TYNE CROSSINGS ALLIANCE, OBJECTOR NUMBER 382

RESPONSE TO MR HARVEY EMMS' REBUTTAL (TWPTA 12 )

I apologise for writing in our Supplementary Proof of Evidence that we had not received Mr Emms' rebuttals. We had not only received them, but I had heavily annotated the appendix concerned for my reply. I then overlooked the document, however. My letter of 26th March to Mr Nixon and Mr Sauvain refers.

Our response is as follows.

Issue: Policy (1) The assumptions in this rebuttal are in our view unsubstantiated and contrary to other (i.e. non-PTA) evidence. That the scheme is identified in the documents cited doesn't validate the scheme.

In our view the necessary prior assessment of valid alternatives wasn't made. The documents submitted by Mr Murphy of NECTAR concerning Phase 6 of TAMMS as Core Document 396/O/5 (TAMMS Scenario Testing Report, Phase 6, pages 79 to 83) in our view confirm my suggestion in my Supplementary Proof that the decision to exclude non-tunnel options from the next stage of the studies was made on political grounds and not on a question of merit. 9.4.1 (page 79) reads: "The New Tyne Crossing is considered likely to proceed independently of TAMMS policy recommendations and therefore is included in Hybrid 2".

Mr Simpson's assertion that "[the tunnel scheme] would provide opportunities for enhancement of public transport services which would not otherwise arise" is simply untrue. The much better from the public services point of view non-road-tunnel option has been excluded, as mentioned above.

The NTC scheme does not "enhance sustainable transport". We claim exactly the opposite.

Issue - amenity I now have the full proposals to which Mr Emms refers and they do not relate to the threat we perceive to the Hebburn to Pelaw Riverside Park. As mentioned in response to other witnesses, we do not accept that pressure for new access roads etc. consequent upon the construction of a new tunnel can be divorced from the logic of building that tunnel. It's like saying that firing a gun can be divorced from the impact of the bullet.

The impact of the scheme on Epinay Estate remains unsatisfactory.

Memo 3

Issue: Property (1) c) We are glad to see that the imposition of waterside housing on commercial waterside sites is no longer favoured but we look to the future of Middle Docks with misgivings. We note that large tracts of formerly ship repair land on both sides of the River have been lost to housing, and that this housing presents a brake on the development of healthy marine businesses on the sites that remain due to its proximity. Even houses across the road, inland, from the Palmers Hebburn dock present a problem for the proprietors of that facility. (Source: conversations with Albert le Blond).

d) This is a restatement of the nostrum that investors always need additional road access. This may have local relevance but the argument does not in our view relate to the construction of a new road tunnel. Workers - especially in shipbuilding and repair yards and other waterside employment - can be enabled to cross the river by the foot and cycle tunnels, the existing and planned extended ferry from South Shields to North Shields, reintroduction of previous ferries (such as the Mid Tyne ferry), and priority bus access to the existing road tunnel and a new Metro crossing, seen as carrots, plus workplace and other parking charging and congestion charging for instance (plus national measures such as higher fuel prices for instance) seen as sticks.

These matters are referred to by ourselves in our main Proof and by most other Objectors in their Proofs.

e) The problem we raised was not just out-of-town retail and other developments. The specific developments we referred to are at Royal Quays and East Boldon, both of we would regard as in-town. The same problems arise as with out-of-town developments, seemingly without the incentive to curb the car emphasis in the design of these facilities which is in place as Mr Emms comments for out-of-town developments.

Memo 4

Property (2) Some of these regeneration aims would be assisted if the outcome from the NTC were indeed to reduce congestion. We submit the opposite to be the case. We submit additionally that the scheme would not "improve" transport. Concerning lorry transport for instance we have suggested that lorries (and buses and emergency vehicles) could be given priority access to the present tunnel. This would need to be in conjunction with a change of planning emphasis away from car traffic to planning and other provisions (sticks as well as carrots) which would enable employees to get to the vast majority of sites without cars, while encouraging workers to choose employment, parents schools, etc. (and to live, when that option comes up which it often does) in locations which minimise travel needs.

