarke, Belmont Hall Court, Lewisham, SE13 5DU Action Group Against the Bridge and St Michaels Residents Association, Mrs Jacqui Wise, 42 Berkeley Avenue, Bexleyheath, Kent, DA7 4UA Mr Steve Wise 42 Berkeley Avenue, Bexleyheath, Kent, DA7 4UA Mr Terry Grant, 34 Albury Avenue, Bexleyheath, Kent, DA7 4SJ They gave evidence and called N1 6NG
Mrs Ida Brown Mrs Tracey Hilliard Greenwich Action to Stop Pollution Mr Philip J Connolly, 39 Derrick Gardens, Anchor and Hope Lane, Charlton, London, SE7 7TA London Thames Gateway Forum Ms Genia Leontowitsch, 192 Hanbury Street, London, E1 5HU The Simon Wolff Charitable Foundation Mr George Stern, MA (Cantab), MSc, MORS, FRSS, Barrister-at-Law, and Mrs Nina Tuckman, 86 Harberton Road, London, N19 3JP They gave evidence and called Ms Lindis Hallan, Chair of the Trustees of the Foundation People Against the River Crossing Dr Barry Gray, MA, MD, FRCP, 25 Eaglesfield Road, Shooters Hill, London, SE18 3BX Friends of Danson Park Mrs Lynn Batham, 112 Crayford Road, Crayford, Kent, DA1 4ER Bexley Civic Society Mr John Mercer, 65 Longlands Road, Sidcup, Kent, DA15 7LQ Woolwich and District Antiquarian Society Mrs Susan Parker, SRN, Dip Arch, 11 Riverview Heights, Eglinton Hill, London, SE18 3DZ Saints Residents Association Mr Tim Chapman, 40 Watersmeet Way, Thamesmead, London, SE28 8PU Bexley Federation of Residents Associations Mr R Hudson, 10 Canberra Road, Bexleyheath, Kent, DA7 5FC Manor House Neighbourhood Residents Association, Sidcup
Mr R Gee, C Phys, M Inst P, 24 Elm Road, Sidcup, Kent, DA14 6AD Belvedere Community Forum Mr John Livingstone, IEng, MIRTE, 32 Milton Road, Belvedere, Kent, DA17 5BA Bexley LA21 Traffic and Transport Focus Group and the A2 (Bexley) Environmental Campaign Committee Mr Ian Lindon, 52 Basing Drive, Bexley, Kent, DA5 1ER Bexley LA21 Natural Environment Focus Group Mr Jeremy Cotton, BSc, CBiol, MIBiol, 43 Whernside Close, London, SE28 8HB Greenwich Wildlife Advisory Group Mr Jeremy Cotton, BSc, CBiol, MIBiol, 43 Whernside Close, London, SE28 8HB Mr Jeremy Cotton, BSc, CBiol, MIBiol, 43 Whernside Close, London, SE28 8HB London Region Liberal Democrats Ms Susan Kramer MP c/o Mr David Raval, 6 Alander Mews London, E17 9SA Mr Clive Efford MP, 132 Westmount Road, Eltham, London, SE9 1UT Mr David Evenett MP, House of Commons, Westminster, London, SW1A 0AA Mr John Austin MP, House of Commons, Westminster, London, SW1A 0AA Mr Robert Neill AM, Greater London Authority, City Hall, The Queens Walk, London SE1 2AA Councillor Ian Clement, Bexley Civic Offices, Broadway, Bexleyheath, Kent, DA6 7LB Councillor Peter Catterall, 17 Mount Road, Bexleyheath, Kent, DA6 8JS Councillor John Waters, 54 Parkhurst Road, Bexley, Kent, DA5 1AS Mr Philip Connolly, 39 Derrick Gardens, Anchor and Hope Lane, Charlton, London SE7 7TA
Mr Roy Carrier, 95 Woolwich Road, Abbey Wood, London, SE2 0DY Mr Kenneth Hobday, 33 Commonwealth Way, Abbey Wood, London, SE2 0LD Mrs Ida Brown 60 Pickford Lane, Bexleyheath, Kent, DA7 4QX Mr Brian Baker, 30 Albury Avenue, Bexleyheath, Kent, DA7 4SJ Mr Phil Hawkes, 32 Albury Avenue, Bexleyheath, Kent, DA7 4SJ Mr Roger Butler, 371 Brampton Road, Bexleyheath, Kent, DA7 5SA Mr Dave Reynolds, BSc, MIEE, CEng, 43A Faygate Crescent, Bexleyheath, Kent, DA6 7NS Mr Robert Watson, 156 Belvedere Road, Bexleyheath, Kent, DA7 4PE Mr Gordon Winbourne, RIBA, 10 St Leonards Road, Epsom Downs, Surrey, KT18 5RH Mrs B Caymen, 24 Longleigh Lane, Bexleyheath, Kent, DA7 5SR Mrs Margaret Cowell, 76 Hurst Road, Sidcup, Kent, DA15 9AA Mrs Zoe Harris, 242 Rybell Drive, Bexleyheath, Kent, DA7 5DG Mrs J Cowell, 50 Walton Road, Sidcup, Kent, DA14 4LN Mr and Mrs G R A Holt, 45 Danson Road, Bexleyheath, Kent, DA6 8HJ Mr and Mrs A Ruddell, 153 Brampton Road, Bexleyheath, Kent, DA7 4SR Mr Paul Berry, 21 Madison Gardens, Bexleyheath, Kent, DA7 5SU Mr David Black, BSc, PGCE, 62 Burnell Avenue, Welling, Kent, DA16 3HW Mr Glen Cook, 2 Fairlawn Avenue, Bexleyheath, Kent, DA7 4TG Mr Matthew Scott, BSc, 85 Orchard Rise West, Sidcup, Kent, DA15 8TA Mr Michael Winship, 47 Clarence Road, Sidcup, Kent, DA14 4DL Mr John Davey, 5 Pinewood Road, Abbey Wood, London, SE2 0RY Mrs Jacqueline Barter, 132 Lodge Hill, Welling, Kent, DA16 1BL Mrs Joyce Weston, 23 Tavistock Road, Welling, Kent, DA16 1HH Mrs Sue Routner, 73 Waldstock Road, Thamesmead, SE28 8SF
Mr R Pudney, 19 Priory Drive, Abbey Wood, SE2 0PP Mrs Ann Hutchinson, 58 Sandtoft Road, Charlton, London, SE7 7LR Mrs Joan Glastonbury, 19 Sandhurst Road, Bexleyheath, Kent, DA5 1DD Ms Janet Mackinnon, MA, MSc, Studio 208, 79 Friar Street, WR1 2NT Worcester,
Ms Jo Thomson, 13 Lancaster Gardens, Wimbledon, SW1T 5DD Ms Jannette Graham, 12 Ashen, Beckton, London, E6 6WY Mrs H Joyce, 68 Pickford Lane, Bexleyheath, Kent, DA7 4QX
FOR BODIES WHICH MADE REPRESENTATIONS AT THE CONDITIONS SESSIONS The Port of London Authority Mr James Trimmer, Bakers Hall, 7 Harp Lane, London, EC3R 6LB The Environment Agency Mr Ben King and Ms Antonia Scarr, 10 Albert Embankment, London, SE1 7SP London Thames Gateway Development Corporation Mr Peter Minoletti, 9th Floor, South Quay Plaza 3, 189 Marsh Wall, London E14 9SH
APPENDIX B THAMES GATEWAY BRIDGE INQUIRY - LIST OF DOCUMENTS Deposit Documents Policy & plans D101
National Road Safety Strategy: Tomorrows Roads Safer for Everyone. DETR, March 2000 D102 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland: Working Together for Cleaner Air. DETR, January 2000 D103 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland: Addendum. DEFRA, 2003 D104 Transport 2010: The 10 Year Plan. DETR, July 2000 D105 The White Paper on the Future of Transport: A New Deal for Transport: Better for Everyone. Department of Transport, 1997 D106 Biodiversity: The UK Action Plan. Department of the Environment, January 1994 D107 Waste Strategy 2000 for England and Wales. DETR, 2000 D108 The Future of Transport: a Network for 2030. Department for Transport, July 2004 Documents D109 D200 not used Legislation D201 D202 D203 D204 D205 D206
D207 D208 D209 D210 D211 D212 D213 D214 D215 D216 D217 D218 D219 D220
Acquisition of Land Act, 1981 Ancient Monuments and Archaeological Areas Act, 1979 Disability Discrimination Act, 1995 Environmental Protection Act, 1990 Food and Environmental Protection Act, 1985 Fourth Quinquennial Review of Schedules 5 and 8 of the Wildlife and Countryside Act 1981 Report and Recommendations. Joint Nature Conservation Committee, September 2002 Greater London Authority Act, 1999 Highways Act, 1980 Land Drainage Act, 1991 New Roads and Street Works Act, 1991 Planning Listed Buildings and Conservation Areas Act, 1990 Port of London Act, 1968 Radioactive Substances Act, 1960/1993 Road Traffic Regulation Act, 1984 Section 61 Prior Consent authorisation under the Control of Pollution Act Thames Regions Land Drainage Bylaws, 1981 Countryside and Rights of Way Act, 2000 Water Resources Act, 1991 Wildlife and Countryside Act, 1981 Town And Country Planning (Safeguarding Aerodromes, Technical Sites and Military Explosives Storage Areas) Direction, 2002
D221 D222 D223 Documents D224 EU Directives D301
Land Compensation Act, 1973 Planning and Compulsory Purchase Act, 2004 Town and Country Planning Act, 1990 D300 not used
Council Directive 97/11/EC amending Directive 85/337/EC, March 1997 D302 Council Directive 85/337/EC The Assessment of the Effects of Certain Public and Private Projects on the Environment, June 1985 D303 Council Directive 2000/60/EC Establishing a Framework for Community Action in the Field of Water Policy, October 2000 D304 Council Directive 91/689/EEC Hazardous Waste, December 1991 D305 Council Directive 1999/31/EC Landfill of Wastes, April 1999 D306 Council Directive 2002/49/EC Assessment and Management of Environmental Noise, 2002 D307 Directive 2003/10/EC Minimum Health and Safety Requirements regarding the Exposure of Workers to the Risks arising from Physical Agent (Noise) 2003 Documents D308 D400 not used Regulations D401 D402
Groundwater Regulations, 1998 Pollution Prevention and Control (England and Wales) Regulations, 2000 D403 Pollution Prevention and Control (England and Wales) (Amendment) Regulations, 2002 D404 Not Used D405 Not Used D406 Conservation (Natural Habitats & C.) Regulations, 1994 D407 Hedgerow Regulations, 1997 D408 Landfill (England and Wales) Regulations, 2002 D409 Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations, 1999 D410 Waste Management Licensing Regulations, 1994 D411 Noise Insulation Regulations, 1975 D412 Noise Insulation (Amendment) Regulations, 1988 D413 Air Quality (England) Regulations, 2000 D414 Air Quality (England) Amendment Regulations, 2002 Documents D415 to 500 not used Design Standard/Advice/Guidance D501 Compulsory Purchase and Compensation - Compulsory Purchase Procedure. ODPM, October 2004 D502 Compulsory Purchase and Compensation - Compensation to Business Owners and Occupiers. ODPM, October 2004 D503 Compulsory Purchase and Compensation - Compensation to Agricultural Owners and Occupiers. ODPM, October 2004
D504 D505 D056 D507 D508 D509 D510 D511 D512 D513 D514 D515 D516 D517 D518 D519 D520 D521 D522 D523 D524 D525 D526 D527 D528 D529 D530 D531 D532 D533
Compulsory Purchase and Compensation - Compensation to Residential Owners and Occupiers, ODPM, October 2004 Compulsory Purchase and Compensation - Mitigation Works. ODPM, October 2004 Biodiversity Strategy and Action Plan for the Environment Agency (Thames Region), December 2000 British Standard (BS) 5228 Part 1: Code of Practice on Noise Control on Construction and Demolition Sites, 1997 BS 5228 Part 4: Code of Practice for Noise and Vibration Control Applicable, 1992 Not Used BS 6472: Guide to Evaluation of Human Exposure to Vibration in Buildings (1Hz to 80 Hz), 1992 BS 7445: Description and Measurement of Environmental Noise, 1991 BS 8233: Sound Insulation and Noise Reduction for Buildings, 1999 BS 5489 Part 1: Lighting of Roads and Public Amenity Areas BS EN 1317: Road Restraint Systems, 1998 BS EN 13201: Road Lighting, 2003 BS EN 752-2: Drains and Sewage Systems Outside Buildings Part 2: Performance Requirements, 1997 Calculation of Road Traffic Noise, 1998 Not Used Circular 1/2000: Strategic Planning in London. GOL, June 2000 Not Used Minerals Planning Guidance 11: Control of Noise at Surface Mineral Workings, 1993 Design Manual for Roads and Bridges A Guide to Transport and Works Act Procedures Transport Analysis Guidance. Department for Transport, April 2004 Docklands Light Railway Design Manual, section 4.4.8 Revision H, April 1993 Docklands Light Railway Engineering Standard Specification ESS/99710 Rolling Stock: Infrastructure Interface Parameters East Thames River Crossing Appraisal Framework, DETR Flood and Coastal Project Appraisal Guidance: Economic Appraisal. Ministry of Agriculture Fisheries and Food (2000) Guidance for Developers and Consultants, Air Quality Assessments for Planning Applications, March 2001 Guidance on Preparing an Economic Impact Report. Department of Transport, July 2003 Guidelines for Landscape and Visual Assessment. The Landscape Institute, 2002 Guidelines for Providing Journeys on Foot. Institution of Highways and Transportation, 1999 Interim Advice Note 44/02 (Revision 1) Interim Requirements for Road Restraint Systems (Vehicle and Pedestrian). Highways Agency
D534 D535 D536 D537 D538 D539 D540
D541
D542 D543 D544
D545 D546 D547 D548 D549 D550 D551 D552 D553 D554 D555 D556 D557 D558
Interim Requirements for Road Restraint Systems (Vehicle and Pedestrian). Highways Agency, July 2002 Local Air Quality Management: Policy Guidance (LAQM.PG(03)). DEFRA, 2003 Local Transport Note 1/89 Making Way for Cyclists. Department of Transport, June 1989 London Cycle Network Design Manual, March 1998 Making the Connections: Final Report on Transport and Social Exclusion. Social Exclusion Unit, Feb 2003 Mitigation Measures in Environmental Statements, DETR, 1998 Piling and Penetrative Ground Improvement Methods on Land Affected by Contamination: Guidance on Pollution Prevention. Environment Agency, May 2001 Preparation of Environmental Statements for Planning Projects that Require Environmental Assessment: A Good Practice Guide. Department of the Environment Planning Research Programme, 1995 Railway Safety Principles and Guidance Part 2, Section G: Guidance on Tramways Local Air Quality Management: Technical Guidance (LAQM.TG903)). DEFRA, February 2003 Revised Guidelines for Reducing Mobility Handicaps: Towards a Barrier Free Environment. The Institution of Highways and Transportation, 1991 Standards and Guidance for Archaeological Desk-based Assessment. Institute of Field Archaeologists, 1994 Standing Advisory Committee for Trunk Road Assessment: Transport and the Economy Tidal Thames Landscape Assessment and Design Guidelines. Environment Agency Streetscape Guidance, Consultation Draft. TfL, July 2004 Not Used Transport in the Urban Environment. The Institution of Highways and Transportation, 1997 BS 5400 (Steel, Concrete and Composite Bridges) Part 1: General Statement, 1988 BS 5400 Part 2: Specification for Loads, 1978 BS 5400 Part 3: Code of Practice for Design for Steel Bridges, 2000 BS 5400 Part 4: Code of Practice for Design of Concrete Bridges, 1990 BS 5400 Part 5: Code of Practice for Design of Composite Bridges, 1979 BS 5400 Part 10: Code of Practice for Fatigue, 1980 BS 5400 Section 9.1 Part 9: Bridge Bearings. Section 9.1 Code of Practice for Design of Bridge Bearings, 1983 BS 5400: Section 9.2 Part 9: Bridge Bearings. Section 9.2 Specification for Materials, Manufacture and Installation of Bridge Bearings, 1983
D559
BS 1317 Part 3: Performance Classes, Impact Test Acceptance Criteria and Test Methods for Crash Conditions, 2000 D560 DD ENV 1317 2002 Part 4: Performance Classes, Impact Test Acceptance Criteria and Test Methods for Terminals and Transitions of Safety Barriers D561 BS 6031: Code of Practice for Earthworks, 1981 D562 BS 8002: Code of Practice for Earth Retaining Structures, 1994 D563 BS 8004: British Standard Code of Practice for Foundations, 1986 D564 BS 8118: Structural Use of Aluminium-Part 1: Code of Practice for Design, 1991 D565 BS 8118: Structural Use of Aluminium-Part 2: Specification for Materials, Workmanship and Protection, 1991 D566 The Assessment of Pedestrian Crossings: Local Transport Note 1/95. Department of Transport, April 1995 D567 The Design of Pedestrian Crossings: Local Transport Note 2/95. Department of Transport, April 1995 D568 Ratified European Text: CEM-TR13201-1-2004: Road Lighting-Part 1: Selection of Lighting, 2004 D569 Manual of Contract Documents for Highway Works: Volume 3 Highway Construction Details. Highways Agency D570 Manual of Contract Documents for Highway Works: Volume 3a Highway Construction Details. Highways Agency D571 BS 7385-Part 2: Evaluation and Measurement for Vibration in Buildings, 1990 D572 Transport Economics Note, DETR D573 Stage 1 Road Safety Audit, TfL, 2004 D574 Designers Response to Stage 1 Road Safety Audit Reports, TfL, 2004 D575 Guidelines for Community Noise, WHO, 2000 D576 Circular 1/97: Planning Obligations, 1997 D577 Supplementary Green Book Guidance-Optimism Bias. HM Treasury D578 Approved Submission for Departure from Standards D579 TfL Maintenance Manual Documents D580 D600 not used Regional and Local Planning D601 Developing Londons Economy: Draft Strategy: Sustaining Success. London Development Agency, GLA, February 2004 D602 Barking & Dagenham Unitary Development Plan. London Borough of Barking & Dagenham, 1996 D603 Beckton Gateway: Urban Framework Plan. London Borough of Newham D604 Bexley Local Biodiversity Action Plan, London Borough of Bexley, 2002 D605 Bexley Unitary Development Plan. London Borough of Bexley, 1996 D606 Not Used D607 Not Used
D608 D609 D610 D611 D612 D613 D614
D615 D616 D617 D618
D619
D620 D621 D622 D623 D624 D625 D626 D627 D628 D629 D630 D631 D632 D633
City of London Biodiversity Action Plan, Corporation of London, July 2003 Communities Plan-Sustainable Communities: Building for the Future, ODPM, 2003 Draft London Plan: Draft Spatial Development Strategy for Greater London. GLA, June 2002 Londons Economic Development Strategy: Success Through Diversity, London Development Agency, GLA, July 2001 Economic Development Strategy for Greenwich. London Borough of Greenwich, April 2002 Draft London Plan-Examination in Public, Panel Report. GLA, July 2003 Greenwich Interim Local Implementation Plan: an Integrated Transport Strategy for the Borough. London Borough of Greenwich, 2001 Greenwich Unitary Development Plan, 1st Deposit Draft. London Borough of Greenwich, 2002 Greenwich Unitary Development Plan. London Borough of Greenwich, November 1994 Greenwich Unitary Development Plan, 2nd Deposit Draft 2004. London Borough of Greenwich, April 2004 Landscape Character Assessment: Guidance for England and Scotland. The Countryside Agency and Scottish Natural Heritage, 2002 London Health Strategy, Outline Strategic Framework: Londons Health - Developing a Vision Together. London Commission, March 2000 The London Plan: Spatial Development Strategy for Greater London. GLA, February 2004 Londons Road Safety Plan. TfL November 2001 Not Used Not Used Management Guidance for the Thames Estuary: Todays Estuary for Tomorrow, October 1999 The Mayors Air Quality Strategy: Cleaning Londons Air. GLA, September 2002 The Mayors Ambient Noise Strategy: Sounder City. GLA, March 2004 The Mayors Biodiversity Strategy: Connecting with Londons Nature, July 2002 Transport for Londons 5-Year Investment Programme 2005/6 2009/10, October 2004 Not Used The Mayors Transport Strategy. GLA, 2001 Newham Council Vision: Newham 2010, London Borough of Newham Not Used Newhams Regeneration Strategy. London Borough of Newham
D634 D635 D636 D637 D638 D639 D640 D641 D642 D643 D644 D645 D646 D647 D648 D649 D650 D651 D652 D653 D654 D655 D656 D657 D658 D659 D660 D661 D662 D663 D664 D665 D666 D667
D668
Newham Unitary Development Plan, London Borough of Newham, 2001 Newhams Archaeological Code of Practice (Supplementary Planning Guidance). London Borough of Newham, 2001 Planning Policy Guidance (PPG) 10: Planning and Waste Management, 1999 PPG 13: Transport, 2001 PPG 23: Planning and Pollution Control, 1997 PPG 25: Flood Risk Assessment, 2001 PPG 3: Housing, 2000 PPG 11: Regional Planning Strategies, 2000 PPG 15: Planning and the Historic Environment, 1994 PPG 16: Archaeology and Planning, 1990 PPG 20: Coastal Planning, 1992 PPG 9: Nature Conservation, 1994 Regional Planning Guidance (RPG) 3: London, 1989 RPG 9: The South East, 1994 RPG 9A: Thames Gateway Planning Framework Royal Albert Basin Development Framework. London Borough of Newham, September 2004 Strategic Planning Guidance for the River Thames (RPG 3B/9B), 1997 Sustainable Communities Making it Happen: Thames Gateway and Growth Areas. ODPM, July 2003 Not Used Thames Gateway Review. ODPM, 2001 The London Low Emission Zone Feasibility Study, 2003 Tidal Thames Encroachment Policy Tower Hamlets Unitary Development Plan. London Borough of Tower Hamlets, 1998 Tripcock Point, Thamesmead Development Framework. London Borough of Greenwich, September 2003 PPG 1: General Policy and Principles, 1997 PPG 23: Planning and Pollution Control, 1994 PPG 24: Planning and Noise, 1994 Planning Policy Statement (PPS) 23: Planning and Pollution Control, 2004 PPS 1: Delivering Sustainable Development, 2005 PPS 11: Regional Spatial Strategies, 2004 By Design, Urban Design in the Planning System: Towards Better Practice, ODPM, 2000 Planning System General Principles, ODPM, 2005 Not Used Bexley Unitary Development Plan: Response to Inspectors Report of the Inquiry into Objections to the Review - Proposed Alterations, London Borough of Bexley, November 2003 The Mayors Economic Development Strategy: Sustaining Success. London Development Agency, GLA, 2005
D669
Greenwich Unitary Development Plan-Public Consultation on PreInquiry changes to the Second Deposit Draft. London Borough of Greenwich, 22 October 2004 D670 Sustainable Communities in London. ODPM, 2003 D671 Sustainable Communities: Homes for All. ODPM, January 2005 Documents D672 D700 not used Research Reports D701 A New Commitment to Neighbourhood Renewal: National Strategy Action Plan. Social Exclusion Unit, 2001 D702 Accidents and Casualties on Londons Roads. TfL, October 2003 D703 A Fish Population Survey of the Tidal Thames 1994-1996. Conclough et al., October 2000 D704 British Plant Communities Volume 3: Grassland and Montane Communities. J S Rodwell, 1992 D705 British Red Data Books: 2 Insects. Nature Conservancy Council, 1987 D706 Chart PLA325: Gallions Reach November 1999 D707 Climate Change Scenarios for the United Kingdom: The UKCIP02 Scientific Report. DEFRA, April 2002 D708 Contaminated Land Final Report of the NATO/CCMS Study Group: Evaluation of Demonstrated and Emerging Technologies for the Treatment and Clean Up of Contaminated Land and Groundwater, June 1998 D709 Thames Gateway Bridge Contaminated Land Desk Study P1-PR005, TfL, March 2003 D710 Countryside Character Volume 7: South East and London D711 Distribution of Copper, Nickel and Zinc in the Thames Estuary, Marine Pollution Bulletin Vol 38 No 4 pp328-331. C Stevenson and B Ng, 1999 D712 Not Used D713 Ecological Data Search of the Thames Gateway Bridge Safeguarded Area, Greater London. London Wildlife Trust, March 2003 D714 Emission Factors for 2010. National Atmospheric Emissions Inventory D715 Employment by Occupation and Industry. Office for National Statistic, 2004 D716 Not Used D717 Not Used D718 Not Used D719 Heavy Metal Concentrations in Sediment from the Thames Estuary, Marine Pollution Bulletin Vol. 30 no. 11 pp742-744. M Attrill and M Thomes, 1995 D720 Level of Accident Risk in Greater London (Issues 9). TfL, January 2003 D721 London Basin Natural Area Profile. English Nature, 2004 D722 London Bird Report 1998. London Natural History Society, 2001 D723 London Bird Report 1999. London Natural History Society, 2002
D724 D725 D726
D727 D728 D729 D730 D731 D732 D733 D734 D735 D736 D737 D738 D739 D740 D741 D742 D743 D744 D745 D746 D747 D748 D749 D750 D751
D752
The London Index of Deprivation: An Alternative to IMD 2000. GLA, July 2002 Not Used Measurements of the Underwater Noise in the Arun River during Piling at County Wharf, Littlehampton. J Nedwell and B Edwards, August 2002 Millennium Waterfront Transit System, Performance Specification Guideway Issue 3, 8. London Transport Planning, February 1999 Modelling Methodology used in the Development of the Mayors Air Quality Strategy Version 1. GLA, September 2002 New Earnings Survey 2003. National Statistics, October 2003 Nitrogen Dioxide in the United Kingdom, Draft Report of Air Quality Expert Group, 2003 Not Used Organotin Compounds in Mersey and Thames Estuaries a Decade after UK TBT legislation, J Mar Biology Ass. H Harino et al. Our Common Future. World Commission on Environment and Development, 1987 Pedestrian Casualties in Greater London. TfL, June 2003 Regenerating Greenwich Brochure. London Borough of Greenwich Not Used Rising Groundwater Levels in the Chalk-Basal Sands Aquifer of the Central London Basin, May 2002 Stocks of VAT Registered Companies by Sector Not Used Not Used Thames Benthic Programme 1998 Thames Gateway Bridge River Bed Sampling Factual Report (2004) Not Used Indices of Deprivation 2000. Department of Environment, Transport and the Regions The Health of Londoners: A Public Health Report for the Health of Londoners Project. The Health of Londoners Project 1998 The Population Status of Birds in the UK Birds of Conservation Concern 2002-2007 Towards an Urban Renaissance: Report of the Urban Task Force Not Used Transport Investment and Economic Development. David Bannister and Joseph Berechman, 2000 Understanding Londons Sub Regional Economies. London Development Agency, GLA, February 2003 Mayors Transport Strategy: Report on Public Consultation on the Draft Transport Strategy-Summary Report and Appendices. Mori and the Greater London Authority, 2001 The Case for London: Londons Loss is No-ones Gain The Mayor of Londons Submission to Spending Review 2004. GLA, 2004
