Time’s running out: Here’s some help in saying NO to TfL’s toxic Silvertown Tunnel

Rochester Way traffic jam

A southbound jam on the A2 in Kidbrooke – in 2014, TfL predicted 20% extra traffic would use this route, adding to pollution and congestion

Transport for London’s consultation into the Silvertown Tunnel ends on Sunday 29 November. You can find out more about why the tunnel’s such a bad idea on the rest of our website. We’ve already submitted our response – and you should submit yours too at www.tfl.gov.uk/silvertown-tunnel.

If you’re looking for some ideas, here are some suggested responses. Everyone will have a slightly different view, so feel free to add your own comments, or amend ours as you see fit.

(Want more detail? Here’s our FULL 18-page response.)

Wherever you live, please also tell your local councillors, London Assembly members and MP you object to the Silvertown Tunnel. Find them at www.writetothem.com.

Do you support the Silvertown Tunnel scheme as a means to address congestion and closures at the Blackwall Tunnel, and support future growth in London?


If you have any comments about our intention to apply for consent to build and operate the Silvertown Tunnel scheme, please let us know in the space below.

The Silvertown Tunnel will not reduce congestion. Indeed, it is very likely to increase southbound congestion on the A102 and A2, and general congestion on the A1261 Aspen Way and A1020 Leamouth Road, Lower Lea Crossing and North Woolwich Road, and on other roads in east and south-east London.

[You may have a better idea of how the Silvertown Tunnel will affect roads in your part of London – so please feel free to add your own thoughts and name the roads you think will be affected.]

London’s future growth would be better secured by investment in public transport provision.

It is inappropriate that this statutory consultation is taking place on the strength of preliminary assessments. This means environmental risks have not been fully assessed in the final public consultation. We are not being presented with full assessments.

Connections to the existing road network: We have described the proposed design of new junctions to link the tunnel to the existing road network. If you have any comments on the design of these new junctions please let us know in the space below.

The only changes envisaged to the existing road network are in the immediate vicinity of the proposed tunnel. The consequences of the scheme further north and south have been ignored.

The planned widening of the Blackwall Tunnel Southern Approach fails to include provision for the inevitable increased traffic heading for the two tunnels. Junctions on the A102 and A2 further south, for instance at the Sun-in-the-Sands, are already under considerable pressure, and are set to remain so. Many residents fear the loss of their homes in the future.

The two A102 flyovers, at Woolwich Road and Blackwall Lane, will experience exceptional strain on their infrastructure. Engineering assessments already indicate they are in a poor condition. This extra strain will result in considerable additional expenditure to ensure their safety.

North of the Thames, the proposal to elongate the Tidal Basin Roundabout – where there are many homes under construction – will result in a sharp decline in the area’s air quality and a huge increase in noise pollution.

Currently, entry and exit roads to this roundabout and links to the A12 and A13 are narrow and complex. These roads are likely to become congested and development in the area will not permit any changes to the layout.

Construction impacts: Our proposals for constructing the Silvertown Tunnel are at an early stage, although we have included our initial thoughts on what temporary road closures and diversions might be necessary. If you have any comments on our construction proposals and their potential impacts please let us know in the space below.

The Silvertown Tunnel’s heavy reliance on the A102/A2 corridor will be exposed by four years of disruption if construction goes ahead.

Public transport users and residents of Greenwich Millennium Village, City Peninsula and nearby developments will bear the brunt of this. North Greenwich station already struggles to cope with the evening rush hour and O2 events. Disruption from road closures and construction traffic will make this worse.

North of the river, the effects of 200 lorries per day on the Silvertown worksite will harm the environment for those moving into new developments in this area.

While the Greenwich side will see fewer movements, the peak period of 140 lorries per day will add to the noise pollution faced by those who live near the A102, particularly around Westcombe Hill and Siebert Road.

User charges: As part of our plans for the new Silvertown Tunnel we are proposing to apply a user charge to both the existing Blackwall Tunnel and the proposed new tunnel in order to manage traffic demand and pay for the new tunnel to be built. The level of the charge would be set closer to the time that the Silvertown Tunnel opens, taking account of the conditions that exist at that time. Further details are set out in the ‘Preliminary Charging Report’, which is available to download. If you have any comments on our proposals for user charging please let us know in the space below.

TfL suggests it can limit the number of vehicles using the Silvertown and Blackwall tunnels by applying user charges. But as TfL will always be under pressure from users and politicians to make these charges affordable, it won’t be able to react to traffic volumes as easily as it suggests.

If these charges are the only thing protecting our neighbourhoods from excess traffic and additional pollution, TfL needs to provide robust evidence to show that the number of vehicles will be kept at a manageable level. TfL has not provided sufficient evidence so far.

The suggested user charges place an unfair burden on residents and businesses of south east London and Kent, as the peak hour charging applies to the northbound tunnel in the morning rush hour and the southbound tunnel in the evening.

Driving a car will remain the cheapest method of crossing the river at any time outside rush hour (including at weekends, when no charges will apply).

At rush hour prices, driving is cheaper if the car carries just one additional passenger. This seems unlikely to encourage drivers to shift to other modes of transport, meaning demand for the tunnel will still be very high.

