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Correspondence Address:

Margaux

Woodlands Lane

Shorne

Gravesend

Kent

DA12 3HH

Email address: abridge2far@gmx.co.uk

BY EMAIL: ltcc@ipsos.com

Freepost RTTH–GRYG–SCXZ Lower Thames Crossing Consultation PO Box 1188 Harrow HA1 9NU

24th March 2016

Dear Sirs

LOWER THAMES CROSSING CONSULTATION: RESPONSE FROM ABRIDGE2FAR

1.0 INTRODUCTION

This consultation response is submitted by Abridge2far. Abridge2far is an organisation which

represents the views of the majority of residents in Shorne and the surrounding DA12 area of Kent in

their opposition to any new crossing at Location C east of Gravesend.

Abridge2far was formed in 2013 to oppose proposals for a crossing east of Gravesend (then referred

to as Option C). It has over 520 members of its ‘abridge2far’ facebook group, and is closely allied with

the ‘3rd Thames Crossing Kent’s Views facebook group’ which has over 1500 members. It has many

other supporters who are not connected by facebook.

In February 2016 Abridge2far initiated a petition to Kent County Council (KCC), which called on the

Council “to withdraw its support for a Lower Thames Crossing East of Gravesend and to support the

thousands of Kent residents whose lives would be devastated by this proposal. A new crossing east

of Gravesend will not address the problems at Dartford”. This petition obtained 3,768 signatures in

just 4 weeks. The petition was terminated after 4 weeks to permit the matter to be debated at KCC’s

Environment & Transport Cabinet Committee.

These figures are given in order to provide an indication of the number of people who Abridge2far

represents, and of the strength of opposition to Option C on the Kent side of the River Thames.

We are aware of similar opposition to Option C on the Essex side of the Thames. We have not

considered the impact of Option C in Essex in our response to this consultation. However, Abridge2far

opposes any routes in Essex which form part of a proposed Option C crossing east of Gravesend.

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2.0 BACKGROUND TO THIS CONSULTATION

In 2013, the Department of Transport consulted on the three remaining options for a Lower Thames

Crossing. These were Option A for an extra bridge to add capacity to the existing crossing at Dartford;

Option B for a new crossing at Swanscombe; Option C for a new crossing east of Gravesend.

It is important to note that at the time of this consultation, Option A at Dartford offered the lowest

cost option at £1.25bn. It is also important to note that Option A offered the best value for money,

with a Benefit Cost Ratio (BCR) of 1.8 rising to 2.4 when wider benefits were included.

By contrast, Option C was the highest cost option at £3.15bn, and offered the lowest value for money

with a BCR of just 1.2, only rising to 1.9 when wider benefits were included.

On the Kent side of the River Thames, the proposal for Option C included a new junction with the M2

motorway, which stretched from junction 1 (where the M2 joins the A2), to west of Brewers Road

overbridge on the A2. The slip roads and link road then ran through Brewers Wood and Randalls

Wood, both parts of Shorne Woods Country Park, passing to the south of Shorne village. The link road

then continued across grade 1 and grade 2 agricultural land before entering tunnels north of Lower

Higham Road near Chalk. All of this link road was located in the Green Belt, and much of the route

was through Kent Downs Area of Outstanding Natural Beauty (AONB).

It is noted that the Review of Lower Thames Crossing Options: Final Review Report published in April

2013 stated that for Option C “there are very serious environmental impacts, particularly associated

with biodiversity and ancient woodland. Some of the impacts may be mitigated slightly, through use

of bored tunnels, albeit not enough to change the overall qualitative assessment. Overall it was

considered that the non-monetised impacts reduced the case for Option C significantly”.

In the 2013 consultation, Option A at Dartford was favoured by the highest number of respondents

who expressed a preferred location, with 20% of respondents favouring Dartford. By contrast, only

6% favoured Option C east of Gravesend, and a further 11% favoured Option C variant which included

junction improvements and road widening at the A229 (Bluebell Hill).

In December 2013, the Secretary of State for Transport announced that Option B had received limited

support and instead raised serious concerns that it would jeopardise major redevelopment of the

Swanscombe Peninsula (Paramount London), a key part of the growth strategy for the Thames

Gateway area. In view of this, Option B at Swanscombe was discarded and the government would

focus on the choice between Options A and C.

In May 2014, Jacobs AECOM published a further Lower Thames Crossing study, in which Module 2

focused on scoping the cost of potential environmental mitigation of Option C, following suggestions

submitted by Kent County Council during the 2013 consultation. This proposed moving the Option C

junction approximately 2km west along the A2, so that the link road avoided Shorne Woods Country

Park and Kent Downs AONB, and included realigning and extending the bored tunnels.

This increased the estimated costs by £250m to £3.4bn, and decreased the BCR to 1.1, or 1.8 including

wider benefits, but reduced the adverse environmental impacts significantly. This route was

designated Option C2 (with the original route henceforth designated Option C1).

On 15 July 2015, the Secretary of State for Transport announced that Highways England had been

tasked with developing and assessing route options at each of the two remaining locations, Option A

at Dartford and Option C east of Gravesend, before choosing the site of a new crossing. The work will

show the possible routes at either location and identify their economic, environmental and social

impacts, as well as costs. This would be followed by a full public consultation on the preferred route.

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Highways England published their preferred route on 26th January 2016 and launched the public

consultation. In this consultation, Highways England has discarded Option A at Dartford, despite this

being the clear preference expressed by consultees at the previous consultation, and is only consulting

on Option C.

In addition to a route based on Option C2, they have introduced a totally new route for Option C south

of the Thames, a route that has not been discussed or consulted on before.