Documents D753 D800 not used Scheme Specific Documents D801 East London River Crossing: Inspectors Report on the Public Local Inquiries held at Woolwich between 10 September 1985 and 23 December 1986 D802 East London River Crossing: Public Inquiry July 1990-January 1991. Inspectors Report. 4 July 1991 D803 River Crossings East of Tower Bridge, 1995 D804 Consultation Summary-The Thames Gateway Bridge - A New Bridge for East London. TfL D805 Review of Alternative Alignments considered as part of the Development of the Thames Gateway Bridge. TfL, May 2003 D806 East London River Crossing draft scheme Orders, 1984 D807 East Thames River Crossings Summary of Economic Regeneration Impact: Final Report, July 1999 D808 Thames Gateway Bridge: Environmental Statement. TfL, July 2004 D809 Thames Gateway Bridge: Environmental Statement Figures. TfL, July 2004 D810 Thames Gateway Bridge: Environmental Statement Volume 2 of the Appendices Design Statement. TfL, July 2004 D811 Thames Gateway Bridge: Environmental Statement Volume 3 of the Appendices Landscape and Urban Design Strategy. TfL, 2004 D812 Thames Gateway Bridge: Environmental Statement, Volume 1 General Appendices. TfL, July 2004 D813 Draft Form 214: Road Highway Classification D814 Not Used D815 Thames Gateway Bridge: Navigation Safety Risk Assessment (P1-PR043). TfL, November 2004 D816 Thames Gateway Bridge: Assessment of Local Potential Hydrodynamic Impacts (P1-P-R061). TfL July 2004 D817 Thames Gateway Bridge: Hydraulic Desk Study (P1-P-R023). TfL, August 2004 D818 Thames Gateway Bridge: Preferred Options Hydraulic Modelling and Sediment Assessment (P1-P-R064). TfL, November 2004 D819 Thames Gateway Bridge: Note of Health Effects reported in the Environmental Statement. TfL, September 2004 D820 Thames Gateway Bridge; Plans submitted with the Planning Application. TfL D821 Thames Gateway Bridge: Public Transport Model Validation Report. TfL, February 2004 D822 Thames Gateway Bridge: Regeneration Statement. TfL, July 2004 D823 Thames Gateway Bridge: Sustainability Report. TfL, September 2004 D824 TfL Board Paper, 19 November 2002 D825 TfL Board Paper, 24 March 2004
10
D826 D827 D828 D829 D830 D831 D832 D833
D834 D835 D836 D837 D838 D839 D840
D841
D842 D843 D844 D845
D846 D847
Thames Crossings The Regeneration Case, Social and Economic Impacts, Final Report (November 2002) Thames Gateway Bridge: Consultation Report. TfL, November 2003 Thames Gateway Bridge: Consultation Response Analysis Report. TfL, November 2003 Thames Gateway Bridge: Local TGX Highway Model Local Model Validation Report. TfL, January 2004 Thames River Crossings: Economic and Regeneration Impacts. TfL, July 2002 Documents for A2012 GLA Road (London Boroughs of Greenwich and Newham) (Public Transport Bridge) Order 2005 Documents for A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 Documents for A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 Open Space Land to the East of the River Thames, Thamesmead, London Documents for A2012 GLA Road (Thames Gateway Bridge) Special Roads and Bridge Scheme 2004 Documents for A2012 GLA Road (Thames Gateway Bridge) Toll Order 2004 Documents for A2012 GLA Road (Thames Gateway Bridge) (Side Roads) Order 2004 Documents for Highway (Designation of GLA Roads) (Thames Gateway Bridge) Order 2004 Thames Gateway Bridge: Traffic and Transport Report. TfL, July 2004 Consultation information to residents of Grasshaven Way and Barnham Drive on proposed Side Roads Order amendments, 2004 Letter to London Borough of Newham on minor amendments to planning application and plans TBTGRC/P2/HIG/033 Revision 1 and TBTGRC/P2/STR/103 Revision 1, 22 November 2004 Letter to London Borough of Greenwich on minor amendments to planning application and plan TBTGRC/P2/HIG/035 Revision 1, 29 October 2005 Plans TBTGRC/PHIG95 Revision 1, TBTGRC/P2/HIG/96 Revision 1 and TBTGRC/P2/STR/109 Letter from Government Office for London on Exchange Land Certificate, 9 December 2004 Report of the Officers of the London Borough of Greenwich on the Thames Gateway Bridge scheme application, 14 December 2004 Report of the Officers of the London Borough of Newham on the Thames Gateway Bridge scheme application, 15 December 2004 Minutes of the London Borough of Greenwich on the Thames Gateway Bridge scheme application, 14 December 2004 Minutes of the London Borough of Newham on the Thames Gateway Bridge scheme application, 15 December 2004
11
D848 D849 D850 D851 D852 D853 D854 D855 D856 D857
D858
D859
D860
D861
Letter from London Borough of Greenwich on the GLA Designation Order, 11 January 2005 Letter and submission documents to London Borough of Newham on planning application for radar facility, 12 January 2005 Letter from Government Office for London to London Borough of Greenwich on call-in decision, 19 January 2005 Letter from Government Office for London to London Borough of Greenwich on call-in decision, 3 February 2005 Letter and submission documents to London Borough of Greenwich on planning application for radar facility, 14 February 2005 Thames Gateway Bridge: Environmental Statement Addendum Volume 1: Main Report. TfL, March 2005 Thames Gateway Bridge: Environmental Statement Addendum Volume 2: Drawings. TfL, March 2005 Thames Gateway Bridge: Amended and Updated Design Statement. TfL Light Transit in London. TfL, April 2004 Letter to London Borough of Newham on proposed amendments to planning application Ref P/041/1170 for a temporary construction worksite, with planning application form and plans TBTGRC/P2/CMP/001, TBTGRC/P2/CMP/002, TBTGRC/P2/CMP/003, 11 March 2005 Letter from Government Office for London to London Borough of Newham on call-in decision on the proposed amendments to planning application Ref 0/04/1170 for a temporary construction worksite, 24 March 2005 Documents regarding proposed amendments to the A2012 GLA Road (Thames Gateway Bridge) Special Roads and Bridge Scheme, the related Side Roads Order, the main bridge planning applications and the Design Statement Notice of approval of planning permission for the VTS Radar Antenna at Jenkins Lane, Barking Barrier West Tower from the London Borough of Newham, 10 March 2005 Thames Gateway Safeguarding Zone
Additional Core Documents deposited by parties other than the promoters ADD/001 ADD/002 ADD/003 ADD/004 Two Wheels Work Countryside Agency, May 2002 The Governments Motorcycling Strategy, Feb 2002 A Solution Looking for a Problem by John Elliott Thames Gateway River Crossing: A social economic and environmental assessment by Eco-Logica for the Simon Wolff Foundation, Jan 2002 Not used as requested document already submitted London Stansted Cambridge Corridor Initial Assessment of Growth Potential in London prepared for the GLA by Roger Tym and Partners, Oct 2004 The SACTRA Report of 1994
ADD/005 ADD/006
ADD/007
12
ADD/008 ADD/009 ADD/010 ADD/011 ADD/012 ADD/013 ADD/014
ADD/015
Not Used Not Used Not Used Sites of Importance for Nature Conservation in Bexley, Dec 2004 Thames Strategy East Public Consultation Draft Sites of Importance for Nature Conservation in Greenwich UDP Consultation Draft, Feb 2004 July 2003 Report for ODPM Relationship between Transport and Development in the Thames Gateway by Llewelyn Davies and Steer Davies Gleave, with Roger Tym & Partners and Atkins, July 2003 The SACTRA Report 1999
Pre Inquiry Documents PID/1 PID/2 PID/3 PID/4 Note of the Pre Inquiries Meeting held on 4 April 2005 Note of the Procedural Meeting held on 28 April 2005 Report of the Inspector to the Secretaries of State on the issue of postponement of the inquiry, 9 May 2005 Decision of the Secretaries of State on the issue of postponement of the inquiry, 17 May 2005
Inquiry Documents INQ/1 INQ/2 INQ/3 INQ/4 INQ/5 INQ/6 INQ/7 Attendance Sheets for each day of the inquiry Daily Transcript List of anticipated appearances as at Tuesday 7th June 2005 Letter dated 18 May 2005 from TfL to Programme Officer regarding availability of Deposit Documents Notes for Guidance of Inspectors Holding Inquiries into Orders and Special Road Schemes Data base of responses received to the proposals before the inquiry up to and including Tuesday 7th June (1- 3258) Extracts from DTLR Circular 04/2001, Development Affecting Trunk Roads and IHT and Essex CC Guidelines on Traffic Impact Assessment Material undertaken to be provided by parties to the inquiry Days 1-80 Annotated Extracts from Document TfL/119 ODPM Circular 05/2005 Planning Obligations DfT Letter dated 25 Aug 2005 to TfL Circular 11/95 (DOE) The Use of Conditions in Planning Permissions Inspectors Preliminary Note for Proposed Roundtable Session on Conditions Inspectors Note regarding Reporting Requirements in connection with the Promoters Proposed Planning Obligation Inspectors Questions 20 Oct 2005
INQ/8 INQ/9 INQ/10 INQ/11 INQ/12 INQ/13 INQ/14 INQ/15
13
INQ/16 INQ/17
INQ/18 INQ/19 INQ/20 INQ/21 INQ/22 INQ/23 INQ/24 INQ/25 INQ/26 INQ/27 INQ/28 INQ/29 INQ/30
Proposed Accompanied Site Visits by the Inspectors December 2005 Comparing the locations where accessibility would increase as a result of TGB with the locations of commercial development sites. Inspectors questions: 24 November 2005 Inspectors Questions 20 Dec 2005 Inspectors queries regarding TfL Traffic Survey Evidence on A406 Further questions to TfL regarding Traffic Flows in the A406 Corridor LB Greenwich Calculation Check Potential Planning Condition: Traffic Note on Closing Submissions Inspectors Questions 28 March 2006 Points to be covered from written representations Checklist of Inspectors Questions Inspectors Queries on consideration of Document TfL/282 Proposed Accompanied Site Visits by the Inspectors April 2006 Objections withdrawn during the inquiry
Documents submitted by TfL TfL/P/01/1 TfL/P/01/2 TfL/P/01/3 TfL/P/01/4 TfL/P/01/5 TfL/P/01/6 TfL/P/02/1 TfL/P/02/2 TfL/P/02/3 TfL/P/02/4 TfL/P/02/5 TfL/P/02/6 TfL/P/03/1 TfL/P/03/2 TfL/P/03/3 TfL/P/04/1 Summary proof of evidence of Henry Abraham MA MSc on Transport Policy Main text of Mr Abrahams proof Appendices to Mr Abrahams proof Replacement versions of Appendices 1 and 7 to Mr Abrahams proof Note making a correction to Mr Abrahams evidence Supplementary proof of evidence of Mr Abraham - 16 Dec 2005 Summary proof of evidence of George Kennedy MSc CEng MICE on Highway Engineering Main text of Mr Kennedys proof Figures relating to Mr Kennedys proof Amended figures showing a visible mapping base Supplementary proof of Mr Kennedy regarding Barnham Drive Public Transport Loop Design Change Nov 2005 Supplementary proof of evidence of Mr Kennedy regarding traffic mitigation measures 16 Dec 2005 Summary proof of evidence of Stephen Ellison CEng MICE MIHT on Bridge Engineering and Cost Estimates Main text of Mr Ellisons proof Figures relating to Mr Ellisons proof Summary proof of evidence of Richard Smith BA MSc on Traffic, Tolling, Public Transport and Appraisal
14
TfL/P/04/2 TfL/P/04/3 TfL/P/04/4 TfL/P/04/5 TfL/P/04/6 TfL/P/04/6/1 TfL/P/04/7 TfL/P/04/8 TfL/P/05/1
TfL/P/05/2 TfL/P/05/3 TfL/P/05/4 TfL/P/06/1 TfL/P/06/2 TfL/P/06/3 TfL/P/06/4 TfL/P/07/1 TfL/P/07/2 TfL/P/07/3 TfL/P/08/1 TfL/P/08/2 TfL/P/08/3 TfL/P/09/1 TfL/P/09/2 TfL/P/09/3 TfL/P/09/4 TfL/P/09/5 TfL/P/10/1 TfL/P/10/2 TfL/P/10/3 TfL/P/10/4 TfL/P/10/5 TfL/P/10/5B TfL/P/11/1 TfL/P/11/2 TfL/P/11/3
Main text of Mr Smiths proof Figures relating to Mr Smiths proof Appendices to Mr Smiths proof Tables relating to Mr Smiths proof Forecast highway impacts of Thames Gateway Bridge Revised Table 36 - Appraisal Summary Table for the Thames Gateway Bridge Figure D17 - Location of High Traffic Changes & Potential Junction Congestion (as set out in Tables 19 & 20) Supplementary proof of evidence of Mr Smith 16 Dec 2005 Summary proof of evidence of Professor Bridget Rosewell MA MPhil on Regeneration Implications of Thames Gateway Bridge Main text of Professor Rosewells proof Appendices to Professor Rosewells proof Supplementary proof of evidence of Professor Rosewell on regeneration implications 16 Dec 2005 Summary proof of evidence of Dr Stephen Allen BA PhD on funding Main text of Dr Allens proof Appendices to Dr Allens proof Supplementary proof of evidence Of Dr Allen on funding 16 Dec 2005 Summary proof of evidence of Professor Richard Burdett BA MSc Dip Arch FRIBA on Design Main text of Professor Burdetts proof Figures relating to Professor Burdetts proof Summary proof of evidence of Mr Ralph Cobham BA MSc on Landscape and Visual Issues Main text of Mr Cobhams proof Appendices to Mr Cobhams proof Summary proof of evidence of Mr Michael Clarke CEng MICE MIMM on Project Strategy and Programme Main text of Mr Clarkes proof Appendices to Mr Clarkes proof Table 2: Outline of the ongoing programme key dates Supplementary proof of evidence of Mr Clarke Summary proof of evidence of Mr Michael Adams BA Dip TP MRTPI MIHBC on Town Planning Main text of Mr Adams proof Figures relating to Mr Adams proof Appendices to Mr Adams proof Addendum to Mr Adams proof Appendix 12 to Mr Adams proof Summary proof of evidence of Professor Duncan Laxen PhD MSc BSc on Air Quality Main text of Professor Laxens proof Appendices to Professor Laxens proof
15
TfL/P/11/4 TfL/P/11/5 TfL/P/11/6 TfL/P/12/1 TfL/P/12/2 TfL/P/12/3 TfL/P/12/4 TfL/P/13/1 TfL/P/13/2 TfL/P/13/3 TfL/P/14/1 TfL/P/14/2 TfL/P/14/3 TfL/P/14/4 TfL/P/15/1 TfL/P/15/2 TfL/15 TfL/16 TfL/17 TfL/18 TfL/19 TfL/20
TfL/21 TfL/22 TfL/22A TfL/22B TfL/22C TfL/22D TfL/23
TfL/24 TfL/24A TfL/24B TfL/24C TfL/24D
Figures relating to Professor Laxens proof Note form Professor Laxen on Low Emission Zones Supplementary proof of evidence of Professor Laxen 16 Dec 2005 Summary proof of evidence of Dr Michael Fillery BSc MSc PhD FIOA on Noise and Vibration Impact Main text of Dr Fillerys proof Appendices to Dr Fillerys proof Supplementary proof of evidence of Dr Fillery 16 Dec 2005 Summary proof of evidence of Dr Jo Hughes on Ecology Main text of Dr Hughes proof Figures relating to Dr Hughes proof Summary proof of evidence of Mr Adrian Maher BSc MRICS on Compensation and Compulsory Purchase Issues Main text of Mr Mahers proof Figures relating to Mr Mahers proof Figure N1 - Agreements with Freehold Owners Proof of evidence of Mr Chris Swiderski BA on Deposit of Documents Appendices to Mr Swiderskis proof Statement of Case Statement of Case for Revised Worksite Compound Statement of Common Ground between TfL, LB Newham and LB Greenwich Supplementary Planning Application regarding radar facility at Woolwich Arsenal London Borough of Bexley UDP 2004 Growth and Regeneration in the Thames Gateway Interregional Planning Statement by the Thames Gateway Regional Planning Bodies The London Plan Draft Sub Regional Development Framework East London May 2005 Draft Five Boroughs Legal Agreement 7 June 2005 Draft Five Boroughs Legal Agreement 21 Oct 2005 Draft Five Boroughs Legal Agreement 14 Feb 2006 together with tracked copy of the same draft Executed Four Boroughs Legal Agreement 19 April 2006 Executed Deed of Undertaking by TfL to LB Bexley 19 April 2006 Thames Gateway Bridge Upper Bound OS Co-ordinates of Permanent Works for LCA/CAA Assessment Drawing TBTGRC/P2/TGB/323 Proposed Planning Conditions 7 June 2005 Proposed Planning Conditions (Revised 23 Sept 2005) TfL Response to Inspectors Preliminary Notes for Proposed Roundtable Session on Conditions (INQ/13 16.09.95) CAP 680 Aerodrome Bird Control Proposed Planning Conditions (Revised 29 Sept 2005)
16
TfL/24E TfL/24F TfL/24G TfL/24H TfL/24I TfL/24J TfL/24K TfL/24L TfL/24M TfL/24N TfL/24O TfL/24P TfL/24Q TfL/24R TfL/24S TfL/24T TfL/24U TfL/24V TfL/24W
TfL/24X TfL/24Y TfL/24Z TfL/24Z/1 TfL/25 TfL/26 TfL/27
TfL/27/1 TfL/28 TfL/29 TfL/30 TfL/31 TfL/32 TfL/33
Inquiry Note - Drawings referred to in Proposed Planning Conditions Revised Conditions A7 & D2 Proposed Planning Conditions Explanatory Note Environment Agency Letter re Planning Conditions 18 Jan 2006 Email dated 5 Jan 2006 from LTGDC re Planning Conditions Email dated 13 Dec 05 from LBG re Conditions Letter dated 24 Jan 06 from LBN re Conditions Letter dated 13 Dec 05 from PLA re Conditions Revised Planning Conditions 30 Nov 05 (Tracked) Proposed Planning Conditions North of the River Proposed Planning Conditions South of the River LTGDC Statutory Instrument 2005 No 2721 Extract of Map referred in TfL/24P Paper regarding proposed planning conditions for the temporary worksite Proposed Planning Conditions Temporary Construction Worksite (25 April 2006) Proposed Planning Conditions North of the River (25 April 2006) Proposed Planning Conditions South of the River (25 April 2006) Email dated 25 April 2006 from LB Greenwich regarding revised Planning Application Drawings Design Statement - Vol 2 of the Appendices to the Environmental Statement July 2004, updated Mar 2005, Sep 2005 and Apr 2006 Planning Conditions Drawings A3 reduced set Proposed Planning Conditions Explanatory Note 2 Table of Drawing Revisions - WITHDRAWN Updated Table of Drawing Revisions Environmental Statement Non-Technical Summary Environmental Statement Non-Technical Summary: Addendum (March 2005) A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 status of Agreements with statutory Objectors 7 June 2005 Updated copy of TFL/27 23 June 2005 British Telecommunications PLC and Bloomsbury Land Investments v Gloucester City Council [2002] 2 P&CR 512 Bexley LBC v SSETR and others [2001] EWHC Admin 323 R v Secretary of State for Transport ex p de Rothschild [1989] 1 All ER 933 Procedure Notes regarding the Orders and applications before the inquiry Thames Gateway Bridge Scheme Plans Transport for London Opening Statement
17
TfL/34 TfL/34A TfL/35 TfL/36 TfL/37 TfL/38 TfL/39 TfL/40 TfL/41 TfL/42 TfL/43 TfL/44 TfL/45 TfL/46 TfL/47 TfL 48 TfL/49 TfL/50 TfL/51 TfL/52 TfL/53 TfL/54 TfL/55 TfL/56 TfL/57 TfL/58 TfL/59 TfL/60 TfL/61 TfL/62 TfL/62/1 TfL/63 TfL/64 TfL/65 TfL/66 TfL/67
Street Map of East London Map of East London Additional Areas Extract of Street Map for East London (North) Extract of Street Map for East London (South) Mayors Answer to query regarding preparatory works on the proposed Silvertown Crossing (GLA Website 08/06/2005) Creating Sustainable Communities: Greening the Gateway Implementation Plan (ODPM and DEFRA, 2005) Changes to A2012 GLA Road CPO Sheet 6 SK-CH-90 The A2012 GLA Road (Thames Gateway Bridge) Compulsory Purchase Order 2004 Sheet 6 of 7 The A2012 GLA Road (Thames Gateway Bridge) (Side Roads) Order 2004 Site Plan 7 Barnham Drive/Grasshaven Way Junction Configuration Extract from TfL Investment Programme 2005/06 2009/10 Extract from ODPM Circular No. 06/2004: Compulsory Purchase and The Crichel Down Rules Details of the proposed TGB Design Panel Design Quality Strategy (Draft) May 2005 Design Manual for Roads and Bridges TA 90/05 Invalid Carriages Inquiry Note Traffic & Revenue Growth Predictions 15 June 2005 Traffic Mitigation Funding 15 June 2005 Cross Sections at CH 4000 & 4050 Modal Share Trends 18 May 2005 Examples of successful DBFO & D&B Projects Public Inquiry & Procurement Programme Letter dated 3 Nov 2004 from Martin Stuckey of TfL to LB Bexley Mitigation Measures Public Inquiry Note Concrete Barriers Lift & Stairway on the North Bank of the River Roads in Bexley that Undergo Significant Changes in Noise Levels Advice on Modelling of Congestion Charging or Tolling Options for Multimodal Studies Technical Case Report January 2004 Regeneration Statement January 2004 Accompanied Site Visits 29 June 2005 Accompanied Site Visits 29 June 2005 Revision Greenwich Waterfront Transport Consultation Report July 2005 Technical Note Halcrow - Tram Design Standards 16 June 2005 Greenwich Waterfront Transit - Public consultation on safeguarding a route May 2004 Note to the Inquiry Article 4(3) of the A2012 GLA Road (Thames Gateway Bridge) Toll Order 2004 Richard Smith Proof of Evidence: Table 21 Amendments
18
TfL/68 TfL/68/1 TfL/69 TfL/70 TfL/71 TfL/72 TfL/73 TfL/74 TfL/75 TfL/76 TfL/77 TfL/78 TfL/79 TfL/80 TfL/81 TfL/82
TfL/83 TfL/84 TfL/85 TfL/86 TfL/87 TfL/88 TfL/89 TfL/90 TfL/91 TfL/92 TfL/93 TfL/94 TfL/95 TfL/96 TfL/97 TfL/98 TfL/99 TfL/100 TfL/101 TfL/102
Integration Requirements June 2003 Halcrow - Extract Integration Requirements June 2003 Halcrow - Full Report DoE Circular No. 11/95: The Use of Conditions in Planning Permissions TGB Public Transport Statement November 2004 Carillion plc Annual Report & Accounts 2003 Mitigation Measures in Harrow Manor Way Borough Spending Plan Submission Guidance TfL Mar 2004 Exchange of Emails between Andrew Merritt and Martin Oaten re availability of information 19 August 2004 High Sided Vehicles Inquiry Note 5 July 2005 Further Information re model results - Bridget Rosewell Public Inquiry Note Thamesmead Junction Procedure for detailed planning approvals Letter from Environmental Agency dated 29 June 2005 consents required in addition to planning permission Map Public Transport Lane Adjacent to Barnham Drive Policy 3C.15 Balancing 6 July 2005 Note responding to Assistant Inquiry Inspectors query re relationship between regional location of growth and longer distance commuting Inquiry Note - Approach to Assessment of Highway Impacts Qualifications and experience of Barry Broe Inquiry Note - TGX Local Model Validation Report Revised Tables 5 July 2005 Examples of Construction Projects carried out by Special Purpose Vehicles Note to Inquiry - Article 4 of the Traffic Signs Regulations & General Directions 2002 Public Inquiry Note Footway/Cycleway on Main Bridge Inquiry Note - M6 Toll Traffic Impacts 7 July 2005 Inquiry Note - Revisions to Local TGX Highway Model LMVR Journey Time Figures 5 July 2005 Noise Levels on Bexley Roads Note on Traffic Noise in Bexley Table 36 TfL/Proof/04/05 Winsor Terrace Junction Inquiry Note - Crossrail Modelling Assumptions Silvertown Link Web Extract Regeneration Framework for Bexley 2005 -2016 Consultation Draft Mar 2005 Bexley Community Strategy 2003 - 2013 Inquiry Note - Reconciliation of Mr Smiths Table 5 with Transport Economics Note 6 July 2005 Inquiry Note - Traffic Impacts, Mitigation Proposals Map Bexley Area Inquiry Note - PM Peak Modelling 7 July 2005 Inquiry Note - Modelling & Appraisal Discussions with ITEA - 7 July 2005
19
TfL/103 TfL/104 TfL/105 TfL/106 TfL/107 TfL/108 TfL/109 TfL/110 TfL/111 TfL/112 TfL/113 TfL/114 TfL/115 TfL/116 TfL/116a TfL/117 TfL/118 TfL/119/A TfL/119/B TfL/119/C TfL/119/D TfL/119/E TfL/120 TfL/121 TfL/122 TfL/123 TfL/124 TfL/125 TfL/125/1 TfL/126 TfL/127 TfL/128 TfL/129 TfL/130 TfL/131 TfL/132 TfL/133
Inquiry Note - Harrow Manor Way - 7 July 2005 Bexley Local Implementation Plan 2005/6 2010/11 Inquiry Note - Erith Roundabout - 7 July 2005 Commissioning a Sustainable & Well-designed City - a Guide to Competitive Selection of Architects and Urban Designers Closures of Blackwall Tunnel & Dartford Crossing Inquiry Note - 12 July 2005 Public Transport Figures Regeneration Evidence - Source of Data Note for Inquiry Ref 10/13 INQ/8 Professor Laxen Note for Inquiry Re 10/12 INQ/8 Professor Laxen Letter dated 18 Jul 2005 from Mayors Office to the Leader of LB Bexley Document Crook Log/Brampton Road Bexleyheath Proposed Pelican Crossing Brampton Road Bexleyheath Local Safety Scheme Strategic Environmental Assessment of Bexleys Local Implementation Plan Feb 2005 Map TGX Modelled Roads for Bexley & Greenwich Local Model Validation Report 6 August 2003 Local Model Validation Report 1 August 2003 Inquiry Note - Current Congestion Levels 19 July 2005 Transyt 12 User Guide Application Guide 48 (Issue B) Map A13 Junction SK-CH-104 Map Thamesmead Junction SK-CH-106 Map A13 Junction Layout TBTGRC/P1/HIG/300 CD of TFL/119/A-D Proposed London Low Emission Zone Overview Inquiry Note - Reductions in Congestion or Severance Inquiry Note - PM Peak Traffic Determination of Urban Road Capacity Inquiry Note - 18 July 2005 - Traffic Mitigation Proposals Assessment of Impacts and Constraints Inquiry Note - 19 July 2005 - Pattern of Use of the TGB Revisions to Fig 3 of TfL/125 Strategic Transport Modelling & Strategic Multi-Modal Studies - Review Report Inquiry Note Minimum Tolls LTS Status Report July 2005 Crossrail Transport Assessment: Methodology and Principal Findings Feb 2005 Closures of Blackwall Tunnel & Dartford Crossing (Bridge and Tunnels) INQ/8 9/8 Inquiry Note - Local Model Validation Report 26 July 2004 INQ/8 22/13 LTS 2001 Forecast Further Analysis Extract from Appendix W1 of TFL/REB/1774/2 Inquiry Note - A13/A406 Junction Transyt Modelling INQ/8 22/8
20
TfL/134 TfL/135 TfL/136 TfL/136a TfL/136b TfL/137 TfL/138 TfL/139 TfL/140 TfL/141 TfL/142 TfL/143 TfL/144 TfL/145 TfL/146 TfL/147 TfL/148 TfL/149 TfL/150 TfL/151 TfL152 TfL/153 TfL/154 TfL/155
TfL/156
TfL/157
TfL/158 TfL/159 TfL/160 TfL/161
