EGRA's submission to the Silvertown Tunnel Consultation
This has now been sent to the Mayor, TFL, our MP, assembly members, councillors and the council.
The proposed new Silvertown Tunnel will possibly impact more severely on the area of East Greenwich than on many other parts of south east London. For this reason, the East Greenwich Residents Association (EGRA) would respond to the latest pre-consultation to call, above all, for better and more accessible information before the final consultation phase expected in summer 2015.
We believe that South East London including East Greenwich should be better connected to the rest of London. We do, however, remain to be convinced that the £¾ billion investment is best spent on a mode of transport that is in decline over London as a whole. This is especially so when existing public transport links are becoming increasingly congested and even threatened in our area.
We are particularly concerned that:
TfL’s traffic modelling is opaque. Previous evidence suggests that increasing capacity does not necessarily reduce congestion. The evidence of the previous expansion of the Blackwall Tunnel refutes this simplistic argument.
TfL has shown no evidence that their tolling charges would adequately manage demand for the proposed new crossing. Such tolls would we believe divert traffic down Woolwich and Trafalgar roads and may lead to queues in local roads as vehicles wait for lower off-peak tolls.
Furthermore, we are concerned that with the prospect of having to pay tolls on the Blackwall and Dartford tunnels, vehicles will divert through Greenwich Town Centre to the Rotherhithe tunnel and increase traffic on the Woolwich/Trafalgar Roads. There seems to be no plan in place to prevent this.
The case for better public transport in East Greenwich (and SE London as a whole) has not been examined thoroughly. Additional bus routes could use the Blackwall Tunnel now whilst the tunnel costs should be compared to equivalent investments in public transport. There is currently only one bus route going through the tunnel and we believe that there is the demand for further routes to go through the tunnel into east London, going to for example, Hackney, Westfield, Bethnal Green and Columbia market.
Apart from suggesting a widening of the tunnel approach road (seemingly to 8 lanes) and a widened flyover, there are few suggestions to cure “pinch points” further up the road system. Above all there is little said about the impact of increased traffic on the wider local road network. This is already becoming overloaded because of the construction of big traffic generators in East Greenwich and Greenwich Peninsula.
Many residents of East Greenwich are aware of the appalling state of air quality in their area, even if they support further river crossings. The air quality assessment of the proposals, and its comparison with other options, must be of a “gold standard”. The Scoping Opinion by The Planning Inspectorate (July 2014) emphasised this for the Environmental Impact Assessment (EIA) as a whole.
EGRA would therefore ask that the quality of information be better and be better presented in the next round of consultation. We note that the above Scoping Opinion (on the EIA) calls for a good quality “Non Technical Assessment”. We would go further and ask for information on all five points above be sufficiently detailed to really inform but be far more accessible to an interested lay reader.