RESPONSE TO SHAPING LONDON PUBLIC CONSULTATION DRAFTS

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1 BEXLEY LA21 NATURAL ENVIRONMENT FOCUS GROUP RESPONSE TO SHAPING LONDON PUBLIC CONSULTATION DRAFTS Introduction:- Bexley LA21 Natural Environment Focus Group (NEFG) consists of voluntary organizations and individuals within the London Borough of Bexley concerned with the natural environment. Its remit does not extend outside the boundaries of that borough although where problems and geographical features also affect Greenwich we refer to them. We therefore do not attempt to prioritise the London wide issues except where they affect Bexley, (eg Crossrail, DLR, River crossings etc) and where local knowledge is needed to correct misapprehensions that arise when a strategic view ignores facts on the ground. Most of the policies have evolved as a result of an emerging consensus based on experience, with which we largely concur. NEFG was involved in the Public Inquiries into the proposed Thames Gateway Bridge (2005 6) and Howbury Park/Prologis (2007) schemes and examined the Crossrail Hybrid Bill closely, but after consultation with the Private Bills Office decided it was not necessary to get involved. Our more detailed comments are set out in paragraphs below, with appendices referring to individual page references in the three public consultation drafts. Comments on Public Consultation Draft documents: Shaping London the London Plan, the Mayor s Transport Strategy and Rising to the Challenge. General 1.0 Bexley LA21 NEFG has welcomed the opportunity to examine these three documents in hard copy. We have no major disagreements with any of the stated objectives, but consider that the broad brush approach necessarily adopted in such strategic plans may have missed serious considerations at local level, which might conflict with some of the proposals. In considering transport proposals in particular it is necessary to examine the details of such proposals to ensure that they do not create more and unnecessary problems in the course of trying to solve existing problems Such problems often include negative impacts on the environment, whether the environment experienced by the human population or the natural environment valued by people as providing the quality of life they want. One aspect in which these documents appear to be deficient is the interaction between development proposals, transport proposals, and environmental quality. While improved environmental quality is regarded as an aim it is not always clear how it is proposed to ensure that this is actually achieved. See comments on Chapter 1 of London Plan below.

2 1.2. We will therefore comment on the basis of our local knowledge of some significant practical considerations which should be taken into account in assessing proposals to avoid creating both physical and environmental problems and a political backlash. The principal of caveat emptor applies particularly when an authority such as the GLA or TfL is presented with a proposal by developers including London Borough councils, anxious to push a project forward and so not assessing some of the practical problems visible to local residents. Geography, Road Proposals and the existing road network. 2.0 One problem apparent at local level is that planners tend to work from two dimensional maps ignoring the topographical third dimension, which can have a significant effect on the practicality of proposals put forward. 2.1 While the River Thames is now regarded as a barrier to movement, (before the invention of the internal combustion engine), river transport was in fact usually quicker than land transport. There are other reasons for restrictions on the transport network in the northern part of Bexley and in Greenwich. Any proposals will have to take into account the escarpment running east west, south of the Thames from Deptford to Dartford. This creates slopes that have historically created an obstacle to land transport and still do to a considerable extent. With a few exceptions the main transport arteries run parallel to the river and the escarpment, e.g. north Kent line, A206 and A2016. There are a limited number of places along this escarpment where the gradients are lower and north south movement is possible. This has resulted in transport hubs, notably in the Deptford/west Greenwich area, at Woolwich, at Dartford and to some extent at Erith. 2.2 The obvious exception to this is the Blackwall Tunnel approach, but this was only constructed in the 1960s and involved major engineering work to make a large cutting through the escarpment. The Blackwall Tunnel was originally built as a local crossing between the dockland and industrial zones north and south of the river. Turning this into a strategic crossing has already involved massive engineering work and still creates significant congestion. 2.3 This example should be borne in mind when considering proposals for a crossing at Gallions Reach and various proposals centered on Abbey Wood station. The original East London River Crossing of was based on strategic proposals in the Abercrombie report of 1943, which exploited one of the few minor valleys which provided a natural route through the escarpment east of Shooters Hill. As the proposal had a massive effect on the existing population of Plumstead and on the open spaces on Shooters Hill, particularly Oxleas Wood SSSI, it aroused opposition which eventually led to the proposal being withdrawn in The smaller proposal for Thames Gateway Bridge aroused similar opposition at the inquiry of , because it ignored the need for an adequate road network south of the river and would have created a massive increase in traffic on a road network which already has difficulty in coping with the current load

