Lower Thames Crossing Myths and Facts

Myth

The planning application for the Lower Thames Crossing is 2,383 documents and 359,000 pages long.

Fact

This myth originated from a roads lobby group called Britain Remade, but has been repeated – unchecked – by mainstream media, including in the Times, FT, and politicians.

We have fact checked these figures and have discovered they have been inflated sixfold. The Development Consent Order (DCO) planning application was actually 554 documents (not 2,383 claimed), and totalled 63,330 pages, not 359,000.

We can only presume that Britain Remade inadvertently included all of National Highways’ evidence submitted to the 6-month long examination, including many duplications and rebuttals of evidence. It did not count the documents in the actual planning application, but instead used these inaccurate and inflated figures. You can view how we calculated our figures here.

It is inevitable that a scheme of the scale and cost of the LTC will require a large and detailed planning application. Due to its high cost and large environmental impacts, National Highways has to work hard to justify the scheme and its £9bn price tag, alongside the 6.6 million tonnes CO2, and large environmental impacts. Many of the DCO documents are required by primary legislation, and many of the DCO documents are detailed plans and maps, showing the 23 km route.

The longest document in the DCO planning application is the 9,000 page Book of Reference, comprising 14% of the page total. This lists every piece of land that has to be compulsorily purchased. DCO applications are unusual as they include all the legal documents and evidence required to compulsorily purchase (CPO) land. Unlike normal highways planning applications where CPOs are dealt with separately, in a DCO application they are combined.

However, National Highways will sometimes submit unnecessarily long documents, partly because consultants want to justify their fees but also to overwhelm and confuse their opponents and the Planning Inspectorate. Some documents are also rather bizarre such as the List of all respondents to statutory consultation in the Consultation Report [APP-078] which is 900 pages of mostly a single column of objectors’ registration numbers. Despite the length of the many documents, vital information can often be missing or obscured.

Those with a political agenda have made a lot of noise about the length of the LTC Development Consent Order (DCO) planning application, with some using it as an excuse to push through planning reforms that would cut environmental protections and democratic participation. However, using the largest ever road project to demonstrate a point about planning shows the weakness of their case, as the DCO application is not typical. They also fail to scrutinise National Highways’ competency, since it had to withdraw its first DCO application for the LTC (a first), because the application was so poor.

Myth

The LTC planning application has cost £800m.

Fact

The £800 million figure came from a letter the then roads minister Richard Holden MP wrote to the Transport Select Committee on 12 August 2023 [1], regarding the costs so far of the Lower Thames Crossing. In it he said: “Over £800m has been spent on the Lower Thames Crossing project to date. This is not solely on planning costs and is across the project, including technical surveys and investigations, land purchasing costs as well as on the three major National Highways contracts to deliver the Lower Thames Crossing“.

TAN asked National Highways to provide a breakdown of these costs [2]. Its response showed that the largest expenditure was for technical surveys and investigations (£307.4m +VAT, so £368.88m, or 46% of the total spent). The numerous (and inadequate) consultations are a tiny part of the costs so far (just under 4% of the money spent). National Highways has also spent £97.7m +VAT, so £117m, on land purchasing costs. The two DCO planning applications (National Highways had to withdraw one, as the Planning Inspectorate said it was inadequate) cost £245.3m +VAT, so £294m, or 37% of the total spent.

It is true that National Highways has thrown good money after bad on this project which has always had a very weak business case, is unaffordable, and has huge environmental impacts. To save the taxpayer money, the £9 billion project should be scrapped, and cheaper and more sustainable options invested in, such as rail freight options at Dover, and public transport crossings.

Sources

[1] Letter from roads minister, Richard Holden MP, to the transport select committee, 12 August 2023

[2] TAN FOI request to National Highways for the breakdown of costs on the Lower Thames Crossing

Lower Thames Crossing Myths and Facts

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Fact

Myth

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Further reading