Written evidence submitted by Gravesham Borough Council (SRI0034)

Thank you for setting up this Inquiry. We agree that careful scrutiny is needed over which Road Investment Strategy projects can be delivered, when by, and at what expense to the taxpayer and that we must make sure lessons are learned so that time and money are not wasted in future.

This submission unashamedly focusing on the Lower Thames Crossing. This is the key Road Investment Strategy rounded 2 project and the one that the November 2022 National Audit Office report highlights as causing significant cost inflation concerns.

Gravesham Borough Council represents a Borough on the Thames Estuary with a strong heritage and a willingness to take opportunities as they arise. The Council recognises that they are challenges at the Dartford Crossing and these have gotten worse over recent years. However, we do not think that the decision to build the Lower Thames Crossing to the East of Gravesend is the right one. As National Highways are aware from our representations to the many consultations that have taken place, we consider that most of the traffic going over the crossing relates to the M25 and so expanding capacity in that location is the required solution. We do not consider that has received sufficient consideration and National Highways have just decided it is too difficult. This is a shame as something like a new bridge would have a more defined cost with less unknowns. Such a new bridge could even primarily be for HGVs etc going northwards thereby taking out the need for traffic to be manged to enable vehicles to be accompanied through the tunnels, now that the crossing is free flow i.e. no toll booths. The need to accommodate larger vehicles, has made the proposed Lower Thames Crossing tunnels much bigger. A bridge is not possible in this location.

The Lower Thames Crossing will be considered against the National Policy Statement for National Networks. Paragraph 3.3. of the document expects applicants to avoid and mitigate environmental and social impacts and provide evidence that they have considered reasonable opportunities to deliver environmental and social benefits as part of schemes. The need to avoid impacts is another reason that Dartford should have been more strongly considered is that the site at Dartford does not have the scale of national and international environmental issues that the Lower Thames Crossing does – no Special Protection Areas, Ancient Woodland, Ramsar, heritage, AONB etc.

We are not alone in considering that National Highways jumps too quickly to big capital projects. We noted with interest the National Audit Office Report in 2017 on the original RIS[1] that National Highways should ‘give more consideration to solving issues on the network with improved maintenance and operations’.

This 2017 NAO report also was clear that value for money depended on the Department for Transport and Highways England focusing resources on those projects which offer the best value to taxpayers and road users. It feels like they are going on regardless whereas we feel that they need to stop and see if, with such an excessive cost, the solution on the table is the right one to be taken forward. We note from the 2022 NAO report that as at September 2022, National Highways is monitoring eight projects due to value for money issues, including the Lower Thames Crossing. However as just shown by the project’s submission to the Planning Inspectorate for Examination, it feels like they are going on regardless whereas we feel that they need to stop and see if, with such an excessive cost, the solution on the table is the right one to be taken forward.

We also consider that the unwillingness to address the problems with the Dartford Crossing at Dartford is not delivering the solution wanted by road users which is fixing the problem at source asap. The Dartford Crossing was designed for 135,000 vehicles per day, it is now operating over capacity and is regularly used by over 150,000 vehicles per day. More than 180,000 vehicles use Dartford Crossing on its busiest days and that will be become the standard traffic level in 2041. National Highways portray the proposed Lower Thames Crossing as a solution to the problems suffered due to the Dartford Crossing. However National Highways state the proposed LTC would reduce traffic at the Dartford Crossing by around 20% in opening year (2030), dropping to around 14% by 2044 and that is nowhere near the reduction needed to get the Dartford Crossing back to its capacity level. In addition, Thurrock Council’s analysis of the official National Highways data shows that the proposed new crossing would take as little as 4% of traffic away in the morning peak hour, and 11% in the pm peak hour.