This is Abridge2far’s response to this consultation.

3.0 A FLAWED AND DISCRIMINATORY CONSULTATION

3.1 Consultees Have Been Misinformed and Denied a Proper Choice of Options

A number of routes have been identified and well publicised in the past. These include Option A at

Dartford, and two possible routes south of the river, Options C1 and C2. These were the routes that

remained after the 2013 consultation, and these were the routes that the public were expecting to be

consulted on.

Instead, Highways England (HE) unilaterally decided not to include Option A in this consultation, and

introduced a totally new Option C route that has not been seen or discussed by the public before.

At the public information sessions conducted by Highways England, consultees were clearly and

repeatedly told that Option A at Dartford was not being taken forward and hence was not part of this

consultation, and that this consultation was only about the routes for Option C east of Gravesend.

Early responders to the consultation will have based their responses on this information.

However, both the Secretary of State for Transport Patrick McLoughlin and the Transport Minister

Andrew Jones subsequently told representatives from Abridge2far that Option A at Dartford is NOT

off the table and is still under consideration. These statements are now in the public domain.

Since these statements by government ministers, HE’s Consultation Manager has subsequently

attempted to claim that Option A at Dartford is not off the table, and that consultees are free to insert

their preferences in the comment boxes in the consultation forms.

This is disingenuous. It is patently obvious from the consultation documents and from the

questionnaire that Option A is totally excluded from this consultation, and that respondents are not

being consulted on Option A.

Consultees are only given choices of routes for Option C east of Gravesend. Contrary to the

statements made by the Secretary of State and the Undersecretary of State, it is abundantly clear that

consultees have been denied the opportunity to express their views on Option A. All the questions

are about Option C. There are NO questions in the consultation questionnaire regarding Option A at

Dartford.

This conflict of information brings the integrity of the whole consultation process into disrepute.

3.2 The Consultation is Discriminatory

Two of the communities most affected by HE’s preferred route are Chalk and Higham, and yet no

public information events were held in either of these communities.

Shorne is another community severely impacted by HE’s proposals, and yet many residents were not

even notified of the consultation. It was not until complaints were made to HE representatives that

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many residents in Shorne were sent notifications, by which time a week of the 8-week consultation

period had already elapsed.

The villages of Shorne and Higham have a high proportion of older residents, many of whom do not

use the internet. However, responses to requests for hard copies of the maps, consultation booklets,

and questionnaires have been extremely slow and disjointed, taking several weeks before the

information was provided. Many of these residents have been unable to respond to the consultation.

The consultation Booklet itself is little more than a sales brochure espousing the benefits of Option C

while glossing over the details.

Maps and details of the routes south of the river have been hidden away in the extensive Scheme

Assessment Report (SAR), with no effective index, making it extremely difficult for ordinary members

of the public to locate, and impossible for non-IT literate or non-internet users to find. It was almost

three weeks into the eight week consultation period before HE even included a link to the maps on

the consultation website.

We believe that insufficient time has been allowed and that the consultation has been discriminatory

against older and non-IT literate people in contravention of the Equality Act 2010.

3.3 The Consultation is Biased and Engineered to Produce a Pre-determined Result

Highways England invited consultation responses from 250,000 people, many from well outside the

affected area, plus up to a million Dart Charge account holders, who have no knowledge of the

environment or the communities affected. We believe that this consultation was extended to large

numbers of uninformed and unaffected people purely to outnumber those who are most affected and

who are most aware of the impact these proposals would have.

It is unreasonable to expect these people to wade through volumes of documentation to reach an

informed decision. Most of the consultees invited by Highways England will base their views on what

is provided in the consultation booklet, which is little more than a sales brochure for Option C, with

no choices other than minor variations of Option C. The map they will see is this:

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This extremely simplified diagram gives no detail of the route or the proximity of the villages, schools,

Sites of Special Scientific Interest (SSSIs), Areas of Outstanding Natural Beauty (AONB), etc.

The Dart Charge users and other consultees invited by Highways England are told that the Dartford

Crossing is one of the busiest roads in the country. They are told that the existing crossing is at

capacity for much of the time and is one of the least reliable sections of the UK’s strategic road

network. Road users regularly experience delays and unreliable journeys, and when there incidents

the congestion on the crossing quickly spreads to local roads and arterial roads in and out of London,

and that “something needs to be done to alleviate the problems”.

They are then given some scary statistics, which are somewhat misleading: they are told that traffic

volumes at Dartford Crossing are increasing, when in fact they have been falling since 2005; they are

told that a closure means a 30 mile detour via Blackwall tunnel or a 100 mile detour round the M25,

when of course this is only true for journeys between Dartford and Thurrock – the distance between

the M20 and the Midlands is not much different whichever direction round the M25 is used.

Readers are then subjected to several pages promoting the benefits of Option C, and then asked “Do

you agree or disagree with our proposal for the location of a crossing at Location C?”

Given no other choice, many will automatically tick the box to agree with Highways England’s

recommendation, and this will be presented to Government as strong support for Option C.

Do not be misled. The majority of consultees will not be making an informed choice – they are not

being informed and they are not being given a choice. They just want to see the congestion disappear

and are being led to believe that this is the only way it can be achieved. They would ‘strongly agree’

with whatever option is put in front of them, whether it is Option A at Dartford, Option B at

Swanscombe, Option C at Gravesend, or any other option which purports to remove the congestion.

We believe that the consultation is biased and has been engineered to produce the result that

Highways England has predetermined.

4.0 THE PROBLEMS AT DARTFORD

The problems at the Dartford Crossing are well known and well documented.

