Why I cannot support the Mayor of London's Silvertown Tunnel Proposals

Matthew Pennycook has posted a blog article detailing his reasons for rejecting the Silvertown tunnel proposals. Read the full article HERE

I have never met a constituent who did not agree that the two sides of the Thames east of Tower Bridge should be better connected. The issue is how we achieve that cross river connectivity in a way that contributes to a sustainable local transport system that delivers benefits for local residents in terms of improved air quality, inward investment and expanded opportunities.

In the wake of Transport for London’s (TfL) October-December 2014 consultation, I took the view that the case for a new road tunnel under the Thames linking Greenwich Peninsula and Silvertown had not been made convincingly. I hoped at the time that TfL would listen carefully to the concerns that had been raised and respond positively to the range of suggestions that were put forward by the council and others to improve the scheme.

Sadly, TfL’s final statutory consultation, which closed before Christmas, contained little new thinking. As such, nothing in the thousands of pages of documents released as part of that exercise removed the scepticism I felt, and still feel, towards the scheme.

As I have long maintained, the rationale for the Silvertown Tunnel cannot simply be dismissed out of hand as the latest craving of an insatiable pro-car lobby. There are reliability problems associated with the Blackwall Tunnel northbound bore which frequently contribute to congestion on our local road network and that no amount of cross-river public transport infrastructure would fully resolve. The status quo is, and will remain, untenable.

However, any proposed solution to the problems of resilience at the Blackwall Tunnel and the appalling congestion those problems so often exacerbate must, first and foremost, do no harm. I am not convinced that the proposed Silvertown Tunnel can be said to pass that test.

TfL’s final statutory consultation did provide some welcome new detail. In particular, we were given new information about the vehicle charging regime that is an integral part of the proposed scheme. Yet the indicative charges outlined in the consultation did not alleviate my longstanding concern that they will not be sufficiently high to deter vehicles that do not currently use the Blackwall Tunnel, particularly heavy goods vehicles, from making the Greenwich Peninsula their preferred river crossing point. I accept that my concerns in this regard might not be insurmountable given that under the proposals TfL would retain the ability to increase charges if they felt it were necessary. However, what the charging regime will be unable to influence is the impact of its operation on other routes across the river.

It is the potential for charging to lead to the harmful displacement of traffic that makes TfL’s decision to ignore calls to extend the charging regime to the Rotherhithe Tunnel so disappointing. As TfL’s own modelling makes clear, charging for use of the Blackwall Tunnel and a new Silvertown Tunnel will lead to traffic diverting westward through Greenwich Town Centre (TfL estimates that this will mean an extra 94 cars per hour during the morning rush hour and an extra 100 cars per hour during the day) and a smaller number eastward toward the Woolwich Ferry at inter-peak (i.e. daytime) periods. That displacement could be managed, or if not mitigated, if Rotherhithe were charged. Instead, as the plans stand it will remain the only fixed road river crossing lying outside the congestion zone that is free from charging and a more attractive route of crossing the Thames as a result. Given the gridlock that so often now characterises the lower road, an increase in displaced traffic along Trafalgar Road and Creek Road is not something that can be contemplated with equanimity.

Alongside an effective charging regime, substantial extra investment in public transport infrastructure is vital if the extra capacity provided by a new Silvertown Tunnel is not to be rapidly exceeded in future years. Yet TfL’s final statutory consultation contained no new proposals for significant public transport improvements, such as an extension of the DLR to either Eltham or Thamesmead or a London Overground link from Barking Riverside to Thamesmead and Abbey Wood, as called for by the council in its November 2014 consultation response. Indeed, the latest consultation did not even contain guarantees that the new cross river bus routes that a new Tunnel might facilitate would be tied into the scheme through the Development Consent Order (DCO) process. In failing to consider the integration of more significant additional public transport schemes into their plans, TfL have wasted an opportunity for a more radical approach that might have ensured local public transport could compete with private car ownership not merely on cost, but on convenience and ease of use. For the same reasons, they have wasted an opportunity to convince sceptics that a new Silvertown Tunnel would be but one element in a more ambitious vision for cross river connectivity in East London.

Given how heavily TfL’s case for a new Silvertown Tunnel rests on the purported economic benefits of the scheme it was also surprising that TfL did not accept the rationale for discounts to be provided for local residents and businesses. TfL Officials argue that discounts would undermine the ability of the charging regime to manage demand and the financial business case underpinning the scheme and they may well be right. However, their decision to dismiss local discounts is in itself a telling indication of what I have come to fear is the primary purpose of the new crossing: not to provide a non-strategic cross river link providing enhanced resilience and a welcome boost to local commerce but to create a strategic crossing that vehicles making non-local journeys can opt for over the less reliable Blackwall Tunnel as a matter of course.

Perhaps most importantly, I remain concerned that the proposed scheme risks a further deterioration in overall air quality in the area. In their October-December 2014 consultation, TfL were open about the fact that a new Silvertown Tunnel would have a detrimental impact on air quality on some local roads. That the same admission did not feature in their latest formal statutory consultation does not render that outcome any less likely. The quality of the air we breathe locally is not a minor consideration. We are talking about a silent killer that is responsible for an estimated 29,000 premature deaths a year across the country. To be worthy of support, any proposed river crossing scheme needs to establish, beyond reasonable doubt, that it would not make an already dire situation worse. Having now considered all the evidence we are likely to see before the formal submission of an application for a DCO, I do not believe the Mayor’s scheme passes that test.

For many years I have resisted calls, often vocal, to rush to judgement on this important issue. Having closely engaged with round after round of consultation, the skepticism I have long felt towards the scheme has not faded. If a new Silvertown Tunnel is eventually built, I hope my fears prove to be unfounded but I hope that the Mayor and TfL, even at this late stage, will think again about whether these plans really add up. My fear is that far from alleviating congestion and air pollution, the proposed scheme will exacerbate both to the detriment of the health and quality of life of local residents. The status quo remains untenable and needs to be addressed but, after wrestling with these proposals over many years, I have come to the conclusion that we deserve smarter, more effective and more imaginative solutions than what is being proposed.