Environmental effects: We have described the likely environmental effects of the Silvertown Tunnel scheme and described some mitigating measures we would take. Further details are set out in the ‘Preliminary Environmental Information Report’ (PEIR), which is available to download. If you have any comments on the likely environmental effects of the scheme and the proposed mitigation measures, or on any of the information set out in the PEIR, please let us know in the space below.

There isn’t enough definitive information presented here to allow anyone to come to the conclusion that the tunnel is safe.

Air quality modelling will only be completed after the scheme is no longer being consulted on. We should not be building new roads that risk placing our neighbourhoods in danger. TfL argues the air quality impact will be limited because user charges will limit the number of vehicles using the crossing. If this assumption isn’t safe, then neither is any reassurance about pollution.

The disruption caused while the tunnel is being constructed will be immense. TfL hasn’t done enough to reassure anyone that construction traffic can be kept off local roads, or that it can mitigate the noise of construction.

Traffic impacts: We have described the traffic impacts of the Silvertown Tunnel scheme and explained that we would monitor its effects on traffic before and after opening. Further details are set out in the ‘Preliminary Transport Assessment’ and ‘Preliminary Monitoring and Mitigation Strategy’, which is available to download. We would take appropriate measures to mitigate any negative effects that might occur as a result of the scheme. These measures could involve adjusting traffic light timings or other traffic management measures. If you have any concerns about the effect of the Silvertown Tunnel scheme in any particular location, or comments about how we might mitigate these, please let us know in the space below.

Even before the new tunnel is built, there is already heavy traffic through the southbound Blackwall Tunnel during the morning rush hour. This traffic won’t be charged at peak rates under the proposals.

There is very often congestion on both approaches to Blackwall at the weekend as people travel to shopping and leisure events on both sides of the Thames. Yet there are no plans to apply a user charge at weekends. With these facts in mind, it is unlikely that the planned user charging scheme will stop the congestion and pollution we see at present.

On both sides of the river, the new tunnel will funnel traffic in both directions into road networks that aren’t ready for the additional vehicles.

As the intention is to direct HGVs to use the new tunnel, northbound HGV traffic will be encouraged to use the A13. Pollution readings from the A12/A13 junction at East India Dock Road suggest this route is already over-burdened by traffic.

Meanwhile, southbound traffic from the existing and new tunnels will both be funnelled into the A102/A2, which already suffers from congestion, particularly in the evening rush hour, as traffic heads through Kidbrooke.

The only way to ease the burden here would be to ensure a net reduction in southbound traffic, which this scheme won’t deliver.

Much of the information that the public needs to make an informed decision on whether the Silvertown Tunnel is an adequate solution to traffic problems just isn’t available.

TfL promises to monitor traffic impacts for five years after the new tunnel opens and for two years before opening (2020 on current dates). If TfL wanted to present accurate information, this monitoring should already have started.

Cross-river bus services: The Silvertown Tunnel scheme would give us the opportunity to introduce new cross-river bus routes for east London. We have described an illustrative cross-river bus network for east London in the ‘Preliminary Transport Assessment’, which is available to download. If you have any comments on the introduction of new cross-river bus routes please let us know in the space below.

The only thing stopping TfL from running more buses across the Thames at this point is TfL. Additional single-deck buses could be run through the Blackwall Tunnel. Passengers have called for a more frequent service on the existing route 108, but these requests have been rejected.

Any other comments: Do you have any comments on any other issue connected to the Silvertown Tunnel scheme. If so, please let us know in the space below.

PFI arrangements will mean that in the long run, TfL will pay more money to build new infrastructure than would have been the case if the project was funded by central government or via bond offers. As the scheme depends on user charging to pay the construction costs, TfL has a reason to make sure traffic volumes aren’t drastically reduced – even though this is what safeguarding public health requires.

According to the scheme documents, one of the main reasons for building the tunnel is to make the road network more resilient to blockages and closures of the Blackwall Tunnel.

Yet the scheme retains a tunnel built for horse traffic in 1897 and does not attempt to rectify its design shortcomings. It seems likely that any resilience improvements will be limited – particularly as both tunnels will still rely on the Blackwall Tunnel Southern Approach and its two flyovers that TfL assessments state are in a “poor” condition.

The consultation documents only present the best case scenario for use of the Silvertown Tunnel after it’s built. It does not adequately reflect the risks to local neighbourhoods if the best case doesn’t come to pass. For example, the documents don’t reflect the costs associated with ill-health brought about by higher levels of air pollution – early death, loss of productivity through ill-health, healthcare costs, etc, if it’s found that current models are incorrect and there is an increase in vehicle emissions once the tunnel is built.

£1 billion spent on this scheme is £1 billion that isn’t being spent on improving public transport in east and south-east London. Public transport services on this side of the capital are a long way behind provision to the north and west. Spending money on roads before public transport will widen this gap.

Defra’s air quality models, used for this scheme, depend on the assumption that diesel vehicles will meet EU standards by the compliance date. The recent Volkswagen scandal has shown this assumption to be unsafe. Much more analysis of the safety of increased volumes of traffic needs to be carried out.

TfL argues that development won’t happen without enhancing the road network. But it also argues that development is already planned, and so will require additional roads. Both of these things can’t be true. Considering that development across east and south east London has already been boosted by public transport improvements, it seems more likely that neither of these things are true.