The original tunnel was planned in the 1930s and opened in 1964, along with the A282, as a link

between what was then the A2 at Dartford (now the A296) and the A13 at Purfleet (now the A1306).

The A2 and A13 have since been relocated, and these original junctions are now designated junctions

1b and 31. The A282 has been extended southwards to the join the A2 at what is now junction 2 and

northwards to join the A13 at what is now junction 30. A second tunnel was added in 1980, and the

M25 has been built around London, linking both ends of the A282 at junction 2 and junction 30. The

QE2 Bridge was added in 1991.

Over the years, the A282 has been dualled and widened, but not converted to motorway standard

due to its original purpose. Junction 1a, which was originally a minor restricted junction to provide

limited access to the administration facilities and the nearby Littlebrook Power Station, is now a very

busy junction with the subsequent building of the A206 and the associated commercial developments.

All this has resulted in the Dartford Crossing becoming very busy indeed. The A282 and Dartford

Crossing was not originally intended as a vital link to the motorway network, but has become so almost

by default, with no efforts made to provide an alternate route for the M25.

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The two northbound tunnels and the southbound bridge have a combined designed capacity of

135,000 vehicles a day, but are now regularly operating at 140,000 vehicles a day.

Free-flow charging was introduced in 2014 to relieve congestion caused by the toll booths. This has

been successful for southbound traffic, with traffic now flowing freely across the bridge. However,

this has not been successful northbound due to the inherent restrictions caused by the tunnels.

The Dartford West Tunnel has a headroom of 4.8m, which is too small to accept larger vehicles. The

Dartford East Tunnel has a headroom of 5.0m, which is also below current headroom standard

requirements.

The use of the tunnels by large vehicles and vehicles with dangerous loads is restricted. This is

managed through a Traffic Management Cell (TMC). One reason for the restrictions on dangerous

loads is that the existing cross passages between the two tunnels are substandard in terms of width

and gradient (and cannot be upgraded economically) meaning that the tunnels cannot be made fully

compliant with European Regulations that would allow unrestricted access by dangerous loads.

In order to implement Dart Charge, and allow the toll plazas to be removed, a Traffic Management

Cell (TMC) was implemented. The TMC controls the passage of restricted vehicles, comprising over-

height, over-width, over-length and dangerous goods vehicles, through the tunnels. Over height and

dangerous goods vehicles are detected using over-height sensors and ANPR cameras capable of

reading the hazardous load codes displayed on vehicles carrying such loads. The system is coordinated

by the TMC control system, and upon detection of a non-compliant vehicle a system of traffic lights

and physical barriers are used to stop the vehicle. A traffic officer vehicle is then dispatched to

intercept and re-route the vehicle, before traffic held in the traffic management system is released.

The TMC enables segregation of restricted vehicles, to enable them to be escorted through the tunnels

safely, and stops traffic in the event of an incident in the tunnels.

However, the high usage of the tunnels by heavy goods vehicles, including foreign registered vehicles,

means that vehicles need to be frequently intercepted and this is very disruptive to free flowing traffic,

and acts as a constraint on capacity. As a result, the northbound capacity at Dartford crossing is less

than the southbound.

Vehicles carrying dangerous substances require on average 800-900 vehicle escorts per week; each of

which can hold up traffic for 2 minutes; full closures of up to 10 minutes are sometimes required.

These delays are caused by vehicles being held back to enable the convoys to proceed.

These tunnel restrictions and consequent delays, together with the large volumes of traffic now

merging from junction 1a just 500 metres from the tunnel portals, result in severe congestion,

together with weaving of traffic, resulting in one of the least reliable sections of the UK’s strategic

road network. This congestion results in severe pollution, with poor air quality and adverse impacts

on the health of the local population.

Despite Highways England’s claims to the contrary, congestion northbound has actually got worse

since the removal of the toll booths, due to failure of their traffic management system.

This is a major bottleneck on the M25 London Orbital Motorway, restricting growth and adversely

impacting the national economy.

These are serious problems, problems which Highways England is very much aware of.

The question is, what do they propose to do to address these problems at Dartford? The answer is

precisely nothing.

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They intend to do nothing to address the problems caused by the outdated and restrictive tunnels.

They intend to do nothing to address the problems caused by the mixing of motorway and local traffic.

They intend to do nothing to tackle the problems caused by local traffic merging from local junctions.

They intend to do nothing to increase the capacity of the Dartford Crossing and its approach roads.

They intend to do nothing to reduce the current levels of traffic volumes using the Dartford Crossing.

They intend to do nothing to address the poor air quality and pollution near the Dartford Crossing.

They intend to do nothing to bypass this major bottleneck on the M25 London Orbital Motorway.

Instead, Highways England has decided to leave all the existing problems at Dartford and to create a

new set of problems east of Gravesend, designated Option C.

5.0 OPTION C - A BLUEPRINT FOR GRIDLOCK NOT GROWTH

5.1 Option C Does Not Address Traffic Volumes at Dartford

Highways England’s proposal for a new crossing east of Gravesend completely fails to provide relief or

an alternative route for traffic using the M25 orbital motorway for journeys other than those

originating or terminating in Kent, and it completely fails to address the congestion and pollution

problems at Dartford.

Figure 2.2 taken from Highways England’s Summary Business Case shows that the Dartford Crossing

is currently carrying an average of 140,000 vehicles a day, 3.7% higher than its designed capacity of

135,000.

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Table 4.3 from Volume 5 of the SAR shows that, even if a new crossing east of Gravesend is built, traffic

volumes at the Dartford Crossing (DC) would still be between 137,000 and 138,000 vehicles a day.

