Silvertown Tunnel

Representations received regarding Silvertown Tunnel

The list below includes all those who registered to put their case on Silvertown Tunnel and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
Adam Deal
"Please build this and many more crossings asap. East London desperately needs more river connections for road, DLR, bikes and pedestrians."
Members of the Public/Businesses
Ann Galloway
"As a resident of Charlton i am concerned that South and London are separated by one unreliable tunnel. I work in East London and have spent hours queuing unnecessarily over 30 years. I have seen cars spuing out exhaust when stationary. This is bad for all especially children and bad for jobs. We need an outlet for traffic when one tunnel is blocked. The new tunnel needs to be built ASAP along with other crossings at the same time. Care needs to be taken to ensure that approach roads are widened so they do not clog up.people who live in SE7 or SE10 or E1 or E14 should not have to pay as it is a local road for them."
Members of the Public/Businesses
Anna-Frevisse Dearsley-Hitchcock
"That the proposed Silvertown tunnel should not go ahead. There is no benefit to be gained, and pollution - when London's air is already poor quality - will be hugely detrimental to the area. There is no proof that traffic will be relieved. "
Members of the Public/Businesses
Charlie Finch
"I live very close to the Rotherhithe Tunnel (south entrance). I am therefore very supportive of any project that relieves congestion and pressure on the Rotherhithe Tunnel. Currently long queues for the tunnel can make it difficult for me to drive around the local vicinity as I get snarled up in the congestion even if I am not using the tunnel. The traffic also creates pollution. However, I am concerned about the suggestion that tolls will be increased on the Blackwall Tunnel in advance of the opening of the new tunnel. That can only make the problems for the Rotherhithe tunnel worse. Please could you consider residents such as myself who will be impacted by any negative knock-on effects for the Rotherhithe Tunnel. "
Members of the Public/Businesses
Clare Ensing
"I would like to have a new river crossing over the River Thames, in East London. I live in Forest Gate and I often drive across the river. I have only three places where I can cross the river: the Blackwall Tunnel, which is often heavily congested, the Woolwich Ferry, where waiting times can be very long, and the Dartford Crossing, which is a long way from where I live. The roads between my home and the Dartford Crossing are also often very congested. I think it is unfair that the people who live in East London have so few options for crossing the river, when people in West London have many options. Having a new river crossing would be better for individuals like me, better for people who live near the Blackwall Tunnel and have a lot of pollution in the air and better for business, because travel will be easier. I think it would be reasonable to pay a small toll to use the new crossing, just like the Dartford Crossing has a toll."
Members of the Public/Businesses
Corporation of Trinity House
"Trinity House is the General Lighthouse Authority for England and Wales. We would be interested in any aspects of the proposed scheme and the construction phase which may have the capacity to affect the safety of navigation in tidal waters. We note that the proposed scheme includes plans for the construction of a temporary jetty and associated works in the tidal Thames. We wish to register as an interested party and examine the possible effects of the project and the construction phase on the safety of navigation."
Members of the Public/Businesses
Damian Aune
"Although more crossings in the east are desperately needed I would question the wisdom of building one where there is already a crossing. The area is already blighted by the pollution and traffic levels of being one of only 3 solid crossings east of Tower bridge. Additional capacity will simply make it worse in the Blackwall and Greenwich areas. Any future crossings should be built in area's that do not already have one, to share the load rather than concentrate it."
Members of the Public/Businesses
David Barrett
"Wish to support the desperate need for an additional road crossing in near east London to ease the unacceptable gridlock of Blackwall tunnel. "
Members of the Public/Businesses
David McLaren
"Impact of resulting traffic in Royal Docks, Silvertown, Beckton and the surrounding areas.An area that cannot cope with the traffic it already has due to the inadequacy of the A13"
Members of the Public/Businesses
Dr Mary Mills
"I was local Cllr for Greenwich Peninsula 2000-2014 and have written books etc on the area I have concerns about the bad effects of the tunnel on regeneration and community issues in East Greenwich and the Peninsula. The area does not need what is essentially a by pass main road. Efforts should rather be put into finding alternative crossings for heavy goods vehicles and others not originating from SE London, improving north/south public transport links, and thought through use of the 'old' Blackwall. Current plans will not help this new community to build but increase tensions and barriers."
Members of the Public/Businesses
Duncan Galloway
"I am a local resident who drives and regularly crosses the river. Blackwall tunnel is not sufficient for this area. "
Members of the Public/Businesses
Elizabeth Green
"I wish to know how the area will be affected during the building of the tunnel and how thus may affect the traffic and health of the local population. "
Members of the Public/Businesses
Eric Manners
"The proposed tunnel would worsen air quality, increase carbon emissions, and after a possible brief initial reduction in traffic congestion would eventually increase the time spent by Londoners stuck in traffic. We can only make London a better place by making better use of existing road infrastructure, and increasing public transport and cycling/walking infrastructure. Travel demand management measures have not been explored to make better use of existing river crossings, and to reduce unnecessary private vehicle trips on them. This proposal is an anachronism and a huge waste of money making London a worse place to live, work or visit."
Non-Statutory Organisations
Gasworks Dock Partnership
"I am writing on behalf the registered charity Gasworks Dock Partnership to indicate our wish to be registered as an interested party so that we may better understand how this project will impact on the local communities we serve and in particular the vehicle movements on Manor and Cody Road, Bidder and Stephenson Street, with regards to the Line, Bow Ecology Park and new Leaway footpaths."
Members of the Public/Businesses
Hamed Shahbakhti
"-I live in southeast London, an area deprived of river crossings, and therefore I believe I have a voice that should be heard. -Most of the routes I need involve crossing the river into north London. -The tunnel is not fit for puropose, and a large amount of time is spent stuck in traffic. -The southeast has very limited river crossings which are insufficient. -The toll associated with the Dartford crossing ultimately leads to overuse of the Blackwall Tunnel. -It is unacceptabele for the Silverlink tunnel to also require a toll, as this will still not ease congestion on the Blackwall Tunnel as many will still opt for the free crossing. -To charge for the Silverlink and Blackwall tunnel will be extremely unfair, as this means all crossings in the southeast will require a charge, whilst the southwest has multiple free crossings."
Members of the Public/Businesses
Ian James Seale
"Whilst I approve of a 3rd Tunnel at Blackwall/Silvertown, I object in the most strongest terms to a Toll being levied at the crossing. There is massive discrimination for those wishing, or indeed needing, to cross the Thames to the East of Tower Bridge/Rotherhithe. Until such time as a Toll is applied to Tower Bridge, London Bridge, Southwark Bridge, Blackfriars Bridge and all other bridges to the West of Blackwall, there should be no Toll at the Blackwall/Silvertown Crossing"
Members of the Public/Businesses
Jam Anderson Mulcare
"As a resident of Woolwich, I am in support of the Silver Town Tunnel for a number of reasons: 1) There are far too few river crossings in the east of London (east of Tower bridge) to support the strong economic development required in the area. 2) The Black Wall Tunnel which is the main method of crossing the Thames is not fit for purpose - it is often congested, closed and can no longer handle the volume of traffic using it. 3) The lack of additional crossing has severely affected the level of pollution in the area as the periods of congestion with cars idling have grown grown longer and more frequent. 4) There is a large amount of residential development that is on going and forthcoming in the area between the Black Wall Tunnel and the Dartford Bridge - the level of infrastructure provided is inadequate to deal with this. 5) Some of the areas of between the Black Wall Tunnel and the Dartford Bridge are amongst some of the most deprived areas in London - these cannot be continued to be cut off and deprived of the opportunity to develop economically and socially 6) The investment in infrastructure across London must be balanced and humane and continued under investment in the East of London will have serious social and economic consequences nationally."
Members of the Public/Businesses
Jan King
"This scheme will increase traffic and further increase pollution in the area which is already above EU recommended limits. The health impact on the area will be adverse. Better public transport across the river is needed rather than a road crossing."
Members of the Public/Businesses
Jane Burch
"I am worried about the environmental impact of the silver town tunnel and the increased traffic that will result in the nearby area. The method of paying for this is also a problem. People who cross the river in east London will be charged to cross the river, while those living in west London will not have to pay."
Members of the Public/Businesses
John Zhang
"we need a new tunnel, as blackwall tunnel is not capable to cope."
Members of the Public/Businesses
Johnathan Phan
"1> I wish to know what tolls will be enforced or how much public money is being spent in order to build this tunnel. Want a clear break down of what is being spent on what or more accurately, I wish to understand how the project intend to be funded. Weather through a Toll, a business loan or tax's. 2> I secondly want to understand what will be put in place to ensure that the extra traffic in the area and the pollution it brings will be countered. IE, how many more tree's/green spaces will planted/made and where they will be placed."
Members of the Public/Businesses
Katharine Frord
"I wish to be included in and involved in this pallnning process because: I am a local resident. I own a property in the effected area. I run a chairty that is located in the affected area and maintains some 30 full time paid jobs. Transport is very important to our teachers, volunteers and particpants - an alternative to the blackwall Tunnell would be very helpful - there have been many ocasisons when the tunnel has been blocked and it has frozen this part of London and stopped us from doing our work. "
Members of the Public/Businesses
Katherine Wass
"I would like to keep up to date with the silver town plans as an interested party as I live very close to the A2 and the Blackwell tunnel, the traffic to which affects me. I would be concerned if the plans brought further traffic to my area which is already heavily congested and noisy. But would welcome an elevation of traffic through a different tunnel other than Blackwell, if this were to be the case. "
Non-Statutory Organisations
Landscape Architects Association
"The landscape, environmental and visual impact of the proposal"
Members of the Public/Businesses
Leslie Clark
"The tunnel will lead to much increased traffic congestion and pollution on residential roads in Plumstead and Shooters Hill to the detriment of residents' health and environment."
Members of the Public/Businesses
RPS Planning and Development Limited on behalf of Lidoka Estates Limited
"Lidoka Estates Ltd (LEL) is the owner of the site on Boord Street. The site is currently leased to the Royal Borough of Greenwich (RBG) who in turn lease it to The London Evening Standard (TLES) who use it as an Operations Centre to distribute papers all over London. TLES also sub-lease parts of the site to two other businesses. As such, the site is in constant use and provides substantial employment in the area. We support the Silvertown Tunnel project. However, we are concerned about the serious disruption to businesses using the approach to the Tunnel and Millennium Way during the construction process. It is worth stating that these representations respond specifically to the proposals for the Silvertown Tunnel project as shown on the plans submitted by TfL. LEL are aware of the fire that destroyed Studio 338 on 8th August 2016. In the event that TfL chose to revise any plans in light of this event, LEL fully reserves its right to comment further on any revised plans. TfL’s proposals involve using three separate parts of our site, temporarily or permanently. We consider these in detail below. 1. Studio 338 “Fire Escape Land” – Land parcel 01-058 on Land Plans Regulation 5(2)(i) Sheet 1 of 7 – Drawing Number ST150030-MCO-ZZZ-06-DR-XS-0002 Our main concern relates to this plot, which is intended to provide permanent emergency fire access for Studio 338. The Silvertown Tunnel scheme will remove land currently used by the nightclub for means of fire escape. We consider that the replacement route is ill-conceived and will not secure the safety of nightclub customers. We have reviewed the Studio 338 Fire Escape Provision Report by Atkins dated July 2016 (document reference STWTN-ATK-GEN-   -RP-Y-0004 Revision P04). As well as some detailed points, we are not convinced that the capacity assumptions in Section 3.2.2 of the report are realistic as to potential numbers on busy nights. The nightclub has a 3,000-person capacity which is not referenced anywhere in the report. Section 3.4 refers to “stacking capacity”; however, in an emergency a “stampede effect” is much more likely, with everyone desperate to leave. We note that Section 3.4 recommends further analysis before a final design solution is agreed including the option to explore the scope to optimise the width of the perimeter escape route. We are concerned that a wider route could require additional LEL landtake. We also object to TfL’s proposed terms to permanently acquire Parcel 01-58. We would prefer TfL to rent the land needed on agreed commercial terms consistent with the rest of the site. 2. “Temporary Land” – Land parcel 01-047 on Land Plans Regulation 5(2)(i) Sheet 1 of 7 – Drawing Number ST150030-MCO-ZZZ-06-DR-XS-0002 TfL intends to use this land for materials storage whilst constructing the new footbridge over the A102 Blackwall Tunnel Southern Approach. While not seriously impacting TLES as the main user of the site, other businesses using the site will have to find alternative premises from which to operate whilst TfL takes temporary ownership . If it is not possible for TfL to find alternative premises , we would urge TfL to use the site for as short a period as possible and to be precise as to when it will be required in order to reduce disruption and uncertainty for the businesses involved. 3. “Permanent Land” – Land parcel 01-046 on Land Plans Regulation 5(2)(i) Sheet 1 of 7 – Drawing Number ST150030-MCO-ZZZ-06-DR-XS-0002 We understand this land is essential to enable an adoptable public highway access for Studio 338 once the footbridge is constructed. We will consider granting TfL an option to acquire this plot provided always that access to the LEL site in this location is not affected. "
Members of the Public/Businesses
Marcio Da Silva
"I do not agree with the Silvertown Tunnel! - It will create chaos in a already very busy small roads - Due to all construction workers and taxis/minicab drivers parking and waiting to collect passengers plus all the lorries the area is a living nightmare. There is NO enforcement of the parking restrictions. - Due to the council negligence in enforcing the traffic and parking laws, the residents of the area will have several years of a living nightmare from a project that will not benefit the locals."
Members of the Public/Businesses
Marcus Relton
"People living less than three miles from Blackwall Tunnel should not have to pay the same as people using it as a cut through from further away, if there is a toll, which I would oppose. This should be integrated into a solution for cross-Thames connectivity by road with two more bridges downstream, between Blackwall and Dartford. I believe this is planned at Thamesmead and Belvedere/Erith. Why should people living in East London have to pay to cross the river when those further upstream in central and west London do not? Cycling options for crossing the river should be included, either new ones, or shared space in the Greenwich Foot Tunnel, as the cable car is expensive and of limited use for journeys into central London where it is. The plans for Silvertown Tunnel and Blackwall Tunnel should be part of an integrated policy with environmental curbs, like those proposed by the new mayor on emissions but there should be facilities for people to park cars for free or cheaply at stations nearby to reduce congestion and pollution in central London and the area near the roads."
Members of the Public/Businesses
Martin Watts
"i wish the silvertown tunnel to go ahead to completion"
Members of the Public/Businesses
Matthew Pettitt
"As a local resident and road user my interest is in ensuring the planning process takes account of local resident user needs, not least to ensure the scheme does not introduce tolls or charges on roads which do not currently incur such charges."
Members of the Public/Businesses
Maurice Patry
"East London suffers from traffic congestion most of the day, everyday. The Blackwall tunnel is a bottleneck where the queues are often long and getting worse. The Woolwich Ferry provides little relief. And then there is no crossing until the Dartford tunnel/bridge. The substantial new developments at and around Canary Wharf and on the Greenwich peninsula will simply add to the congestion with their thousands and thousands of new homes and and new offices being built. The Silvertown Tunnel is vital if East London is to continue to prosper and grow economically. Without it the area will become unnattractive to residents and to businesses as travel becomes more and more difficult, and the area will start to decline again. We must support the new opportunities that the new homes and businesses will provide. It is a matter of some embarassment that the silvertown tunnel was not started some time ago because now it cannot be ready by the time the new developments are occupied - but better late than never."
Members of the Public/Businesses
Michael Byrne
"The landing points on both sides of the river are not well enough tied into the rest of the road network. As such, this will create grid-lock around those landing points."
Members of the Public/Businesses
Michael Park
"Up to a million people in south east London are cut off from north London and the rest of England for large parts of the week, due to Blackwall Tunnel congestion. Like thousands of others, my family has relations and friends who can only be visited via the tunnel, which should have been augmented decades ago. The ridiculous and unnecessary problems for businesses are obvious. Furthermore, the pollution caused by three lanes of stationery traffic in both directions, for hours every day, adds to London's unhealthy environment that, I understand, TfL has always wanted to combat."
Members of the Public/Businesses
Miles Delap
"That the Silvertown Tunnel will provide much needed relief to congestion in East Greenwich, with associated benefits to air quality and accessibility. That despite significant opposition to the tunnel, not all residents of East Greenwich are against this development."
Members of the Public/Businesses
Mohammed Akthar Hussain
"The application submitted will benefit and ease the congestion of vehicles in the east and central parts of London to cross over to the South. With nearby Blackwell tunnel, at times of rush hour it becomes difficult for commuter to cross, especially when emergency occurs. Just recently commuter were stuck for 24 hours at the Northbound tunnel, so the Silvertown crossing will help to prevent these problems and vice versa."
Members of the Public/Businesses
Mr Joseph Francis Mc Clory
"I believe a new tunnel will aleviate both the traffic and the air pollution "
Members of the Public/Businesses
Mr Neil Smith
"I am a local resident who resides in Greenwich within 500 metres of the town centre and have done so since 2008. I also work at the offices based on Greenwich Peninsula (6 Mitre Passage) and have done so for the past 3 years and my office directly overlooks the Blackwall Tunnel approach road. I commute to work from Greenwich to the Peninsula by a variety of transport modes be it the bus, private vehicle, cycle and I also walk depending on the day. I also use similar modes of transport when travelling in and around London and I am a regular user of the Blackwall Tunnel, (approximate usage twice a month) and have experience at most times of the day and week. In light of the above I consider that I have a reasonable though understanding of the operations of the Blackwall Tunnel. I could highlight my numerous experiences of the impact of Blackwall Tunnel but in summary if the Blackwall Tunnel experiences a minor incident the traffic is impacted as far as Greenwich town centre very quickly circa 15 mins and if a major incident occurs then the whole of the surrounding highway network is grid locked for hours. Given that the Blackwall Tunnel regularly (1000 times a year) suffers from various operational disruptions in varying degrees it is in my view clear that the do nothing option is not an option and therefore given Silvertown Tunnel is the only option available I support the principle of the tunnel as it will reduce congestion on the Blackwall Tunnel approach road and also the surrounding highway network. Notwithstanding the above I do consider that the tolling of the Tunnels is grossing unfair to residents of the Royal Borough and this aspect needs to be reconsidered. In terms of air quality - I feel that the introduction of cleaner vehicles and improved technology over the next few decades will improve the current conditions and hence support the current assessment which concludes little change as a result of Silvertown. Regards Neil Smith "
Members of the Public/Businesses
Mr Zvi Sobel
"I am in favour of a new crossing as the current infrastructure is not able to cope with weight of traffic as I see by the constant jams. I live in NW4 and work in SE6 and need a car for my work so have to drive in every day. Although there is a need for a new tunnel the option to charge for this would directly affect myself and other road users who have to cross on a daily basis."
Members of the Public/Businesses
Naz Islam
"Interested in the project. In favour. "
Members of the Public/Businesses
Nick Eastwell
"East London is crying out for a new crossing to augment the Blackwall Tunnel crossing which for large parts of every day is a constant slow moving traffic jam. That describes a normal day. When an accident or breakdown occurs the whole of south east London becomes gridlocked, very often for many hours. The cost to the economy of this constantly clogged crossing is immeasurable. We desperately need another road river crossing in the vicinity."
Members of the Public/Businesses
Nick Raynsford
"I am making my representation on two bases: 1. As a resident in the area closely adjoining the southern approach to the existing Blackwall tunnel, I am very much affected by the serious problems of traffic congestion and air pollution both of which are attributable to the inadequate capacity of the Blackwall Tunnels to cope with the volume of traffic seeking to cross the river Thames at this point. 2. Having served as Member of Parliament for the Constituency of Greenwich (1992 -1997) and Greenwich & Woolwich (1997 - 2015) I am very well aware of the protracted delays in progressing plans for improved river crossings in this area, and am keen that the long-overdue additional crossing now proposed is expedited. In my view the new Silvertown link is essential for a number off reasons: a) to improve accessibility across the river Thames b) to reduce the unacceptable current levels of congestion which occur on a daily basis and at times have much wider impacts on traffic movement in the surrounding areas c) to reduce the levels of air pollution generated by stationary or slow-moiling traffic waiting to cross the river at this point d) to help economic development in South East London by making it easier for existing businesses to deliver their goods and services, and making it more attractive for new business start ups or relocations in this area e) to improve cross-river public transport services by facilitating cost-river bus services. Currently only the 108 service crosses the Thames east of Tower Bridge, and this is restricted by the height of the tunnel to a single deck service. I believe it is both appropriate and desirable for a toll to be charged for using the new Silvertown Link and the existing Blackwall Tunnels. This should be set at a level which is comparable to the toll charged at Dartford (to avoid any displacement effect between the two crossings) and sufficient to deter unnecessary use of the crossings, so as to avoid the risk of traffic volumes rising to a point where congestion problems recur. I believe it will also be essential for new traffic management arrangements to be put in place along the Woolwich Road and Trafalgar Road leading to Greenwich Town Centre to mitigate potential displacement from the Blackwall crossing once tolling is introduced there. I trust that you will approve the proposed Silvertown link without further delay. I am happy to appear in person and give additional evidence if you would find this useful."
Members of the Public/Businesses
Pamela Winders
"Environmental issues including pollution problems in Greenwich"
Members of the Public/Businesses
Paul Humphrey
"Agree with the crossing but I feel that it should be alongside Blackwall tunnel where all of the infrastructure is in place."
Members of the Public/Businesses
Peter Brown
"The plans make serious assumptions about traffic reduction to be the outcome of imposing a toll. My belief is that motorists will simply pay the toll and traffic will not be materially reduced; indeed with faster crossings, it may well increase. The concept of tolling crossings east of Tower Bridge is unreasonable bearing in mind that other London residents further west are not charged at all."
Members of the Public/Businesses
Peter Cope
"I regularly travel through East London (Eltham to Snaresbrook) during the week and understand first hand the problems of crossing the river at Blackwall. The points I want to make include: 1. Time wasted for individuals and collectively by those trying to cross the river in this area 2. The environmental impact of slow moving vehicles in this area, unable to cross the river in a timely and effective manner. 3. The detrimental effect of the lack of capacity on commerce and business that needs to cross the river in this area. "
Members of the Public/Businesses
Rajiv Rankan
"Having just bought a property in Greenwich and having moved from North of the river (Isle of Dogs) to south of the river - Greenwich my commute for work/leisure/social life is now dependant on the traffic of the Blackwall tunnel. It takes a 45 mins to 1hr: 30 mins during peak traffic the same journey which I complete in 15-20mins in off-peak hours. Hence any plan that is going to share or distribute the traffic I would be personally interested in that. Secondly, the chaos or road closures during the construction of the proposed tunnel until its completion would impact my daily life, hence I consider myself an interested party."
Members of the Public/Businesses
Rebecca McCullough
"I live in the borough of Greenwich and believe that we need an additional river crossing to ease traffic congestion."
Members of the Public/Businesses
Richard Allen
"I will provide my views on the location and design."
Members of the Public/Businesses
Richard JS Bucknall
"The current long delays in the approaches to the Blackwall Tunnel are unacceptable, reflecting a huge waste of time ,hinder the development of the local economy and cause unnecessary congestion and pollution"
Members of the Public/Businesses
Richard Speller
"In favour of application "
Members of the Public/Businesses
Robbie Moore
"I intend to make a representation regarding the proposed charging of motorcycles to use the Silvertown tunnel. The basis of my representation will be centred around the apparent contradiction within TfL's rationale for charging motorbikes, detailed in the points below: 1) The intention of the Silvertown Tunnel, as described by TfL is to reduce congestion; 2) motorcycles will be charged to use the tunnel, despite not representing a significant cause of congestion within London."
Members of the Public/Businesses
Robert Hicks
"I do not agree with the crossing. It will push more traffic into the area of Eltham, which has a high density of schools and young children. Spending the money on river crossings for a new tube line or further DLR extensions would be best."
Members of the Public/Businesses
Roger Tester
"I am very much supporting the proposal for Silvertown Tunnel which I believe is vital for the area and will relieve traffic congestion particularly on the southern approach My only concern is the level of capacity for extra public transport links which I think needs to be increased "
Members of the Public/Businesses
S.A. Wood
"Environmental issues mainly. Traffic management. Visual amenity."
Members of the Public/Businesses
Simon Antoine
"In principle I am in support of the tunnel, since I believe it will bring new prosperity and jobs to the area, however! The quality of life of the local residents must be respected, and the impact to health, traffic and pollution (both noise and air), must be carefully assessed, understood and shared with the local people who will be impacted by this development. If it's ill conceived don't build it"
Non-Statutory Organisations
South East London Chamber of Commerce
"That the new crossing is urgently needed to reduce traffic problems in South East London. That it should be in conjunction with further crossings to the East of the capital.. That the proposed tolling is an unfair tax on East and South East London residents and businesses."
Members of the Public/Businesses
Stephen Boatright
"The outline of the main points that I wish to make will be: 1. The effects of increased traffic flow on levels of air pollution in the borough of Tower Hamlets and surrounding boroughs 2. The effects of increased traffic flow on road congestion in the Borough of Tower Hamlets and the surrounding boroughs 3. The provision for cyclists on this river crossing 4. The provision for powered two wheelers on this river crossing 5. The encouragement, by differential tolls, of electric vehicles using the river crossing 6. The effect on drivers and other vehicle users (including bus passengers) of air pollution within the tunnel when moving slowly or waiting in stationary traffic."
Members of the Public/Businesses
Stephen Brundish
"I feel the tunnel needs to be built as soon as possible to improve the links between North and South London which have for so long been needed to improve the ever growing traffic flows and invigorate the plan for a city in the east. Hopefully this will be the first of a string of bridges and tunnels which will help make London more cohesive and break down the North South divide that inhibits economic growth and social interaction."
Members of the Public/Businesses
Stephen Tribble
"As some one who lives on a bus route with 3 buses passing my house, north and south , every 10 minutes, that means 36 an hour. Will the 108 bus be able to redirect and use the silvertown tunnel. Also, when will TfL enforce diesel free buses in London? Also, when will buses more than 10 years old be taken off the road?7"
Members of the Public/Businesses
Stewart Walker
"I feel that the proposal to charge for both the Silverton Crossing and Blackwell Tunnel is hugely unfair to those living in the East of London - it effectively means that to travel from south to north has a premium of over £5 whilst those in the West can do this for free. This is in addition to the poorer public transport links available. Either making the tunnels free of if necessary introducing a charge on all London river crossings would be much fairer."
Members of the Public/Businesses
Thomas Greenwood
"I intend to explain why I do not agree with the building of the Silvertown Tunnel and I will outline several reasons for this, including (but not limited to) the negative environmental consequences, health consequences, the deleterious effect on traffic and transport in the local area and the impact on the character of the local area."
Members of the Public/Businesses
Tom Killick
"I believe this scheme will be environmentally damaging, in common with other such road-building projects."
Members of the Public/Businesses
Tom Kirk
"Please build a new river crossing?"
Members of the Public/Businesses
Yonatan Higgsmith
"I worked on developing a documentary about the Silvertown Tunnel and have chatted with numerous experts about the value of the project - I would very much like the opportunity to take part in examining the evidence and case for the tunnel and providing an opinion based on my research."
Members of the Public/Businesses
Andrea Carey Fuller
"Measurements of harmful nitrogen dioxide levels have been taken all across London and I know from participation in local Neighbourhood Forums in both Lee Green and Deptford that the current levels of air pollution caused by traffic - especially diesel near the *Blackwall Tunnel Approach have been recorded at a level of 110 micrograms per cubic metre, nearly THREE TIMES THE E.U./UK regulation limit of 40 micrgrams per cubic metre - which as we all know is causing over 10,000 deaths from air pollution across London EVERY YEAR! (*http://www.newsshopper.co.uk/news/11038665.New_Cross_Road_and_Blackwall_Tunnel_among_most_polluted_roads_in_the_country/) With air pollution in London at these astronomical illegal levels, we should be focusing on making public transport improvements outside Central London, such as the Bakerloo Line extension to reduce the need for private cars. We need to cut down on car use and stop building roads for cars in and around London. We need more bridges for pedestrians and cyclists and over-land trains or tram networks (some of which may still exist from infrastructure dating back to the 1950's) to encourage people to find healthier and easier ways to travel rather than depending on cars. Improving Air quality is essential to the survival not only of ALL people but our planet - as air pollution is also a large contributing factor to Climate Change. As you undoubtedly know, traffic increases with every road built; and it will be no different with the silver-town tunnel if this goes ahead. The impact upon Public transport on the roads is horrific - bus lanes are jammed and children and vulnerable people are most likely to suffer chest diseases as a result of this increase in traffic - building a tunnel for private cars including the influx of Uber vehicles which aren't being controlled is only going to make things worse. Solutions lie in other directions - as Clean Air, No to Silvertown Tunnel, Friends of the Earth, the Green Party and a host of other Organisations have been saying all along. Isn't it about time that People's welfare was put before Profits made from these enterprises - as a mother of a teenage child - I think it is. "
Members of the Public/Businesses
Andrew Beswetherick
"The proposed tunnel will in my view only increase the amount of traffic feeding into the Blackwall tunnel and its feeding roads which are already at full capacity. There is much research to show that increased road building increases traffic. It is estimated that around 9,000 deaths a year are attributable to motor vehicle pollution in London therefore greater use of motor vehicles on already highly congested roads will serve to cause more deaths as the pollution from motor vehicles and congestion will increase. A better alternative would be to focus on a river crossing for pedestrians and cyclists which would take traffic people off the already congested and highly polluted roads. "
Members of the Public/Businesses
Anum Arif
"I think I am in the favour of the tunnel."
Members of the Public/Businesses
Brian Wharf
"Keen for the process of building at least one crossing within the 10 years."
Members of the Public/Businesses
Centre for Sports Technology
"I understand that as part of this proposal, funds are to be generated by imposing tolls on the Blackwall Tunnel. This is totally unacceptable. That tunnel was built before there were any motor vehicles in London. It has been a nightmare for decades and in the last few years, it has rendered any journey in London that involves using it a total lottery. It must have cost my company alone thousands of pounds in wasted time and fuel in jams. To impose a charge for this experience would be an insult beyond belief. "
Non-Statutory Organisations
Charlton Rail Users' Group
"Charlton Rail Users' Group has widened its remit and now engages with Transport for London (TfL) over bus services and road schemes. Our representation will cover the effect of the Silvertown Tunnel on local roads and public transport, including bringing to light evidence that may not have been considered before. "
Members of the Public/Businesses
Christopher Dyson
"As a resident of the lime house area i have an interest in this development "
Members of the Public/Businesses
Daniel Wilson
"I am very surprised that this proposal is still being actively considered: it should be scrapped immediately. It is a well established fact that simply increasing road capacity generates more road traffic (in the absence of some alternative system of incentives/disincentives). This scheme will have a huge adverse environmental impact on the area in which I live – which is already enormously clogged with traffic and which has extremely poor public transport provision. The launch of CrossRail – in 2019!! – will do something to help the riverside communities of east London, but this is still a drop in the ocean. The bus network in Newham is completely overwhelmed by the enormous population surge, the tube and the DLR are unable to cope with the numbers using them, and the road network is at a complete standstill most days. Instead of a new road that does not help this area – and is only wanted by hauliers – we should be investing money to get people OFF THE ROADS and OUT OF THEIR CARS. Lorries and HGVs should be disincentivised and eventually banned from entering the area inside the M25 – like happens in Paris. I am a driver myself and dread the prospect of using the Blackwall or Rotherhithe Tunnels but a new crossing which will be tolled, will only increase congestion in the rest of the network. Has the impact been properly assessed? Have communities on both sides of the river been consulted? Has the impact on cyclists, on pedestrians, on local business and schools, pollution levels and accidents been modelled or investigated? Nothing in this proposal suggests this has been done adequately and I urge you to block this proposal and instead to suggest an integrated approach to the traffic and congestion issues of east London – which this scheme does NOTHING to address realistically or sustainably. This is like a throwback to the 1980s and should be stopped. We know more about urban planning and transport than in the past and so this plan must be thrown out. Dr Wilson"
Members of the Public/Businesses
Dartforce Limited
"We are a property maintenance company who service residential housing sites either side of the thames but are based in the Royal Borough of Greenwich (Eltham) our staff spend a considerable time queueing either northbound or southbound at various times of the day. We waste thousands of pounds each year in tradesmans time and fuel for our vehicles and are unhappy about the pollution being generated. The situation is so poor that we give our staff trapped across the thames by the Blackwall tunnel an additional 30 mins time to cross which his a serious negative impact on our profits. We wholeheartedly support the building of the new tunnel."
Members of the Public/Businesses
Dr Valerie Wilson Trower
"As a local resident, I am concerned that the tunnels will increase the road usage, and that should there be an accident which would immediately cause traffic congestion, there will be no means by which emergency vehicles could reach the tunnel/s affected from the south side as the Peninsula is an isthmus. Far better to build the tunnel/s in a location in which emergency supplementary access is assured. Secondly, I strongly object to the proposal that use of the Silvertown tunnel and the existing Blackwall Tunnel incurs a toll. This penalises residents of East and South East London, whereas residents of West London, cross a bridge for free. (Second rep submitted 17 August below) Given that the Blackwall tunnel is already accessed from an isthmus with limited emergency access to the south, it seems foolhardy to add to the traffic burden in the event of a major incident by adding a second tunnel which shares the same access roads. In addition, the development of the Peninsula for new densely built housing (15000 homes in total) will increase the traffic at all access points from the Blackwall Tunnel approach roads to the new development. This will conflict with the traffic attempting to access the existing tunnel and the new tunnel resulting in further bottlenecks on all approach roads. In my opinion, it would be far better to replace the existing Woolwich ferry with a new tunnel since the routes to access it are in place and are not constrained by the isthmus."
Members of the Public/Businesses
GES
"I am representing our business 'GES' (Global Experience Specialists). We are full service providers for the events, congress and live stage industry, located on the Royal Victoria Dock within the site of ExCel. Our main interest is how this will effect the local infrastructure and surrounding areas, including journey time adjustments from the North and main motorway connections. "
Members of the Public/Businesses
Gordon Aitchison
"I have concerns about timing and application of charging, in particular charging on routes other than Silvertown Tunnel and charging model disproportionally targeting resident south of the Thames. "
Members of the Public/Businesses
Lyn Juniper-Solley
"I am writing in concern of a residential development located in the proximity of the proposed Silvertown tunnel, predominantly affected by the north of Thames exit (Silvertown side). Whilst very much in support of the additional crossing, and also its location, I have concern for the increased weight in traffic that I believe is likely to increase, taking the route from Silvertown, along the Royal Albert Dock route to the Galleons Reach roundabout, and then turning along Woolwich manor way to re-join the A13. From experience living in this area for 14 years, when there is an incident along Royal Docks Road, or the A13 or just heavy traffic, traffic will detour along this route to join the A13 further along. Woolwich Manor way is a single carriageway road that serves not only Beckton Bus Garage, but a substantial residential area that can only be accessed via this road, via the junction of two small roundabouts. In my experience when such an occasion occurs it can take up to an hour to access this residential area by car due to weight of traffic diverting along Woolwich Manor Way. My concern as a community group representative in this area, is that with additional traffic avoiding the Blackwall tunnel and naturally routing toward the A13/ A406 via this direction, this increased weight in trafiic will become more frequent and likely trapping residents in or out of this estate (Accessed via Ferndale St & East Ham Manor Way) many of whom are key workers ( working at Newham General Hospital for example), or reliant on bus station. I would like consideration to view the wider implications of exit routes or access routes to the north entrance, connecting to A13 and A406,and the impact to local residents of that area, especially in this circumstance. Please reference my address and the route in our out via East Ham manor way as example) "
Members of the Public/Businesses
Mark Barnes
"1. I am concerned that the proposed tunnel will aggravate, not relieve, the current problems of congestion and severe air pollution in the areas to the south of the Blackwall tunnel. 2. The roads south of the Blackwall tunnel are already heavily used and very often congested. The proposal assumes that current congestion is all due to the bottleneck at the Blackwall tunnel. If that were true, then southbound traffic (away from the tunnel), would normally run freely. In fact, afternoon peak traffic southbound away from the tunnel from the Woolwich flyover onwards is often at a crawl, sometimes as far as Sidcup. This indicates that the roads themselves are already at or near capacity. That limited capacity is itself a further bottleneck. 3. The Transport Assessment (TA) forecasts a substantial increase in demand for river-crossings, and in the overall level of traffic in the ESR, even without the tunnel – i.e in the 2021 ‘reference case’. That increase could only further overload the roads south of the tunnel(s). The TA touches on the problem but fails to address it adequately. 4. The proposed tunnel will relieve the bottleneck at the tunnel, but not that further bottleneck in the roads to the south: indeed, it will make the problem worse, because in the AM peak the Silvertown tunnel will attract the larger and most polluting HGVs that cannot currently use the northbound Blackwall tunnel, and in the PM peak the extra tunnel capacity will pour the southbound traffic more quickly into a road network that is already overwhelmed. 5. There is no doubt that there is already a substantial problem around the Blackwall tunnel, but it is suggested that there are better methods of dealing with it: a. Add capacity by building extra crossings to the east (Gallions Reach and Belvedere), reducing the load on the A102/A2/A20. b. Reduce closures at the Blackwall tunnel by severely increasing the penalties for over-height vehicles, and consider ‘no-fault’ penalties for those involved in any breakdown or road traffic accident that causes a closure. c. Add provision for pedestrian and (more particularly) cycle crossings: cycling is growing rapidly as a means of commuting. It is a non-polluting means of reducing the demand on the road and PT network. It ought to be at the forefront of planning, but the current proposal offers nothing at all by way of a crossing for cyclists. "
Members of the Public/Businesses
Matthew Meylan
"Please stop wasting money on building this tunnel Please look at the map and how the land lays, building a tunnel there would create a bottle neck clogging and polluting North Greenwich for another 100 years, Please follow the A102 from Westcombe part station, follow the old railway, and go deep then join the A1020. Please don’t build 30000 new homes and schools then add fumes from cars. "
Members of the Public/Businesses
Michael King
"As a daily tunnel user for over 30 years"
Members of the Public/Businesses
Michael Walsh
"As some one who travels around East and South London on a daily basis I suffer enormous delays, inconvenience and frustration from the lack of appropriate cross Thanes crossings in East London. It has been a national scandal that no additional crossings have been built since the 1960s in East London. This is a classic example of government failure which is carrying major adverse economic impacts. Getting additional crossing built quickly is of enormous importance to me personally and for my business and for the people of East and South Lond on and Essex."
Members of the Public/Businesses
Miss Sarah Poole
"I disagree with a toll been implemented as this is unfair to people living in south London it is another tax on people living in south London, to travel to work. Instead of wasting money on a garden bridge why not invest it in the cost of this silvertown tunnel. It will not solve the problem of congestion around the tunnel as people on normal wages who cannot afford another £30 to travel to work will find other routes through Greenwich, old kent road."
Members of the Public/Businesses
Mladen Stariha
"I strongly support the project."
Members of the Public/Businesses
Mr. David Crafter
"I am very annoyed that the proposed new tunnel will be chargeable AND that there will then be a charge on the old Blackwall tunnels,which must have been paid for years ago. This seems yet another way of extracting money from the poor motorist,who already pays tax as road tax,on fuel,on insurance,etc. The tunnel itself will attract more non-local traffic,thus adding to the congestion and poor air quality in the area."
Members of the Public/Businesses
Mrs Elizabeth Angela Guyver
"The roads in the borough of Greenwich are already overloaded with traffic from the coast ports and people travelling into work daily. A tunnel along side the rail tunnel for the Euro Star from Kent to East London would be more useful and take traffic away from the borough of Greenwich. The pollution in the borough must be above the required limits at present and this should be considered when a decision is made. Elizabeth Guyver "
Members of the Public/Businesses
Nick Ely
"I am all for the tunnel as it will make the south more accesible and reduce traffic levels around the wharf and surrounding area. With the new business park being developed and the olympic park/stratford area being promoted it will bring much needed wealth and development to the area."
Members of the Public/Businesses
Peter Lewis
"Impact of noise from vehicles. Pollution of emissions in the environment Cost to users of the tunnel "
Members of the Public/Businesses
Rob Hunter
"That the traffic in and around Greenwich does not increase due to people trying to go through Greenwich to go through the Rotherhide tunnel to avoid paying the fee. also that local residence should be given a reduced price to travel through the Blackwall and Silvertown tunnels such as the residence of Dartford receive for the Dartford Tunnel and Bridge."
Members of the Public/Businesses
Rob McCracken
"I am a frequent user of the existing tunnels and I also live and work in the local area So that's my reasons for wanting to be registered as an interested party. I'm also a health and safety rep for my union so anything that might affect members it would be good to give a comment on "
Members of the Public/Businesses
Sally Hughes
"1. The project as so far developed has been based on an presumptions that are either unrealisable or that misrepresent essential underlying information about, and breach nationally and internationally agreed standards of: - information - consultation - pollution - congestion - child health - expenditure - viability and value for money - environmental resilience Consultation: The initial consultation(s) did not appropriately define the objectives of the project other than to improve the 'resilience' of the Blackwall Tunnel. No information was sought or presented on (1) other methods of improving resilience (shifting large freight to a more appropriate crossing point); monitoring inappropriate traffic more effectively etc; (2) the impact of charging and methods of graduated charging; (3) pollution and congestion outcomes on surrounding areas, including increased traffic. (4) Consultees were self-selected, unweighted and conflicts of interest were not monitored. Pollution: EU limits are already significantly breached on the Greenwich approach and are likely to increase with any projected traffic increase. Similar considerations apply to Congestion and Child Health. A meaningful consultation and consideration of the project must include estimates of morbidity associated with the crossing, consequences of tunnel failure following construction, a full survey of impacts on the surrounding population of increased traffic circulation. The same applies to the redevelopment of the Greenwich peninsula, now including a far higher residential population and consequent child yield. Expenditure is now put at £1bn. The consultation should consider alternative uses of these funds to control use of the existing tunnel and divert road traffic to alternative routes and modes of transport. "
Members of the Public/Businesses
Selima Rollins
"There are very few crossings in the south east which is economically deprived. The Blackwall tunnel and Woolwich ferry could just the relief of having another free crossings that the people who live in the and work in areas where house prices make it seem as the people are more well off than they are. I am all for charging for the building of the new tunnel but once built there needs to be another FREE crossing in the south east. West London has its fair share of free crossings. "
Members of the Public/Businesses
Shawm Kreitzman
"My strong feeling is that another tunnel in East London is a very bad idea. West London has multiple bridges, which provide easy access for pedestrians and cyclists, as well as cars. The fact that this does not extend to the East End makes it very difficult for East Londoners to get across the river; especially if they don't drive. Tunnels also have many unique problems. An accident or breakdown inside a tunnel is very dangerous, and causes huge congestion and chaos. Motorcyclists in particular are very vulnerable in a tunnel, and it can be difficult (or even impossible) for emergency services to get through if needed. East London desperately needs better access across the river, but a new bridge would be a much better solution. London's poorest residents (many of whom live in North-East and South-East London) often don't have cars. A tunnel will do absolutely nothing to help them."
