“EWT is fundamentally opposed to the plans for a Lower Thames Crossing and we have serious concerns about the impact of these proposals on the wildlife and habitats of Essex. The cumulative impacts from this scheme in terms of biodiversity loss, habitat damage, increased noise, associated development and road lighting could potentially have a serious detrimental impact on the south Essex landscape. We will rigorously seek appropriate mitigation and compensation for the lost or damaged habitats, impacts on protected and priority species and opportunities to enhance, restore or create new habitats as part of the local ecological network. Our aim will be to ensure that there is no net loss to biodiversity as a result of this infrastructure project.”
Background and detail
Following the Highways England consultation in March 2016 on proposals for a Lower Thames Crossing, the Government has announced its decision on the preferred route. The new road (Option C) will link the M25, near North Ockendon, Essex, with the A2 near Shorne, Kent, passing through greenbelt land. It will cross the A13 at Orsett and connect land east of Tilbury to land east of Gravesend via a 2-mile bored tunnel under the River Thames. The Government argues that a new crossing is needed to reduce congestion at the existing Dartford crossing and unlock economic growth, supporting the development of new homes and jobs in the region.
EWT is fundamentally opposed to the plans for a Lower Thames Crossing and we have serious concerns about the impact of these proposals on the wildlife and habitats of Essex. We accept that the choice of a bored tunnel avoids direct impacts on the internationally important wetland and coastal habitats of the Thames Estuary Ramsar/Special Protection Area. However, the location of the tunnel portal to the north of the crossing (and, in particular, the potential works area associated with the tunnel portal) will destroy habitats of importance for protected water voles, reptiles and rare invertebrates.
The new road will result in impacts on a further three designated Local Wildlife Sites and four areas that support UK Biodiversity Action Plan (BAP) priority habitats, including ancient woodland. One of the affected local wildlife sites, Low Street Pit, is an important site for rare Thames Terrace invertebrates.
Overall, the new road will result in loss or damage to important habitats and fragmentation of the habitats that remain, with accompanying impacts on protected and priority species. The cumulative impacts of noise, road lighting and the visual intrusion of ‘man-made’ infrastructure will combine to reduce the remoteness and wildness of the landscape and its tranquillity.
The Trust believes that poorly planned and assessed road developments can have a negative impact on the natural environment (sites, habitats, species and ecosystem function). Road developments should be considered only as a last resort and as part of a sustainable transport strategy, which should be strategically planned and fully integrated with conservation objectives and the land use planning process. This should:
- prioritise environmentally sensitive maintenance and improvement of the current road network over new road schemes;
- reduce the need to travel, for example through well designed towns, cities and neighbourhoods, and improved transport technology;
- promote less carbon intensive forms of transport;
- promote reductions in private vehicle use in order to reduce traffic levels, fuel consumption and vehicle emissions, including fiscal measures and car share schemes;
- minimise dependency on private vehicle use by increasing and improving public transport and active travel routes, which are well connected to essential services;
- promote walking, cycling and other forms of active travel and promote active travel routes which are easy, safe and attractive to use; and
- ensure no net loss to biodiversity.
The LTC scheme appraisal places undue emphasis on the theoretical economic benefits of the scheme. It places insufficient emphasis on all other impacts of the scheme, including the economic costs. These include impacts on biodiversity, ecosystem services, community health and tourism.
The scheme appraisal has not taken account of the effect of the Northern link road in stimulating car-based development. It consequently also fails to take account of the resulting congestion on the new road and feeder roads, arising as a result of new (induced) car trips to new housing, retail and business parks.
We have major concerns that the new road will encourage increased car dependency, generate induced traffic and hence fail to achieve the stated aim of relieving congestion. At the same time it will cause serious environmental damage, adversely impacting on biodiversity and increasing CO2 emissions which contribute to climate breakdown.
The cumulative impacts from this scheme in terms of biodiversity loss, habitat damage, increased noise, associated development and road lighting could potentially have a serious detrimental impact on the south Essex landscape.
We will rigorously seek appropriate mitigation and compensation for the lost or damaged habitats, impacts on protected and priority species and opportunities to enhance, restore or create new habitats as part of the local ecological network. Our aim will be to ensure that there is no net loss to biodiversity as a result of this infrastructure project.
We will also seek to ensure that all opportunities are taken to:
- reduce environmental damage through good design
- secure net biodiversity gain by creating, enhancing and managing ecological networks, associated wildlife habitats and key species populations
- ensure any landscaping is appropriate to the natural character and ecological functionality of the area.
Finally, we aim to impress upon the Government and Highways England the importance of species recording and long-term post-development monitoring. This will be essential in relation to both the impacts of the new road and the enforcement and implementation of any mitigation/compensation measures undertaken.