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REF: APP/G5750/V/05/1174146 & APP/E5330/V/05/1174147
THE PROPOSED THAMES GATEWAY BRIDGE
RULE 6 STATEMENT
A conjoined Rule 6 Statement Submitted on Friday 25
th March 2005 by: -Action Group Against the Bridge (AGAB)
Jacqui Wise
(Co-Founder & Coordinator of AGAB, SMRA Committee Member)Steve Wise
(Co-Founder & Coordinator of AGAB, SMRA Member)42 Berkeley Avenue
Bexleyheath
Kent
DA7 4UA
TEL : 020 8301 4243
MOBILE : 07748 132161
St Michael’s Residents’ Association (SMRA)
Terry Grant
(SMRA Secretary, Coordinator of AGAB)34 Albury Avenue
Bexleyheath
Kent
DA7 4SJ
TEL : 020 8298 1105
MOBILE : 0780 1265713
INDECENT HASTE
There appeared to be an attitude of indecent haste on the part of Greenwich Council to ensure that the planning
application was approved before the end of year 2004. There was a rumour doing the rounds that if they failed
to pass it before the start of 2005 they would be unable to complete construction of the bridge for the London
Olympics in 2012 if successful.
A point of order was made regarding the statement by Greenwich Council that we were now dealing with a
totally new Planning Agenda and therefore there had been insufficient time to analyse, consider and discuss the
new Agenda, the original Agenda having been discarded. They ran roughshod over the concerns of the objectors.
REPRESENTATION
We as residents have little or no funds to afford legal representation and in order to make a level playing field
out of this public inquiry all parties should be unable to have legal representations themselves. Let them stand
up on their own feet and speak for themselves unrepresented as we will have to.
DISCREPANCIES IN RECORDS & NOTIFICATION LETTERS
It has become apparent that there are discrepancies in the records kept for objectors’ responses resulting in some
groups being omitted from TfL’s list of Objectors and Respondents (Statement of Case March 2005 point 9.28).
Also some Groups and individuals are not receiving letters from the Government Office in Newcastle and/or
the Inquiry Manager’s office in West Sussex who should be. This has resulted in groups/individuals being
unaware of the pre-inquiry meeting, the date for the Public Inquiry and therefore having insufficient time in
which to prepare their proof of evidence.
We have been unable to cross-check the lists of individuals ourselves as information has been denied under the
Freedom of Information Act (Data protection) by both LB Greenwich and the Government Office of London
(GOL). We have reapplied for lists of groups and organisations from LB Greenwich after lists were released by
the GOL.
LACK OF FREEDOM OF INFORMATION
Information requested under the Freedom of Information Act is not always being made available to us even
though we feel it should be in the public domain. Some requests are time consuming and on-going. In some
cases our requests have been met by a request for unreasonably high charges. As we have been unable to afford
these charges we have been unable to have copies of the requested documents. Therefore we feel this process
has been undemocratic and has not allowed us to have detailed access to all information that we require to put
our case forward at the public inquiry.
INADEQUATE CONSULTATION
We believe TfL did not consult residents adequately on the proposals for the Thames Gateway Bridge and that
certain people were not included in the consultation process that we feel should have been.
We believe inaccurate information was given to residents by some TfL representatives at TfL exhibitions and
road shows in Bexley Borough. We believe this breaks the good practice guidance which is ‘to ensure Londoners
are engaged and consulted effectively’.
Residents were not offered alternative schemes.
An Environmental Impact Assessment (EIA) was not available during the Consultation period and traffic figures
also increased while the consultation was in progress.
FLAWED MARKET RESEARCH
We believe that TfL’s Market Research is neither accurate nor balanced.
INSUFFICIENT INFORMATION
We believe that there has been a lack of accessible information available for residents to enable them to form a
balanced opinion on the proposed Thames Gateway Bridge scheme.
TRAFFIC MODELLING
We believe that traffic modelling produced by TfL under-estimates the level of traffic that will be generated by
this scheme with resultant adverse impacts on air quality, noise pollution, forecasts for road traffic accidents,
damage to natural habitats and residents’quality of life.
We believe that TfL’s Traffic & Transport Report (Table 4.11) does not show an accurate prediction of major
traffic flow changes and therefore is redundant.
TfL’s Traffic & Transport Report (Table 4.11) shows some roads in the LB Bexley as having a decrease in
traffic flow as a direct result of the proposed Thames Gateway Bridge being built which we believe are evidently
inaccurate and therefore need to be re-modelled before a Public Inquiry commences.
Other roads (such as Park View Rd, Welling) are shown as having decreases in traffic flow on Table 4.11 but
will be used for suggested mitigation measures by TfL. Therefore these roads will actually receive an increase
in traffic flow not a decrease.