Members of the Public/Businesses
Stanley Ginsburg JP
"The sooner the better"
Members of the Public/Businesses
Susan Boner
"The A2 narrows dramatically between Kidbrook and Blackheath and already causes major hold ups on the approach to the Blackwall Tunnel, an additional tunnel will bring more traffic into Greenwich on a road that is unable to cope with the existing traffic. We already notice that when the Dartford tunnel is closed for any reason the towns and villages between Dartford and Greenwich are completely gridlocked with traffic attempting to access and alternative route. Just recently children missed GCSE's and people were late for work, holidays missed through being unable to commute to the airport because the Dartford tunnel was closed plus the Blackwall tunnel was also closed due to an oil leak which meant the tunnel had to be shut whilst the carriage way was dug up and resurfaced at a cost of thousands, plus the blackball tunnel also has been closed for flooding at the end of June due to heavy rain! Only yesterday the Dartford tunnel had been closed due to an accident in the early hours between two lorries which then caused a knock on effect during the rush hour a into lunch time that ensured the A2 & M25 was once more at a standstill and Greenwich had the full brunt of the traffic. The current proposal will not reduce the traffic because TFL has deemed that the proposed two lane tunnel will have one lane dedicated to a bus lane (buses not yet in existence between Greenwich and North Thames) which will ensure the volume of traffic which may use the tunnel will just have another single carriage way in which to move hence not easing the problem but creating a new one in another part of the Greenwich peninsular, which is already seeing the traffic increased due to drivers attempting to bypass existing queues to the Blackwall Tunnel and getting closer to the tunnel mouth. From Kidbrook at peak times it take an hour to get to the Blackwall Tunnel even an additional single lane will not cut this time, it will just encourage more people to attempt to travel by car and you will have added the confusion of which lane drivers need to be in which at this time is already bad enough because of the layout of the approach to the Blackwall Tunnel. Originally we were told that the Lorries and vans would not use the Blackwall tunnel once we had the Dartford Tunnel operating efficiently - this has proved to be not the case as we still see just as much lorry and van traffic as we ever did particularly from Dartford and Swanley areas as they avoid their nearest tunnel because of the charges and congestion. To make any scheme work in the area you need to ensure that only cars motor cycles and bikes are allowed to pass through the tunnels of Greenwich as they do at Limehouse/Rotherhithe and insist all vans and lorries pass through Dartford Tunnel because otherwise it will never work no matter what you do, and the existing problem will just be exacerbated. However if the tunnel was installed at Thamesmead you have the infrastructure to allow for lorries and vans to pass through freely. For many years it was agreed that the very best place for a crossing was at Thamesmead to Silvertown, and infrastructure was installed by Bexley Council to meet this demand in the 1980's and 90's. This infrastructure is still there to this day under utilised and directly linked to the Dartford Tunnel, with the space (although it is Marsh) and facilities to accommodate another crossing be it by bridge or tunnel. However the heavily Conservative Council of Bexley has now decided they do not want the hassle or the expense of continuing the upgrade of this area as they would need to look at the Perry Street Roundabout which would need considerable investment in making it more user friendly and are now lobbying for Greenwich to take the strain in an area already straining enough!! The air pollution in Eltham and Greenwich are already above the legal limits and more traffic would cause more harm to the atmosphere in which we live already schools within less than 1/2 a mile of this road are suffering the effects of pollution for the children. If you approve this development then you will not meet the criteria for the proposed clean air scheme requirement that the Mayor of London wishes to enforce. "
Members of the Public/Businesses
Tanvir Tayab
"I am a resident of Woolwich since 2003. Over the years, I had a lot of transport related troubles with the Blackwall Tunnel. The closest crossings for myself is the Blackwall Tunnel and Woolwich Ferry. The Blackwall Tunnel is at most times very heavily congested and Southbound remains closed Saturday nights. The Ferry is always very busy and there are long queues. The next available crossings are either Tower Bridge or Dartford Bridge/Tunnel, both of which are very far. In my view, in line with population growth in London and sharp increases in number of motorists, there should have been already at least another two tunnels or bridges built 5 to 10 years ago. The traffic situation in this region is extremely bad, specially peak times. There needs to be urgent consultations for a bridge and a tunnel, to alleviate current traffic problems. However, we also need strategic consultations for long term and future traffic situations and need to start consultations for bridges/tunnels that may need to be built in the next 10-20 years time. TANVIR TAYAB WOOLWICH"
Members of the Public/Businesses
Victoria Rance
"The proposed Silvertown Tunnel will bring a much greater volume of HGVs into Greenwich and make pollution and congestion much worse rather than improved."
Members of the Public/Businesses
Warren Hoskins
"That a six lane tunnel be built as soon as possible so that the misery, danger and pollution of attempting to cross the east side of the River Thames by using The Blackwall Tunnel is mitigated"
Members of the Public/Businesses
William Lee
"The tunnel should not be a toll tunnel. The cost should be funded by other means e.g. government grant"
Members of the Public/Businesses
Wilson Ma
"As a local resident in South East London, a new river crossing to the north of the river will have impact to my travel. It also may impact the economy of my local area, so I would like my opinion heard on it. I support this project in principles and would like to contribute details to it to make it better if needed. "
Members of the Public/Businesses
Ardra Kilaparti
"This will ease the congestion of Blackwall tunnel and improve transportation eminities across the river .. it will also improve the neighborhood"
Members of the Public/Businesses
Chris Hale
"I cannot see any valid reason why the toll charge should include Motorbikes. Motorbikes reduce congestion and are generally less polluting than cars (obviously there are exceptions), but if the toll is the same as for cars I might as well use a car and add to congestion and pollution."
Members of the Public/Businesses
Eric Huntington
"I disagree with the plans to use tolls for the proposed tunnel and the supposed reasoning behind it. 1. We already pay all kinds of taxes to the government in return for government services, which should include roadways and tunnels if they are needed. The study the government ran obviously concluded that the tunnel is needed, or the process would not of proceeded this far. A toll is a secondary tax on top of our regular taxes which should already be covering this. 2. It is especially vexing in that none of the other London river crossings incur a toll. (Dartford does and I disagree with that one, too.) The study stated that if any other ricer crossings were to begin in, say, West London, they would also now incur tolls. Why does this begin now, and why does this begin with East London? At least we could understand this toll of all river crossings incurred them. 3. One of the supposed reasons for creating this toll is to control the amount of traffic using the tunnel. Reading from that, it means to reduce the amount of traffic using the tunnel. (What else could it mean?) a. Why shouldn't a new tunnel or similar infrastructure be used to its physical capacity? All the other roads and tunnels and bridges in London are. b. If the new tunnel does indeed become clogged down with too much traffic, then that situation resolves itself naturally. People will learn that the very first time and then decide to use an alternate route, just like I don't use the Woolwich Ferry if I can avoid it because it is too slow. I learned that the first time I used it and I use an alternate route."
Members of the Public/Businesses
Fiza Khan
"We absolutely need more crossings in East London. However, charging for both this new tunnel and the Blackwall tunnel is unfair - especially when all river crossings are free in west London. Can we not fund this by applying a small charge to all bridges within the congestion charge area? Or from public funds?"
Members of the Public/Businesses
Gowtham Dev Kallempudi
"Would love to see this happen and improve my neighbourhood .. thanks "
Members of the Public/Businesses
Gurvinder Singh
"Yes thanks"
Members of the Public/Businesses
Jean Cole
"I do believe that we need another form of crossing the Thames in East London as it would help with journey times. The Blackwall tunnel often has problems due to incidents, but is this likely to cause further congestion on the approach to both tunnels. Also the impact of more noise and reduced air quality. If there is going to be a toil charge for both tunnels this could push more traffic into Newham to use the Woolwich Ferry. A bridge at Gallions Reach would be a better option. "
Members of the Public/Businesses
Joel Roberts
"I would like to make a representation in favour of the additional tunnel. The pollution caused by stationary vehicles stick in traffic is appalling. Having an additional tunnel will help keep traffic moving. Introducing a toll will help to make drivers think before they use their cars on the route. However their should be a significant discount offered to residents who live in the boroughs either side of the crossing as we have no other options available to us. Large tolls will cause local residents to travel further and possibly through Greenwich to get to the Rotherhithe crossing. The new tunnel will potentially open up possibilities for better bus links across the Thames. Have to make sure that double deck buses can be accommodated and that links are attractive enough to entice eople out of their cars. Has TfL conducted a survey to establish the most common local journeys made using the Blackwall tunnel? This might help with bus service planning."
Members of the Public/Businesses
Peter Ritchie
"I hope my comments are appropriate. I think another crossing is needed, however I think that Silvertown is the wrong place. I do not think that the A102 south of the river can possibly cope with the extra traffic. I think a new crossing further east is required."
Members of the Public/Businesses
Richard Dinkeldein
"Adverse impact on air quality. Congestion in southern feeder road A102 to get worse. No consideration to running a trial congestion charge (similar to Dartford) at Blackwall to measure effect on peak traffic volumes. (morning and evening rush hours) Noise - huge intercontinental HGVs attracted to new tunnel. Alternative river crossings (bridges at Galleons Reach and Belvedere) not specifically included and thus comparative benefits/disbenefits not considered. Mass transit public transport could take cars off the road and relieve rush hour congestion and traffic fumes. eg Bakerloo or DLR extensions to Eltham area. (Second rep submitted 30 August below) My representation will urge the Planning Inspectorate to reject this scheme. Reasons: 1. The tunnel will increase congestion, delays and pollution in feeder roads. 2. East London growth, down river, will be better promoted by building bridges at Gallions Reach and Belvedere rather than adding capacity at Blackwall/Silvertown where feeder roads are currently overwhelmed in rush hours. 3. This area of South East London is badly served by mass transit public transport. (tubes, overground, DLR) If London wants to reduce its appalling levels of vehicle pollution this is where the investment is needed - not extra road capacity producing extra traffic."
Members of the Public/Businesses
Thomas Turrell
"My representation will be based on the need for a much better offer on public transport. Notably wanting to see a new DLR extension to at least Kidbrooke Village included in these plans. "
Members of the Public/Businesses
Maria Ruggiero
"I am relatively frequent user of river crossings in the east and south east of London, having immediate family relatives in South East London. My principal concern with the Silvertown development is to make all 3 east river crossing toll crossings. This is grossly unfair as river crossing in all other parts of London are free to use. River crossing in the east is predominantly for commuting and visiting relatives, not for scenic day trips to admire the view. This cannot be said of all other river crossings yet these are free to use. I am hugely in favour of an additional river crossing in the east but it must be free to use."
Members of the Public/Businesses
Tom Royal
"I am a resident of the area that will be affected by this development. I believe that the available data demonstrates that the plans, if they are to go ahead, will cause more traffic and pollution in the local area, and wish to make a representation to that effect."
Members of the Public/Businesses
Diane Barnwell
"That the Slivertown Tunnel proposal does not adequately take into account traffic and pollution impact on the areas surrounding the exit of the tunnel on the south side of the Thames (ie Charlton, Greenwich and Blackheath) and will lead to increased traffic and pollution in these areas. The impact of any traffic incident occurring on the A2 or A102 before the tunnel mouths will mean there is even more traffic on the existing A2 or A 102 increasing congestion in the surrounding areas. Southbound traffic in the evening on the A2 will be much worse. A new tunnel with new trunk road designed to take the traffic generated should be considered at an alternative location."
Members of the Public/Businesses
Laurence Pinturault
"The Silvertown Tunnel will attract more traffic, cause more pollution and ill health for the people of East London. It will create more noise, more dust during construction, lead to more congested roads at either end of the tunnel when cars hit smaller residential roads and the environmental impact of the tunnel is not fully considered or mitigated against. We need more public transport, more buses on clear bus routes, more safe cycle and pedestrian routes, not more cars."
Members of the Public/Businesses
Paul David Lukes
"The proposed Silvertown Tunnel will increase motor traffic in East London, with no extra provision for alternative means of transport (cycling, walking). This proposal, therefore, seems to go against the government's stated aims of increasing take up of cycling and reducing pollution, At a time when other European capitals are trying to decrease or even eliminate motor traffic, this project seems anachronistic. "
Members of the Public/Businesses
Philip Hennessy
"I believe that both the North and South entrances to the Blackwall Tunnell are already so overcrowded that there is now a serious danger of pollution reaching levels which will be poisonous to the local residents, if not already. The problem as I see it is that the majority of vehicles are diesel powered and it is this exhaust component that is the major problem that Government has. To open another tunnel nearby will not alleviate this problem, and so I am minded to give my support to another tunnel (clearly another crossing is required from the current levels of traffic) but further down river. My favoured location, which incidentally has all the requisite preparation already completed is at Galleons Reach where you have the major circular route around London placed (the A406 on the north side of the River and the equivalent on the south side of the River)."
Members of the Public/Businesses
Claire Yarborough
"As I am a resident living very close to the proposed Silvertown Tunnel, I want to ensure that the existing roads/infrastructure will be upgraded to ensure that the increased volume of traffic is handled correctly. I am in favour of building the tunnel but the local infrastructure needs to be updated too to ensure minimum impact. "
Members of the Public/Businesses
Daniel Margetts
"I intend to outline my broad support for the application, in reducing the amount of standing traffic in the area, and in providing much needed resilience in the case of problems with the existing link. I would also highlight however that local residents do not have a choice of alternatives and therefore should qualify for discount on any new charges, in line with the Dartford crossing."
Members of the Public/Businesses
David J Oxspring
"Background I am retired and do not use the tunnel on a daily basis BUT I live in SE London and most of my journeys are to East Anglia and north of London. These journeys cannot be made by public transport, because the destination does not have public transport or it takes too long or I am carrying too much. Before I make these journeys I look at the traffic cameras at Blackwall and Dartford to assess the situation. Even then you cannot be confident that you will arrive at your destination in a reasonable time. Current situation 1. Unreliable – a lot of productive time is wasted by people queuing in traffic to cross the river in east London. 2. A lot of pollution is emitted by vehicles in traffic in these queues. 3. Population has grown since the last crossing infrastructure addition (Dartford Bridge) and is currently growing very fast. The traffic will therefore get worse. 4. Current crossing options are old or inadequate or both. Rotherhithe tunnel 2 lanes opened in 1908 built for the horse and cart. Blackwall tunnel 4 lanes opened 1897 (2 Lanes again built for the horse and cart ) further 2 lanes in 1967. Woolwich ferry 2 boats – just a joke !! Dartford Tunnel/Bridge 8 lanes. Opened 1963 2 lane tunnel, 1980 2 lane tunnel, 1991 4 lane bridge. 5. Population in eastern/south eastern half of London roughly 4million. 6. The Channel tunnel has enabled increased freight vehicles and visitors from mainland Europe, to arrive in the South East but the river crossings have not been increased sufficiently to enable those vehicles to get further up country beyond London. For a city that has pretentions of being world class, the river crossings to the east of the city are totally inadequate for the current era of vehicle travel and population size. They are a disgrace for a modern city – even compared to our European neighbours such as Antwerp, Rotterdam, and Amsterdam which have far more rivers and water crossings to overcome. The Blackwall and Rotherhithe tunnels were built for the horse and cart and it shows. With the amount of tunnelling expertise generated by the crossrail project you would have thought that they would have been able to drill a couple of tunnels at Silvertown very quickly. Points on the proposed Silvertown crossing. 1. Additional river crossings for the South East are long overdue but this proposal is inadequate and by the time it is finished the traffic requirements will have grown even further. Provision of just one lane each way for cars/small vans/motorbikes will barely reduce the existing level of congestion. If one lane to be allocated only for buses/coaches/HGVs, then additional two lanes must be created to reduce congestion. Why would we go through all this planning and construction to deliver such a limited impact on existing congestion, let alone the inevitable growth demand. "
Members of the Public/Businesses
Edmund Wroblewski
"I oppose this new crossing. Studies have found in other cities that building new vehicle infrastructure creates more new traffic - not reduce it. London does not need more roads for cars. What london needs is more options for those wishing to cycle to have safe segregated lanes especially new ped and cycle crossings. "
Members of the Public/Businesses
Gordon Joly
"I do not agree with the proposal to build the Silvertown Tunnel. Traffic is the area where I live (Poplar, East London) is often affected by the closure of the Blackwall Tunnel. In the evening rush hour, when the traffic is heading to the East, no commuters would be able to make use of the Silvertown Tunnel. This would also be true of the Southbound traffic. I am also concerned that traffic on the North side of the River Thames would add congestion to local roads poor suited to an increase (resulting from the Silvertown Tunnel being open). "
Members of the Public/Businesses
John Pipal
"this is encouraging the wrong kind of traffic and will increase congestion and pollution. there is a need for more crossings that are suitable for pedestrians and cyclists. safe crossings for cyclists are few - southwark bridge is the only one I can think of and it can still be quite daunting. in london we should be looking at ways to DISCOURAGE road transport"
Members of the Public/Businesses
Nicholas Joyner
"It is difficult to see that the proposed tunnel will achieve anything beyond increasing traffic on the already overcrowded roads of south-east London, increasing already unacceptable air pollution levels. It is hard to see any benefit for residents; road travel within the area is likely to become more difficult because of increased traffic levels, probably ecouraged away from the Dartford crossing. The only benefit will be to traffic trying to pass through London from the south-east. And we will then be obliged to pay a toll to cross the river. How would the residents of Kensington and Chelsea feel if they had to pay to drive across Chelsea bridge? Finally at a time when from the environmental standpoint we should be encouraging increased use of rail and other public transport why is money is being poured into a project that will only increase pollution in one of the poorer and less healthy parts of the city?"
Members of the Public/Businesses
Nita Gologorsky
"The Blackwall Tunnel has now reached breaking point. Queues stretch back up to Bexleyheath some days as the existing tunnel has reached capacity. The pollution being caused by so many vehicles simply being gridlocked is unacceptable. As a result of the congestion, it is difficult to impose any further public transport connections locally as it will simply not be able to cope with the heavy traffic. I STRONGLY support the building of the new Silvertown tunnel and also am excited about the new opportunities for public transport connections across the river this will bring as per TFL's proposals to add extra buses, some connecting areas like Grove Park and Stratford. I feel from a socio economic point of view there as huge benefits as this will unlock areas for development and pave the way for new jobs in deprived areas Please grant this scheme"
Members of the Public/Businesses
Valerie Gordon-Walker
"I live in Blackheath. The Blackwall Tunnel is the route I take to Canary Wharf and central London. It is congested and the only local method available to me to enable crossing the river. I am concerned about the proposed future planning on the grounds of disruption and cost (ie I believe whatever route is proposed should NOT incur costs to users). We should be treated the same as other central London river crossing citizens. We should not have to pay to use the new crossing."
Members of the Public/Businesses
William A H Hamilton
"2 points: 1 The sooner this scheme is constructed the better. The present situation for cross-river traffic is appalling, and has been for many years. 2 Cycling: If it is really policy to encourage cycling in the capital, then this new river crossing should include a CYCLE TRACK. Should be included as a separate tunnel element, for safety and air pollution avoidance. 3 Pedestrians: Same issue as for cycling applies. Footway should also be provided but physically separated from any cycle track."
Non-Statutory Organisations
Cygnet Hospital Beckton
"As a mental health care provided of 61bedded inpatient care we would like to understand the impact this development would have on our business in relation to commuting for staff and visitors to the hospital and disruptions during the building works."
Members of the Public/Businesses
John Jappy
"The unfair levy of a charge to use the crossing. "
Members of the Public/Businesses
Matchbox Day Nursery Ltd
"We are a childcare nursery based close to Blackwall Tunnel. We have both staff and parents using the nursery that travel through the tunnel to get to and from work. We are interested to know the outcomes of consultations and timescales involved. We collectively agree that there is a great need for a new river crossing in the area, and whilst we appreciate the high cost involved are concerned that the extra cost will be for users of the Blackwall Tunnel and the new crossing. Apart from Dartford crossing all other river crossing are free. It would seem fairer if a small charge is made for all river crossings, both tunnels and bridges and not just charges to crossings to the east of the city, ie Dartford, Blackwall and the new Silvertown crossing. "
Members of the Public/Businesses
Nic Vine
"London in general and East Greenwich in particular has a very serious air quality problem. The Mayor of London is considering radical action on diesel vehicles. The Cruise Liner Terminal is likely to go ahead, right next to the proposed tunnel, emitting the equivalent of over 500 HGVs when a ship is berthed, and not covered by the Mayor's plans. Providing more roads simply attracts more traffic. How can we defend all this additional transport when it is injurious to health, most especially young children. My proposal is to use the tunnel only for public transport, small commercial traffic, and bicycles if it is possible to provide a safe lane. This resolves the issue of there only being one bus service that crosses the river (east of Tower Bridge) and avoids tempting more private cars when we must have less."
Members of the Public/Businesses
Alan Findlay
"I am concerned about levels of pollution and noise which will arise from the Silvertown side of the proposed tunnel."
Members of the Public/Businesses
Ben
"I am a local resident of East London, also a visitor to South East London who believe that East and South East London should have more crossing for better connectivity, increasing the amount of home and job opportunities. If central and west London gets crossings like bridges, why cant East, why do the East and South East Londoners have to be restricted to the way of travel. Another thing about connectivity what about changing the bus network in East London and South East London to serve current and new destinations, you already done that with trains and its proven that the problem has not been solved yet."
Members of the Public/Businesses
Chris Todd
"I strongly object to creation of another road based river crossing for private motor vehicles which will cause a number of problems: 1) Increase motor traffic and increase congestion across a wider area 2) Increase air and noise pollution both locally around the tunnel portal areas and more widely through encouraging greater car use 3) Make it harder and less pleasant to walk and cycle in the immediate area and more widely due to the extra traffic 4) Undermine public transport In addition, I do not believe it represents value for money and will be an expensive undertaking. London needs to be investing more in walking, cycling and public transport. These modes of transport make better use of the scarce space in the city and are more efficient ways of moving large numbers of people as well as being healthier."
Members of the Public/Businesses
John Baker
"pinch point. For many years I have driven through the Blackwall Tunnel.I try not go through it where possible as it forever congested going from south to north.The fact that I am put off going through would also apply to businessmen who would be adverse to opening up branches of their Companies if they were domiciled on one side of the river or the other . The lack of free movement restricts the possible expansion of business.The fumes from vehicles generated cannot be good for the general welfare of people living to the east of the tunnels. The east side of London is neglected by the Government when it comes to cross river access.A new tunnel should have been in OPERATION TEN YEARS AGO.How much longer do we have to wait?."
Members of the Public/Businesses
Martin Arnold Ltd
"We are a local firm of Chartered Surveyors who work across East London, Kent and Essex. The river crossings are very important to us because we are regular and frequent users."
Members of the Public/Businesses
peter heath
"why is it taking so long. it should have built ten years ago"
Members of the Public/Businesses
Thames Clippers
"1. Role of the tunnel alongside other crossing options proposed for East London 2. Access for staff to our operation and base at North Greenwich Pier and Trinity Buoy Wharf 3. Joint interest with our Parent Company, AEG and the Greenwich Peninsula impct "
Members of the Public/Businesses
response has attachments
Brooks Jackson
"It is obvious that Blackwall Tunnel cannot cope with the ever increasing traffic with all the building going on North and South of the River Thames in East London. There are often frustrating delays already but when there is a problem which happens often the backlog of traffic is a nightmare. Recently when there was major problem and the tunnel was closed for almost a day there was gridlock and no buses cars or any traffic could move with people stuck for hours in their vehicles. A disaster for so many, with the Silvertown Tunnel it will help with the Blackwall Tunnel to keep the traffic moving. Some people think there will be increased pollution but it could be worse with gridlock. In any case it is probable that the use of diesel fuel will be eliminated by the time the tunnel is completed and that there could be many more electric cars. Plus the fact that cars should be moving."
Members of the Public/Businesses
David Harris
"The entire proposal should be abandoned. There is a strong case for improving north/south transport links across the Thames but: 1. NOT at this point, so near to the existing Blackwall tunnel; 2. the real need is at Woolwich to link the north and south ring roads; 3. it is vital that pedestrian and cycle provision is included. It is madness in this day and age to ignore non-polluting means of transport. Dave Harris"
Members of the Public/Businesses
Russell Cooke LLP on behalf of GLE Property Developments Limited and Waterfront Studios Limited
"We act for GLE Property Developments Limited and Waterfront Studios Limited (together “GLE” for purposes of this representation). GLE have two areas of land that are going to be substantially affected by the Order. GLE has a building that is tenanted to many different SMEs with communal reception and meeting rooms (the “Studios”), plus adjacent space it rents to SMEs in self contained “arches” beneath an overhead flyover (the “Arches”). The Studios and Arches are not within the Order themselves, but are situated on land immediately adjacent to it. In addition GLE has a lease of an adjacent car park (the “Car Park) which is within the Order (plots 05-121, 05-134, 06-028, 06-029, 06-031, in Book of reference). The Car Park will be permanently acquired if the Order is confirmed. This car park is key to GLE’s tenants and needs to be re-provided ahead of its acquisition to ensure continuity of use. Discussions are underway with TfL as regards a temporary and permanent re-provision but to date Heads of Terms offered are not acceptable in terms of the entirety of the car park not being replaced and the distance of the replacement car park from the front entrance of GLE’s property. A failure to re-provide all of the spaces within the car park will have a negative impact on the ability of the Studios and Arches to meet the needs of the occupying tenants. Secondly, as regards the Studios and Arches. There are approximately 350 people employed in businesses in the Studios and Arches and these jobs are at risk if the following issues are not satisfactorily resolved. Tenants are on leases with 3 mth rolling break rights. If the noise/dust that will be created by construction works adversely impacts their occupation they may exercise the same. At a meeting between my client and TfL, GLE suggested various mitigation measures such as moving the proposed site entrance to the east so that it is no longer opposite the front entrance to the Studios and providing further glazing to the Studios. To date TfL has not agreed to either. In the event that the decision maker decides to grant the Order it is requested that the Order is made conditional upon conditions/requirements that require the same. This will reduce the need for any compensation claim from GLE which given the number of jobs at risk should be given significant weight. "
Members of the Public/Businesses
Jane Lawson
"I strongly object to the building of this tunnel. The pollution levels will rise significantly, leading to great distress of local residents and to the school pupils in the vicinity. Thete isn't the infrastructure to sustain it and it is a retrograde step simply encouraging more vehicles to the roads. A pedestrian / cycling tunnel / bridge is the way forward. (Second rep submitted 30 August below) The biggest objection to the tunnel is the enormous increase in pollution. As it is schools and residences are adversely affected by fumes from the Blackwall Tunnel, if this one goes ahead thousands more will be affected and there will be an increase of respiratory illness and more deaths. In addition to that, this is a motorists facility. There needs to be more connectivity of the north and south of the river but a cycle and pedestrian tunnel or bridge would enable the thousand who work at Canary Wharf to access this locality swiftly and pollution free. And why do you propose a charge? If you are intending to charge to cross the river then charge the wealthy of west London as well. As ever, the poor of the south and east will bear the brunt of increased charges. "
Members of the Public/Businesses
Jane Pawley
"I am opposed to the Silvertown tunnel because I cannot imagine that it will solve the problems of pollution locally. That there will be similar problems to those that already exist with, for example, Blackwall tunnel which causes major jams when a Truck or other vehicle has broken down. I hope that the Woolwich ferry will keep operating whatever the outcome as it is one of the only distinctive aspects of old Woolwich that still exists. All traffic problems locally cannot be solved with this proposal and as part of a larger strategy it makes little economic or environmental sense. "
Members of the Public/Businesses
Kate Brian
"I am deeply worried about this proposal. The area is one of the most polluted in London, as seen by the fact that it is one of the areas currently targeted by the Mayor. It is of grave concern to me that a project which will actually attract more traffic to the area is being considered. I appreciate the arguments that the current traffic jams for the Blackwall Tunnel are an issue, but bringing more traffic into the area is not a solution. We need to start spending money on getting people NOT to drive in London by improving public transport. If this tunnel goes ahead, we will see more premature deaths in Greenwich from air pollution, more children with severe asthma, more chronic lung disease. Please, please consider putting people's health above the needs of motorists. "
Members of the Public/Businesses
Woolwich and District Antiquarian Society
"The tunnel plans show connections to road systems on both north and south sides of the Thames which are already overloaded. On the south side the overloading will increase as the large number of dwellings now being, and planned to be, built become occupied."
Members of the Public/Businesses
Barbara Moss
"This new tunnel will be a godsend. It has to reduce overall pollution as the traffic will be moving quicker! And thus, less pollution per car users will be inhaled."
Members of the Public/Businesses
Jude Taylor
"what measures are being considered to manage the huge traffic issues that will arise during the construction process. E.g, Night service at woolwich ferry? (install more flood lights across crossing) 2 extra boats at woolwich ferry? Temporary suspension of Dartford crossing tolls while Silvertown construction is underway? "
Members of the Public/Businesses
Matthew Sparkes
"As central London becomes increasingly pedestrianised and space is given over to cyclists, it seems backwards to build large new infrastructure for cars. Blackwall Tunnel is congested, but the solution is not to build yet more roads – building roads will lead to more traffic, and an inevitable increase in congestion. You cannot build your way out of congestion. Instead there should be more walking and cycling routes created, including bridges which do not allow cars. And Tube/rail extensions. By the time this project is finished we’ll have driverless cars and central London will be even more hospitable for cyclists – the Silvertown Tunnel is a project that will be an anachronism as soon as it is complete. It will also increase pollution, do nothing to encourage walking or cycling which tackle the obesity epidemic, and create a hostile environment for humans. Yet more traffic jams… "
Members of the Public/Businesses
William Kerr
"I feel if this is allowed to go ahead it will bring more pollution to what is already over polluted area & should be stopped from being allowed to go ahead"
Members of the Public/Businesses
David Taskis
"I intend to make points about the following: Construction: * the nature, techniques and completeness of the desk studies and geotechnical surveys along and around the tunnel route to minimise construction risk and maximise gains in geological knowledge. * the collection of in-situ information and properties of the tunnel walls, the hydrogeological regime of the site and their collection into a coordinated geological dataset. Demonstrable improvements in traffic management: * modelling techniques and assumptions used in planning the roadway capacities and decision support for the tunnel sizing and number of bores. * modelling techniques and result interpretation in informing how the tunnel connecting roads will join and impact the existing road network, especially on the south side. Education: * proposals for an accessible visitor centre during, and as a legacy of the construction and fitting out phase. * using the geological dataset(s) from the planning and construction phases to illustrate the reasons for the choices of construction techniques, disposal of tunnel waste, and precautions taken to maximise effectiveness of the tunnelling, the safety of the work force, and minimising environmental impact. * provisions for engaging and interactive presentations of the geological data and the engineering aspect of the tunnel construction, modelling techniques for traffic volume forecasting, its impact on the existing road network and the construction of the connecting roadways. * provisions to include any lessons learned from the CrossRail construction and how experience was shared with the "Stratford Tunnelling University". * whether any toll revenue (from this scheme or others) will be assigned to the upkeep of the visitor centre, its staffing and its displays."
Members of the Public/Businesses
Dominic Leggett
"I would aim to make the case that the Silvertown Tunnel as currently planned provides much more capacity under the Thames at this point than will ever be used. I note that the current traffic forecasts for the tolled tunnel show little more traffic than existing levels, and that even if traffic levels are allowed to ramp up the constraint on traffic is the limits on capacity of the approach roads, and the lack of any plans to increase their capacity in the near future.Finally, I would point out that use of the excess capacity as bus lanes provides little benefit as bus lanes provide little advantage to buses or other traffic in a free-flowing tunnel. The conclusion here is that a single-bore, two lane tunnel will provide all the resilience and peak-time congestion benefits of a double bore tunnel, at much lower cost - and that building a two-bore tunnel is a waste of several hundred million pounds that Londoners will eventually have to pay through tolls. "
Members of the Public/Businesses
Margaret Jones
"The proposed tunnel will not lessen the impact of traffic pollution on either north or south of the river. The proposed tunnel will not lessen the problems of traffic hold-ups on either north or south of the river. The proposed tunnel will exacerbate problems on the south of the river, with traffic going southward, if increasing, causing congestion on other roads, thus causing road afficianados to call for road widening southward, eg at Falconwood. "
Members of the Public/Businesses
Rajinder Pal
"I fully support the application to provide a much needed new river crossing in the east."
Members of the Public/Businesses
Alan Clarke
"Another crossing is urgently needed and silvertown/Greenwich is a good place ,but I regularly travel South/North but use Blackwall tunnel because of the tolls at Dartford so unless it is toll free I don't believe it would be used to full potential as an alternative to Blackwall Tunnel."
Members of the Public/Businesses
David Such
"I am concerned that the area that I live in will be further disenfranchised by the implementation of tolls to the West as well as the East of this area. The area is not well served by North-South transport infrastructure across the River Thames."
Members of the Public/Businesses
David Westburgh
"As a resident of Lewisham and previously Canning Town and a user of the existing crossing for the last 60 years I am aware of its personal, local and regional importance to residents and businesses and the desperate need to improve this road link across the Thames. I will support strongly the proposed new Silvertown Tunnel for providing increased capacity in a beneficial location and thereby easing the current congestion."
Members of the Public/Businesses
Ian Stephen
"The creation of a new Eastern Thames Crossing is important because the present crossings are overloaded and restricting the development of the economy of East London, Kent & Essex. The institution of tolls will generate income which should be dedicated to further improvements to the transport infrastructure. These further developments should include public transport & low carbon emission systems. The tolls should be collected electronically & not manually. There should be a substantial discount for low carbon emission vehicles."
Members of the Public/Businesses
John Bain
"travel delays and disruption"
Non-Statutory Organisations
Motorcycle Action Group (MAG) (Motorcycle Action Group (MAG))
"The Motorcycle Action Group (MAG) is primarily concerned with elements of the toll system under consideration for users of the new tunnel. Specifically, we wish to challenge the proposal to levy a toll upon motorcyclists and scooter riders. MAG would like the opportunity to set out our case by evaluating the economic, congestion and ecological arguments for and against imposing these charges on operators of powered two wheelers. The synopsis of our case is as follows: The current plan to charge riders is inconsistent with the congestion and environmental goals of the scheme. In the assessment of respondents' concerns some important considerations have not been taken into account in the authority's response. We will, of course, seek to persuade the Examining Authority on the basis of an evidential case which takes full account of the collective interest of road users and the overall aims of the project, not just from the perspective of the thousands of riders who would be affected. Our key points will relate to: (a) the context of powered two wheeler road use in relation to the proposed tunnel; (b) the impact - in terms of the environment - of modal shift towards (and away from) powered two wheelers; (c) assessments of the impact of the imposition of tolls upon powered two wheeler usage, in as much as this relates to other road users and the overall traffic mix and congestion. Within our submission, we will also reference the relationship between charging a toll for motorcycles and scooters versus other vehicles which are regarded as having a low environmental footprint. We hope we will be granted the opportunity to make our submission as an Interested Party."
Members of the Public/Businesses
Tatjana Simjanovic
"I am against the tunnel as in my opinion will bring just more pollution and trough traffic especially to neighboring boroughs . "
Members of the Public/Businesses
Katy Delahay
"I have not seen any planning evidence to show how congestion will be prevented (both sides of the river) at points of converging traffic. As a case example, what happens in instances where the majority of traffic wishes to get to the A12, North side? Will the congestion points simply not be transferred away from the entrance to the Blackwall tunnel to points along the A12, further up, when traffic from two tunnels need to meet? I'm especially concerned about this theory, for peak trim traffic travelling South bound. Both Blackwall Tunnel and Silvertown Tunnel traffic will be coming out onto the same stretch of the A102. The A102 South Bound is notoriously busy and often static during peak times, which leads me to think that there will be an increase in this with the traffic from two tunnels. I honestly can't see that having a tunnel at the Silvertown site is going to alleviate the problem, but that a proposed tunnel at an alternative site, further away from Blackwall would work better. Thank you for considering these concerns. "
Other Statutory Consultees
Licensed Taxi Drivers association (LTDA) (Licensed Taxi Drivers association (LTDA))
"London desperately needs extra river crossings to the east of Tower Bridge. The current fiasco of north bound drivers queuing for 2-3 miles most morning is seriously affecting:- London's ability to do business The development and regeneration of vast swathes of available land are hindered by an inability to cross the river. The air quality around the Blackwall Tunnel is very poor, directly attributable to queuing and stationary diesel vehicles, most of them commercial traffic. The quality of life for many in East and South East London is affected by their inability to move around for much of the day. The taxi trade is part of the public transport infrastructure and we struggle to supply a good service in much of South East London from Rotherhithe to Greenwich and North East London from Aldgate to Canary Wharf for much of the day. The traffic and inability to move are all directly attributable to a lack of river crossings."
Members of the Public/Businesses
Richard Andrew
"I strongly object to the proposal for a new road tunnel at Silvertown as it will without any doubt at all generate more motor traffic in this area , which cannot cope with any increase. Road building is NOT the answer to London's congestion not pollution problems - and is contrary to the New Mayor's stated policy of reducing our ''unacceptably'' high levels of pollution - from traffic exhausts. Tolls on existing river crossings / other measures to deter non-essential car use are what London needs - not this throwback to the bad old days. Surely no-one now believes the myth that road building ''relieves congestion'' ? Furthermore East London now has good new rail crossings (both Overground and DLR) so I fail to see how this can possibly be deemed necessary. Off-peak the existing crossings cope ok as is - queues only occur during peaks - and it is NOT government ploicy (at any level) to make car commuting easier. This would be a waste of a huge amount of public money which would be much better spent on developing / upgrading alternatives to private car use. "
Members of the Public/Businesses
John Deakins
"I feel that the restoration of London is just as important as the upgrading of roads, transport links, restaurants, monuments, museums, infrastructure and historical landmarks. From what I understand the Silvertown Tunnel project embraces all these factors. When it is completed local residents will benefit, business's will benefit, culture will benefit, tourism will benefit and cutting technology will learn from it. This part of London has been developing sporadicly since 1981, it would be nice to see the smooth and thoughtful development continue to develop in a well thought out and with careful consideration of local residents above all who should benefit from these steps, I am not a local resident and live some 25 miles North West of the location but do frequent the area for culture and history from time to time. I say yes and go for it"
Members of the Public/Businesses
Peter Liam Jones
"Additional traffic in the local area. Air pollution. Lack of additional public transport provision. Charges for use of the crossing."
Members of the Public/Businesses
Reto Fisher
"The provision of active travel made by teh tunnel and the impact it will have the area around the north exit."
Members of the Public/Businesses
Gary Sargent
"I am a supporter and interested party and would like to be kept abreast of developments."
Members of the Public/Businesses
Mrs M White
"By creating a new Silvertown Tunnel extra traffic is generated in South East London/ North west Kent. Local people already suffer delays and jams on the A2 and M25 junctions. (Sun in the Sands, Danson interchange Darenth interchange.) on to smaller side roads jamming them. The burden is then increased on people's health by extra pollution, stress, noise and traffic jams. Already in this area there are NO2 readings almost double the Eu 40 mg limit. There are thousands more homes in construction and planned in Erith and Slade Green for example. These will bring many more cars. A giant new freight forwarding depot is in the planning stage at Slade Green. None of these extra vehicle movements have balancing extra road capacity to spread on to. The extra pollution will add to already rising asthma and allergy levels, however there is no mention of public transport or trams to assist in reducing individual car journeys."
Members of the Public/Businesses
Steve Chambers
"I want to highlight design problems with the proposal."
Members of the Public/Businesses
Tim Butcher
"The need for traffic congestion relief via Thames crossing options east of Tower Bridge, and the need for cycling and pedestrian options"
Members of the Public/Businesses
Wei Du
"As a Tower Hamlets resident and someone who works in Poplar, I am strongly against the proposed Silvertown tunnel. The tunnel will increase the number of vehicles in the area - and this will be overwhelmingly through traffic which brings no benefits to area. It will worsen air quality in an area which already regularly exceeds pollution limits. It will further damage the health of residents in an area already suffering from poor health. Build a cycling/walking bridge between Canary Wharf and Rotherhithe instead if you really want to improve connectivity."
Members of the Public/Businesses
B Bajwe
"Hi I would like to mention that the since the two Tunnels end close to each other on the south side of the river, it will create more traffic congestion during peak hours. Secondly I Would oppose the introduction of Toll for crossing, which had been spoken about earlier. Further the comments or suggestions are to be put forward as we proceed. Thanks Bajwe"
Members of the Public/Businesses
David S Garfield
"As there has been no material change in conditions since my last response, I maintain precisely the same points as I established previously, with one or two additional elements. Read my submission here: I do not understand why Transport for London is so fixated on the principle of road-based crossings. You shall be well aware of robust and demonstrable evidence that new roads and routes invariably engender new traffic. The London Metropolis already has a serious continuing problem with air quality etc., so it would be invidious to add to the current situation by encouraging more vehicle movements. No doubt TfL shall receive support for its road-based crossing proposals from those who would like to drive anywhere of their choice without consideration for fellow-Londoners who would suffer from their driving activities, but their approaches should be resisted in the interests of long-term sustainability and quality of life. • The Tunnel proposal would do nothing to facilitate sustainable transport modes, such as Cycling and Walking. • It does not address the (arguably) more important problem of a crossing to serve Residents and Commercial Interests between the Dartford Crossing and the Woolwich Ferry. There is currently a proposal under preliminary consideration in Havering Borough which shall result in several thousand new homes and related population between Rainham and Dagenham along the A1306 (www.rainhamandbeampark.com .) When completed, this scheme shall create an even greater imperative for such a crossing in this stretch of the Thames. • As your records shall attest, I have called for a crossing solution based on a multi-role Ferry Service. Despite raising these points several times, no one at Transport for London has ever engaged with me on the subject or attempted to contest my arguments. Consequently, I am left wondering if there is some ulterior motive behind the insistence on propounding road-based crossings. • I note that a new privately-owned passenger ferry service was recently announced to be forthcoming for the Greenwich Peninsula, which is an encouraging sign. I commend my comments to you and look forward to your response in due course. (Second rep submitted 31 August below) Thank you for affording me the opportunity to register for the proposed Silvertown Tunnel Inquiry. I have the following observations to offer: • It has become well established that new routes engender new traffic. Numerous examples can be cited to illustrate this. • There are already unacceptable and illegal air pollution levels in the Metropolis; It makes no sense to exacerbate the problem. • The proposed tunnel would direct additional vehicle movements toward already heavily-congested areas. Instead, measures should be sought and championed to reduce motor traffic in favour of sustainable transport. • The proposal would establish ‘environmental inequality’ for concentrated communities with relatively low private care ownership. Despite being unable to take direct advantage of the crossing, they would suffer the additional noise & air pollution and congestion accruing. • Instead of relieving other crossings, the proposed tunnel would increase pressure on existing approaches, which would have to be shared. • Tunnels (and Bridges) are highly susceptible to disruption from collisions or vehicle breakdowns; extensive hold-ups can occur because there is nowhere to move offending vehicles to allow rapid resumption of traffic movement. Frequent occurrences at the M25 Dartford Crossing bear witness to this. • Claims of the projected costs are also subject to doubts. Schemes of this sort are notorious for overrunning original estimates and, in any case, in view of the loss of central Government funding, would present a considerable burden on local Taxpayers in the Metropolis. Following the vote to withdraw from the European Union, there shall be no option of funding from that source. • Why is Transport for London so fixated on Road Bridge and Tunnel options, anyway? This represents outmoded attitudes that have failed to produce lasting benefits in the past. • What is needed is a crossing that would favour Pedestrians, Public Transport & Cycle-users and local traffic. This could best be accomplished with a comprehensive Ferry Service at this and other locations along the River (all users would cross at precisely the same speed.) I envisage vessels along the lines of the Woolwich Ferry but larger and, if practicable, hydrogen fuel-cell powered. Moreover, In view of the propensity for national and regional Government to seek Private Sponsorship for ventures of this sort, Ferry Crossings would appear to offer great attractions for this alternative, in ways that a fixed-link (Bridge or Tunnel) could not. It could even cover everyday running costs to allow free use — at least, to selected users. If required at some stage, a comprehensive submission on my substantiation for this principle can be read here: (Content within link supplied blocked) Despite several opportunities, Transport for London has failed to respond on this question. I look forward to hearing from you in due course."
Members of the Public/Businesses
Mike Shallcross
"My view is that the proposed Tunnel: - will blight communities around the tunnel entrances on both sides of the river as a result of the additional pollution and noise, - will not ultimately reduce traffic congestion, but will rather attract additional traffic to the new route (the "M25 effect"), - does not reflect the need for additional crossing facilities for pedestrians and cycles."
Members of the Public/Businesses
Nathan Modell
"Existing pollution, increase in noise, pollution and traffic"
Members of the Public/Businesses
Arnold Ridout
"The Silvertown Tunnel will simply bring more traffic onto Newham's Roads, increasing the environmental and social degradation of an area which is already blighted by heavy road traffic and aircraft noise. The tunnels will simply increase the congestion on local roads. it will stifle sustainable transport. Newham Council purport to want to make the borough a place where people live and stay. This development will have the opposite effect. No-one will want to live in the area around the tunnel. Development taking place will decay into slums. "
Members of the Public/Businesses
Glyn Ellis
"I am a local resident within the Greenwich Millennium Village. I am generally supportive of this initiative but have two key points that I want to make. Firstly, the route of the tunnel effectively follows that of the cable car. By the cable car there is a pedestrian riverside pathway which is used extensively by residents to get from the Greenwich Millennium Village to North Greenwich tube station. It must be ensured that pedestrian access along this key route is maintained at all time through construction. Lengthy detours must not be put in place that would extend this pedestrian commuter 'route' to the station. Additionally, whilst an element of mess will be inevitable, the cleanliness of the surrounding area must be maintained throughout the works. My second key point is around the charging structure. Whilst I accept that charges, which are effectively a tax, will be implemented, but they should be structured in a way that local residents who have always used this route across the river (through Blackwall) are not significantly financially impacted, as the current proposals will do. This should be in the form of a 'local user' discount scheme as is in place at the Dartford River Crossing. We will already be impacted by the adverse pollution, regardless of whatever reports may be made up which states to the contrary. Whilst I don't believe there will be anything but adverse environmental impacts to this scheme I don't believe that these will make any difference whatsoever to this being progressed. The implementation of a local discount scheme of some sort will effectively be some form of recompense for the inevitable inconvenience during construction and deterioration in air quality due to the increase in vehicle traffic to our area. "
Members of the Public/Businesses
Heather Scott
"I think that the Silvertown Tunnel is an excellent idea, as a resident of Blackheath who travels towards Essex regularly, an alternative to the Blackwall Tunnel is a dream come true, and also gives me the opportunity to explore the Royal Docklands area, which in my opinion is a bit of a ghost town where there are inadequate links to the beautiful area. This will create so much more business for the Royal Docklands and reduce congestion around my area. "
Members of the Public/Businesses
Wyndham Resources UK Limited
"As a business owner we lose a considerable amount of time transiting through the Blackwall Tunnel on a weekly basis and am very interested in the proposal to build an alternative route"
Members of the Public/Businesses
Mark Morris
"I am strongly opposed to the Silvertown Tunnel and believe that a much bigger priority should be to improve pedestrian and cycling links across the Thames, extending the Bakerloo Line to Lewisham and Bromley and ensuring the DLR is extended as well."
