Representation by Transport Action Network (Transport Action Network)
- Date submitted
- 24 February 2023
- Submitted by
- Members of the public/businesses
Transport Action Network OBJECTS to the DCO application for the Lower Thames Crossing. Our objection includes but is not limited to: CLIMATE CHANGE - the scheme would increase traffic growth leading to more carbon emissions. Combined with the construction emissions, the total carbon emissions from the scheme would be at least 6.6 million tonnes over its lifetime making this the biggest emitting scheme ever proposed (APP-518, 7.3.37). The carbon emissions caused by the construction (at least an additional 2 million tonnes although National Highways are obscuring the real total with offsetting schemes), all occur within the critical fourth carbon budget when we need to achieve 68% reductions in UK carbon emissions by 2030 under our commitments in the Paris Agreement. The significance of the carbon emissions has not been properly assessed, as it only compares emissions against total UK emissions which is a pretty meaningless comparison. Whilst the National Policy Statement for National Networks (NPSNN) is under review as it is out of date, the 2022 IEMA guidance should be used for deciding on the significance of carbon emissions for this scheme. The Applicant is relying on speculative and unevidenced claims made in the Transport Decarbonisation Plan (TDP) about the rate of decarbonisation. The Applicant is also relying on speculative, future technologies to reduce construction emissions VALUE FOR MONEY - the scheme is low value for money with an adjusted benefit cost ratio (BCR) of just 1.22. This does not justify the harm, costs and disbenefits caused by the construction and operation of the LTC. The scheme would cost the country over £10 billion while failing to meet many of its objectives. The money would be better spent on transport schemes which encourage mode shift, decarbonisation and levelling up. BIODIVERSITY, LAND USE CHANGES, FARMING - the scheme would harm the setting of the Kent Downs Area of Outstanding Natural Beauty (AONB) which cannot be justified in planning terms as the purported benefits are so low. It would also destroy and impact on woodlands, including ancient woodland, hedgerows, veteran trees, the habitats of protected and endangered species, and thousands of acres of high quality farmland. AIR AND NOISE POLLUTION - due to the increased traffic caused by the scheme there would be an increase in air and noise pollution resulting in greater health impacts. SEVERANCE - the extra traffic on the local road network will increase severance. ACTIVE TRAVEL AND PUBLIC TRANSPORT - no provision for cross river public transport and active travel, which will cement in traffic growth and car dependency. The additional traffic the road will create on the wider road network will also have a negative impact on bus services and put off people from cycling. DANGERS OF SMART MOTORWAYS - the scheme is being built to Smart Motorway standards and for all intents and purposes is a Smart Motorway. The evidence base does not exist to conclude that these roads are safe, and they are unpopular with the public.