If LTC is approved and can deliver what is promised, it will be years till it is operational and the problems will continue. A multi-faceted approach using technology for clearer enforcement and lane control on the M25 and A282 as well as ensuring true free-flow seems obvious. As local residents, we see poor driving and the overlapping strategic and local traffic flows, as a contributory reason to some of the incidents. These are comparatively simple junctions and we fear that the very complex junctions' arrangements in North Kent and Thurrock, which Thurrock have proven don’t work, will never deliver the predicted scheme benefits as the roads will be highly incident prone. We also fear of the impact that this will have on the Borough’s residents and businesses, especially as the local road modelling is limited and there is no commitment to address issues requiring capital road expenditure on KCC roads during the construction or operational phases.

The Council has been working hard for a number of years on several regeneration projects which will bring forward under-used sites to realise the huge potential that we feel that the Borough has. At the moment, it feels like all that effort will be undermined by the Lower Thames Crossing. The project will add further pressures on the existing dwelling stock and no proposals for additional permanent or temporary stock; a construction phase that is likely to force businesses to close and cause pressures for businesses that remain from congestion and disruption for deliveries, employees and customers; and an environment that will be hostile to a good quality of life for residents and fauna and flora.

In addition, whilst estimated costs for the project are huge they are underestimated because of the way the Road Investment Strategy works. We recognise that the strategic roads are a network (hence the name) and whilst we accept that a line needs to be drawn on a project, it needs to be realistic. The 2017 NAO report recommended that whole sections of the network were looked at rather than indidivual projects.

Originally there was Route C and C variant which included works to Blue Bell Hill, which is one of the busiest roads in the county, to link the M2 and M20. This was not taken forward. The 2016 consultation booklet[2] included the following rationale:

Our assessment has concluded that this upgrade would have limited benefits, high environmental impact and high cost and is not essential as part of a new crossing scheme. We will give further consideration to this link separately as part of Highways England’s ongoing regional route planning.

We don’t accept this and consider that Blue Bell Hill improvements are associated development for LTC rather than a project that National Highways is artificially separating, and that separation means that Kent residents will have to pay 15% of the costs as only 85% will be funded by national Highways. National Highways would not accept this from a private NSIP promoter.

Also because it is not part of the LTC project, there is considerable uncertainty about its delivery as indicated by recent press articles[3] following KCC’s recent announcement setting out the hurdles this needs to go through. KCC in their response to the statutory consultation in 2018 explained why they supported C Variant and the risks:

The traffic modelling shows that the wider network to the east of the new LTC, both local and strategic, will be put under increased pressure as a result of the new Crossing. Unless these roads and junctions receive capacity upgrades to relieve existing congestion and background growth, the induced and transferred traffic resulting from the LTC will constrain economic growth in the county.

The Council is aware that it isn’t just the A229 at risk. The submission documents highlight issues with A228 and we are concerned that there is also a risk for the A227.

A key justification from National Highways for LTC is that it will boost regional economic growth. We think that this is disingenuous. As we explained earlier, whilst we acknowledge the problems at the Dartford Crossing, we don’t think LTC is the solution as the problems are at Dartford. Growth needs Dartford to be dealt with and growth will always be constrained until that is achieved.

And finally the cost - in the 2016 Summary Business Case[4] for the Lower Thames Crossing, the ‘most likely cost estimate’ was £4.3 billion. For the 2018 Statutory Consultation, the revised most likely costs was £6,752m (including portfolio risk) and the revised Open for Traffic date was October 2028. The National Audit Office’s “Road enhancements: progress with the second road investment strategy (2020 to 2025)[5]” now estimates the project will cost up to £9bn to deliver including an increase of nearly £2bn (£1.9 billion) since March 2020. The National Audit Office is clearly concerned about National Highways progressing very expensive projects with low value for money. This is without taking into consideration hidden costs associated with the scheme, such as the impact upon local services, health infrastructure, affordable housing, homelessness, skills and workforce.

We welcome this inquiry and the opportunity to provide some input to that consideration.

February 2023

Endnotes