Members of the Public/Businesses
Muhammad Uddin
"There is a desperate need in the East End of London for more river crossings. These crossings must be free to use and have facilities for cyclists and foot passengers as other bridges in the centre and west of London. There should be no charging for the new crossings or the current crossings as this will severely reduce the economic benefit that the crossings will give to the east of London. For example I live less than 3 miles from a major shopping area on south side of the river, however to cross the river and to get to the shopping area it takes about an hour from my home. This makes it a very unattractive option for me when I think about where to go and spend time and money. If there was a crossing which was more easily accessible and more reliable, I would regularly use it for social and professional reasons."
Non-Statutory Organisations
Alliance of British Drivers
"The Alliance of British Drivers supports the proposals for a new Silvertown Tunnel on the basis that the existing traffic demand on the existing Blackwall Tunnels is higher that the capacity of those tunnels (in both directions). This results in excessive queues of traffic at most peak periods which is every expensive in terms of the wasted time of vehicle occupants. In addition if there is the slightest incident, or a requirement to close either tunnel for maintenance or vehicle recovery, the resulting traffic congestion can spread over a very wide area of south-east and north-east London. Also, the slow moving or stationary traffic that results causes high air pollution in the area. There are currently very limited cross-river links east of central London which inhibits commercial development and causes long detours to use other routes, particularly for large commercial vehicles. The existing bridges/tunnels are Tower Bridge, which has limited capacity with poor access roads and is also a major historic tourist attraction, the Rotherhithe Tunnel - a very old tunnel which is a rated as a major safety risk even though usage is restricted to light vehicles, and the Dartford Crossing tunnels/bridge which is many miles from the centre and is also congested a peak times. There has been clear demand for other Thames river crossings in this area for very many years, and numerous proposals for such crossings which for various reasons have not been progressed. Such crossings would enable the improvement and development of the areas east of London both north and south of the river which are major focuses for more housing and commercial development as these areas are some of the few providing development potential in the outer London area. Residents and businesses who reside both north and south of the river would benefit from additional river crossings, particularly those south of the river as the major commercial centres in London are north of the river and to reach most of the rest of the country requires road access across the Thames. There are limited public transport services such as main-line train or underground services that provide the access required and what there are tend to be provide access mainly to central London and not to other areas. This often requires travel into and out of central London to gain access to other areas which is time consuming and expensive. More direct road links are the answer which a new river crossing would provide. In summary, we wholeheartedly support the proposal for a new tunnel. "
Members of the Public/Businesses
Mayflower Hygiene Supplies
"ref TR010021. As a company based South of the river, our main concerns over this proposed new tunnel link, is how this will effect the current blackwall tunnel. We are concerned charges will be put into place on the existing blackwall crossing. This will have a huge financial effect on our company which uses this crossing on a daily basis to deliver goods North of the Thames. Also the huge undertaking that will have to take place to build the new link will surely cause greater traffic issues to the local area. Adding to the already heavy traffic flow in and around the area south of the blackwall tunnel. We would object to any charge being put into place on the blackwall tunnel, and also the increase in traffic issues this development would cause the area."
Non-Statutory Organisations
BNP Paribas Real Estate on behalf of Royal Mail Group Limited
"Royal Mail is responsible for providing efficient mail sorting and delivery nationally. As a Universal Service Provider under the Postal Services Act 2011, Royal Mail has a statutory duty to deliver mail to every residential and business address in the country as well as collecting mail from all Post Offices and post boxes six days a week. Royal Mail’s postal sorting and delivery operations rely heavily on road communications. Royal Mail’s ability to provide efficient mail collection, sorting and delivery to the public is sensitive to changes in the capacity of the highway network. Royal Mail is a major road user nationally. Disruption to the highway network and traffic delays can have direct consequences on Royal Mail’s operations, to meet the Universal Service Obligation and comply with the regulatory regime for postal services thereby presenting a significant risk to Royal Mail’s business. In exercising its statutory duties, Royal Mail uses all of the main roads in the vicinity of the proposed Silvertown Tunnel on a daily basis. In particular, the A12, A13 and A2 are all strategically important routes for Royal Mail operations. Royal Mail has no issue with TfL’s proposed Silvertown Tunnel going ahead. However, Royal Mail has operational facilities that either run or receive mail services and use the main roads in the vicinity of the proposed development. Any additional traffic congestion or delays on these roads during the construction phase may cause significant disruption to Royal Mail operations. Congestion caused by the construction of the proposed Silvertown Tunnel and any resultant disruption to Royal Mail operations could be made worse by any traffic from other major developments in the area. Therefore, Royal Mail considers that careful attention must be given to the potential for cumulative traffic impact during the construction phase. Royal Mail has not yet been able to satisfy its concerns based on the traffic impact information that has been made available within the supporting information to the DCO application. Notably, TfL’s Construction Traffic Management Plan is not yet available. Consequently, the level of risk to Royal Mail and the effectiveness of any proposed mitigating measures cannot be accurately assessed. Royal Mail wishes to be an Interested Party to the Examination because it is concerned that its future ability to provide an efficient mail sorting and delivery service to the public in accordance with its statutory obligations may be adversely affected by this proposed scheme. As a minimum, Royal Mail requests that TfL: • fully consults with Royal Mail, • includes major road hauliers such as Royal Mail in its proposed public communications strategy, • keeps Royal Mail fully informed in advance of all temporary road closures and/or delivery of Abnormal Indivisible Loads, and • considers the cumulative traffic effects during the 5 year construction programme. Royal Mail may simply rely on this statement but reserves the right to make further representations to the Examination in due course once further information is available and advice is provided by its consultants on whether it satisfactorily addresses Royal Mail’s concerns. "
Members of the Public/Businesses
Simon Robinson
"INDUCED TRAFFIC: There is considerable evidence from academic research that providing new road capacity induces new traffic onto the roads to fill that capacity. The context of the Silvertown tunnel is that this is likely to increase congestion on local roads that would feed into the tunnel. Many of these roads are in residential areas which would therefore see increased noise and pollution and slower journeys. The additional congestion and slower journeys could harm both residents and businesses in a wide area around the vicinity of the tunnel, cancelling out any net benefit for traffic using the tunnel. LACK OF PUBLIC TRANSPORT CONSIDERATION: Further, the tunnel enables journeys by private car and lorry along a corridor for which there is insufficient public transport provision. This is likely to induce a new generation of car-dependency, further damaging the local economy and environment. Although the plans suggest bus services may use the tunnel, this ignores that buses tend to be slow and often suitable only for short journeys. Buses in London are becoming less reliable and there is evidence that this is due to congestion (which could be made worse by the tunnel) and is harming bus usage. In the light of this, it would make far more sense, from economic, business and mobility perspectives, to be prioritising a North-South rail-based scheme to allow more people to avoid using cars for the kinds of journeys that would use the tunnel. BRINGING LONG DISTANCE TRAFFIC INTO AN URBAN AREA The design and location of the tunnel will encourage long and medium distance journeys through London by cars and lorries for which neither end-point of the journey is in London. Yet there are clear environmental reasons for wishing to discourage such journeys from entering urban areas en route. AIR QUALITY Air quality in London is known to be very poor. We should be focusing on improving transport connectivity in a way that doesn't further damage air quality - which the plans do not adequately address TOLLING The plans involve charging tolls in order to discourage induced traffic, yet no evidence is provided that the level of tolls proposed is sufficient to achieve this. Further, insofar as alternatives using public transport are available, the tolls are generally proposed to be set at a level that is less than the corresponding public transport journey. This suggests that grossly inadequate thought has been given to this aspect of the tunnel. CYCLING/PEDESTRIANS There is no provision for pedestrians or cyclists to cross the Thames at this point. No access through the tunnel. The suggested alternative - the cablecar - is unsuitable because it is very expensive and does not have 24-hour operation."
Members of the Public/Businesses
Gerri Grogan
"I would like to object to the proposal of the Silverlink tunnel as a local resident as I feel it will bring a huge increase in traffic and pollution. We are already way over the limit on pollution and not only is this not being addressed, but the proposal will only increase it. I have a young child and feel very strongly I need to represent her best interests for her health and future. "
Members of the Public/Businesses
Nathaniel Lichfield & Partners
"We act for the U and I Group as long term leaseholders of Morden Wharf, alongside the southern access road to the Blackwall Tunnels. Morden wharf contains two main parcels - i. a substantial development site for mixed uses including housing within an area already identified by RB Greenwich for major development and ii. a proposed Safeguarded Wharf within a Strategic Industrial Location and to replace that wharf to be lost through the proposed development - all establishing substantial movements by vehicles, cyclists and pedestrians. We have consulted with TfL throughout the emergence of the proposals and have made considered representations at each stage. U+I has no objection in principle to the proposed scheme. It does, however, object to the detailed arrangements proposed for accommodation works on and around Tunnel Avenue (which provides the main access to Morden Wharf). The detailed proposals take no account of the representations made in relation to highway and cycle/pedestrian safety on Tunnel Avenue. A proposed new dual-use overbridge will disgorge pedestrians and cyclists onto a narrow pavement on the western side of Tunnel Avenue, with no provision for safe cycle movements southwards towards Morden Wharf and to new housing and cruise liner terminal further south, all of which will require the overbridge for safe connection to North Greenwich centre and Underground. The public transport provisions of the proposal remain largely unformed but the details as proposed would preclude the safe operation and stopping of bus routes along Tunnel Avenue and serving the busy western side of the Peninsula. The limit to land take and the details currently proposed fall short of providing a safe basis for non-car modes properly to be available - 'an accident waiting to happen'. Such an approach is contrary to national and London Plan policies and alternative details could build in the solutions to the overall scheme rather than build them out. "
Members of the Public/Businesses
GoAhead, Docklands Buses
"As an operator of bus services on behalf of TfL in the local area, our concerns are the impact of the tunnel on our operations. "
Members of the Public/Businesses
Howard Wynne
"I don't see any advantage from the tunnel south of the river because the Rochester Way is already at capacity and the roundabouts at either end of Lower Lea crossing will end up being bottlenecks as the resulting extra traffic. "
Members of the Public/Businesses
Matthew O
"The points I will make in reference to this application will include: - the impact on local traffic and transport - the impact on local environmental conditions - the impact on local businesses and residents, both during the proposed development and after it has been completed"
Members of the Public/Businesses
Ralph Hardwick
"I object to the Silvertown Tunnel because it will not reduce congestion as there is no free flow of traffic on the north side. The additional traffic will bring more pollution on the south side where there are already breaches of NO2 limits. New sources of emissions in the local area need to be considered. The incremental effect of tugs and shipping surrounding the Enderby Wharf development. The Low Carbon Energy Centre which will be generating 43MW of gas fired energy. The refurbishment of Greenwich Power Station with 6 new massive gas engines. Additional traffic brought by the new Ikea store. In total a whole package of new emission sources which are likely to exacerbate the local levels of toxic emissions. All these developments need to be modeled to understand their effects."
Members of the Public/Businesses
Paul Mitcheson
"1. As I have emailed many times, it is more crossings needed along the river, not more tunnels to create an even tighter pinch point. THis has been ignore for years. 2. At one of the forums held previously, I asked for an explanation of how turning two tunnels into four will how alleviate the outbound traffic from each tunnel. For example, if you take the southwards heading traffic, all three lanes of the A102 heading south are slow moving every day during the evening rush hour(s). How will doubling the amount of traffic heading into these three lanes help alleviate it? It will do the exact opposite. The only response I got was 'I'm sure our modellers have thought of this' "
Local Authorities
Southwark Council
"At present the council has significant concerns on the impact of Silvertown tunnel on Southwark's two free river crossings Tower Bridge and Rotherhithe Tunnel and the impact on of increased congestion and air pollution in these areas. "
Members of the Public/Businesses
Laura Grainger
"The residents of North Woolwich and Silvertown have done and continue to experience upheaval on an epic scale with the Crossrail project and now the LCY expansion. We DO NOT want any more works adding to the air pollution, traffic etc in the area."
Members of the Public/Businesses
Michael Beach
"I am opposing the Silvertown Tunnel because of the following: - It will add further pollution to an already over polluted area with London City Airport already an issue. - It will only add further traffic to London rather than decreasing it adding to Londons congestion problem. - There has been insufficient consultation with local community, the people this will effect. - It will have drastic health and environmental effects on the local population which have not been considered properly. - It will not help any regeneration of the area and businesses simply turn them into somewhere to avoid. "
Non-Statutory Organisations
No to Silvertown Tunnel
"The No to Silvertown Tunnel campaign is a community-based group of east and south-east London residents who are opposed to the construction of the Silvertown Tunnel. We work with other residents and community groups to raise awareness of the scheme’s impacts on air quality, noise levels and traffic congestion, as well its effects on the health of individuals and communities. We have responded to previous consultations, and have met TfL on several occasions to discuss the project. We now would like to register as objectors to the Silvertown Tunnel. The points we will make include: - TfL’s claims that the Silvertown Tunnel will increase resilience for this road corridor are unjustified. The tunnel will simply displace traffic into the already heavily-congested local road system. - The business case does not adequately consider the economic impacts for users. - The scheme will not support regeneration in the immediate or the wider areas, as claimed. - The Silvertown Tunnel will not provide economic or social benefits to the to people living in areas most in need of regeneration locally, notably North Woolwich and Thamesmead. Congestion: - The levels of traffic on the Silvertown Tunnel and Blackwall Tunnel cannot be controlled in the way TfL has laid out. - The scheme will cause traffic levels to rise, with increased congestion across a wide area, north and south of the Thames, both on main trunk roads and local roads through areas including (but not limited to) Greenwich and Canning Town. - TfL has not properly considered a wide range of alternatives including public transport. - Real-world examples of induced traffic would suggest that TfL has not taken sufficient account of the phenomenon. Furthermore, its strategy for mitigation is not sufficient and strong enough to prevent a severe deterioration in local conditions, both in the immediate aftermath of opening and in the longer term once its five-year monitoring period ends. - The risks to the Maritime Greenwich World Heritage Site from traffic congestion have not been properly considered. Environmental impacts: - TfL has not given adequate information on the scheme’s likely environmental impacts - particularly regarding air quality - and its strategy for mitigation is insufficient. - There is inadequate mitigation for noise pollution. - The scheme provides improved access for northbound HGVs and coaches - but the resulting noise, pollution and congestion impacts have not been properly considered. - The impact on London’s overall air quality has not been fully considered in relation to current objectives. Cost and opportunity cost: - Provision of public transport in and between east and south-east London lags behind other London areas. Orbital public transport links could be improved. Tolling and demand management: - The charging structure’s effects on traffic congestion on local roads has not been properly considered. - What economic effects charging will have for users in relation to those in other parts of London, as well as the tidal patterns of traffic, have not been properly considered. Provision of alternative solutions: - Instead of building new roads, schemes to improve the management of traffic and the road network should be implemented. Consultation: - There has not been sufficient consultation with local residents and communities in areas that will be affected by the scheme. We approved this submission at our committee meeting of 11 August 2016. We would be happy to answer any questions you have, and you can find more information about our campaign at www.silvertowntunnel.co.uk. "
Members of the Public/Businesses
Matthews & Son LLP on behalf of Tarmac Limited
"Tarmac Limited trading as Euromix operates a concrete batching plant and wharf facility at Dock Road Silvertown directly and indirectly affected by the proposed Silvertown Tunnel scheme. The site itself is not required by the Tunnel construction footprint and could continue to operate throughout the construction period. Although the access link to Dock Road is shown in the site layout to be severed there is capacity within the land available to provide for an alternative access to ensure this important site continues to operate throughout the construction phase supplying aggregates and ready mixed concrete and beyond into the future meeting redevelopment needs of the area. The representations will seek to demonstrate the scheme’s; • Unacceptable economic impact on delivered prices for a network of sites north and south of the River Thames reliant on the river crossing. Presently aggregate and value added products such as ready mixed concrete are distributed by road through the Blackwall Tunnel from river connected sites to ensure sustainable delivery of products. The introduction of tolls on both the Blackwall and proposed Silvertown Tunnels will have an adverse impact on the economics of the business. • Unacceptable economic impact on investment in sites due to effects on the business by discouraging the free flow of trade north and south of the river influencing volumes of material supplied. • Encouraging supply north of the river by sites further outside of the market demand area resulting in unsustainable increased vehicle movements • Failure to protect an important ready mixed concrete site and meet mineral safeguarding provisions of the national planning policy framework • Failure to protect an important wharf facility and meet mineral safeguarding provisions of the national planning policy framework • Neglecting the opportunity for a local ready mixed concrete supply during the project, minimising traffic movements in the area, and continued operation of the site after completion of the tunnel to supply local development needs • Neglecting to maximise use of the river for aggregates supply during the project and as a wharf facility into the future • Unacceptable economic impact on the use of the Thames for freight resulting in lost income to PLA as a result of closure of the wharf and plant site"
Members of the Public/Businesses
Alan Bradley
"The inadequate number of road crossings to the East of Greenwich has resulted in overcrowding in all the approaches to the Blackwall and Rotherhithe tunnels. We residents have to live with the appalling congestion in Greenwich Town Centre and along the A2 Blackheath. Our limited Green space is under pressure and we are heavily polluted as a consequence of air saturated with petrol vapour. A powerful HGV lobby along with Civil Engineers ( who seek public finance for this entire project) has brought about this scheme without regard for the increase in traffic and HGVs that will occur as a consequence. TfL by their own admission have not considered the impact of yet more traffic here in the South East. Therefore opening us up to more and bigger road schemes in what should be our living space. This scheme has not been thought through and the problems faced in Greenwich Town Centre and all feeder roads are not reasonable at all. A tunnel would be fine if you would put another DLR form of public transport in there to provide for Eltham and Silvertown zones. The last thing they need is more and bigger traffic use. Heavy traffic should be moved further East and this area and the peninsula provided with a massive increase in public transport. The 60,000 dwellings proposed for the peninsula will need a further DLR public system. "
Members of the Public/Businesses
Andrew Slavin
"I live in the area affected by the proposed tunnel. I feel that it will increase air polution in an area that already suffers from poor air quality, add to noise polution and increase congestion. I think that a better way to improve traffic movement would be to remove tolls completely on the Dartford Crossing and direct traffic to the M25."
Members of the Public/Businesses
Bruce Jamieson
"I am concerned about the vehicle pollution that comes with extra traffic travelling through both the Silvertown and Blackwall tunnels. An extra tunnel will attract more traffic."
Non-Statutory Organisations
Campaign for Better Transport
"The Silvertown Tunnel is promoted as responding to increasing population, meeting demand for river crossings and providing economic benefit. However, the scheme has serious problems that undermine this rationale. New roads generate new traffic: increases in traffic, including heavy goods, would blight, not regenerate, parts of Greenwich, Newham and Tower Hamlets. Instead of 'relieving' the Blackwall Tunnel, the approach roads to the south would be shared, creating increased demand on existing roads, relocating congestion rather than reducing it, while increasing noise and air pollution. Air pollution is already at lethal and illegal levels: over 90% of modern vehicles on the road emit more pollution than the standard lab tests record. Even a marginal increase in traffic levels will add to roadside pollution. The Mayor’s ULEZ proposals, although welcome, will charge, not exclude, the most polluting traffic. The proposed tunnel is designed to accommodate HGVs in both directions, incentivising larger, more dangerous and more polluting vehicles, to come into areas that already suffer from noise, air pollution and congestion. There is no economic or social benefit to the Greenwich peninsula, which is in need of new public transport to serve 10,000 new homes planned for the area. There is no benefit to the communities in North Woolwich, Silvertown and Canning Town: existing car ownership levels are relatively low, and the new homes being built there are largely car-free, benefitting from access to the DLR, Crossrail and the Canning Town interchange. Toll costs will adversely impact local small businesses making deliveries (e.g. florists): tolls will add to local construction costs, undermining the viability of affordable housing in new developments. The main beneficiary of the tunnel is likely to be commercial traffic servicing businesses in the Royal Docks, Isle of Dogs and Canary Wharf. Exploring options for smarter last mile deliveries, following the expertise in Greenwich, and for workplace parking levies, would be a better and more sustainable option, in tune with emerging transport policy. There appears to have been no serious consideration of alternatives, including, but not limited to, a public transport only connection; provision for cycling routes; a package of demand management measures on existing roads, including smart road user charges, as part of the proposed London ULEZ. There is also the cost and impact of removing the spoil from the tunnels and where it would be dumped, with removal adding to the danger and pollution on local roads. ?The scheme is projected to cost £1bn, at a time when TfL is facing massive cost pressures from loss of central Government funding, delivering a fares freeze and meeting growing demands on public transport. We are not satisfied that this scheme represents value for money. The money could be much better spent on providing pedestrian and cycling links between the Greenwich peninsula and Canary Wharf, among other sustainable transport infrastructure. We believe the combination of these factors - little or no local economic benefit, significant adverse environmental impacts, and high cost - combine to undermine the case for the Silvertown Tunnel."
Members of the Public/Businesses
David Jackson
"I object strongly to the proposal for the Silvertown tunnel as it will attract more traffic, increasing pollution and congestion. This view is based on 10 years experience of daily travel through the Blackwall tunnel and 17 years of living in an area profoundly affected by any major congestion or closure of the tunnel."
Members of the Public/Businesses
Ian Blore
"New roads generate more traffic. The tunnel won’t make the road network more resilient - it willl only increase congestion on local roads especially Trafalgar Rd. TfL hasn’t given adequate information on the environmental impacts of the scheme. I note that the air quality assessments are preliminary."
Members of the Public/Businesses
Lalit Gulhane
" New roads generate more traffic. The tunnel won’t make the road network more resilient - it’ll only increase congestion. (You might like to name specific roads or areas here.) The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. TfL has not properly considered alternatives, including new public transport and better management of the existing network. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise pollution (you might like to name affected areas). The environmental impact of better access for HGVs and buses has not been properly considered. TfL has not properly considered the effects of tolling on the wider road network (for example, on routes to the Rotherhithe Tunnel, which would remain free, though you may also have other examples). Tolling will also have a negative impact on local businesses - firms in other parts of London will not have to pay charges to get around. There’s been insufficient consultation with communities that will be affected by the scheme. "
Members of the Public/Businesses
Louise Blore
"New roads generate more traffic. The tunnel won’t make the road network more resilient - it’ll only increase congestion on local roads like Blackwall Lane. The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. TfL has not properly considered alternatives, especially public transport. "
Members of the Public/Businesses
Marissa Ryan-Hernandez
"The proposed Silvertown Tunnel contradicts local and regional planning policy with regard to air quality, vehicular traffic and highway congestion. North and East Greenwich already have substandard air quality, which this will exacerbate further, particularly when considered alongside cumulative schemes such as the nearby IKEA store at Millennium Leisure Park and the recently approved Enderby Wharf cruise liner terminal. Such schemes should be considered in full within any submitted environmental statement. Congestion charges would be more appropriate in order to lower traffic volumes, improve air quality and encourage cleaner forms of transport and increase public transport usage. Please consider the future of our children and refuse this unsustainable proposal. "
Members of the Public/Businesses
Mike Smith
"I do not believe those proposing this scheme have given sufficient consideration to the environmental impact of the increase in road traffic to the area adjacent to the tunnel, its feeder roads and the surrounding area. On a wider context the simplistic approach of constructing more roads/tunnels to cope with an increase in road traffic is flawed. The population increase in Kent and outer London Boroughs is caused by inflated and unaffordable property in more central London Boroughs. The centre still needs such people to work in inner :London. A noticable percentage of such people choose not to use public transport. This seems to include a growing number of small business vehicles (white vans). The priority should be to reduce the amount of vehicles travelling from outer London and Kent on a daily basis.....more affordable family homes in inner London.....improved public transport...numeric and qualitative.....tax incentives....etc"
Members of the Public/Businesses
Myles Bartoli
"I oppose the Silvertown Tunnel project. -Its purpose is to increase vehicle traffic capacity in south east/east London. This will make it a draw for further vehicle traffic. Therefore, it will increase vehicle traffic. I oppose this as the reality is that vehicle traffic is motor vehicle traffic. I oppose motor vehicle traffic being increased. Reasons why are explained in the further two points. -I rely on public transport to move throughout London (especially south east London, where I live). I believe increased vehicle traffic will significantly negatively impact public transport services in south east London. -My wife is asthmatic as is my young son (who has had recurrent breathing problems throughout his life so far). I am extremely concerned about air quality in south east London. My wife and child are not the only ones with health problems related to air quality. According to http://www.phoutcomes.info/public-health-outcomes-framework, Lewisham has on average a greater fraction of mortality attributable to particulate air pollution as compared to the England average. Motor vehicles are well known to be great contributors to air pollution. As the result of Silvertown tunnel will be increased vehicle traffic (which is motor vehicle traffic), I am extremely concerned that air quality in south east London will worsen. I oppose air quality worsening, therefore oppose the Silvertown tunnel project."
Members of the Public/Businesses
Richard Stow
"I object to this scheme , as it will increase traffic and pollution in a deprived area of London, and lead to a shift from Public Transport, in addition its cost is far too High @ 1 Billion and the money would be far better spent on Public Transport, benefiting NOn Drivers, the Disabled and Disadvantaged. In addition Public Transport Investment, will stimulate economic Growth, create Jobs and develop diverse economy, as Evidenced by the East London Extension on London Overground."
Members of the Public/Businesses
Richard Sylvester
"As a local resident and self employed person I wish to object to the proposed new Silvertown Tunnel on the following grounds: 1. It will increase congestion during peak hours (we experience this "peak" regualrly as 6.45 - 9.30 am and 4-7 pm locally) on the A102M and the local feeder roads including Blackwall Lane 2. Increase i vehicle movements - and stationary queuing vehicles at peak or congested times will add to the already poor the air quality and associated ill health in the area (SE10) 3. I do not feel that TFL have adequately explored the public transport options including for example, new cross river bus routes - car sharing and more affordable day parking to encourage park and ride from the 02 onto jubillee line and river ferries."
Members of the Public/Businesses
Shirley Broughton
"1. The proposed road will generate more traffic, congestion and pollution. 2. The scheme will not support regeneration in the affected areas or provide the promised economic or social benefits. 3. TfL hasnt properly considered possible alternatives, eg. new public transport options or better traffic management. 4. The risks to the Maritime Greenwich World Heritage Site have not been properly considered. 5. TfL has not provided adequate mitigation for noise or air pollution. 6. The environmental impact of better access for HGV's and buses has not been properly considered. 7. TfL has not properly considered the effect of tolling on the wider road network, eg Rotherhithe Tunnel. 8. The toll will have a negative impact on local business. 9. There has been insufficient consultation with local communities affected by the scheme."
Members of the Public/Businesses
Susan Jenkins
"I wish to register my opposition to the Sivertown Tunnel because of the following concerns: The increase in traffic volume. The increase in congestion caused by additional traffic using the A102(M) and surrounding roads to access the Silvertown Tunnel. The increase in pollution caused by additional traffic in the Greenwich area. As a Greenwich resident living wilthin 100m of the A102(M), I am aware of the effect heavy traffic and idling engines waiting to access the Blackwell Tunnel can have on the air quality in the area. Both my husband and I have asthma, which is severely affected by pollution caused by the increase in traffic in our immediate neighbourhood, and a new tunnel without adequate road access with increase the problem."
Members of the Public/Businesses
Ben Page
"I oppose the Silvertown Tunnel as I believe it will add to congestion in the areas around the area (both north and south of the river). In particular I am concerned about the impact along the Woolwich Road on the Greenwich World Heritage site. I do not see convincing evidence for future regeneration from a new tunnel in the areas most affected, such as the neighbourhood where I live on the south side of the river. I believe it will continue to add to local air quality problems in my street and those around it. Neighbours have already fled the area following the development of asthma in their children. I have not seen convincing plans for adequate improved noise mitigation for the streets in this area (I am listening to the traffic noise from the flyover as I write this). I believe it will change the balance of traffic passing through London by encouraging HGVs, including the very largest lorries to take this route with issues for health and safety. I believe it sends the wrong signals about the future of private road-based transport at a time when London is becoming less car dependent. I do strongly support the introduction of tolling. "
Members of the Public/Businesses
Shoosmiths LLP on behalf of Brenntag UK Limited (company registration no. 05262170)
"Brenntag UK Limited: Silvertown Tunnel Project – Relevant Representation Introduction & Background Brenntag is a global market leader in chemical distribution. With its headquarters in Mulheim an der Ruhr, Germany, the company operates a global network of sites, based in more than 480 locations, across in the order of 70 countries. Brenntag provides a link between chemical manufacturers, suppliers and users, offering tailor made distribution solutions and a formal route to market for industrial and speciality chemicals. Brenntag UK Limited operates from 21 strategic locations around the UK and Ireland, with an integrated network of production facilities, warehousing and storage depots and distribution centres. Brenntag Inorganic Chemicals Limited (“BICL”) is the leasehold owner of approximately 2.43 hectares of land at Tunnel Avenue, Greenwich (the freehold owner being The Official Custodian for Charities, on behalf of The Trustees of the Charity of Sir John Morden, known as Morden College) (“the Greenwich site”). The Greenwich site, a critical commercial and operational component in the Brenntag UK and Ireland network, is comprised of offices, warehousing for both material and life science grade products, bulk storage for acids and lyes, associated package filling capabilities, and general storage. As regards the package and storage of leisure (i.e. swimming pool and spa) chemicals, the site serves the entirety of the Brenntag UK Limited group. Warehouse throughput (outbound) at the Greenwich site is in the region of 30,000 tonnes per annum, with this volume of products being distributed throughout the south-east region of the UK. The Greenwich site has and continues to be the focus of significant investment, aimed at both maintaining the site’s existing infrastructure, and in order to enhance its strategic role within the Brenntag UK and Ireland network. This investment has principally facilitated the development of the Greenwich site as the UK hub for the packaging and storage of leisure chemicals, and allowed for the significant improvement of local warehousing infrastructure in order to meet the demands of the food, feed and pharmaceutical sectors. Due to the hazardous nature of certain of the products stored and handled at the Greenwich site, its operation is governed by COMAH legislation. Operating at the ‘Lower Tier’ level, the site is heavily regulated by the Joint Competent Authority (i.e. the UK Environment Agency and the Health and Safety Executive). The Silvertown Tunnel Project Brenntag UK Limited (representing the interests of BICL) has been in discussions with Transport for London (“TfL”) regarding the Silvertown Tunnel Project (“the Project”) since September 2015. Brenntag UK Limited shall be referred to hereinafter as “Brenntag”. The project proposals for which development consent is being sought will necessitate the acquisition of a swathe of land at the front of the Greenwich site, adjacent to Tunnel Avenue, from which access into the site (i.e. the main vehicular access) is currently taken. Temporary possession of a strip of land within the same location will also be required to provide an area of working space. In all cases, the land at the Greenwich site is required for the carrying out of improvements to Tunnel Avenue and for the construction of the new Boord Street foot and cycle bridge (the existing footbridge is located immediately north/north-west of the aforementioned main vehicular access into the site). Brenntag does not object to the principle of the Project, however, in the absence of appropriate mitigation, protective and safeguarding measures, the Project will have a severe impact on the continuing operation of the Greenwich site. Given the proposed land take in order to deliver the Project, an optimum solution as regards the internal, physical reconfiguration of the site will need to be identified, programmed and executed. Furthermore, any commercial and operational disruption will need to be minimised and proactively managed not only during the carrying out of any site reconfiguration works, but also, crucially, during the construction and operational phases of the Project. Brenntag is about to embark on negotiations with TfL as regards the Heads of Terms and substantive provisions of a Land and Works Agreement, which it is hoped will secure the implementation of the aforementioned mitigation, protective and safeguarding measures. However, pending an agreement being reached, a summary of Brenntag’s primary concerns in relation to the Project and its anticipated impact on the Greenwich site is set out below. Impact of the Project – Key Matters of Concern As already stated, the permanent acquisition of land to the front of the Greenwich site, adjacent to Tunnel Avenue, will lead to a reduction in the overall site area (by approx. 865sq. m.), which, in turn will necessitate the internal, physical reconfiguration of the site. In particular, the main access into the Greenwich site will need to be relocated, existing on-site structures, including a sprinkler tank, pump house, office block and a series of bund walls, will require demolition, and the existing staff and visitor car park (located to the south-east of the site’s main access) will need to be relocated (necessitating the bringing back into use of currently non-operational land which may require substantial remediation). It is anticipated that the execution of the above-mentioned works to reconfigure the Greenwich site will take in the order of 12 weeks. Brenntag has prepared a preliminary scope of works and budget/costing schedule, and shared the same with TfL. However, a detailed agreement is required to be reached in respect of the execution and completion of the works, both in terms of the party responsible (i.e. implementation and cost) and, crucially, timing. Significant and unacceptable levels of business disruption are anticipated in the event that the works to reconfigure the Greenwich site and the construction works for the Project are undertaken in parallel. Turning to the impact on the Greenwich site during the construction and operational phases of the Project, there are a number of areas of uncertainly in respect of which Brenntag is seeking clarification. The site is currently served by four access points: the main access point off Tunnel Avenue and three secondary accesses located on Morden Wharf Road, an access further down Tunnel Avenue adjacent to the site’s main offices, and a smaller access off the Thames Footpath. The supporting documents submitted by TfL with their application for development consent offer assurances of access/’reasonable’ access to business premises being maintained throughout the construction period (estimated to be for in the order of four years, starting in March 2019 and ending in March 2023, followed by a period of tunnel testing and commissioning). A clearer understanding of what is meant by ‘reasonable’ access, the measures which will be put in place to secure this, and how the phasing of the construction of the Project (details of which are contained in the Construction Method Statement for the Project [Document 6.3.4.1]) will impact specifically on the availability of the accesses at the Greenwich site (subject to the suitability of the secondary accesses in particular being investigated and confirmed), both for normal business usage and in the event of an emergency, is required. Typically, commercial vehicle movements in and out of the Greenwich site number in excess of fifty per day. The site has a fleet of seven Heavy Goods Vehicles (“HGV”) and one Light Goods Vehicle (“LGV”). Outbound distribution activity (i.e. customer deliveries) is also supported by third party logistics providers with their own means of transport. Furthermore, the Greenwich site is the recipient of a high volume of inbound traffic primarily associated with bulk stock replenishment and customer purchases/collections. It will be imperative for the Construction Traffic Management Plan prepared in respect of the Project, and specifically, the Greenwich work site, to take account of the vehicle movements (both their number and nature) generated by the commercial businesses located along Tunnel Avenue, including Brenntag’s facility, in order that current efficiency levels and service standards (both during standard and high demand periods) are maintained and that commercial vehicular traffic entering and exiting the relevant businesses can continue to do so safely. Given the already very heavy traffic volumes within the Tunnel Avenue area, this is a matter of particular concern for Brenntag. Brenntag notes the reference in the supporting documents submitted by TfL with their application for development consent, specifically the Code of Construction Practice [Document 6.10], to a Community Engagement Plan and the establishment of a Community Liaison Group, however, to date, there has been insufficient dialogue between Brenntag and TfL regarding stakeholder engagement during the construction phase of the Project and how this will be managed. Considerably more comfort is required in relation to this issue. Brenntag staff (35 direct employees) and visitors to the Greenwich site currently have access to a car park located south-east of the site’s main entrance. Upon parking their cars, staff and visitors needing to access the main offices at the site, located further along Tunnel Avenue and adjacent to the Thames Footpath, leave the Greenwich site through a pedestrian access gate situated on Tunnel Avenue. They then follow a pathway to the site’s main offices, which are accessed via another pedestrian gate. The land take proposed in order to the deliver the Project will mean that the existing car park has to be relocated to the south and that the route of the aforementioned pedestrian pathway will be in direct conflict with the area required by TfL to provide a temporary work space and, consequently, the works required to improve Tunnel Avenue and to construct the new Boord Street foot and cycle bridge. In the absence of robust measures to resolve and/or manage the above-mentioned conflict, Brenntag staff and visitors will have the option of accessing the main offices through an operational part of the Greenwich site, which will mean having to negotiate a number of potential hazards, including HGV, LGV and forklift truck movements and chemical storage tanks. Alternatively, they will have to make their way through what is, in effect, an operational and active TfL construction site. Brenntag does not consider either of these options to be acceptable, and is seeking an assurance from TfL that appropriate measures can and will be put in place to secure an appropriate and safe pedestrian route for its staff and visitors to the Greenwich site from the relocated car park to the site’s main offices. Concluding Remarks The Greenwich site is a critical part of the Brenntag UK and Ireland business. It makes a major contribution to Group performance and plays an integral role in both serving the company’s customer base in the south-east of the UK, and in supporting the wider integrated national network of Brenntag sites. The delivery of the Project, and the public benefits it promises to deliver, should not be at the expense or to the material detriment of such a significant, thriving business (having regard to its economic contribution) and local employer. "
Members of the Public/Businesses
Ingrid
"I oppose the planned Silvertown Tunnel. The traffic network south of the proposed tunnel is stretched to breaking point as it is. Hefty housing development is currently under way on the Greenwich peninsula. A port for cruise ships is being built. Adding another tunnel will further choke up the roadwork. It will attract MORE road traffic, something the roadwork cannot cope with. A toll system will only worsen the problem encouraging motorists to drive along to Rotherhide tunnel. The air quality in the Charlton area is highly toxic already. More traffic will NOT improve this. People LIVE here!!!Treating heart and lung disease is costly. Public transport is the obvious main part of dealing with the expanding population in London. This infrastructure needs the development funding. Attracting more road traffic only augments the problems of congestion, health and quality of life"
Members of the Public/Businesses
Joan Sakkas
"Deeply concerned about the increased pollution this will bring, already we have a serious pollution problem in the Area with many suffering from lung damage, both children and adults. This will increase the pollution levels to an even more serious problem. I am worried about the fuutre of the local population! Some years ago LBG banned HGV's using the through roads of Greenwich because of their concern, so why is this now changing?"
Members of the Public/Businesses
Patricia Taylor
"As a Charlton resident, I have great concern about the building of the Silvertown tunnel. My main objection is that the amount of traffic which uses the blackwall tunnel causes unacceptable levels of pollution which results in air quality which has a serious impact on the health of local residents such as myself but in particular on children. The building of another tunnel would result in an increase in traffic and consequently further impact negatively on the air quality in the region. I am convinced by the research undertaken by Dr Ian Mudway on this subject. As someone who lives very close to the Blackwall tunnel approach on the southern side, I understand and support proposals to develop the infrastructure to reduce current congestion and improve air quality but there are other ways of achieving this which would not have a negative impact on already dangerous levels of air pollution. An improved public transport system would benefit everyone without further deterioration in the environmental impact particularly on air quality. The funds allocated to the building the tunnel could be well spent on public transport for the benefit of all. A proposal to counter the costs of building the tunnel is to charge a toll for its use and it is suggested that by doing this an additional benefit is that potential traffic volume would probably reduce. Would this not be an option now - and so also eg ate the need for an additional tunnel? As a local resident who sometimes uses the car instead of public transport to cross the river, I don't particularly support the notion of a toll for the blackwall tunnel but I support even less an additional tunnel and tolls for each. I trust that the logic used to justify the building of the tunnel will be re examined and a less deleterious plan proposed. "
Members of the Public/Businesses
Tristan Alexander
"It has been proven that additional road bring additional traffic. People in Greenwich and Tower Hamlets already suffer from the poorest air quality in London, to increase the traffic flow through the area would be criminal. Southeast London is poorly served by public transport and disadvantaged by the zoning structure. This inequality needs to be rectified instead of pushing additional traffic through southeast London. Regular incidents on the A12 and A102 cause huge knock on effects across the surrounding areas. Traffic on the A102 would be doubled by the additional tunnel, when the A102 were closed by an incident - which regularly happens traffic would create congestion across the entire borough of Greenwich and beyond to Bexley, and Lewisham. There has been no though put into providing pedestrian, bicycle and public transport access between these areas. "
Members of the Public/Businesses
Carmel Durkin
"As a Greenwich resident I am opposing the development of the Silvertown Tunnel for a number of reasons: 1. I live about 300m from the road which currently leads down to the Blackwall Tunnel and hence the proposed Silvertown Tunnel. It is my view that providing two tunnels from the same northbound approach road WILL substantially increase the traffic. This will lead to increased noise and air pollution. 2. The air pollution in the borough of Greenwich is already at an unacceptably high level. I was diagnosed with asthma in my thirties after moving to live in London, at that point having lived in Blackheath for 4 years. 3. In an age where climate change is an increasing concern this borough should be developing greener ways of travel and opposing schemes that create revenue to the detriment of its residents' health. 4. The view that having two tunnels will ease congestion is flawed. Not only will northbound traffic increase but southbound traffic also and where congestion already occurs as three lanes are collapsed into two at the Sun in the Sands junction, this problem would only get worse so the effect of the Silvertown tunnel would be to increase pollution from southbound vehicles as gridlock builds up, further increasing the pollution less than a quarter of a mile from my home. "
Members of the Public/Businesses
Frank Jennings
"The Silvertown Tunnel could alleviate congestion and pollution north of the river, but would do nothing to alleviate it south of the river. Another tunnel here won't split the same traffic across two tunnels but will attract more traffic, making it even worse on the Greenwich peninsula and surrounding areas. A river crossing east of Blackwall Tunnel and west of the Dartford Crossing could, as part of a well-thought-out joined-up transport strategy, alleviate not only congestion but also the build up of pollution in such a confined area. For example, consider replacing the Woolwich ferry with a tunnel using the same feeder roads."
Members of the Public/Businesses
Helen Hutchinson and Duncan Marley
"Dear Sir/Madam, We live at   Road and wish to formally lodge our objection to the proposed Silvertown tunnel. People living in southeast London are living with air pollution levels of as much as two-and-a-half times over European legal limits: http://www.silvertowntunnel.co.uk/our-study/2014-silvertown-tunnel-pollution-study-results/ This proposed tunnel would make this even worse. New roads lead to more traffic. One of the most polluted congested roads in the UK (the A2) thunders past the back of our house. Our house shakes, there are cracks in the walls and you can't hear yourself talk in the garden. We NEED a noise and pollution barrier down the back of   Road. We DO NOT need a tunnel built that will only increase the noise and pollution levels and the number of HGV trucks either hurtling down the back of our house causing it to shake or being stuck in traffic leading to pollution smog. This proposed tunnel must not go ahead – however a pollution and noise barrier down the A2 to protect the residents of Siebert Road from further risk of health issues and damage to property must be put in place. Yours faithfully, Helen Hutchinson and Duncan Marley "
Members of the Public/Businesses
Metin Calim
"This connection is urgently needed for vehicles to relieve pressure on all surrounding transport networks How can an area of the nation's capital with an airport included , be so left behind in connections to the south of the river Thames and south eastern England , for so long is unbelievable. I have to use that arcane ferry which fills up with just 4 juggernauts. Some one speed this project up asap."