This is 98% to 99% of current traffic volumes, and would already exceed the designed capacity. Traffic

volumes at Dartford would be back up to current levels within one to two years of Option C opening.

Table 4.4 below shows that within 16 years of the new crossing opening, traffic volumes at the

Dartford Crossing are forecast to be over 150,000 vehicles a day, well in excess of its designed capacity.

It is patently clear that a crossing east of Gravesend will not address congestion at the Dartford

Crossing, and there would still be an urgent need for additional capacity at Dartford.

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Highways England (and Kent County Council) have ignored this, and appear to be narrowly focused on

providing an alternate route for freight transport travelling to and from the Channel Ports.

Their proposed crossing east of Gravesend would undoubtedly provide an alternative route for traffic

using the A2/M2 to travel between Dover and the rest of the UK. However, it does little or nothing to

provide an alternative route for traffic using the M20 primary route to travel to and from the Channel

Ports. The M20 is the only road that provides a motorway connection between the Channel Ports and

the rest of the UK motorway network.

The proposed crossing is being promoted as providing motorway-to-motorway connection. This is

disingenuous. Whilst it may provide a direct link between the M2 and the M25, traffic using the M2

must use ‘A’ roads to get to and from the Channel Ports. The M2 stops 25 miles short of Dover; the

remainder of the journey is via the A2. The proposed crossing east of Gravesend provides no link to

the M20 primary route, and traffic would need to cross country via the A228 or the A229. The

“motorway-to-motorway” claim is fallacious.

The situation is made worse by the omission of the ‘variant’, ie the road widening and junction

improvements to the A229. We suspect this has been omitted to conceal the real cost of Option C,

which is already significantly more expensive than Option A. (We note that junction improvements at

junction 30 and junction 2 have been ‘lumped in’ to the cost of Option A, however.) The A229

junctions with the M2 and the M20 are already heavily congested at peak times, resulting in traffic

queues onto the A229 itself. How these junctions are expected to cope with the additional traffic

trying to travel between the M20 and the proposed new crossing east of Gravesend defies credibility.

Nevertheless, Highways England and Kent County Council are missing the bigger picture, in that the

Dartford Crossing is on the M25 and a key part of the national strategic highways network, and serves

a far greater purpose than merely being a route for cross-channel traffic.

A crossing east of Gravesend will do nothing to provide an alternative route for traffic travelling around

the M25 Orbital Motorway. It is too far away from the primary route through Dartford to serve this

purpose. Little if any traffic would choose to make a lengthy detour east of Gravesend.

Nor will it provide so-called ‘resilience’ in the event of an incident at Dartford. The A2 and the

proposed link roads simply do not have the capacity to cope with an additional 75,000 to 150,000

vehicles a day on top of their existing traffic volumes, and we would quickly find that the whole of the

road infrastructure from the Medway Towns to South East London would be gridlocked, as well as the

feeder roads such as the A227, A228, A229, and A289.

Both proposed routes for the link road south of the Thames cut off Chalk Church from its community.

Both routes are entirely within protected Green Belt and internationally protected RAMSAR marshes.

There is a presumption against development in Green Belt areas, and opportunities for development

and growth in the immediate locality will therefore be extremely limited. It assumed that any growth

that occurs will be beyond the Green Belt or on 'Brown Field' sites.

With no direct link to the A289 and the Hoo Peninsula and Chatham Maritime, the Eastern Southern

Link will provide little opportunity for these areas.

Since there is poor interconnectivity between the M2 and the M20, and the likelihood of increased

congestion on the nearest interconnecting roads (ie the A227, A228, and the A229) we foresee little

opportunity for growth in the regional hinterland; in fact existing commerce may well be impeded.

Both routes south of the river (ESL and WSL) propose a junction to the A226. The presence of this

junction would result in a massive increase in traffic and heavy goods vehicles, estimated at around

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8,400 vehicles a day but likely to be considerably more, to the local infrastructure, and would

encourage traffic to use the local villages as alternative routes to and from the crossing.

In the event of an incident at either Dartford or the new crossing, the A226 and the surrounding area

would quickly become gridlocked, preventing access from the local villages to schools and other

facilities in Gravesend.

The junction would put the protected Green Belt and the RAMSAR marshes under pressure from the

type of inappropriate commercial development that has happened on the approaches to the Dartford

Crossing.

We therefore strongly oppose any junction on the A226.

A crossing east of Gravesend is a recipe for gridlock, not growth. It will not address the congestion

and pollution problems at Dartford, it will not remove the bottleneck from the M25, it will not provide

resilience or a motorway-to-motorway connection for cross channel traffic, and it is unlikely to support

economic growth.

We STRONGLY DISAGREE with Option C East of Gravesend.

5.2 Option C - Value for Money has been Exaggerated

In the Review of Lower Thames Crossing Options: Final Report published for the previous consultation

in April 2013, the Benefit Cost Ratio (BCR) for Option C1 was estimated at just 1.2, ie barely break

even, only rising to 1.9 when wider benefits are included. Option C2, which is very similar to the WSL,

had an even lower BCR, at just 1.1 rising to 1.8 with wider benefits.

There have been no material changes since 2013; the estimated cost for Option C has risen by 18% to

£3.720bn, which might be expected to depress the BCR slightly, but there have been no material

changes to economic forecasts.

And yet in the current consultation, we find that the BCR for Option C has inexplicably risen from 1.2

to 2.4, increasing to 3.5 when wider benefits are included. The BCRs for Route 3 ESL are even higher,

at 2.7 rising to 3.9 with wider benefits. There is no valid reason why this dramatic improvement in

BCR should have occurred.