We agree that regeneration is a planning matter but disagree that it must be geared to roads access, or that regeneration means any old jobs anywhere. Employment creation (more properly, encouragement) programme has in our view to be much more subtle, and it should also have a maximum of organic growth rather than imposed options.

Planning (1) As mentioned elsewhere since TAMMS is predicated on the construction of a new tunnel it cannot be used to evaluate the merit of non-tunnel options.

We don't have details of the Volkswagen terminal but we just mention that transhipment is not an ideal employment source, and it may be heavy on land use (e.g. the huge area devoted to parked cars for Nissan on the south side of the river which creates negligible employment, though it is ties in with employment at the Nissan factory and there is revenue from rent and Port activities, of course).

Planning (2) Reference to TAMMS and Orpheus misses the point. Our comments in 8e of our Supplementary Proof of Evidence (responses to Mr Henderson) refer to TAMMS, and 8d (responses to Mr Simpson) 11.3, refer. While we welcome the Orpheus project in principle, we suggest that if £650 million is available for rail and tram improvements a much lesser sum (probably less than the estimated cost of the NTC without its unwelcome and expensive side effects) would extend the Metro under the Tyne from South Shields to North Shields, as we suggested in our main Proof of Evidence (page 9). If as is frequently suggested non-roads schemes won't attract funding, how does the PTA propose to fund Orpheus?

The NTC would not, as claimed, "reduce vehicle kilometres travelled by car....". A small saving on current via-bridges trips from south to north of the river between points which are further than they would be by the NTC, and by people who are unwilling to accept delays at the present tunnel (no worse than those experienced every day by public transport users however) will in our view be vastly offset by trips by car to the projected 50,000 new jobs. (Figures on this vary). As mentioned, these jobs can and should be allied to public transport means and while not every house can be located next door to a Metro station, there are very many ways of making these trips other than by car. Until very recently everyone did that as a matter of course. We didn't think twice about it!

Traffic without a tunnel will only worsen if other measures such as we propose are not put in place. They will certainly worsen if the NTC is built, as a direct result of that construction.

Planning (3) We have no additional comment to make.

Policy (2) We do not accept that traffic would reduce, as shown in our response to Planning (2) above and elsewhere, so the scheme does not meet the requirements of PPG1.

Policy (3) We agree that the policy is in accord with TAMMS (presumably - we don't seek to verify this) but the trouble is that TAMMS is not in accord with what we understand to be a main requirement of GOMMMS. I don't have access to our GOMMMS expert as I write but I understand that GOMMMS requires an evaluation of a full relevant range of options. TAMMS excludes the no-tunnel option and is therefore irrelevant to an assessment of that option. Likewise the other requirements cited are not met, as also because of the traffic-inducing effect of the proposal. We submit that Mr Henderson's evaluation of induced traffic goes against common sense, and we also point out that the NTC is part of a traffic-increase set of policies which cannot fail to have that effect in due course whether Mr Henderson is right in his predictions or not. We support an alternative traffic-reducing scenario. Dr Richardson's FOE evidence also refers.

Policy (4) 2.3.1.4 PPG13 Our comments on these claims are made in relation to other rebuttals (above).

Policy (5) 2.3.1.7 PPG24 Regarding the sentence "In relation to operational noise it has been demonstrated that there will not be an increase in current noise levels, due to appropriate mitigation being provided by the tunnel design process to minimise impact" is frightening in its missing the point of where 99% of the noise problem would arise. It would arise outside the tunnel, and clear of its immediate approach roads. Our comments to Mr Manning also refer.

Policy (6) 2.3.2.2. RES We cover these points elsewhere and in our evidence generally, which Mr Emms seems to be contradicting without adducing additional evidence to show how a traffic increase can be sustainable.

Environmental (1) 4.8.6. (Hebburn to Pelaw Riverside Park) We refer to this point in our Supplementary Proof of Evidence 8(d).

Environmental (2) 8 Visual impact Only Mr Emms' comments with regard to the Hebburn to Pelaw Riverside Park are relevant. My response on that issue is as in the paragraph above.

Our responses to Mr Emms' Proof of Evidence in our Supplementary Proof of Evidence, Section (8d), page 6, also refer.

END