InfoMinor Refinement Consultation

TCAG comments on LTC Minor Refinements Consultation

Since the consultation launched on 17th May 2023 we’ve been looking through the consultation booklet, here are a few of our initial comments on the LTC Minor Refinements Consultation.

The first thing to mention is how we and many others are saying how much gobbledegook there is in the consultation booklet.  It certainly generates more questions than answers, so make sure to get your questions in to NH/LTC asap for the best chance of possibly getting answers in time to submit your response.

There are no consultation events or webinars for this consultation, so any questions have to be either emailed to or asked over the phone 0300 123 5000.  Please be aware that if you call you will be speaking to an answering service who will take your details and have someone call you back, you will not get answers immediately.

If you want to respond to the consultation via mail there is not a FREEPOST address as there was for previous consultations.  You can either request a stamped addressed envelope from NH/LTC, again by emailing or calling, otherwise you will have to pay for stamps to send it to the consultation address.

The Foreword

Even just reading the foreword by LTC Executive Director, Matt Palmer generated more questions, and we’ve emailed asking for information and evidence to back up some of the claims he appears to be making about the proposed LTC, as we question the validity of much of what is being said.  We put some questions to NH/LTC and below are the responses we have received, many of which we do not believe really answer the questions in a satisfactory manner.  We refuse to simply believe what NH/LTC say just because they are telling us, we want evidence to back up their claims and apparently it seems they are, in our opinion, unable to do that in many cases.

  • How would the proposed LTC be vital in tackling the daily delays and frustration caused by congestion at the Dartford Crossing, when evidence shows that it would still remain over design capacity, and that there wouldn’t be adequate connections to allow traffic to migrate between the two crossings when there are incidents?

The Project would include junctions with key parts of the strategic road network (SRN), such as the A2/M2, A13/A1089 and M25. It would also provide connections to a number of local roads via the junctions at Orsett Cock in Thurrock and at Gravesend East.

The new road would feature advanced safety systems, including variable mandatory speed limits, red-X lane signalling to support incident management, stopped vehicle detection systems, CCTV, and emergency areas for road users to access in an emergency. Incident management plans and protocols would play a key part in minimising the impact of incidents.

The number of incidents and collisions at the Dartford Crossing would fall as a result of the reduced traffic flows, which would improve resilience at both crossings. For more information about the traffic modelling, see 7.7 Transport Forecasting Package, which is Appendix C of the Combined Modelling and Appraisal Report [Application Document APP-523]. As a result of the around 20% reduction in traffic in the peak hours the impact of incidents on the road network would be reduced and the road network would be able to recover faster.

  • Please confirm what percentage of traffic you estimate the proposed LTC would take away from the Dartford Crossing

Traffic modelling presented as part of the application for development consent predicts that, compared with the situation without the Project, the overall level of traffic using the Dartford Crossing is forecast to reduce by around 20% in the peak hours in the year the road opens and remain below current levels for the foreseeable future. Average speeds on that part of the network would rise and journey times would become more reliable, reducing journey times at the Dartford Crossing in line with the Scheme Objectives agreed with the Department for Transport (DfT).

  • Please explain how you calculate that the proposed LTC would be the greenest road ever built, and provide evidence to back up this claim.

There are a number of ways in which the Lower Thames Crossing will be the greenest road ever built in the UK.  A Pathfinder scheme, the Lower Thames Crossing is exploring ways to achieve carbon neutral construction, and will pass on learnings to future major infrastructure projects.  The amount of carbon expected from construction has been significantly reduced by optimising the design of the road, as well as the methods and materials used to construct it.  For example, we are considering alternatives to carbon intensive materials such as concrete and steel; and exploring removing diesel from our work sites by only using hydrogen and electric powered plant.

The project is the first major UK infrastructure project to put carbon reduction at the heart of its procurement process, with incentives for contractors to drive further continuous carbon reduction.  Due to planned government policy, (outlined in the Transport decarbonisation plan – GOV.UK ( by the time the new road opens, brand new petrol and diesel cars will no longer be offered for sale.  The government’s plans to decarbonise cars and goods vehicles would cut the 60-year forecast of carbon emissions from Lower Thames Crossing traffic by at least 80%.

The Lower Thames Crossing is also green by design – over 80% of the road will be in a tunnel, cutting or behind an embankment to reduce its visual impact on the landscape.  Two new public parks will be created,

Chalk  Park on the south bank of the River Thames and Tilbury Fields on the north bank. Over one million extra trees will be planted in Kent, Thurrock, Essex, Havering and Brentwood.

  • Please explain and provide evidence of how the proposed LTC would connect communities.