3 2.4 The problem of the existing road network will create problems for rail proposals terminating at Abbey Wood and the limited amount of rail capacity will have a similar effect on the Prologis project at Howbury Park, Slade Green. 2.5 While the road network converging on Erith has less capacity than that converging on Woolwich it still provides better access from the higher part of Bexley south of the escarpment to the river and the road and rail corridor south of the river than is possible at Abbey Wood station. Major traffic developments at Abbey Wood station could be expected to have a similar effect on Knee Hill, Lessness Abbey Woods (in Bexley) and Bostall Heath and Woods (in Greenwich) as the East London River Crossing would have had in the relevant parts of Greenwich. Rail proposals and problems of congestion. 3.1 Bexley Natural Environment Focus Group therefore strongly supports the Crossrail proposal, provided this is extended east of Abbey Wood station. There are proposals by local authorities to use Transport and Works Act procedures to extend Crossrail to Gravesend or Ebbsfleet. An Ebbsfleet link would create an interchange with the Channel Tunnel Rail Link and so with high speed rail links currently proposed to extend to the rest of the UK. At local level such an extension would disperse the traffic generated by passengers trying to access Crossrail. The original proposal envisaged Abbey Wood station as the only access point south of the Thames, with the result that all of the feeder traffic would have converged in this one point with completely inadequate road links and parking capacity. The Woolwich station will spread some of this load, but would still leave far to much car traffic converging on Abbey Wood. A series of Crossrail stations along an extension as far as Ebbsfleet would disperse the feeder traffic much more effectively. It is therefore essential that the Mayor and the London Plan give their total support to an extension of Crossrail (proposed by local authorities utilizing Transport and Works Act procedures). 3.2 Any road link at Gallions Reach would create problems of access. Even the proposed ferry would require a complete new access road as the existing road network was designed before any such proposal was suggested. A road bridge at this point would require substantial road links to overcome the congestion on the existing road network. The problems over the East London River Crossing and the Thames Gateway Bridge have already demonstrated that. A public transport crossing at this point could be designed in such a way as to eliminate these problems. A link from Gallions Reach to Abbey Wood would still create traffic problems at Abbey Wood and would do little to improve access to work and to the wider London public transport network for people in east Thamesmead, Belvedere and Erith. Evidence presented by TfL to the Thames Gateway Bridge Inquiry did in fact imply this, but was not examined as fully as it might have been. Any public transport link at Gallions Reach should therefore be extended further east than Abbey Wood, preferably as far as Erith, where it could be fed by the local bus routes, which converge there. Designing such a route through the already developed areas would however be problematic.

4 3.3 The Howbury Park road rail interchange at Slade Green has already received planning permission, despite evidence over the limited number of train slots available. This congestion of rail movements has parallels with the road congestion around Abbey Wood station. If the proposed Crossrail extension happens the number of rail slots would be reduced further. An alternative site for such an inter change without this degree of rail congestion should be found. This is a prime example of how a strategic planning process should be used to locate the most appropriate sites within the rail network, rather than allowing the process to be driven by an individual project based on an advantageous land deal without regard to the practicalities of rail movements. 4 Conclusion We would like to draw attention to our comments in Appendix 3 on the Mayor s economic Strategy, Proposal 2c (p41). Table 2 indicates that London is ranked number 1 for both internal and external transport links. By contrast London is only ranked 14 th for quality of life and 27 th for freedom from pollution. We therefore consider that it is more urgent for the Mayor to tackle the environmental problems that already exist rather than to add an already highly rated transport system. Appendix 1 comments on The London Plan Public Consultation Draft Chapter 1 This introductory chapter sets out a number of worthy principles but is less clear as to how these principles should be achieved, and how different aims can be reconciled. Para 1.37 This principle is a truism, but we are concerned as to how these aims can be reconciled with environmental criteria dealt with elsewhere. Para 1.42 (5 th bullet point) There is no clear mechanism in the rest of the plan as to how to minimize such negative impacts. Para1.43 We note the approach for planning to be consensual, but there is no indication of whose consent is required or how different viewpoints can be reconciled. Chapter 2 Policy 2.18 Green Infrastructure Bexley LA21 NEFG strongly supports the principles of Policy 2.18 and has been involved over many years in discussion meetings organised by L B Bexley on this topic. We are concerned whether other policies within the London Plan can lead to conflicts with Policy 2.18 and have not been able to establish where in the document there are mechanisms for preventing such conflicts.