Over the same period, the BCR for Option A at Dartford has fallen, from 1.8 to 1.6, and from 2.4 to 2.3

when wider benefits are included.

We are now faced with a reversal of relative value for money. In 2013, Option A at Dartford offered

the best value for money by a considerable margin; in 2016, we find that Option C east of Gravesend

offers the best value for money, again by a considerable margin.

Highways England has set great emphasis on the supposed value for money. The benefits in BCR

forecasts are, at best, assumptions of the value of benefits that might conceivably accrue over a

considerable period of time. They cannot be proved or disproved, they are based purely by applying

monetised values to largely non-tangible items, including leisure time. As far as we are aware, damage

to the ecology and the natural environment are not monetised, nor are the very real costs associated

with dealing with health issues resulting from pollution and poor air quality.

In view of the wide disparity between the 2013 BCRs and the 2016 BCRs for Option C, we have serious

doubts about the figures quoted by Highways England, and would advise extreme scepticism.

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5.3 The Eastern Southern Link (ESL)

Highways England has made the ESL its preferred route. This is a totally flawed decision.

Highways England states that ESL “would create a motorway-to-motorway connection”. This is

spurious, since there is no motorway connection to or from the Channel Ports via the M2.

The junction with the M2 would require a number of major structures as it is located at the existing

junction between the A2, M2 and A289. The complexity of the junction requires four levels of slip

roads and the heights of the slip roads are further increased by the topographical dip located between

the existing junction and the LTC mainline located on the Shorne to Higham ridge. A series of five

viaducts would therefore be required with lengths varying from 300m to 1000m with pier heights up

to 23m. This overlooks and partly impinges on Kent Downs Area of Outstanding Natural Beauty, and

would require the demolition of up to 8 residential properties.

The junction is shown in figure 4.5 in Volume 4 of the SAR and reproduced below.

As well as being extremely intrusive, the proposed connection to the M2 motorway is ill conceived

and poorly designed. It provides no connection between the A289 Wainscott Bypass and the ESL, nor

does it provide a connection to the A2 towards Strood and Rochester. Thus key areas of population

and commerce (including Chatham Maritime, Medway City Estate, Thamesport container port, and

the Hoo Peninsula) would have no direct access to the proposed crossing east of Gravesend.

All traffic heading to and from Chatham Maritime, Medway City Estate, Thamesport container port,

and the Hoo Peninsula would therefore have to continue to use the A2 to cross via the Dartford

Crossing. The only alternative would be for traffic to use the single carriageway A226 local road

through Gads Hill, Higham, and Shorne, to travel between the A289 and the proposed new crossing.

This would result in a massive increase in traffic and heavy goods vehicles, estimated at around 8,400

vehicles a day but likely to be considerably more, to the local infrastructure.

The connections between the ESL and the westbound carriageway of the M2/A2 are far too close to

the connections to and from the A289 Wainscott Bypass, allowing insufficient room for merging and

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filtering, which will result in excessive braking and weaving, creating hazardous driving conditions.

Furthermore, any incident on the A2 westbound will result in westbound traffic from the M2, the A2

from Rochester, the A289 Wainscott Bypass, and the ESL, all coming to a complete standstill. This is a

recipe for gridlock.

From this highly intrusive junction and slip roads, the ESL carves a swathe through Great Crabbles

Wood, a Site of Special Scientific Interest, and cuts through Pear Tree Lane, one of the most expensive

and desirable places to live in North Kent.

This dual carriageway then crosses agricultural land on an 800m embankment, before cutting through

the village of Shorne.

The map below provides an illustration of how close the road would be to the village of Shorne, and

how the dual carriageway and embankment would effectively cut the community of Shorne in two.

The properties shown above the link road are in Shorne Village, the properties below the link road are

in Lower Shorne.

After crossing over Forge Lane, the main road into the village, and Crown Lane, the link road then runs

parallel to the A226, crossing through grade 1 and grade 2 farmland, before reaching the proposed

new junction with the A226.

On ESL, this junction would provide the only route for traffic travelling between the proposed crossing

and the A289, since there is no other route. We have already discussed that this would result in a

massive increase in traffic and heavy goods vehicles, estimated at around 8,400 vehicles a day but

likely to be considerably more, to the local infrastructure. All traffic travelling between the crossing

and the A289 (ie to or from Chatham Maritime, Medway City Estate, Thamesport container port, and

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the Hoo Peninsula) would have to use the single carriageway A226 local road through Gads Hill,

Higham, and Shorne. This is totally unacceptable, and we strongly object to any junction to the A226.

In our opinion, the ESL has absolutely no merits whatsoever. It blights an AONB, it destroys ancient

woodland and an SSSI, it destroys grade 1 and grade 2 agricultural land, and blights and divides an

ancient village community.

It is noted that the Review of Lower Thames Crossing Options: Final Review Report published in April

2013 stated that for Option C “there are very serious environmental impacts, particularly associated

with biodiversity and ancient woodland. Some of the impacts may be mitigated slightly, through use

of bored tunnels, albeit not enough to change the overall qualitative assessment. Overall it is

considered that the non-monetised impacts act to reduce the case for the scheme significantly”.

There is little in this latest ESL proposal that changes this position. Instead of passing through Brewers

Wood and Randalls Wood, an Area of Outstanding Natural Beauty (AONB), the link road now passes

through Great Crabbles Wood, a Site of Special Scientific Interest (SSSI). Instead of passing to the

south and west of the village of Shorne, it now passes to the east and north of the village, so close in

fact that it requires the demolition of residential properties and cuts off Lower Shorne from the Village

centre. For the remainder of its route, it crosses the same grade 1 and grade 2 farmland as the

discarded route, before passing close to Chalk Church, thereby cutting the church off from its

community.

