Yet more HE inadequacies
It probably won’t surprise regular visitors to our site that we have come across yet more HE inadequacies, this time on their official Lower Thames Crossing website.
If you click through from their official social media accounts, or search for the official LTC website online, you would expect all the latest accurate information about the proposed route, including obvious details of the current Supplementary Consultation. Wouldn’t you?!
The two URLs that Highways England are using which both point to the same website are www.highwaysengland.co.uk/lower-thames-crossing-home and www.lowerthamescrossing.co.uk.
We are now over 5 weeks into the 8 week consultation and we have noticed some seriously outdated info, and a distinct lack of info about the current Supplementary Consultation on the official HE/LTC website.
Don’t HE have some kind of obligation to provide us with accurate and adequate info?
Indeed, and as stated in the Planning Inspectorate’s Advice Note 8.1 (Overview of the nationally significant infrastructure planning process for members of the public and others) Highways England are legally required to carry our pre-application consultation on the proposed development, and the consultation material presented must be clear and informative.(1)
So what are the latest inadequacies?
Below we have listed page by page some of the inadequacies of the official Highways England Lower Thames Crossing website, highlighting the inaccurate and misleading info. Read the following and then decide for yourself if you feel HE are presenting LTC and the Supplementary Consultation in a clear and informative way.
On the home page the only suggestion that there is currently a Supplementary Consultation happening is a small update at the very bottom of the page, dated Jan 23rd. This is an extremely discreet mention considering this is the only notification on the home page of the official LTC website that is currently running.
We have screen captured the Home page and circled the reference to the Supplementary Consultation in red. Bear in mind this image shows the page zoomed right out to allow us to screen capture. If you visit the site/page yourself you will likely need to scroll down before even seeing the area circled in red.
The image used is a stock image from the Statutory Consultation which does not give the impression of drawing attention to something new and current. The title of the section is abbreviated so that you can’t even see the wording of Supplementary Consultation in the title. It’s almost like HE are trying to hide the fact there is a consultation happening!
We have highlighted some of the errors on the About page in red in the image below.
HE are showing the route at approximately 14.5 miles, yet in the latest update they are now referring to it as being approximately 14.3 miles.
We have always questioned “3 lanes in both directions” since they started announcing it as that during the 2018 Statutory Consultation, as there was a 2 lane section around the A13 junctions. However, now they have actually announced in the latest update that the LTC southbound between the M25 and A13 will be 2 lanes, so again this is not a true and accurate representation.
“two 2.5 mile (4km) tunnels” is also inaccurate as the latest changes state that the tunnels will now be two 2.6 mile (4.3km) tunnels.
We also question how they get the figure of 90% extra road capacity, and have emailed to ask for an explanation.
There are currently 4 lanes in each direction at the Dartford Crossing. 4+90% = 7.6 lanes.
The proposed tunnel section of LTC is 3 lanes in each direction. 4+75% = 7 lanes. Last time we checked 4+3 was 7 and not 7.6!!
Reference to the 2016 consultation is also outdated and could have commented on the 2018 Statutory Consultation.
The latest info can all be confirmed on pages 6 and 7 of the Supplementary Consultation Guide.
The video included on this page is definitely out of date and not a true representation of the current proposed route. It is the fly through video that HE produced for the 2018 Statutory Consultation.
One of the most obvious inadequacies of the video, amongst many, is it still clearly shows things like the Service Station and Tilbury junction which have now been removed.
When captured on Feb 17th the time line shown at the bottom of the page, stated 2018 Statutory Consultation and then jumped straight to 2020 as Submission of DCO Application. No mention of the Supplementary Consultation.
Many people are concerned and confused as to what is happening, and where we are within the time line of what has to happen.
When checked again on 6th March they have now added the Supplementary Consultation to the time line. However, the outdated and now misleading fly through video can still clearly be seen just above it still! Why are they updating certain things but not others?!
In My Area Page
Again another reference and chance to watch the now out of date fly through video of the proposed route which was released in 2018.
A section titled ‘What’s happening now?‘ which makes no mention of the Supplementary Consultation at all. In fact the info they share about the Summer 2019 Project Update, Ground Investigations and Ground Penetrating Radar Surveys were announced in July 2019. It even includes a link to the Summer Engagement events that happened in 2019.
But no mention of the current Supplementary Consultation or public info events.
Under the same heading of ‘What’s happening now?‘ a clearly out of date map, as it still shows the Tilbury junction, which has been removed as part of the Supplementary Consultation!
More questionable statements highlighted in red in the image below.
Again it is not 3 lanes in both directions, there is a 2 lane section southbound between M25 and A13.
It is also stated that it will be a motorway. HE have categorically told us that the road has yet to be categorised, suggesting when asked at the February LTC Task Force Meeting that it would likely be categorised an all purpose trunk road.