LMVR Highway Models Version 4 - 27 July 2003 Inquiry Note - Modelling of Junctions within SATURN INQ/8 10/02 Greenwich Waterfront Transit Drawings Harrow Manor Way Greenwich Waterfront Transit - Section 01 Safeguarding Route Greenwich Waterfront Transit - Section 2 Safeguarding Route Inquiry Note - Value of Time Growth Assumptions Inquiry Note - Additional Modelling Work Winsor Terrace Junction Inquiry Note - D 829 Local Highway Model LMVR Journey Time Figures Inquiry Note - A13/A406 Junction Lane Markings Inquiry Note - Commercial Vehicle Forecasts Inquiry Note on Questions Submitted by Mrs Wise Map Comparison of Barnham Drive Public Transport Loop Mar 2005 to Sep 2005 Greenwich Waterfront Transit Sponsors Endorsement of proposed route Extract from DMRB - Traffic Appraisal in Urban Areas LTS Model Tables requested by Professor Goodwin Thames Gateway Skills Audit Inquiry Note - Glasgow Traffic Model Audit Extract from D801 Summary of Local TGX Modelled Traffic Flows on the North Circular Road (A406) Extract from the Street Map of East London TGB Thames Gateway Bridge- Environmental Statement: Addendum 2 - Main Report (September 2005) Thames Gateway Bridge - Environmental Statement: Addendum 2 Non-Technical Summary (September 2005) Thames Gateway Bridge- Design Statement: Volume 2 of the Appendices to the Environmental Statement (July 2004 (Updated March 2005 and September 2005)) Paper describing amendments to Design Statement: Volume 2 of the Appendices to the Environmental Statement (July 2004 (Updated March 2005 and September 2005)) Thames Gateway Bridge- Landscape and Urban Design Strategy- Volume 3 of the Appendices to the Environmental Statement: Addendum (September 2005) Thames Gateway Bridge- Proposed Amendments to the Planning Applications Proposed modification to the A2012 GLA Road (Thames Gateway Bridge) (Side Roads) Order 2004 Residents Notification Letter concerning proposed amendments to Planning Application and Side Roads Order Copy of letter to GONE concerning proposed amendments to Planning Application and Side Roads Order
21
TfL/162 TfL/163
TfL/164 TfL/165 TfL/166 TfL/167 TfL/168 TfL/168A TfL/169
TfL/170 TfL/171 TfL/172 TfL/173 TfL/174a TfL/174b TfL/175 TfL/176 TfL/177 TfL/178 TfL/179 TfL/179a TfL/180 TfL181 TfL/182 TfL/183 TfL/184 TfL/184A TfL/185 TfL/186 TfL/187
Plan TBTGRC/SK/CH113 (Plan of proposed Amendment to Public Transport Loop) Copy of the public notice appearing in local newspapers concerning proposed amendments to Planning Application and Side Roads Order European Objective on Ambient Air Quality and Cleaner Air for Europe (21 Sept 2005) Communication from the European Parliament on Thematic Strategy on Air Pollution (21 Sept 2005) Inquiry Note - LMVR Clarification of Figures Get Back 24/1 Inquiry Note - TGB Information provided to the Highways Agency Get Back 29/1 Inquiry Note - Assessment of Economic Benefits 29 Sept 2005 Annex 1 to TfL/168 - TUBA Guidance Inquiry Note - DMRB Vol.12, Section 2, Part 1 Traffic Appraisal in Urban Areas Important Recommendations and the TGB 29 Sept 2005 Newspaper Extract PMs Investment Pledge (same as Annex to 1839/1/A1 Manor House Residents Proof) Inquiry Note - Daily Traffic Estimates on London Crossings Extracts from Greater London Authority Act 1999 (D207) Extract from D524 TAG Unit 1.1 ODPM Publication Thames Gateway Map Extract highlighting Thames Gateway Inquiry Note on Further Analysis - Professor Rosewell Inquiry Note - Response to Mrs Brown Document 1732/2 Mayor of London Press Release 20 June 2005 on Climate Change Inquiry Note - Distribution of Traffic on Road Network 11 October 2005 FOE London Plan examination in Public Response to Questions Matter 5 FOE London Plan examination in Public Response to Questions Matter 3 A Transport Strategy for London. April 1996, DOT/GOL Traffic Forecasts for Danson Road 12 Oct 2005 Draft Mayors Transport Strategy pp 247-259 Inquiry Note - Distribution of Benefits 20 Oct 2005 The Mayors Transport Strategy Highlights Response Form for Mayors Draft Transport Strategy Consultation TGB: Consideration of a Non-road Enhancement Option Inquiry Note - Requests for Information on Cold Starts & Relative Contributions of NO2 and PM10 to Concentrations Clarification Para 3.15 of TfL Rebuttal to SWCF Proof of Evidence
22
TfL/187A TfL/188 TfL/189 TfL/190 TfL/191 TfL/192 TfL/193 TfL/194 TfL/195 TfL/196 TfL/197 TfL/198 TfL/199 TfL/200 TfL/201 TfL/202 TfL/203 TfL/204 TfL/205 TfL/206 TfL/207 TfL/208 TfL/209 TfL/210 TfL/211 TfL/212 TfL/213 TfL/214 TfL/215 TfL/216 TfL/216A TfL/217
Clarification Para 3.8 of TfL Rebuttal to SWCF Proof of Evidence Note on Benzene - Professor Laxen Inquiry Note - Accessibility & Key Regeneration Areas 20 Oct 2005 Public Transport Statistics Bulletin GB: 2005 Edition Inquiry Note DLR Extension to Woolwich Capital Costs 21 October 2005 Proposed Amendments to Planning Application & Modification to Side Road Order September 2005 - Consultation Inquiry Get Back 44/1 Consultation Questionnaire Languages 8 Nov 2005 The Disclosure of Information obtained under section 1 of the Statistics of Trade Act 1947 TGB Option Assessment Clarification 9 Nov 2005 Response to Requests from Mr George Stern Nov 9 2005 The Environmental Information Regulations 2004, SI 2004 No 3391 Replacement Radar Facilities 10 Nov 2005 The River Crossings Package & Impact of Crossrail & the Silvertown Link 10 Nov 2005 Additional Counts & Modelling Work 10 Nov 2005 Inspectors Report Dated 10 Nov 2005 to the Greenwich UDP Review Additional Highway Modelling & Updated Forecasts 30 Nov 2005 Drawings referred to in paragraph 49 of TfL/202 2 Dec 2005 TGB Newsletters April 2004 and May 2005 Economic & Financial Estimates from Re-based Modelling Re-based TGX Model Calibration/Validation Dec 2005 Barnham Drive Public Transport Loop Comment by Ralph Cobham 12 December 2005 Re-based Modelling Supplementary Information to TfL/202 12 Dec 2005 Accessibility Impacts of The TGB (Get Back 49/4) AM & PM Peak Local Junction Assessments & Further Information to TfL/202 M25 Traffic Conditions and Routing 16 December 2005 Environmental Statement: Addendum 3 Main Report Dec 2005 Environmental Statement: Addendum 3 Non-Technical Summary Dec 2005 Modifications to the Toll Order to be proposed by TfL to the Secretary of State Assessment of Economic Benefits Response to INQ/15 Provisional Programme for Phase 4 of the inquiry Revised Provisional Programme for Phase 4 of the inquiry Additional Funding for Objectors Expert Advisors
23
TfL/218 TfL/219 TfL/220 TfL/221 TfL/222 TfL/223 TfL/224 TfL/225 TfL/226 TfL/227 TfL/228 TfL/229 TfL/230 TfL/231 TfL/232 TfL/233 TfL/234 TfL/235 TfL/236 TfL/237 TfL/238 TfL/239 TfL/240 TfL/241 TfL/242 TfL/243 TfL/244 TfL/245 TfL/246 TfL/247 TfL/248 TfL/249 TfL/250
Core Study Area Count Calibration & Validation LTS Forecasts Local Screenline Performance Review & Professor Goodwin Tables 4 INQ/8 Action 27/1 Benefits to Local Trips Letter dated 22 Dec 2005 from TfL to GONE re modifications to Orders Assessment of Commercial Vehicle Benefits Map showing Proposed Change to Local Discount Area Conversion of TGB to Dual 3 Lane Carriageway Response to AGAB letter of 14 Dec 2005 Re-based Traffic Model Calibration/Validation Count Sources 19 Jan 2006 LTS Technical Note 43 B3.00 Reference Forecasts & Validation Report London Cycling Design Standard (document not supplied) Schedule of Updates to Traffic, Transport & Appraisal Evidence - 25 Jan 2006 A406 Summary of Traffic Forecasts Re-Based Model Update to TfL/151 - 26 Jan 2006 Pattern of Use of the TGB Re-based Model Update to TfL/125 - 25 Jan 2006 Transport 2000 Clarifications & Additional Data Requests 20 Jan 2006 Air Quality Assessment A118/A406 Junction 31 Jan 2006 Details of Air Quality Assessment Sites in Bexley Response to INQ/8 56/5 dated 9 Feb 2006 Response to INQ/8 3/11 London City Airport Temporary Construction Measures Consistency of TfL Landscaping Proposals with CAP 680 Response to the Inspectors Note INQ/19 of 20 Dec 2005 Review of Cost of Proposed Traffic Mitigation Measures 30 Jan 2006 RNPR Traffic Note1, Nov 2005 - Traffic Levels on major roads in Greater London 1993-2004 Response to INQ/8 49/1 Response to INQ/8 49/3 Cycle Route & Journey Distance Assessment 16 Feb 06 Local Junction Models Guidance to Use of Outputs on CD Response to INQ/8 35/3 Further Response to Objectors Expert Advisors Discussions with Objectors Experts Summary of actions to date 09 Feb 2006 Length of Cycle Trips in London Response to INQ/8 36/1 Revised Annex 2 to TfL/210 to Reflect Changes to Inter-peak Tolling 16 Feb 2006 Correction to Supplementary Proof of Evidence Dr M Fillery, Noise & Vibration Impact 16 Dec 2005 TfL/Proof/12/4
24
TfL/251 TfL/252 TfL/253
TfL/254 TfL/255 TfL/256 TfL/257 TfL/258 TfL/259 TfL/260 TfL/261 TfL/262 TfL/263 TfL/264 TfL/265 TfL/265A TfL/266A TfL/267 TfL/268 TfL/269 TfL/270 TfL/270A TfL/271 TfL/272 TfL/273 TfL/274 TfL/275 TfL/276 TfL/277 TfL/278 TfL/279 TfL/280 TfL/281
Letter dated 14 Feb 2006 from TGLP to Mayor of London re Five Boroughs Agreement Land at A117/A1020 Gallions Roundabout Email dated 28 Feb 2006 from David Hawkett to Martin Stuckey LTS Modelled Results of Congestion Charge increase from 5 to 8 Information for Mr Cotton in response to request regarding an article in The Times 22 Feb 2006 Letter dated 2 Mar 2006 to LB Bexley Re Boroughs Agreement Response to INQ/8 60/1 Unemployment in Tower Hamlets Inter-peak Counts & 2001 Model Forecasts INQ/8 61/3 TfL/206 Revisions 7 Mar 2006 Extracts from LB Bexley Local Implementation Plan (Final Draft) Greenwich UDP Proposed Modifications Jan 2006 Policy M13 Clarifying the Basis for Decisions on Tolling Changes in Bexley Letter dated 9 Mar 2006 from LB Bexley to Mayor of London Inquiry Note referring to INQ/8 59/3 Inquiry Note Response to INQ/8 61/1 Additional Junction Analysis Information Response to INQ/8 59/1 & 59/2 Response to Query by Assistant Inspector Day 73 P119 TfL Response to Bexley 1774/31 TfL REB/1774/3 Revisions to Fig 1 -3 & Blackwall Tunnel Capacity Clarification Points INQ/8 63/1 TfL/231 Revisions to Fig 3 & 4 INQ/8 63/3 TfL response to Bexley 1774/31 Traffic Impacts of the TGB Revised TfL/249 & TfL/210 Annex 2 Addendum to TfL/270 Mouchel Parkman Mr Wang Letter 7 Mar 2006 TfL Comment Potential Inconsistencies between Assessments of Traffic & Regeneration Benefits Knee Hill Traffic Levels Additional Traffic Information Requested by Bexley TGB Traffic Forecasts to Inform Decisions on Tolling Changes in Bexley Bus Routes of Abbey Wood/Bexley area Friends of the Earth Consultation Leaflet Employers Evidence on Employment Impacts of TGB Response to INQ/23 Section 21 of the Traffic Management Act 2004 Response to AGAB letter 23 Mar 06
25
TfL/282 TfL/283 TfL/284 TfL/285 TfL/286 TfL/287 TfL/288 TfL/289 TfL/290 TfL/291 TfL/292 TfL/293 TfL/294 TfL/295 TfL/296 TfL/297 TfL/298 TfL/299 TfL/300 TfL/301 TfL/302 TfL/303 TfL/304 TfL/305 TfL/306 TfL/307 TfL/308 TfL/309 TfL/310 TfL/311 TfL/312 TfL/313A TfL/313A/1 TfL/313B TfL/313C TfL/313C/1
TfL Response to INQ/20 & INQ/21 & Other Issues Relating to A406 Sustainable Communities Building for the Future 2003 Map from Page 52 Information on Walking & Cycling Journey Lengths & Comparative Travel Distances for Cars & Cycles Plot of GEH Statistics for Inter peak Validation Counts (LMVR 2004) & Bexley Local Counts (TfL/257) Response to INQ/25 in relation to TfL/219 TfL Response to Ian Lindons letter to the Inspector 30/03/06 (1961/8) Responses to Keith Buchan Documents 4982/4, 5, 6 & 7 Blackwall Tunnel Closures Further information to TfL/107 Response to Mr Connollys (GASP) Appendices (2069/2) Response to INQ/25 in Relation to TfL/264 Junction Diagrams for Junctions 1 & 2 Note on Ecology Issues in AGAB Supplementary Proof Hornagold & Hills Report The Thames Gateway: Laying the Blue Line Knee Hill Dimensions + CD showing journeys on Knee Hill TfL Response to INQ/25 in relation to TfL/265 Belvedere Incinerator Traffic Impact Letter dated 17 Mar 06 from LB Greenwich re GWT Letter dated 28 Mar 06 from LB Bexley Re GWT Response to Professor Goodwin document 4985/3 Response to Jeremy Cotton Reference Day 66 Page 81 Response to query from Mr Black to Dr Hughes 17 Mar 06 Table 3.7 in Environmental Statement Blackwall Tunnel Closures Response to Inspectors Points on 18 Apr 06 Response to Inspectors Points on 18 Apr 06 on GWT Phase 1 application Number of Transport Studies that Include a PM Peak 1774/45 Traffic Forecast Reliability Response to INQ/8 63/2 GLA Roads Order (TGB) Request for Mayoral Approval Article in Gateway News as referred to in 2052/37 Response to Inspectors Questions in INQ/18 Response to INQ/27 Checklist of Inspectors Questions Blackwall Tunnel Note on Closures The A2012 GLA Road (TGB) CPO 2004 Modifications to be proposed to the Secretary of State - WITHDRAWN Revisions to TfL/313A dated 26/04/06 Note on Proposed Modifications to the A2012 GLA Road (TGB) CPO 2004 The A2012 GLA Road (TGB) CPO 2004 as proposed to be modified April 2006 - WITHDRAWN Revisions to TfL/313C 26/04/06
26
TfL/313D TfL/314 TfL/315 TfL/316 TfL/317 TfL/318 TfL/319 TfL/320 TfL/321 TfL/322 TfL/323 TfL/324 TfL/325 TfL/326 TfL/327 TfL/328 TfL/329 TfL/330 TfL/331 TfL/332 TfL/333 TfL/334 TfL/334A TfL/REB/264/1 TfL/REB/340 TfL/REB/342/1/B TfL/REB/480/1 TfL/REB/537/1 TfL/REB/1083/1 TfL/REB/1179/1 TfL/REB/1183/1 TfL/REB/1199/1 TfL/REB/1521/1 TfL/REB/1544/1 TfL/REB/1732/1 TfL/REB/1732/1Rev 1 TfL/REB/1752/1
Modifications to CPO 26/04/06 Knee Hill Traffic Levels The A2012 (LB of Greenwich & Newham) (Public Transport Bridge) Order 2006 Highways (Inquiries Procedure) Rules 1994 - Compliance Note on Response to Inspectors Question concerning Plots 206-211 (Day 83, Page 3, Lines 6-22) Response to Questions Raised by the Inspectors on Flythrough presented during Public Consultation in 2003 Observations on 1774/46 Traffic Growth & Growth Targets Queue capacity on A13 Off Slip to A406 Junction Blackwall Tunnel Closures Blackwall Tunnel Closures Response to 1732/15 INQ/14 Response to the Inspectors Note Humber Terminal Ltd v Secretary of State for Transport & Associated British Ports Ltd [2005] EWHC 1289 Admin R v Rochdale Metropolitan Borough Council ex parte Tew & Others The London Cycling Action Plan R v Rochdale Metropolitan Borough Council ex Parte Milne (2001) 81 P & C R 27 Extracts from Judicial Review Handbooks Response to 4982/9 Mr Buchans Comments on the TGB AST Response to INQ/26 (Points to be covered from written representations) A2012 GLA Road (TGB) CPO 2004 Status of Agreements with statutory of objectors A2012 GLA Road (TGB) Toll Order 2004 Modification proposed by TfL to the Secretary of State Email correspondence between TfL and LB Bexley re Bexley Database Closing Statement on behalf of TfL Addendum to Closing Statement (FODP) Rebuttal to Mrs Jacqueline Barter Rebuttal to Mr Paul Berry Rebuttal to Mr Jeremy Cotton Rebuttal to Mr & Mrs Ruddle Rebuttal to Abbey Wood Wildlife Federation Rebuttal to Mr Glen Cook Rebuttal to Mrs Ann Hutchison Rebuttal to Bexley LA21 Natural Environment Focus Group Rebuttal to Friends of Danson Park Rebuttal to Mr David Evennett MP Rebuttal to Evidence from Roy Carrier Rebuttal to Evidence from Mrs Ida Brown Revised Rebuttal to Evidence from Mrs Ida Brown Rebuttal to Thames Gateway London Partnership
27
TfL/REB/1774/1 TfL/REB/1774/2 TfL/REB/1774/2/A TfL/REB/1774/2/B TfL/REB/1774/2/C TfL/REB/1774/3 TfL/REB/1839/1 TfL/REB/1938/1 TfL/REB/1944/1 TfL/REB/1944/2 TfL/REB/1991/1 TfL/REB/1991/1A TfL/REB/19912062/2 TfL/REB/1995/2060/1 TfL/REB/1995/2 TfL/REB/2001/1 TfL/REB/2001/1/1 TfL/REB/2017/1 TfL/REB/2035/1 TfL/REB/2041/1 TfL/REB/2052/1 TfL/REB/2052/2 TfL/REB/2052/3
TfL/REB/2052/4 TfL/REB/2052/5 TfL/REB/2052/6 TfL/REB/2054/1 TfL/REB/2059/1 TfL/REB/2065/1 TfL/REB/2065/2 TfL/REB/2065/12 TfL/REB/2068/1 TfL/REB/2069/2 TfL/REB/2069/3 TfL/REB/2676/1 TfL/REB/2682/1 TfL/REB/2683/1/A1/1
TfL/REB/2684/1
Rebuttal to LB Bexley Rebuttal to the LB Bexley - Appendices Rebuttal to LB Bexley - Appendix B1 Rebuttal to LB Bexley - Revised Figure 3.1 Rebuttal to LB Bexley Supporting Tables Rebuttal to LB Bexley Supplementary Evidence Rebuttal to Manor House Neighbourhood Residents Association Rebuttal to Mr & Mrs Holt Rebuttal to Mr David Black Rebuttal to Mr David Blacks Supplementary Evidence Rebuttal to evidence of Professor Hamilton (delivered at the inquiry by Professor Focas) on consultation Rebuttal to Friends of the Earth Proof of Evidence Rebuttal to Supplementary Evidence from Friends of the Earth Rebuttal to Transport 2000 Rebuttal to Evidence from Transport 2000 Rebuttal to Saints Residents Association Further Rebuttal to Saints Residents Association Rebuttal to People Against the River Crossing Rebuttal to Bexley Civic Society Rebuttal to Woolwich & District Antiquarian Society Rebuttal to Action Group Against the Bridge Rebuttal to Action Group Against the Bridge (Mrs Tracey Hilliard) Rebuttal to Action Group Against the Bridge (Mrs Jacqueline Barter - proof not delivered at inquiry - regarded as written representation)) Rebuttal to Action Group Against the Bridge (Mrs Ida Brown) Rebuttal to Action Group Against the Bridge (Mr Steve Wise) Rebuttal to Terry Grant (St Michaels Residents Association) Rebuttal to London City Airport Rebuttal to Greenwich Wildlife Advisory Group Rebuttal to Simon Wolff Charitable Foundation (Mr Stern) Rebuttal to Simon Wolff Charitable Foundation (Mrs Tuckman) Rebuttal to Comments on TfL/241 SWCF Rebuttal to Cllr John Waters Rebuttal to Greenwich Action to Stop Pollution Rebuttal to GASP Supplementary Evidence Rebuttal to Thames Water (not delivered at inquiry following withdrawal of objection) Rebuttal to Mr John Austin MP Rebuttal to Evidence from Anna & Keith Townend on behalf of Greenlands in Trust (not delivered at inquiry as objection became written representation) Rebuttal to Mr Clive Efford MP
28
Rebuttal to LB Newham Rebuttal to Mr John R Elliott Rebuttal to Mr John Elliotts Supplementary Proof Rebuttal to Bexley & Greenwich Liberal Democrats Rebuttal to LB Greenwich Assessment of Public Transport Options Rebuttal to Greenwich & Lewisham FOE Rebuttal to Supplementary Evidence from Greenwich & Lewisham FOE TfL/REB/2714/1 Rebuttal to London Cycling Campaign TfL/REB/4237/1 Rebuttal to Ms Janet Mackinnon TfL/REB/4982/1 Rebuttal to Keith Buchan MTRU TfL/REB/4982/1/A2/REV 1/1 Rebuttal to Keith Buchan Revised Supplementary Proof TfL/REB/4982/2 Rebuttal to MRTU Report - Pressure to Revive a north- south route TfL/REB/4983/1 Rebuttal to Professors Therivel & Whitelegg TfL/REB/4983/2 Rebuttal to Professor Whiteleggs Supplementary Proof TfL/REB/4984/1 Rebuttal to Professor Hamilton TfL/REB/4985/1 Rebuttal to Professor Goodwin TfL/REB/4985/2 Rebuttal to Professor Goodwins Supplementary Proof TfL/REB/4986/1 Rebuttal to Professor Mark McCarthy TfL/REB/4987/1 Rebuttal to Mr Phillip Connolly Documents submitted by Supporters Thames Gateway London Partnership 1752/1/A 1752/1/A1 1752/1/B 1752/1/C 1752/1/D 1752/1/E 1752/2/A1 1752/2/B 1752/3/A1 1752/3/B 1752/4/A 1752/4/A1 1752/4/B 1752/4/C 1752/4/D 1752/4/E 1752/5 1752/6 Proof of Evidence Summary Stephen Joseph Proof of Evidence Main Text - Stephen Joseph Appendices Stephen Joseph Position Statement on TfL/22 Draft 5 Boroughs Agreement Traffic Using Major Crossings with TGB Itchen Bridge Re INQ/8 Proof of Evidence Vivien Cutler Thames Gateway Skills Audit Proof of Evidence Summary and Full Proof - Peter Gluckman Appendices Peter Gluckman Proof of Evidence Summary Aman Dalvi Proof of Evidence Aman Dalvi Proof of Evidence Appendices Aman Dalvi An Essential Crossing from the Business Perspective Map Distribution of NLUD- PDL Brownfield Sites within the TGB Boundary Map Distribution of NLUD- PDL Brownfield Sites within the East London Boundary TGLPs response to TFL new evidence using higher traffic predictions Response to INQ/23 dated 30 Mar 06
TfL/REB/2687/1 TfL/REB/2691/1 TfL/REB/2691/2 TfL/REB/2698/1 TfL/REB/2703/1 TfL/REB/2703/2 TfL/REB/2704/1 TfL/REB/2704/1A2/1
29
1752/7
Closing Submission
London First 1987/1/A 1987/1/A1 1987/1/A2 1987/1/B 1987/1/C Proof of Evidence Stuart J Robinson Executive Summary Proof of Evidence Stuart J Robinson Supplementary Proof of Evidence Stuart Robinson Appendices Stuart J Robinson Letter received 15 July 2005 re INQ/8 Getbacks
London Development Agency 2007/1/A1 2007/2 2007/3 2007/4 Statement of Support Tony Winterbottom Additional Information 11 July 2005 re INQ/8 Letter dated 8 Aug 2005 re issues raised by Mr Terry Grant Letter dated 31 Jan 2006 responding to the new evidence put forward by TfL and how this affects evidence submitted by LDA in May 2005
London Borough of Redbridge 2067/1/A 2067/1/A1 2067/1/B 2067/2/A2 2067/2 2067/3 2067/4 2067/5 2067/5A 2067/6 2067/7 2067/8 2067/9 2067/10 2067/11 2067/12 Proof of Evidence of Mr Billy Parr BA (Hons) AMIHT Summary Proof of Evidence of Mr Parr - Main Text Appendices to Mr Parrs proof Supplementary proof of evidence of Mr Parr Additional Note - Objections to TGB Scheme Additional Note - Types of Jobs Created as a result of the TGB Additional Note - Approach to Traffic Assessments Additional Note - Peak Hour Congestion on the Principal Road Network in Redbridge 15 July 2005 Additional Note - Peak Hour Congestion on the Principal Road Network in Redbridge 1 Sept 2005 Additional Note - Peak Hour Congestion on the Principal Road Network in Redbridge 1 Sept 2005 Revised Letter dated 29 Nov 2005 re TfL New evidence Letter dated 21 Dec 2005 re 5 Boroughs Agreement Letter dated 4 Nov 2005 re 5 Boroughs Agreement Response to INQ/23 Response to INQ/14 Closing Submission
London Borough of Newham
30
2687/1/A 2687/1/A1 2687/2/A 2687/2/A1 2687/3/A 2687/3/A1 2687/4/A 2687/4/A1 2687/5 2687/6 2687/7 2687/8 2687/9 2687/10 2687/11 2687/12 2687/13 2687/14 2687/15 2687/16 2687/17 2687/18 2687/19 2687/20 2687/21 2687/22 2687/23 2687/24 2687/25 2687/26
Summary of Proof of Evidence of Andrew Merritt MSc BSc MIHT Main Text of Mr Merritts proof Summary of Proof of Evidence of Ian Fines MSc Dip TP MRTPI Main Text of Mr Fines Proof Summary Proof of Evidence of Mr Robin Whitehouse MCIEH Main Text of Mr Whitehouses proof Summary of Proof of Evidence of Mr Peter Minoletti BA MRTPI Main Text of Mr Minolettis proof Jacobs Babtie TGB Summary Report Nov 2004 Jacobs Babtie July 2004 Traffic & Transport Review Jacobs Babtie Summary Report Opening Submissions Andrew Merritt Email 5 Aug 2004 Re Traffic & Transport Report Further Questions for Halcrow arising from interim Review of Traffic & Transport Report TGB Data Issue to Babtie Report to Committee re Application No: P/04/1170, the main planning application John Fearon Review of Terry Wangs Proof of Evidence for Bexley Daily mean PM 10 - LB Newham Annual Mean Nitrogen Dioxide - LB Newham Technical Note Review of TfL Transyt Re INQ/8 Jacobs Babtie July 2004 Traffic & Transport Report with amendments to update to Nov 2004 Traffic Congestion on Main Road Network in Newham Proposed Conditions regarding TGB Construction Site Comments on Para 5.9 TfL Rebuttal LB Newham Air Quality Action Plan 2004 Email dated 19 October re conditions session Letter received 12 Mar 2006 Re TfL revised Traffic Modelling Response to INQ/23 Response to INQ/14 Closing Submissions
London Borough of Greenwich 2703/1/A1 2703/1/B 2703/1/B1 2703/2/A 2703/2/A1 2703/2/A1/2 2703/2/B Proof of Evidence (Summary and Main Text) of Mr Frederick Brown BA MRTPI Appendices to the proof of Mr Brown Revised Appendix FB3 Summary Proof of Evidence of Mr Bob Chard MPhil MA BA Dip TP MRTPI Main Text of Mr Chards proof Revised Proof of Evidence of Mr Chard Appendices to the proof of evidence of Mr Chard
31
2703/3/A1 2703/3/B 2703/3/C 2703/4/A 2703/4/A1 2703/5 2703/6 2703/7 2703/8 2703/9 2703/10 2703/11 2703/12 2703/13 2703/14 2703/15 2703/16 2703/17 2703/18 2703/19 2703/20 2703/21 2703/21A 2703/22 2703/23 2703/24 2703/25 2703/26 2703/27 2703/28 2703/29 2703/30 2703/31 2703/32 2703/33 2703/34 2703/35
Proof of Evidence of Mr Andrew Whittles BSc Dip EMA Swedish Low Emission Zones re INQ/8 Map Air Quality Monitoring in Greenwich re INQ/8 Summary Proof of Evidence of Mr John Hopkins MSc BSc MICE FIHT Main Text of Mr Hopkins proof Draft London Code of Practice Part 1: The Control of Dust from Construction What Light Rail Can Do for Cities, Final Report, Feb 2005 What Light Can Do for Cities Report, Jan 2005 - Appendices Review of Traffic Modelling Nov. 2004 Jacobs Babtie Review of Public Transport Model Validation Report Nov. 2004 Jacobs Babtie Letter dated 13 June 2005 from Mr R Chard - Holding Objection to the CPO revisions The Future of Light Rail and Modern Trams in Britain Developing Light Rail to Improve Public Transport Bob Chard Letter dated 22 June 2005 to the Crossrail Bill Team re Crossrail & Petts Wood Station Extracts from Tramways & Urban Transit Select Committee on Transport Tenth Report LB Greenwich Planning Board Minutes 26 August 2004 Greenwich LIP Consultation Draft Key Developments in Greenwich which have received Civic Trust recognition Extract from Mayors Transport Strategy LIP Guidance July 2004 Crossrail Hybrid Bill Information Drawings Letter from R Chard dated 13 June 2005 (same as 2703/10 Planning Permissions for Tripcock Park & Gallions Hill Breakdown of estimated cost of air monitoring re INQ/8 Submission re Guaranteed Minimum Public Transport Provision over TGB Definition of Public Transport INQ/8 15/5 Locations on Principal Road Network in Greenwich Congested in Peak Hours INQ/8 15/7 Note- Opening of Nottingham Tram System INQ/8 15/9 LBG Proposed Modification to the Orders INQ/8 15/4 Assumptions about Other River Crossings INQ/8 15/3 Environmental Tolls & the Draft Legal Agreement Transport Assessment INQ/8 15/6 Harrow Manor Way & Crossrail & GWT Plans Map Barham Drive Highways & Transit Land Reservations & Proposals Letter Dated 2 Sept.2005 Re Cross Examination by Objectors of LB Greenwich Witnesses Letter Dated 2 Sept 2005 re INQ/8 15/4 Letter Dated 2 Sept 2005 Re Legal Agreement