It is also becoming apparent that there are other roads in the LB Bexley where there are concerns that ‘rat
running’ may occur. We believe that traffic flows on these roads again have not been taken into account in TfL’s
traffic modelling.
Greenwich Council’s consideration ‘to make representations to the Mayor of London to secure the tolling of
Blackwall Tunnel when the Thames Gateway Bridge opens’ (Planning Agenda page 20, point 5.16 g.v.) has also
not been taken into account in TfL’s traffic modelling forecasts. This suggestion is also supported by the
Thames Gateway London Partnership (TGLP).
There is also concern over the possible demise of the Woolwich Ferry which would transfer further traffic
elsewhere. Again we believe that this has not been taken into account in TfL’s traffic modelling.
TfL state that if traffic flows are under predicted by 25% there will be over capacity on the bridge and a loss of
‘free flow conditions on the bridge’. In plain English this means congestion and an end to the travelling times
predicted by TfL. These dubious time saving benefits for commuters form a major part of TfL’s economic
argument for having the bridge in the first place.
Independent transport consultant John Elliot states ‘No previous big road has relieved congestion in London -
they normally add to congestion over a wide area’.
This proposed bridge and resultant traffic will conflict with the Mayor’s Transport Strategy which requires a
reduction in traffic rather than generating and encouraging increased use of cars.
ROAD SAFETY
TfL have forecast an increase of 116 road traffic accidents per year that includes 6 serious accidents and one
fatality as a direct result of the proposed Thames Gateway Bridge being built. If traffic forecasts are underestimated,
these figures will increase further.
Some mitigation measures, we believe, can discourage cycling, especially at night as cyclists have to manoeuvre
around built out kerbs and are forced into the path of following traffic.
AIR POLLUTION
European Union directives state that certain limits on air quality should be required by all member states by
2005. We believe that an increase in traffic and air pollution generated by the proposed Thames Gateway
Bridge will breech EU limits of certain pollutants.
In Greenwich Borough’s planning Agenda, the assessment concluded that ‘in total there is a minor adverse
change in exposure to air pollution as a result of the Thames Gateway Bridge’. The same agenda states (page
89, point 9.49) ‘there is predicted to be more premises experiencing an increase in PM10 concentrations compared
with a decrease’. In other words it is likely that
levels of PM10 will increase. ‘The evidence on healtheffects of PM10 suggests that there is
no threshold for the onset of health effects’. From very low to highenvironmental concentrations of particles, increased exposure leads to an increased risk for those already susceptible
to experience adverse health effects from air pollution’ (Greenwich agenda, page 89). This will affect
people who have existing heart and lung diseases including adults and children with asthma. If particles are
small enough they may also carry surface-absorbed carcinogenic compounds to the lungs.
Bexley Council have documented that levels of Nitrogen Dioxide & PM10 in some areas of Bexley
are expected to be close to the National Air Quality Objective levels in 2005. Many of these roads are residential
and extra-generated traffic will detrimentally affect people’s health.
LB Bexley has the worst rates of childhood asthma of any London Borough and increases in PM10 will pose
further serious health affects to an area already recognised as having major health problems. This must surely
conflict with national policies on health & air quality (Cleaning London’s Air : Air Quality Strategy).
We have major concerns that LB Bexley already has an Air Quality Management Area (AQMA) in Manor
Road, Erith. Many residents have serious concerns that the route along the A2016 and A206 will not be capable
of coping with further predicted increases in traffic as a direct result of the proposed bridge being built. In
particular it is believed that much of this traffic will be heavy freight & we believe it is totally unacceptable to
knowingly add further pollution to an area where Bexley Council has a responsibility to adhere to the Mayor’s
Air Quality Strategy in actively improving air quality to protect the health of residents.
NOISE POLLUTION
Increased traffic will mean an increase in noise and for many people this will be constant noise day and night.
The London Mayor’s ‘Ambient Noise Strategy’ describes noise as ‘the forgotten pollutant’. In the GLA London
Household Survey it states that 46% of Londoners polled considered noise a problem and 24% included
noise as one of their top priorities for improving the quality of the environment in London. 13% then went on to
say that traffic noise was a ‘serious problem’ for them.
Traffic generated by the proposed Thames Gateway Bridge
will ‘rat run’ through our residential roads &will cause disruptions to conversations & activities, increase stress & disturb concentration, rest & sleep
to thousands of people. TfL state that 5000 people would suffer a ‘moderate/substantial adverse effect’ from
extra noise but they would
eventually get used to it.People will
not get used to it they will be forced to put up with it because they will have no choice. It willstill affect their health & demean their quality of life.