It really appears as though no proper survey of the route has been carried out, which are no more than

lines on a map. It is clear that no thought has been given to the impacts to the environment or the

community. Little can be done to mitigate these impacts, and if for no other reason than this, the

route should be quickly and decisively rejected, as was the previous one.

We STRONGLY DISAGREE with the Eastern Southern Link (ESL).

5.4 The Western Southern Link (WSL)

The WSL is based on the route considered by Jacobs AECOM in 2014, in Module 2: Scoping the cost of

potential environmental mitigation of Option C, following suggestions submitted by Kent County

Council during the 2013 consultation. In doing so, it attempts to address some of the worst impacts

of Option C south of the River Thames.

However, in this version, Highways England has chosen to introduce a junction to the A226. Due to

the close proximity with the tunnel portals, this would mean moving the A226 southwards by a

considerable distance, causing yet more destruction to valuable agricultural land and to the

environment in general.

In our enquiries, we have been unable to find any local authority prepared to admit to requesting this

junction. We can therefore only assume that Highways England has taken this decision themselves to

unlock the Green Belt and RAMSAR marshes for commercial development, in an attempt to generate

further ‘benefits’ to help offset the cost of Option C.

We have already discussed that a junction on the A226 would result in a massive increase in traffic and

heavy goods vehicles, estimated at around 8,400 vehicles a day but likely to be considerably more, to

the local infrastructure, and it would encourage traffic to use the local villages as alternative routes to

and from the crossing. In the event of an incident at either Dartford or the new crossing, the A226 and

the surrounding area would quickly become gridlocked, preventing access from the local villages to

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schools and other facilities in Gravesend. As with the ESL, we strongly object to any junction to the

A226.

As with the ESL, the full length of the WSL is within the Green Belt. Although marginally less

environmentally destructive than the ESL, it blights the rural hamlet of Thong, and is located very close

to properties in the Shorne West / Riverview Park area.

Highways England has proposed an extremely restrictive junction on the A2, and cites this as one of

the main reasons for preferring the ESL. The junction is shown in figure 4.4 in Volume 4 of the SAR,

and is reproduced below.

In our view, this junction design is unnecessarily restrictive, and it would be a relatively easy task to

produce a more free flowing design.

However, the only technical merits the WSL has, in comparison to the ESL, is that it provides a direct

access to and from the A289 Wainscott Bypass and to and from the A2 to Strood and Rochester. This

would provide a direct route for traffic to and from Chatham Maritime, Thamesport, and the Hoo

Peninsula, and would render any junction on the A226 superfluous.

In addition, because the junction with the A2 is further west and the link road is shorter than the ESL,

this effectively moves its traffic attraction area further west. We do not believe that the WSL would

be any less attractive than the ESL for traffic to and from the M2, but we do believe it would attract

more traffic to and from the A289, and from areas served by the A2 to the west. We estimate that the

WSL moves the effective centre point between the Dartford Crossing and the proposed crossing east

of Gravesend westwards by over a mile, from the A227 to the B262.

Nevertheless, we cannot support the WSL since it does not address the problems at Dartford, and is

only marginally less environmentally intrusive than the ESL.

We STRONGLY DISAGREE with the Western Southern Link (WSL).

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6.0 OPTION A – ADDRESSING THE CAPACITY PROBLEMS AT DARTFORD

The quickest and cheapest way to increase capacity at Dartford, in order to get traffic moving and

reducing the delays and pollution, is to build a bridge adjacent to the existing one.

It has already been demonstrated that an unrestricted, 4 lane bridge provides relatively free-flowing

traffic from Essex into Kent, certainly no worse or better than other 4 lane sections of the M25. It is

reasonable to assume that a similar bridge from Kent into Essex would achieve similar results.

In fact the improvements in traffic flow would be significantly better in both directions, since an extra

bridge would increase capacity of the crossing itself by over 50%.

It would also overcome the restrictions caused by the tunnels, since oversize vehicles and hazardous

loads would have unrestricted access to the new bridge, whilst the tunnels would be available for cars

and light goods vehicles, thereby speeding up traffic flows.

This would immediately remove the underlying causes of the congestion (capacity restrictions and

tunnel restrictions) and would get the traffic flowing again, thereby reducing pollution significantly.

It is noted that the cost of this option was given as £1.25bn in the 2013 consultation.

In May 2014, Jacobs AECOM published a further Lower Thames Crossing study, in which Module 3

focused on the cost of junction improvements at junction 30 and widening of the A282 north of the

crossing, and Module 4 which focused on widening the A282 between junction 1a and junction 2. The

most likely costs of these works were estimated to be £402m for Module 3 works and £439m for

Module 4 works.

This would increase the total cost for Option A, including junction improvements and road widening,

to £2.1bn.

However, we note that in the 2016 consultation, Highways England has increased the cost to £3.365bn.

They have done this by adding in further junction improvements, and the replacement of major

overbridges at junction 1a and at the B260. Both of these are unnecessary works.

We believe that Highways England has deliberately exaggerated the scope, cost, and difficulty of

Option A at Dartford in order to make it appear less attractive, and that the work could realistically

carried out for far less than the £3.365bn stated.

We TEND TO AGREE with Option A, an additional bridge at Dartford.

In view of the fact that Option C does NOT address the traffic volumes and capacity constraints at

Dartford, it is inevitable that this work would still need to be carried out even if a crossing east of

Gravesend was built.

