Silvertown Tunnel Consultation
The Greenwich Society submission - our 'representations' - have gone to the Planning Inspectorate for their next-stage Examination of the Silvertown scheme: -
The Greenwich Society is the main local amenity society for the historic Greenwich area, representing about 1,000 members. We wish to make the following representations to the Planning Inspectorate’s examination of the Silvertown Tunnel project (TR010021).
- Air Pollution As a result of traffic congestion, predominantly along the A102, this area is among the worst affected by air pollution in south-east London. In their 2015 consultation TfL argued that the Silvertown Tunnel scheme was the only way to prevent harmful traffic emissions around the Blackwall Tunnel getting worse. It is therefore surprising and disappointing that their latest forecasts show only small or ‘imperceptible’ changes in NO2 emissions along the A102 in our area. Apparently this is because the improvement in the morning peak is offset by increased traffic congestion southbound from the tunnels in the afternoon peak. This needs to be reviewed urgently to see how junctions along the A102 southbound can be improved, before Silvertown is opened, to achieve a much-needed net improvement in air pollution in our area.
- Consultation The impact of the Silvertown Tunnel scheme on local roads is necessarily uncertain. TfL have assured us that their forecasts show ‘no negative effects’ along Trafalgar Road, which is also already congested at peak times (and the same applies to the Town Centre and Creek Road). But the diversionary effect of tolls on cross-river traffic which now travels free – and in particular diversion to and from the Rotherhithe Tunnel which stays free – cannot be predicted in advance with any confidence. So we welcome TfL’s proposals for detailed annual monitoring, and the commitment to liaise with ‘the hoist boroughs’. But borough councils do not always consult adequately with local amenity societies. A wider Community Liaison Group is proposed ‘for the duration of the works’ to deal with construction issues; this should be extended through the monitoring period so that TfL can communicate directly with local amenity societies on data collection and possible mitigations. We also note that the details of the proposed Community Fund will be decided ‘through discussions with the relevant local authorities’; we hope the Community Liaison Group will be kept in touch with this.
- Tolls This is the first occasion (so far as we know) when a toll is proposed on an existing free main road. It will also be the only inner London river crossing where tolls are charged. We understand TfL’s reasons for proposing a toll (to pay for the tunnel and control traffic levels). But locals who regularly drive through the tunnel, and whenever possible outside peak hours (hence without imposing any ‘cost’ on other users) will be differentially penalised by comparison with other users. In our view there should be a discount for local resident account-holders, allowing them free off-peak travel (which could be easily arranged given automatic charging).