Local Authorities
London Borough of Redbridge
"The London Borough of Redbridge has noted with interest the proposals developed by Transport for London for a new road crossing under the River Thames in the form of the Silvertown Tunnel linked to the present highway network in the Silvertown and Greenwich Peninsula areas. In the context of addressing traffic congestion and closures at the existing Blackwall Tunnel and supporting further growth in London, based upon information made available by Transport for London in respect of its proposal, this Borough is supportive of the Silvertown Tunnel project being delivered, complemented by associated proposed alterations to the approaches and operation of the Blackwall Tunnel. This Borough’s view has been reached against the background of that information indicating that implementation of the Silvertown Tunnel would result in wide benefits in the East and South East London sub-region, and would only have relatively modest and generally neutral impacts overall upon the London Borough of Redbridge area. Specifically with regard to Transport for London’s modelling of traffic impacts, the Borough notes that the introduction of the Silvertown Tunnel is not expected to lead to any significant overall increase in traffic levels, and that no further steps beyond the proposed user charge are presently envisaged to be necessary to mitigate the impacts of the Silvertown Tunnel scheme upon traffic. It welcomes, nonetheless, Transport for London’s intention to monitor traffic levels before and after the opening of the new tunnel and for appropriate measures to be taken to manage and mitigate any negative effects that might occur as a result of the scheme, working closely with the relevant local authorities. In that regard, the Borough is pleased to be a participant in the Silvertown Tunnel Implementation Group that would be established to monitor traffic impacts and make recommendations for any mitigations and for potential variations to the user charge. The Borough supports the setting of the initial charge being based by Transport for London upon updated information on traffic, environment and other general factors including background growth and developments, particularly in east London. It considers that any eventual surplus revenue generated by the charge after building and maintenance costs have been taken into account should be concentrated upon other transport improvements in the East and South East London sub-region in view of its expected population growth and transport network pressures. In summary, as outlined above, the London Borough of Redbridge supports the introduction of the Silvertown Tunnel scheme as presently proposed. "
Members of the Public/Businesses
Nicholas Pouyiouros
"Challenge charging for use of new tunnel -Request free use of tunnel for all inhabitants of boroughs the scheme connects -Request allocation of free tunnel use passes for a limited number of passes a year for local residents -Challenge charging for existing infrastructure which takes traffic across the river in east London e.g. Rotherhithe tunnel, due to this proposal -Legal enforceable end date for charging, when scheme paid off -Request more than one scheme is built to move traffic across the river in east London -Challenge slow pace of progress and build -General challenge due to scheme -Ensure local community properly treated "
Members of the Public/Businesses
Iris Dove
"The proposal will lead to increased traffic congestion in the Charlton area and beyond."
Members of the Public/Businesses
Justin Sylvester
"As written in my response to the consultation document, I believe the project is unnecessary and the inconvenience the building of the tunnel will cause will outweigh the minimal benefits of the tunnel."
Members of the Public/Businesses
Matthew Field
"I object to the sivkertown tunnel for many reasons. 1.too close to existing tunnel using the same roads to approach the tunnels. An accident on the approach will seize both tunnels. 2. Its too costly for building....and just for 1 lane for cars /motorcycles 3. There are more deserving needs of a tunnel (between Dartford and Blackwall) 4. Tunnel will not help the commuters as they will have to pay £120 a month. 5. Concerned about the north of the junctions.... Cause congestion."
Members of the Public/Businesses
Meirion Jones
"AGAINST BUILDING SILVERTOWN TUNNEL The evidence is unambiguous that building another tunnel will increase the amount of traffic passing under the Thames in the Blackwall/Silvertown area. To the South the Silvertown tunnel will suck more traffic in along the A2 and A20 corridors, which are already at saturation point, and increase pollution. From the North building a new Ikea at the southern end of the Silvertown tunnel (on the old Sainsburys site) will increase the amount of traffic coming from North of the river - particularly at weekends. As the proposal is to toll the new tunnel an experiment of tolling the existing tunnels should be tried before committing to a new one. A toll would discourage the budget hauliers and long distance commuter traffic coming in from South East London and Kent. Meirion Jones   "
Members of the Public/Businesses
Peter Underwood
"I am writing to object to this project because I believe it is the wrong solution to the problem and its wider impacts have not been properly assessed. TfL should be getting more people to use public transport instead of investing in more road schemes and I don’t believe that TfL has properly considered the alternatives to a Silvertown tunnel, such as new public transport options or better management of the existing network. I am also concerned this development will make congestion worse in the surrounding areas rather than better as it will attract even more traffic to streets that are not coping with existing levels. On the wider impacts, I don’t believe that TfL has conducted a full environmental impact assessment of the scheme. London already suffers with illegal levels of air pollution and this scheme is likely to make the situation worse. Although I don’t live in close proximity to this development I believe that if it goes ahead it will set a dangerous precedent of building ill thought out and ineffective road schemes that will suck money away from better projects that would be of more benefit to Londoners."
Members of the Public/Businesses
Richard Smith
"I am deeply concerned about this project as the tunnel will lead to more congestion around Woolwich and Plumstead increasing the already high pollution in the area. Decreasing the already low air quality around the effected Woolwich main Rd. The effects of air quality has already been shown to effect young children and yet the proposal would lead to a increase in pollution around many schools."
Members of the Public/Businesses
Nicholas Marks
"Traffic forecast The traffic forecast has failed adequately to address the likely incerase of traffic flows due to both latent and induced demand, let alone population growth. TfL’s forecast of a reduction on private motor vehicle trips following the opening of the tunnel is not credible Economoic Assessment The economic assessment identifies 20,000 jobs available north of the Thames for residents south of the Thames, which will be accessible by private motor vehicle. Given that TfL forecast a reduction in privite motor vehicle trips either the econimic benefit of the tunnel is false or the traffic forecase is false. Charging to Control Demand Charging has been identified by TfL as their preferred mechanism to control demand. TfL have not provided evidence to show that this tool will be effective. Environmental Assessment The environmental impacts of the operation of the tunnel are dependent on the accuracy of the traffic forecast. If the traffic forecast is inaccurate, the environmental impact must also be inaccurate. "
Members of the Public/Businesses
Phil Buckley
"I believe that this tunnel will have a negative impact on east London - the increase in motor vehicular traffic will cause more air pollution and noise pollution. Air pollution is a critical problem in London at the moment and this tunnel will make it worse. I believe that modal share *away* from motor traffic is essential and this scheme is the exact opposite of that. I do not believe that TfL has adequately considered alternatives."
Members of the Public/Businesses
Andrew Riley
"New roads simply generate more traffic: the Silvertown tunnel would serve only to increase congestion. It would also lead to a rise in "rat running" through local streets in Greenwich as drivers attempt to avoid paying the tunnel charge, and increased congestion in the Rotherhithe tunnel for the same reason. As a local resident, I cannot see how the proposed scheme will provide any economic or social benefit. Instead it will degrade the quality of life of local residents with increased road noise as more traffic is attracted to the new road. In the short term - a period nevertheless likely to span several years - it will generate unnecessary construction noise and dust, high levels of construction traffic, diversions, traffic delays and significant disruption to local residents and businesses. Worst of all, the scheme will lead to a further rise in air pollution. I have not read anything in the associated documentation that demonstrates, conclusively, that air quality will improve; Transport for London's surveys and data are woefully inadequate. Far more detailed analysis is needed in this area, and by an independent expert organisation so as to ensure a truly impartial, objective view. Air pollution in Greenwich is already among the highest of any London borough. I myself developed asthma, in my thirties, after moving to East Greenwich. Local GPs report a high level of respiratory conditions in the local population - just ask them. I do not believe that Transport for London has properly considered alternatives, including improved public transport and better management of the existing transport network. More roads are not the solution. Tolling would also have a negative impact on local businesses. Why should businesses and residents in south and east London have to pay to cross the river when people in west London can cross the Thames without charge via one of the many bridges in west London? For the above reasons I oppose the Silvertown tunnel scheme"
Non-Statutory Organisations
Federation of Small Businesses
"We will be covering the following in our submission: o Lessening the impact on small and micro businesses of the charge and during the development o Root-and-branch reform of the entire Congestion Charge scheme, including tunnel charging. o One registration system for business vehicles for all charging schemes. o Fair, equitable and appropriate packages offered at the outset to small businesses facing trading difficulties or closure due to major public construction work. o The Mayor to encourage and support small businesses to supply to London Government and its related departments through a single portal. o Ensure that procurement processes are compliant with best practice, and closely monitor implementation of the prompt payment provisions within the Public Contracts Regulations of 2015. o Split large contracts into smaller lots to create more opportunities for small firms, and avoid contract aggregation wherever possible, to enable more micro and small companies to bid. o Encourage consortium bids of micro and small businesses by relaxing finance diligence until they are awarded the contract (i.e. formal formation of the group). FSB submission in the last consultation said that our preferred option was for a tolled Silvertown tunnel with a peak, off peak and free rate running parallel to a non-tolled Blackwall Tunnel. We said that we were supportive of the new Silvertown tunnel; however, to simply charge businesses to use an existing free stretch of road (the Blackwall Tunnel) would add another business cost onto small businesses. We urged TfL to lessen the impact on small and micro businesses operating in London. "
Members of the Public/Businesses
Joel Kosminsky
"The TfL Consultation response was over 1100 pages - too much to read - with an unclear Executive Summary; it also appeared to reject every objection. I live beside the East Cross Route (which will take the burden of new and diverted through traffic) at Hackney Wick. As a former Underground station planner (eg Angel station), the 'Sparks Effect' applies, and TfL's consequent under-estimation of new traffic. The East Cross Route is congested now; 'blue light' vehicles now use my residential road   instead, due to traffic levels at Hackney Wick interchange. Silvertown Tunnel will not alleviate this. Noise levels for homes abutting new facilities were demonstrably greater in the consultation material at Canning Town, but this evidence was deep inside one of the thicker documents. It needed over 5 minutes to find and much longer to read. Noise from new traffic also deteriorates air quality through new pollution. As that former [railway] planner I examined the Tunnel's northern portal junction layout: at-grade traffic crossings create tailbacks in all directions, affecting Commercial Road and further north at peaks. CPO'd land will evict small businesses providing vital local employment. No assistance is offered. There is no similarly-priced local site to relocate to; unemployment will result and no substantive evidence was offered of new / alternative employment. As a pensioner now and a near-daily bus user, I visit South London on a reasonably regular basis, I did not see any practical new or diverted routes. As a former London Bus Schedules / Central Traffic Division worker, these proposals are too localised. Buses are not sufficiently separated from other traffic, particularly at the Northern Portal junction. On all of these grounds, I register a strong objection to the Tunnel."
Members of the Public/Businesses
Mr R Poldermans
"I object to the Silver town tunnel on the following grounds. 1. The pollution to are area 2. extra traffic on are road from the A2 3. The cost of the tunnel tax payer 4. the cost to use the tunnel "
Members of the Public/Businesses
Steven Baldwin
"I object to the proposal fro Silver Town Tunnel: 1. Air quality in the area: this is poor enough with out making it worse, by increasing the amount of traffic that passes through the area. 2. Access issues for local residents: in the last 12 months a number of large sacel development have come online, with more in the immediate area to follow: the lea mouth flyover will be over corded with increased number of residents set to move into the immediate area in the next 2 years. The runner will make this worse for all involved. 3. The tunnel seeks to improve things, not I feel for those that live in the area as ordinary people, but for other road users needing to cross London. 4. By making it easier to cross London/Thames with the Silver town tunnel at this point, we encourage traffic to come into central London, rather than join gout to the M25 and using an orbital. 5. As London a a whole is encouraging less use of motorised transport, why are we doing things that will encourage it in the area? 6"
Non-Statutory Organisations
East Sussex Healthcare Trust/Eastbourne district general hospital
"Looking at the areas of delivery from were we are situated in Sussex we deliver to north London. The products we supply are required for patient care within the NHS environment. With the increase of vehicles in the London area this tunnel will make delivery times more realistic."
Non-Statutory Organisations
Freight Transport Assiociation
"FTA believes there is an urgent need for new road river crossing in East London to reduce congestion, improve connectivity, provide greater resilience and support growth and new residential and business developments are constructed. We therefore strongly welcome proposals for a new tunnel at Silvertown. The Blackwall Tunnel is a major pinch point in the capital, particularly in the morning and evening peaks. FTA figures calculate the cost of congestion for an HGV at £1 a minute, so the daily queues are costly for business. Stop-start traffic also has a hugely detrimental impact on fuel consumption and emissions, increasing transport costs, carbon emissions and leading to poor local air quality. The height restriction at the Blackwall Tunnel means that many HGVs have even fewer opportunities to cross the Thames within London and the Woolwich ferry suffers from reliability issues. This adds additional time and cost to transport companies servicing the capital and results in higher prices for London’s businesses, residents and visitors. FTA accepts that charges may need to be introduced to both fund the new infrastructure and to manage demand. However, any demand management measures implemented on new river crossings should be focused on those who have alternatives (i.e. private car drivers) rather than essential delivery vehicles which have little alternative option but to use the capital’s road network. At the very least, there should be a flat rate for all vehicles, with fleet discounts and lower rates for cleaner/greener vehicles more in line with the Congestion Charge system. FTA strongly advocates the proposals for shared HGV and bus lanes, which provide recognition that these are essential users making the most efficient use of road space. It is also a sensible way of ensuring that the bus lane is used as efficiently as possible whilst maintaining journey time reliability for the new bus routes which will use it. There has been lots of investment in rail river crossings over the last few decades, but in contrast, the road network has been severely neglected. This new infrastructure is long overdue and strongly welcomed. About FTA: The Freight Transport Association (FTA) is one of the UK’s largest trade associations and represents over 15,000 companies relying on or providing the transport of freight both domestically and internationally, to or from the UK. Our members include hauliers, freight forwarders, rail and air freight operators, through to customers – producers, manufacturers, wholesalers and retailers. They cover all modes of transport – road, rail, air and sea. FTA members operate over 200,000 commercial goods vehicles on the roads in the UK, which is approximately half of the UK fleet of goods vehicles. FTA members also consign around 90 per cent of goods moved by rail and around 70 per cent of goods moved by air and sea. "
Non-Statutory Organisations
Friends of the Earth Hackney & Tower Hamlets
"Friends of the Earth Hackney and Tower Hamlets is a group of volunteers, committed to campaigning on local environmental issues. We have been working with residents and community groups in both boroughs for over 30 years to campaign for a greener, safer, healthier environment for Hackney and Tower Hamlets. We are submitting this written representation to object to the proposed Silvertown Tunnel, which we believe will negatively affect the health and wellbeing of residents in Tower Hamlets. Our specific reasons for objecting are: • There is strong evidence that, rather than reducing congestion and air pollution, building new roads generates additional traffic through induced demand[1], which in turn leads to worse congestion overall, and to worse pollution[2]; • London is already one of the most polluted cities in the UK and the Greater London Authority estimates that nearly 9,500 people die early each year in the city due to long-term exposure to air pollution ; • Tower Hamlets has the third highest figure for early deaths attributable to air pollution in London[3] (8.1%, 85 attributable deaths per annum), and through traffic is the cause of 60% of air pollution emissions in the borough[4]; • Tower Hamlets is the third most deprived local authority in the UK[5], and people living in deprived areas are already more affected by poor air quality[6]; • We believe that any economic benefits the scheme will deliver to the residents of Tower Hamlets will be far outweighed by the increase in air pollution and its associated health impacts; • We believe the proposed infrastructure investment would be far better spent on a package of non-road crossings and complementary measures for the area, which would help improve connectivity without adding to traffic and air pollution; and • We need to take urgent action on carbon emissions to tackle climate change. Carbon emissions from the transport sector accounted for just over a quarter of all carbon dioxide emissions in 2014[7] and because of this we need an urgent structural shift away from reliance on fossil fuel-based transport options. We look forward to the opportunity to provide further and more detailed written evidence as the project moves into the Examination phase, and will be willing to speak at any hearings as appropriate. [1] http://www.bettertransport.org.uk/roads-nowhere/induced-traffic [2] https://www.theguardian.com/environment/2015/jul/15/nearly-9500-people-die-each-year-in-london-because-of-air-pollution-study [3] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/332854/PHE_CRCE_010.pdf [4]http://modgov.towerhamlets.gov.uk/documents/s83927/HWBB%20%20Air%20Quality_FINAL%2004032016.pdf [5] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/465791/English_Indices_of_Deprivation_2015_-_Statistical_Release.pdf [6] https://www.london.gov.uk/what-we-do/environment/pollution-and-air-quality/air-quality-and-health [7] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/416810/2014_stats_release.pdf "
Non-Statutory Organisations
Greenwich Millennium Village Association
"Pollution readings taken in and around our neighbourhood are already well in excess of EU limits. The Silvertown Tunnel cannot make any legitimate claims to ease pollution, and in fact cannot make legitimate claims that it won't increase pollution. The health and lives of the residents of this peninsula, which is now becoming a premiere region of London, are at risk because of pollution."
Members of the Public/Businesses
Kevin Groom
"I regularly travel from SE London to North London and return and the journey can take anything from one hour to in excess of three hours due to traffic conditions at the Blackwall Tunnel. It is a pinch-point and whenever there are problems, breakdowns oversize vehicles to name but two the whole of the surrounding area becomes gridlocked. Whilst I accept that just building another road is the answer in every case, in this one I believe it is. As a South East Londoner I get very frustrated when I hear those people from West London complain about the lack of crossings and then to cap it allthey are talking about building the Garden Bridge. Surely the money being spent on that would be better spent freeing up South East London from daily gridlock"
Members of the Public/Businesses
Lime Logistics Ltd
"The current traffic congestion experienced by cross Thames road traffic between Dartford Crossing and Rotherhithe is severely hampering not only our ability to service our clients, but industry in general. The frequency that one or more of the crossings are closed or restricted on a daily basis is increasing, with the severe disruption created expanding outwards to surrounding roads and areas causing gridlock. This is costing UK Ltd billions of £££s in lost revenues and increased costs. Industry needs additional Thames crossings that allow commercial traffic to flow easily. The current suggestion that vital traffic ( trucks, buses, vans etc) will be charged to fund these crossings is once again penalising industry, as we have no alternatives but to use roads that are inadequate for modern traffic requirements. The traffic that has an alternative - ie private cars etc should be made to contribute more than they currently do. In addition, new routes should be designed so that buses and trucks can use the same lane(s) and therefore speed up traffic flow, reduce congestion and more importantly reduce the financial burden on UK Ltd industry. "
Non-Statutory Organisations
Maritime Academy Trust/Millennium Primary School
"Pollution readings taken just outside our school are already well in excess of EU limits. The Silvertown Tunnel cannot make any legitimate claims to ease pollution, and in fact cannot make legitimate claims that it won't increase pollution. "
Members of the Public/Businesses
Philip Marsden
"i support the proposed new crossing to relieve congestion and give better connections between southeast and the eastern side of UK"
Members of the Public/Businesses
Tiffany Beck
"Pollution readings taken in and around our neighbourhood are already well in excess of EU limits. The Silvertown Tunnel cannot make any legitimate claims to ease pollution, and in fact cannot make legitimate claims that it won't increase pollution. The health and lives of my family are at risk. "
Members of the Public/Businesses
TNT
"TNT is supportive of the plan to build a new river crossing as in the Silvertown Tunnel proposal. There is obvious need for more river crossings to reduce congestion and the critical risk that the Dartford Crossing presents. TNT would be able to better route plan to service the areas both north and south of the river if there were alternative crossing opportunities and this would make our road operations on the East side of London much more efficient allowing us to reduce routes and/or increase vehicle productivity. These resulting improvements would help reduce congestion and commercial vehicle activity in this area. The new crossing would improve traffic flows which is proven to improve air quality accordingly."
Non-Statutory Organisations
Confederation of Passenger Transport
"The Confederation of Passenger Transport (CPT) is the National Trade Association representing the Bus & Coach Industry in the UK. CPT members provide both scheduled and non-scheduled services which rely on the effective operation of the Capital's road links for the efficient operation. It is regularly reported that the cross-river links are something of a "pinch point" and additional capacity is to be welcomed for this alone. It is widely recognised that under developed transport links in this part of London have been a restriction on growth in the area. The lack of cross-river connectivity is undoubtedly a factor and CPT warmly welcomes this and other proposals which will tackle the issue and offer greater opportunities in London. Commuter coach services offer both choice to consumers and travel options from areas poorly served by rail services. These services suffer badly from the lack of resilience in cross-river links, this has undoubtedly had an impact on the prospects for these services which we firmly believe can provide London employers with access to a labour force, and conversely employees with opportunities currently unavailable to them. The local services within London would also benefit greatly from the proposals and provide consumers with a much wider variety of options for employment, education and leisure, promoting growth in a much underdeveloped area of London. CPT's particular interests in the Silvertown project are: - Promoting the improved resilience the project offers - locally and nationally. - To support the possibilities for efficient and environmentally friendly public transport afforded by the tunnel. - To represent both our members and their customers in supporting the bus and coach priority measures proposed as part of the project. - Promoting Recognition of the significance of this project as part of the National road network. CPT looks forward to playing a full and active role during the period of examination by the Planning Inspectorate and hopes the project can be delivered to realise all the hopes and opportunities we firmly believe it offers."
Members of the Public/Businesses
Daniel O'Loghlen
"To Whom it may Concern, I am writing to register my opposition to the Silvertown Tunnel Project. In my area we already suffer greatly when the Blackwall Tunnel is blocked. The local roads to and from the Woolwich Ferry ( Shooters Hill Road and Academy Road ) become jammed and no one is able to get anywhere. Placing another tunnel next to the Blackwall, which is already at full capacity, is going to put enormous pressure on the local infrastructure; as we know, new roads generate more traffic. I have a small child and I am extremely concerned about the pollution created by this new crossing with its affects on our health and the health of our children with asthma on the increase due to pollution. I do hope you will consider this project fully and think of all the communities that have not been fully consulted up to this point, but yet will be the ones adversely affected by it. Many people I speak to locally have no prior knowledge of the Silvertown Tunnel! Yours sincerely, Daniel O'Loghlen   "
Members of the Public/Businesses
Dermot McLaughlin
"I object to the Silvertown Tunnel. My local area, Deptford, is cut in half by the A200. We already suffer from noise and pollution from traffic running through Deptford. A new bridge will just increase that traffic. Instead, we should build river crossings that allow more public transport, cycling and walking. This will make Deptford a better community to live in, and I'd guess Southwark and Greenwich as well."
Members of the Public/Businesses
HaulTech Ltd
"Although our business is based in Staffordshire we regularly work in London and we completely support the river crossing proposal and strongly recommend that it should go ahead . It has been proven that it will ease the serious traffic congestion caused by the insufficient river crossings currently available . Regards Bob Haughton."
Members of the Public/Businesses
Nita Humphreys
"My concern is the damage/loss to the woods and other green areas in Greenwich. Our City is losing many of these areas to cater to infrastructure and housing. I understand why as I have previously had to commute from south to north London but we as a City are renowned for our history and our parks/green areas and to lose these would be a loss forever to us and wildlife. I am also concerned about the difficulties we (residents and commuters) will face with the disruption planned works will have to our already stressful and time consuming journeys. It might look good and work on paper but living with the reality causes anxiety, stress and depression. I'd like to see that all these factors are taken into consideration with justifiable reasoning before a decision is taken. "
Members of the Public/Businesses
Paul McQuillen
"• New roads generate more traffic. The tunnel won’t make the road network more resilient – it’ll only increase congestion. There will be a significant increase in traffic on roads close to where I live in New Eltham and longer-distance travellers attempt to ‘rat run’ between the A20 and the new tunnel. • The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. • TfL has not properly considered alternatives, including new public transport and better management of the existing network. • The scheme does not provide facilities for cyclists and pedestrians to cross the river. • TfL hasn’t given adequate information on the environmental impacts of the scheme • There isn’t adequate mitigation for noise pollution. • The environmental impact of better access for HGVs and buses has not been properly considered. • TfL has not properly considered the effects of tolling on the wider road network, for example, on routes to the Rotherhithe Tunnel, which would remain free. • Tolling will also have a negative impact on local businesses – firms in other parts of London will not have to pay charges to get around. • There’s been insufficient consultation with communities that will be affected by the scheme. "
Members of the Public/Businesses
Sophie O'Loghlen-Vidot
"I oppose the silver town tunnel as I believe the area cannot manage to have more traffic than it already has, I believe any tunnel or bridge should be further away from the blackwall tunnel. The area is already extremely busy with traffic and the public transport cannot cope. I also think the money should be spent on other things like local services. "
Members of the Public/Businesses
Colin Espiner
"I wish to improve the design and scope of the suggested User Charging Scheme (USC). There are a range of reasons given. To paid for the construction of Silvertown tunnel. To reduce congestion, pollution and pay for maintenance. 1) As a motorist I do not mind paying only for the cost of construction. Motorist will be the main but not the only benefiters. 2) TfL states than there is prove that UCS reduce congestion but do not state what this is or how to find it. 3) TfL imply that USC will suppress any large increase in traffic volume. At the same time UCS will not displace any traffic to the nearby Rotherhithe tunnel. 4) I have written evidence from TfL that peak time at the Blackwall tunnel is 7am to 10am (morning) and 4pm until 7pm (evening). Not 6am until 10pm which is identical to Dartford Crossing. 5) Even though I am not a residence, not having a discount is inconsistent with London Congestion Charge Zone (CCZ). 6) I am disappointed about no discount for congestion caused by other reason eg accidents. 7) As for pollution the charges for the same class of vehicle are identical for high or zero polluting vehicle. Also this is within the Low Emission Zone (LEZ). 8) Motor bikes being charged the same as cars for reason of congestion, pollution as well as wear and tear does not make sense. Again I am not a motor bike rider and I would point out they are not charged in CCZ nor all other river crossings. "
Members of the Public/Businesses
DHL
"DHL believes there is an urgent need for new road river crossing in East London to reduce congestion, improve connectivity and support growth and new residential and business developments are constructed. We therefore strongly welcome proposals for a new tunnel at Silvertown. However, we see this as just a starting point and part of a future network of new road river crossings in East London to provide greater resilience for the capital’s road network and spread the traffic flow rather than funnelling it along one route. The Blackwall Tunnel is a major pinch point in the capital, particularly in the morning and evening peaks. FTA figures calculate the cost of congestion for an HGV at £1 a minute, so the daily queues are costly for business. Stop-start traffic also has a hugely detrimental impact on fuel consumption and emissions, increasing transport costs, carbon emissions and leading to poor local air quality. The height restriction at the Blackwall Tunnel means that many HGVs have even fewer opportunities to cross the Thames within London and the Woolwich ferry suffers from reliability issues. This adds additional time and cost to transport companies servicing the capital and results in higher prices for London’s businesses, residents and visitors. The Silvertown Tunnel, coupled with plans for additional road river crossings in East London are therefore vital to support growth, improve connectivity and reduce congestion. "
Members of the Public/Businesses
Kapila Perera
"This is a complete waste of resources. Money would be better spent on rail, cycling and walking infrastructure. Air pollution will undoubtedly increase, with the increased capacity leading to more motor vechicle journeys (which will eventually get congested themselves)."
Members of the Public/Businesses
Ozan Ibrahim
"I commute to work from Greenwich to Palmers Green three times per week. If there are any major issues with black wall tunnel the entire borough of Greenwich becomes grid-locked. We need a extra tunnel to ensure the road network us robust in times of emergency & during the rush hours. Only having a few cRossings east of tower bridge seems to me to be negligent of East Londons needs."
Members of the Public/Businesses
Protem HGV Ltd
"Protem are a dedicated driver employment agency supplying Southeast operators with all classes of professional drivers, around 40% of whom will work in the greater London area on a daily basis. We believe that East London is desperately in need of more river crossings to support growth and ease congestion. We welcome proposals for a new tunnel at Silvertown."
Members of the Public/Businesses
response has attachments
DLA PIPER UK LLP on behalf of Ansco Arena Limited
"1. This summary representation is prepared on behalf of Ansco Arena Limited (previously known as AEG London Arena Limited) ("Ansco"). It is made in response to the application for development consent having reference TR010021 (“Application”) for the Silvertown Tunnel (the "Scheme") promoted by Transport for London (the “Applicant”). 2. A fuller representation setting out the detail of Ansco’s concerns together with relevant plans and drawings (“Representation”) is being submitted by email to [email protected] The Representation should be considered as Ansco’s relevant representation in respect of the Application. 3. Whilst this summary representation and the Representation both constitute an objection, subject to addressing its important and relevant concerns (but not otherwise), Ansco supports the Scheme in principle. This is on the basis that improved transport infrastructure, including an additional river crossing, is essential for the continued growth and development of Greenwich Peninsula (“Peninsula”) and surrounding areas of east London. However, the contents of the Application reveal that the Applicant has failed properly to review and assess Ansco’s requests in respect of transport on the Peninsula. As a result Ansco has a number of significant concerns about the effects of the Scheme on the transport system and the operation of its business at The O2 both during the construction and operational phases of the Scheme. In summary, these include (although are not limited to): 3.1 the provision of a sufficient number of car and coach parking spaces, which are suitably located and operationally workable, to serve The O2 (which is operated by Ansco) and its visitor attractions without degrading the customer experience; 3.2 the impact of construction work on the road network on the Peninsula, particularly during peak ingress and egress periods for events at The O2; and 3.3 the long term impact of user charging at the Blackwall and Silvertown Tunnels on the night time economy of the Peninsula. 4. Furthermore, it is submitted that the Application is deficient as it has not been subject to assessment or analysis of the effects of the Scheme on The O2, which are lawfully required to enable the Application to be determined. Therefore, the Application is premature and, unless these items are properly addressed, development consent should not be granted - indeed it would not be lawful to do so. "
Local Authorities
Essex County Council
"Silvertown Tunnel Scheme Planning Inspectorate Reference: TR010021 Essex County Councils Registration and Relevant Representation Date 25 August 2016 ECC is a neighbouring strategic authority within the definition of the Duty to Co-operate S110 of the Localism Act 2012 and Section 30 of the 2008 Planning & Compulsory Purchase Act 2008. This is a strategic cross-boundary matter and ECC wish to engage with this process as an interested party. ECC is a relevant strategic authority, with the following roles: • A key partner and service provider within Essex promoting economic development, regeneration, infrastructure delivery and new development; • The highway and transportation authority, with responsibility for the delivery of the Essex Local Transport Plan, and • The local education authority; Minerals and Waste Planning Authority and local lead flood authority. Overall, ECC supports the principle of the Silvertown Tunnel scheme to address congestion and closures at Blackwall Tunnel and welcome the opportunity to contribute to this Scheme. The scheme is of significance to ECC, given the importance of and potential impact on the Essex road network for the ongoing security and growth for both London and Essex. Further assessment of the implications and opportunities are required by TfL, including connectivity, capacity and network resilience. The assessments should be extended to include the A12, A127, A130, A13 & M11 (the strategic routes) from Essex, to London, in addition to the provision of further Thames river crossings to the south and east of London as well as the Lower Thames Crossing. These strategic routes are vital for connecting the economies of Essex & London and the impacts on these routes need to be understood, alongside the cumulative impacts from other TfL projects and planned growth (London City east). ECC needs to be satisfied that any impacts on the strategic routes connectivity, capacity and resilience are addressed and potential benefits for the Essex economy are optimised. ECC requires further data and analysis on the wider strategic routes to: • Identify the impact on Essex and surrounding areas, to access both the new Silvertown tunnel and the existing Blackwall Tunnel. • Evaluate the impact, with regard to TfL transport projects in the vicinity of the scheme and Essex. • Establish the projected increase in traffic arising from the scheme and the cumulative impact of current planned growth (and transport projects) including London City east and within Greater Essex. • Establish the implications, sensitivity and inter-relationship on the level of new “tolls” on Silvertown and Blackwall tunnels on transport movements across the wider strategic network, including the Dartford crossing. The evidence should include: • Individual and cumulative impacts with other strategic transport schemes of importance to the Essex economy, communities and their resilience. Emphasis should be placed on the implications on the river crossings, Essex economy and connectivity, capacity & network resilience with East of England. • The full life time of the project, from construction to operation, combined with other strategic transport schemes across London and Essex, and significant planned growth in London city east. • Assessment on “Connectivity” between the Essex and London economies and communities (including commuting), areas beyond and vice-versa. ECC will co-operate with TfL and the examination process. "
Members of the Public/Businesses
John Lewis Partnership
"The John Lewis Partnership fully supports the need for another river crossing in East London. The proposed tunnel at Silvertown will provide a welcome improvement to traffic flows and help to relieve other traffic hotspots, for example the Blackwall Tunnel. The costs of using the tunnel , if any, must also be kept in clear perspective, and consideration to freight vehicles being exempt. "
Members of the Public/Businesses
response has attachments
Knight Dragon
"Summary of Objections This summary of representation is made on behalf of Knight Dragon Developments Limited and Knight Dragon Investments Limited ("KD"). A full letter of objection which expands on the points below is also submitted together with associated plans. KD is the master developer of Greenwich Peninsula; currently the single largest regeneration scheme in London which will help to deliver much needed homes and jobs. KD is supportive of the principle of the proposed new Silvertown tunnel crossing ("the Application") but wishes to make the following objections which are considered significant enough to warrant the Application being refused consent. 1. AEG Car Parking The replacement car park within the Application is ill conceived. The Application fails to address and assess the disruption caused by providing a temporary replacement car park. No consideration is given to the impact upon the parking provision for The O2. The Application identifies one area of land for the replacement car parking. The Application does not contain any traffic impact analysis of the proposals and its subsequent impact on the local highway network and KD also questions whether the reprovision of spaces is appropriate in this sustainable location. KD requires confirmation from TfL that it will be responsible for all costs associated with the provision of any replacement car parking and associated infrastructure together with assurances of appropriate re-instatement of the land. 2. Closure of Edmund Halley Way The Application proposals fail to suitably mitigate the impact of the closure of Edmund Halley Way on the local highway network. 3. Diversion of Millennium Way The proposed temporary diversion to the east of Millennium Way will seriously disrupt traffic and parking on the Peninsula. The Application fails to propose a suitable alternative route to mitigate this impact. 4. Tunnel Avenue Extension to Peninsula Quays The Application fails to propose an early reinstatement of Tunnel Avenue as a mitigation measure to the disruption caused to the Peninsula by the Application. 5. Direct Access to Silvertown Tunnel from Greenwich Peninsula The Application proposals fail to provide suitable access for all vehicles to the Scheme. 6. Other Highway Impacts The Application fails to provide a detailed mitigation strategy, despite the Transport Assessment stating that "the Scheme does have a significant adverse traffic impact on local junctions and highways links", including specific measures and monitoring of the impacts. 7. Failure to Adequately Mitigate the Impact of Construction The Scheme does not mitigate the impact of the construction which will have a significantly adverse impact on the regeneration of the Peninsula. 8. Failure to adequately mitigate impacts on existing buildings The Application fails to make specific provision for settlement agreements. The DCO should contain a requirement for these to be entered into prior to the carrying out of the development. 9. Location of Buildings The proposed location of the southern portal building is inappropriately located on land to the north of the Tunnel. The Application incorrectly states that both parcels of land previously considered are open to the same redevelopment opportunities. The current proposed location benefits from outline planning permission, the land to the south does not currently benefit from planning permission for any redevelopment. The Application identifies a large and disproportionate area within which the head house can be located, creating an unacceptable level of uncertainty for KD in relation to its ongoing redevelopment of the Peninsula. The size and scale of this building is considered inappropriate for the proposed location. 10. Design of Buildings Inadequate consultation has taken place with KD on the design of the buildings. The Application fails to give suitable approval rights for KD regarding the design of the portal building given their close proximity to the 2015 Masterplan proposals. 11. User Charging KD considers that user charging outside of peak periods will have a detrimental impact on the success of the Peninsula for both residents and businesses. 12. Programme The Application fails to provide a detailed programme for the replacement of essential facilities namely the temporary car parking, access roads and pedestrian and cycle links. TfL’s procurement route (PFI) is considered inappropriate for this Scheme and an alternative procurement method should be considered to reduce the Scheme's delivery timescale. 13. Failure to Address the Existing Safeguarding Direction The Application fails to make provision for the existing safeguarding to be removed upon completion of the Scheme. This should be included within the draft Development Consent Order. Conclusions KD considers that the Application is significantly lacking in relation to the consideration of alternatives, adequate assessment of existing proposals and adequate provision of mitigation measures. KD considers that the objections highlighted provide sufficient justification for Development Consent to be refused. Full representations below The Planning Inspectorate Temple Quay House Temple Quay Bristol BS1 6PN Ref: TR010021 26th August 2016 Dear Sir/Madam WITHOUT PREJUDICE PROPOSED SILVERTOWN TUNNEL ORDER OBJECTION TO APPLICATION FOR A DEVELOPMENT CONSENT ORDER ("the Application") This letter of objection is submitted on behalf of Knight Dragon Developments Limited and Knight Dragon Investments Limited ("Knight Dragon") in relation to the Application for a Development Consent Order to authorise the construction, operation and maintenance of the Silvertown Tunnel ("the Scheme"). Background Knight Dragon is the master developer of Greenwich Peninsula which currently benefits from several planning permissions. These permissions will see over 60 hectares of brownfield land at the Peninsula being developed to provide: • 15,720 homes; • 60,000sqm of commercial space; • a redeveloped North Greenwich tube and bus station providing additional bus capacity as well as neighbourhood retail, hotel and office accommodation; • a 40,000sqm film studio; • 24,000sqm of new retail/food/drink space; • two hotels; • two schools for over 2,000 pupils (one primary, one 'all through school'); • a 20,000sqm cultural and visitor attraction; • a ferry jetty terminal; • new parks and enhanced open space; • a 5km running and leisure track around the whole site; • a healthcare facility; • a multi-storey car park accommodating up to 2,000 spaces for AEG (the current operators of the O2); and • an expanded Ravensbourne College. Attached to this letter is the 2015 Masterplan which shows the layout of the proposed development and uses and how the Greenwich Peninsula is intended to look once completed. Knight Dragon has recently completed the first 506 homes and construction is continuing, with over 1,800 homes anticipated to be completed between 2017 and 2019. Knight Dragon is also undertaking a series of place making and meantime initiatives across the Peninsula including events held at the NOW Gallery and Peninsula Gardens and also at the recently opened temporary Golf Driving Range. The Peninsula is identified as an Opportunity Area in the London Plan and is the largest single regeneration scheme in London. The 2015 Masterplan will help to deliver much needed homes and jobs in line with the Mayor of London’s priorities and, as will be noted from the above, Knight Dragon is accelerating development in order to meet these needs. Knight Dragon is generally supportive of the principle of the proposed new tunnel crossing and considers that it has the potential to relieve the current congestion suffered on the Blackwall Tunnel and may also reduce travel times, particularly northbound. However, having assessed the detailed proposals, Knight Dragon wishes to make the following objections to the Application which are considered significant enough to warrant the Application being refused consent. These objections are as follows: 1. AEG Car Parking 2015 Masterplan Multi-Storey Car Park The Application states that the 2015 Masterplan anticipates a multi-storey car park coming forward within the first phase of the 2015 Masterplan development to "gather up and concentrate current surface car parking associated with the O2 Arena". The Application states that it makes provision "for O2 car parking affected by the scheme's construction to be temporarily replaced if the multi-storey car park is not developed in time" . Whilst it was anticipated within the 2015 Masterplan application documents that the development would follow the Development Zone Parameter Plan, with development in the Transport Hub commencing first, this is not necessarily the case and indeed, development within Zone C is commencing first, with a Zonal Masterplan and Reserved Matters in relation to that Zone having been recently submitted. Additionally, the Application fails to consider the fact that a large amount of area of the Peninsula required for a work site associated with the Application is situated on the area of the Peninsula allocated to provide the multi-storey car park, making it impossible for the multi-storey car park to be brought forward whilst construction works in relation to the Scheme are ongoing. The Application should therefore make sufficient provision for replacement car parking during the Scheme's construction works and should not be predicated on the multi-storey car parking within the 2015 Masterplan being brought forward beforehand. Temporary Replacement Car Park Despite being anticipated that The O2 car parking will need to be re-provided, the Application makes minimal reference to the disruption this will cause, stating that during construction, the Scheme would "lead to some localised impacts e.g. access to residences and businesses in the immediate vicinity" . No direct consideration is given to the impact upon the parking provision for the O2. This is considered insufficient, given that approximately 600 parking bays will be displaced to make provision for the Greenwich compound for the Scheme and will need to be in place for the duration of the Scheme, currently anticipated to take approximately 4 years to complete. The Application proposals state that TfL would reprovide these car parking spaces at "other suitable locations, local to the O2" . However, it is noted that only one area of land has been identified for the provision of a replacement car park, namely on land to the south of the Emirates Air Line cable car. Knight Dragon is disappointed to note that the Application does not contain any traffic impact analysis of the car-parking spaces being relocated to this location. Further, it does not appear that any alternative locations for the provision of this temporary car park have been considered, nor has any detail been provided as to why this location is considered the most appropriate. Additionally, there does not appear to have been any consideration given to access to this location, taking into account the number of users of the car parking during events. The provision of approximately 600 car parking spaces, located within close proximity to the Emirates Air Line, combined with the already existing 264 car parking spaces in Car Park 3, will result in the provision of just under 1,000 spaces on a part of the Peninsula that lacks the necessary road infrastructure to support this number of parking spaces. As a result cars will need to both access and egress onto the single carriageway at West Parkside to access the temporary Edmund Halley Way diversion, before reaching Millennium Way. Taking into account the significant developments which sit to the north of (the existing) Edmund Halley Way (Ravensbourne College, TfL offices, offices at Mitre Passage and associated retail), the new residential neighbourhood at Upper Riverside (1,007 homes and commercial space with occupation commencing in 2018) and the peak arrival and departures to the car parks which will occur during major events held at the O2 (an average of 200 per year), together with associated construction and general traffic, the capacity of a single carriageway at West Parkside and the Edmund Halley Way diversion is wholly inadequate to cater for the level of traffic anticipated in this location. AEG is constructing a Designer Outlet Village within The 02 Arena which, when it opens in 2018, will bring significant additional traffic to the Peninsula. In the situation where the car parking is re-provided by TFL in the proposed temporary location there will be a more constant demand for spaces not just when events occur thereby creating an even greater problem at the junction. The temporary replacement car parking solution does not take into account that both the Prayer Space and GLLAB currently use significant land within the designated area. As they are not shown on The O2 replacement car park plan Knight Dragon has to assume that the Applicant intends to re-locate these buildings but no information is provided as to where they will be located. These are important resources for the Peninsula and must remain operational and easily accessible for users. In addition to the above, are the numerous bus services which run to and from North Greenwich transport interchange via the Pilot bus way. Without significant junction and infrastructure improvements this will result in both the existing and proposed diverted highways becoming stressed to such a degree that the whole of the Peninsula will be brought to a standstill and result in conditions detrimental to the safety of pedestrians, cyclist and road users. An analysis of the traffic impact in this location as a result of temporary works required during the construction of the Application is required prior to the Application being determined. Knight Dragon would also question the reasoning behind the provision of approximately 600 replacement spaces. As a whole, the Peninsula benefits from over 2,500 spaces, many of which are rarely fully occupied. Knight Dragon consider it surprising that TfL, as a sustainable transport authority, have failed to assess whether it would be more appropriate for alternative measures to be included to avoid the need for such a large number of car parking spaces. The Peninsula is well served by a range of public transport, including the Jubilee Line, a large bus station, the Emirates Air Line and river services; Knight Dragon consider it unacceptable that no analysis appears to have been carried out as to whether there is a need to re-provide such a large number of spaces, on land which could otherwise be used for the continued redevelopment of the site as illustrated by the 2015 Masterplan. In light of the above, Knight Dragon considers that both the location and distribution of the displaced car parking needs to be revisited in consultation with both Knight Dragon and AEG so that any agreed solution can be programmed well in advance of the main construction of the Scheme, together with the necessary infrastructure improvements. This is to take into account the necessary design, planning and commissioning timescales to allow for the replacement car parking provision to be fully operational prior to the construction of the Scheme. Knight Dragon considers that such further analysis is required prior to the approval of the Application. In addition to the above, Knight Dragon requires confirmation from TfL that it will be responsible for all costs associated with the provision of all replacement car parking and associated infrastructure together with assurances of appropriate re-instatement of the land. Knight Dragon therefore objects to the Application on the basis of the location, design, access and scale of the proposed temporary car parking provision. 