32
2703/36 2703/36A 2703/37 2703/38 2703/39 2703/40 2703/41 2703/42
2703/43 2703/44 2703/45 2703/46
2703/47 2703/48 2703/49 2703/50 2703/51 2703/52 2703/53 2703/54 2703/55 2703/56 2703/57 2703/58
Draft Five Boroughs Agreement as at 9 Sept 2005 Missing Page 34 of 2703/36 Petition against Crossrail Bill - LB Greenwich Extract from DEFRA Sustainable Consumption & Production Indicators Inquiry Note - Why LB Greenwich considers that Motorbikes should pay tolls on TGB De-Coupling New Development & Traffic Growth The Viability of Tram Systems in Relation to Passenger Demand Forecasts Letter dated 10 November addressed to Government Office re Amendments to the Thames Gateway Bridge Planning Application Note on Proposed Cruise Liner Terminal Letter dated 28 Nov 2005 Re INQ/14 Withdrawn Duplicate of 2703/42 Letter received 28 Nov 2005 from Fred Brown to TfL re use of 2003 meteorological and air quality data in environmental assessment Record of LB Greenwich Council Meeting Decisions 30 Nov 2005 Council Minutes LB Greenwich 30 Nov 2005 Letter dated 16 Dec 2005 withdrawing objection to CPO Letter dated 16 Dec 2005 withdrawing objections to Side Roads Order (Sept 05) Letter dated 27 Jan 2006 to Secretary of State for Transport re Proposed Modifications to the Toll Order Authority to Pursue an Objection to the Planning Application Supplementary Written Representation in response to further evidence submitted by TfL in Dec 2006 Withdrawn Response to INQ/23 proposed Planning Condition Jacobs Babtie Review of TfL Traffic Evidence Final Report March 06 LBG Response to Mr Paul Berry document 340/3 Closing Submissions
Documents submitted by Objectors Mrs Jacqueline Barter 264 264/1/A1 264/1/A1/2 264/1/B 264/2 264/3 Email Outline Proof dated 24th June 2005 Proof of Evidence Proof of Evidence Annotated Version Appendices to Proof of Evidence Letter dated 13 July from Mrs Barter to Port of London Authority Letter dated 3 August from Port of London to Mrs Barter
33
264/4 264/5
Brochure Port of London Cruise - Information re planned permanent cruise terminal Reply to TfL/REB/2052/3
Mr Dave Reynolds 277/1 Mr Paul Berry 340/1/A 340/1/A1 340/1/A1/2 340/1/B 340/1/B1 340/2 340/3 340/4 340/5 Proof of Evidence Summary Proof of Evidence Revised Proof of Evidence Appendices to Revised Proof of Evidence Appendix 54 (DVD) to Revised Proof of Evidence Letter dated 12 March 2006 re appearance and request for cross examination of witnesses from LB Greenwich Questions for LB Greenwich Summary of Proof of Evidence Thamesmead Street Map Letter of Objection dated 14 Jan 2006
Mr Jeremy Cotton 342/1/A 342/1/A1 342/1/A2 342/1/B 342/2 342/3 342/4 342/5 342/6 Summary Proof of Evidence Proof of Evidence Supplementary Proof Mar 2006 Proof of Evidence Appendices Letter dated 20 October 2005 re availability of TfL proofs The Times 16 Feb 2006 Letter to the Editor re legislative reform Car Ownership and Cycling in London and Great Britain Minutes of Proceedings at ELRC Public Inquiry 27 March 1986 Dept of Transport ELRC (A13 to A2) Proof of Evidence on Traffic Vol. 2 Drawings Aug 1985 Press Cutting & E-mail to TfL re Congestion Charging within M25 27 Feb 2006 PowerPoint Presentation Traffic Management & Local Government 21 Feb 2006 Copy of EU directive 1999/62/EC Extract from Bexley Extra 3 Mar 2006 re Tavy Bridge Thamesmead Closing Submission Jeremy Cotton
342/7 342/8 342/9 342/10 342/11
Mr & Mrs A Ruddell 480/1/A1 480/1/B Proof of Evidence Appendices to proof of evidence
34
480/2
Additional Statement made by Mr and Mrs Ruddell
Abbey Wood Wildlife Mr Kenneth Hobday 537/1/A1 Proof of Evidence
Councillor Peter Catterall 652/1 Mrs H Joyce 1080/1 1080/2 Letter dated 19 September 2005 re Emergency Services Letter dated 22 April 2006 re points of clarification Day 86 Email dated 21 Nov 2005 regarding TFL new evidence
Mrs Ann Hutchinson 1179/1/A1 1179/2 Proof of Evidence The Greenwich Strategy
Bexley LA21 Natural Environment Focus Group 1183/1/A 1183/1/A1 1183/1/A2 1183/1/B 1183/2 1183/3 1183/4 1183/5 1183/6 1183/7 1183/8 1183/9 1183/10 Summary Proof of Evidence of Jeremy Cotton Proof of Evidence Main Text Supplementary Proof 2 March 2006 Appendices to proof of evidence Crayford/Dartford Marsh Strategic Framework (Maps) Dept of Transport ELRC (A13 to A2) Proof of Evidence Environmental Evaluation Volume 2: Drawings Managing The Marshes Summary Report Feb 2006 Press Cutting Safeguard our Wild Marshland 3 Mar 2006 Friends of Crossness Nature Reserve Newsletter Issues 1 to 4 of 2005 Set of Maps re location of Water Voles NEFG Mailing List Terms of Reference of NEFG Friends of Crossness Nature Reserve Newsletter Issue 5/6 2006 & 2005 Annual Report
Friends of Danson Park 1199/1/A 1199/1/A1 1199/1/B 1199/2 1199/3 1199/4 1199/5 Proof of Evidence Summary Mrs Lynn Batham Proof of Evidence Main Text Appendices to Proof of Evidence Authority to Mrs Batham to appear at the inquiry on behalf of the Friends of Danson Park Letter to LB Bexley dated 22 July 2005 re Traffic Modelling Letter dated 27 June 2005 re Summer Site Visit Written Submission re TfL Supplementary Evidence
35
Mr David Evennett MP 1521 Letter Received 28th June 2005 Synopsis
Mr Roy Carrier 1544/1/A 1544/1/A1 1544/1/A2 1544/1/A2/1 1544/1/B 1544/3 1544/4 1544/5 Mrs I Brown 1732/1/A 1732/1/A1 1732/1/A2 1732/1/B 1732/2 1732/3 1732/4 1732/5 1732/6 1732/7 1732/8 Proof of Evidence Summary Proof of Evidence Supplementary Proof of Evidence 3 March 2006 Proof of Evidence Appendices Inquiry Note re status of Pickford Lane, Brampton Road and Long Lane Addition to Para 10 of the main proof dated 19 Oct 2005 Traffic Counts for Vehicles Passing my House in Pickford Lane Photographs to show Traffic in Pickford Lane Extract from Daily Mail 8 Mar 2006 re Sat- Nav Extract from RSPB Web re Black Redstart Response to Asst Inspectors request for information to substantiate reference to closures of Blackwall Tunnel, the Woolwich Ferry & the M25 Crossing Is it possible to have regeneration and the incinerator? Additional Information re Blackwall Tunnel Closures Additional Information to 1732/8 re Le Crossing. Blackwall Tunnel Closures 20 Apr 2006 Closing Statement Regeneration, Quality Jobs, Sustainable Communities Re TfL/321 Blackwall Tunnel Blackwall Tunnel & TfL 322 Proof of Evidence Summary Proof of Evidence Main Text Supplementary Proof of Evidence Feb 2006 Supplementary Proof of Evidence Summary Feb 2006 Proof of Evidence Appendices Email dated 24 July 2005 re cross examination Law Report Hereford Waste Watchers Limited v Hereford Council M6 Toll Road Pricing Table
1732/9 1732/10 1732/11 1732/12 1732/13 1732/14 1732/15 1732/16
London Borough of Bexley 1774/1/A 1774/1/A1 Proof of Evidence of Mr Richard Hawkins MSc CEng MICE MIHT MCIT - Summary Mr Hawkins proof - Main Text
36
1774/1/B 1774/1/B1 1774/1/C 1774/1/C1
Appendices to Mr Hawkins proof Addition to Appendix 8 Supplementary & Rebuttal Proof - Mr Hawkins Map showing Traffic Calming & Distributor Roads in North Bexley Notification of Schemes & Works affecting the Strategic Road Network & GLA Roads Second Supplementary Proof of Evidence of Mr Hawkins Mar 2006 Proof of Evidence of Terry Wang BSc MSc CEng MICE FCILT Summary Mr Wangs proof - Main Text Appendices to Mr Wangs proof Jacobs Babtie Draft Review of Traffic Modelling Nov 2004 Babtie Group Extract Annual Traffic Monitoring Report April 2001 March 2002 Mayor of London Travel Report 2004 Letter to Mr Clarke TfL dated 19 April 2005 re transport issues concerning the TGB Halcrow Group report re Traffic Mitigation Measures July 2004 Tables and Figures supporting Mr Wangs proof Supplementary & Rebuttal Proof from Mr Wang Supplementary & Rebuttal Tables & Figures supporting Mr Wangs proof Supplementary & Rebuttal Appendices supporting Mr Wangs proof Statement on Planning Policy Addendum to 1774/3/A and response to Section 4 of TfL Rebuttal to LB Bexley Supplementary Statement of Planning Policy and comment on the revised tolling proposals Comments on TfL Rebuttal to Supplementary Evidence from LB Bexley (TfL/REB/1774/3) Bexley Street Map Interim Note in response to TfLs opening statement Supplementary Note to 1774/5 Technical Note 66 - Model Performance Review TGB Traffic Mitigation Measures TGB Traffic Study WS Atkins Final Report Availability of 2001 London Area Transport Survey Data East Thames Crossings Appraisal Framework Local Model Validation Report 1996 Highways Models Table 2 Average Morning Peak Hour Cordon & Screenline Flows Comparison and Map Greenwich Waterfront Transit Sections 01, 02 & 03 Comparison of Modelled Flows (2001 AM Peak)
1774/1/C2 1774/1/D 1774/2/A 1774/2/A1 1774/2/B 1774/2/B1 1774/2/B2 1774/2/B3 1774/2/B4 1774/2/B5 1774/2/C 1774/2/D 1774/2/E 1774/2/F 1774/3/A 1774/3/A/REB 1774/3/B 1774/3C 1774/4 1774/5 1774/5A 1774/6 1774/7 1774/8 1774/9 1774/10 1774/11 1774/12 1774/13
37
1774/14 1774/15 1774/16 1774/17 1774/18 1774/19 1774/20 1774/21 1774/22 1774/23 1774/24 1774/25 1774/26 1774/27 1774/28 1774/29 1774/30 1774/31 1774/32 1774/33 1774/34 1774/35 1774/36 1774/36A 1774/37 1774/38 1774/39 1774/39A 1774/40 1774/41 1774/42
1774/43 1774/44 1774/45 1774/46
Copy Letter dated 19 July 2005 from Leader of Bexley Council to Mayor of London Opening Statement on behalf of LB Bexley Resolution of Bexley Council re evening sessions of the inquiry Traffic Management Act 2004 Extract Authority for the presentation of LB Bexleys case to the Public Inquiry Letter dated 20 July 2005 from DfT to LB Bexley re attendance at meetings between Halcrow and ITEA DMRB Relevant Extracts LMVR June 2003 Background to the LTS Model Planning applications re site at 100-106A Harrow Manorway Crossrail Bill Petition from LB Bexley Inquiry Note - Tavy Bridge Development Inquiry Note - Rationale for 10 Maximum Toll Inquiry Note - Network Management Duty Letter dated 4 Nov 2005 re programme for presentation of Supplementary Evidence Inquiry Note - Brampton Road Traffic & Speed Survey Inquiry Note - Brampton Road Land Designation Land Ownership in Harrow Manorway Letter dated 25 Jan 2006 to Secretary of State for Transport re Modifications to Proposed Toll Order Letter dated 14 Feb 2006 to M Stuckey TfL Re Revised Modelling Letter dated 16 Feb 06 from Mr Wang to Mr Hawkins re TfLs new traffic evidence Letter dated 23 Feb 06 confirming appearance and cross examination arrangements Copy correspondence with Mayor of London & TfL Letter from the Mayor of London dated 7 March 2006 Halcrow -Thames Gateway Integrated Land Use & Transport Study 31 Aug 2004 Mouchel Parkman Letter dated 7 Mar 2006 re TfL Rebuttal to LB Bexley Supplementary Evidence Table of Deprived Super Output Areas in Bexley Revised Table of Deprived Super Output Areas in Bexley Letter dated 25 Jan 2006 to TfL re Revised Modelling Report Cabinet Advisory Group LIP 2005/06 to 2010/11 Regeneration Framework for Bexley 2006-2016 Text Presented for Adoption to the Meeting of the Council 13 July 2005 Response to INQ/8 20/1 LB Bexley Term Consultant - Mouchel Parkman Number of Transport Studies that include PM peak Traffic Growth & Growth Targets
38
1774/47 1774/48 1774/49 1774/50
Closing Statement on behalf of LB Bexley Response to TfL/271 Traffic Mitigation Measures & the Network Management Duty Bexleys unilateral proposals for mitigation
Manor House Neighbourhood Residents Association 1839/1/A 1839/1/A1 1839/2 Preamble to MHNRA Case & Response to TfL Rebuttal Proof of Evidence of Mr Ronald Gee Copy of Letter circulated to members (INQ/8 46/1)
Mr John Davey 1906/1 Proof of evidence of Mr Davey
Mr & Mrs G R A Holt 1938/1/A1 Proof of Evidence
Mr David Black 1944/1A 1944/1/A1 1944/1/B, C, D 1944/1/A2 1944/1/A2/1 1944/2 1944/3 1944/4 1944/5 1944/6 1944/7 1944/8 1944/9 1944/10 1944/11 1944/12 1944/13 Mr Ian Lindon Proof of Evidence Summary Proof of Evidence Proof of Evidence Appendices Supplementary Proof of Evidence Supplementary Proof Addendum & Annexes March 2006 Letter dated 18 Oct 2005 re cross examination Decision Letter dated 28 July 1998 re East London River Crossing Decision Letter dated 27 Sept 1991 re East London River Crossing The A406 London North Circular Trunk Road (ELRC (A13 to A2)) Orders 1988 & 1991, Revocation Order 1997 Letter dated 7 Mar 2006 re rebuttal delivery Letter dated 1 Apr 2005 from the European Commission re TGB European Directive 2001/42/EC 27 June 2001 Andrews Dury & Herberts Map of Kent 1769 LB Bexley Web Page Parks - 7 Open Spaces Lesnes Abbey Metapopulations & Patch Dynamics On the Impracticability of Recreating Ancient Woodland Written Closing Submission
39
1961 1961/2 1961/3 1961/4 1961/5 1961/6 1961/7 1961/8
Letter of objection Not used Not used Not used Living with the A2 The A2 Noise Report February 1999 Paper re A2 (Bexley) Environmental Campaign Committee 1995 Extracts from Reviewing the London Plan
Friends of the Earth 1991/1/A1 1991/1/A2 1991/2062/1/A2 1991/1/B 1991/99 1991/100 1991/101 1991/101A 1991/102 1991/103 1991/104 1991/105 1991/106 1991/107 1991/108 1991/109 1991/110 1991/111 1991/112 1991/112A 1991/113 1991/114 1991/115 1991/116 1991/117 1991/118 1991/119 1991/120 1991/121 1991/122 1991/123 1991/124 Proof of Evidence of Ms Jennifer Bates Supplementary Proof of Evidence 3 Mar 2006 Supplementary Rebuttal Notes/Proof of Evidence A Reasoned Critique of the TGB Consultation Process A Bridge Too Far - FOE Leaflet Letter of Objection to TGB Planning Applications addressed to LBN & LBG - No date FOE Book Release - Tomorrows World HM Government Sustainable Development Strategy DTI Our Energy Future DTI Creating a Low Carbon Economy DEFRA Statistics about Global Atmosphere DEFRA Key Facts about Global Atmosphere Table 5 Estimated emissions of carbon dioxide DEFRA Consultation on the review of the UK Climate Change Programme Mayors Transport Strategy - Report on Public Consultation Long Term Reduction in Gas Emissions in UK Relationship between Transport & Development in the Thames Gateway Less Traffic Where People Live: How Local Transport Schemes can help cut Traffic The Gaps Widening Regenerating the Isle of Dogs Final Report on Transport & Social Exclusion Health Inequality Gap Widening ODPM Community Involvement in Planning Better Buses and Safer Streets for Longsight Climate Change Programme Review Do you agree with DEFRA emission projections? DfT Energy & the Environment Avoiding Dangerous Climate Change Timeline Climate Change EA The Impacts of Climate Change FOE Tackling Climate Change in the English Regions Extract from Labour Party Manifesto 2005 Chapter 7
40
1991/125 1991/126 1991/127 1991/128 1991/129 1991/130 1991/131 1991/132 1991/133 1991/134 1991/135 1991/136 1991/137 1991/138 1991/139 1991/140 1991/141 1991/142 1991/143 1991/144 1991/145 1991/146 1991/147 1991/148 1991/149 1991/150 1991/151 1991/152 1991/153 1991/154 1991/155 1991/156 1991/157 1991/158 1991/159 1991/160 1991/161 1991/162 1991/163 1991/164 1991/165 1991/165A 1991/166
Alistair Darlings speech to Labour Party Conference 2005 DfT Delivering Better Transport The Mayors Energy Strategy Extract from Ken Livingstones speech to the State of London Debate DfT Protecting the Environment FOE Press Release New Car Emissions Website Extract Tyndall Centre on UK Climate Change FOE Press Release Food Miles Londons Warming (Extract) Climate Change 2001 (P19) Challenges and Choices Thames Estuary (EA) TfL London Travel Report 2004 (Extract) River Tyne (Tunnels) Order Inspectors Report CBRE Changing the Face of The Greater London Property Market DfT Web Search Transport & Development Thames Gateway TGB Question No 1456/2005 Darren Johnson Guardian Extract on Long Distance Commuting Kent Online A2 Widening Withdrawn Web Extract Sustainable Suburbs Draft Toolkit Web Extract Households without a car or van 2001 Stavros Diamas - European Mobility Week 2005 Web Extract The London Air Quality Network Withdrawn WHO Fact Sheet - Particulate Matter Air Pollution Cutting from Evening Standard re Congestion Charge Extension Withdrawn Withdrawn Mayor of London Sustainable Development Framework Web Extract London Sustainable Development Commission Guardian Extract Troubled Waters FOE Report Environmental Justice Impact Assessment Web Extract Links to the London Equalities Agenda LSx Environmental Justice for London TfL Board meeting 24/03/04 Notes M74 Extension Decision TGLP Response: Draft Sub Regional Development Framework Flooding Risk in the Thames Gateway FOE Implementing the Barker Report Web Extract SDC Creating Communities with a Low Environmental Impact Enabling One Planet Living in The Thames Gateway FOE Response Planning for Housing Provision Web Extract ODPM - The Need to Create Sustainable Communities Key Facts
41
1991/167 1991/168 1991/169
1991/170 1991/171 1991/172 1991/173 1991/174 1991/175 1991/176 1991/177 1991/178 1991/179 1991/180 1991/181 1991/182 1991/183 1991/184 1991/184A 1991/185 1991/186
ODPM Planning for Sustainable Housing and Communities in the South East Planning for Sustainable Communities in the SE Government Response Government Response to the House of Commons Environmental Audit Committee Report Housing: Building a Sustainable Future Study into the Environmental Impacts of Increasing the Supply of Housing in the UK Web Extract Association of British Insurers - Flood Risk in Growth Areas ABI Making Communities Sustainable Email New City the Size of Leeds Guardian Extract Homes will Swamp Countryside Guardian Extract Urban Myth Web Extract Sustainable Development in the South East Guardian Extract Weather forecasters to warn Prescott over new homes plan Guardian Extract Watchdog blames Councils over flood risk UK Parliament Environmental Audit First Report CPRE Building on Barker SDC Sustainable Communities and Sustainable Development Revisions 21/10/05 to Additional submitted docs Material referred to in Supplementary Proof of 3 Mar 2006 Closing Statement from Friends of the Earth 24 April 2006 Amended Closing Statement from Friends of the Earth 24 April 2006 Note re TGB BBC London Politics Show summer 2005 Copy email dated 13 Aug 2003 re 2003 consultation
Transport 2000 1995//1 1995/1/A 1995/1/A2 1995/1/A2/1 1995/1/B 1995/2 1995/3 1995/4 1995/5 1995/6 1995/7 1995/8 Proof of Evidence of Richard Bourne Proof of Evidence Summary Addendum to Proof Information about T2000 Supplementary proof of Evidence 3 Mar 2006 Report by MRTU Assessment against National, Regional & Local Policies London Travel Report 2003 Note on Alternatives - MTRU Oct 2005 Email dated 19 Dec 2005 Request for Information Letter of Authority dated 16 Jan 2006 Parking Provision in Planned Developments Near the Proposed Thames Gateway Bridge. T2000 history of objecting to the proposed TGB T2000 Response to the Draft London Plan
42
1995/9 1995/10
The Criteria for new road schemes in policy 3C.15 of the London Plan Closing Statement
Saints Residents Association 2001/1/A 2001/1/A1 2001/1/A1/2 2001/2 2001/3 Summary Proof of Evidence of Mr Tim Chapman Proof of Evidence - Main Text Revised Proof of Evidence March 2006 Summary of Proof of Evidence as delivered Response to TfL Rebuttal TfL/REB/2001/1
People Against The River Crossing 2017/1/A 2017/1/A1 2017/1/B 2017/1/C 2017/1/D 2017/1/E 2017/1/F 2017/1/G 2017/1/H Summary Proof of Evidence of Dr Barry Gray Proof of Evidence of Dr Barry Gray - Main Text Bundle of Documents referred to in 2017/1/A1 Proof The Thames Gateway Skills Audit - London Metropolitan University Eastern River Crossings Assessment Llewelyn Davies Jan 1994 Bundle of Documents for Cross Examination of Mr Gluckman Additional Submitted paper Health Inequalities Bundle of Documents referred to during Cross Examination Bundle of Coloured Diagrams to be used in Cross Examination
Belvedere Community Forum 2030 2030/1 E-mail dated 26 Sept 2005 re speaking at Evening Session Outline of statement made by Mr John Livingstone on behalf of the Forum
Bexley Civic Society 2035/1/A1 Proof of Evidence of Mr John Mercer
Woolwich & District Antiquarian Society 2041/1/A1 2041/2 2041/3 2041/4 Proof of Evidence of Mrs Susan Parker Response to TfL Rebuttal Written representation regarding East Londoner Extract from the Independent 30 August 2005 London Doesnt Need the Bridge
Action Group Against the Bridge and Saint Michaels Residents Association
43
2052/1/A 2052/1/A1 2052/1/A1/1 2052/1/A2 2052/1/A2/1 2052/1/A3 2052/1/B 2052/1/B2 2052/1/B3 2052/2/A 2052/2/A1 2052/2/A1/1 2052/2/A2 2052/2/B 2052/3/A1 2052/3/A2 2052/3/B 2052/4 2052/4A 2052/4/A1 2052/5 2052/5/A1
2052/6 2052/6/A1 2052/6/A1/1 2052/6/C 2052/7 2052/8 2052/9 2052/10 2052/11 2052/12 2052/13 2052/14 2052/15 2052/16 2052/17 2052/18
Summary Proof of Evidence on Traffic Issues - Mrs Jacqui Wise Proof of Evidence on Traffic Issues - Main Text Supplementary Proof of Evidence on Traffic, Consultation, Health and Ecology Issues - 24 Mar 2006 Proof of Evidence on Health Issues - Mrs Jacqui Wise Summary Proof of Evidence on Health Issues Proof of Evidence on Consultation - Mrs Jacqui Wise Appendices on Traffic Issues Appendices on Health Issues Appendices on Consultation Summary Proof of Evidence on Regeneration - Mr Steve Wise Proof of Evidence on Regeneration Supplementary Proof of Evidence on Regeneration - 24 Mar 2006 Proof of Evidence on Consultation - Mr Steve Wise Appendices on Regeneration Proof of Evidence on behalf of the SMRA - Mr Terry Grant Supplementary Proof of Evidence 24 Mar 2006 Appendices SMRA National Statistical Profiles of Selected East London Boroughs Summary Proof of Evidence on Consultation - Mrs Jacqui Wise Proof of Evidence on Consultation - Mrs Tracy Hilliard New City the Size of Leeds Proof of Evidence on Consultation - Mrs Jacqueline Barter (not delivered at inquiry and regarded as written representation) Learning Body to Cut 1,300 Jobs Proof of Evidence on Consultation - Mrs Ida Brown Letter dated 9 Sept 2004 from LB Bexley re Planning Exhibition on 16 September 2004 received by Mrs Brown Letter dated 9 Sept 2004 from LB Bexley re Planning Exhibition on 16 September 2004 Letter dated 14 June Consultation Questionnaire Responses Amendments to Proofs of Evidence No document submitted Questions of Clarification re TfL/P/04/05 to TfL Note submitting additional appendices & revised 2052/1/B1 Note dated 16 Nov 2005 re deferring appearance Letter dated 14 Dec 2005 re Traffic Counts Letter dated 13 Jan 2006 to TfL re Knee Hill Copy of Fax from LB Bexley dated 14 Dec 2006 re December updates and new evidence Email from TfL dated 19 Dec 2005 re Additional Modelling Email from TfL dated 28 Dec 2005 re Additional Junction Analysis TfL Response to AGAB Information Request of 14 Nov 2005
44
2052/19 2052/20 2052/21 2052/22 2052/23 2052/24 2052/25 2052/26 2052/27 2052/28 2052/29 2052/30 2052/31 2052/32 2052/33 2052/34 2052/35 2052/36 2052/37 2052/38 2052/39 2052/40 2052/41 2052/42 2052/43 2052/44 2052/45 2052/46 2052/47 2052/48
Letter dated 27 Jan 2006 to Secretary of State for Transport re proposed Toll Order Traffic Flows on Knee Hill Response from TfL to Mrs Wises letter 23 Jan 2006 AADT Forecasts & Inter Peak Traffic Flows Note for Mrs Wise 8 Feb 2006 Briefing note to Bexley Councillors re Knee Hill Widening Response of LB Greenwich to Freedom of Information request re Knee Hill Regeneration & Sustainability Regeneration - West London & Bridges Regeneration - People & The Gateway Regeneration - Skills & Jobs Response of LB Bexley to Freedom of Information Request Borough Spending Plan 2006-07 LB Greenwich Managing Water Resources & Flood Risk in the South East Press Release 22 Dec 2005 Thames Gateway Leadership Planning application re redevelopment of former site of Bexley College, St Josephs Annex Extract, page 38 from LB Greenwich Borough Spending Plan 2006/7 Bundle of Photographs, Brampton Road, Knee Hill, Long Lane area ODPM Relationship between Transport & Development in the Thames Gateway Extract from The Londoner Sept 2005 Go Batty Extract from Gateway News February 2006 One Year On Road Casualty Figures Knee Hill Extract from News Shopper 4 April 2006 re Green Party view of TGB Green Party report to support 2052/39 TfL Response to AGAB letter 1 April 2006 re Links Email dated 18 Apr 2006 from Port of London Authority re bridge height. Letter from Bexley Labour Party dated 8 Apr 2006 re Round About Magazine Satellite Navigation/ Speed Camera Detection User Manual TGB Report of Findings Sept 2003 (TNS Travel & Tourism) Extract from Kent on Sunday 23 Apr 2006 Re New Road Bridge Extract from Tiscali Web Site re Global Warming Closing Statement 26 April 2006