The Lower Thames Crossing would provide much needed additional capacity and reliability that would not only improve journeys, but drive growth across the region, as well create new jobs and green spaces for the local community and wildlife. It would give millions of people more flexibility and choice regarding where they choose to work, where they live and where they get their education, through quicker and more reliable journeys. Over 400,000 more jobs would be accessible within a 60-minute commute due to improved journey times.

We are also creating around 40 miles of new and improved routes for walkers, cyclists and horseriders that will make it easier to enjoy nature as they move between parks, woodlands and heritage sites.

  • Please explain  and provide evidence of how the proposed LTC would enhance nature

The Lower Thames Crossing is green by design, and aims to give nature the chance to thrive in the area. We’re building seven green bridges to connect habitats across the new road, providing safe and easy ways for wildlife to travel between new and existing habitats along the length of the route.  We will be planting over one million extra trees in the region, and we’re working closely with wildlife experts to create bigger, better, more connected habitats across the region.  We are creating three times as much woodland as that being lost, twice as much ditch and watercourse length as that affected, four times as many ponds, and a   50% increase in hedgerow length.

  • Please explain and provide evidence/details of how the proposed LTC provides new ways to build infrastructure in a net zero future.

As mentioned above, the Lower Thames Crossing is a Pathfinder scheme, exploring ways to achieve carbon neutral construction.  This means the project will be exploring new and innovative methods of construction, power and materials to help the UK government achieve its target of being net zero by 2050 – and, crucially – the project will share its carbon reduction learnings with the next major UK infrastructure scheme. The UK will still need new infrastructure in the future, whether that be transport, homes, schools or hospitals. The challenge for the UK construction sector is how can it continue to provide that new infrastructure in a net zero future. We are determined to play a significant part in defining how that can be achieved.


Nitrogen deposition compensation changes

Despite the proposed LTC being hugely destructive and harmful, it seems NH/LTC deem it acceptable to propose reducing the nitrogen deposition compensation land further.  As you will see in our update on this, rather bizarrely one of the sites they are proposing to remove, a site in Burham, was added to the Order Limits between the Local Refinement Consultation and the LTC DCO application being submitted, without any consultation.


Northern Tunnel Portal changes

The actual position/location of where the tunnel would start/stop with the ‘outside world’ would remain in the same place.  The change is all about how the tunnel was constructed either being bored with a Tunnel Boring Machine, or created using Cut and Cover.

The change is to allow the contractor more leeway with how they construct it. Why it has taken until now for NH/LTC to decide they might need a bit more leeway on that is unknown.

To be clear the length of the tunnel does not change in length or position, just how it is physically constructed.  You can find out more about that in our Northern Tunnel Portal changes update.


Revised utility proposals (East Tilbury)

Strangely it seems that NH/LTC are proposing making some changes near the Linford/East Tilbury area that would see a section of land removed from the Order Limits that co-incidentally are being proposed for a large housing development.  Our update covers more on that, as well as info about the proposed relocation of a couple of the Utility Logistics Hubs in the area, and a proposal to change the land use status of some land following a request from a utility company.  Yet again, it seems strange to us that these changes are only just surfacing now, and we question why these changes have not been proposed prior to the DCO application being submitted.


Tunnel Boring Machine update

NH/LTC have also taken the opportunity to share an update about the possibility of using one Tunnel Boring Machine (TBM) rather than 2, if the proposed LTC goes ahead.  Our update on this explains the basics we’ve managed to get from the info in the consultation booklet, but also the long list of questions reading it generated!  We’re really not sure how they can be saying a lot of what they are saying, and also have to question why it has taken this long for them to be considering something that is such a key element of the proposed LTC.  After all if you are planning a new crossing surely one of the main aspects is how you would construct the actual tunnel for the crossing.

Whilst this is not apparently part of the consultation, as none of the questions in the response form ask about it, there is a section for ‘Other comments’ if you did want to have your say.  It appears though that ultimately, if the proposed LTC did go ahead, it would be the contractors who decide whether to use 1 or 2 tunnel boring machines.


Other comments

As always in the consultation this should be our chance to have our say.  The last question is an opportunity for ‘Other comments’.  However, in the Minor Refinements Consultation we note that question 6 states ” We welcome any other comments you, would like to make about the changes proposed to the Lower Thames Crossing as part of this minor refinement consultation”.

We are surprised that there are other changes that have not been proposed in the Minor Refinements Consultation and will be comment  to explain other things we feel are missing from the consultation!  You may wish to consider doing similar.  Together we are stronger!

We hope you have found these comments on LTC Minor Refinements Consultation helpful.

Please have your say before 23:59 on Mon 19th June 2023

Our Step by Step to Consultation has now been published to help those that may appreciate a little extra help with responding to the consultation.



Minor Refinements Consultation Updates Indexclick here

Changes to green measures in Thames Crossing plan raise more questions than answersclick here

Consultation starts on latest LTC changes including ‘freeing up’ of land near East Tilburyclick here