Lower Thames Crossing statutory consultation. Thank you for the opportunity to respond to the Lower Thames Crossing statutory consultation proposals. This response is made for and on behalf of the Dartford and Gravesham Cycling Forum. Introduction. The Dartford and Gravesham Cycling Forum (D&GCF) is a group that campaigns for policies and measures that enable people to choose cycling for their everyday journeys in Dartford and Gravesham. We believe that the best way to enable people to choose to cycle for their everyday journeys is to provide the appropriate infrastructure that enables people to cycle in a safe environment away from the dangers presented by motor vehicles. Ultimately D&GCF believes that congestion cannot be solved by building new roads and D&GCF is opposed to any additional crossing of the Thames that promotes the unrestricted growth of motor vehicle traffic. Our response to the consultation will focus on provision for Non-Motorised Users (NMUs) particularly on that made to enable people to choose to cycle. It will be based upon information provided in the current consultation and will refer to current design standards, principally those outlined in Interim Advice Note 195/16 (IAN 195/16). Our response will be limited to those elements of the scheme that are south of the River Thames. D&GCF believe that to deliver convenient safe and appealing routes that make it as easy as possible for people to walk, cycle or use other forms of active travel, the preferred design standards outlined in IAN 195/16 must be applied throughout the scheme. The scheme offers opportunities to decrease severance created by previous A2 realignment schemes. It also presents challenges that must be overcome to avoid creating additional issues of social exclusion for the people of Gravesham. D&GCF note that the scheme is a Nationally Significant Infrastructure Project (NSIP) and call upon Highways England to deliver and maintain flagship pioneering NMU facilities within the scheme that will be worthy of a NSIP and enable walking and cycling to be people’s first choice for short everyday journeys. D&GCF believe that to achieve safe routes for NMUs that provide appropriate segregation from the dangers presented by motor traffic and to avoid conflict between pedestrians and people cycling, Highways England should be applying the principles and design standards outlined in IAN 195/16 to improve all of the NMU facilities and routes throughout the Development Consent Order zone and in some cases beyond it. The consultation. The statutory consultation brochure states: “Walkers, cyclists and horse riders. The Lower Thames Crossing is a motorway and will have the same restrictions, which means walkers, cyclists and horse riders will not be allowed to use the tunnel or road. If footpaths, bridleways and cycle paths along the route are affected by the Lower Thames Crossing, we will reinstate them where practicable when construction is complete to ensure people continue to enjoy access to the landscape. Throughout the design process we will look to improve and enhance these routes as we consider how they will be affected. During construction, we will keep disruption to public rights of way used by walkers, cyclists and horse riders to a minimum, by limiting full route closures and providing alternative routes. Wherever a right of way is affected, we will provide a nearby alternative.” “To find out more about how walking, cycling and horse riding routes are affected, see Map Book 1.” “ Highways England recognises that different groups of NMUs have different needs. D&GCF are concerned that Map Book 1 uses the same coloured designation for all types of NMU routes without providing clarity as to which categories of NMU will be able to access any particular route. All new cycle routes must be designed and constructed to IAN 195/16 with segregation between people walking, cycling and horse-riding. Existing NMU routes in the area do not meet current standards and the scheme offers an opportunity to address this. D&GCF feel particular attention is required to the following areas of IAN 195/16: 2.2.2: As all roads encompassed in the scheme have limits of 40mph or greater the minimum standard of provision required for people on cycles will be cycletracks. D&GCF believe a new segregated two-way cycletrack must be provided alongside the new link road between the Gravesend East junction and Brewers Lane junction. It would be disingenuous to consider this new road to be anything other than an integral part of the Strategic Road Network. Whilst Highways England have provided neither predicted motor traffic flows nor the proposed speed limit for this road, it is inconceivable that they would be below those where IAN 195/16 requires segregated cycle provision. 