London City Airport 2054/1/A1 2054/2 Proof of Evidence Mr Robert Grafton BSc Aerodrome Safeguarding Note for Conditions Session 7 Oct 2005
45
2054/3 2054/4 2054/5 2054/6 2054/7 2054/8 2054/9 2054/10
AEA Technology - Assessment of Penetrations of Obstacle Limitation Surfaces at London City Airport National Air Traffic Services Technical Report Jaybeam Study on the effects of TGB on the Non Directional Beacon at London City Airport Aerodromes - International Standards and Recommended Practices - Obstacle Restriction and Removal Airport Services Manual Part 6 Control of Obstacles 1983 Cap 168 Licensing of Aerodromes TGB Assessment of Penetrations of Obstacle Limitation Surfaces at London City Airport Note on Current Controls on Highway Lighting Aerodrome Safeguarding
Environment Agency 2057/1 Letter dated 18 Jan 2006 to TfL re Proposed Planning Conditions
Greenwich Wildlife Advisory Group 2059/1/A 2059/1/A1 2059/1/A2 2059/2 2059/3 2059/4 2059/5 2059/6 2059/7 2059/8 2059/9 2059/10 2059/11 2059/12 2059/13 2059/14 2059/15 Summary Proof of Evidence of Mr Jeremy Cotton, Chartered Biologist Proof of Evidence - Main Text Supplementary Proof 2 March 2006 Heathland Recovery Project at Bostall Heath Letter dated 16 Nov 05 from Greenwich Council re Black Poplar Trees LWT Site & Ecological Date Search Request Form PPS 9 Biodiversity & Geological Conservation ODPM Circular 06/2005 Biodiversity & Biological Conservation Development Plan Policies for Biodiversity, Mayor of London Protected Species in London. GLA, July 2005 London Biodiversity Action Plan Priority Species Terms of Reference of Greenwich Wildlife Advisory Group Address List used by Greenwich Wildlife Advisory Group Planning for Biodiversity & Geological Conservation - A Guide to Good Practice Joint Closing Statement for GWAG and Bexley Natural Environment Focus Group Completed LWT site & Ecological Date Search Form 27/03/15 Completed LWT site & Ecological Date Search Form 24/02/03 Correspondence
Simon Wolff Charitable Foundation 2065/1/A Summary Proof of Evidence on regeneration Mr George Stern MA (Cantab) MSc FRSS Barrister at Law
46
2065/1/A1 2065/1/A2 2065/1/B 2065/1/B2 2065/1/C2 2065/2/A 2065/2/B 2065/3 2065/4 2065/5 2065/6 2065/7 2065/8 2065/9 2065/10 2065/11 2065/12 2065/13 2065/14 2065/15 2065/16
Proof of Evidence George Stern - Main Text Proof of Evidence The real Cost of TGB George Stern - List of Publications Bundle of Slides Reference 2065/1/A2 Extract Pages from Statistics for Experimentalists Proof of Evidence Mrs Nina Tuckman Consideration of pressure to revive a north-south route between a new road bridge and the A2 - Report by MTRU Estimating the Uncertainty around forecasts for GDP Growth and Inflation Article from Evening Standard 30 Sep 2005, The Growing Cost of Kens Secret Army Simon Wolff Memorial Publication Paper by Mr George Stern - Sophistical Obfuscation of SelfInterest and Prejudice, 1976 Comments on TfLs Rebuttal to Case for Regeneration Vol 2 Appendix to Comments on Rebuttal Extracts from Statistical Methods for Geography Additions to Appendix to Comments on Rebuttal Email dated 23 Dec 2005 from Nina Tuckman Comments on TfL/241 TGB & Regeneration Revised extracts from 2065/12 Closing Submission Volume 1 Mr George Stern Closing Submission Volume 3 Mrs Nina Tuckman Closing Submission Volume 2 Mr George Stern
Cllr John Waters 2068/1/A1 2068/2 2068/3 Proof of Evidence Letter dated 12 Jan 2006 INQ/8 Get Back 53/1 Road Improvements at Erith Letter dated 24 Jan 2006 to Secretary of State for Transport re proposed amendments to Toll Order TfL Ref FS/10093
Greenwich Action To Stop Pollution 2069/1/A1 2069/1/A2 2069/1/B 2069/2/A1 2069/2 2069/3 2069/4 Proof of Evidence of Mr Philip Connolly on Air Quality Supplementary Evidence on Air Quality March 2006 Proof of Evidence Appendices (Poor Show) Proof of Evidence of Mr Phillip Connolly on design Bundle of Documents referred to during appearance What we have learnt from Professor Laxens cross examination Closing Submissions
Thames Water Utilities Ltd
47
2676/1/A1 2676/2/A1 2676/2/B 2676/4 2676/5
Proof of Evidence of Mr Henry Church MRICS Proof of Evidence of Mr Alan Lenander CEng MCIWEM MIPHE Appendices to Proof of Evidence of Mr Alan Lenander Letter dated 11 Nov 2005 Request to drop down the programme Letter dated 13 Apr 06 re Inquiry appearance
Mr John Austin MP 2682/1/A1 2682/2 Proof of Evidence Email dated 20 Feb 2006 re Get Back 54/1
Greenlands in Trust 2683/1/A1 Draft Outline Proof of Evidence of Mrs Anna Townend 13 Oct 2005 (not delivered at inquiry and treated as a written representation) Not used Not used Letter received 29 Mar 2006
2683/2 2683/3 2683/4
Mr Clive Efford MP 2684/1/A1 2684/2 Proof of Evidence Unemployment by Constituency Sept 2005 RP 05/64
London Thames Gateway Forum 2691/1/A 2691/1/A1 2691/1/A1/1 2691/1/A2 2691/1/A2/1 2691/1/B 2691/2 2691/3 2691/4 2691/5 2691/6 2691/7 2691/8 Summary Proof of Evidence Mr John R Elliott CEng MICE MIM FIHT Proof of Evidence John R Elliott 16 August 2005 - Main Text List of references John Elliott - Supplementary Proof of Evidence John Elliott - Summary Supplementary Proof Appendix - A Critique of TGB Assessment of Public Transport Options Apr 2004 LTGF Opening Statement The State of World Transport Economics & Social Research - Reliability - Modelling Variability when Demand Exceeds Capacity LTGF 1 Letter dated 25 March 2005 enclosing Rule 6 Statement Rule 6 Statement Final draft dated 24 March 2005 Response to Consultation on TGB by LTGF Extract from London Assembly Building Bridges Aug. 2003
48
2691/8a 2691/9 2691/10 2691/11 2691/12 2691/13 2691/14 2691/15 2691/16 2691/17 2691/18 2691/19 2691/20 2691/21 2691/22 2691/23 2691/24 2691/25 2691/26 2691/27 2691/28 2691/29 2691/30
Full Copy of Original Submission Traffic Impact of Highway Capacity Reductions, Mar 1998 LTGF Paper re possible Planning Conditions London Travel Report 2004 MOT Highway Development Survey 1937 How to Improve Journey Speeds in & to the Centres of Conurbations Making Smarter Choices Work Proof of evidence of Mr Elliott to the ELRC Inquiry Nov 1985 Greater London Development Plan Statement 1969 Letter dated 23 July 1985 Road Policy in London Dave Wetzel to Nicholas Ridley MP DfT Summary of Planned Research 2004-05 WS Atkins Thames Gateway River Crossings Oct 2000 The Blackwall Tunnel Experience 1985 Paper to TfL Board re progress on TGB, 19 November 2002 1981 traffic assigned to the 1981 A road network (Phase II) Letter dated 21 November 2005 re new evidence from TfL Letter dated 6 Dec 2005 re further costs Letter dated 21 Dec 2005 re new evidence PowerPoint Presentation DLR Horizon 2020 Study Section 4 Mayors Transport Strategy, LIP Guidance, July 2004 Further Note on Planning Conditions Written Closing Statement Review of Past Road Schemes
Bexley Federation of Residents Associations 2693/1 Proof of evidence of Mr Ray Hudson
Bexley and Greenwich Liberal Democrats 2698 2698/2 E-Mail dated 13 June 2005 Synopsis of Evidence Email dated 19 Nov 2005 from Susan Kramer MP re Evidence Correction
Greenwich & Lewisham Friends of the Earth 2704/1/A1 2704/1/A2 2704/1/A2/1 2704/2 2704/3 2704/4 2704/5 2704/6 Proof of Evidence of Mr Dominic Clarke Supplementary Proof of Evidence 7 Nov 2005 Supplementary proof of Evidence 3 Mar 2006 Extract from Transport Trends 2005 Extracts from Energy Systems & Sustainability Press Cutting, The Mercury, 5 Oct 2005 re 51 Bus Extract from TfL Website 14 Feb 2006 showing 51 Bus Route Press Cutting, The Mercury, Oct 2005, re Fares on Bus and Tube
49
2704/7
Page from Stagecoach Bus Web Site re Changes to Routes 69 & 101
London Cycling Campaign 2714/1/A 2714/1/A1 2714/1/A1/2 2714/2 2714/3 2714/4 2714/5 2714/6 2714/7 2714/8 2714/9 2714/10 Summary Proof of Evidence of Mr Richard Lewis BA Proof of Evidence - Main Text Revised Proof of Evidence - Main Text - 20 Oct 2005 London Cycle Guide London Cycling Design Standards Commuter Flows in London and the wider South East 2001 to 2016/21 Real & Perceived Travel Behaviour in Neighbourhood Shopping Areas in Bristol, Final Report Jan 2006 Shoppers & How They Travel Sustrans LN02 Travel Behaviour Research Baseline Survey 2004 Photographs from Thames Gateway Email dated 20 Mar 2006 re PLA & New Bridges downstream of Tower Bridge Closing Statement
Mr Robert Neill AM 2904/1 Email dated 3 Nov 2005 providing Outline of Evidence
Mrs Brenda Caymen 3719 Email dated 17 Oct 2005 providing Outline of Objection
Ms Janet MacKinnon MA MSc 4237/1/A 4237/1/A1 4237/1/A1/2 4237/1/A2 4237/1/B 4237/2 4237/3 4237/3B 4237/4 4237/4A 4237/5 Proof of Evidence - Conclusions Outline of Proof of Evidence (either objection or representation) 27 May 2005 Revised proof of Evidence dated 20 Oct 2005 Supplementary proof of Evidence 21 Apr 2006 (received out of time, and treated as a written representation) Addendum - Greenwich Peninsula Letter dated 10 August 2005 Outline Objection Email dated 7 July 2005 Email dated 25 July 2005 Email dated 19 July 2005 re timing of appearance and cross examination Email dated 12 September 2005 re extension of time Email dated 1 October 2005 re Venue and Ken Livingstone
50
4237/6 4237/7 4237/8 4237/9 4237/10 4237/11 4237/12
Proof of Evidence Remaining Pages The Environmental Assessment of Plans and Programmes Extract from The Times Focus Report Thames Gateway At Thames Gateway (Poem) Letter dated 20 Dec 2005 re points arising from attendance Letter dated 3 Mar 06 Re Supplementary Evidence Closing Speech 26 April 2006
Mr Matthew Scott BSc 4656 4656/1 4656/2 Letter dated 21 July 2005 Letter dated 22 Nov 2005 re New Evidence Letter dated 22 Nov 2005 re Traffic Counts
Mr Keith Buchan (Mr Buchan was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4982) 4982/1/A1 Report by MTRU on Consideration of pressure to revive a North-South route between a new road bridge and the A2, in particular through the Oxleas Wood Corridor Supplementary Proof of Evidence of Mr Keith Buchan MSc MIHT Revised Supplementary Proof of Evidence Summary of Supplementary Proof of Evidence Response to TfL Rebuttal (TfL/REB/4982-1-A2/Rev1/1) Data Extracted from Document 2703/40 Clarification of results from LASER Model Note on pre-determination of option assessment at the Inquiry by the statements of support for a multi-modal bridge in the London Plan Response to the contention that development is automatically more sustainable because it is within London Note on shorter trip lengths & reducing the need to travel Note clarifying Table 1 in MTRU 4982/2 Note on Scheme Appraisal Summary Table as amended Dec 2005 from TfL/P/04/8 Written Closing Submission (accepted as a written representation, since Mr Buchan was a witness rather than a party to the inquiry)
4982/1/A2 4982/1/A2 R1 4982/1/A2/2 4982/2 4982/3 4982/4 4982/5
4982/6 4982/7 4982/8 4982/9 4982/10
Professor John Whitelegg (Professor Whitelegg was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4983) 4983/1/A Summary of Supplementary Proof of Evidence of Professor Whitelegg, Feb 2006
51
4983/1/A1 4983/1/A2 4983/2 4983/3 4983/4 4983/5 4983/6
Case for the objectors on Regeneration, Riki Therivel & John Whitelegg, Aug 2005 Supplementary Proof of Evidence, Feb 2006 Response to Question from Mr George INQ/8 28/1 Report by the National Audit Office: Road Planning Oct 1988 Inaccuracy in Traffic Forecasts. Flyvbjerg, Holm & Buhl, 5 April 2005 Article by Professor Flyvbjerg Misrepresentation Drives Projects Jan 2004 Extract from Book Megaprojects & Risk: An Anatomy of Ambition by Professor Flyvbjerg and Others
Professor Caralampo Focas (Professor Focas was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4984) 4984/1/A Summary of Report on Consultation regarding the Thames Gateway Bridge by Professor Kerry Hamilton and Professor Focas A reasoned Documented Critique of the Thames Gateway Bridge Consultation Report by Professor Hamilton and Professor Focas, Summer 2005 Revised Summary Report Consultation Resources - the Approach of the Mayor of London Report to the London Transport Users Committee regarding the calling in of the TGB planning applications Apr 2005
4984/1/A1
4984/1/A1/1 4984/1/B1 4984/1/B2
Professor Phil Goodwin (Professor Goodwin was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4985) 4985/1/A1/2 4985/1/A2 4985/1/B 4985/2 4985/3 Witness Statement by Professor Goodwin Revision B Supplementary Proof of Evidence 14 Feb 2006 Addendum to Supplementary Proof of Evidence 24 Feb 2006 How to Reconcile the Traffic & Regeneration Proposals Inconsistencies between Assessment of Traffic & Regeneration Benefits
Professor Mark McCarthy (Professor McCarthy was called as a witness to give evidence on behalf of an alliance of objectors, but submitted documents to the inquiry under his own Document number, 4986) 4986/1/A1 Professor Mark McCarthy MA PhD Health Impact Review
52
Mr Philip Connolly (As well as appearing for GASP, Mr Connolly was called as a witness to give evidence on behalf of an alliance of objectors, and in that role submitted documents to the inquiry under his own Document number, 4987) 4987/1/A1 4987/2/A1/2 4987/3 4987/4 4987/5 4987/5A 4987/6 4987/7 4987/8 4987/9 4987/10 4987/11 Proof of Evidence Air Quality Revised Proof of Evidence - Phillip Connolly Set of Documents as referenced in Proof of Evidence Extract from Transport for a Sustainable Future John Whitelegg Extract from LBG Air Quality Action Plan Full Copy of LBG Draft Air Quality Action Plan Extract from Bowling Alone by Robert D Putnam page 26 The Air Quality Limit Values (Amendment) Regulations 2002 Extract from LB Redbridge UDP, Nov 2003 Extract from Making a Difference in Redbridge - LB Redbridge Community Strategy Action Plan, Oct 2004 LB Redbridge Local Implementation Plan 2005/06 - 2010/11 Consultation Draft, May 2005 LB Redbridge Local Implementation Plan 2005/06 - 2010/11 Strategic Environmental Assessment, May 2005
Ms Jo Thomson 4996/1 4996/2 4996/3 4996/4 Note to TGB Inquiry dated 17 Oct 2005 Letter dated 31 Mar 2006 regarding Document 4996/1 Letter dated 19 Apr 06 re lack of TfL response Summary of Note 4996/1
Mr Michael Winship 4998/1 Statement made by Mr Michael Winship
Mrs Joyce Weston 4999 5000
Statement made by Mrs Weston
Mr Roger Butler 5010/1 Proof of Evidence of Mr Roger Butler
Mr Robert Watson 5012/1 Proof of Evidence of Mr Robert Watson
53
5012/2 5012/3
Extract from East Londoner - Mar 2006 Covering letter from the Mayor of London sent to recipients of the East Londoner
Mr Gordon Winbourne RIBA 5014/1 Bundle of Documents re River Tram Transit Initiatives Limited
54
APPPENDIX C THAMES GATEWAY BRIDGE RECOMMENDED PLANNING CONDITIONS ON MAIN BRIDGE APPLICATION NORTH OF THE RIVER P/04/1170 1. In these Conditions, the relevant Local Planning Authority means: a. the London Thames Gateway Development Corporation where the relevant statutory functions of the local planning authority are exercisable by the London Thames Gateway Development Corporation; or b. the London Borough of Newham. 2. The planning permission applies to the following drawings: TBTGRC/P2/HIG/001 Rev1 TBTGRC/P2/HIG/032 Rev1 TBTGRC/P2/HIG/033 Rev1 TBTGRC/P2/HIG/034 Rev5 TBTGRC/P2/HIG/040 Rev0 TBTGRC/P2/HIG/050 Rev0 TBTGRC/P2/HIG/051 Rev0 TBTGRC/P2/HIG/052 Rev0 TBTGRC/P2/HIG/053 Rev0 TBTGRC/P2/HIG/071 Rev0 TBTGRC/P2/HIG/072 Rev0 TBTGRC/P2/HIG/080 Rev0 TBTGRC/P2/HIG/090 Rev2 TBTGRC/P2/HIG/091 Rev0 TBTGRC/P2/HIG/092 Rev0 TBTGRC/P2/HIG/093 Rev1 TBTGRC/P2/HIG/094 Rev1 TBTGRC/P1/TGB/005 Rev4 TBTGRC/P1/TGB/006 Rev3 TBTGRC/P2/TGB/323 Rev5 TBTGRC/P2/TGB/324 Rev1 All other drawings submitted with the application are illustrative. 3. An application for the approval of matters pursuant to Condition 9 shall be made to the relevant Local Planning Authority before the expiration of 5 years from the date of this permission, and the development hereby authorised must be begun not later than whichever is the later of the following dates, failing which the permission shall be of no effect:
a. b.
The expiration of 7 years from the date of this permission: or The expiration of 5 years from the final date of approval of matters pursuant to Condition 9.
4.
Drawings, plans and other documents, other than those approved by this planning permission, that have been approved by the relevant Local Planning Authority may be revised, subject to the same approval procedure as was required for the original drawing, plan or document. Where under any Condition set out below the approval, agreement or consent of the relevant Local Planning Authority is required, that approval, agreement or consent shall be given in writing. The works thereby approved shall be carried out in accordance with that approval unless subsequently otherwise approved in writing by that Local Planning Authority.
5.
6.
The development means the development authorised by the planning permission to which these Conditions apply. The Environmental Statement in these Conditions means the Environmental Statement July 2004, Addendum March 2005, Addendum 2 September 2005 and Addendum 3 December 2005. The Design Statement in these Conditions means volume 2 of the Appendices to the Environmental Statement July 2004 (updated March 2005, September 2005 and April 2006). The Landscape and Urban Design Strategy in these Conditions means volume 3 of the Appendices to the Environmental Statement July 2004 and Addendum September 2005.
7.
8.
The design of the works shall be in accordance with the parameters set out in the Design Statement. Construction of: a. The main bridge and approach viaducts; b. Other proposed bridges; c. Pumping stations; and d. Operation and Maintenance compound and offices shall not be started until detailed drawings showing plans, sections and elevations of the relevant building or structure have been submitted to and approved by the relevant Local Planning Authority. All construction shall be carried out in accordance with the parameters set out in the Design Statement and the approved drawings.
9.
10.
The drawings submitted for approval pursuant to Condition 9 shall show: a. the design and external appearance of Street lighting and feature lighting; Bridge parapets, safety barriers and any wind barriers; Noise barriers and road surface; Signage, gantries and other highway furniture; Bus service infrastructure including bus stops and bus lanes,
and: b. c. d. The form, scale and proportion of structures and buildings; The location and form of piers and abutments to all bridges; Colour, materials and finishes.
The drawings submitted for approval under Condition 9 shall be accompanied by reports setting out: i. ii. 11. how the parameters of the Design Statement have been met; the design quality findings of the Design Panel. The facing materials or finishes to be used on the bridge, approach viaducts and other structures and all other finishing materials including paving, roads, parking areas and means of enclosure shall be in accordance with the design principles set out in the Design Statement. Details of the facing materials or finishes to be used on the bridge, approach viaducts and other structures and all other finishing materials including paving, roads, parking areas and means of enclosure shall be submitted to and approved by the relevant Local Planning Authority prior to the start of construction of the relevant parts of the works. Before commencement of the development, full details of all proposed pedestrian and cycle routes, links and associated furniture and crossings within the site shall be submitted to and approved by the relevant Local Planning Authority. The details shall include specific measures to aid access to the bridge by pedestrians with mobility or visual impairment. Details of the proposed lifts shall be submitted to and approved by the relevant Local Planning Authority. Such details shall include the location and design of the lifts, and the measures to ensure that the lifts accommodate people with mobility or visual impairment and cyclists.
12.
13.
14.
15.
One lift on either side of the river to provide pedestrian access to the bridge shall be provided prior to the use of the bridge by the public, unless otherwise agreed by the relevant Local Planning Authority. The lifts shall accommodate people with mobility or visual impairment and cyclists, and shall be in accordance with the details approved pursuant to Condition 14. Details of arrangements for a CCTV system or equivalent, to monitor the pedestrian and cycle lanes on the bridge, its approaches, the lifts and the entrance to each lift, shall be submitted to and approved by the relevant Local Planning Authority before the bridge comes into use. Notwithstanding the drawings and other material submitted with the application: a) the height of the carriageway, the bridge deck and parapets of the permanent bridge structure and any other part of the development shall not infringe the obstacle limitation surfaces at London City Airport being the Safeguarded and Obstacle Limitations Surfaces London City Airport, Aerodrome Standards Department Safety Regulations Group, Civil Aviation Authority: August 2004 and as shown on drawing numbers TBTGRC/P2/TGB/005 revision 4 and 006 revision 3; b) the lighting columns, signage gantries, plant, aerials, antennae, any overhead line equipment, street furniture or any other structures which are to be attached to the permanent bridge structure shall not be constructed higher than is shown on the drawing number TBTGRC/P2/TGB/323 revision 5.
16.
17.
18.
Notwithstanding the drawings and other material submitted with the application, the details to be submitted for approval of the siting, design and external appearance of the building(s) and structures (including plant, lighting columns, aerials, antennae and any overhead line equipment), including the choice of materials and any temporary structures, as required by condition, shall be accompanied by a technical assessment of any potential effects of the development including potential cumulative effects upon radio and/or electromagnetic signals, navigational and communications aids at London City Airport. The development shall not be commenced until approval of the assessment has been received from the relevant Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority.
19.
Before the commencement of development, details of all external lighting and/or flood lighting, including any external illuminated
signage, shall be submitted to and approved by the relevant Local Planning Authority: a. in consultation with the operator of London City Airport and the Civil Aviation Authority and; b. in relation to lighting in, over or immediately adjacent to the River Thames in consultation with the Port of London Authority. Such lighting will not be permitted where its design or intended use is likely to distract or mislead any pilots of aircraft operating at London City Airport or any persons navigating vessels on the River Thames. Such lighting may only be installed in accordance with the approval details. Except for general upkeep and like for like replacement, the lighting shall not thereafter be altered or added to in any way without the prior approval of the relevant Local Planning Authority: a. in consultation with the operator of London City Airport and the Civil Aviation and; b. in relation to lighting in, over or immediately adjacent to the River Thames in consultation with the Port of London Authority. 20. The design and specification of the landscaping shall be in accordance with the Landscape and Urban Design Strategy and the Design Statement. Any trees, shrubs, plants or other vegetation to be planted or grown shall as far as practicable be selected from species and planted and grown in such a manner as to adhere to guidance in CAP (Civil Aviation Publication) 680. Full details of the landscaping of all areas of the application site, including hard and soft landscaping and screening, water features and means of enclosure, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority before any landscaping works are commenced on any part of the application site. The landscaping scheme shall be completed within one year of completion of the works. 22. The details of landscaping, submitted pursuant to Condition 21 shall include details of public art provision within the application site. Before the commencement of development details of the methods of construction, including details of the use, location and height of cranes and other plant and equipment or temporary structures, shall be submitted to, and approved by the relevant Local Planning Authority in consultation with the operator of London City Airport
21.
23.