BRIDGE DESIGN
Due to constraints on the bridge design we believe there may still be conflicts between the Port of London
Authority (PLA), London City Airport (LCA) and the Environmental Agency (EA) that are still unresolved. We
are concerned that compromises could be made to the detriment of the natural environment and people’s enjoyment
of the Thames Estuary.
ADVERSE EFFECTS ON NATURAL HABITATS
There is continued concern for Oxleas Woods. Although the Mayor Ken Livingstone, TfL and Greenwich
Council have publicly pledged that the bridge and its associated roads will not affect Oxleas Woods will they be
held responsible for future decisions that may be made by their successors?
We wrote to Ken Livingstone requesting that he publicly pledge that the bridge and its associated roads will not
affect Lesnes Abbey Woods, Bostall Woods & Bostall Heath but have received no such pledge.
Lesnes Abbey Conservationists have objected to the proposed Thames Gateway Bridge on environmental
grounds. There are many other open spaces & parks that will be detrimentally affected and threatened in Bexley
& Greenwich by increased traffic and resultant noise or by the physical structure of the bridge.
It is obvious from recent planning permission that Bexley’s Biodiversity plan is not worth the paper it is written
on regarding safe-guarding rare and natural habitats.
There is concern that people’s enjoyment, relaxation & access to places such as Danson Park will be spoilt as
Danson Road will take the brunt of the traffic leaving the A2 to reach the bridge (and vice versa). Friends of
Danson Park have also objected to the proposed scheme.
We are also very concerned that traffic volumes will necessitate the widening of Knee Hill in the future with the
loss of ancient woodland. We have been informed that widening has been discussed (and the fact that it has
been discussed worries us) and we have been given no reassurances that this will not happen
in the future ifthe road is unable to cope. Knee Hill is already at capacity during peak times and close to capacity during interpeak
times and in our opinion it
will not be able to cope with any further traffic.The Environment Agency (EA) has also documented loss of and disturbance to, the environment although their
remit is, we have been informed, focused on the Thames Estuary area.
TRAFFIC MANAGEMENT/MITIGATION
So far TfL’s suggestions for traffic management are to ‘encourage’ traffic onto ‘A’ roads, which are near capacity
already. Traffic ‘given a choice’ will use the quickest/easiest route, which will mean congestion and ‘rat
running’.
As far as we are aware no further traffic modelling has been carried out on Bexley’s roads by TfL prior to the
Public Inquiry even though both residents and Bexley Council strongly said this was crucial at Bexley’s planning
meeting in November 2004. Therefore residents and Bexley Council will still be none the wiser as to the
true detrimental impact of generated traffic on Bexley’s road network than we were in November 2004.
We also strongly believe that mitigation money is insufficient.
TOLLING REGIME
Flawed precedence.
We do not believe that tolls will discourage long-distance traffic and in particular heavy freight.
STRATEGIC BRIDGE NOT LOCAL BRIDGE
We do not believe this bridge is a local bridge for local people. We believe it is a STRATEGIC bridge for transnational
traffic.
Unlike the Dartford Bridge, the proposed Thames Gateway Bridge will be generating traffic into an already
existing residential area with a lack of foresight about the real long-term problems this will cause.
REGENERATION/JOB CREATION/ECONOMIC BENEFITS
We do not believe that the proposed 6 lane road bridge is essential to job creation in the Thames Gateway area.
There is no evidence to suggest what type of jobs would be created and no guarantee that they would benefit
local people. It is more likely that people will travel from further afield therefore generating traffic and pollution.
Benefit Cost Ratio (BCR).
Professor Whitelegg report.
HEALTH
We have serious concerns regarding the apparent total lack of consultation between TfL and the LB Bexley’s
health officials regarding the health and well-being of Bexley residents.
POORLY THOUGHT OUT PUBLIC TRANSPORT
We have concerns over the possible demise of the Woolwich Ferry.
We believe there are also shortcomings in TfL’s provision of adequate Public Transport.
UNSUSTAINABILITY OF THE THAMES GATEWAY
We are concerned that the whole Thames Gateway development is over-ambitious, not well thought out and
unsustainable and that the proposed bridge should not be seen in isolation.
CONCLUSION
If this bridge is allowed to proceed it will be at the brutal disregard of the existing communities and the environment.
The health implications would be disastrous with unforeseen consequences for future generations.
DO YOU WANT TO LEAVE THIS LEGACY TO FUTURE GENERATIONS?
WE RESERVE THE RIGHT TO EXPAND UPON THE ABOVE POINTS AND ADD FURTHER POINTS TO
OUR PROOF OF EVIDENCE.