5 Chapter 6 Para 6.2 Refers to positive and negative effects on areas surrounding transport infrastructure but does not give either here or elsewhere any indication of how these might be balanced or the negative effects neutralized. Such negative effects are very important to the people affected and in the case of the proposed Thames Gateway bridge it was these negative effects which created the degree of opposition which the project faced, (i) at public inquiry (2005 6) and in both (ii) parliamentary (2005) and (iii) local elections (2006) in the L B Bexley, resulting in one parliamentary seat changing hands and a landslide defeat for the previously majority Labour group which was perceived as being lukewarm in its opposition. Para (Map 6.1 p149) Describes the very welcome Crossrail project as at present approved by Parliament. However, Map 6.1 showing the south eastern branch terminating in mid air in fact at Abbey Wood station, shows the weakness of the present scheme. As originally conceived Abbey Wood was to have been the only Crossrail station south of the R. Thames and would in consequence have attracted car journeys to an extent that no road network could have coped with and would have made car parking impossible. The addition of a station in Woolwich has reduced this problem slightly but not enough. It is therefore essential that the Mayor and the London Plan give their total support to an extension of Crossrail (proposed by local authorities utilizing Transport and Works Act procedures), to either Ebbsfleet or Gravesend providing a link to the Channel Tunnel link. This will allow access to Crossrail at a number of stations reducing the traffic and parking problems at each to more manageable proportions and also maximizing the benefits of Crossrail by providing a link to the high speed rail link. Policy 6.15 We would question whether such projects will work in practice. In the case of the Howbury Park (Prologis) scheme at Slade Green, there is a conflict with the needs of existing rail traffic. There are very few slots available for freight rail movements in and out of the facility. There is a strong likelihood that those managing the facility will have to side line the rail aspects and in practice it will become a road transport depot without a significant rail dimension. Appendix 2 - Comments on Mayor s Transport Strategy Public Consultation Draft Page17 The diagram of significant additions to capacity in London is so vague as to justify our comments on the lack of relationship to the physical problems on the ground. The same goes for Fig 3 on page 37. Page 25 Table E40 goals and proposals see comments on Thames River crossings in our main submission. Page 28 para 9 We endorse the concern over congestion and poor environmental quality. More could be included in the plan on how to reduce these. As indicated in our main submission some proposals may increase the problem.

6 Page 29 para 12 Experience in Bexley indicates the need for orbital public transport capacity, which the proposed hub and spoke approach does not appear to meet. Page 31 para 32 Proposes that London s transport system should achieve the highest environmental standards. In our main submission we indicate where some proposals can have the opposite effect. Page 36 Fig 2 includes enhancing the built and natural environment and improving air quality, health and noise impacts, not all proposals are compatible with this. Page 41 para 55 We endorse this paragraph provided it also supports the Crossrail to the Channel Tunnel rail link at Ebbsfleet. Pages para 67 We have dealt with the proposed rail freight hub at Howbury Park (Slade Green) in para 3.2 of our main submission. Pages Section 5.8 River Crossings dealt with in sections 2 & 3 of our main submission. Pages 282/283 We note that Proposal 39 for the Gallions Reach and other east London crossings is unfunded. Page 299 Policy 34 While it is appropriate for the Mayor and TfL to secure developer contributions to transport proposals which meet the appropriate criteria, this should not allow developers proposals to be supported where they do not meet such criteria. Page 304 Fig 84 We support the goal of enhancing the quality of life for all Londoners. It is important that the word ALL is emphasised and that this is one of the criteria which must be met is assessing transport proposals. Appendix 3 - Comments on Rising to the Challenge Mayor s Economic Strategy Public Consultation Draft Page 41 Proposal 2 c - states that The mayor will monitor the factors effecting London s competitiveness so as to identify where corrective action is needed to address factors having a negative effect. We note that in Table 2 that London is ranked number 1 for both internal and external transport links. This therefore suggests that transport is not a negative factor affecting London s competitiveness and while there can always be improvements the situation is not such that such improvements should be allowed to have a negative effect on other factors, which may have a negative effect. For example in Table 2 London only ranked 14 th on quality of life and 27 th in freedom from pollution. Page 51, Table of the Mayor s proposed carbon mitigation programme gives a block in the block diagrams for electric vehicles but does not indicate whether this includes public transport. Many modes of public transport are in fact electric and encouragement of public transport in general results in a reduction in the use of fossil fuels.

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