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The Lower Thames Crossing would be the UK’s largest road project since the M25 motorway ring around London was completed in 1986. Cost: an estimated £8.2 billion.
It is the largest project envisaged in part 2 of the government’s Road Investment Strategy (RIS2) that covers the period 2020-25.
And it would blast another hole in attempts to meet the UK’s own inadequate greenhouse gas emission reduction targets, let alone meaningful targets set by climate scientists.
The Thames Crossing Action Group, which coordinates local opposition to the Lower Thames Crossing monstrosity, is asking people to write in to a consultation about the project (see below). Of course more direct forms of action may be needed, too.
The Silvertown tunnel project, which has faced opposition in east and south east London, is further ahead than the Lower Thames Crossing. Contracts have been signed with developers, and within weeks the tunnel boring machine could get going.
The Lower Thames Crossing is one more reason to stop the Silvertown tunnel. If one alien abomination is created, the other even bigger monster could follow.
To help combat dangerous climate change, and combat social inequality, transport policy needs to prioritise cutting the number of cars on the road, fast.
The Welsh government’s decision to suspend all new road building shows the way forward. Such an approach should also include massive investment in cheap or free public transport, and a concerted effort to develop urban transport systems with fewer cars.
The Transport Action Network, which campaigns to make transport work for people, launched a legal challenge to RIS2 investment strategy, and when that failed, pressed on with pressure on the government to drop numerous road-building schemes.
Obstructing these schemes, one after another, is part of the fight to avert dangerous climate change.
Research by the Transport for Quality of Life group shows that the government’s investment plans will, by 2032, push greenhouse gas emissions from the UK’s strategic road network up by 20 million tonnes per year of carbon dioxide equivalent – while, to meet climate targets, they need to go down by 167 million tonnes per year.
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Support TCAG: send in a submission
The Lower Thames Crossing project has not yet received a Development Consent Order from the government – the first step for any major infrastructure project – and the Thames Crossing Action group are trying to make sure that it never does.
They are asking people to take a few minutes between now and Monday to contribute to a consultation about the scheme. Note: you do not have to write a long letter. A few sentences about why you think the project is a bad idea is fine.
TCAG have made a step by step guide to the consultation process here.
You can email in your objections to the project to LTC.CONSULTATION@TRAVERSE.LTDor send them by post, for free (no stamp needed) at FREEPOST LTC CONSULTATION.
The deadline for the consultation is Monday 20 June at 23.59!!
I wrote a submission that focused on the climate impact of the project. Here it is.
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Submission to the Lower Thames Crossing Local Refinement Consultation
I submit that, due to the contribution of the Lower Thames Crossing (LTC) to global warming, the only responsible course of action by National Highways is to cancel the project.
National Highways emissions estimates
You released your estimates of carbon emissions only in response to a Freedom of Information request by Ms Rebecca Lush. These estimates are of 2 million tonnes of CO2e for construction, and 3.2 million tonnes for sixty years of operation. (“Climate change: Lower Thames Crossing CO2 impact figures revealed”, BBC web site, 6 December 2020; letter from Jonathan Drysdale of HE to Rebecca Lush, 4 December 2020, available on the WhatDoTheyKnow web site, “Carbon assessment of LTC for 60 year appraisal” page.)
I believe that National Highways is very well aware that the project is incompatible with UK climate targets, and tried to keep these figures concealed for that reason.
Presentation of emissions estimates
When National Highways finally released the carbon emissions figures, you attempted to trivialise them, by presenting them as proportions of the UK’s carbon budgets, e.g. 0.013% of the third budget, 0.089% of the fourth budget, 0.013% of the fifth budget. (J. Drysdale letter to R. Lush.)
This methodology strikes a sharp contrast with the way that National Highways presents the supposed benefits of the project. For example it lists as benefits “journey time and vehicle operating cost savings”, and, as “wider impacts”, that the project would “reduce perceived distances between businessses, boosting their productivity and economic output”. Both of these are accompanied by apparently large monetary estimates (£1253 million and £1657 million respectively), which can be little more than speculative. (Combined Modelling and Appraisal Report, Appendix D, Table 2.1.)
If the carbon emissions are compared to anything remotely relevant, they look much more worrying. One place to start would be with domestic transport sector emissions.
The government’s Net Zero Strategy calls for reductions of 34-45% (42-56 MtCO2e/year) in domestic transport sector emissions by 2030, and of 65-76% (81-94 MtCO2e/year) in domestic transport sector emissions by 2035 (Net Zero Strategy: Build Back Greener, 2021, page 154).