2. Closure of Edmund Halley Way In addition to the failings of the location of the displaced car parking it is noted that the Application proposes the closure of Edmund Halley Way from approximately March 2019 to June 2022 , with a planned diversion located south of, and running parallel to, the existing Edmund Halley Way . The closure of the existing Edmund Halley Way will result in the entrances to Car Park 2 and the station car park being removed. The Application fails to detail the provision of alternative access to both of these. It is not clear whether new access will be provided to Millennium Way, or whether users of these car parks will be required to travel via West Parkside, and the diverted Edmund Halley Way, further exacerbating the problems already outlined above. Without suitable detail as to the provision of alternative accesses, and appropriate mitigation measures being provided, Knight Dragon considers the Application proposals to be wholly unacceptable and ill-considered. The proposed location of the Edmund Halley Way diversion will result in a much heavier usage of West Parkside. The Application does not appear to consider the fact that West Parkside is currently a priority bus highway and consideration has not been given to changing this piece of highway to a dual carriageway, with no bus lanes. This would allow greater flexibility and increased road capacity on a road which is likely to become a significant thoroughfare during the construction of the Scheme. Knight Dragon notes with concern that no assessment of this amendment to West Parkside appears to have been considered within the Application. Knight Dragon therefore objects to the Application on the basis of the proposed diversion of Edmund Halley Way. 3. Diversion of Millennium Way Knight Dragon has held detailed discussions with TfL on this matter, and is pleased to note that the proposals in this regard have been amended to ensure full access will be maintained along Millennium Way for the full duration of the construction period in response to representations from service providers, operators and businesses. Knight Dragon notes that there will be some temporary localised diversions during some periods of construction, with traffic moving back to the original alignment once the "cut and cover" section of the Scheme has been constructed. Knight Dragon considers it imperative that any diversions should be kept to an absolute minimum given the importance of Millennium Way as a primary means of access to the Peninsula. Despite the above Knight Dragon considers that the temporary diversion to the east of Millennium Way seriously disrupts traffic and parking on the Peninsula. An alternative route to the west of Millennium Way can be achieved and would significantly mitigate the impact of the diversion. Knight Dragon therefore objects to the Application on the basis of the proposed diversion of Millennium Way. 4. Tunnel Avenue Extension to Peninsula Quays It is noted that the Application seeks the reintroduction of Tunnel Avenue to connect both the north and south of the Peninsula and in line with the east west pedestrian/cycle route. Knight Dragon considers that this route should be implemented prior to the main tunnel construction to offer an alternative connection north to south that is not currently enjoyed. This will be particularly beneficial as lorries and commercial vehicles wishing to exit Victoria Deep Water Terminal will be able to access main routes without navigating through the Peninsula site which will already be heavily impacted by the disruption to the Peninsula highway network caused by Millennium Way and Edmund Halley Way diversions and relocated car parking. 5. Direct Access to Silvertown Tunnel from Greenwich Peninsula Knight Dragon considers it important from both an urban design and traffic management perspective that all vehicles have the ability to access directly both the Blackwall and Silvertown Tunnels at the earliest opportunity rather than via the existing access point at the southern end of the Peninsula. Knight Dragon believes that this would have the potential to reduce both congestion and travel times across the River Thames and has the potential to prevent unnecessary southbound journeys along Tunnel Avenue and Millennium Way. This is also considered particularly important for the success of the emerging Greenwich Peninsula district and particularly for the Meridian Quays neighbourhood which sits on land to the east of the A102. Knight Dragon believes that this can be achieved by designing both the orientation and priorities of the slip way off Millennium Way directly onto the north bound land of the proposed Silvertown Tunnel. It is noted however that no consideration appears to have been given to alternative accesses to the Scheme and Knight Dragon considers this to be a failure of the current Application. Direct access, as set out above, would also provide a convenient means of departure of vehicles from the proposed multi-storey car park which will eventually replace the existing surface car parks that serve The O2, particularly following evening events which occur up to 200 times a year. The location of the multi-storey car park in relation to the proposed access to the Scheme does not appear to have been considered within the Application and this omission is considered unacceptable by Knight Dragon. Knight Dragon therefore objects to the Application on the basis of insufficient consideration of alternative accesses to the Scheme. 6. Other Highway Impacts Knight Dragon is also concerned to note that whilst the Transport Assessment identifies that "the Scheme does have a significant adverse traffic impact on local junctions and highways links" there is no detailed mitigation strategy for improvements to be made to the local junctions and highways as a result of the Scheme. It is noted that monitoring of the impacts of the Scheme will take place once the Scheme is completed and operational however Knight Dragon does not consider this sufficient as any impacts will have a significant effect on the redevelopment of the Peninsula under the 2015 Masterplan; any bringing forward mitigation measures "after the event" is not a satisfactory strategy, given the size of the Scheme and the surrounding area. Greater security is required around what mitigation measures will be provided should surrounding the highway network suffer significant impacts as a result of the Scheme. Knight Dragon therefore objects to the Application due to the failure to appropriately mitigate the impacts of the Scheme on the wider highway network at an appropriate stage. 7. Failure to Adequately Mitigate the Impact of Construction The regeneration of Greenwich Peninsula is currently providing, and will continue to provide, much need homes and jobs for London over the coming years. Knight Dragon considers that the impact of the Scheme is so significant that it will adversely impact on the regeneration of the site. It is important to emphasise that given the proximity of the Scheme to the redevelopment proposals under the 2015 Masterplan, Knight Dragon has been in regular dialogue with TfL to ensure that the continued and accelerated regeneration of Greenwich Peninsula can continue at its present pace; that The O2 car parking remains effective and operational and that the Silvertown Tunnel project can proceed with minimal disruption to the residents, businesses, visitors and workers. Mitigation of the impact of the construction of the Scheme is proposed to be addressed by the requirement for a CEMP and CTMP to be developed prior to works commencing which would address "a variety of environmental impacts of construction activities, including construction traffic-related impacts" . Knight Dragon does not consider this to be adequate or appropriate, given the extent of the proposed redevelopment works taking place under the 2015 Masterplan. Despite the regular meetings and workshops, Knight Dragon considers that the Application proposals will cause such significant disruption, which has failed to have been adequately addressed within the Application proposals, that the entire project should be considered unacceptable until such impacts have been appropriately analysed, addressed and mitigated against. Knight Dragon therefore objects to the Application due to the failure to appropriately mitigate the impacts of the construction of the Scheme. 8. Failure to adequately mitigate impacts on existing buildings Knight Dragon is aware that TfL are seeking to enter into Settlement Agreements with landowners affected by the DCO to address any mitigation which may be required as a result of settlement arising from the construction works. Whilst Knight Dragon welcomes this, they are concerned to note that specific provision for the entering into of these agreements is not provided for within the DCO. Specific provision is made for protective works to be carried out by TfL both during and following the development , but this does not address the provisions which are to be included within the Settlement Agreements. Knight Dragon considers the measures contained within the Settlement Agreements to be of such importance to the carrying out of the Development, that a requirement to enter into Settlement Agreements prior to the carrying out of the development should be contained within the DCO itself. Knight Dragon considers that without this, the DCO should be refused. 9. Location of Buildings Southern Portal Building Within the designs put forward during consultation in autumn 2015, the southern portal buildings were located to the south side of the tunnel portal. It is noted that the Application states that this was considered "unbalanced" and the southern portal buildings are now proposed to be located on land to the north of the southern portal, on land which benefits from outline planning permission for coach parking pursuant to the 2015 Masterplan. The Application states that the siting and building arrangement of the southern portal "has been refined and organised to reduce and make equal their impact on neighbouring landowners and their future development proposals" despite the fact that whilst the land to the north of the portal benefits from outline planning permission, the land to the south does not currently benefit from planning permission for any redevelopment, and is further subject to restrictions on development due to the consultation zones in relation to the historic Hazardous Substances Consent relating to the gas holder. It is also concerning that Knight Dragon was only informed of the new proposed location of the portal buildings, after the expiry of the consultation period with unjustified reasons being put forward in support of this amendment. The Application infers that both parcels of land are open to the same redevelopment opportunities, which is clearly incorrect. Knight Dragon considers that the proposals now directly impact upon the 2015 Masterplan, which will require amendment to ensure that adequate provision for coach parking is made elsewhere within the site. Knight Dragon considers that the previously identified location of the portal buildings, to the south of the tunnel portal is a much more appropriate location. Knight Dragon therefore objects to the Application on the basis of the proposed location of the southern portal building and the failure to properly assess and consider alternatives. Head house This building is proposed to be located at the northern end of Central Park, on Metropolitan Open Land. It is noted that the Application considers the head houses to be "small structures" despite having a footprint of approximately 50sqm. The size and scale of this building is considered inappropriate in the proposed location. Additionally, the Application identifies an extremely large and disproportionate area within which the head house can be located. This creates an unacceptable level of uncertainty for Knight Dragon in relation to its ongoing redevelopment of the Peninsula and a smaller area should be identified within the Application. Knight Dragon therefore objects to the Application on the basis of the proposed location of the southern head house building. 10. Design of Buildings The Design of the Greenwich Portal Building is stated to be "similar to that of the Silvertown Portal and so together, establish a strong identity for the tunnel and its important within the city's infrastructure" . Whilst the Application states that the design of buildings and structures have been designed to integrate with the 2015 Masterplan Knight Dragon fails to see how this can be stated, given that limited consultation has taken place with Knight Dragon on the design of the buildings. The final design of the buildings is currently undefined and the detailed design is to be brought forward in accordance with the principles and parameters as set out in the Design Principles submitted with the Application. The detailed design will be the responsibility of the Contractor for the Scheme. Knight Dragon is concerned to note however that the Design Principles in relation to the Greenwich portal building (GREPO.01 to GREPO.02) make no reference to the design of the portal building integrating into the 2015 Masterplan. Knight Dragon considers that this should be a Design Principle applicable to the design of the Greenwich portal building. Given the strategic importance of the 2015 Masterplan, and the size and scale of the buildings, Knight Dragon considers that the design of the buildings to be located on the Peninsula should be approved by Knight Dragon to ensure that the buildings comply with the objectives for the 2015 Masterplan as a whole. The design should be brought forward at an early stage to ensure compliance with the redevelopment proposals and place making objectives of the 2015 Masterplan. The Applicant has so far failed to commit provide any assurances in this regard and Knight Dragon therefore objects to this element of the Application. 11. User Charging Knight Dragon is concerned with regard to the proposed charging for users of the Scheme and considers that the residents of the Peninsula will be directly impacted by these proposals. Whilst the principle of user charging at peak periods is generally supported, Knight Dragon considers that user charging outside of peak periods will have a detrimental impact on the success of the Peninsula for both residents and businesses. It must also be emphasised that the introduction of tolling at these major river crossings is considered deeply unfair to both residents and other users of the Peninsula, as well as the wider south east London area, given that residents in other parts of London are not required to pay a toll to cross the river. In the event that Silvertown Tunnel proceeds, Knight Dragon considers that all river crossings should be treated equitably. If this is not done, Knight Dragon objects to the overall principle of user charging for both the Scheme and the Blackwall Tunnel. It is noted that the main aim of user charging is primarily to reduce "induced traffic" and secondarily to provide reimbursement towards the costs of constructing, operating and maintaining the Scheme. However, Knight Dragon does not consider that the impact on residents and businesses on the Peninsula has been adequately assessed. Knight Dragon is concerned to note that the Application states that "the charges for the Blackwall and Silvertown Tunnel would apply to a relatively confined stretch of highway where there are no residential dwellings" . Whilst this may be the case at present, there will be a high level of residential dwellings in the medium to long term due to the implementation of the 2015 Masterplan. It is further noted that users would have a choice to use either the charged crossings, or change their route to an uncharged crossing. Knight Dragon believes that this would cause significant disadvantage to residents of the Peninsula, due to the close proximity of the Scheme and residents would have to travel significantly further in order to access a crossing not subject to charging. Knight Dragon would consider this to cause significantly more than "some inconvenience" to residents. Further Knight Dragon is surprised that this would be considered a sustainable way to travel. Knight Dragon considers that further assessments should be made in relation to a reduction in charging for local residents and businesses, and consideration should also be given to car club users, a sustainable transport measure which Peninsula residents will be able to benefit from. Knight Dragon welcomes the proposals for charging at both the Blackwall Tunnel and the Silvertown Tunnel to ensure that access to river crossings in this location is fair (subject to other major river crossings being subject to the same charges, as stated above). However, Knight Dragon believes that consideration should be given to charging being introduced for the Blackwall Tunnel prior to the implementation of the Scheme. The significant beneficial impacts of charging for the Blackwall Tunnel are considered within the Application and Knight Dragon considers this to be of such significant benefit that it should be introduced as a mitigation measure to reduce the construction impacts of the Scheme. 12. Programme Whilst Knight Dragon notes that there is a high level programme contained within the Application with a commencement of development beginning in 2019, it is noted that there is no detailed programming in place in relation to the replacement of essential facilities namely the temporary car parking, access roads and pedestrian and cycle links. Knight Dragon considers this to be wholly inadequate, given the importance of these facilities to the Peninsula, as well as the redevelopment of the site pursuant to the 2015 Masterplan. These details should be included within the Application as soon as possible. In addition the current delivery programme is elongated due to TfL’s procurement route (PFI) and Knight Dragon considers it appropriate that an alternative procurement is pursued to reduce the delivery timescale. This will have huge benefits to the local area, users and businesses alike. 13. Failure to Address the Existing Safeguarding Direction Reference is made within the Application that a benefit of the Scheme is to "unlock" the future regeneration of the land which is current subject to safeguarding and that "once the scheme is complete, the rest of the Safeguarding Area not used will become available for development". These assertions are incorrect: the existing safeguarding only provides a heightened level of consultation in relation to development of the safeguarded land, as opposed to preventing development coming forward at all. Knight Dragon therefore wishes to ensure that any safeguarding is brought to an end at the earliest possible time. Despite the Application making reference to the safeguarding falling away upon completion of the Scheme, no provision is made for a direction to be made ensuring this. Knight Dragon therefore considers that the appropriate direction should be included within the draft Development Consent Order ensuring that upon completion of the Scheme, the 2001 Direction is cancelled. Conclusions In conclusion, whilst Knight Dragon is generally supportive of the principle of the Scheme, it is considered that the Application is significantly lacking in relation to the consideration of alternatives, adequate assessment of existing proposals and adequate provision of mitigation measures that the Scheme will cause a significant detrimental impact upon the regeneration of Greenwich Peninsula and the implementation of the 2015 Masterplan. Failure to address the points outlined above will result in conditions that put the delivery of much needed homes and jobs for London in jeopardy. Knight Dragon considers that the objections highlighted provide sufficient justification to warrant the Application being considered deficient and wholly unacceptable and that Development Consent for the Application should be refused. Should Development Consent be granted, without the above objections being addressed, Knight Dragon would consider any such grant to be open to challenge by way of judicial review. Should you wish to discuss the contents of this letter or require any further clarification please do not hesitate to contact the writer, Neil Smith, at the below details. Yours faithfully Neil Smith Head of Planning T +44 (0) 203 440 7201 M +44 (0) 782 501 6288 [email protected] www.knightdragon.com "
Local Authorities
response has attachments
Bilfinger GVA on behalf of London Borough of Lewisham
"Silvertown Tunnel London Borough of Lewisham relevant representation 26 August 2016 1. Introduction 1.1 Bilfinger GVA and Project Centre are acting on behalf of the London Borough of Lewisham (“LBL”), coordinating their submissions and correspondence with the Planning Inspectorate (PINS) and Transport for London (TfL). On behalf of our client, GVA is submitting this relevant representation and requests that LBL is registered as an interested party to the Examination. 1.2 In accordance with the Planning Act 2008 and the Infrastructure Planning (Interested Parties) Regulations 2010 (as amended), this relevant representation sets out a summary of the key points that LBL wish to make during the Examination. LBL’s subsequent written representation will expand upon this and LBL would like to discuss their concerns at the oral hearing sessions. LBL will also submit a Local Impact Report assessing the evidence based impact of the proposed tunnel. 1.3 LBL has serious concerns with the detail and merits of the proposal in relation to: • impacts on traffic congestion; • impacts on air quality and the local community; • sustainable transport and connectivity; • the need for a package of river crossings; and • consistency with planning policy. 1.4 These concerns are summarised below and will be expanded upon through the Examination. 2. Detrimental impacts on traffic congestion 2.1 LBL objects to the scheme on the basis that: • It exacerbates rather than disperses the current pressures of traffic congestion especially as the proposed tunnel relies on the same southern approaches as the Blackwall Tunnel, including parts of the A2 and South Circular. • LBL disagrees with TfL’s assessment of impacts on traffic and considers the scheme will have a more significant impact on Lewisham’s roads than recognised by TfL. TfL’s findings show that the majority of Lewisham’s roads do not currently experience significant congestion – LBL strongly disagree with these findings based on its local knowledge. • LBL is yet to be provided with TfL’s transport model to enable LBL to assess the model and its impacts as projected by TFL. It is understood that TfL and its consultants (Steer Davies Gleave) have shown the draft model to the host boroughs and that once finalised it will also be shared with LBL and others. LBL therefore reserves the right to comment further once the model has been made available by TfL. • LBL’s current understanding is that the model does not take into account the cumulative effects of other development schemes including the Thames Tideway Tunnel and other major mixed use schemes in Lewisham and Canada Water. The model needs to account for these schemes during both construction and operation to fully assess the potential impacts on the transport network. • As LBL has yet to see the transport model (and understand that model is yet to be finalised), it is difficult to establish whether the mitigation strategy is adequate. There needs to be a clear trigger level at which the measures within the mitigation strategy will come into force together with an ability for LBL to enforce any TFL breach. • LBL has concerns with TFL’s view that an appropriate level of user charging will manage demand and mitigate impacts of the scheme. LBL consider that it will be extremely difficult to determine and consistently charge users at a level which will deliver the benefits TFL claim whilst not harming the East London economy. • LBL has concerns that traffic will be directed to the Rotherhithe Tunnel as that will remain the only crossing not subject to either a toll or London congestion charging east of Vauxhall Bridge if charging is imposed at Blackwall Tunnel. • LBL understand that TfL are currently not proposing a local discount for user chargers. If, in the future, TfL decide to apply a local discount, LBL would like to be part of discussions to ensure that the methodology for areas to qualify for a discount is fair and not simply based on borough boundaries. 3. Detrimental impacts on air quality and the health of Lewisham’s community 3.1 LBL objects to the scheme on the basis that: • The proposed tunnel will increase traffic volumes and congestion which is likely to reduce air quality further. • Air quality in Lewisham is already poor, with much of Lewisham being within a designated Air Quality Management Area (AQMA). The Mayor has already acknowledged the need to improve air quality within Lewisham’s AQMA and has allocated funding to deliver this improvement. • The methodology used by TfL to assess impact on air quality is unsuitable as it does not take account of existing pollution levels. Furthermore, the model’s definition of 1000 vehicles as significant is too high. TfL has relied on methodology within the Design Manual for Roads and Bridges (DMRB) in assessing impacts on air quality, using 1000 annual average daily traffic (AADT) as their basis. This methodology is not appropriate for this assessment on air quality as that is not what the guidance intends the threshold to be applied to. The DMRB defines 1000 vehicles as significant in terms of road design and construction, not in terms of impact on air quality. It also does not take into account existing air quality and existing pollution which is key in Lewisham where the AQMA is already in place, and thus any increase in traffic levels could increase pollution levels beyond levels which are dangerous to health. In addition, the DMRB guidance is increasingly becoming outdated and recent guidance from Environmental Protection UK and the Institute of Air Quality Management (May 2015) indicates that much lower volumes of traffic could cause significant impacts, particularly within AQMAs. Their indicative criteria are 100 ADDT for LDVs and 25 AADT for HDVs. LBL considers that lower levels such as these levels should also be used in TfL’s assessment. • Deterioration in air quality could lead to negative impacts on the health of Lewisham’s community. • Requiring a package of river crossings rather than just Silvertown Tunnel would help reduce the negative impacts on air quality as traffic flows would be shared across a greater area. • Whilst mitigation measures are being put in place through the creation of Silvertown Tunnel Implementation Group (STIG), LBL wish to ensure that there is adequate monitoring of the impact on air quality. LBL has requested a neutral chair/decision maker. 4. Missed opportunities to contribute to sustainable transport and improved connectivity 4.1 LBL objects to the scheme on the basis that: • It does not promote sustainable transport and neglects opportunities to improve connectivity for walking and cycling as it is solely a tunnel for motorised vehicles. Prioritisation of walking and cycling is a priority for LBL and TfL. This is not being delivered. • LBL acknowledge that the cost of delivering a cycle or pedestrian route through the tunnel is likely to be prohibitive, however LBL is of the view that cost effective alternatives exist. • Provision of a cycle transit service through the new tunnel, the Blackwall Tunnel and Rotherhithe Tunnel would go some significant way to improving sustainable transport links in East London. Such a service already exists at the Dartford Tunnel Crossing. • Furthermore, TfL should commit to providing improved high quality cycling connections at a strategic level from key centres such as Catford and Lewisham, to ensure that sustainable transport is promoted alongside motor vehicles. TfL could build on the existing and proposed Cycle Superhighways in the region as part of the Silvertown Tunnel development. • LBL welcomes the tunnel’s ability to carry cross river buses, but no commitment has yet been made on the subsequent bus provision. TfL need to provide a more detailed and defined strategy for cross river buses so that boroughs can consider whether this is supported. Commitment to delivery of an enhanced bus service would mitigate the lack of a pedestrian link. 5. Package of river crossings 5.1 LBL support the principle of increasing transport capacity across the river in the east, but believes that there should be a package of crossings further east of the proposed Silvertown Tunnel. 5.2 National and regional government have both been clear from the outset that a package of river crossings is needed. Government’s Transport Select Committee stated “….Silvertown Tunnel must not be built in isolation. Instead it must be part of a package of crossings”. Similarly the London Plan refers to a …”programme of works under development to improve cross-Thames road links in East London including Silvertown tunnel”. The emphasis is on a package of crossings but there is no evidence as yet of further crossings coming forward which would seek to ensure that larger traffic flows are shared across a greater area. TfL need to commit to bringing forward a package of new crossings. 6. Consistency with planning policy 6.1 In making a decision on the proposed tunnel, the Planning Act 2008 requires the decision maker to use the National Networks National Policy Statement (NN NPS) as the primary basis for decision-making and also specifies that the development plan may be both important and relevant. 6.2 On this basis, LBL’s view is that the proposed scheme is not consistent with all aspects of policy as the tunnel: • is not coming forward as a package of crossings; • does not promote sustainable development; and • could deliver a potential adverse impact on the health of Lewisham’s community. 6.3 The proposed scheme contravenes the key planning policies and guidance summarised below. • National Networks National Policy Statement o Paragraph 3.2 recognises that development should be designed to minimise social and environmental impacts. o Paragraph 4.6 states that applications should be supported by a local transport model to provide sufficiently accurate details of the project. o Paragraphs 4.79-4.82 recognise the potential to affect health and well-being such as opportunities for cycling and walking. • London Plan o Policy 6.1 and its supporting text envisage the Silvertown Tunnel being delivered as part of a wider programme of works to improve cross river access in East London. o Policy 7.14 focuses on improving air quality and tackling air pollution, especially within Air Quality Management Areas. • Lewisham’s Core Strategy o Policy 7 refers to applying the London Plan policies on climate change including those related to air quality. o Policy 9 seeks to improve air quality and minimise negative air quality impacts, as well as working with TfL to improve air quality. 7. Conclusions 7.1 In conclusion, the London Borough of Lewisham submits this representation to object to the Silvertown Tunnel DCO application due to: • its potential detrimental impacts on: o traffic congestion; o air quality; o health of the local community; • its failure to contribute to sustainable transport and connectivity; • it not being delivered as a package of river crossings; and • its inconsistency with planning policy. 7.2 LBL will submit a full written representation and Local Impact Report as part of the Examination process. "
Non-Statutory Organisations
Road Haulage Association
"The Road Haulage Association (RHA) believe strongly that there is a requirement for a second upper Thames Road River crossing in East London. The RHA feel that the connectivity benefits for our members will help support growth, reduce emissions and significantly cut journey times. Morning and evening peak traffic congestion at the existing Blackwall Crossing creates stop start traffic that is both bad for business and the environment. The addition of a further crossing will help to alleviate congestion and allow a choice of passage for motorists. The Road Haulage Association strongly support the plan."
Members of the Public/Businesses
DLA PIPER UK LLP on behalf of The Waterfront Limited Partnership
"1. This summary representation is prepared on behalf of The Waterfront Limited Partnership ("WLP"). It is made in response to the application for development consent having reference TR010021 (“Application”) for the Silvertown Tunnel (the "Scheme") promoted by Transport for London (the “Applicant”). 2. WLP is a joint venture company, which is jointly owned by (i) AEG Inc, of which Ansco Arena Limited (“Ansco”) is a subsidiary and (ii) Crosstree Real Estate Management Limited. WLP and Ansco’s operations and interests are aligned. Ansco operates the arena at The O2, whereas WLP operates the Entertainment District at The O2 and will operate the proposed Designer Outlet Village at The O2, which is due to be opened in or around 2018. 3. WLP’s position in respect of the Scheme is therefore aligned with that of Ansco, which is also submitting both summary and fuller form representations as an Interested Party (the “Ansco Representations”). On the advice of the Planning Inspectorate case team, WLP therefore wishes to rely on the Ansco Representations which will be submitted by Ansco via email to [email protected] The Ansco Representations should therefore also be considered as WLP’s relevant representations in respect of the Application. 4. Whilst this summary representation and WLP’s reliance on the Ansco Representations both constitute an objection, subject to addressing its important and relevant concerns (but not otherwise), WLP supports the Scheme in principle. This is on the basis that improved transport infrastructure, including an additional river crossing, is essential for the continued growth and development of Greenwich Peninsula (“Peninsula”) and surrounding areas of east London. However, the contents of the Application reveal that the Applicant has failed to properly review and assess WLP’s challenges in respect of transport on the Peninsula and as a result, WLP has a number of significant concerns about the effects of the Scheme on the transport system and the operation of its business at The O2 both during the construction and operational phases of the Scheme. In summary, these include (although are not limited to): 4.1 the provision of a sufficient number of car parking spaces, which are suitably located and operationally workable, to serve The O2 and its visitor attractions without degrading the customer experience; 4.2 the impact of construction work on the road network on the Peninsula, particularly during peak ingress and egress periods for events at The O2; and 4.3 the long term impact of user charging at the Blackwall and Silvertown Tunnels on the night time economy of the Peninsula. 5. Furthermore, it is submitted that the Application is deficient as it has not been subject to assessment or analysis of the effects of the Scheme on The O2, which are lawfully required to enable the Application to be determined. Therefore, the Application is premature and, unless these items are properly addressed, development consent should not be granted - indeed it would not be lawful to do so. "
Members of the Public/Businesses
Anders Tingsgård Bone
"It is damaging for the Environment of Greater London. There are better Alternatives such as investing in Active Transport instead of a Motor Vehicle Tunnel that does not provide access for Active Transport Users."
Members of the Public/Businesses
Caroline Sefton
"I am objecting to the plans for a Silvertown Tunnel because I cannot see that TfL have adequately considered alternatives to the current plan which would be based on expanding use of public transport (i.e. rather than improving access for cars, coaches and lorries). Greater consideration of public transport is justified because its provision in and between east and south­east London remains less than elsewhere in London and there is scope to improve orbital public transport links. I would like to see more thought given to the effect of the charging structure on congestion on local roads. I would like to see more schemes to improve the management of traffic and the road network rather than new roads. I rely on bus, train and walking for my journeys. I support the general arguments of the No to Silvertown Tunnel campaign."
Members of the Public/Businesses
Richard Lufkin
"This is a scheme that will significantly worsen air quality in East London, It is absolulty incompatible with the Mayor's air quality agenda. The time for massive road building programmes is over."
Members of the Public/Businesses
Rosalind Readhead
"I object to the huge cost to taxpayers of an unnecessary new road that is the Silvertown Tunnel. Increasing road capacity has consistently been shown to increase traffic, causing increased congestion, air pollution, noise pollution, severance and greenhouse emissions. It is clear that we need to minimise road traffic in London through road pricing and banning private cars that are not essential. Congestion is waiting in line for an underpriced road. "
Members of the Public/Businesses
Susan Younghouse
"My concerns The Silvertown tunnel will cause more traffic and therefore more congestion on an already heavily used road network. I am particularly concerned, as a resident, about the current levels of pollution around Greenwich and the effect on our health.. I understand that the biggest cause of air pollution is exhaust from vehicles. There will be more cars and more heavy goods vehicles exacerbating the problem. A toll does not prevent pollution. I am very conscious of the traffic smell where I live and it must be far worse for those around Tunnel Avenue. The increase in traffic noise is another concern. A river crossing must be supported by a suitably resilient road system which is not the case in this instance. "
Members of the Public/Businesses
Anne Richards
"I am opposed to the Silvertown Tunnel Plan. This new tunnel will inevitably encourage more traffic into the area. Although there are many blockages in the Blackwall tunnel, there are many blockages (e.g., accidents) on the A2 itself and an additional tunnel will only exacerbate these tailbacks. I have spent many hours stuck on the A2 as a result of a problem on the A2 itself. An extra crossing is needed but not near Greenwich where pollution levels are already at a dangerous love."
Members of the Public/Businesses
Anne Robbins
"I am asking to make a written representation on the proposed Silvertown tunnel as a resident of the Royal Borough of Greenwich, living close to the affected area. I am concerned about the Silvertown Tunnel plans because they would increase local traffic congestion, diminish the air quality in the area, and add more noise. I do not believe that adding new roads solves traffic congestion problems, but rather encourages more people to drive, compounding the level of congestion. London needs to find ways of improving public transport, especially across the South-East corner where provision is particularly poor; encouraging road use will not achieve this. While drivers must be charged if the Silvertown Tunnel is built, I think that the tidal charging structure disadvantages those living and running businesses which depend on river crossings on the south side. I think TfL has not adequately considered the danger that drivers will seek to avoid the charges by using the Rotherhithe Tunnel or other uncharged crossings, putting further pressure on roads, especially through Greenwich World Heritage Site and its approaches. The proposed Tunnel does nothing to help pedestrians or bicyclists. Improved access for north-bound heavy HGVs will bring them closer to central London, which should not be encouraged. Better traffic management for the Blackwall Tunnel has not been adequately explored, nor have other means for lowering demand for road use, for instance workplace parking levies which could cut demand among those driving through and parking at Canary Wharf. Controls on construction traffic are inadequate to keep lorries off local residential roads."
Members of the Public/Businesses
Charlotte Baker
"The plan for the Silvertown tunnel does not take into consideration the knock on effects for Greenwich and the surrounding area. Tolling will divert traffic to the Rotherhithe tunnel resulting in an increase of traffic through greenwich town centre with catastrophic results. The design of the tunnel does not include enough noise and pollution barriers. The details of the plan are confusing and n some instances contradictory."
Members of the Public/Businesses
Jill Austen
"I live close to the proposed development and through my local RA and environment groups have been involved with AQ surveys over the past few years, I have seen the increase in air pollution and traffic congestion and I listen to those living outside my area. This suggests to me that another vehicle-only road on such a narrow spur of land will not have the desired effect of easing congestion or lowering pollution levels. Already people from Kent travel to my area to avoid payment of the Dartford Crossing toll more will travel through it to get to the free Rothethithe Tunnel. New roads induce new journeys, with a football club and new shopping development and proposed a superstore (IKEA) and cruise terminal the effects could be catastrophic affecting my health and the unique beauty of the Greenwich Heritage site. Reports suggest bridges and flyovers serving the approach road are in seriously poor condition and will add to the high cost of the development, already rapidly exceeding original costs. Approach roads already have no resilience to increases in traffic and will induce more traffic onto local roads. More public transport is desperately needed to serve the growing population of the area, especially with new residential developments not providing many parking places. It might have been indicative of demand if the Blackwall Tunnel had been tolled from the beginning of the consultations because charges will not ultimately deter increased traffic that the scheme hopes will occur. Silvertown Tunnel is designed to take HGVs nearer Central London, this is not to be considered as advisable - distribution centres outside the M25 and very high tolls for HGVs within it need considering to discourage raised air pollution levels. My own family has been deeply affected by the results of diesel-produced air pollution, time has come for no more families to suffer the effects of it."
Members of the Public/Businesses
John Booth
"This is spending an enormous sum of public money to allow London to be even more overcrowded and car-dependent before gridlock. London should look at its environmental footprint and despair. Focus of investment should be on areas outside London and on improving quality of life and shifting to a lower-carbon economy. Road pricing, planning for localism, and investment in public transport are the way forward."
Members of the Public/Businesses
Laura Sessions
"New roads generate more traffic. The tunnel won’t make the road network more resilient – it’ll only increase congestion. (You might like to name specific roads or areas here.) The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. TfL has not properly considered alternatives, including new public transport and better management of the existing network. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise pollution (you might like to name affected areas). The environmental impact of better access for HGVs and buses has not been properly considered. TfL has not properly considered the effects of tolling on the wider road network (for example, on routes to the Rotherhithe Tunnel, which would remain free, though you may also have other examples). Tolling will also have a negative impact on local businesses – firms in other parts of London will not have to pay charges to get around. There’s been insufficient consultation with communities that will be affected by the scheme."
Members of the Public/Businesses
Paul West
"I object to this tunnel. Most research shows the project will in the short term being relief to current congestion, but this will return and exceed current levels in the longer term. I also believe current pollution levels already exceed safe limits and a new tunnel will make this worse. The area needs more and better public transport links, not more roads."
Members of the Public/Businesses
Ray King
"New roads generate more traffic and this tunnel will exacerbate already chronic congestion and pollution problems throughout east London and beyond. Better public transport, especially rail, outperforms road building for economic regeneration without the noise, pollution and energy waste created by road building. Road building degrades economic activity by creating a hostile environment which people and businesses avoid. Rather than building a new road tunnel, the only new river crossings in this area should be dedicated to rail which would contribute to reducing congestion on the roads. The existing Gospel Oak to Barking line should be extended via a rail tunnel to link north and south London and the Docklands Light Rail Railway should also be extended to Dagenham and via a rail tunnel to link north and south London. Proposals to provide a new rail link from Gatwick airport to Canary Wharf and Stansted Airport should also be implemented. This would have a real impact on reducing congestion on London road and rail links by providing alternative commuter links for workers from Kent, Sussex and Surrey and provide a massive stimulus to economic development."
Local Authorities
Royal Borough of Greenwich
"Relevant Representation: Royal Borough of Greenwich. This representation is to be read in the context of the Council’s response to the previous consultation. The Royal Borough accepts the need for an additional vehicular crossing at Silvertown to support growth and address the current lack of resilience. The Council’s S42 response provided qualified support for the proposal chiefly because the critical traffic forecasting and modelling work which underpins predictions of impacts was incomplete and not validated. The Council acknowledges that the scheme design has evolved such that the impact on the built environment and arrangements for connecting into the road network on Greenwich Peninsula are acceptable. The “assessed case” model is still not agreed as adequate for travel forecasting and provides insufficient confidence of predictions of traffic movements and consequent environmental impacts. Until such time that an acceptable model is provided to demonstrate environmental impacts are acceptable, the Council will require amendments to the proposed Monitoring and Mitigation strategy to ensure it is sufficiently detailed and affords adequate protection. The Council’s remains concerned about the potential impact of the proposal and will expand on those concerns in later submissions. Concerns include, but are not limited to: • Forecast environmental impacts, during and post construction, particularly air quality and noise impacts. • The traffic model and associated traffic impact forecasting, particularly the ‘compaction’ of the southbound pm peak southbound through increased capacity which effectively increases queuing on the local network where junctions are already at or near capacity, • A lack of confidence in the validity of the output from the tested sensitivity scenarios arising from a lack of confidence in the assessed case model, • The absence of assurance that the bus routes, on which socio-economic benefits are predicated, are an integral part of the proposal, • The disproportionate impact on Borough resident and businesses of paying peak charge in both peak periods, given the high local IMD, in the absence of a discount scheme within charging proposals, • The impact during construction including the lack of a disaggregated (north/south) commitment to the movement of materials by river, acceptable construction vehicle routes and the inclusion of Brewery Wharf as a viable option, • The absence of an acceptable mechanism, framework and triggers for any changes to the future charging regime. • Arrangements for agreeing Monitoring and Mitigation, with assured TfL funding for the timely implementation of required schemes of mitigations and the inclusion of a hypothecated Community Fund to address unintended consequences. • Recognising that charges at the Woolwich Ferry cannot be applied without primary legislation, the absence of proposed and effective mitigation to address the impact of forecast demand to use the Ferry, • The absence, as an integral part of the proposal, of a committed and funded public transport element to a quantum that, at least, matches the public transport modal increase forecast in the Transport Assessment • The absence of acceptable (i) protection and improve-ment of walking and cycling routes abutting the scheme’s limits of deviation and (ii) integral arrangements (such as pedestrian/cycle ferries) to support cross-river movement of pedestrians and cyclists. "
Members of the Public/Businesses
Sanne Baaij
"I oppose the addition of tunnels in with an area approach that is already super congested. Alternatives to cross the river ahould be addressed further outside london / alternatives for hhvs should be firther out. Greenwich is already congrsted as it is and we need cleaner air, not more polluted air in our neighbouhood."
Members of the Public/Businesses
Wincanton
"I support the scheme to relieve congestion and improve cross-river connectivity that this scheme provides. I have a reservation surrounding the ability of the two roads serving the tunnel being able to feed the volume of traffic into and away from the two tunnels. Steps need to be taken that ensure that traffic flows freely and that the surrounding area of the Greenwich Peninsula does not become grid-locked as it does now when traffic becomes congested on the A102M. The police and TfL need to have better contingency plans to manage local traffic when the A102 is closed as their existing plans to push traffic out towards Kent simply moves the problem as far as Woolwich Ferry thus effectively closing Charlton and the Greenwich Peninsula. "
Members of the Public/Businesses
Alan Haughton
"New roads generate more traffic. The tunnel won’t make the road network more resilient – it’ll only increase congestion. (You might like to name specific roads or areas here.) The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. TfL has not properly considered alternatives, including new public transport and better management of the existing network. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). Tower Hamlets is one of the most polluted boroughs in London and the Silvertown tunnel will make it worse. There isn’t adequate mitigation for noise pollution in Tower Hamlets, already seriously impacted by London City Airport noise from aircraft. The environmental impact of better access for HGVs and buses has not been properly considered. TfL has not properly considered the effects of tolling on the wider road network or the Blackwall Tunnel alone. Tolling will also have a negative impact on local businesses – firms in other parts of London will not have to pay charges to get around. There’s been insufficient consultation with communities that will be affected by the scheme."
Members of the Public/Businesses
Alessandro Sansone
"I am strongly against the Silvertown Tunnel project because of increased pollution and congestion in the area"
Members of the Public/Businesses
Anna Mars
"I am a local resident and parent of 2 children at a local school that backs onto the A102. Air pollution and traffic congestion are both at already at high levels and will only increase if the Silvertown Tunnel goes ahead so I am against the plans."
Members of the Public/Businesses
JLL on behalf of ASD Limited
"This representation is submitted by JLL on behalf of ASD Limited (trading as Kloeckner Metals UK) who requests to be registered as an interested party. ASD Limited is the freeholder of a site in Thames Wharf, with an additional leasehold interest on the adjacent Instone Wharf. Currently, this land is used for storage and distribution of metals. There are long term ambitions for its residential-led redevelopment. ASD Limited supports general improvements to London’s transport network, including the principle of a cross-river link, but has concerns relating specifically to the construction and operation of the proposed Silvertown Tunnel, and the impact that this will have on the current business and future redevelopment plans. We intend to bring forward evidence in relation to the following: a) The inclusion of ASD Limited’s site within the proposed construction area We will explain that the nature of ASD Limited’s business means that the business has very specific operational requirements, and that its current site is utilised as efficiently as possible to facilitate this. No formal agreement has yet been reached with TfL as to how the impacts of the proposed temporary acquisition will be mitigated. ASD Limited, therefore, reserves its position with regards to phasing of the proposals and any related compensation. We will draw attention to the current absence of site specific business analysis within the supporting documentation, including the Regeneration and Development Impact Assessment, Social Impacts Appraisal, Distributional Impacts Appraisal, Transport Assessment and traffic regulation measures plans. We will query the basis of relying on the opinions of the surveyed 500+ east London employers. Technical evidence will be provided as needed. b) Proposed new access arrangements to the proposed re-alignment of Dock Road We will query whether sufficient testing has been undertaken to ensure that the re-alignment can safely accommodate large vehicles and allow for ASD Limited’s continued successful operation. In so doing we will: • Refer to ASD Limited’s specific operational requirements, and its utilisation of its current site; • Highlight the lack of detailed or indicative site-specific plans and mitigation measures; • Provide technical analysis relating to relevant highways issues, including sight lines and swept paths. c) Impact of the scheme on the local environment, including traffic congestion, air quality and noise We will: • Highlight the desire for regeneration to take place locally, drawing on adopted and emerging planning policy including the London Plan (2016), LB Newham’s Core Strategy (2012) and the emerging Opportunity Area Planning Framework. • Query the appropriateness of leaving responsibility for producing an Air Quality Management Strategy and Construction Management Plan to the appointed contractor, without pre-testing potential impacts on a site-specific basis. • Draw on technical expertise to demonstrate impacts by way of traffic, air quality, noise (etc). • Interrogate TfL’s supporting documentation, including findings that more residents will experience an increase in noise levels than will experience a reduction. • Request that ASD Limited be party to the production of both the Air Quality Management Plan and Construction Management Plan. d) User charging We will respond to TfL’s proposed approach to user charging, and its general assessment of the impact, which focuses primarily on local residents. In so doing we will demonstrate the impact on ASD Limited and its employees. e) Monitoring We will consider TfL’s proposed strategy for mitigating adverse local traffic impacts, and the proposed monitoring timescales. Contrary to TfL’s proposed reactive approach, we will request a proactive approach, routed in detailed analysis and will draw on technical expertise as needed. ASD Limited reserves the right to add to the submissions in response to any other matters that may arise."
Members of the Public/Businesses
Barbara
"I am against of building the Silvertown Tunnel because: - it will encourage all the drivers to use cars instead of a public transport - the air will be definitely more polluted, more roads and tunnels means more pollution - there are not enough trees and green spaces in the area so the fumes will be spread easily across the city - more and more people will develop breathing problems like asthma for example - if the Blackwall tunnel is too congested then people should use tube, DLR and busses - i don't own a car and i can easily use public transport in London and whoever has a problem with a traffic jam then they should be encouraged to use TFL busses, tubes - i think that Silvertown tunnel will make London more congested and polluted "
Members of the Public/Businesses
Britannia Village (One) Resident Management Company (Britannia Village (One) Resident Management Company)
"The tunnel with have a negative effect on the Royal Docks area and East London as a whole because; 1/ New roads invite more traffic. Traffic will increase, causing an unbearable amount of traffic to be added to infrastructure not designed and not capable of accepting it. Silvertown Way and the Lower Lea Crossing are unable to cope with the demands of even minor roadworks or a bicycle show at Excel, which regularly causes traffic to back up to the Limehouse Link. 2/The scheme will not support the on-going regeneration in the area. The area around the northern tunnel portal is earmarked as almost 100% residential. 3/Alternatives have not been properly considered. Public transport links or a new rail/bus/cycle crossing would be more fitting. 4/ Air quality. The Royal Docks area will suffer greatly from poor air quality if the tunnel is built. 5/ Isolation of communities. Communities in the Royal Victoria dock area will be cut off by a major highway and constant traffic, creating a barrier to travel and integration with surrounding communities. 6/ Consultation has been insufficient. Despite being on the doorstep of the tunnel, many residents have no knowledge of it at all. 7/ Noise. Residents already endure the nightmare of noise from City Airport. They should not have to put up with the constant source of noise. 8/ Proximity to residential property and schools. The tunnel is close to many schools and homes, and will negatively affect them through increased noise and pollution."
Members of the Public/Businesses
Britannia Village General Management Company
"New roads generate more traffic. The tunnel won’t make the road network more resilient – it’ll only increase congestion, especially in the large residential area of the Royal docks. The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. TfL has not properly considered alternatives, including new public transport and better management of the existing network. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise pollution. Silvertown Way and the thousands of homes and schools stand to suffer greatly. The environmental impact of better access for HGVs and buses has not been properly considered. TfL has not properly considered the effects of tolling on the wider road network (for example, on routes to the Rotherhithe Tunnel, which would remain free). Tolling will also have a negative impact on local businesses – firms in other parts of London will not have to pay charges to get around. There’s been insufficient consultation with communities that will be affected by the scheme."
