Thirteen false and unproven claims the Mayor repeatedly makes about the Silvertown Tunnel – and the truth.
Claim 1:‘TfL did an exhaustive analysis of alternatives to the Silvertown Tunnel’.
Not true. TfL has never made a detailed comparison of the economic benefits and environmental, traffic and public transport effects of any of these credible alternative options:
- a scheme that tolls Blackwall Tunnel at levels to fully relieve congestion, without building a new tunnel;
- a wider smart road pricing scheme that would also fully decongest Blackwall Tunnel;
- a single bore tunnel at Silvertown reversible in the direction of tidal flow, with a bike/e-cargo bike route/escape/fire access under the roadway.
TfL also did not account for the opportunity cost of building the tunnel: if toll income is not spent on paying back the cost of the Silvertown Tunnel, it can be spent on other infrastructure or public transport services, which will offer far better economic and environmental returns than the tunnel.
TfL failed to assign any economic value to reductions in carbon emissions, or reductions in local air pollution, in its comparison of economic benefits of options.
Claim 2:‘TfL showed that tolling the Blackwall Tunnel alone cannot remove congestion at the crossing.’
Not true. TfL have not modelled the traffic effects of a level of toll that would remove congestion entirely from Blackwall.
Claim 3:‘The money available to build the Silvertown Tunnel comes from tolling this crossing, as part of the PFI scheme and cannot be used for anything else.’
Not true. It’s road pricing income. There’s nothing stopping Mayor Khan tolling the Blackwall crossing alone, and spending that income on, for example, better public transport, or cycling schemes like the Rotherhithe Bridge
Claim 4:‘The Silvertown scheme enables a step-change in public transport across the river, with 37 new buses an hour.’
Not true. The Mayor could enable a step-change in public transport right now, if he wanted to, and not in six years’ time, by tolling Blackwall Tunnel to remove congestion. (The main reason people don’t take buses across the river is unreliability.) He could also make those buses free, using the income from tolls. The number of buses promised in the Development Consent Order is 20, not 37. And only for 3 years. It is true that the Silvertown scheme would allow TfL to use double-decker buses, but we don’t believe this advantage is worth £1bn.
Claim 5:‘A toll high enough to de-congest Blackwall Tunnel would send too much new traffic to Rotherhithe and the Woolwich Ferry’
Not proven. TfL have never actually modelled this scenario. Nor have they modelled alternatives such as wider road pricing, or providing free buses through Blackwall funded by toll income to reduce private car numbers at the tunnel.
Claim 6:‘The Silvertown Tunnel is necessary because the northbound Blackwall Tunnel is old and frequently blocked by over-height vehicles’
Not true. Firstly, (and in particular once Blackwall Tunnel is tolled), technology that won’t cost £1bn should be available to prevent over-height vehicles entering the tunnel. Secondly, no vehicle gets stuck in the tunnel voluntarily. The Blackwall and Silvertown tunnels share a narrow approach road. If a vehicle gets stuck in Blackwall, where most of the traffic will still go when Silvertown Tunnel is built, traffic will still rapidly back up and block that approach road.
Claim 7:‘The Silvertown Tunnel will improve air quality’.
Not proven; highly unlikely. The scheme as described will improve air quality at the tunnel mouths (where there are no houses), by releasing traffic and reducing queuing, but it will increase congestion and reduce air quality on the approach roads, pushing the tunnel bottlenecks back onto roads where thousands of people live, work and learn.
- Even TfL’s modelling (which SSTC regards as highly optimistic) shows increased traffic in an area of concern south of the river: the A102 southbound, after coming OUT of Blackwall Tunnel in the evening rush hour. This is already very congested (see the daily feed from TfL cameras at http://livetrafficuk.com/) so what will be the effect of an extra two tunnel lanes feeding in what TfL itself says would be 25-30% more traffic?
- Research shows consistently that new roads = more traffic. Plans are already being made for freight logistics centres near both tunnel exits.https://www.handyshippingguide.com/shipping-news/new-giant-three-storey- logistics-facility-for-the-heart-of-london_8987
- A recent, typical example in the news is Scotland’s new Queensferry Bridge which Transport Scotland has just admitted has led to over 1m extra car journeys in the last year, while the goal to raise public transport journeys instead has failed – half the planned public transport projects have not even been implemented. https://www.edinburghnews.scotsman.com/news/traffic-and-travel/transport-chiefs- admit-unwanted-queensferry-crossing-traffic-increase-1358484
Air pollution from traffic in parts of Greenwich and Newham is already over legal limits. The UK Courts have been clear in the 3 ClientEarth judgements (2011, 2015 and 2018) that the UK must comply with the EU Air Quality Directive within the shortest possible time. In the September 2019 Gladman case judgement, the Appeal Court refused to allow, by applying the ClientEarth judgements, a development that would increase air pollution to illegal levels.
- Research from King’s College London shows that living within 50m of a busy road may raise lung cancer risk by 10%, and stunt children’s lung growth by 3-14%.https://www.kcl.ac.uk/news/air-pollution-restricting-childrens-lung-development
- Children’s hearts and cognitive abilities are also affected, see e.g. this just-published research: https://www.edworkingpapers.com/ai20-188
- Around 16,000 children attend schools in Greenwich that will be affected by increased congestion resulting from the extra tunnel, and another 16,000 in Newham.
