Boris (or TfL, who are increasingly operating as a semi-detached body these days) wants to build a tunnel under the Thames from the southern Blackwall Tunnel approach to Silvertown on the northern bank.  This is, fairly obviously, a rubbish idea from start to finish; induced traffic, sprawl, air pollution, obesity and congestion are what road projects bring, not alleviate as TfL claim, so I’m filling in their consultation as follows.  Note that they ask for your views on the consultation before you’ve filled it in or seen the questions:

“What do you think about the consultation itself (leaflets, website, publicity etc.)?”

“It is unclear as to what TfL’s consultation strategy is, given the plethora of consultations being offered to the public on east London river crossings and the fact that this is not apparently the statutory consultation required by the new fast track infrastructure planning process. It would be far better to have one, widely advertised consultation on a range of road and non-road based options.

The visualisations offered are misleading, since they give the impression a new road will not be used by traffic, when the opposite is true. They should be redone showing the expected level of traffic generated by the tunnel plus other visualisations produced showing the traffic induced in other areas where no congestion relief is planned, such as on the A2 approaching the tunnel or on local roads around Lewisham, Greenwich and Newham Boroughs.

Finally, in discussion of journey times (such as Lewisham to Stratford) no reference is made to the existing public transport alternatives – the existing DLR from Lewisham to Stratford is already quicker than the car journey now or with the tunnel.

“We consider that a new crossing is needed to improve the resilience of the road network in east London, relieve congestion at the Blackwall Tunnel and beyond and to support growth in London’s population. Do you agree that a new crossing is needed and could successfully address these issues?”

“The resilience of road networks is not increased by adding traffic to them, but by removing traffic *from* them. Since adding new roadspace such as Silvertown induces new traffic, which inevitably adds to congestion on routes where no roadspace has been added, the net effect will be to increase congestion and reduce the resilience of the network. It therefore fails in this primary objective.

As for supporting growth in London’s population, London has increased by approximately a million people over the last few years while road traffic has declined. There is therefore no supporting evidence for needing to support road traffic growth as an inevitable corollary of population growth. In fact the evidence is the other way.”

“Would you support a user charge that was similar to Dartford charges levels, and during peak periods slightly higher, to help pay for the new crossing and resulting in more reliable journey times and less overall delays?”

“The route, if tolled, would disincentivise use of it during peak times – that’s the point. Unless roadspace reallocation is planned in local town centres traffic will be displaced to those areas, worsening the local environment. Additionally a time-based user charge will incentivise travel around the edges (say at 6pm, as happens in the congestion charging zone). This will therefore push traffic seeking to avoid the tolls through residential areas in the early evening.

A true road pricing system would avoid these negative effects, actually deliver the targets for resilience and reliability and almost certainly avoid the need to pay for the expensive tunnel altogether.

“Would you sign-up to an account system, with the benefits of auto-pay and a charge that would be lower than what non-account holders would pay?”


“The Silvertown Tunnel would create an opportunity for new cross-river bus connections. What sort of new bus connections do you think are important?”

“It is more important to improve the reliability and speed of existing public transport alternatives, which requires bus priority and reduction in traffic. This scheme includes neither, so it is immaterial what bus connections I consider important as they would not be effective.”

“We will link the new tunnel to the existing road network with new junctions in the Royal Docks and Greenwich Peninsula areas.

Do you agree that the new junction in the Royal Docks area on the north side provides the right connections?”


“We will link the new tunnel to the existing road network with new junctions in the Royal Docks and Greenwich Peninsula areas.

Do you agree that the new junction at the Greenwich Peninsula on the south side provides the right connections?”


“Please use the space below to let us know any additional comments you may have on our proposals for new junctions to link the tunnel to the existing road network:”

“The southern one appears to have extremely tight corners and a junction for merging traffic possibly with poor sight-lines.  The northern one, with a dual carriageway terminating on a signalled roundabout linking several existing roads, has extremely limited capacity and begs the question as to what the point of spending the thick end of a billion pounds on all that capacity is if you’re going to hold it up at traffic lights and expect an unmodified existing road network to disperse it”

“We have published a large number of technical reports. These deal with a number of disciplines, including traffic, the environment, optioneering and engineering, amongst others. If you have any comments on our methodology or approach to any of these disciplines, please let us know in the space below.”

“The traffic forecasts (st-silvertown-traffic-forecasting-report.pdf page 5) suggest that car use will continue to be a declining share of trips, yet no public transport alternatives for river crossings are being prioritised, nor is this called out properly.

This risks misleading people into thinking that car traffic growth is overwhelming when in fact it isn’t. Further, it indicates that new developments north of the river should (and probably will) cater primarily to the public transport mode share and therefore will disproportionately attract people via those modes despite the investment going into roads.

Far from supporting the case for the tunnel, the technical reports tell me that it could easily become a white elephant, never paying back its construction cost, because the developments it is intended to serve are not built to generate tolled trips via the tunnel.

It is clear that elsewhere in London major developments such as Kings Cross and Old Oak Common, the City margins or the existing Docklands sites are not demanding increased road space on this scale, and the reasons why this trend does not apply to the Royal Docks and other local developments are unclear.”

“Please use the space below to let us know any other thoughts you may have”

“It is dispiriting to find that in the 41 years since the 1973 abandonment of the Ringway plans, a decision which paved the way for London to lead UK transport policy economically and environmentally ever since, that the arguments that were entirely disproved by that decision have been ignored or forgotten.

– Encouraging car use does not automatically bring growth – we have had sizeable economic growth in London for years with reducing car use

– Building roadspace does not alleviate congestion – the M25 widening schemes that fill up immediately show this, as do myriad examples around the world.

– Increasing population does not require new roads – London’s population was around 7.1m in 2000 and is now 8.6m, without any additional roadspace and in the centre particularly quite large reductions

– The public do not demand the right to drive everywhere without congestion as much as they demand freedom from traffic in their local environment

The view that people need to drive from home to work and workplaces therefore need good road connections is wrong – in London commercial property developers, judging by where they choose to invest, know that good public transport access attracts top-rank tenants to their developments far more than being right beside a major road. They also know that land used for parking is land you can’t make money from, and without parking there’s no need for new roadspace. If no one’s building new commercial developments requiring car commuting and internet shopping is replacing car-based shopping, where is this vital traffic growth coming from?”

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