Written evidence from Gravesham Borough Council (SRC0040)

 

Gravesham Borough covers the towns of Gravesend and Northfleet in Kent (see diagrammatic map at end of document), and the surrounding countryside running south to the crest of the North Downs, on the south bank of the River Thames east of the Dartford Crossing.  It is a Green Belt authority although much of the rural area is also Ramsar/Special Protection Area (North Kent Marshes) or an Area of Outstanding Natural Beauty (North Downs).  East of Gravesend is the point where the Metropolitan Green Belt fully reaches the Thames and divides the Medway Towns from Dartford/Gravesend and London.  The A2 Trunk Road (4 lane dual-carriageway with hard shoulders) runs across the Borough forming the southern edge of the urban area, as does the high speed railway (HS1).  The latter has an international and domestic station at Ebbsfleet located just in Dartford Borough.  This is also a focus for Ebbsfleet Garden City (where an Urban Development Corporation has been proposed), part of which is in Gravesham.  The A2 connects to the M2, and together they provide the strategic highway link across North Kent from the M25 and the Dartford Crossing through to Thanet. Main road access to Channel Tunnel and Dover is via the M20 which runs just south of the Borough.

The Borough Council has played a major role in the Thames Gateway since its inception, creating development and transport strategies for Dartford/Gravesham.  It has also been involved in projects such as HS1 (originally called Channel Tunnel Rail Link), widening and realigning the A2, possible estuary Airports (Cliffe and subsequently Isle of Grain) so is well versed in dealing with major transport projects and their implications.  It is currently dealing with the assessment of the London Paramount Entertainment Resort proposal, on the border with Dartford.  The Local Plan Core Strategy was adopted in September 2014 following examination.

The Dartford Crossing is located 8km west of Gravesend and the Borough Council’s stance on additional crossing capacity is:

The Committee would like to know:

How well does local and national government work together to plan and deliver river crossing projects?

In the Borough Council’s experience working relationships between it and the Department for Transport, the Highways Agency and their consultants have been excellent (as opposed to always agreeing with them).  The issue of concern is more the remit of the studies being undertaken – or to put it another way, what is the question?  There is an obvious congestion issue but there is no meaningful national transport strategy or regional planning context within which to place any proposed solution.  Transport is a means to an end so it is necessary to define what a scheme of this scale is supposed to be achieving in land use, social or economic terms as well as congestion relief.  The environmental impacts are significant in the case of Option C (east of Gravesend).  These are a major constraint since a Habitats Regulation Assessment is required because of the potential impact on SPA/Ramsar (Special Protection Area) where the test is whether there are alternative options – which there are (Option A).  There is danger that the Green Belt is being regarded as a soft touch.

The studies behind the 2013 consultation showed that simply adding to crossing capacity does not transform the overall position because of congestion elsewhere on the network.  As with most of the rest of the south east, most strategic roads are at or near capacity at peak times.  Resilience is often talked about but experience in Kent is that if a major road link is blocked for some reason the resulting congestion means that the rest of the network rapidly seizes up.  A major accident on the M20 or A2/M2 in West Kent rapidly causes major congestion on the other route.  Another example is impact of the Operation Stack on Mid and East Kent.  A new crossing would suffer from the same problem – fine in theory not a great deal of use in practice.

 

What knowledge, resources and experience does the public sector need to deliver large, strategically significant river crossing projects?

As outlined above the public sector needs to understand what the proposed crossing is supposed to achieve and what the implications are for the wider area.  Taking the Dartford Crossing there is clearly an issue with the capacity of the existing bridges and tunnels but the next question is then what problem are you trying to solve?  The bulk of the traffic on the M25/A282 is trying to go around London so given the physical constraints the answer to the question is to improve the existing crossing.  The 2013 technical work showed that if option C were built the existing crossing remained running at over 90% of capacity – and therefore likely to be subject to significant congestion.

Kent and Essex County Councils have sought a crossing east of Gravesend partly to serve flows from Dover and the Channel Tunnel – but that is an answer to a different, though valid, question. Such an approach would require significant investment on linkages between the M20 & A2/M2, including possible upgrades to the A2 in East Kent.  The impact of Operation Stack shows the volume of lorries on the strategic road network in Kent.  Any appraisal needs to examine the options for spreading this load on a wide scale not just local routing (e.g. better use of ports further up the east coast by continental traffic, rail freight etc.). There are no longer Regional Planning authorities and the National Policy Statement for National Networks contains no detail. There is therefore a void in the strategic decision making process. 

The decision maker is presented with choice between a cheaper short crossing (Option A) or a much longer one (Option C in some form) which is much more expensive due to the widening Thames and the length of the access routes.  Both raise questions about what other transport schemes are needed to support them, especially Option C.  The question becomes whether the additional benefits make the additional cost worthwhile, in both financial and environmental terms.  

 

What other government priorities, such as new house building, urban regeneration and new business opportunities, can be delivered through additional strategic river crossings?