2.2.4: All aspects of cycle provision in the scheme must be suitable for the cycle design vehicle (Fig, 2.2.4.1), 2.8m long and 1.2m wide. 2.2.11: Two way cycletracks shall have an absolute minimum width of 3.5m with further reference to the minimum additional width requirements to make allowance for fixed objects adjacent to or within the cycle track as described in Table 2.2.11.1. 2.3.3: Provision of horizontal separation between cycle tracks and the carriageway will be in accordance with table 2.3.3 throughout the scheme. 2.4.2: Cycle crossing design options provided on links and at junctions will be in accordance with table 2.4.2. D&GCF call for Highways England’s to implement its own preferred option in IAN 195/16 of grade separated or signalised NMU crossings at all locations, the need being based upon motor vehicle speeds and volumes. This must include upgrades of existing courtesy crossings at the Gravesend East junction and Brewers Lane junction to signalised control. There must be no courtesy crossings anywhere within the scheme. All routes must have street lighting. D&GCF believe that a failure to apply the principles of IAN 195/16 to NMU routes throughout the DCO zone would prejudice the promotion of active travel for transport within Gravesham. Remarks and recommendations. The D&GCF response will consider the impact the scheme will have upon existing cycle routes. It will make recommendations for improvements. What does a good NMU route look like? What might make a route attractive to less experienced cyclists and indeed enable those who do not currently cycle to choose cycling for their everyday journeys? Chris Boardman, Cycling and Walking Commissioner for Greater Manchester speaking to the London Assembly, January 10, 2018 gave a simple answer to this when he said, ”If you want genuine modal shift then somebody who is currently in a vehicle has to want to use a cycle route. So then the question becomes what would make me want to use it — and overwhelmingly it is 'it must be easy, attractive and safe'. And if it’s not those three things, all of them, probably in that order, then I’m not getting out of the car. I’m not going to get out of any kind of vehicle to do that. So it has to be those three things, and a big chunk of that is a safe, easy space that is convenient, goes where I want to, uninterrupted, and it puts me first.” His statement is very much in line with the Department for Transport’s “Five Design Criteria” for cycle networks which are set out in IAN 195/16. • Coherence: Cycle networks shall link trip origins and destinations, including public transport access points and shall be continuous and easy to navigate. • Directness: Cycle networks shall serve all the main destinations and shall seek to offer an advantage in terms of distance and journey time. • Comfort: Infrastructure shall meet design standards for alignment and surface quality, and cater for all types of user, including children and disabled people. • Attractiveness: Aesthetics, noise reduction and integration with surrounding areas are important. • Safety: Cycle networks shall not only improve cyclists’ and other road users’ safety, but also their feeling of how safe the environment is. The response from D&GCF to the consultation will consider how these five design criteria should be applied to NMU routes within the DCO zone. • Coherence: Existing NMU routes need improvements as outlined below. Signing needs improvement throughout and beyond the DCO zone. • Directness: The proposed routes are often physically less direct than the current route alignments. Many of the slip roads and junctions feature at grade crossings which prioritise motor vehicle movements and they are therefore unlikely to provide a journey time advantage. Additional grade separated facilities would improve journey times. • Comfort: Improvements to path widths and surfaces together with the removal of hazards in close proximity to the cycle tracks are required to increase attractiveness and comfort. Machine laid surfaces will be essential to maximise comfort. • Attractiveness: There is a clear if limited opportunity to improve the aesthetics of the NMU routes. Improved maintenance regimes, particularly vegetation management and litter clearance will be essential to the ongoing attractiveness of the NMU routes. • Safety: Motor traffic volumes and speeds support the use of grade separated crossings throughout the scheme. Additional signalised at grade crossings at various locations will be the minimum provision required for NMU safety. Map Book 1, sheet 1 The sheet shows a realignment of NCN177 south of the A2/M2 at Park Pale. There is no detailed information on the new alignment. Provided that gradients, radii and other details of the construction are in accordance with IAN 195/16 the realignment is a sensible proposal. D&GCF note that much of the pedestrian side of the existing shared track south of the A2 on-slip link from Strood has been all but lost to vegetation encroachment.