Members of the Public/Businesses
Caroline Russell AM
"The Silvertown Tunnel project will not meet its own objectives. I oppose it for the following reasons. Traffic generation - This scheme is presented as a response to London’s growing population and growing congestion. However, research commissioned by the Department for Transport, ‘Trunk Roads and the Generation of Traffic’ concluded "An average road improvement, for which traffic growth due to all other factors is forecast correctly, will see an additional [i.e. induced] 10% of base traffic in the short term and 20% in the long term”. The approach roads to the south of the Silvertown Tunnel would be shared with the existing Blackwall Tunnel, putting more pressure on these roads. This would not meet scheme objective 2 (to improve the road network performance of the Blackwall Tunnel and its approach roads) and would increase air and noise pollution for local people. No mitigation measures are included, yet the new tunnel would be used by HGVs, which would impact road safety in the neighbourhood. Air pollution - Given that the scheme is likely to result in increased road traffic, air quality is likely to deteriorate within the Air Quality Management Areas (AQMAs) designated by the London Boroughs of Newham and Greenwich. London Plan policy 7.14c on Improving Air Quality states that new developments should ‘be at least ‘air quality neutral’ and not lead to further deterioration of existing poor air quality (such as areas designated as AQMAs).’ Lewisham and Hackney councils have passed motions against the scheme due to concerns about traffic impacts. And Newham, Southwark, Waltham Forest and Tower Hamlets have all expressed opposition to the proposals due to local traffic and environmental impacts. Objective 6 of the scheme is ‘to ensure where possible that any proposals are acceptable in principle to key stakeholders, including affected boroughs’. The project fails to meet this objective. Poor value for money - TfL is already facing a rapid decline in central government funding, while the new Mayor’s fares freeze and growing demand for TfL’s services make for challenging circumstances. Objective 7 of the project is ‘to achieve value for money’ yet there has been scant consideration of public transport, pedestrian and cycle crossings which TfL’s early options paper confirmed would be far cheaper. TfL estimate the scheme will cost £1bn in total. For comparison, the current ten year cycling budget for London is £931m. The chair of TfL’s finance and policy committee has stated that the public private partnership (PPP) funding and design, build, maintain and operate contract approach planned for the Silvertown Tunnel will not achieve the best value for money (source: minutes of 21st Jan 2016 meeting). However, the Silvertown scheme can only go ahead if this approach is used - including it in TfL’s current business plan would mean deferring other high profile schemes. The DCO application should be withdrawn so that the Mayor can conduct his promised joined up review of river crossings. This must include consulting Londoners on a package of public transport, cycling and walking alternatives to the Silvertown scheme. "
Members of the Public/Businesses
Chris Gallant
"My submission will primarily focus upon challenging the proposed Charging Structure, in particular the ‘Consideration of a Resident’s Discount’ and how the Assessed Case does not include a discount for residents. My representation will specifically challenge Transport for London’s interpretation and logic surrounding these key areas: • The proportion of residents in the neighbouring boroughs who use cars as a regular mode of transport and therefore the population who might be impacted by such a resident’s discount • TfL’s out-of-hand view that a driver simply moving their route to an uncharged crossing is classified as ‘some inconvenience’. I will base my response here on TfL’s own Strategic Case for the tunnel and the crossing frequency across the Thames based upon population density of the surrounding areas • The points made in section 4.12.7 and how they are being used to support the rationale of not bringing in a Resident’s Discount. The statistics shown actually demonstrate clear rationale why a Resident’s discount would not have an adverse impact upon the operation of the tunnel nor counteract the social benefit of building the tunnel in the first place • How the zoning structure that could be used to support a Resident’s discount is dismissed with barely a mention and the comparison with the Congestion Charging zone shows no historic understanding of that scheme, nor the logical fallacy that is demonstrated • How a Resident’s discount is not zero-sum-game against other parties who may, or may not, be ‘worthy’ of a discount • That variances of Resident’s Discount have not been looked at and an interpretation that any form of discount must be 100% (similar to coaches or buses) – whereas instead multiple of other options could have been looked at that would both meet the Strategic Case and Traffic Management requirements of the tunnel • More generally, comments on the issue of the ‘Tax on East London’ that Lyn Brown MP for West Ham and others have raised"
Members of the Public/Businesses
City of London Corporation
"The City of London Corporation (COL) is the local authority for the City of London. It is also the traffic and highway authority, except in relation to GLA roads, and is subject to a network management duty under the Traffic Management Act 2004. The COL is also the lessee of first floor offices at Cory Environmental Riverside, Charlton, London SE7 7SU. As trustee of the Bridge House Estates charity, the COL owns and maintains Tower, London, Southwark, Blackfriars and Millennium Bridges. The COL supports the proposed new tunnel in principle but has concerns about aspects of the proposals summarised below:- 1. The COL seeks that the new tunnel will be constructed and operated with Category A designation under the Carriage of Dangerous Goods by Road Regulations to provide a route for the carriage of dangerous goods avoiding the Central London road bridges, particularly Tower Bridge, thereby very substantially reducing the need for dangerous goods to be routed through Central London both north and south of the River Thames and reducing the risk of spillages into the river. 2. Tower Bridge (listed Grade 1) was opened in 1894 and was not designed for the heavy weight of modern traffic. To protect its historic structure the COL seeks to ensure the proposals do not lead to an increase in overweight vehicles using Tower Bridge and seeks a commitment in the monitoring and traffic mitigation strategies to a signing and overheight vehicle strategy to reflect the existing 18t weight limit on the Bridge and monitoring of changes of movement of large and overweight vehicles so the commitment is secured by DCO requirement 7. The COL is separately pursuing with TfL arrangements to secure more effective enforcement of the existing 18t weight restriction. 3. The COL seeks inclusion of the City’s bridges in TfL’s commitment in the monitoring strategy to monitor effects on adjacent river crossings (so the commitment is secured by way of DCO requirement 7) and in traffic monitoring plans. 4. The COL seeks a commitment in the monitoring strategy to monitor the impacts on air quality in the City of London. 5. Specific commitment in the CoCP is sought for compliance with the London Permit Scheme to ensure coordination with other major works and events across central and inner London. 6. The COL continues to review the draft DCO, CoCP (in particular in terms of mitigation of any disturbance to premises leased to the COL) and other documentation, may have comments on the details, and wishes to be included in relevant discussions with TfL about the details to secure any necessary protections. "
Members of the Public/Businesses
Emily and Mike Norton
"We live in the Westcombe Park area and are bounded by the A2, A106 and A206 roads and affected by the levels of traffic that use all these roads. We are very concerned about the proposed Silvertown Tunnel. The Blackwall Tunnel approach roads cut through large residential areas where the level of housing is increasing all the time. These are inner London areas and we feel that the priority should be to reduce the levels of traffic in the area and discourage through traffic rather than build a new tunnel that will encourage even more use. The levels of pollution in these areas is currently unacceptable and there seems to be no guarantee that this will improve significantly if the Silvertown Tunnel is built, in fact we fear a worsening polllution in some areas. We feel the priority should be to improve the public transport infrastructure even further so that public transport becomes a real option for travelling between north east and south east London. There have been huge improvements in recent years but there is still a big incentive to use a car when travelling anywhere other than central London. We also feel that considering the Silvertown Tunnel as a standalone project without taking into account other proposed East London river crossings is crazy. We haven’t seen any proof that the Silvertown tunnel would even be needed if other crossings were built first. We fear years of disruption and increased pollution during construction followed by an increase in overall traffic and in particular in HGV traffic because of the removal of the northbound height restriction. We know that the A2 southbound cannot cope with the current levels of traffic so fear additional overspill into local roads in the evening peak if the Silvertown Tunnel is built. We also fear overspill onto local residential roads that link the A2 and A206 as drivers seek alternative routes to free crossings to avoid the tolls. We haven’t seen anything that guarantees this will not happen. We also object to the tolling structure in that it penalises residents and businesses in East London compared to West and Central London where it is free to cross the river. The structure of the toll proposals are particularly unfair to those who live or run businesses in South East London and occasional travellers who are not account holders and fear that this will affect investment in South East London. If tolls are necessary to control levels of traffic then this should be part of a far wider tolling scheme that discourages the use of roads in all of inner London not just the central zone. We would like to see the whole Silvertown Tunnel scheme rethought as part of a wider transport plan for London. "
Other Statutory Consultees
response has attachments
Environment Agency
"The Environment Agency has comments on this application relating to the following topics: flood risk and flood defence, the Water Framework Directive, groundwater protection, land contamination, fisheries, biodiversity and waste. We have written a letter which provides detailed comments. This was sent by email to the [email protected] inbox at 15.50 on Tuesday 30 August 2016. We would request that this letter is considered as our "relevant representation". "
Non-Statutory Organisations
Greenwich Borough Liberal Democrats
"The Greenwich Liberal Democrats believe that the case for building the Silvertown Tunnel has not been made. Rather than reducing congestion, research suggests that, after at best a short ‘honeymoon period’, the extra capacity provided will simply fill up. This extra traffic – including heavy goods vehicles which currently are unable to use Blackwall – would severely worsen what are already often illegal levels of air pollution in the borough of Greenwich. This doubling of tunnel capacity will not only increase road traffic and congestion in the medium term but also move the current pinch point (the tunnel) south to the residential approach roads surrounding the entrance which are already suffering the adverse effects of air pollution. At a time when the threat of air pollution has never been greater, and when levels of road traffic in London are actually decreasing, it cannot be right to pump massive investment into road building, rather than focusing that money on much needed improvements to greener forms of transport such as walking and cycling. TfL are suggesting that traffic can be managed once Silvertown is built by the use of tolling. But if tolling is the answer and congestion is the problem then that is something that could happen now, by tolling the tunnel purely at rush hour. At other times the tunnel is not congested, barring accidents. As memorably described by one clean air campaigner, Silvertown Tunnel is ‘a solution in search of a problem’. We believe that the Silvertown Tunnel is not the answer to the capitals most pressing problems and that other solutions are available."
Other Statutory Consultees
Health and Safety Executive
"The proposed Silvertown Tunnel, at the Southern Greenwich end, is located within the inner consultation zones of two major hazard sites with current hazardous substances consent. HSE normally advises against the granting of planning permission for a new dual carriageway in the inner zone of a major hazard. The busy transport link currently proposed is classed as sensitivity level 2 in HSE’s published LUP methodology – see http://www.hse.gov.uk/landuseplanning/methodology.pdf . In view of the density of traffic that is likely to be present at this proposed transport link within the inner zone of two major hazard sites, HSE advises against this proposed development. It is HSE’s policy to provide its advice on the basis of the hazardous substances consent entitlement. The current operational status of the site is not a matter that HSE takes into account because hazardous substances consent runs with the land and hazardous substances could be present at any time without further application through the planning system. HSE’s advice against the proposals can be addressed through existing planning powers in the Planning (Hazardous Substances) Act 1990, which allow the HSA to modify and/or revoke the hazardous substances consents which has the potential to reduce the major accident risks such that HSE would no longer advise against the proposed transport link. Certain land required during the tunnel construction for temporary works or site compounds falls within the safety distances of an area licensed for the handling of explosives under the Dangerous Substances in Harbour Area Regulations 1987. The granting of the DCO might prevent explosives being handled there for the duration of the tunnel construction. After completion, HSE’s Explosives Inspectorate will have no objection to the tunnel development, as it will not impinge upon the licensed explosive site. However, during the construction phase, it appears that land controlled by General Marine (Tugs and Barges) Ltd is to be included in the “temporary land taken for temporary works or site compounds”. Therefore during the construction phase, General Marine would be unable to handle any explosives at their premises, unless they can ensure that the area is cleared prior to explosives handling. This constraint may adversely affect the commercial viability of the licence holder. There are means by which HSE would be prepared to reconsider its safety advice and HSE will continue the dialogue with Transport for London and Greenwich Council on these aspects. "
Members of the Public/Businesses
Hedley Shaw
"The area is already suffering from excessively high levels of air pollution and an additional tunnel will increase the traffic numbers and hence further increase pollution. The entrance for this tunnel and the existing tunnels are adjacent so any additonal traffic will cause further tailbacks of traffic on the approach roads. I would urge planners to consider an alternative crossing between the Blackwall Tunnel and the Dartford Crossing and to consider a pedestrian and cycle crossing between Deptford/Greenwich and the Isle of Dogs. The plan for this second tunnel does nothing to help pedestrians, cyclists of improve public transport links across the river in South London."
Members of the Public/Businesses
J Currie
"I am extremely concerned about air quality in the immediate and surrounding areas. My aunt who lives just off Woolwich New Road has been diagnosed with a type of lung cancer linked to air pollution. With asthma levels in Royal Greenwich Borough being high I am concerned about the health impacts on all local residents. I am also concerned that Greenwich Council and the Mayor of London are doing little to discourage car use with huge car parks associated with new developments"
Members of the Public/Businesses
Kevin Godby
"There has been insufficient consideration given to the effect of increased congestion on local roads caused by the extra traffic that will be generated by the Silvertown Tunnel. I can tell when there are problems on local roads because Winn Common Road becomes noticeably busier, whereas usually it is very quiet. This tunnel will push traffic out onto other roads if it is built. There has been insufficient consultation with communities that will be affected by the scheme. Noise pollution will increase, air quality will worsen, and wildlife will be destroyed. This will not benefit local residents, it will instead encourage more 'through' traffic from outside the local area. "
Local Authorities
London Borough Of Bexley
"The London Borough of Bexley is concerned about the extent of the proposed monitoring set out in the Monitoring Strategy and the mitigation of traffic impacts as set out in the Traffic Impacts Mitigation Strategy. Extent of monitoring The Transport Assessment (TA) submitted with the DCO application indicates an increase in traffic as a result of Silvertown Tunnel in the PM peak hour along the A2 eastbound through the Borough to the M25 at Junction 2. In addition, increases in delays are indicated at junctions along the A2 corridor, the A206 and the A207 in the Borough. The TA suggests such increases are insignificant. That assumption is made in relation to modelling based on future growth aligned to the Further Alterations to the London Plan (FALP). Bexley and other boroughs are anticipating growth greater than that indicated in the FALP. Such growth may result in less spare network capacity than TfL’s modelling has assumed and any increase in traffic as a result of the Silvertown Tunnel could have a noticeable impact upon the free-flow of traffic on the network. The Monitoring Strategy proposes that the traffic monitoring extends eastwards along the A2 to the Danson Interchange only and does not include the A206 or A207 in the Borough at all. The Council acknowledges that there is a process allowing further monitoring sites to be added later through the Silvertown Tunnel Implementation Group (STIG) and that may be suitable for the A206 and A207. However, the A2 is a strategic route linking London to the motorway network, and, together with the A20, connects the capital to the Channel Ports, and taking into account the above issues regarding the modelling, the Council believes that the A2 corridor up to Junction 2 of the M25, and the A20 up to Junction 3, must be included in the Monitoring Strategy. Mitigation of traffic impacts The process to determine the need for, and type of, any mitigation is set out in the Traffic Impacts Mitigation Strategy (TIMS) which includes an indicative list of mitigation measures. The Council believes that the TIMS should state that it is not an exhaustive list because the type of mitigation will depend on the level of impact identified through the assessments to be undertaken nearer to the opening date. The TIMS also indicates that mitigation will only be on TfL road network and those under London Borough Control and not Highways England roads. The Council believes that the extent of mitigation cannot be determined until the assessments, to be undertaken nearer the opening date, have been completed. The process for deciding the need for mitigation, based on a Red-Amber-Green (RAG) approach is mentioned in TIMS. However, the report does not provide precise details on how RAG rating will be determined. The Council believes that full details should be provided on the process for determining the RAG rating of any potential location requiring mitigation. "
Local Authorities
Bruton Knowles on behalf of London Borough of Newham
"LB of Newham:- 1 Support the scheme as a Borough Council but 2 Would also like to register their requirement that the interests of their tenant/occupier, Waterfront Studios, must be properly considered in respect of their parking requirements, which are being removed under the scheme proposals. "
Local Authorities
London Borough of Waltham Forest
"This is to confirm that the London Borough of Waltham Forest has a continuing interest in the Silvertown Tunnel scheme and we wish to be kept informed as the project progresses Thank You"
Non-Statutory Organisations
London Chamber of Commerce and Industry
"The capital needs more fixed river crossings in East London. The lack of fixed river crossings east of Tower Bridge has hampered economic development for decades. Despite several false starts, no additional fixed river crossings have been added with the exception of the additional bore at the Blackwall Tunnel that created a separate southbound route in 1967. The combination of over-congested, low-resilience and archaic road river crossings in east and south east London means that an important area of the capital is relatively inaccessible compared to other parts of London. This has held back the area’s economic development for the following reasons: 1. The pool of potential customers and labour is lower for businesses located in east and south east London as the Thames acts as a barrier to labour and customer movements. 2. Businesses that have a high reliance on freight movements are less likely to locate there as supply costs are higher due to longer and more unpredictable journey times. 3. Poor accessibility lowers land values, which in turn lowers the development potential of east and south east London, reducing its capacity to provide homes and jobs for London’s growing population. The immediate main impact of the new Silvertown Tunnel would be to relieve congestion in and around the Blackwall Tunnel. Longer journey times and congestion lead to delays, increased fuel consumption and therefore greater cost – impacting the majority of local businesses. Congestion around the Blackwall Tunnel and its approaches costs motorists £17.5 million per year, according to TfL estimates. The case for a new tunnel to relieve congestion in East London is overwhelming and the tunnel should be constructed as soon as possible. LCCI accepts that charges may be required to fund the infrastructure and to reduce the likelihood of further delays. However, any user charge must be proportionate, and sensitive to the concerns of local residents and businesses. If a charge is introduced, it should be designed to reflect the flexibility, or otherwise, of user modes. Business traffic (particularly freight) is less capable of shifting from road usage to rail than private car users, and therefore should not incur as high a usage fee. By the same token, LCCI would argue that the toll should take into account the economic value of different journeys. Freight and fleet journeys have a higher economic benefit than leisure journeys, and therefore should not incur a high charge. LCCI believes that if tolling is introduced in a proportionate manner it could help with meeting the costs of whatever new river crossings are finally built. Whilst an additional tunnel at Silvertown is vital to relieve congestion at the Blackwall Tunnel, one new tunnel alone is not sufficient to unlock the economic and housing potential of East London. "
Non-Statutory Organisations
Vectos on behalf of London City Airport (Rachel Ness)
"London City Airport (‘LCY’) recognises that additional capacity is required for river crossings in East London, and that the existing Blackwall Tunnel infrastructure cannot accommodate the forecast increase in demand. Therefore, LCY supports the principle of the Silvertown Tunnel. Notwithstanding this, and following review of the Silvertown Tunnel Transport Assessment (April 2016) (‘TA’), LCY objects on three grounds: 1.the impact of construction traffic on the local highway network surrounding LCY; 2.the predicted operational peak hour delay on junctions serving LCY; and 3.insufficient assurance of improvements to public transport services as a result of the Silvertown Tunnel. 1. Construction Traffic - the TA assumes that, for the Silvertown Tunnel worksite, 20% of HGVs will travel along Royal Albert Way, Connaught Bridge Road and North Woolwich Road and 80% via the Tidal Basin Roundabout. These are key links and junctions which serve LCY; - the efficient operation of the local highway network (and these key junctions in particular) is vital to LCY’s customers and staff. A congested network can affect the ability of passengers to make designated flight times which, in turn, could compromise the performance and attractiveness of the Airport. Furthermore traffic delays to staff accessing the Airport will also compromise operational efficiency; - the TA states that a Construction Traffic Management Plan (‘CTMP’) will be prepared by the contractor before construction commences. The applicant has already prepared a Framework Construction Site Travel Plan as part of this but it only addresses the impact of traffic from construction workers; there is no framework for managing HGVs and ensuring that construction traffic adheres to the routes identified and in the proportions that have been assumed; - LCY requires the CTMP to be considered during the examination stage so that it can satisfy itself that impacts of construction traffic have been properly considered and can realistically be controlled and mitigated as proposed. As such, LCY requests that the Examining Authority uses the preliminary meeting to request that a framework version of the full CTMP is prepared. This will enable LCY’s concerns to be fully taken into account as part of the examination process. 2. Junction Delay - the TA identifies the potential for delay at key junctions serving LCY once the tunnel is operational, including on Victoria Docks Road, Royal Albert Way, Connaught Bridge Road and North Woolwich Road. This is important because (as indicated above) the operation of local junctions directly affects the performance of LCY; - the TA states that TfL are not identifying specific junction mitigation works in the DCO application, but propose assessing the traffic impacts on the wider network closer to the opening date of the scheme (in accordance with the Traffic Impacts Mitigation Strategy (‘TIMS’)) to determine whether any consequential mitigation measures are required. If so, the TA states that TfL will undertake such works; - LCY considers this approach to be unacceptable, since in effect it leaves the determination of whether mitigation works are necessary to the applicant itself and it provides no assurance or enforceable requirement that TfL will carry out any necessary works; - As such, LCY requests that the DCO, if granted, requires TfL to submit for approval details of mitigation measures and a programme of works to address any impacts identified during the three-year pre-Scheme monitoring period proposed in the TIMS. In addition, LCY requests that the DCO requires TfL to set aside a fund for undertaking these measures. Approval of these measures, the programme and the funding arrangements should be determined by the relevant local planning authority. - LCY also considers that it should be part of the Silvertown Tunnel Implementation Group which will have a consultative role under the terms of the DCO. 3. Public Transport - LCY considers that the DCO, if granted, should require that TfL promotes improved bus connections through the tunnel and in particular facilitates the indicative bus network enhancements as set out in TA."
Other Statutory Consultees
London Fire and Emergency Planning Authority
"The London Fire and Emergency Planning Authority (LFEPA) is the relevant Fire and Rescue Authority for this project. The LFEPA runs the London Fire Brigade (LFB). LFB will be responsible for emergency response to incidents in the tunnel both during the construction phase and after the Silvertown Tunnel becomes operational and our Fire Safety (Community and Statutory) department will be responsible for the enforcement of applicable Fire Safety legislation in premises associated with the tunnel. Both LFB Transport (Fire Safety) Group and LFB Operational Resilience Transport Infrastructure Liaison Group have been engaged with stakeholder consultation regarding the Silvertown Tunnel project to date. We have been consulted regarding emergency response and resilience arrangements and the fire safety engineering design for the tunnel, including means of escape, fire-fighting access arrangements and fire-fighting facilities, and our formal representation regarding future consultation for this project will address these areas and any other areas that are relevant to our jurisdiction as a Fire and Rescue Authority."
Members of the Public/Businesses
London First
"London First is a business membership organisation with the mission to make London the best city in the world to do business. Our members include the capital’s leading employers in key sectors such as financial and business services, property, transport, ICT, education, creative industries, hospitality and retail. London First strongly supports new river crossings in east London. The proposed Silvertown Tunnel would help reduce congestion and improve journey time reliability in an area with limited river crossing capacity for road traffic. The existing Blackwall Tunnel is a key strategic route for the east London economy, but is now struggling to cope with traffic levels far beyond those it was designed for. Heavy congestion is now a daily occurrence, punctuated by periods of complete paralysis when the tunnel is forced to close due to a crash, breakdown or other incident. A recent fuel spillage on 24th May, for example, caused the tunnel to be closed for 20 hours resulting in extensive tailbacks and significant disruption to businesses and their staff. A recent WSP Parsons Brinckerhoff survey of businesses in East London found that three quarters of all companies said that daily congestion at Blackwall is hurting their business and that two thirds think that journey time predictability at the crossing is poor. As a result, a third of all businesses have missed time-critical deliveries to their clients, while four out of ten are often late for appointments or meetings. The Silvertown Tunnel is also essential to support additional housing and population growth in east London. GLA forecasts are that London will grow by around 1.2m people between 2011 and 2031. The three Silvertown Tunnel host boroughs plus the London Borough of Barking and Dagenham are expected to accommodate 23 per cent of this growth. By improving connections north and south of the river the Silvertown Tunnel would enhance the links between new and existing homes and potential jobs. It would also provide new opportunities for businesses to thrive and grow. Half of all businesses in the WSP survey think that the new tunnel would have a positive impact on their business. London First also supports the principle of user charging to manage demand and/or to pay for new infrastructure. We support TfL’s proposal to apply a user charge to both the existing Blackwall Tunnel and new Silvertown Tunnel so as to reduce congestion and improve journey time reliability, and to fund the new scheme. This is consistent with the WSP survey which found that over half of all businesses would be happy to pay a toll at both Blackwall and Silvertown if it meant that journey times were made more predictable and congestion reduced. "
Members of the Public/Businesses
Margaret Gravelle
"I am a local resident and have attended a number of meetings and exhibitions about the proposals as well as reading some of the documents. I live within 2 miles of the Blackwall Tunnel and use it regularly, although not on a daily basis. My concerns • Congestion: I am aware of the congestion on the approaches to the Blackwall Tunnel and the delays that this causes but am not convinced that the proposed Silvertown Tunnel will reduce traffic or congestion, and consequent pollution, in the area. Rather, by attracting more traffic it may in fact increase the problems. • I am concerned that by facilitating north-bound heavy lorries Silvertown Tunnel will draw more of them to the area with impacts on noise, traffic congestion and air quality. • TfL proposes a new tunnel with very limited change to the rest of the road system. Some of the most serious congestion currently is southbound on the A2 in the evenings and a new tunnel feeding additional traffic into this system will only increase the problems. • Charging: I support charging for use of the proposed tunnel and the Blackwall Tunnel, but feel that this should be part of a wider road user charging structure. The danger is that charges will deflect traffic to other free crossings and increase local congestion. I am also concerned that the proposed charges are not sensitive or flexible enough to make an immediate impact. • East London Crossings: The Silvertown Tunnel should be considered in the full context of all East London river crossings. TfL should be looking at the most appropriate combinations of crossings, including public transport and provisions for pedestrians and cyclists. • I believe that alternative measures, such as introducing charging and putting in more robust measures to deter overheight vehicles and increasing access and frequency of public transport should be tried and evaluated prior to the decision to build the tunnel • I am worried that construction traffic using local residential roads to transport waste and building materials will have a serious impact. "
Members of the Public/Businesses
Maria Knight
"The tunnel with have a negative effect on the Royal Docks area and East London as a whole because; 1/ New roads invite more traffic. Traffic will increase, causing an unbearable amount of traffic to be added to infrastructure not designed and not capable of accepting it. Silvertown Way and the Lower Lea Crossing are unable to cope with the demands of even minor roadworks or a bicycle show at Excel, which regularly causes traffic to back up to the Limehouse Link. 2/The scheme will not support the on-going regeneration in the area. The area around the northern tunnel portal is earmarked as almost 100% residential. 3/Alternatives have not been properly considered. Public transport links or a new rail/bus/cycle crossing would be more fitting. 4/ Air quality. The Royal Docks area will suffer greatly from poor air quality if the tunnel is built. 5/ Isolation of communities. Communities in the Royal Victoria dock area will be cut off by a major highway and constant traffic, creating a barrier to travel and integration with surrounding communities. 6/ Consultation has been insufficient. Despite being on the doorstep of the tunnel, many residents have no knowledge of it at all. 7/ Noise. Residents already endure the nightmare of noise from City Airport. They should not have to put up with the constant source of noise. 8/ Proximity to residential property and schools. The tunnel is close to many schools and homes, and will negatively affect them through increased noise and pollution."
Members of the Public/Businesses
Matthew Pennycook MP
"The case for improving cross-river connectivity east of Tower Bridge is unassailable. However, that connectivity must be achieved in a way that contributes to a sustainable local transport system that delivers benefits in terms of improved air quality, inward investment and expanded opportunities. Any proposed solution to the problems of resilience at the Blackwall Tunnel and the appalling congestion and air pollution those problems so often exacerbate must, first and foremost, do no harm. Sadly, I am not convinced that the proposed Silvertown Tunnel can be said to pass that test. I have four main concerns: First, I remain concerned that the indicative charges outlined in TfL’s final statutory consultation are not sufficiently high to deter vehicles that do not currently use the Blackwall Tunnel, particularly heavy goods vehicles, from making the Greenwich Peninsula their preferred river crossing point. I note that under the proposals TfL would retain the ability to increase charges to manage demand. However, I fear that higher charges, should they be required, would simply lead to the harmful displacement of traffic westward given TfL’s refusal to extend the charging regime to the Rotherhithe Tunnel. Second, despite the need for continued investment to sustain modal shift toward public transport, TfL’s final statutory consultation contained no new proposals for significant public transport improvements e.g. an extension of the DLR to either Eltham or Thamesmead or a London Overground link from Barking Riverside to Thamesmead and Abbey Wood. Indeed, the consultation did not even contain guarantees that the new cross-river bus routes that a new Silvertown Tunnel might facilitate would be tied into the scheme through the Development Consent Order (DCO) process. Third, given how heavily TfL’s case for a new Silvertown Tunnel rests on the purported economic benefits of the scheme, no discounts for local residents or local businesses in the Royal Borough of Greenwich are proposed. The absence of such discounts suggests that the primary purpose of the new crossing is not to provide a non-strategic cross river link providing enhanced resilience and a welcome boost to local commerce, but to create a strategic crossing that vehicles making non-local journeys can opt for over the less reliable Blackwall Tunnel as a matter of course. Lastly, and perhaps most importantly, I remain concerned that the proposed scheme risks a further deterioration in overall air quality in the area. In their October-December 2014 consultation, TfL were open about the fact that a new Silvertown Tunnel would have a detrimental impact on air quality on some local roads. To be worthy of support, any proposed scheme needs to establish, beyond reasonable doubt, that it would not make an already dire situation worse. In sum, far from alleviating congestion and air pollution, I fear that the proposed scheme will exacerbate both to the detriment of the health and quality of life of my constituents. The status quo is untenable but we deserve smarter, more effective and more imaginative solutions than what is being proposed."
Members of the Public/Businesses
Merida Mathen
"I would like to make a representation on the following points: I agree in principle with the Silvertown Tunnel scheme. However, I have a number of issues with Transport for London’s proposals for user charging, and in particular the ‘Consideration of a Resident’s Discount’ section of their Charging Statement. 1) Having user charging on both the Silvertown and Blackwall Tunnels will be a hidden tax on local residents, some of the most deprived in the country. It will also increase the inequality between those living East and West of the city. 2) The suggestion in 4.12.2 that those who do not want to pay the user charge can simply use another crossing when one of TfL’s main reasons for promoting the Silvertown Tunnel is the lack of river crossings in East London. 3) The lack of discussion around suitable areas/zones eligible for a resident’s discount e.g. using postcodes. Also the lack of discussion regarding partial discounts or a peak/off peak charging structure for local residents. 4) The disproportionate impact of the charging structure on those who want to infrequently travel across the river to reach destinations outside the M25 (e.g. Kent, Sussex, Essex etc.) 5) The impact of user charging on non-charged crossings such as Tower Bridge and the Rotherhithe Tunnel (both of which are woefully inadequate and unfit for purpose). 6) TfL’s interpretation of statistics, primarily the focus on the 15% of East Londoners who say they never cross the river by car as opposed to the 85% which do. 7) That TfL have not objectively looked at the case for user charging and have made a premeditated decision to proceed with it in order to support their business case for the tunnel. "
Non-Statutory Organisations
Gerald Eve on behalf of Morden College
"SILVERTOWN TUNNEL (PINS Ref TR010021) : OUTLINE REPRESENTATIONS ON BEHALF OF MORDEN COLLEGE Morden College Morden College (the College) is a long-standing charity which provides residential care in Blackheath, south-east London. The College has been helping the elderly suffering financial hardship for more than 300 years. When it was founded the residents were housed in the College, but today a range of accommodation is provided comprising independent living, sheltered housing, and a Nursing / Residential Care Home. The College is the freehold owner of a substantial area of land on the western side of the Greenwich Peninsula and income from tenancies on the Greenwich Peninsula holdings helps to fund these charitable undertakings. Any loss of income in this respect could adversely impact on the ability of the College to achieve its charitable aims. Principle of the Silvertown Tunnel As set out in our previous representations dated 27th November 2015, we welcome the principle of both the Silvertown Tunnel and the ambition of Transport for London to improve the quality of the multi modal transport links into, within and out of the Greenwich Peninsula. However we note that the scheme will involve the permanent and temporary acquisition of areas of land in the freehold ownership of the College, and that this will adversely impact on the College’s tenants, on future income, and also on the future development potential of the land. Key Impacts and Requested TFL Action 1. Access to College Land A large proportion of the Morden College estate to the west of Tunnel Avenue is let under a head lease to Greenwitch Limited, which in turn has sub-tenants who access their tenancies via Tunnel Avenue and Morden Wharf Road. The remainder of the College riverside estate is let to Brenntag Inorganic Chemicals Limited, Hanson Civil and Marine Limited and Thames Craft Dry Docking Services Ltd who also access their tenancies via Tunnel Avenue. The proposed scheme will adversely impact on both normal and emergency access to these tenancies during the construction period and at present it is not clear from the Transport Assessment or Construction Method Statement how, and to what extent, access will be maintained throughout the project for the numerous HGV and other vehicle movements that currently take place to and from these sites from Tunnel Avenue on a daily basis. This is particularly the case during phase one when “traffic management” will be in place on Tunnel Avenue when the new footbridge is being constructed. The impact of this is to create uncertainty and potential loss of income to the College and their tenants if satisfactory arrangements cannot be put in place to maintain access to these sites at all times before, during and after construction. Greater clarity, more detailed worksite construction phasing plans, and guarantees in terms of maintaining access are therefore requested in this respect. 2. Relocation of Brenntag Car Parking Facilities The proposed new Boord Street foot / cycle bridge will take College freehold land leased to Brenntag Inorganic Chemicals Limited. This is currently used for a car park which will need to be moved and as a consequence the existing Brenntag operation will need to be reconfigured. Safe staff access to and from the new car park will also be important. The responsibility for the implementation, cost and timing of this work is yet to be formally agreed and we would note that it is important that the works are undertaken prior to the Silvertown construction works commencing in order to avoid major business disruption to Brenntag, The impact of the current position is to create uncertainty and potential loss of income to the College if satisfactory arrangements cannot be put in place to resolve this issue. Greater clarity and engagement from TfL is therefore required in this respect. 3. Traffic Impact During the Silvertown Tunnel construction works there will be an impact on the traffic conditions in and around the Tunnel Avenue area. The Transport Assessment sets out a phased approach to construction and access, but it is unclear to what extent traffic conditions on the surrounding network will change and how this will impact on the ability of tenants of the College to continue their normal business activities during the construction phase. Greater clarity and guarantees are therefore required in this regard. 4. Environmental Impact The construction works for the Silvertown Tunnel and also for the potential car park relocation work outlined above will disturb ground which may be contaminated. This may adversely impact on the tenants of the College and the therefore the College itself. At present, TFL have not accepted liability for the cost of dealing with any issues caused by the disturbance of contaminated land. This may therefore adversely impact on the College and its tenants. It is therefore requested that TFL accept liability for these costs. 5. Impact on Development Potential The land in the freehold ownership of the College to the south of Morden Wharf Road has short and medium term redevelopment potential. This is highlighted in the Greenwich Peninsula West Masterplan SPD adopted by the Royal Borough of Greenwich in 2012. This potential will be adversely impacted by the proposals because the ability of Morden College and its tenants to access this land during the period of the construction works will be limited at various points during construction of the Silvertown Tunnel. This may delay or impinge upon future redevelopment proposals. We therefore request greater clarity, more detailed worksite construction phasing plans and guarantees in terms of maintaining access to the College’s land via Morden Wharf Road and existing access from Tunnel Avenue adjacent to Thames Bank House throughout the Silvertown Tunnel construction period, as in our view, the existing Transport Assessment and Construction Method Statement are unclear in this respect. 6. User Charges It is noted that in the Silvertown Tunnel Charging Statement dated April 2016, the current proposals exclude any specific discounts for local residents or businesses, on both the Blackwall and Silvertown Tunnel and we would disagree with the arguments used to justify this position. For example, we believe that the current proposals for the introduction of a Blackwall tunnel charge will have the effect of significantly increasing the business costs of our client’s tenants who located to the site on the reasonable assumption that a road tunnel constructed in 1897 would remain free of charge. Costs of tunnel usage will not be factored into current operating costs which, as a result, may negatively affect the value of the property. On this basis, we would strongly oppose the introduction of a Blackwall tunnel charge at any pricing level, unless a mechanism could be introduced that exempted, or minimised, the charge to local businesses in the immediate vicinity of the tunnels. 7. Bus Services With regard to future development on the Greenwich Peninsula, and in response to sustainable travel policy, there will also be a need for an effective distribution of bus routes, to offer good load spread and passenger convenience. This is particularly important in view of the planned residential redevelopment of a significant portion of the western Greenwich Peninsula, including such sites such as Morden Wharf, Enderby Wharf and the Telegraph Works site. We would therefore emphasize that in our view this means that existing bus services and stops on Tunnel Avenue should be retained and enhanced as part of the proposed scheme. In particular it is important that the existing bus service number 108 which serves Tunnel Avenue is retained, and the existing number 129 service is potentially extended along Tunnel Avenue, in order to serve the existing and future workers and residents on the western Greenwich Peninsula. 8. Cycle and Pedestrian Accessibility Finally, we also have specific concerns regarding cycle and pedestrian accessibility in relation to the currently proposed scheme. These concerns are shared by the long leaseholder of Morden Wharf (Greenwitch Limited – subsidiary of the U + I Group formerly known as Development Securities and Cathedral Group). In summary we are of the view that the cycle and pedestrian infrastructure provisions as part of the proposals are inadequate. We would refer you to our last representations dated 27th November 2015 which set out further detail in this respect. "
Other Statutory Consultees
Winckworth Sherwood LLP on behalf of Port of London Authority
"The PLA is the statutory body responsible for the conservancy of the River Thames (“the river”) and the administration of navigation on the river. The area of the river affected by the proposed works is within the PLA’s jurisdiction and the riverbed is owned by the PLA. The Order limits extend across the river and include the width of the proposed tunnel (permanent acquisition of land); an area either side of the tunnel (permanent rights over land); and two temporary possession areas one on each side of the river. Compulsory acquisition of land is under discussion with TfL. The extent of the proposed exclusion zone around the tunnel, coupled with the proposed limits of deviation, is of particular concern. Other issues include the as yet uncertain impact of the proposals on the licensed works mentioned below. The PLA believes the permanent rights proposed to be acquired are excessive. The proposed temporary possession powers (in articles 29 and 30) and the power to use the river for works (article 17) are excessive and would close potentially the whole of the river to navigation. The permitted upward deviation for the tunnel would not ensure that there is sufficient cover for the tunnel. This could inhibit shipping by restricting the size of vessels that can navigate [past][over] the tunnel. The PLA is concerned by the effects of the Order on the ship impact protection pontoons protecting the Emirates Airline tower and some Greenwich Yacht Club moorings (all works licensed by the PLA) and the PLA’s mid-stream Barge Roads (lower) and Barge Roads (upper) moorings. The PLA is seeking to agree detailed amendments to the draft Order with TfL. These relate to, among other things, article 14 (discharge of water), article 16 (survey etc.) article 17 (works in the river) Part 1 of Schedule 2 (requirements) and Part 4 of Schedule 3 (protective provisions for the PLA). The PLA is discussing detailed amendments with TfL with a view to reaching agreement. The PLA believes the project could make greater use of the river during construction. It is also concerned that temporary works should be satisfactorily constructed with minimum intrusion into the river and proper safeguards on decommissioning. Detailed protections are required in relation to the dredging activities proposed. It is imperative that the proposed works maintain an appropriate access road for Peruvian Wharf, which is due to be reactivated for river borne cargo handling. The level of impact on existing river users, particularly cargo handling operations, could be exceptionally severe and potentially result in some permanent loss. This is contrary to policy and completely unacceptable. The PLA is very concerned at the effect of the Order proposals on affected river users. "
Other Statutory Consultees
Public Health England (PHE) (Public Health England (PHE))
"Thank you for your consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on your proposals, including the Environmental Statement (ES) and the Health and Equalities Impact Assessment (HEqIA). All advice offered by PHE is impartial and independent. PHE notes that we have replied to earlier consultations as listed below and this response should be read in conjunction with that earlier correspondence. • Request for Scoping Opinion 24th July 2014 • Section 42 Consultation 18th December 2014 • Health Impact Assessment and Equality Impact Assessment Scoping Reports Consultation 24th July 2015 • Section 42 Consultation 27th November 2015 PHE has considered the submitted documentation and can confirm that we are broadly satisfied with the approach taken in preparing the Environmental Statement ES and HEqIA and the conclusions drawn but would like to clarify certain aspects of the application. Our comments below are based on the assumption that the traffic modelling undertaken is both robust and validated. Summary PHE notes that overall, the implementation of the scheme is predicted (see HEqIA) to result in an overall increase in emissions (less than 0.5%) of nitrogen dioxide (NO2) and particulate matter. Whilst the exact health impact of an increase of this size is difficult to quantify, PHE would recommend that the proposer ensures that the local overall air quality is not worsened. PHE would encourage any new road or traffic development to consider, if practicable and cost effective, opportunities to secure improvements in local air quality. There are a few points to note from a wider health and wellbeing perspective. The proposer does not seem to have addressed or made an assessment or estimation of community anxiety and stress arising from perceived risk. The scheme itself would appear to be relatively neutral in terms of increasing (or decreasing) rates of physical activity through modes of active transport. However, from a wider health and wellbeing perspective, it would seem that this project represents a very intense use of resources aimed entirely at one mode of transport. Alternative proposals that support further increases in active travel with wider benefits to population health and wellbeing do not seem to have been considered and so there may be an opportunity missed. Air quality- general The proposer has utilised Defra baseline modelling data from 2012 alongside traffic data from the same year to compare against the reference (without scheme) and assessed (with scheme) cases when operational in 2021 but provides limited justification for using that baseline year. Hence PHE is seeking clarity as to the reasoning behind selection of this year and why a more recent year was not selected to be representative of current air quality. PHE notes that the scheme has considered current developments and those where planning permission has been agreed in the cumulative impact assessment. It is reassuring that the proposer’s HEqIA concludes that following a population exposure analysis of the study area, there will be no significant change in the population exposure to NO2 or particulate matter as a result of the Scheme. We note that the proposer intends to undertake air quality monitoring prior to and during the operation of the scheme. PHE would also expect the proposer to have assessed the potential impact of a 20mph zone within and around the Silvertown tunnel. There is evidence to suggest that the introduction of these zones in London can have beneficial effects on air quality Nitrogen dioxide (NO2) PHE note that in the ES the proposer focused on modelled differences in air quality at 52 “worst case” receptors (i.e. close to affected roads) within the study area. This subset of receptors was chosen based on professional judgement but it is unclear why a relatively low number (52) receptors was chosen to be analysed in further detail given that the study area comprised 1069 receptors where there was a perceptible change in air quality for NO2 (improvement or deterioration). In addition PHE notes that the data presented in the ES focuses on sensitive receptors which are located in areas where the air quality standard for NO2 is already breached or would be breached in the assessed or reference cases. The proposer’s assessments indicate that of these 52 receptors there are more receptors that would expect to see an improvement in air quality than a deterioration. However the assessments focus on receptors in areas where air quality standards are exceeded and further detail on all receptors would be useful. The Hoola building is a residential development in close proximity to the proposed North portal of the tunnel. Air quality modelling at this receptor has indicated potential increase at this receptor for NO2 at heights up to the second floor and also an increase for PM10. In addition, two schools (Faraday and Britannia Village) are predicted to experience a deterioration in air quality. PHE would seek further clarity on how the scheme would mitigate against any potential air quality / health impacts specifically for these receptors. Particulate matter (PM) The proposer’s assessment within the ES notes that at all receptors, except the Hoola building (see above), PM10 concentrations are predicted to be less than the annual air quality objective (i.e. 40µg/m3) both with and without the scheme. Similarly for PM2.5 all modelled concentrations are below the annual mean of 25 µg/m3. However, PM is a non threshold pollutant that can cause health effects at very low concentrations and the World Health Organization (WHO) has set its air quality guidelines for PM10 and PM2.5 at 20 ?g/m3 and 10 ?g/m3 respectively, which are below the current UK Air Quality Standards (AQS) . Hence, PHE would seek further detail on any potential impacts for PM10 and PM2.5 at receptors where concentrations are predicted to be below the current Air Quality Standards. Construction Phase PHE is supportive of the proposed baseline monitoring for particulate matter during the construction phase but awaits further detail on the scope of the monitoring in the Construction Environmental Management Plan (CEMP) once complete. The presence of potentially contaminated soils is identified and PHE would expect the CEMP to outline control and mitigation measures to ensure that there are no potential off-site impacts from the excavation of any contaminated soil. PHE also welcomes the commitment by the proposer to transport a minimum of 50% of excavated waste via the River Thames which should limit impacts on air quality during the construction phase. We would encourage the proposer to consider air pollution mitigation measures around the transfer points for excavated waste and subsequent transport. Summary and Recommendations PHE notes that overall, the implementation of the scheme is predicted (see HEqIA) to result in an overall increase in emissions (less than 0.5%) of nitrogen dioxide (NO2) and particulate matter. Whilst the exact health impact of an increase of this size is difficult to quantify, PHE would recommend that the proposer ensures that the local overall air quality is not worsened. PHE would encourage any new road or traffic development to consider, if practicable and cost effective, opportunities to secure improvements in local air quality. Hence based on our review, PHE would like to request further detail on: - The rationale for using 2012 as a baseline year for modelled data - Baseline monitoring that will be undertaken for particulate matter in the construction phase - Monitoring of particulate matter during the construction phase and NO2 pre and post implementation of the scheme - Air quality impacts in the ES have focused on change in air quality in areas where limit values/air quality objectives are exceeded (and on the number/proportion of receptors that are predicted to see improvements in air quality or a deterioration). It would be helpful to understand better the predicted impacts of NO2 and particulate matter for a larger subset of sensitive receptors where there was a perceptible deterioration noted, including receptor locations where an air quality standard isn’t breached with / without the scheme - Potential mitigation measures to limit any potential health impacts for residents of the Hoola building and nearby schools - Assessments of the potential impact of a 20mph zone within and around the Silvertown tunnel Should you have any questions or concerns please do not hesitate to contact us. "
Members of the Public/Businesses
Robbie Gordon
"As a local resident I fear deeply that this will be detrimental to the lives of local people.If this goes ahead the traffic will automatically go up Silvertown Way Canning Town Barking Rd Beckton Rd onto A13.This will debate the loves of local people and as to an already highly polluted area which has 3 primary schools.I urge you to reconsider tis and make a crossing further up linking the 406 roundabout. Yours sincerely. Robbie Gordon "
Members of the Public/Businesses
Rosalind Francis
"I am a local resident who feels that this area will be adversely impacted by the Silvertown Tunnel. I would like to register as an objector to the Silvertown Tunnel. Congestion: TfL have not considered the fact that new roads induce traffic and that the Silvertown Tunnel will increase congestion. This will increase across the wider road network in south East London and adversely affect congestion on the A102, A2, Woolwich Road, Trafalgar Road and at junctions such as Fiveways (junction of A20/B263 etc.) and the Kidbrooke Interchange, which are all unable to cope with the present levels of peak-time traffic. The extra vehicles will increase congestion on local and residential roads, already used by commuter traffic at peak travel times. This congestion will increase travel times on buses, the main form of public transport in the area, therefore discouraging sustainable travel. The increase in congestion on tributary will have a detrimental effect on both local resident and the local economy. TfL have not taken sufficient account of how the tunnel will affect the wider road network and have not provided sufficient plans to control the levels of traffic. One clear example is that at present HGVs over 4m tall avoid the area as they cannot go through the Blackwall Tunnel. There are no sufficient contingency plans for where to redirect vehicles above 4m when the Silvertown Tunnel inevitably closes due to accidents/breakdowns etc. Environment: TfL has not given adequate information on the scheme's likely environmental impacts, particularly regarding air quality and has an insufficient strategy to control the level of emissions. TfL claim that air quality will improve as the traffic will move more quickly, but does not take sufficient account of either extra traffic that will be attracted to the tunnel or the change in vehicles using this route, including large diesel driven HGVs and coaches that cannot currently use this route. The Woowich flyover is already one of the most polluted areas in London and the air quality will worsen with the Silvertown Tunnel, as will the increase in noise pollution in East Greenwich, especially roads bordering the A102 from these larger vehicles. The risks to the Maritime Greenwich World Heritage Site have not been properly considered. The environmental impact on the buildings and area in terms of increased air and noise pollution has not been considered, nor has the potential damage to the local economy this may cause in terms of loss of tourism/visitors due to worse environmental conditions. Tolling: TfL say that they will control the amount of traffic that uses the tunnel by raising or lowering the tolls. If the tolls are raised too high, some of the extra traffic induced by the tunnel will be displaced onto surrounding roads, through the World Heritage site to the Rotherhithe Tunnel, which will not be tolled; if the tolls are too low, air and noise pollution will get worse."