and the Civil Aviation Authority. During the normal operating hours of London City Airport such temporary works shall be constructed within the height constraints shown on drawing no. TBTGRC/P2/TGB/324 revision 1 unless otherwise agreed by London City Airport. Outside the normal operating hours of London City Airport, works which exceed the height constraints shown on drawing no. TBTGRC/P2/TGB/324 revision 1 shall be undertaken in accordance with a method statement submitted to and approved by London City Airport, and all works, cranes, plant equipment and other temporary structures which exceed such height constraints shall be removed in accordance with the approved method statement. 24. Details of how the River Thames will be used to optimise the delivery of construction materials and the removal of construction waste are to be provided to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority and the Environment Agency before development commences. No construction work shall be started to the bridge piers in the River Thames or any alterations to the river banks before details of local hydraulic impacts have been submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency and Port of London Authority. Designs approved under Condition 9 shall include appropriate measures to mitigate impacts of the proposed works on the flood defences and the foreshore ecology. 26. Before the development commences details of any proposed changes or modifications to the existing flood defences within the site shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency and riparian owners. Any flood defences, which remain in the ownership of TfL, shall be maintained in accordance with procedures developed in consultation with the Environment Agency. 27. For all works in or beside watercourses, a method statement and an assessment of the effects of the working method and any associated temporary works shall be submitted to and approved by the relevant Local Planning Authority, in consultation with the Port of London Authority and the Environment Agency, before the works start. The assessment shall include details of the local hydraulic impacts and consider the effects of vessel movements relating to the works.
25.
The method statement shall include proposals for working methods and temporary works in or beside watercourses designed to minimise and mitigate the impact on both the flood defences and the foreshore. 28. Before the start of construction of any drainage system, full details of the system for the disposal and attenuation of surface water runoff from the site together with a maintenance and monitoring programme shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency. Before the start of any drainage works, details of the design, location, number of outfalls and assessment of the effects of discharges from proposed outfalls into the River Thames shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority and the Environment Agency. Such design shall seek to minimise the impact on both flood defences and foreshore ecology, and impacts shall be mitigated. 30. Before development commences, a statement of the method of working for disposal, drainage or dewatering of contaminated surface or ground water, including provision of alternative disposal routes where contamination levels are unacceptable, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency. Details of all piling to be undertaken shall be submitted to and approved by the relevant Local Planning Authority: a. in consultation with the Environment Agency, and b. in relation to all piling in the River Thames, in consultation with the Port of London Authority before development commences. 32. Details of all proposed temporary work sites, including means of access, and the location of all temporary buildings, batching plants, car parks, stockpiles of excavated and imported materials, and means of enclosure shall be submitted to and approved by the relevant Local Planning Authority before development commences. No temporary housing, including caravans, shall be provided or located on the site without the prior approval of the relevant Local Planning Authority.
29.
31.
33.
34.
Details of visual and/or noise screening to riverside working compounds shall be submitted to and approved by the relevant Local Planning Authority in consultation with the relevant statutory consultees before development commences. Before the works commence, a desktop study, and site investigation if indicated as necessary by the desktop study, appropriate to the proposed works, shall be carried out within the land affected by the works, in order to determine groundwater characteristics and assess any risk arising from the presence of contaminants causing or likely to cause significant harm to persons, pollution of controlled waters or significant harm to the environment. A land assessment report shall be prepared by a recognised consultant acceptable to the relevant Local Planning Authority, which shall identify any necessary remediation measures to render the land fit for the intended purpose, and any long term measures that are necessary with respect to contaminants remaining on site shall be set out in a management plan. The land assessment report and management plan, which shall include measures for monitoring the effectiveness and integrity of any remediation measures, shall be prepared in accordance with the principles set out in the code of construction practice, or other such principles as may be subsequently agreed with the relevant Local Planning Authority. Both the land assessment report and the management plan shall be submitted to and approved by the relevant Local Planning Authority before the works commence; and any remediation measures approved by the relevant Local Planning Authority shall be implemented within such period as the local planning authority may agree. In the event of the land assessment report, the management plan, or both disclosing any lack of effectiveness, integrity, or both, the relevant Local Planning Authority shall be notified of the same forthwith, and all works necessary to rectify the same shall be carried out forthwith.
35.
36.
On completion of the remediation measures undertaken pursuant to Condition 35, a validation report detailing all works carried out shall be submitted to the relevant Local Planning Authority within 6 months and approved by them. Unless otherwise agreed by the relevant Local Planning Authority, normal working hours for construction activities shall be:
37.
Monday Friday Saturday Sundays, Public and Bank Holidays
0800 to 1830 0800 to 1300 No work
Subject to the prior agreement of the relevant Local Planning Authority, working outside these hours will normally be permitted for: a. work requiring road or rail closures b. continuous operations lasting more than 12 hours c. work constrained by river conditions. (This includes both construction activities and the loading and off-loading of materials transported by river transport.) d. work that would otherwise affect the operation of the London City Airport or the statutory undertaking of the Port of London Authority. e. movement of abnormal loads or other specified construction activities agreed with the relevant Local Planning Authority. The Local Planning Authority shall consult with the Port of London Authority in respect of items c. and d. above and with London City Airport in respect of item d. above. In an emergency, work may be carried out outside the normal working hours. Should this be necessary, the Contractor shall immediately notify the relevant Local Planning Authority and prepare a report, detailing what work was done and why it was treated as emergency work, and submit it to the relevant Local Planning Authority before the end of the second working day following the completion of the emergency work. 38. The proposed method, frequency and location of vibration, noise and dust monitoring during the construction period shall be submitted to the relevant Local Planning Authority for agreement, and acceptable levels of dust, vibration and noise shall be agreed with the Local Planning Authority in consultation with the Environment Agency before the start of demolition or construction. The levels of vibration, noise and dust shall be monitored in the agreed manner pursuant to Condition 38 during construction using an objective method of measurement at each site. Best practicable means shall be used at all times to ensure that the levels of dust, vibration and noise remain within the agreed levels. 40. No soils or filling materials are to be imported on to the site until they have been satisfactorily proven to be suitable for use and to protect human health, planting or the environment. A declaration
39.
to this effect, together with acceptable documentary evidence to confirm the origin of any imported soils and infill materials, supported by appropriate chemical analysis test results and risk assessment, must be submitted to and be approved by the relevant Local Planning Authority prior to transfer to the site. 41. No vehicle shall leave the site with earth, mud etc, adhering to the wheels in a quantity which may result in its being deposited on the public highway or footpath, and creating nuisance or hazard to vehicles or pedestrians. Effective wheel cleaning equipment to avoid such problems shall be installed, operated and maintained on the site until the completion of the works. An ecological management plan, including proposals for mitigation measures, replacement habitats, biodiversity, long term objectives, management responsibilities and maintenance schedules, covering both aquatic and terrestrial habitats, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority and the Environment Agency before the commencement of the development. The parameters of the plan shall reflect the principles and guidelines set out in the Environment Statement. 43. Before development commences a Construction Environmental Management Manual (CEMM) shall be submitted to and approved by the relevant Planning Authority, in consultation with the Environment Agency. Prior to the commencement of construction a detailed Code of Construction Practice shall be submitted to and approved by the relevant Local Planning Authority. No development shall take place until a programme of archaeological work has been submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority. The programme shall accord with good practice as set out in Section 12 of the Environmental Statement. Full details of ecological enhancement measures and protection of wildlife habitats, including appropriate planting of native species, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority, the Greater London Authority Biodiversity Team, English Nature and the Environment Agency prior to the start of relevant parts of the works. The measures shall be in accordance with the Environmental Statement and in particular Chapter II (Ecology and
42.
44.
45.
46.
10
Nature Conservation) and the landscape principles and guidelines set out in the Landscape and Urban Design Strategy. 47. A method for reducing the impacts on fish, teal and other waterfowl from disturbance, noise and vibration impacts shall be submitted to and approved by the relevant Local Planning Authority, in consultation with the Port of London Authority and the Environment Agency, before work starts. No development shall commence until a programme for monitoring and review of ecological management has been submitted to and approved by the relevant Local Planning Authority, in consultation with the Port of London Authority and the Environment Agency. The monitoring programme shall be established to monitor the impact on ecology throughout the construction of the bridge and associated works, and in particular: a) the effects of water quality on in-stream flora and fauna, including impacts of both chemical and diffuse pollution (for example from mobilisation and/or silt deposition), and b) the introduction and re-distribution of alien species (direct or indirect). The purpose of the programme shall be to verify the successful translocation of flora and fauna and the success of habitat and species enhancement, habitat creation, and mitigation and/or compensation measures. 49. Before development commences, details of a monitoring scheme to measure the impact of construction disturbance on fish, teal and other waterfowl are to be submitted to and approved by the relevant Local Planning Authority. Before any work is carried out within 5 metres of non-main watercourses or water bodies, details of ecological and engineering mitigation works shall be submitted to and agreed with the relevant Local Planning Authority, in consultation with the Environment Agency. Planting within river corridors should comprise locally native species only, unless otherwise agreed. Before planting commences, details of such planting shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority. 52. All existing trees on the site that are not directly affected by the proposed works shall be retained and shall not be lopped or topped
48.
50.
51.
11
without the prior approval of the relevant Local Planning Authority. Any such approved tree works shall be undertaken outside the bird nesting season (1 March to 31 August inclusive), and the trees affected shall be inspected for bats. If any trees die during, or are removed as a result of, construction, replacement trees shall be planted to the satisfaction of the relevant Local Planning Authority, within 9 months of completion of the works. 53. Any trees or shrubs that die within a period of 5 years from the date of planting, are removed, or become seriously damaged or diseased, shall be replaced in the next planting season with others of a similar size and species, unless the relevant Local Planning Authority gives consent to any variation.
12
APPENDIX D THAMES GATEWAY BRIDGE RECOMMENDED PLANNING CONDITIONS ON MAIN BRIDGE APPLICATION SOUTH OF THE RIVER 04/1800/F 1. In these Conditions, the relevant Local Planning Authority means the London Borough of Greenwich. The planning permission applies to the following drawings: TBTGRC/P2/HIG/002 Rev1 TBTGRC/P2/HIG/032 Rev1 TBTGRC/P2/HIG/034 Rev5 TBTGRC/P2/HIG/035 Rev3 TBTGRC/P2/HIG/036 Rev1 TBTGRC/P2/HIG/040 Rev0 TBTGRC/P2/HIG/054 Rev0 TBTGRC/P2/HIG/055 Rev0 TBTGRC/P2/HIG/056 Rev1 TBTGRC/P2/HIG/072 Rev0 TBTGRC/P2/HIG/073 Rev1 TBTGRC/P2/HIG/090 Rev2 TBTGRC/P2/HIG/094 Rev1 TBTGRC/P2/HIG/095 Rev2 TBTGRC/P2/HIG/096 Rev2 TBTGRC/P1/TGB/005 Rev4 TBTGRC/P1/TGB/006 Rev3 TBTGRC/P2/TGB/323 Rev5 TBTGRC/P2/TGB/324 Rev1 All other drawings submitted with the application are illustrative. 3. An application for the approval of matters pursuant to Condition 9 shall be made to the relevant Local Planning Authority before the expiration of 5 years from the date of this permission, and the development hereby authorised must be begun not later than whichever is the later of the following dates, failing which the permission shall be of no effect: a. b. The expiration of 7 years from the date of this permission: or The expiration of 5 years from the final date of approval of matters pursuant to Condition 9.
2.
4.
Drawings, plans and other documents, other than those approved by this planning permission, that have been approved by the relevant
Local Planning Authority may be revised, subject to the same approval procedure as was required for the original drawing, plan or document. 5. Where under any Condition set out below the approval, agreement or consent of the relevant Local Planning Authority is required, that approval, agreement or consent shall be given in writing. The works thereby approved shall be carried out in accordance with that approval unless subsequently otherwise approved in writing by that Local Planning Authority. 6. The development means the development authorised by the planning permission to which these Conditions apply. The Environmental Statement in these Conditions means the Environmental Statement July 2004, Addendum March 2005, Addendum 2 September 2005 and Addendum 3 December 2005. The Design Statement in these Conditions means volume 2 of the Appendices to the Environmental Statement July 2004 (updated March 2005, September 2005 and April 2006). The Landscape and Urban Design Strategy in these Conditions means volume 3 of the Appendices to the Environmental Statement July 2004 and Addendum September 2005. 8. The design of the works shall be in accordance with the parameters set out in the Design Statement. Construction of: a. The main bridge and approach viaducts; b. Other proposed bridges; c. Pumping stations; and d. Operation and Maintenance compound and offices shall not be started until detailed drawings showing plans, sections and elevations of the relevant building or structure have been submitted to and approved by the relevant Local Planning Authority. All construction shall be carried out in accordance with the parameters set out in the Design Statement and the approved drawings. 10. The drawings submitted for approval pursuant to Condition 9 shall show: a. the design and external appearance of Street lighting and feature lighting; Bridge parapets, safety barriers and any wind barriers; Noise barriers and road surface;
7.
9.
Signage, gantries and other highway furniture; Bus service infrastructure including bus stops and bus lanes, and: b. c. d. The form, scale and proportion of structures and buildings; The location and form of piers and abutments to all bridges; Colour, materials and finishes.
The drawings submitted for approval under Condition 9 shall be accompanied by reports setting out: i. ii. 11. how the parameters of the Design Statement have been met; the design quality findings of the Design Panel. The facing materials or finishes to be used on the bridge, approach viaducts and other structures and all other finishing materials including paving, roads, parking areas and means of enclosure shall be in accordance with the design principles set out in the Design Statement. Details of the facing materials or finishes to be used on the bridge, approach viaducts and other structures and all other finishing materials including paving, roads, parking areas and means of enclosure shall be submitted to and approved by the relevant Local Planning Authority prior to the start of construction of the relevant parts of the works. Before commencement of the development, full details of all proposed pedestrian and cycle routes, links and associated furniture and crossings within the site shall be submitted to and approved by the relevant Local Planning Authority. The details shall include specific measures to aid access to the bridge by pedestrians with mobility or visual impairment. Details of the proposed lifts shall be submitted to and approved by the relevant Local Planning Authority. Such details shall include the location and design of the lifts, and the measures to ensure that the lifts accommodate people with mobility or visual impairment and cyclists. One lift on either side of the river to provide pedestrian access to the bridge shall be provided prior to the use of the bridge by the public, unless otherwise agreed by the relevant Local Planning Authority. The lifts shall accommodate people with mobility or visual impairment and cyclists, and shall be in accordance with the details approved pursuant to Condition 14.
12.
13.
14.
15.
16.
Details of arrangements for a CCTV system or equivalent, to monitor the pedestrian and cycle lanes on the bridge, its approaches, the lifts and the entrance to each lift, shall be submitted to and approved by the relevant Local Planning Authority before the bridge comes into use. Notwithstanding the drawings and other material submitted with the application: a) the height of the carriageway, the bridge deck and parapets of the permanent bridge structure and any other part of the development shall not infringe the obstacle limitation surfaces at London City Airport being the Safeguarded and Obstacle Limitations Surfaces London City Airport, Aerodrome Standards Department Safety Regulations Group, Civil Aviation Authority: August 2004 and as shown on drawing numbers TBTGRC/P2/TGB/005 revision 4 and 006 revision 3; b) the lighting columns, signage gantries, plant, aerials, antennae, any overhead line equipment, street furniture or any other structures which are to be attached to the permanent bridge structure shall not be constructed higher than is shown on the drawing number TBTGRC/P2/TGB/323 revision 5.
17.
18.
Notwithstanding the drawings and other material submitted with the application, the details to be submitted for approval of the siting, design and external appearance of the building(s) and structures (including plant, lighting columns, aerials, antennae and any overhead line equipment), including the choice of materials and any temporary structures, as required by condition, shall be accompanied by a technical assessment of any potential effects of the development including potential cumulative effects upon radio and/or electromagnetic signals, navigational and communications aids at London City Airport. The development shall not be commenced until approval of the assessment has been received from the relevant Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority.
19.
Before the commencement of development, details of all external lighting and/or flood lighting, including any external illuminated signage, shall be submitted to and approved by the relevant Local Planning Authority: a. in consultation with the operator of London City Airport and the Civil Aviation Authority and;
b. in relation to lighting in, over or immediately adjacent to the River Thames in consultation with the Port of London Authority. Such lighting will not be permitted where its design or intended use is likely to distract or mislead any pilots of aircraft operating at London City Airport or any persons navigating vessels on the River Thames. Such lighting may only be installed in accordance with the approval details. Except for general upkeep and like for like replacement, the lighting shall not thereafter be altered or added to in any way without the prior approval of the relevant Local Planning Authority: a. in consultation with the operator of London City Airport and the Civil Aviation and; b. in relation to lighting in, over or immediately adjacent to the River Thames in consultation with the Port of London Authority. 20. The design and specification of the landscaping shall be in accordance with the Landscape and Urban Design Strategy and the Design Statement. Any trees, shrubs, plants or other vegetation to be planted or grown shall as far as practicable be selected from species and planted and grown in such a manner as to adhere to guidance in CAP (Civil Aviation Publication) 680. Full details of the landscaping of all areas of the application site, including hard and soft landscaping and screening, water features and means of enclosure, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority before any landscaping works are commenced on any part of the application site. The landscaping scheme shall be completed within one year of completion of the works. 22. The details of landscaping, submitted pursuant to Condition 21 shall include details of public art provision within the application site. Before the commencement of development details of the methods of construction, including details of the use, location and height of cranes and other plant and equipment or temporary structures, shall be submitted to, and approved by the relevant Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority. During the normal operating hours of London City Airport such temporary works shall be constructed within the height constraints shown on drawing no. TBTGRC/P2/TGB/324 revision 1 unless otherwise agreed by London City Airport.
21.
23.