Claim 8: ‘The terms of the Development Consent Order ensure that traffic, congestion and pollution won’t get worse once the tunnel is built.’
Not true. The DCO makes it clear that, although any future Mayor has to pay attention to TfL’s opinion on tolls, the decision on the level of toll is theirs alone. It’s a political decision (as all decisions on taxes are) and they are able to remove the toll entirely, and let pollution and congestion ramp up, if they want to do that. (As Mayor Johnson did with the Congestion Charge western extension.)
Claim 9: ‘The Silvertown Tunnel project is consistent with the Mayor’s declaration of a climate emergency, and London’s 1.5 degree compatible plan’
Not true. The business case for the tunnel (entirely based on the assumed benefits of less congestion), and the repayment plan for the PFI financing both assume that private vehicle demand and use remain constant in the foreseeable future. This assumption is catastrophically flawed from the perspective of climate action:
- Even to meet London’s existing, weak carbon reduction targets (set by Khan himself), the Mayor/ TfL will need to replace many private vehicle trips with trips by public transport, cycling, walking and micro- EVs. That would sharply reduce demand and congestion at the Greenwich/ Newham river crossing.
- But the targets are based on old data anyway. The Mayor’s draft Strategy (May 2018) and planned carbon reduction pathway predate the IPCC’s Special Report on 1.5 degrees (SR15, October 2018). SR15 is the key report that changed the landscape of the debate on climate change and the climate emergency. It significantly updated the scientific basis underlying global carbon budgets, and this is crucial for interpreting London’s transport plan and carbon budgets.
- These will need to be toughened considerably, to a 12.5% year on year reduction in carbon emissions, for London to meet its contribution to the IPCC’s target of keeping global heating to 1.5 degrees.
- City Hall has also cited a C40 Cities letter (April 2018) and the Climate Action Plan Assessment (July 2018). These documents also preceded SR15.
- Switching to electric vehicles alone is not enough (see claim 10). We will need to sharply reduce private car use.
- This means both the business case for the tunnel and the repayment plan fall apart, and TfL is left with a £1bn debt to pay off on what’s effectively a white elephant. The PFI project’s financial structure is a mismatch with Khan’s stated environmental aims.
New scientific research based on the SR15 from climate scientists at Manchester Tyndall University shows the extent of the gap between plans and what’s needed; and the urgency. At 2017 CO2 emission levels, London would use its entire budget by 2027. A different analysis, using the data in the London Environmental Strategy (LES), produces a similar conclusion: that if London followed the LES budget, it would breach London’s IPCC 1.5 degree carbon budget in 8 years. We have shared these analyses with City Hall, who have ignored them in their responses. More information available on request.
Claim 10: ‘Electric vehicles will result in significant carbon savings’.
Not true. City Hall’s arguments rely heavily on electric vehicles (EVs) but these are not a credible pathway to the emissions reductions we need in the time we have available. Reasons include the big rise in UK electricity demand which cannot be met by renewable sources, limited EV resources such as lithium and cobalt, and up-front carbon emissions from EV production. https://www.nhm.ac.uk/press-office/press-releases/leading-scientists-set-out-resource-challenge-of-meeting-net-zer.html
Claim 11: ‘London cannot wait any longer for us to build the Silvertown Tunnel.’
Not true. The tunnel will take six years to build. The Mayor could get most of the supposed benefits of the scheme (less congestion, better public transport) right now by tolling the Blackwall Tunnel, and investing the income in free bus services that will allow us to use that tunnel much more efficiently. And unlike the Silvertown scheme, this option will allow immediate improvements on the two problems that we do need to solve urgently: London’s poor air quality, and high carbon emissions.
Claim 12: ‘The Silvertown Tunnel is necessary to support population growth and economic growth in East London.’
Not true. The Silvertown scheme will not allow increased cross-river traffic because approach roads, shared with Blackwall Tunnel, are already saturated. Widening these, or creating new routes through the already very polluted adjacent neighbourhoods, is not politically or practically feasible. All Silvertown does is allow the same traffic to do the actual river crossing slightly faster at peak times (while crawling in the approaches). Silvertown creates new road capacity in the most expensive place possible – doubling the Blackwall Tunnel – but nearly all of it can’t be used.
If the Mayor wants to increase capacity across the river, his best option would be to extend the DLR or the Overground to Thamesmead and Abbey Wood, toll the Blackwall Tunnel to remove congestion, and use the toll income to fund free and reliable buses through Blackwall. To support economic growth and population increase it’s much cheaper and greener to use existing road infrastructure more efficiently, by moving private trips to public transport and freeing up road space for businesses that need to use it.
Claim 13: ‘The Silvertown Tunnel has been supported in several consultations and by the planning inspectors. There is no need for further scrutiny.’
Not true. TfL has given false information to the public at consultation, to politicians, and to the planning inspectors – claiming repeatedly, and wrongly, that their modelling proves that it is not possible for a pricing strategy to remove congestion at Blackwall. None of these groups had the resources to check TfL’s work – so their conclusions are based on this false information. Furthermore, climate issues were ‘scoped out’ of the planning enquiry entirely. We think the climate crisis should have been considered as a key factor in any scrutiny of the scheme, and it has never been.
From The Stop Silvertown Tunnel Coalition January 2020