Representation by CPRE Kent (CPRE Kent)
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
CPRE Kent OBJECTS to the Lower Thames Crossing project. This project is fundamentally flawed, will not deliver the benefits it promises, and will inevitably cause significant environmental damage. CPRE Kent is an independent charity that works closely alongside other CPRE branches, as well as the national CPRE organisation. As such the geographic focus of our comments is the southern element of the project. Our comments are in part informed by national CPRE’s research and policy and we support and endorse the comments on this consultation made by CPRE Essex. Our objections fall under the following general themes: Congestion reduction at Dartford: This was the original justification for the delivery of a LTC. Thurrock District Council’s modelling has revealed that the reduction in traffic at the existing Dartford crossings would be as low as 4%, and therefore still well over their design capacity, perpetuating the status quo of congestion, air pollution and delays for many years into the future. Induced traffic growth: it has been documented for nearly 100 years that new roads generate additional traffic, rather than alleviating congestion. Lack of modal shift opportunities: the induced traffic growth caused by this development would lock in car-dependency for generations. It is absurd to invest public funds in a project that caters only for road-based traffic, and which discriminates against non-car users. Climate impacts: despite NH’s claims to the contrary, the construction and use of this project will have a significant carbon impact and the measures proposed to limit this are not yet in use. On 14th February 2023 the Welsh government announced the suspension of all major road building over environmental concerns, particularly increased climate impact. Cost benefit: we remain to be convinced that the BCR figures are reliable, as demonstrated by the recent climb in claimed costs to £9bn for the project, not including the significant upgrades to other parts of the road network that will be needed to cope with increased traffic. A recent study of the M25 widening between Junctions 23 and 27 showed that contrary to the BCR (justified largely by aggregated reductions in individual journey time), the rapid growth of induced traffic meant that within 2-3 years post opening journey times had returned to the pre-project levels. Damage to habitats and wildlife: While we acknowledge the proposed mitigation plans, the project will nevertheless cause considerable harm to the landscape, wildlife (including protected species) and habitats including Green Belt, SSSIs, ancient woodland and Best and Most Versatile agricultural land. Air pollution: claims that air pollution will no longer be an issue once internal combustion engines are phased out are misleading because EVs still generate PM2.5 and internal combustion engine vehicles will not disappear from the roads overnight. Heritage and Cultural impact: impacts on Scheduled Ancient Monuments and listed buildings are an unacceptable consequence of this misguided project.