Outside the normal operating hours of London City Airport, works which exceed the height constraints shown on drawing no. TBTGRC/P2/TGB/324 revision 1 shall be undertaken in accordance with a method statement submitted to and approved by London City Airport, and all works, cranes, plant equipment and other temporary structures which exceed such height constraints shall be removed in accordance with the approved method statement. 24. Details of how the River Thames will be used to optimise the delivery of construction materials and the removal of construction waste are to be provided to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority and the Environment Agency before development commences. No construction work shall be started to the bridge piers in the River Thames or any alterations to the river banks before details of local hydraulic impacts have been submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency and Port of London Authority. Designs approved under Condition 9 shall include appropriate measures to mitigate impacts of the proposed works on the flood defences and the foreshore ecology. 26. Before the development commences details of any proposed changes or modifications to the existing flood defences within the site shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency and riparian owners. Any flood defences, which remain in the ownership of TfL, shall be maintained in accordance with procedures developed in consultation with the Environment Agency. 27. For all works in or beside watercourses, a method statement and an assessment of the effects of the working method and any associated temporary works shall be submitted to and approved by the relevant Local Planning Authority, in consultation with the Port of London Authority and the Environment Agency, before the works start. The assessment shall include details of the local hydraulic impacts and consider the effects of vessel movements relating to the works. The method statement shall include proposals for working methods and temporary works in or beside watercourses designed to minimise and mitigate the impact on both the flood defences and the foreshore.
25.
28.
Before the start of construction of any drainage system, full details of the system for the disposal and attenuation of surface water runoff from the site together with a maintenance and monitoring programme shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency. Before the start of any drainage works, details of the design, location, number of outfalls and assessment of the effects of discharges from proposed outfalls into the River Thames shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority and the Environment Agency. Such design shall seek to minimise the impact on both flood defences and foreshore ecology, and impacts shall be mitigated.
29.
30.
Before development commences, a statement of the method of working for disposal, drainage or dewatering of contaminated surface or ground water, including provision of alternative disposal routes where contamination levels are unacceptable, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Environment Agency. Details of all piling to be undertaken shall be submitted to and approved by the relevant Local Planning Authority: a. in consultation with the Environment Agency, and b. in relation to all piling in the River Thames, in consultation with the Port of London Authority before development commences.
31.
32.
Details of all proposed temporary work sites, including means of access, and the location of all temporary buildings, batching plants, car parks, stockpiles of excavated and imported materials, and means of enclosure shall be submitted to and approved by the relevant Local Planning Authority before development commences. No temporary housing, including caravans, shall be provided or located on the site without the prior approval of the relevant Local Planning Authority. Details of visual and/or noise screening to riverside working compounds shall be submitted to and approved by the relevant Local Planning Authority in consultation with the relevant statutory consultees before development commences.
33.
34.
35.
Before the works commence, a desktop study, and site investigation if indicated as necessary by the desktop study, appropriate to the proposed works, shall be carried out within the land affected by the works, in order to determine groundwater characteristics and assess any risk arising from the presence of contaminants causing or likely to cause significant harm to persons, pollution of controlled waters or significant harm to the environment. A land assessment report shall be prepared by a recognised consultant acceptable to the relevant Local Planning Authority, which shall identify any necessary remediation measures to render the land fit for the intended purpose, and any long term measures that are necessary with respect to contaminants remaining on site shall be set out in a management plan. The land assessment report and management plan, which shall include measures for monitoring the effectiveness and integrity of any remediation measures, shall be prepared in accordance with the principles set out in the code of construction practice, or other such principles as may be subsequently agreed with the relevant Local Planning Authority. Both the land assessment report and the management plan shall be submitted to and approved by the relevant Local Planning Authority before the works commence; and any remediation measures approved by the relevant Local Planning Authority shall be implemented within such period as the local planning authority may agree. In the event of the land assessment report, the management plan, or both disclosing any lack of effectiveness, integrity, or both, the relevant Local Planning Authority shall be notified of the same forthwith, and all works necessary to rectify the same shall be carried out forthwith.
36.
On completion of the remediation measures undertaken pursuant to Condition 35, a validation report detailing all works carried out shall be submitted to the relevant Local Planning Authority within 6 months and approved by them. Unless otherwise agreed by the relevant Local Planning Authority, normal working hours for construction activities shall be: Monday Friday Saturday Sundays, Public and Bank Holidays 0800 to 1830 0800 to 1300 No work
37.
Subject to the prior agreement of the relevant Local Planning Authority, working outside these hours will normally be permitted for: a. work requiring road or rail closures b. continuous operations lasting more than 12 hours c. work constrained by river conditions. (This includes both construction activities and the loading and off-loading of materials transported by river transport.) d. work that would otherwise affect the operation of the London City Airport or the statutory undertaking of the Port of London Authority. e. movement of abnormal loads or other specified construction activities agreed with the relevant Local Planning Authority. The Local Planning Authority shall consult with the Port of London Authority in respect of items c. and d. above and with London City Airport in respect of item d. above. In an emergency, work may be carried out outside the normal working hours. Should this be necessary, the Contractor shall immediately notify the relevant Local Planning Authority and prepare a report, detailing what work was done and why it was treated as emergency work, and submit it to the relevant Local Planning Authority before the end of the second working day following the completion of the emergency work. 38. The proposed method, frequency and location of vibration, noise and dust monitoring during the construction period shall be submitted to the relevant Local Planning Authority for agreement, and acceptable levels of dust, vibration and noise shall be agreed with the Local Planning Authority in consultation with the Environment Agency before the start of demolition or construction. The levels of vibration, noise and dust shall be monitored in the agreed manner pursuant to Condition 38 during construction using an objective method of measurement at each site. Best practicable means shall be used at all times to ensure that the levels of dust, vibration and noise remain within the agreed levels. 40. No soils or filling materials are to be imported on to the site until they have been satisfactorily proven to be suitable for use and to protect human health, planting or the environment. A declaration to this effect, together with acceptable documentary evidence to confirm the origin of any imported soils and infill materials, supported by appropriate chemical analysis test results and risk
39.
assessment, must be submitted to and be approved by the relevant Local Planning Authority prior to transfer to the site. 41. No vehicle shall leave the site with earth, mud etc, adhering to the wheels in a quantity which may result in its being deposited on the public highway or footpath, and creating nuisance or hazard to vehicles or pedestrians. Effective wheel cleaning equipment to avoid such problems shall be installed, operated and maintained on the site until the completion of the works. An ecological management plan, including proposals for mitigation measures, replacement habitats, biodiversity, long term objectives, management responsibilities and maintenance schedules, covering both aquatic and terrestrial habitats, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority and the Environment Agency before the commencement of the development. The parameters of the plan shall reflect the principles and guidelines set out in the Environment Statement. 43. Before development commences a Construction Environmental Management Manual shall be submitted to and approved by the relevant Planning Authority, in consultation with the Environment Agency. Prior to the commencement of construction a detailed Code of Construction Practice shall be submitted to and approved by the relevant Local Planning Authority. No development shall take place until a programme of archaeological work has been submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority. The programme shall accord with good practice as set out in Section 12 of the Environmental Statement. Full details of ecological enhancement measures and protection of wildlife habitats, including appropriate planting of native species, shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority, the Greater London Authority Biodiversity Team, English Nature and the Environment Agency prior to the start of relevant parts of the works. The measures shall be in accordance with the Environmental Statement and in particular Chapter II (Ecology and Nature Conservation) and the landscape principles and guidelines set out in the Landscape and Urban Design Strategy.
42.
44.
45.
46.
10
47.
A method for reducing the impacts on fish, teal and other waterfowl from disturbance, noise and vibration impacts shall be submitted to and approved by the relevant Local Planning Authority, in consultation with the Port of London Authority and the Environment Agency, before work starts. No development shall commence until a programme for monitoring and review of ecological management has been submitted to and approved by the relevant Local Planning Authority, in consultation with the Port of London Authority and the Environment Agency. The monitoring programme shall be established to monitor the impact on ecology throughout the construction of the bridge and associated works, and in particular: a) the effects of water quality on in-stream flora and fauna, including impacts of both chemical and diffuse pollution (for example from mobilisation and/or silt deposition), and b) the introduction and re-distribution of alien species (direct or indirect). The purpose of the programme shall be to verify the successful translocation of flora and fauna and the success of habitat and species enhancement, habitat creation, and mitigation and/or compensation measures.
48.
49.
Before development commences, details of a monitoring scheme to measure the impact of construction disturbance on fish, teal and other waterfowl are to be submitted to and approved by the relevant Local Planning Authority. Before any work is carried out within 5 metres of non-main watercourses or water bodies, details of ecological and engineering mitigation works shall be submitted to and agreed with the relevant Local Planning Authority, in consultation with the Environment Agency. Planting within river corridors should comprise locally native species only, unless otherwise agreed. Before planting commences, details of such planting shall be submitted to and approved by the relevant Local Planning Authority in consultation with the Port of London Authority.
50.
51.
52.
All existing trees on the site that are not directly affected by the proposed works shall be retained and shall not be lopped or topped without the prior approval of the relevant Local Planning Authority. Any such approved tree works shall be undertaken outside the bird
11
nesting season (1 March to 31 August inclusive), and the trees affected shall be inspected for bats. If any trees die during, or are removed as a result of, construction, replacement trees shall be planted to the satisfaction of the relevant Local Planning Authority, within 9 months of completion of the works. 53. Any trees or shrubs that die within a period of 5 years from the date of planting, are removed, or become seriously damaged or diseased, shall be replaced in the next planting season with others of a similar size and species, unless the relevant Local Planning Authority gives consent to any variation.
12
APPENDIX E THAMES GATEWAY BRIDGE RECOMMENDED PLANNING CONDITIONS ON TEMPORARY CONSTRUCTION WORKSITE - P/05/0428 1. In these conditions, the Local Planning Authority means the London Thames Gateway Development Corporation. The planning permission applies to drawing TBTGRC/P2/CMP/003 Rev 0. All other drawings submitted with the application are illustrative. 3. An application for the approval of matters pursuant to Condition 14 shall be made to the Local Planning Authority before the expiration of 5 years from the date of this permission, and the development hereby authorised must be begun not later than whichever is the later of the following dates, failing which the permission shall be of no effect: a. b. The expiration of 7 years from the date of this permission: or The expiration of 5 years from the final date of approval of matters pursuant to Condition 14.
2.
4.
Drawings, plans and other documents, other than those approved by this planning permission, that have been approved by the Local Planning Authority may be revised, subject to the same approval procedure as was required for the original drawing, plan or document. Where under any condition set out below the approval, agreement or consent of the Local Planning Authority is required, that approval, agreement or consent shall be given in writing. The works thereby approved shall be carried out in accordance with that approval unless subsequently otherwise approved in writing by the Local Planning Authority.
5.
6.
The development means the development authorised by the planning permission to which these conditions apply. The Environmental Statement in these conditions means the Environmental Statement July 2004, Addendum March 2005, Addendum 2 September 2005 and Addendum 3 December 2005. The Design Statement in these conditions means volume 2 of the Appendices to the Environmental Statement July 2004 (updated March 2005, September 2005 and April 2006).
7.
The Landscape and Urban Design Strategy in these conditions means volume 3 of the Appendices to the Environmental Statement July 2004 and Addendum September 2005. 8. The design of the works shall be in accordance with the parameters set out in the Design Statement. Before the commencement of development, details of all external lighting and/or flood lighting, including any external illuminated signage, shall be submitted to and approved by the Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority. Such lighting will not be permitted where its design or intended use is likely to distract or mislead any pilots of aircraft operating at London City Airport or any persons navigating vessels on the River Thames. Such lighting may only be installed in accordance with the approved details. Except for general upkeep and like for like replacement, the lighting shall not thereafter be altered or added to in any way without the prior approval of the Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority. 10. Before the commencement of development, details of the methods of construction, including details of the use, location and height of cranes and other plant and equipment or temporary structures, shall be submitted to, and approved by the Local Planning Authority in consultation with the operator of London City Airport and the Civil Aviation Authority. During the normal operating hours of London City Airport, such temporary works shall be constructed within the height constraints shown on drawing no. TBTGRC/P2/TGB/324 revision 1 unless otherwise agreed by London City Airport. Outside the normal operating hours of London City Airport, works which exceed the height constraints shown on drawing no. TBTGRC/P2/TGB/324 revision 1 shall be undertaken in accordance with a method statement submitted to and approved by London City Airport, and all works, cranes, plant, equipment and other temporary structures which exceed such height constraints shall be removed in accordance with the approved method statement. 11. Before the start of construction of any drainage system, full details of the system for the disposal and attenuation of surface water run-off from the site together with a maintenance and monitoring programme shall be submitted to and approved by the Local Planning Authority in consultation with the Environment Agency. Before development commences, a statement of the method of working for disposal, drainage or dewatering of contaminated surface
9.
12.
or ground water, including provision of alternative disposal routes where contamination levels are unacceptable, shall be submitted to and approved by the Local Planning Authority in consultation with the Environment Agency. 13. Details of all piling to be undertaken shall be submitted to and approved by the Local Planning Authority in consultation with the Environment Agency before development commences. Details of the proposed temporary construction work site, including means of access, and the location of all temporary buildings, batching plants, car parks, stockpiles of excavated and imported materials, and means of enclosure, shall be submitted to and approved by the Local Planning Authority before development commences. No temporary housing, including caravans, shall be provided or located on the site without the prior approval of the Local Planning Authority. Before the works commence, a desktop study, and site investigation if indicated as necessary by the desktop study, appropriate to the proposed works, shall be carried out within the land affected by the works, in order to determine groundwater characteristics and assess any risk arising from the presence of contaminants causing or likely to cause significant harm to persons, pollution of controlled waters or significant harm to the environment. A land assessment report shall be prepared by a recognised consultant acceptable to the Local Planning Authority, which shall identify any necessary remediation measures to render the land fit for the intended purpose, and any long term measures that are necessary with respect to contaminants remaining on site shall be set out in a management plan. The land assessment report and management plan, which shall include measures for monitoring the effectiveness and integrity of any remediation measures, shall be prepared in accordance with the principles set out in the code of construction practice, or other such principles as may be subsequently agreed with the Local Planning Authority. Both the land assessment report and the management plan shall be submitted to and approved by the Local Planning Authority before the works commence; and any remediation measures approved by the Local Planning Authority shall be implemented within such period as the Local Planning Authority may agree.
14.
15.
16.
In the event of the land assessment report, the management plan, or both disclosing any lack of effectiveness, integrity, or both, the Local Planning Authority shall be notified of the same forthwith, and all works necessary to rectify the same shall be carried out forthwith. 17. On completion of the remediation measures undertaken pursuant to Condition 16, a validation report detailing all works carried out shall be submitted to the Local Planning Authority within 6 months and approved by them. Unless otherwise agreed by the Local Planning Authority, normal working hours for construction activities shall be: Monday Friday Saturday Sundays, Public and Bank Holidays 0800 to 1830 0800 to 1300 No work
18.
Subject to the prior agreement of the Local Planning Authority, working outside these hours will normally be permitted for: a. work requiring road or rail closures. b. continuous operations lasting more than 12 hours. c. work constrained by river conditions. (This includes both construction activities and the loading and off-loading of materials transported by river transport.) d. work that would otherwise affect the operation of the London City Airport or the statutory undertaking of the Port of London Authority. e. Movement of abnormal loads or other specified construction activities agreed with the Local Planning Authority. The Local Planning Authority shall consult with the Port of London Authority in respect of items c. and d. above, and with London City Airport in respect of item d. above. In an emergency, work may be carried out outside the normal working hours. Should this be necessary, the Contractor shall immediately notify the Local Planning Authority and prepare a report, detailing what work was done and why it was treated as emergency work, and submit it to the Local Planning Authority before the end of the second working day following the completion of the emergency work. 19. The proposed method, frequency and location of vibration, noise and dust monitoring during the construction period shall be submitted to the Local Planning Authority for agreement, and acceptable levels of dust, vibration and noise shall be agreed with
the Local Planning Authority in consultation with the Environment Agency before the start of demolition or construction. 20. The levels of vibration, noise and dust shall be monitored in the agreed manner pursuant to Condition 19 during construction, using an objective method of measurement at each site. Best practicable means shall be used at all times to ensure that the levels of dust, vibration and noise remain within the agreed levels. 21. No soils or filling materials are to be imported on to the site until they have been satisfactorily proven to be suitable for use and to protect human health, planting or the environment. A declaration to this effect, together with acceptable documentary evidence to confirm the origin of any imported soils and infill materials, supported by appropriate chemical analysis test results and risk assessment, must be submitted to and be approved by the Local Planning Authority prior to transfer to the site. No vehicle shall leave the site with earth, mud etc. adhering to the wheels in a quantity which may result in its being deposited on the public highway or footpath, and creating nuisance or hazard to vehicles or pedestrians. Effective wheel cleaning equipment to avoid such problems shall be installed, operated and maintained on the site until the completion of the works. An ecological management plan, including proposals for mitigation measures, replacement habitats, biodiversity, long term objectives, management responsibilities and maintenance schedules covering both aquatic and terrestrial habitats shall be submitted to and approved by the Local Planning Authority in consultation with the Port of London Authority and the Environment Agency before the commencement of the development. The parameters of the plan shall reflect the principles and guidelines set out in the Environmental Statement. 24. Before development commences a Construction Environmental Management Manual shall be submitted to and approved by the Local Planning Authority in consultation with the Environment Agency. Prior to the commencement of construction a detailed Code of Construction Practice shall be submitted to and approved by the Local Planning Authority. No development shall take place until a programme of archaeological work has been submitted to and approved by the
22.
23.
25.
26.
Local Planning Authority. The programme shall accord with good practice as set out in Section 12 of the Environmental Statement. 27. No development shall commence until a programme for monitoring and review of ecological management has been submitted to and approved by the Local Planning Authority in consultation with the Environment Agency. The monitoring programme shall be established to monitor the impact on ecology throughout the construction of the bridge and associated works, and in particular the introduction and re-distribution of alien species (direct or indirect). The purpose of the programme shall be to verify the successful translocation of flora and fauna and the success of habitat and species enhancement, habitat creation, and mitigation and/or compensation measures.