All the available research and commentary shows that the UK is on track to miss such targets. For example Lord Deben, chair of the Climate Change Committee – hardly the most vocal critic of government climate policies – wrote to the government in 2018, drawing attention to how far behind it had fallen in terms of reducing transport sector emissions.
Compared to the CCC’s own estimate of the domestic transport sector reductions needed by 2030, 68 MtCO2/year, i.e. higher than the government’s, Deben stated that the CCC projects a shortfall of 14 MtCO2e/year due to a “policy gap”, and a further 42 MtCO2e/year “at risk due to lack of firm policies and measures or those with delivery risks”. (Letter from Lord Deben to Chris Grayling and Greg Clark, 11 October 2018.)
There is no sign that the government is closer to meeting its targets as a result of its activity in the three-and-a-half years between then and now. The failure to cut transport sector emissions could without exaggeration be described as a national emergency.
If the LTC is built, it will make this emergency worse.
During the construction period, the LTC would add more than 0.3% each year to total domestic transport emissions (assuming five years of construction, as a proportion of 2019 emissions), at a time when they should be falling sharply.
During the sixty years of use, the LTC would each year add more than 0.04% of total 2019 domestic transport emissions. And this in a time period that stretches several decades (between four and six, depending on how you count) past the point at which transport sector emissions should be reduced to zero.
There are other, indirect effects to take into account, including:
□The opportunity cost, in climate policy terms, of financial and other resources being put into the LTC, that could rather have been put into projects that rapidly reduce transport sector greenhouse gas emissions; and
□The cumulative effect for transport policy of building more roads, including the induced traffic effect, encouragement to people to buy cars, etc, all of which impacts negatively on the objective of reducing greenhouse gas emissions.
The need to adopt the precautionary principle with respect to infrastructure
It is vitally important, from the standpoint of greenhouse gas emissions reduction, that all governments, government departments and businesses take account of the body of research showing that all new fossil-fuel-intensive infrastructure – which includes roads, and will continue to include roads for decades, even if the most optimistic forecasts of the effect of introducing electric vehicles are realised – will put climate targets further out of reach.
A summary of this research published in 2019 concluded that: “[L]ittle or no new CO2-emitting infrastructure can be commissioned, and […] existing infrastructure may need to be retired early (or retrofitted with carbon capture and storage technology) in order to meet the Paris Agreement climate goals.” This paper, by an international team of researchers headed by Dan Tong of the University of California, presented estimates that existing energy, transport and built infrastructure will cumulatively emit about 658 Gt CO2, compared to a total global budget of 420-580 Gt CO2 to achieve the 1.5°C target, and 1170-1500 Gt CO2 to achieve the 2°C target. (Dan Tong et al, “Committed emissions from existing energy infrastructure jeopardize 1.5degC climate target”, Nature vol. 572 (15 August 2019), pages 373-377.)
Earlier work, published in 2010, warned that “sources of the most threatening emissions have yet to be built”, and that CO2-emitting infrastructure would expand, “unless extraordinary efforts are undertaken to develop alternatives.” That paper showed that the transport sector is the second largest source of emissions globally after the energy sector; and that the rapid expansion of the transport sector, principally road transport, globally was a source of climate danger. (Steven Davis et al, “Future CO2 emissions and climate change from existing energy infrastructure”, Science vol. 329 (10 September 2010), pages 1330-1332.)
Another paper, published in 2016 with a specific focus on urban infrastructure, warned that new infrastructure in cities “could consume a considerable share of the remaining carbon budget as it is a carbon-intensive process”. (Felix Creutzig et al, “Urban infrastructure choices structure climate solutions”, Nature Climate Change vol. 6 (December 2016), pages 1054-1056.)
There is no indication that National Highways has consulted this extensive body of literature, or commissioned research into its relevance to the LTC, which it has pointed to as the largest road-building project since the M25. From a climate policy point of view, this is a reckless mistake that should be corrected urgently.
Comment on the Silvertown Tunnel project
As author of a report on the Silvertown Tunnel project, I would like to point out that an honest appraisal of the project with respect to climate policy has never been conducted. When the documentation for the project was prepared, prior to the Development Consent Order being issued in 2018, the connections between road building, induced traffic, transport sector emissions and climate policies were much less clearly understood than they are now. (See S. Pirani, The Silvertown Tunnel is in a hole, so Stop Digging (2020), accessible on Transport Action Network web site.)
There has been a substantial shift since that time, towards a recognition that all projects that enhance either fossil fuel production or fossil fuel use should be questioned. It is to be hoped that National Highways will not repeat the policy mistakes by Transport for London and the Greater London Authority, that have led to preparatory work on the Silvertown Tunnel going ahead, helping to make it all but certain that London’s greenhouse gas emissions reduction targets for the transport sector will be missed by a wide margin.
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