The fact they list it as having no hard shoulders in common with smart motorways, also is a cause for great concern considering how dangerous Smart Motorways are. Not forgetting that we specifically asked David Manning, Development Director, HE at Feb LTC Task Force if it would be a smart motorway.
Listen to a section of audio recording of that meeting which covers this.
If you wish to hear the answer to the second part of this question, or indeed the audio of the whole meeting it can be found here.
Again another reference to the 90% extra road capacity that we are waiting for HE to explain!
Finally on that page of their website a section called ‘What areas are affected‘.
The map they refer to as the updated development boundary (this map ) is clearly out of date, it is from Statutory Consultation in 2018.
The development boundary comparison plan is also out of date (2018).
Project Updates Page
Again the Supplementary Consultation is being hidden away. The current featured update relates to the Utilities Trial Trenching survey works.
Then there is an article about the Supply Chain School events.
Considering HE have NOT submitted a DCO application yet, let alone been granted one, maybe they should be giving more priority to ensuring that everyone is aware of the Supplementary Consultation!
Keep in touch Page
This page states “You may also visit one of our information points in local communities to pick up Lower Thames Crossing print material.”
The link provided takes you to a list of locations that do not all have the most up to date info about the Supplementary Consultation. We know this as we, along with many of our members have been along only to find there are no Supplementary Guides and response forms etc at some of these locations!
On this page they also state “We want to make sure that information about the Lower Thames Crossing project is accessible to as many people as possible.
That is why we are sharing an update on the progress of the scheme with local communities by post this week. You can view this information on our November project update page.”
Seriously, the latest info they provide is November, and no comment about keeping in touch with the latest updates by getting involved in the Supplementary Consultation?!!
Just to point out this update only covers the issues we have identified with the official LTC website, and not anything we feel as being inadequacies of the project, or the current Supplementary Consultation and it’s supporting suite of documents.
What can we do about this?
Well we as an action group have sent an email about our serious concerns over this, and calling for a rerun of the Supplementary Consultation to the CEO of Highways England, Jim O’Sullivan, firstname.lastname@example.org, and cc’d the 4 local MPS affected most by the LTC (Adam Holloway MP- Gravesham, Jackie Doyle-Price MP – Thurrock, Stephen Metcalfe MP – South Basildon and East Thurrock, and Julia Lopez MP – Hornchurch & Upminster), the Transport Select Committee, local authorites (Gravesham, Thurrock, Havering), the Planning Inspectorate, and the Secretary of State for Transport, Grant Shapps MP.
We will also be commenting on this in our official Supplementary Consultation response, and would encourage you to comment on this and any other concerns and HE inadequacies you feel there have been in your own consultation responses. Remember there is a section – Question 9 The Consultation where you can add all your comments like this if using the official response form online or in paper format. If responding using physical paper format you can add as many extra sheets of paper as needed, if there is not enough space on the form, just be clear which question your comments relate to!
We need as many people as possible commenting and emailing about this please. Remember HE have a legal obligation to consult us adequately with clear and informative material, which clearly they are not. We deserve a consultation that is not full of inadequacies and that is what we must demand. Together we are stronger!
Update 9th March 2020
We’ve just had an email on Mr O’Sullivan’s behalf from someone in the Highways England High Level Correspondence Team.
The email says:
“Thank you for your email 6 March to our Chief Executive Jim O’Sullivan. Please accept this email as receipt of your complaint.
Our Chief Executive has asked for details of your complaint to be passed to the relevant business area for their investigation.
The maximum response time is 15 working days, however we will try to respond sooner.”
We have not included the Complaint Reference number in the copy and paste above, but will of course keep you updated as we get further responses!
This could be a very important step in our campaigning, and we need everyone to please keep reporting everything you consider to be an inadequacy of LTC consultation via email or letter to HE, as well as commenting about it in your consultation responses. To be clear this will not neccessarily directly stop LTC, but could buy us some time whilst the Government are making other decisions which could help our cause, with the ultimate aim of stopping LTC. Plus at the end of the day we deserve adequate consultation on LTC with clear and informative materials, and HE have a legal obligation to provide us with that too!
(1) Planning Inspectorate’s Advice Note 8.1 (Overview of the nationally significant infrastructure planning process for members of the public and others)
1.1 The process begins before an application is submitted. The developer of the Nationally Significant Infrastructure Project (NSIP) is legally required to carry out pre application consultation on the proposed development.
1.4 It is important to remember that the consultation material presented by the developer at the pre- application stage is not “the application”. The pre- application process is intended to allow the developer to gather useful information from the public and others that will influence the preparation of the application that is eventually submitted. The consultation material presented must be clear and informative, but it is not necessarily a draft version of the application. Some developers may have more than one pre- application consultation stage to allow the public and others to comment on and influence the project as it evolves.