It is therefore essential therefore that Option A, an extra bridge at Dartford, is built in preference to

Option C east of Gravesend.

However, there is a better solution which obviates the need for either Option A or Option C, which

provides a strategic, 21st century solution to a 20th century problem.

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7.0 OPTION A14 – THE TOTAL STRATEGIC SOLUTION

Highways England has already dismissed an option which would not only provide significant additional

capacity for traffic travelling to and from the Channel Ports but would also provide relief for other

traffic using the M25, while relieving traffic and pollution at Dartford by at least 40%.

This is known as Option A14, which provides for a 3 lane dual carriageway, mainly in tunnel, linking the

M25 just south of junction 2 with the M25 just north of junction 30.

It would increase crossing capacity by 75%;

It would finally 'complete' the M25, which has never been completed. Is it not about time this

was achieved? Neither Option A (an extra bridge at Dartford) nor Option C achieves this;

At the moment, all M25 traffic still has to use the A282 between junction 2 and junction 30, and

will continue to do so even if an extra bridge or tunnel is built alongside the existing crossing at

Dartford, and even if a new crossing is built east of Gravesend;

With this solution, M25 through-traffic (including traffic travelling to and from the Channel Ports

via the M20 primary route) would no longer use the A282 or the existing crossing; neither Option

A or Option C would achieve this;

The A282 would revert to its original intention, ie to carry non-motorway traffic between the A2

and the A13;

It provides a true motorway-to-motorway link, Highways England's clear preference; Option C

does not achieve this for traffic travelling via the M20, and M2 traffic still needs to use the A2,

the A228, or the A229 to get to and from the Channel Ports;

It provides a high degree of resilience, providing an alternate route without the need for lengthy

diversions;

It provides a massive reduction in traffic through junctions 2, 1B, 1A, 30, & 31, far more than

would be achieved by Option C; Highways England estimates that traffic on the A282 and the

existing crossing would be reduced by 40% - we believe it may be more;

It would result in a massive reduction in noise and pollution through the populated parts of

Dartford, far more than would be achieved by Option C, and without spreading it to others;

5 or 6 miles of vehicle emissions can now be 'captured' and filtered and/or directed away from

population centres;

It does not interfere with the existing bridge or tunnels, and there would be minimal disturbance

to the existing approach roads while the construction work is carried out;

There would be no need for Option C, or the link roads and new intersections, or the associated

pollution and environmental damage;

There would be no need for the A229 variant;

There would be no need for a new bridge at Dartford either;

No buildings would need to be demolished;

It would be a 'Win-Win' for Dartford & Gravesham, and for the national economy;

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It would cost less than the combined cost of Option C and a bridge at Dartford, which Highways

England’s traffic forecasts clearly demonstrate will be needed.

This is the only solution that would complete the M25, provide massive relief for the people of

Dartford, and avoid further pollution and environmental harm.

Highways England estimates that the cost of this option would be around £6.6bn. This estimate seems

high in comparison to the costs of other tunnel projects that have been carried out around the world.

It is certainly very high in comparison to the £6bn estimated cost for the proposed 18 mile dual

carriageway Trans Pennine tunnel, which was the subject of a recent Highways England report.

But even at £6.6bn, it is less than the estimated combined cost of the proposed crossing east of

Gravesend and providing additional capacity at Dartford, which Highways England’s own traffic

forecasts show will still be needed even if a new crossing at Gravesend is built.

Highways England forecasts that Option A14 would attract 40% of traffic from the existing crossing, far

more than the 15% which would be achieved by Option C. However, Highways England’s estimate of

40% would suggest that 60% of all traffic using the Dartford Crossing either joins or exits between

junction 2 and junction 30. This estimate needs to be corroborated. Observed experience from regular

users suggests that this through-traffic estimate of 40% is understated; there is a general belief that

the proportion of traffic which is genuine through traffic, ie travelling beyond junctions 2 to 30, is at

least 50%.

This would have a significant positive impact on value for money BCR.

Highways England estimates the BCR for this Option A14 at just 0.4 to 0.8. There is no proper

information to support this, and this estimate should be treated with scepticism.

We suspect that Highways England has not taken into account the full effect of the savings in time and

congestion for through traffic on the M25, which would include traffic travelling to and from the

Channel Ports via the M20 primary route. It may not factor in the savings in other traffic using the

crossing to and from the A2 and A13 due to the reduced congestion.

We do not believe that it has taken full account of the pollution savings from the removal of up to 50%

of the traffic from the populated areas adjacent to the A282.

In any event, Highways England’s BCR calculations need to be treated with scepticism. We have seen

how the BCR for Option C has been doubled from 1.9 to 3.8 since 2013, even though there has been

no fundamental change in the design and economic factors affecting that option. There is no

satisfactory explanation for this, and we suspect that the BCR for Option A14 may have been

manipulated to reduce its attraction.

Nevertheless, we believe that Option A14 is the only route which addresses at the problems at

Dartford, as well as providing additional capacity, resilience, and reduced congestion and pollution.

Not only does it provide a true motorway-to-motorway connection for cross channel traffic, it

completes the final link in the in the M25 Orbital Motorway, and provides a strategic solution to the

national motorway infrastructure, rather than a tactical solution to address a regional problem.

We STRONGLY AGREE with Option A14, a tunnel linking the M25 to the M25, and recommend that

the Government invests in this solution.

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9.0 SUMMARY

We consider that the Consultation is flawed and discriminatory.

Consultees have been misinformed and denied a proper choice of options. There has been conflicting

information given out by Highways England and Government Ministers. This conflict of information

brings the integrity of the whole consultation process into disrepute.