Additional connectivity is generally seen as a ‘good thing’ and if you compare east and west of London it can be argued that the east side would benefit from additional Thames crossings. Assessment of economic benefits is always a difficult process.  It can either be done in an econometric way or by a focus on actual sites.  The former risks ignoring realities on the ground and the latter will pick up existing sites but not future ones that have yet to emerge in the Local Plan process.  Greater economic benefits are claimed for Option C but this is not founded in solid evidence of what difference it would make to actual sites – their land use, density, viability etc.  There also has to be an appreciation of the environmental impacts of the proposals which may act in their own right to depress the attractiveness of part of the area even if the overall effect is positive.  This is all in context of a highly congested network overall as noted above.  It is also in a context where public transport links have or will be significantly upgraded between the north and south banks over the historical position (DLR, Jubilee Line, HS1 and Crossrail). 

As noted above there are overall objectives for connectivity and support economic development – but for any particular option will have differential impacts on particular places locally? An obvious question would be that route C would benefit the rest of Kent as it effectively bypasses Dartford/Gravesham and the latter is still left with a constrained crossing.

 

Do existing cost-benefit analysis methods adequately capture any potential transformative effects of new river crossings?

By definition modelling methods (whether highway or financial) have problems when applied to a problem that has significant as opposed to incremental implications.  Transport models for example find it difficult to deal with major changes in the network as opposed to incremental additions.  This is because the amount of supressed demand can be hard to estimate whereas existing trips that are diverted is much easier to model. Claiming economic benefits is even more difficult because it depends on assumptions about new sites coming forward for development and/or existing ones coming forward for higher value uses.  Just providing infrastructure is in itself not enough.  The obvious local example would be Ebbsfleet International Station – though the Paramount Entertainment Resort proposal, which the Borough Council supports, will change that situation.

The 2013 consultation BCR’s (Benefit Cost Ratio’s) ranged from 1.0 – 2.4 (ignoring option B now dropped) with the wider benefits being a major component towards the higher ratios. There is a concern that especially for route C the benefits may mainly be felt outside Thames Gateway as the amount of relief to the Dartford Crossing itself is limited (still running at 90% of capacity).

BCR’s do not take into account the environmental impact.  Option C would need to be subject to Habitat Regulations Assessment (HRA) – and or course if there are significant impacts there is a perfectly feasible alternative – A.  It has been suggested that a tunnel be used and made longer, but this would put up cost and reduce the BCR and also on the Kent side introduces issues over gradients due to the climb needed up to the A2/M2.

 

What are the best methods for financing additional river crossings?

The preferred model seems to be that private investment is seen as the way forward funded by toll revenue.  In the case of the Dartford Crossing it is a reasonable assumption on past experience that revenue would be forthcoming to support the cost of building and maintaining the crossing itself (bridge/tunnel etc.).  Whether this would fund the approaches and knock on schemes is another matter, and logically more difficult for the longer Option C. The Council however objects to the use of actual as opposed to shadow tolls – see further below.  If this is seen as major national infrastructure the logic would be that it would be funded by the state.

 

How can the public sector attract greater investment from the private sector for the delivery and maintenance of river crossings?

An important issue here is the distinction between the river crossing itself (in whatever form) and the infrastructure necessary to support it.  In the case of Dartford Crossing itself any new capacity may be fairly short in length (though not necessarily cheap).  If you move east of Gravesend you end up with a longer crossing, much longer approach roads (order of 20 km depending on route) and probably the need for additional schemes elsewhere (e.g. upgrading a M2/M20 link without which there is no good access to the Channel Tunnel).  That link is either via the A228 which passes through various pinch points in the Medway Valley or A229 which involves climbing the North Downs (Blue Bell Hill) and junction 3 of M2 which is already grossly overloaded at peak times

Tolling is an obvious way of achieving a cash flow for paying for maintenance and capital cost, but for reasons set out below the Borough Council believes this should be shadow not actual tolls

 

Should strategic river crossings be tolled? How should tolling be implemented? How can technology be used to improve strategic river crossings for road users (e.g. better management of traffic flows)? 

The Borough Council objects to tolling of river crossings as it impedes interaction across them.  Currently the Dartford Crossing is tolled and the Blackwall tunnel is not.  Great play has been made of the lack of crossings on the east side of London compared with the west.  The Mayor of London is proposing to toll the Blackwall tunnel and the new Silvertown link plus any other new crossings that may be built to which the Central London congestion charge can be added (accepting that this applies whether you cross the river or not). A pecuniary charge is a charge whatever it is called.  The result would be, with very few exceptions (Tower Bridge, Rotherhithe Tunnel), that there will be a charge to cross the Thames in the east and not in the west.  Logically this does not look like supporting the economic regeneration of the Thames Gateway. 

If tolling is insisted upon then it needs to be in a user friendly means as possible since the toll booths at the Dartford crossing have been a cause of delay and congestion.  Until the physical works are complete it will not be fully possibly to judge the benefits of the current tolling mechanism.

 

February 2015