Members of the Public/Businesses
Stewart Christie
"I believe there are a number of flaws in the application as submitted including, but nit limited to, inadequate environmental assessments and plans for mitigation of air and mouse pollution. There is also a lack of planning or modelling of the impacts of induced traffic further out from the scheme on the approach roads and the knock-on effect of tolling. I also fail to see any adequate explanation of improvements for local businesses or regeneration for the area."
Other Statutory Consultees
Berwin Leighton Paisner LLP on behalf of Thames Water Utilities Limited
"Thames Water Utilities Limited (“TWUL”) is appointed by the Water Industry Act 1991 (“WIA”) as water and sewerage undertaker for the Thames region, which includes the location of the Silvertown Tunnel (“the Proposal”). TWUL does not in principle object to the Proposal. However, there are at least 20 TWUL assets of concern, including strategic assets that will be affected by the Proposal. Other assets may also be affected. TWUL also has easements and other rights in land which will be affected by the Proposal. TWUL wishes to register as an Interested Party to ensure adequate provisions are included in the Development Consent Order (“DCO”) to protect TWUL’s existing and future assets, and TWUL’s ability to comply with its statutory obligations. TWUL is in discussion with the Applicant in relation to its objections. An outline of TWUL’s principle objections are: 1. TWUL seeks comfort that Article 14 does not override the need for the Applicant to comply with sections 106 and 118 WIA, which prevent inappropriate connections/discharges being made to the public sewer system that could result in damage to the sewer network and environment. Article 14 gives the Applicant powers which are inconsistent with sections 106 and 118 WIA; 2. Article 29(6) excuses the Applicant from removing protective works around undertakers’ apparatus. This is unacceptable if such measures have an adverse impact on TWUL’s ability to comply with its statutory obligations, on the full operation of the assets or cause TWUL to incur additional future expense; 3. The definition of ‘statutory utility’ (Article 32) does not include TWUL. TWUL requires the protection of Article 32, which limits the Applicant’s powers under Article 9, in order to ensure it can continue to comply with its statutory obligations; 4. Article 32(7) refers to section 85 of the New Roads and Street Works Act 1991. Section 85 should not apply to stopped up streets, as they are no longer streets; 5. Schedule 13: 2(c)-(d) do not reflect all the apparatus and accessories that are/could be vested in TWUL, and which therefore need to be protected under the DCO; In order to ensure that TWUL can comply with its statutory obligations, 4(1) should permit TWUL to lay new apparatus, and 5 should require the Applicant to obtain consent before acquiring, extinguishing or overriding interests in land required for the retention/maintenance of apparatus; TWUL owns a headwall in land to be temporarily occupied by the Applicant. TWUL requires assurance that this will be protected under the DCO; The notice period in 6(2), 8(1) and 8(5) is insufficient to arrange potentially significant infrastructure works; TWUL objects to sub-paragraph 6(3). TWUL’s powers are not unlimited, and TWUL should not be obliged to use its powers to obtain rights and facilities for the benefit of the Applicant, where it has failed to make sufficient provision within the DCO; 6(5): The Applicant must not carry out work on TWUL apparatus without prior written consent. To do so could prejudice TWUL’s ability to comply with its statutory obligations; 6(7): the protection zone should be at least 600mm; 7(2)(b): the arbitrator should ensure that facilities and rights are no less favourable to TWUL than its existing rights, and must have regard to TWUL’s ability to fulfil its statutory obligations; 8(1): Notice must be given for any works authorised by the DCO that could impact TWUL apparatus and not just those carried out under 6(2); 9(1): The Applicant should repay to TWUL all expenses, costs and charges reasonably incurred; 9(3) and (4): clarity is required as to what does not amount to betterment in relation to TWUL specific apparatus; and 10 does not give parity with the indemnity provisions afforded to other undertakers under the DCO. "
Members of the Public/Businesses
Mills & Reeve LLP on behalf of Trinity (D) Limited
"1 Representation 1.1 This representation is submitted on behalf of Trinity (D) Limited (company registered number 04346508) of Bidwell House, Trumpington Road, Cambridge, Cambridgeshire (“Trinity D”), in respect of the application made by Transport for London (“TfL”) for a development consent order (“the DCO”) in respect of the proposed Silvertown Tunnel scheme (“the Scheme”). 2 Trinity D’s relevant interests 2.1 Trinity D has: 2.1.1 a 999 year leasehold interest in the O2 Arena and Dome Waterfront; 2.1.2 a 999 year leasehold easement allowing Trinity D to use land on Greenwich Peninsula (“the Car Parking Land”) for the parking of up to 2,000 vehicles by visitors to and customers of the O2 Arena or others authorised by Trinity D; and 2.1.3 granted leases of the O2 Arena and Dome Waterfront to Ansco Arena Limited and The Waterfront Limited Partnership, the operators of the facility. 3 The O2 Arena 3.1 The O2 Arena is a significant entertainment, retail and leisure destination, as recognised by both the London Plan and the Greenwich Local Development Framework. 3.2 The London Plan (March 2016) identifies: 3.2.1 Greenwich Peninsula, which includes the O2 Arena, as an ‘internationally significant leisure attraction’ (Annex 1, table A1.1); and 3.2.2 Greenwich Riverside as a Strategic Cultural Area (Map 4.2). Policy 4.5(A)(f) specifies that the Mayor will, and boroughs and relevant stakeholders should, ‘promote, enhance and protect the special characteristics of major clusters of visitor attractions including those identified in Strategic Cultural Areas’. 3.3 The Royal Greenwich Local Plan: Core Strategy with Detailed Policies (2014) identifies: 3.3.1 at paragraph 3.2.9, ‘the O2 Arena’s standing as the most popular indoor entertainment venue in the world’; and 3.3.2 at paragraph 4.2.4, ‘the important role that the O2 Arena plays in meeting the entertainment needs of both local residents and visitors from the UK and beyond.’ 4 Effect of the DCO 4.1 If a DCO is granted for the Scheme in the terms applied for, the DCO would confer powers on TfL to construct new twin-bore road tunnels, including: 4.1.1 power to compulsorily acquire parts of the Car Parking Land on a permanent basis; 4.1.2 power to use parts of the Car Parking Land temporarily; and 4.1.3 power to acquire permanent rights over parts of the Car Parking Land. 4.2 The Car Parking Land provides car parking facilities which are utilised for the successful operation of the O2 Arena as an internationally significant leisure, entertainment and retail destination. Trinity D relies on its easement to use the Car Parking Land in this regard. 4.3 Trinity D’s interests, and the public interest in the successful operation of the O2 Arena, would be adversely affected by the existence and exercise of such powers, both in terms of the permanent and temporary disruption and interference with the use of the Car Parking Land. 4.4 The DCO should not be made in its current form, and development consent should not be granted, unless and until Trinity D’s right to car parking, and the corresponding public interest in the same, is protected. Trinity D therefore objects to the application for the DCO. "
Members of the Public/Businesses
Agnes Vivier
"A. New roads generate more traffic. The tunnel won’t make the road network more resilient – it will only increase congestion. This will be an issue for Silvertown Way and the North Woolwich Road, Britannia Way, Wesley Avenue. It will also spread to roads feeding into the area B. Road transport is the principal cause of air pollution in over 95% of legally designated “Air Quality Management Areas” in the UK. Current estimates are that over 50,000 deaths a year can be attributed to air pollution in this country. The tunnel will make this issue worse. This will be more even more for areas close to the tunnel. C. Researchers have found that UK transport planners are not taking the environmental impacts of transport choices sufficiently into account. Despite pollution contributing between 15 and 30 times the annual number of deaths associated with road traffic accidents (RTAs) (2000-2015), Road Traffic Collisions (RTC) continue to remain the primary concern of transport planners while, at best, air pollution has been designated a “shared priority” between the Department for Environment, Food and Rural Affairs(Defra) and the Department for Transport (DfT). D. There is a strong social equity issue, with households in poorer areas tending to be exposed to much higher levels of air pollution, whilst contributing much less to the problem, principally through driving less. E. If a solution to motor traffic needing to cross the Thames is required then a traffic bridge should be built elsewhere as most of the traffic does not want to come to Silvertown at all. It wil be only passing through, heading to other destinations. There will be no benefit to the area. F. TfL has not properly considered alternatives, including new public transport and better management of the existing network. G. There is an urgent need for a pedestrian and cycle river crossing between the North Greenwich Peninsula and Canary Wharf. This should be built instead as an environmentally friendly solution. This could be another ferry or a new bridge or more use of the cable cars. H. The proposed scheme will not support regeneration in the affected areas, as claimed, and will not provide the promised economic and social benefits. I. Risks to the Maritime Greenwich World Heritage Site have not been properly considered and need to. J. TfL has not given adequate information on the environmental impacts of the scheme (its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise and air pollution K. The environmental impact of better access for HGVs and buses has not been properly considered. L. TfL has not properly considered the effects of tolling on the wider road network e.g. on routes to the Rotherhithe Tunnel, M. Tolling will also have a negative impact on local businesses – firms in other parts of London will not have to pay charges to get around. This is discriminatory for East Londoners and others wishing to do business and travel in this part of London N. There has been insufficient consultation with communities that will be affected by the proposed scheme. "
Members of the Public/Businesses
Alex Ingram
"I wish to object to the plans for the Silvertown Tunnel as currently presented. I focus my particular concerns as someone who primarily uses a bicycle as his method of transport in London and lives in Forest Hill, SE23. It is clear to me that there is a strong risk of transport impacts from higher volumes of traffic especially HGVs utilising the Silvertown Tunnel. These pose a particular danger to people on foot and on cycle as shown in KSI statistics in London. Where I live in South London the South Circular runs at the top end of my road. This road has never been correctly resolved and is essentially a series of residential roads that are being used as a key arterial route. It is an excluded route in the London Lorry Control Scheme and as such sees HGV traffic at any time, day or night. This route will see increases in traffic from the Silvertown Tunnel, as access to it is throttled by the existing arrangements. It is inevitable, even with tolling but especially even with preferential access for HGVs that large and dangerous vehicles will be on the South Circular at an increased rate. There is no cohesive network plan or spare capacity in roads in South East London ready for the Silvertown Tunnel. Finally, to add insult to injury no attempt is being made to use the Silvertown Tunnel works to provide for cycling in any meaningful way. There will be no extra crossing for cycles from the tunnel. At present the options to cross the Thames by cycle are Tower Bridge (free, but close to town), Rotherhithe Tunnel (only on the footway and dodging rare pedestrians unless you want to take the lane and hold up traffic for a mile), Greenwich and Woolwich tunnels (on foot) and if you pay the DLR or cable car (though the DLR cannot be used in rush hour). It seems utterly wrong that if tolling is meant to discourage unfavourable traffic that no free crossing is being provided to cycle over the Thames at this location. There are already regular queues to use the Greenwich foot tunnel lifts at rush hour. In a few years they will be even longer. Secondly, even with the changes being proposed no consequent increases in cycle access are proposed on nearby highways of any notable quality. I can see nothing in the Silvertown Tunnel that provides anything but increased risk to people on foot and on cycle and further bias to providing for motorised modes in crossing the Thames."
Members of the Public/Businesses
Amelia Anderson
"TfL has not properly considered alternatives, including new public transport and better management of the existing network. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise pollution (you might like to name affected areas)."
Members of the Public/Businesses
Andrew Pettitt
"There is absolutely no basis on which this project can be clearly demonstrated to be of benefit to the residents of Greenwich and the surrounding areas. Air quality is already poor and can only deteriorate with an increase in traffic volumes this project will generate. A progressive, integrated 21st Century solution (involving public transport, and all London crossings) to congestion and traffic issues is essential. A solution that puts air quality for our children, congestion, and the best interests of all Londoners as the main priority. This is not it. There is little or no support in Greenwich for this proposal, yet those with vested interests have ignored all sensible representations, preferring to accommodate the interests of property developers, local politicians of questionable motive, and big business. If this is allowed to proceed history will judge those responsible for it in the harshest possible terms. It is not too late, please do not build this tunnel. "
Members of the Public/Businesses
Anne James
"That having a tunnel from the Greenwich peninsula will exacerbate the already severe traffic problems in East Greenwich. There will be a knock-on effect for the surrounding areas of Charlton and West Greenwich. It is sometimes impossible to access some local businesses and services with the existing weight of traffic - it appears that the proposed scheme will attract further traffic, which will on,y make maters worse. That the air quality in the local area, already bad, will deteriorate further as traffic will sit in queues for even long than it does now. That the proposed scheme will, by making traffic congestion even worse, make it harder for Londoners like me who have to cross the river to take care of relatives.."
Members of the Public/Businesses
Athena Maschi
"the pollution is not good especially for the children and there are many of them in the area. All this pollution will put the value of properties down. Airport, A13, scrap yards, rubbish dumps, homeless people centers, crimes, gangs. There are enough problems here. The tunnel will only have negative impact no positive outcome for the people living in this area. If positive projects will take place the area could flourish and change for the better because it is quite central there is a potential. That won't happen if the area is ruined."
Members of the Public/Businesses
Bazalgette Tunnel Limited (Tideway) (Bazalgette Tunnel Limited (Tideway))
"Bazalgette Tunnel Limited (Tideway) is the ‘Infrastructure Provider’ for the Thames Tideway Tunnel. The Secretaries of State for the Department for Environment, Food and Rural Affairs; and the Department for Communities and Local Government; granted the Development Consent Order for the Thames Tideway Tunnel on 12th September 2014, which came into force on 24th September 2014 (The Thames Water Utilities Limited (Thames Tideway Tunnel) Order (SI:2014/2384) as amended by The Thames Water Utilities Limited (Thames Tideway Tunnel)(Correction) Order (SI:2015/723) and the Notice of Variation No 1 to the Deemed Marine Licence)). The Order provides consent for the construction and operation of a wastewater storage and transfer project of national significance. This consent is a material consideration of substantial weight in the determination of planning applications in the vicinity of the project, and the consented project should be afforded considerable weight in the consideration of other nearby projects, plans and proposals. Tideway supports improved infrastructure within London and has no objections to the proposal in principle, however wishes to make the following observation. Project Interfaces The Tideway project commenced construction in 2016 and construction works will take place up to 2022. Whilst not in the immediate vicinity of the Tideway project, construction of the Silvertown Tunnel has the potential to impact on Tideway’s logistics, and therefore the safe and timely delivery of the Thames Tideway Tunnel. The delivery of the Tideway project is reliant on river transport and is therefore likely to have a key interface with the Silvertown Tunnel Scheme. The River Transport Strategy for the Thames Tideway Tunnel scheme summarises the key commitments by the Undertaker to the transport of materials by river. During development and construction of the Silvertown Tunnel, the river navigational channel needs to be maintained and any short term restrictions would need to be minimised and approved by the Port of London Authority. It is vital that Transport for London takes the Thames Tideway Tunnel project into account when looking at cumulative effects, particularly any impacts that could cause the loss of the use of the river for transporting materials for the project."
Members of the Public/Businesses
Ben Morrin
"It is clear that simply building more roads is not a panacea for congestion or poor air quality and the argument that London requires additional road capacity simply to meet the demands of an expanding population is contested. Given the congestion and poor air quality we suffer from locally and the corresponding risk of making an already bad situation worse, the onus is on the Mayor and TfL as the scheme’s proposers to establish beyond reasonable doubt that the assumptions and analysis upon which the scheme’s purported benefits rest are sufficiently robust. The evidence and analysis that TfL has released to date has, in my view, failed to adequately meet that test. "
Members of the Public/Businesses
King & Wood Mallesons LLP on behalf of British Land
"British Land is currently preparing proposals for the Canada Water Masterplan, a major mixed use scheme in the Rotherhithe area. Approximately 3,500 homes and up to 10,000 jobs are proposed across the 46 hectare site. A planning application is expected to be submitted in mid-2017. Rotherhithe is a busy area with poor conditions at certain times of day for local residents close to the main vehicular corridor along the A200, including Lower Road, Jamaica Road and the Rotherhithe roundabout. The routes suffer from high levels of traffic flow and congestion in the peak hours, resulting in poor air quality, noise problems, community severance and delays to local bus services. A key contributory cause to the traffic congestion locally is the proximity of the Rotherhithe Tunnel, which is accessed from the A200. As a single bore, two lane tunnel, the route has limited capacity and is highly used on a daily basis. We conditionally support the proposals for the Silvertown Tunnel, which we expect could lead to improvements in the resilience of the road network in southeast London and could promote economic and population growth in the area. We acknowledge the analysis provided in the Transport Assessment (Document Reference 6.5) and the inclusion of a Monitoring Strategy (Document Reference 7.6) and a Traffic Impacts Mitigation Strategy (Document Reference 7.7) as part of the DCO application. The modelling analysis identifies limited impacts in the Rotherhithe area. We understand that an additional 900 vehicles are expected to use the Rotherhithe Tunnel on a daily basis and that this represents a marginal increase in the context of the existing level of traffic in the network. It is clear that the modelling results represent one set of outcomes which may or may not occur in practice once the Silvertown Tunnel is operational. We are therefore keen to ensure that suitable monitoring and mitigation is in place to protect and maintain the local road network for current and future residents in the local area, in the event that actual conditions prove to be different. The Monitoring Strategy identifies Rotherhithe as part of its “Area of Influence”, with specific mention of Lower Road. We consider that Jamaica Road and the Rotherhithe roundabout should also be formally included in the Monitoring Strategy in order to ensure that suitable weight is given to the monitoring of these key routes. We also note the focus of the proposed Silvertown Tunnel Implementation Group (STIG) to review the implementation and effectiveness of the Monitoring Strategy. We understand that STIG is intended to include key stakeholders. Given its major land interests, British Land has an active role in the Rotherhithe area and we would be keen to play a formal role in the monitoring of the scheme’s impacts. We would welcome the opportunity to engage with TfL and relevant stakeholders on the issues raised above before and during the Examination process and would like to reserve our position to appear at the hearing if sufficient guarantees are not forthcoming from the promoter."
Members of the Public/Businesses
Canary Wharf Group plc
"Silvertown Tunnel – registration of interest Canary Wharf Group has always argued for improved infrastructure in east London and additional river crossings have long been required. Despite a number of improvements over the last quarter of a century cross-river infrastructure in east London bears no comparison with that west of London Bridge. There has been an understandable call for better public transport crossings and over the last couple of decades four new crossings have been built (DLR to Lewisham and Woolwich and the Jubilee line to North Greenwich and on to Canning Town) with another (Crossrail to Abbey Wood) due to open in a couple of years. However proposed road crossings have been controversial and the Silvertown tunnel is no exception. Canary Wharf Group has previously raised concerns about the strategic impact of the proposed crossing and also pointed to localised operational issues. The east/west cycle super-highways have constrained traffic north of the river and as originally planned the Silvertown crossing would have exacerbated this. Furthermore the geometry of the northern exit appeared ill conceived and would have added to concerns about congestion. However TfL’s positive response appears to have addressed our principal concerns subject to an equitable charging regime for the existing and new tunnels. As TfL will be aware Canary Wharf Group have succeeded in reducing commuting to the estate by private car to less that 5% of journeys and our support for improved river crossings is not to improve conditions for commuters but to widen the catchment area for businesses in south-east London serving the companies based in Canary Wharf. Canary Wharf Group through its Local Business Liaison Office has succeeded in placing contracts worth more than £1billion with businesses in east London but to date these have predominantly been located north of the river. Businesses in south-east London have been at a serious disadvantage due to access difficulties via the Blackwall Tunnel. The Silvertown Crossing will therefore open up opportunities in Canary Wharf for small and medium size companies in south-east London which will widen the reach of prosperity generated by the Canary Wharf economy. We note that it is proposed to dedicate a lane of the tunnel to buses and HGVs. While we recognise the importance of improved bus services through the new tunnel, and would support their introduction, and also support the provision for high sided vehicles, we suggest that the use of the Bus/HGV only lane be monitored and be managed flexibly in order to optimise the tunnel’s utility. In conclusion therefore we remain concerned about the negative impact on commerce in London of the cycle super-highways but acknowledge that as now configured the Silvertown Crossing represents an improvement. However crucial to the success of the planned tunnel will be its management both in terms of the charging regime for the existing and new tunnels and the operation of the Bus/HGV lane. We strongly urge that a flexible approach is adopted, depending on conditions. "
Members of the Public/Businesses
Carrie Thompson
"I object against the Silvertown Tunnel which is proposed to provide a tunnel from Silvertown to Greenwich Peninsula in South East London. This road link will bring many vehicles to South East London/Greenwich area which is already a highly polluted area. There are many residential building being constructed in this area and it is therefore a negative to increase pollution in the already polluted area. The roads (Trafalgar Road etc) into London is already very congested with slow moving traffic. In my opinion a new tunnel should be looked at the area of SE London as a whole - it will cause a funnel affect. My opinion is that in the present day we should be seeking ways to decrease traffic in the area and not increase as would be done with this. Everyone would like a pedestrian/bike bridge from N Greenwich to Canary Wharf. Thanks Carrie Thompson"
Members of the Public/Businesses
Cesare Maschi
"I am concerned about pollution. I have two children 4 and 3 and they have problems in their Breathing. The pollution level is already high and it will be even worst because of the City airport expansion."
Non-Statutory Organisations
Citizens UK
"Newham Citizens is an alliance of 19 local community organisations in Newham. Our members are listed below: Birkbeck University of London, Stratford St Francis of Assisi RC Church Stratford and Canning Town Methodists St Angela's School St Bonaventures School St Antony's Primary School St Antony's RC Church Parish of the Divine Compassion Shpresa Programme Anchor House St Margarets RC Church Money A and E University of East London University of East London Students' Union Royal Docks Catholics Ursuline Convent St Stephen's RC Church Newham Sixth Form College Applecart Newham Citizens is part of The East London Communities Organisation (TELCO), the founding chapter of the national charity Citizens UK. Our mission is to make Newham one of the best places in Lindon to raise a family and get good paying jobs. Together with our sister alliance, Greenwich Citizens, members of our organisation would like to ensure that: The proposed Silvertown tunnel leads to building resilient families and communities through co-operation with decision-makers across the four Boroughs of Newham, Greenwich, Bexley and Barking and Dagenham. Local residents and community groups are involved in decision-making and have a say on the proposed Silvertown Tunnel beyond the initial consultation The scheme provides apprenticeships and training opportunities for local young people, and that there is a transparent mechanism for accessing these opportunities. Our view is that all apprentices must be paid the London Living Wage. In addition, we would like to see a legacy of training and skills created by Silvertown Tunnel and future river crossings in the area. Local people in the four boroughs are prioritised for the jobs created by the scheme, and that all jobs are paid at least the London Living Wage rate. Access to jobs should also go beyond the usual Job Centre or Local Authority Brokerages, and include some community-based recruitment models to ensure that as many local people as possible benefit from the job opportunities."
Members of the Public/Businesses
Clare Griffiths
"I am writing to object to the proposed Silvertown Tunnel for the following reasons: 1. New roads generate more traffic. The tunnel won’t make the road network more resilient – it’ll only increase congestion. I live off the South Circular road which is regularly heavily congested and backs up when the tunnel is closed, with jams spreading out into local side roads. An increase in traffic generated by the proposed tunnel will make these jams an even more regular event. 2. The scheme will not support regeneration in the affected areas, as claimed, and won’t provide the promised economic and social benefits. 3. TfL has not properly considered alternatives, including new public transport and better management of the existing network. 4. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. 5. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). 6. There isn’t adequate mitigation for noise pollution, particularly along the A2 and A12 corridor. 7. The environmental impact of better access for HGVs and buses has not been properly considered. 8. TfL has not properly considered the effects of tolling on the wider road network. If Rotherhithe Tunnel remains free this is likely to increase traffic in Deptford, Greenwich, Poplar and Limehouse. 9. There’s been insufficient consultation with communities that will be affected by the scheme. In particular, my borough of Lewisham was not included as one of the three main affected boroughs despite the fact that it's road network is very likely to carry a heavy burden of Silvertown tunnel traffic. The council and the borough's residents have not been properly consulted with - Lewisham council's response was simply considered along with those from the wider London area and there were no consultation events for Lewisham residents. "
Members of the Public/Businesses
Clem Riches
"This Tunnel scheme will not serve to reduce emissions in London over the long term- quite the opposite. Air pollution in London is a serious concern for me, and there is clearly growing awareness of the harmful effects of vehicular emmissions, particularly from diesel, in urban environments. The growing concern over diesel emissions has, coincidentally as it happens, come to light during the course of this planning application. On just this one issue alone, I find the Tunnel scheme a critically flawed proposal, and now quite untenable for TfL to continue to persist forward with it. To my knowledge, there are no examples of past road building initiatives in London that have not, over a longer period of time, served to significantly increase traffic levels on all roads, large or small, over wide areas, not just the immediate vicinity of the road in question. I strongly feel the Silvertown tunnel will incentivise people to use a car to commute over other alternatives, with the result of a marked increase in levels of traffic throughout East and South East London in years to come. I believe efforts should be made to reduce traffic in London, not increase it. It is improvements to public transport infrastructure that can be of the most benefit for all people of London, as well as offering a clear alternative to driving. If there is a need for easing the amount of lorries using existing crossings, then I would consider in this general location the merits of a dedicated HGV/bus only boat crossing- but absolutely not a general ferry for all vehicles. The area of the Royal Docks, north of the river, will be severely adversely impacted by noise and particulate pollution by the tunnel, already a serious problem in this area. In this same locality, the very recent permission for expansion of site infrastructure at London City Airport will also result in a further future increase in vehicles traveling to/from the Airport, particularly along the North Woolwich Road, which leads up to the proposed tunnel entrance. It is disappointing that the combined and cumulative future pollutive effects of these two significant but separate planning matters have not, as I understand, thus far being considered 'in the round', so to speak. "
Members of the Public/Businesses
Colin Tweed
"I object to the proposal and implementation of the Silvertown Tunnel. London has the worst air quality in the world resulting in the premature deaths of thousands of people. New road schemes such as this will only create more polluting traffic bringing more congestion, dirtier air and unsafe road conditions. National Infrastructure Planning needs to be focussed on creating roads so that people who want to be able to walk or cycle are enabled to. Sucha s protected cycle lanes on main routes, filtered residential streets and cycle/pedestrian only river crossings"
Members of the Public/Businesses
Daniel Blaney
" I am concerned about implications for air quality and traffic congestion and the failure to promote sustainable development via sustainable transport modes including walking and cycling. "
Members of the Public/Businesses
Darryl Chamberlain
"My name is Darryl Chamberlain, and I have lived close to the Blackwall Tunnel Southern Approach for most of my life. Between 1977 and 1999 I lived in Combedale Road, Greenwich, just 50 metres away from the Woolwich Road Flyover, and know only too well the effects of congestion on the A102, as well as the noise, dirt and pollution this road generates. I now live in Victoria Way, Charlton, some 600 metres away, and the noise from the road can still be heard at night. I would like to object to the Silvertown Tunnel for the following reasons. 1) Transport for London still hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). 2) This road will generate new traffic, exacerbating congestion on roads that already struggle with the load from the existing Blackwall Tunnel, such as the southbound A102/A2 corridor south of the river, and surrounding roads such as the A206 Woolwich Road, which already suffers from terrible air pollution levels. Relying so heavily on the A102/A2 corridor will simply make a weak point in the road network even more vulnerable to congestion. 3) North of the river, the congested Lower Lea Crossing, Aspen Way and Leamouth Road will also face extra traffic, while this will do nothing about jams on the southbound A12 through Bow and Poplar. 4) TfL has also failed to consider the impact on the wider road network - such as on the South Circular Road, and on routes to the Rotherhithe Tunnel - and is relying solely on best-case scenarios to make its case. In addition, the impact on the Maritime Greenwich World Heritage Site - which may be used as a diversion for traffic seeking to avoid tolls - has not been considered properly. 5) The scheme will not support regeneration in the affected areas, as claimed. Indeed, the regeneration is already happening without the tunnel, including the acceleration of developments at Greenwich Peninsula, Royal Wharf and City Island. 6) The environmental impact of better access for HGVs has not been properly considered. Currently many HGVs cannot use the northbound Blackwall Tunnel - a new Silvertown Tunnel would increase noise south of the river before sending HGVs through unsuitable roads north of the Thames. 7) TfL has not properly considered the effects of tolling on the wider road network. Tolling Blackwall/Silvertown risks increasing congestion and pollution on routes to the Rotherhithe Tunnel (such as Brockley Road, Trundleys Road, Creek Road and Evelyn Street), which is planned to remain free. (TfL has already admitted these roads will face extra traffic.) But if the fee is set too low, which it appears to me to be, the tunnel will simply add to congestion. In the absence of a proper London-wide road charging scheme, and considering the lack of proper orbital public transport routes in this area, building a tunnel here will simply be counterproductive. 8) There has been insufficient consultation with communities that will be affected by the scheme. In particular, Lewisham Council and Lewisham borough residents have not been properly consulted, despite that borough's proximity to the A102/A2 junction at Sun in the Sands and the risks to residents from increased traffic on the A2 and A205. By contrast, Greenwich Council, which has actively lobbied for the Silvertown Tunnel - and encouraged residents to do the same in its weekly Greenwich Time newspaper - has been closely consulted, to the detriment of residents outside its area. 9) TfL has not considered alternative schemes properly. Obviously, this should include better public transport or walking/cycling alternatives. But even better management of the northbound Blackwall Tunnel - such as detecting overheight vehicles much earlier - has not been properly considered. Nor has cutting the A102 to two lanes each way so there isn't the bottleneck at the Blackwall Tunnel entrance (the third lane could be used for buses, boosting public transport use). I hope these points are useful. I would like to emphasise that while I have been involved in the No to Silvertown Tunnel group, this is a personal submission."
Members of the Public/Businesses
Deborah O
"The rationalisation for adding a further road link across the Thames at this, or any, point within Greenwich, is flawed. As with the creation of the second Blackwall Tunnel, additional, new, traffic (particularly HGV) will be attracted to an already heavily congested and polluted area."
Members of the Public/Businesses
Duncan Alexander
"The Silvertown tunnel would increase pollution while doing little to reduce congestion."
Members of the Public/Businesses
Edith Speller
"I don't think the Silvertown Tunnel scheme will help address congestion in SE London - it will induce more traffic to use the roads and south of the river the entrance is right next to the existing tunnel, so if there is an accident or other disruption on the approach it will affect both crossings and the traffic in the area will get even worse. I live in Lewisham and work in the Maritime Greenwich World Heritage Site and am a frequent bus user - there is already a very high level of private traffic on the roads in the area and in particular the roads in the heritage area already get very congested. The Silvertown Tunnel would not relieve this. TfL have not made the best use of the existing crossings e.g. by providing a range of bus routes through the Blackwall Tunnel, and should also provide more crossings for pedestrians and cyclists. I'm further concerned about the environmental impacts of the crossing and more traffic in the area."
Members of the Public/Businesses
Elisabeth Whitebread
"I am writing to object to the proposed Silvertown tunnel. My reasons for objecting are as follows: - increased air pollution - so close to LCY airport, the area already suffers from awful - ILLEGAL - levels of air and noise pollution. It seems immoral to expand the airport and simultaneously create a tunnel and more road users in the same borough. With no mention of carbon offsetting or messages to reduce the environmental impacts. Studies show bridges are better than tunnels for dispersal of air pollutants. - increased traffic congestion and issues of road safety - will the network be able to support the additional traffic created? Will our roads be safe for cyclists and pedestrians? - pedestrian and cyclists access/provision - environmental impacts during construction (both on the environment generally, and for local residents - yet more noise and air pollution from construction, etc.) - impacts on/lack of benefits for local small businesses and residents - years of construction in the area have already taken a toll, the projected additional construction, and the increase in through traffic once the tunnel is completed will make it harder for locals to get around and use existing small businesses and local services - tolls to use the tunnels - where is that money going, and why hasn't the toll been introduced at Blackwall for a test of concept? - Why are only East Londoners facing charges for new and existing river crossings? We've always been at a disadvantage to West London for river crossings, and the ones we get are all tunnels, now they'll all be tolled tunnels! We want more crossings, but ones that work for everyone in the local community, not just commuters coming in from outside London - I'd prefer a bridge to a tunnel. My understanding of the project to date suggests that this concept has not been investigated thoroughly. The foot/cycle bridge closer to the city is popular with locals, they'd like something similar included in this plan. Not everyone in Royal Docks have (or want/need/can afford!) cars! In fact, only half of households in Newham have access to a car, the projected tunnel offers nothing to us but additional health problems and inconvenience! - discrepancies between size needed for stated use and actual size of tunnel on plans is worrying - we already allow lorries bigger than other countries in the EU, to reduce carbon emissions we should be planning for smaller, cleaner transit options - Financially wasteful - pointlessly wide tunnels, with vast cross-tunnels. Seems far bigger than necessary. Bigger structures = more materials used. Money could be used more effectively."
Members of the Public/Businesses
Elizabeth Winder
"I am a local resident whose health and enjoyed of my home will be severely damaged by these proposals as: 1. The area suffers from an already high level of pollution which this proposal will make higher - nobody is looking out for or standing up for impact on the health of local residents; 2. The noise from the traffic will damage the enjoyment of my property; 3. The expansion of city airport will put too much pressure on a very small area of London; 4. There are better sites in East London for this project. 5. We have received one notification to object - this is surely unfair given the impact on lives it will have? Why have people not been given a fair notification for the chance to object?"
Members of the Public/Businesses
JLL on behalf of ExCeL London Limited
"On behalf of our client, ExCeL London Ltd (‘ExCeL’), JLL wishes to register ExCeL as an Interested Party in relation to the proposed Silvertown Tunnel. ExCeL operates the ExCeL Exhibition Centre London on Victoria Dock Road. ExCeL welcomes transport improvements which support and improve the resilience of east London’s road network, particularly in relation to the Blackwall Tunnel. We agree that transport improvements are needed in order to support economic and population growth across the Royal Docks and wider east London area, and support the principle of providing additional cross-river links. We intend to bring forward evidence in relation to the following: a) Potential impact on local traffic congestion across the wider highway network We will review TfL’s Transport Assessment, drawing on technical expertise as needed. At this stage, it is worth repeating that ExCeL is concerned about potential impacts, and whether these have been considered in sufficient detail to determine whether ExCeL will be detrimentally affected. Particular regard will be had to assessing whether the new tunnel may hinder people’s ability to access ExCeL, both during construction and once operational. This includes any temporary road closures. No formal agreement has been made with ExCeL to provide comfort as to how the tunnel’s construction will ensure ‘business as usual’. We respectfully request that ExCeL is party to the timing and location of any road closures / diversions, and that sufficient technical analysis is undertaken to test the impacts on a site-specific basis. b) Impact of the scheme on the local environment, including traffic congestion, air quality and noise We will: • Highlight the desire for regeneration to take place locally and the recognised strategic importance of ExCeL, drawing on adopted and emerging planning policy including the London Plan (2016), LB Newham’s Core Strategy (2012) and the emerging Opportunity Area Planning Framework. • Query the appropriateness of leaving responsibility for producing an Air Quality Management Strategy and Construction Management Plan to the appointed contractor, without pre-testing potential impacts on a site-specific basis. • Draw on technical expertise to demonstrate impacts by way of traffic, air quality, noise (etc). • Interrogate TfL’s supporting documentation, including findings that more residents will experience an increase in noise levels than will experience a reduction. • Request that ExCeL be party to the production of both the Air Quality Management Plan and Construction Management Plan. c) Monitoring We will consider TfL’s proposed strategy for mitigating adverse local traffic impacts, and the proposed monitoring timescales. Contrary to TfL’s proposed reactive approach, we will request a proactive approach, routed in detailed analysis. We will draw on technical expertise as needed to support our approach. d) User charging We will respond to TfL’s proposed approach to user charging, and its general assessment of the impact, which focuses primarily on local residents. In so doing we will demonstrate the impact on ExCeL, including visitors and its employees. ExCeL reserves the right to add to the submissions in response to any other matters that may arise. "
Non-Statutory Organisations
Friends of the Earth
" Friends of the Earth will make the case that the scheme does not perform against its own criteria and that there are better alternatives to address issues including on congestion, resilience and dealing with population growth. The adverse impacts, including particularly those on air pollution, are not acceptable. Traffic issues We challenge assumptions made and modelling carried out, including regarding journey lengths, impacts on other crossings, and worst-case scenarios. We argue that increased traffic, even if just during peak hours, would be unacceptable and that traffic reduction is needed. With tolling it would be possible to levy charges so high that there were no extra trips or vehicles or vehicle kms - but this would risk rendering the scheme pointless in its own terms. Congestion Even if existing patterns of congestion change and existing queuing at Blackwall is reduced, the scheme will cause worse congestion in other places at times when traffic volumes would be higher. This is unacceptable and bad for business. The only way to cut congestion is to reduce traffic levels altogether. We understand that for a given volume of traffic, moving traffic causes less air pollution than stationary vehicles. However increased traffic (even if just at certain places / times of day) would result in worse congestion and air pollution, particularly at peak times, which would negatively impact many existing road users. Air pollution Inadequate information has been provided for the public to come to an informed view on the air pollution implications. Even in TfL’s reference cases, air pollution would be worsened in some locations. In addition to the legal imperative for action to reduce air pollution in London, there is also a strong moral case for Londoners’ health. The fact that it will worsen air pollution in some locations means the scheme is not acceptable. The number of locations which would be projected to see improved air quality versus those which would see worse air pollution is irrelevant. Relying on a test of whether the scheme would delay compliance with EU NO2 requirements in the Greater London AQ Zone is not acceptable. There are considerable co-benefits of action to cut air pollution in reducing climate changing emissions, on which there is also an imperative to act. Worsening air pollution would have a disproportionate impact on the most disadvantaged; this would be unacceptable. Regeneration Our arguments include how public transport-based regeneration makes better use of space, enabling better use of space for much needed housing. Population growth The way to cater for this is to reduce demand for travel by reducing the need to travel, and to provide public transport for longer journeys – helping free up space on, and make better use of, the existing roadspace. Alternatives not properly assessed TfL has never publicly considered, nor given the public a chance to comment on, the option of a comprehensive package of non-road options including non-road river crossings and complementary measures to improve accessibility without adding to air pollution. "
Local Authorities
Greater London Authority
"The GLA supports the principle of the Silvertown Tunnel project, which will address severance issues and improve connectivity north/south across the River Thames in east London. The City in the East masterplan highlights the significant growth potential in east London, but acknowledges the challenges that exist to realise this potential, in relation to infrastructure constraints and poor connectivity, and the Silvertown tunnel project is one measure that will improve this situation. As the statutory planning authority, the GLA will be submitting a Local Impact Report at the next stage of the process, and this will cover the following strategic matters in more detail, in relation to compliance with the London Plan policies: Principle – This section will expand on the above and provide additional policy context, in particularly in relation to emerging policy in the draft Royal Docks Opportunity Area Planning Framework (OAPF). Urban design – This section will look at the design principles and indicative design and how the tunnel will integrate with key development sites to ensure that land use strategies, densities and connections can be optimised. Air quality - Improving London’s air quality is a top priority for the Mayor, so this section with look at how the scheme delivers improvements in air quality, mitigation and monitoring. Transport – This section will cover: the existing situation; the TA; construction including use of river transport (and wharves); future traffic and transport impacts; design and local connectivity around portals (in relation to pedestrian/cycle connectivity), and; monitoring and mitigation. Flooding – This section will cover the long term look at flood risk, including the Thames Estuary 2100 flood defences, given the long term nature of this piece of infrastructure. Ecology and noise – how the project ensures compliance with the relevant London Plan policies."