We believe that the delays in providing hard copies of the consultation booklets and questionnaires

has resulted in insufficient time being allowed for the consultation. We also consider that the

consultation has been discriminatory against older and non-IT literate people in contravention of the

Equality Act 2010.

We believe that the consultation is biased and has been engineered to produce the result that

Highways England has predetermined. The consultation booklet is little more than a one-sided sales

brochure for Option C, and it is not reasonable to expect people to wade through volumes of

documentation to reach an informed decision.

Abridge2far is prepared to support any legal action taken to challenge the consultation process.

Highways England has decided to do nothing to address the problems at Dartford, but merely to create

a new set of problems east of Gravesend instead.

Option C does not address the problems at Dartford. Even if a new crossing east of Gravesend was

built, traffic volumes at Dartford will be back up to current levels within one to two years of it opening.

This information was not published in the consultation booklet.

A crossing east of Gravesend will do nothing to provide an alternative route for traffic travelling

around the M25 Orbital Motorway, nor will it provide ‘resilience’ in the event of an incident at

Dartford. It will do little to promote economic growth in the region.

We STRONGLY DISAGREE with Option C East of Gravesend.

In view of the wide disparity between the 2013 BCRs and the 2016 BCRs for Option C, we have serious

doubts about the figures quoted by Highways England, and would advise extreme scepticism.

The Eastern Southern Link (ESL) has absolutely no merits whatsoever. It blights an AONB, it destroys

ancient woodland and an SSSI, it destroys grade 1 and grade 2 agricultural land, and blights and divides

an ancient village community.

We STRONGLY DISAGREE with the Eastern Southern Link (ESL).

Despite the technical advantages that the Western Southern Link (WSL) has in comparison to the ESL,

we cannot support the WSL since it does not address the problems at Dartford, and is only marginally

less environmentally intrusive than the ESL.

We STRONGLY DISAGREE with the Western Southern Link (WSL).

We strongly oppose any junction on the A226 on either route.

Option C does not address the problems at Dartford. The quickest and cheapest way to increase

capacity at Dartford, in order to get traffic moving and reducing the delays and pollution, is to build a

bridge adjacent to the existing one.

We TEND TO AGREE with Option A, an additional bridge at Dartford.

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We believe that Highways England has deliberately exaggerated the scope, cost, and difficulty of

Option A at Dartford in order to make it appear less attractive, and that the work could realistically

carried out for far less than the £3.365bn stated.

It is clear from Highways England’s own traffic forecasts that even if a new crossing is built east of

Gravesend, an extra bridge at Dartford will still be needed.

But for a total solution, we believe that Option A14 is the only route which addresses all the problems

at Dartford, as well as providing additional capacity, resilience, and reduced congestion and pollution.

Not only does it provide a true motorway-to-motorway connection for cross channel traffic, it

completes the final link in the in the M25 Orbital Motorway, and provides a strategic solution to the

national motorway infrastructure, rather than a temporary solution to address a regional problem.

We STRONGLY AGREE with Option A14, a tunnel linking the M25 to the M25, and recommend that

the Government invests in this solution.

We attach a table which provides an illustrative comparison of the relative benefits for Option C,

Option A, and Option A14 for your consideration, and we would ask you to give this serious

consideration.

In the longer term, the Government must consider other ways in tackling the ever-growing volume of

freight on the UK highways infrastructure. It cannot be allowed to continue unabated while we

continue to concrete over the countryside.

We need to take a more holistic approach, which could include transferring freight onto rail, and the

use of shipping, and ferry ports other than Dover.

Otherwise we will be looking at widening our motorways to 5 or 6 lanes, and will be considering yet

another Lower Thames Crossing in 25 years’ time.

Yours faithfully

Bob Lane

For and on behalf of Abridge2far

See Attachment.

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Illustrative Comparison of Relative Benefits for Option C, Option A, and Option A14

Option C – a new crossing east of Gravesend

Option A – an extra bridge or tunnel at Dartford

Option A14 – a long tunnel from M25 to M25

Provides additional capacity at Dartford

No Yes – 50% Yes – 75%

Relieves congestion on the A282 at Dartford

Minimal. Traffic volume is forecast to be 98% of current level

Yes, by providing additional capacity on the Dartford crossing

Yes, by providing additional capacity and removing 40% of traffic

Completes the M25 No No Yes

Addresses tunnel problems at Dartford

No – the problems at Dartford remain

Yes – provides alternate route via a bridge

Yes – provides alternate route via tunnel

Segregates motorway and non-motorway traffic

No No Yes

Provides a motorway to motorway connection to the Channel Ports

No – M2 does not link to the M20 or the Channel Ports

No, but provides easy access to the M20

Yes – via M25 and M20

Provides resilience/alternate route

Partial – lengthy detour required but will result in gridlock

Local resilience provided by tunnels

Yes – provides full resilience with no detour

Reduces noise and pollution at Dartford

Minimal reduction at Dartford

No reduction in noise – but reduced pollution due to less congestion

Massive reduction in noise and pollution

Introduces noise and pollution east of Gravesend

Yes No No

Destruction to Green Belt, SSSIs, AONB, grade 1 & 2 agricultural land

Yes No No

Demolition of property 10 properties ESL 4 properties WSL

Minimal residential but bridge may result in commercial demolitions

None

Cost £3.72bn plus £3.4bn to relieve congestion at Dartford, total £7.1bn

£3.4bn (£2.0bn if 2014 AECOM Modules 3 & 4 proposals are chosen)

£6.6bn