Thames Gateway Bridge Inspector's Report

Caricato da

Informazioni sul documento

Titolo originale

Copyright

Formati disponibili

Condividi questo documento

Condividi o incorpora il documento

Opzioni di condivisione

Hai trovato utile questo documento?

Questo contenuto è inappropriato?

Copyright:

Formati disponibili

Thames Gateway Bridge Inspector's Report

Caricato da

Copyright:

Formati disponibili

Report to the Secretary of State for Communities and Local Government and the Secretary of State for Transport

By Michael Ellison MA(Oxon)

Date: 17 November 2006

Assisted by John Watson BSc(Hons), FIHT, MICE,

10 RECOMMENDATIONS ........................................................................ 578

GLA GLAA 1999 GLFoE GLIT

the main bridge applications the planning applications

Summary of Recommendation: That the Order be not confirmed.

PROCEDURAL AND LEGAL SUBMISSIONS

THE CASE FOR TRANSPORT FOR LONDON

iii. iv. v. vi.

GEH < 8 Journey Time within 25% or 1 minute

Journey Time within 15% or 1 minute

Total mitigation funds proposed to be available

(pcu/hr) 366 944 721 777 441 691 2401

Present Value (m, 1998)

1,635 144 1,779

468 281 -187

In some circumstances, it may be justifiable to refuse planning

Revised Toll Proposal 0 13 10 118 641

12.9 92.8 377.5 5.0 96.2 69.2 547.9 640.7

THE CASES OF THE SUPPORTERS

Without it, the potential

6. THE CASES OF THE OBJECTORS

It is wrong to criticise TfL for

Its objection to the

Traffic model - reliability

Traffic - mitigation measures

Regeneration and development

West East West East

1.7 5.7 2.9 3.4 5.6

Redbridge Newham Wandsworth Hammersmith Average Average West West West

93 117 121 129

3.8 6.9 5.1 4.1 3.7 3.2

Flora and Fauna

TfL current [4.135]

Bexley Council [6.45]

D221 D222 D223 Documents D224 EU Directives D301

D534 D535 D536 D537 D538 D539 D540

D542 D543 D544

D608 D609 D610 D611 D612 D613 D614

D615 D616 D617 D618

D724 D725 D726

D826 D827 D828 D829 D830 D831 D832 D833

D834 D835 D836 D837 D838 D839 D840

D842 D843 D844 D845

ADD/008 ADD/009 ADD/010 ADD/011 ADD/012 ADD/013 ADD/014

INQ/8 INQ/9 INQ/10 INQ/11 INQ/12 INQ/13 INQ/14 INQ/15

TfL/P/04/2 TfL/P/04/3 TfL/P/04/4 TfL/P/04/5 TfL/P/04/6 TfL/P/04/6/1 TfL/P/04/7 TfL/P/04/8 TfL/P/05/1

TfL/21 TfL/22 TfL/22A TfL/22B TfL/22C TfL/22D TfL/23

TfL/24 TfL/24A TfL/24B TfL/24C TfL/24D

TfL/24X TfL/24Y TfL/24Z TfL/24Z/1 TfL/25 TfL/26 TfL/27

TfL/27/1 TfL/28 TfL/29 TfL/30 TfL/31 TfL/32 TfL/33

TfL/158 TfL/159 TfL/160 TfL/161

TfL/164 TfL/165 TfL/166 TfL/167 TfL/168 TfL/168A TfL/169

TfL/251 TfL/252 TfL/253

TfL/REB/2687/1 TfL/REB/2691/1 TfL/REB/2691/2 TfL/REB/2698/1 TfL/REB/2703/1 TfL/REB/2703/2 TfL/REB/2704/1 TfL/REB/2704/1A2/1

London Borough of Newham

2703/36 2703/36A 2703/37 2703/38 2703/39 2703/40 2703/41 2703/42

2703/43 2703/44 2703/45 2703/46

342/7 342/8 342/9 342/10 342/11

Additional Statement made by Mr and Mrs Ruddell

Abbey Wood Wildlife Mr Kenneth Hobday 537/1/A1 Proof of Evidence