Non-Statutory Organisations
Greenwich Friends of The Earth
"Greenwich Friends of The Earth is a part of Greenwich & Lewisham Friends of the Earth. This response is additional to the response of National Friends of The Earth. Greenwich Friends of the Earth is in complete agreement with the views expressed by National Friends of the Earth regarding the proposals for additional river crossings in east London. If there is considered to be any conflict between this submission and National Friends of The Earth then National Friends of The Earth's response will take precedent. Whilst Greenwich Friends of The Earth is in agreement with the aims and objectives of National Friends of The Earth we also wish to present to the examining authority submissions that reflect our local knowledge in relation to this proposal, whilst bearing in mind that the examining authority will need to assess the merits of this proposal in terms of regional and national policies, rather than solely local considerations. Below we outline summary grounds for our objection to the proposed 1. Needs and alternatives. Greenwich Friends of The Earth considers that there has been no proper consideration for the need for this ( and other Thames river crossings ) crossing. We consider that the ( mandatory ) consultation process is flawed, particularly in terms of failure to properly consider a package of crossings that are not based on private vehicle use. 2. Traffic levels and congestion Greenwich Friends of The Earth considers that the proposers of the Silvertown crossing have not fully taken into account the effects of 'induced traffic' , in other words the phenomenon whereby the creation of new road space does not solve the problem of congestion, rather it merely provides a very brief respite. In addition during the the construction phase of the Silvertown crossing congestion and disruption would be significantly increased for a significant period of time. 3. Air quality We note the increasingly conclusive evidence with regard to the widespread and serious damage to health caused by poor air quality and that the UK is currently in breach of EU directives regarding air quality, and that these directives continue to have legal force. We consider that the proposed Silvertown crossing will worsen air quality in an area which is already in breach of pollution limits to a very significant degree. In particular we are seriously concerned that the proposed Silvertown crossing will have long term serious health consequences with regard to younger residents who are already experiencing serious multiple deprivation. 4. Climate Change – whilst the proposed scheme may only contribute a very small percentage amount to the UK's carbon budget we would bring to the examining authority's attention the fact that the UK needs to urgently reduce greenhouse gas emissions in order to co,bat dangerous levels of climate, and the scheme would run counter to this aim. 5. Supposed benefits/regeneration – we would like to remind the Examining Authority that in the case if the proposed Thames Gateway Bridge an independent inspector found that the benefits were significantly overstated. "
Non-Statutory Organisations
Greenwich Green Party
"On behalf of the Greenwich Green Party I object to the proposed Silvertown Tunnel on the grounds that: New roads generate more traffic rather than alleviate it, this will have severe consequences for traffic in areas such as Plumstead Extra diesel vehicles will add to already dangerous air pollution levels The environmental impact has not been properly considered There has been insufficient consultation with local nearby communities "
Non-Statutory Organisations
Greenwich Society
"1. Air Pollution As a result of traffic congestion, predominantly along the A102, Greenwich is among the worst affected by air pollution in south east London. In their 2015 consultation TfL argued that the Silvertown Tunnel scheme was the only way to prevent harmful traffic emissions around the Blackwall Tunnel getting worse. It is therefore surprising and disappointing that their latest forecasts show only small or" imperceptible" changes in NO2 emissions along the A102 in our area. Apparently this is because the improvement in the morning peak is offset by increased traffic congestion southbound from the tunnels in the afternoon peak. This needs to be reviewed urgently to see how junctions along the A102 southbound can be improved, before Silvertown is opened, to achieve a much needed net improvement in air pollution in our area. 2. Consultation The impact of the Silvertown Tunnel on local roads is necessarily uncertain. TfL have assured us that their forecasts show "no negative effects, along Trafalgar Road which is also already congested at peak times (and the same applies to the town centre and Creek Road). But the diversionary effect of tolls on cross-river traffic which now travels free- and in particular diversion to and from the Rotherhithe Tunnel which stays free- cannot be predicted in advance with any confidence. So we welcome TfL's proposals for detailed annual monitoring and the commitment to liaise with the "host boroughs". But borough councils do not always consult adequately with local amenity societies. A wider Community Liaison Group is proposed "for the duration of the works" to deal with construction issues; this should be extended through the monitoring period so that TfL can communicate directly with local amenity societies on data collection and possible mitigation a. We also note that the details of the Community Fund will be decided "through discussions with the relevant local authorities"; we hope the Community Liaison Group will be kept n touch with this. 3. Tolls This is the first occasion (so far as we know) when a toll is proposed on an existing free road. It will also be the only inner London river crossing where tolls re charged. We understand TfL's reasons for proposing a toll (to pay for the Tunnel and to control traffic levels). But locals who regularly drive through the tunnel, and whenever possible outside peak hours (hence without imposing any "cost" on other users) will be differentially penalised by comparison with other users. In our view there should be a discount for local resident account holders, allowing them free off-peak travel which could easily be arranged given automatic charging,"
Non-Statutory Organisations
Hackney Cycling Campaign
"The Hackney Cycling Campaign represents over a thousand residents in Hackney. As part of the London Cycling Campaign we have discussed the proposals for the Silvertown Tunnel at length. Along with Hackney Council we object to the tunnel for a variety of reasons. We believe it will encourage more, not less motor vehicle traffic into Hackney. We believe this increase in motor vehicles will worsen air quality and increase road danger. East Hackney is blighted by very heavy motor traffic from the Blackwall tunnels, and we feel that by adding more capacity to this area, this situation will deteriorate even further. We object to a river crossing that does not cater for cycling at all despite a real need for one. "
Members of the Public/Businesses
Hallam Wiltshire
"I believe (in line with all current evidence) that a new tunnel in this location would have a detrimental effect to Greenwich town as a whole; particularly the main artery into the town Woolwich Road/Trafalgar Road. New roads only serve to increase congestion in the surrounding infrastructure. TfL has not considered alternative projects which could serve the vastly underfunded transport network in Greenwich borough and the south east of London as a whole. TfL has not completed sufficient environmental reports as yet and it is vital that these are fully completed before anything else. No report has been issued into how this (tolled or not) would impact other river crossings, most notably the Rotherhithe tunnel."
Other Statutory Consultees
response has attachments
Historic England
"Dear sir/madam Please find attached Historic England’s comments on the recently consulted Silvertown Tunnel infrastructure scheme. If you have any questions in light of the comments made then please do get back to me. Kind regards Graham "
Members of the Public/Businesses
Huw Nicholls
"I object to the Silvertown Tunnel on the following grounds: - it will increase congestion - increased road traffic will increase pollution levels"
Members of the Public/Businesses
Ian Gibson
"1. New roads generate more traffic. The tunnel won’t make the road network more resilient – it will only increase congestion. This will be an issue for Silvertown Way and the North Woolwich Road, Britannia Way, Wesley Avenue. 2. Road transport is the principal cause of air pollution in over 95% of legally designated “Air Quality Management Areas” in the UK. Current estimates are that over 50,000 deaths a year can be attributed to air pollution in this country. The tunnel will make this issue worse. 3. Researchers have found that UK transport planners are not taking the environmental impacts of transport choices sufficiently into account. Despite pollution contributing between 15 and 30 times the annual number of deaths associated with road traffic accidents (RTAs) (2000-2015), Road Traffic Collisions (RTC) continue to remain the primary concern of transport planners while, at best, air pollution has been designated a “shared priority” between the Department for Environment, Food and Rural Affairs(Defra) and the Department for Transport (DfT). 4. There is a strong social equity issue, with households in poorer areas tending to be exposed to much higher levels of air pollution, whilst contributing much less to the problem, principally through driving less. 5. If a solution to motor traffic needing to cross the Thames is required then a traffic bridge should be built elsewhere as most of the traffic does not want to come to Silvertown at all. It wil be only passing through, heading to other destinations. 6. There is an urgent need for a pedestrian and cycle river crossing between the North Greenwich Peninsula and Canary Wharf. This should be built instead as an environmentally friendly solution. This could be another ferry or a new bridge. 7. The proposed scheme will not support regeneration in the affected areas, as claimed, and will not provide the promised economic and social benefits. 8. TfL has not properly considered alternatives, including new public transport and better management of the existing network. 9. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. 10. TfL has not given adequate information on the environmental impacts of the scheme (its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise and air pollution 11. The environmental impact of better access for HGVs and buses has not been properly considered. 12. TfL has not properly considered the effects of tolling on the wider road network e.g. on routes to the Rotherhithe Tunnel, 13. Tolling will also have a negative impact on local businesses – firms in other parts of London will not have to pay charges to get around. This is discrimkiatory for East Londoners and others wishing to do business and travel in thispoart of London 14. There has been insufficient consultation with communities that will be affected by the proposed scheme."
Members of the Public/Businesses
Isabelle Anderson
"I currently live in Stratford, Newham but grew up in West Silvertown, close to the proposed northern entry/exit point of the Silvertown Tunnel. My family still live in West Silvertown and I visit the area regularly on foot, by bike and on public transport. I would like to register as an objector to the Silvertown Tunnel. I object to this project for the following reasons: - There will be a significant increase in overall traffic volume. TfL deny this and yet their own projections show huge increases in traffic throughout the borough of Newham and in neighbouring boroughs. TfL expect an increase in traffic of over fifty percent on major roads closest to the tunnel. Research demonstrates that new roads create new traffic through the phenomenon of "induced demand". - Greater traffic volumes will lead to an unacceptable increase in air pollution. Newham already suffers from poor air quality that regularly breaches legal limits. The borough also has high levels of deprivation and poor health outcomes with above average rates of illnesses such as asthma and chronic obstructive pulmonary disease (COPD). TfL has not provided adequate information regarding the impact of the scheme on air quality either locally nor on London as a whole. West Silvertown already suffers from high dust levels and this will be worsened by another construction project. - There is inadequate mitigation for noise pollution that would be generated during and after construction. Residents in West Silvertown are already blighted by noise from roads, airplanes and industry. This will worsen if the tunnel is constructed. - Alternatives such as a pedestrian/cycle bridge and new public transport provision have not been considered. Around half of households in both Newham and the Royal Docks do not have access to a car, so will derive no benefit whatsoever from the tunnel. Currently the only cost-free way to cross the river is by using the Woolwich Ferry. The ferry is a two mile walk from my family's home and the total journey time including river crossing is about an hour. The alternative is paying to use public transport or the extortionately priced "Emirates Air Line". Residents in this economically deprived part of Newham should be able to cross the river free of charge. - The Silvertown Tunnel will not provide any economic or social benefits to people living in Newham. The tunnel will not support regeneration in the Royal Docks and will instead lower quality of life and cause streets and public spaces in the area to become less liveable. "
Members of the Public/Businesses
Jacqueline Smith
"The Silvertown Tunnel will not decrease the volume of idling traffic in the approach roads to the Blackwall Tunnels and the Silvertown Tunnel, only increase the traffic volume in each direction. There will still be massive bottlenecks form the various road networks flowing into the approach roads to these two Tunnels. The air quality in East Greenwich has far exceeded European and UK Safety Levels for decades, yet this factor even does not deter planners and local authorities and Governments from planning yet more projects that will only increase traffic levels in the area, and thus cause yet more and higher toxic air quality here. During the period when my daughters were at Meridian Primary school in East Greenwich 1989-1995 the bad air quality in East Greenwich was measured extensively (as the power station nearby wished to expand its power production in order to sell-off surplus to requirements on the National Grid - previously the power station had supplied back-up power to the London Underground lighting systems), but the results on the air-quality measured were revealed to show the worse childhood asthma rates for the whole country. On these grounds permission to expand the power station's capacity were denied. The air quality in East Greenwich, under certain weather conditions is a highly toxic make-up due to the fact that the air cannot disperse due to the steep rise of the land there. The East Thames corridor is known to be thus highly toxic under certain prevailing weather conditions. The building of another motorway tunnel at East Greenwich will only create higher toxicity of fumes and air quality as more and more vehicles head for the river crossing, and bottleneck in the approach sections. When one of the Blackwall Tunnels has to close, the entire South Circular road network grinds to a halt. You wouldn't know the chaos unless you lived in the surrounding areas and witnessed the chaos. It is not at all sensible or ethically right to condemn East Greenwich to even more vehicular traffic. Also in east Greenwich, two other epic projects are also planned, both of which will also create worsening air quality here, these are the Deep Terminal Cruise Liner at Enderby Wharf, and an IKEA store at the Greenwich peninsular. IKEA will create a massive traffic increase despite IKEA's statement that most customers will come by public transport! The Cruise ships also will create more toxic fumes. I am totally against any more projects that will increase toxicity in an already over-polluted air-quality area as East Greenwich."
Members of the Public/Businesses
James Clay Harris
"I live close to the Blackwall Tunnel southern approach. It takes about 3 minutes to walk from my front door to the eastern end of the Bramshot Avenue/Siebert Road pedestrian underpass. From my garden, I am in constant earshot of traffic noise on the motorway. In the 37 years I have lived in Charlton, I have seen the traffic increase on the motorway, with congestion especially at rush hours, although that has become a flexible concept. Even worse than the motorway congestion, however, is the increase in traffic on local roads, especially Trafalgar Road/Woolwich Road between Greenwich and Woolwich town centres, and the whole Greenwich Peninsula development. Development in the area has been allowed to proceed without due consideration to the effect on traffic, and the planned IKEA on the former Sainsbury's site will only make things worse. Although i have a driving licence, I choose not to own a car and rely entirely on public transport - mainly buses - and Shanks's pony in my daily life. Rigorous air monitoring both by councils and by local amenity and campaigning groups in wide catchment areas on both sides of the river has shown pollution levels far in excess of recommended standards. Several primary schools are close to the tunnel approaches and directly affected local roads. Building the Silvertown Tunnel would only increase the volume of road traffic passing through, and the congestion in the surrounding area. The fact that new roads *create* traffic has not been in dispute for decades. We who live near the tunnel approach would get no benefit from a new tunnel and the pollution and local congestion it would cause. There have to be better transport solutions to replace, rather than increase, road traffic. Thank you. "
Members of the Public/Businesses
Jo Lawbuary
"My representation is very simple: new roads (far from relieving congestion -which is usually the premise on which they are built) create new traffic. This is now well-studied and well-understood. More here: http://www.bettertransport.org.uk/roads-nowhere/induced-traffic Therefore, there needs to be new and fresh approaches about how to deal with traffic congestion in London. Also: With Climate change beginning to affect us all, we need to find ways of being more efficient with fossil fuels - so improved connectivity for mass transit must be a priority. Existing high traffic levels (+ congestion) in the borough of Greenwich -particularly around east Greenwich (near where the Silvertown tunnel would exit) has contributed to significant air pollution and breaches in nitrogen dioxide levels, beyond 'safe' thresholds according to EU and World Health Authority guidelines (40 microgrammes per metre cubed). Though some academics working in the field of public health, such as Dr Ian Mudway of King's College, London, posit that there is no safe level of NO2 exposure regarding human health. His work on the effects of air pollution on children is particularly shocking -see here: http://www.thesundaytimes.co.uk/sto/news/uk_news/cleanaircampaign/article1624208.ece Finally, today an academic study highlights that in the pursuit of economic growth, consideration of the environmental impacts of transport planning was increasing air pollution: Dr Tim Chatterton + Professor Graham Parkhurst, from the University of the West of England, said their work concluded that UK transport planners were not taking the environmental impacts of transport choices sufficiently into account. As a result, our air is getting more toxic: https://www.theguardian.com/environment/2016/aug/30/uk-air-quality-shows-little-improvement-past-20-years-says-study?CMP=share_btn_tw With almost 10,000 early deaths a year in London due to our ever more toxic air, we need to face up to this situation and understand it for what it is: a public health disaster. That means planning for a world changed by a warming climate and where the burning of fossil fuels needs to be wound down. It means doing more with less, and finding alternatives to our present car-based transport in London, because it's also making us all ill and killing us early. That must mean no to the Silvertown Tunnel. "
Members of the Public/Businesses
John Rastall
"As has been proved time and again more roads will bring more traffic to the area, resulting in more pollution and blocking of more roads in the area. This area is badly affected by air pollution as it is and this will only add to the damage to the health and wellbeing of people living and working in the area. I believe that sufficient studies of this cannot have be carried out, as that would have shown that the only logical option, if more transport was need, was for this to be more public transport links. Tolling will have a negative effect on businesses already in the area and deter any further regeneration of the area and is likely to lead to more build up of traffic in the area."
Members of the Public/Businesses
Kenneth Law
"I oppose to Silvertown tunnel due to the following concerns: 1) increase congestion in surrounding roads of Canary Wharf, Blackwall and Poplar, as it will attracts more vehicles with 2 crossings; 2) increase air pollution to the local area due to increase traffic, local school and residential area already highly polluted. 3) disruption to local traffic during the construction period 4) question about the toll charges; if Blackwall tunnel not toll, will not decrease traffic to Blackwall tunnel, but rather add more traffic to the local area for cars using the Silvertown tunnel. 5) Silvertown tunnel too close to Blackwall tunnel "
Members of the Public/Businesses
L. James
"TFL have done a poor job of consulting, if I didn't have the Internet - would have not been able to object (- only found out today is the last day to resister an objection!). Many of my neighbours do not use the Internet, or know about this! TFL has not properly considered alternatives, including new public transport and better management of the existing network. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. TfL hasn’t given adequate information on the environmental impacts of the scheme (for example, its air quality assessments are still preliminary ones). There isn’t adequate mitigation for noise pollution (you might like to name affected areas). The environmental impact of better access for HGVs and buses has not been properly considered. TfL has not properly considered the effects of tolling on the wider road network (for example, on routes to the Rotherhithe Tunnel, which would remain free, though you may also have other examples). A serous re think and better standard of 'fully engaged community' consultation is required! "
Local Authorities
London Borough of Hackney
"We would like to note that whilst London Borough of Hackney is supportive of improved transport connections in east London across the river Thames, we have however objected to the Silvertown Tunnel proposal as it is currently constituted for the following reasons: (a) Serious concerns about the risk of increased motor traffic on approach roads to the tunnel in Hackney if tunnel tolls are set inappropriately low; fail to be properly inflation-proofed or are not adjusted to manage demand for the tunnels higher than the Assessed Case. (b) Uncertain benefit to local public transport users. Lack of benefit to cyclists and pedestrians. Highways The proposal envisages tolling at the tunnel to act as a travel demand measure. However once the capital cost of the tunnel is paid off, this method of controlling traffic will be highly vulnerable to political pressures to reduce tolls with a consequent additional increases in traffic on Hackney’s roads especially in the East of the borough around Homerton, Cassland Road, Well Street and Victoria Park Road with a negative impact on air quality, vehicular speeds, community severance and highway safety. We note that • The 2021 Reference case for traffic on the A12 north of the Bow Roundabout shows little change in traffic levels without the new tunnel reflecting the fact that traffic through the Blackwall Tunnel is currently capacity-constrained. (TA, p 159, Figs 5-7, 5-8 and 5-9) • The Assessed Case for 2021 with the new Silvertown Tunnel and tolls on both the Silvertown and Blackwall tunnels shows an overall slight reduction in river crossings in the Blackwall and Silvertown area in the context of unchanged total daily flows summed across all river crossings in the Eastern Sub Region (TA, pp 231-2, Figs 7-2 and 7-3) • That the increased flows on the A12 in the PM peak in the Assessed Case are due to the elimination of the queue in southbound traffic and are balanced by lower traffic flows during the rest of the day (TA, pp 238-9, Figs 7-7 and 7-8) • While the scheme reduces junction delay in the immediate area of the tunnel in the peak period, these increased flows do result in small but potentially significant increases in junction delay where this increased traffic reaches the local Hackney road network. (TA, p 262, Figs 5-26 and 5-28) • Without the use of appropriate tolls the scheme will lead to an unacceptable increase in traffic on approach roads which would be detrimental to Hackney. The level of tolling needs to set at an appropriate level to prevent this and needs to strongly inflation-proofed and able to be adjusted if demand for the tunnel is unexpectedly high. There is no assurance in the scheme that this will happen and there are bound to be political pressures to make sure that toll increases are restricted or even reversed. There is a precedent for this in the way that the congestion relief provided by the central London Congestion charge has eroded since it was introduced in 2003. • The 100% discount for low-emission vehicles using the tunnel although desirable from an air quality point of view has the potential in time to erode the travel demand management aspect of the tolling as more and more vehicles qualify for the discount. Future use of tunnel by taxis, private hire vehicles and Blue Badge holders will also need to be monitored as all currently have a 100% discount. • There is also a reference in the Charging Policy document (CP p16 para 2.4.3) that overall, in setting and varying the user charges, TfL will seek to manage traffic demand at the Blackwall and Silvertown Tunnels to a level that ensures network capacity is not exceeded, and that displacement to alternative crossing routes is minimised.” There is a potential conflict between limiting the traffic impact on the network to the extent outlined in the ES and not raising the charges on the crossings to cause displacement to alternative crossing routes. Here there is a worrying reference here to the managing to ‘network capacity’ rather than to meeting acceptable traffic and environmental limits. Uncertain Benefit to PT and Lack of Benefit to Pedestrians and Cyclists Hackney residents reliant on public transport will not benefit from direct bus services through the tunnel. New bus routes enabled by the tunnel north of the river will reach no further than the Royal Docks. In addition none of the existing buses making use of the tunnel (which might benefit from increased frequencies) go as far as Hackney with Stratford being the most northerly destination served. The bus services planned for the new tunnel (TA p 284, Figure 7-47) are only indicative and reassurances are needed if the promised increase in bus modal share through the tunnels from the 10% to 30% in the Assessed Case (TA p288, Fig 7-49) are to be realised. This is especially true given the current funding constraints on TfL bus services. The proposal represents a missed opportunity to improve cross-river connectivity for cyclists and pedestrians both of whom will be prevented from using the tunnel. In particular banning cyclists from the tunnel means that the only way to legally cycle across the river downstream of Tower Bridge will continue to be through the Rotherhithe tunnel which has critical air quality issues for cyclists. The tunnel’s pricing mechanisms will effectively penalise cyclists. The tunnel not being open to cyclists will force them to use the nearby Emirates Cable Car. An adult single for a cyclist on the Cable Car is £3.40 compared to £1.00 for cars or light vans using the tunnels (off-peak) (£3 in peak). It should be noted that carrying bicycles on the DLR is also prohibited during peak periods. "
Local Authorities
London Borough of Tower Hamlets
"Tower Hamlets Council recognises that action is required to deal with traffic congestion at the Blackwall Tunnel and to minimise the resulting adverse environmental and economic impacts. The congestion and resulting delays impact both on people living and working in the borough as well as local and national businesses. Local roads suffer adverse environmental impacts of noise and air pollution from traffic seeking to avoid the congestion. The Council therefore recognises the potential of the additional capacity provided by the proposed Silvertown Tunnel accompanied by user charging to ameliorate these issues. The borough has very varied socio economic profile. The gap between pay for the top and bottom 20% of earners in Tower Hamlets is the highest in London. Canary Wharf and the adjacent parts of the Isle of Dogs function as an international financial centre generating over 100,000 jobs, many of which are highly paid. Elsewhere in the borough employment is concentrated in small businesses operating in the service sector. The Council’s strategy in respect to the proposed Silvertown Tunnel is thus to minimise adverse environmental and economic impacts on borough residents, whilst seeking to maintain economic activity for both low and high income employees working in the borough. No objections are raised to the design proposals for the tunnel and associated buildings and the Council welcomes the commitment to provide a dedicated bus, coach and HGV lane in the new tunnel. The council welcomes Transport for London’s objectives as set out in the Charging Strategy to minimise induced traffic whilst reducing delays and congestions to road traffic crossing the Thames. Whilst the Transport Assessment (TA) indicates that these objectives can be met with an appropriate charging scheme, the traffic model forecasting may not be entirely accurate and therefore the council welcomes the proposals for monitoring and mitigation set out in Monitoring Strategy. The proposals for the Silvertown Tunnel Implementation Group (STIG) as described in Article 65 of the DCO are an essential and fundamental mechanism for taking action to deal with the outcomes of the Monitoring Strategy The Council has a number of additional concerns that need to be addressed: • Improved public transport bus services, although fundamental to the TA, are not guaranteed; • Further consideration and discussion should take place concerning a discount on the charge being made available for borough residents; • Although cycling is recognised by TfL as being a growing mode of transport, proposals for improving cross river provision are not part of the DCO; • The Monitoring Strategy requires greater detail on socio economic monitoring methods; • The implementation of any necessary traffic mitigation measure will require TfL funding - it is not clear what priority it will have in the light of future budgetary constraints; • The membership and operating arrangements of the STIG need refining • STIG should continue in operation up to 5 years after scheme opening unless otherwise agreed by STIG members; • Although not a Relevant Planning Authority, LBTH should be consulted on all applications for the discharge of Requirements. "
Other Statutory Consultees
response has attachments
Marine Management Organisation on behalf of Marine Management Organisation
"Sent by email."
Members of the Public/Businesses
Michael Jemmeson
"I would like to register as an objector to the Silvertown Tunnel. The points that I would like to make include: The tunnel will induce demand and consequently not relieve congestion on local road networks. The resulting increased traffic will worsen local air and noise pollution. Alternatives such as improving public transport (for example an Overground rail link between Barking and Thamesmead) have not been adequately considered, when this would benefit areas south of the river in need of regeneration by making a connection with the rest of the Overground and Underground networks for commuting. The risks to the Maritime Greenwich World Heritage Site from traffic congestion have not been properly considered. "
Other Statutory Consultees
National Grid
"Representation by National Grid Electricity Transmission Plc (NGET) and National Grid Gas Plc (NGG) (together ‘National Grid’) to the Silvertown Tunnel Scheme (Reference TR010021) National Grid wishes to make a relevant representation to the Silvertown Tunnel Order to protect its position in light of apparatus, land and any other equipment not already identified which is within or in close proximity to the proposed DCO boundary. National Grid’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the order limits should be maintained at all times and access to inspect such apparatus must not be restricted. The documentation and plans submitted for the scheme have been reviewed in relation to impacts on National Grid’s existing apparatus, and it has been identified that appropriate protective provisions will be required to be included within the DCO to ensure that National Grid’s apparatus and land interests are adequately protected and to include compliance with National Grid’s relevant safety standards. National Grid is currently in discussion with the promoter in order to secure appropriate protective provisions. National Grid has the following assets and interests located within or in close proximity to the order limits: Electricity Transmission: ZR 400kV Overhead Transmission Line – Barking-West Ham, which forms part of the national electricity transmission network. Gas Distribution: High or Intermediate pressure (above 2 bar) Gas Pipelines and associated equipment; and Low or Medium pressure (below 2 bar) gas pipes and associated equipment, both of which form part of the gas distribution network. Above ground gas sites and equipment has also been identified as being located within or in close proximity to the order limits. National Grid will continue to liaise with the promoter to agree an appropriate form of protective provisions for inclusion within the DCO. As a responsible statutory undertaker, National Grid’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations including its health and safety obligations. National Grid reserves the right to make further representations as part of the examination process but in the meantime will continue negotiations with the promoter with a view to reaching a satisfactory agreement. "
Non-Statutory Organisations
Newham Friends of the Earth on behalf of Newham Friends of the Earth
"I am opposed to the proposed Silvertown Tunnel because of resulting increase in road traffic in the already traffic congested Borough of Newham. Pollution from cars is already a threat to the health of local residents. Francis Bassett Resident Manor Park London E12 6SS and Convenor Newham Friends of the Earth Group "
Non-Statutory Organisations
Newham Green Party
"I'm writing as a resident of Newham for most of my life, and as a member of the Newham Green Party. We've held meetings with other members and also an open meeting with residents in the area near the proposed site. Our collective concerns include: - increased air pollution - so close to LCY airport, the area already suffers from awful - ILLEGAL - levels of air and noise pollution. It seems immoral to expand the airport and simultaneously create a tunnel and more road users in the same borough. With no mention of carbon offsetting or messages to reduce the environmental impacts. Studies show bridges are better than tunnels for dispersal of air pollutants. While we'd rather there were no additional pollution being created, a bridge is by far the lesser evil - and something almost all of the local residents we spoke to would prefer. - increased traffic congestion and issues of road safety - will the network be able to support the additional traffic created? Will our roads be safe for cyclists and pedestrians? - pedestrian and cyclists access/provision - environmental impacts during construction (both on the environment generally, and for local residents - yet more noise and air pollution from construction, etc.) - impacts on/lack of benefits for local small businesses and residents - years of construction in the area have already taken a toll, the projected additional construction, and the increase in through traffic once the tunnel is completed will make it harder for locals to get around and use existing small businesses and local services - tolls to use the tunnels - where is that money going, and why hasn't the toll been introduced at Blackwall for a test of concept? - Why are only East Londoners facing charges for new and existing river crossings? We've always been at a disadvantage to West London for river crossings, and the ones we get are all tunnels, now they'll all be tolled tunnels! We want more crossings, but ones that work for everyone in the local community, not just commuters coming in from outside London - we'd prefer a bridge to a tunnel. Our understanding of the project to date suggests that this concept has been investigated thoroughly. The foot/cycle bridge closer to the city is popular with locals, they'd like something similar included in this plan. Not all of us in Royal Docks have (or want/need/can afford!) cars! In fact, only half of households in Newham have access to a car, the projected tunnel offers nothing to us but additional health problems and inconvenience! - discrepancies between size needed for stated use and actual size of tunnel on plans is worrying - we already allow lorries bigger than other countries in the EU, to reduce carbon emissions we should be planning for smaller, cleaner transit options - Financially wasteful - pointlessly wide tunnels, with vast cross-tunnels. Seems far bigger than necessary. Bigger structures = more materials used. Money could be used more effectively."
Members of the Public/Businesses
Nina Parmar
"I am a local resident and live close to the Newham side of the tunnel. I object based on the increased noise, pollution and traffic in the area. The roads near canning town are already very congested. Pollution is already increasing due to the expansion of city airport this will add further to it. Also, I object to having to pay to cross both tunnels, at the moment it is free and this doesn't increase freedom of moment rather penalise people who have no choice but to cross. It may also result in increased traffic to the other free crossing already on the Thames."
Members of the Public/Businesses
Olawale Ajibola
"The Silvertown Tunnel will induce new traffic - the tunnel and approach roads will add to the high pollution, congestion and blight in some of London’s most densely populated eastern neighbourhoods (e.g. Greenwich, Silvertown and Canning Town). The Silvertown Tunnel has no major public transport benefits - no new London Underground, rail or Dockland Light Railway connections except for some additional bus routes. The Silvertown Tunnel has no provision for cycling traffic despite the massive growth in cycling as a mode of transport in London recently and increased potential cycling traffic growth between the east London and south eastern London neighbourhoods. The Silvertown Tunnel construction process, including removal of spoil, will be hugely disruptive in terms of high HGV movements, dust and noise pollution in an area already full of construction projects e.g. the recently approved expansion of the London City Airport in the nearby Royal Docks area."
Members of the Public/Businesses
Paul Speller
"New roads have been proven by studies time and again to generate new traffic. Building a new road such as the Silvertown Tunnel will not relieve congestion; in fact it will increase congestion on approach roads such as the A2 near my part of London, and by increasing traffic will increase pollution emitted into already toxic air, which regularly breaches EU pollution limits, that I have to breathe daily. This tunnel will shorten my life and thousands of other Londoners' lives if it goes ahead. If we want to improve connectivity across the river, we should invest the money set aside for this project in new public transport links such as an Overground link across to Thamesmead and Abbey Wood from Barking. And if we want to reduce pollution and congestion, we need to reduce traffic on the roads, which means finding new ways to get people out of their cars and onto public transport. There's no reason additional bus routes couldn't be run through the Blackwall Tunnel, as well as the 108, especially if proper bus priority measures were put in place to ensure smooth passage across the river in both directions for this bus. The Silvertown Tunnel is not needed and will do far more harm than good. Please do not permit this to go ahead. Thank you."
Members of the Public/Businesses
Philip Tyler
"As a local resident the proposed new road tunnel will have a negative impact on my family and our health. It will increase traffic and associated pollution. Traffic is already untenable in rush hours around the tunnel approach - especially blackwall lane with both 422 and 188 busses often caught in traffic. TFL has not sufficiently considered alternative options that provide public transport options. London needs to be a forward thinking city, road infrastructure was for the 20th century. SE London needs significant investment in public transport to reduce road traffic, not encourage more. Tolling of the existing crossing should be considered first as a trial run to see impacts on the local road network before ploughing millions into a potentially unnecessary piece of infrastructure. More crossings are needed in East London - but road crossings should be lower down on the priority list."
Members of the Public/Businesses
Purnendu Roy
"As a local resident for 26 years in Greenwich I would like to register my objection to the Silvertown tunnel. It been my experience that increasing road capacity results in the long run to create traffic and congestion and therefore this will not increase road resilence as Tfl claims. This evidently can be seen how despite increasing the number of lanes at the Blackwall tunnel, Dartford tunnel,QE2 bridge congestion has got worse, rather then better. What is needed is solutions to reduce car use and tfl has not adequately addressed this. The scheme will not assists businesses in local areas such as Plumstead where I reside and I believe that the extra traffic that will be generated through it creation will already add to already high levels of pollution that exists in the borough of Greenwich which will will result in increase number pollution related deaths. I do not feel I been consulted properly over this scheme."
Members of the Public/Businesses
Winckworth Sherwood LLP on behalf of Quintain Limited
"Initial Representations on the Silvertown Tunnel (“the Scheme”) 1. Quintain’s Interest Quintain has ownership interests in the Carlsberg and Tetley Wharf Site (‘the Site’). Plans for the Scheme show the entirety of the Site being compulsorily acquired temporarily or permanently for construction and/or its subsequent operation. The Site is strategically important for the future development of the area. It is currently allocated for employment, in the emerging Royal Docks and Beckton Riverside Draft Opportunity Area Planning Framework for residential and recognised in TFL’s Planning Policy Compliance Statement for housing and mixed use. Quintain does not object to the construction of the Tunnel beneath the Site. It objects to the terms of the DCO for the Site. 2. Principal Grounds Contrary to the requirements of s122(c) Planning Act 2008 and the DCO Guidance TFL has failed to demonstrate that: (a) the acquisition of/interference with the Site is required for the Scheme’s construction; (b) all reasonable alternatives have been explored; (c) the interference with Quintain’s rights is for a legitimate purpose, necessary and proportionate; (d) there is a clear idea of how the Site is to be used; and (e) there is a compelling case in the public interest for acquisition/interference. Further, TFL’s Environmental Statement (‘ES’) contravenes the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (‘EIA Regulations’). 2.1 Construction and Design The Scheme will hamper the development of the Site. Not merely by sterilising the Site for a number of years (during construction) but also by impeding the area which may be developed. The land-take of the scheme is excessive. Quintain will highlight the unnecessary: (a) location of the TBM Chamber which will prevent the development of the Site for many years; (b) extent of the areas claimed to be required for construction of the TBM Chamber; and (c) extent of areas claimed to be for associated infrastructure. TFL has also failed to consider the impact of the operation of the tunnel on the future development of the Site. This includes the need for building above the tunnels and the impact of the tunnels’ operation (particularly with regards to noise and access) on the future use of the Site. Quintain will refer to alternative schemes (unconsidered by TFL) to enable swifter simultaneous housing/employment delivery during construction and maximise the development potential of the Site. 2.2 Contents of the ES The requirements of the EIA Regulations have not been met. The ES has failed to adequately identify and assess: (a) the environmental effects in the absence of basic details about the Scheme and has unlawfully stated that mitigation measures are to be determined at a later date; (b) alternative options to minimise the impact upon the Site; (c) the noise and air quality impacts of the Scheme, in particular in relation to the Site; (d) transport impacts and include a detailed transport mitigation strategy; and (e) the cumulative impacts of the Scheme. 3. Conclusion The accumulation of the above matters means that there is no compelling case in the public interest for the CPO of the Site. "
Members of the Public/Businesses
R.J.Allard
"1. Prior to the construction of any new east London river crossing there should be a comprehensive review as to what combination of possible crossings (and what charging structure) would most effectively reduce current levels of congestion, whilst also reducing the current disadvantage of residents and businesses in SE London. 2. The current plan to set and, if necessary, vary the level of tolls on the Silvertown/Blackwall crossings to avoid any increase in traffic levels, needs to be backed by a commitment which is strong enough to effectively prevent any subsequent decision to change this policy and reduce charges. 3. To be fully effective, any river crossing tolls need to be part of a wider system of road user charging."
Members of the Public/Businesses
JLL on behalf of Railway Pension Nominees Ltd
"On behalf of our client, Railway Pension Nominees Ltd (‘Railway PN’), JLL wishes to register Railway PN as an Interested Party in relation to the proposed Silvertown Tunnel. Railway PN own the City Cross Business Park located off Tunnel Avenue in North Greenwich (SE10 0AT). Railway PN welcomes transport improvements which support and improve the resilience of east London’s road network, particularly in relation to the Blackwall Tunnel. We agree that transport improvements are needed in order to support economic and population growth across the wider east London area, and support the principle of providing additional cross-river links. City Cross Business Park will not be directly affected by the Silvertown Tunnel works, in so much as its site is not included within the proposed construction area; however, the area proposed for construction works stops just shy of City Cross’ northern boundary and some works to the A102, including the proposed replacement pedestrian and cycle bridge, will take place very close to Railway PN’s site. a) Impact of the scheme on the local environment, including traffic congestion, air quality and noise We will: • Highlight the desire for regeneration to take place locally, drawing on adopted and emerging planning policy including the London Plan (2016), LB Newham’s Core Strategy (2012) and the emerging Opportunity Area Planning Framework, as well as the Greenwich Peninsula Masterplan. • We will draw attention to the current absence of site specific business analysis within the supporting documentation, including the Regeneration and Development Impact Assessment, Social Impacts Appraisal, Distributional Impacts Appraisal, Transport Assessment and traffic regulation measures plans. Technical evidence will be provided as needed. • Query the appropriateness of leaving responsibility for producing an Air Quality Management Strategy and Construction Management Plan to the appointed contractor, without pre-testing potential impacts on a site-specific basis. • Draw on technical expertise to demonstrate impacts by way of traffic, air quality, noise (etc). • Interrogate TfL’s supporting documentation, including findings that more residents will experience an increase in noise levels than will experience a reduction. • Request that Railway PN be party to the production of both the Air Quality Management Plan and Construction Management Plan. b) User charging We will respond to TfL’s proposed approach to user charging, and its general assessment of the impact, which focuses primarily on local residents. In so doing we will demonstrate the impact on the City Cross site in terms of business operations and also employees. c) Monitoring We will consider TfL’s proposed strategy for mitigating adverse local traffic impacts, and the proposed monitoring timescales. Contrary to TfL’s proposed reactive approach, we will request a proactive approach, routed in detailed analysis and will draw on technical expertise as needed. Railway PN reserves the right to add to the submissions in response to any other matters that may arise. "
Members of the Public/Businesses
Richard Green
"With no new roads around either side of the tunnel this tunnel will force more traffic onto already badly planned roads. The Greenwich Peninsula is already going through major changes with developers not taking into account their effect on local traffic issues. With the ocean liner terminal and ikea to name a few they will encourage more traffic into the local area causing major traffic issues. There has not been any decent public transport options considered in this consolation, the Jubilee line is already over capacitated."
Members of the Public/Businesses
RRS London Waste Paper Ltd
"Our business operates from the same yard as the Evening Standard on Millenium Way, Greenwich and believe TFL require the site. Therefore we need to be informed of TFL's plans for this area that may affect our business."
Members of the Public/Businesses
Ruth Cracknell
"As a local resident of over 25 years I am very concerned that this project will add to the already terribly bad levels of air quality in Greenwich and do nothing to reduce the overall numbers of vehicles on the roads in Greenwich. I am concerned about the negative impact on health. "
Members of the Public/Businesses
Samantha White
"Extra traffic brought into the area by the new tunnel will exacerbate the existing pollution problems in SE10, already far in excess of legal limits. This has a negative impact on the health and wellbeing of residents with respiratory illnesses. Congestion along the main routes in SE10, such as Blackwall Lane, Woolwich Road and Trafalgar Road is already unacceptable, causing delays to bus journeys. Improving public transport links to encourage fewer people to depend on cars would benefit a much wider section of the population than a tunnel scheme. Risks to the Maritime Greenwich World Heritage Site have not been properly considered. There has been insufficient consultation with communities that will be affected by the scheme and rigorous environmental and noise impact studies have not yet been conducted. "
Members of the Public/Businesses
Sian Berry
"I object to this application. I believe that the building of a new road tunnel in this location will: a) increase traffic across a wide area by encouraging more travel by car and more trips over both long and short distances b) increase congestion at pinch points across a wide area c) increase air pollution, which is already above legal limits in the area affected d) increase noise pollution d) do nothing to achieve objectives of economic development in London, in particular i the area near the new road tunnel e) not achieve any objectives to reduce travel by car, or to increase the quality or attractiveness of travelling by foot, bike or public transport I believe the case for this project is not sound, either economically, socially or environmentally and that it does not represent a good use of public money. Tolling options have not been properly considered. These plans are likely to either not succeed in reducing the environmental impact of the plans or have negative effects on other crossings nearby. The local community has not been properly consulted on these plans - presentations have conflated the Silvertown Tunnel with other crossing plans in order to minimise opposition during the development stages. Many people in the local area are opposed. There are many alternative options for investment to reduce congestion and increase resilience on the road network in this area, and these have not been properly evaluated or presented in consultations. These plans should be rejected and alternatives to improve walking, cycling and public transport services in the area explored instead."
Members of the Public/Businesses
Simon Hopper
"The proposed tunnel will induce new traffic journeys and will not reduce congestion in the local area or London as a whole. In particular, by increasing traffic from and onto the A102 in Greenwich it may increase congestion. Increased traffic and congestion will lead to further increases in air and noise pollution along with road danger. TfL have not adequately considered alternatives to the tunnel - better management of the existing road network along with river crossings for public transport and walking/cycling. Overall, I am opposed to the proposed tunnel and that it should not go ahead."
Members of the Public/Businesses
Simon Short
"As a resident near to the A102 blackwall tunnel approach I can't stand by and watch a development happen that will significantly add to traffic congestion and pollution in the area. I live in a n area that has a high population of families and young children, there a reason several schools close by including nurseries for very young children. Their health will be irreparably damaged by the addition of another significant source of traffic to this already congested carriageway. Please do not approve the Silvertown Tunnel and instead look at ways of diverting traffic to alternative routes in the south east of the Thames. "
Members of the Public/Businesses
Tim Castro
"I am a resident of Mauritius Road. My son attends Millennium Primary school. I believe the Silvertown Tunnel scheme will have a negative impact on where we live. New roads generate more traffic. This will only increase congestion on Blackwall Lane and the Trafalgar Road. Getting around the local area in a car or on a bus will become more difficult. My son travels to school along Blackwall Lane and this is already badly polluted. The air quality assessments for this project are still preliminary so there isn't enough information to assess the environmental impact of the extra traffic. Traffic on Tunnel Approach can be heard from our house 24 hours a day. There isn’t adequate mitigation for noise pollution from the extra traffic. The scheme will not support regeneration in East Greenwich and local residents will not see the promised economic and social benefits. TfL has not properly considered new cross river public transport. The environmental impact of better access for HGVs and buses has not been properly considered. The inadequate consultation with the local community has focused on attempts to convince us of the benefits as opposed to listening to concerns. "
Members of the Public/Businesses
Vijay Pankhania
"I am a local resident and live close to the Newham side of the tunnel. I object based on the increased noise, pollution and traffic in the area. The roads near canning town are already very congested. Pollution is already increasing due to the expansion of city airport this will add further to it. Also, I object to having to pay to cross both tunnels, at the moment it is free and this doesn't increase freedom of moment rather penalise people who have no choice but to cross. It may also result in increased traffic to the other free crossing already on the Thames. "
Non-Statutory Organisations
Westcombe Society Environment Committee
"The Westcombe Society is a fully independent local amenity society, bounded by Greenwich Park, the South-Eastern rail line, the A102, and Shooter’s Hill Road. It was set up in 1973, and among its activities it publishes a monthly newsletter distributed to all residents, and monitors planning and environmental concerns to protect and improve the area. It has held two public meetings to discuss the Silvertown Tunnel proposals, and found that residents broadly oppose the plans. We have incorporated considerations raised at those meetings in the comments below, and have published these views in the Westcombe News, with no negative response. Our concerns: • We are well aware of the congestion on the approaches to the Blackwall Tunnel but despite assurances by TfL we are not convinced that traffic levels on the route itself will be effectively restricted if the Silvertown Tunnel is built. • We believe that the Silvertown Tunnel should be considered in the full context of potential new East London river crossings, and this consideration is lacking in the application. TfL should be looking at the most appropriate combinations of new crossings, including additional public transport links and provisions for pedestrians and bicyclists. • We fear that due to differential treatment of the Thames road crossings, there will be increased traffic through the area which the link roads will not be able to deal with. Avoidance of congestion on link roads and/or tolls is likely to lead to increased traffic congestion on local roads and negative impacts on air quality. Clearly demand needs to be managed but any charging of the proposed river crossings should be part of a wider road user charging structure rather than standalone. • We are concerned that making the Silvertown Tunnel large enough to remove the height restriction on north-bound HGVs will draw more of them to the area with impacts on noise, traffic congestion, and air quality. • Many in our area are concerned that the proposed tidal flow for charges will negatively impact on residents and businesses in south east London. • We question whether TfL have a strong enough commitment to prevent any increase on overall traffic using the Blackwall/Silvertown crossings, and that it will be vulnerable to subsequent relaxation because of political pressure. • We believe that TfL could increase the resilience of the Blackwall crossing, reducing the frequency of closures, for instance by more effective controls on over-height vehicles. • We feel that insufficient consideration has been given to reducing overall demand for this crossing which runs through predominantly residential areas. • We are concerned by construction impacts, in particular regarding HGVs using local residential roads to transport waste and building materials. In light of our concerns, bearing in mind that we may find other objections as we read through the full application, the Westcombe Society wishes to register as objectors to the Silvertown Tunnel."