Rising East Online

A Reasoned Documented Critique of the Thames Gateway Bridge Consultation Report

Kerry Hamilton and Caralampo Focas

Introduction

Transport for London undertook a consulting exercise on the proposal to erect a bridge across the Thames on the location of the East London River Crossing which has been proposed since the 1970s and went to a public inquiry in 1985-86. They chose a methodology based on a core of a short post-back questionnaire supplemented by comments from Roadshows, responses from stakeholder meetings, written responses and market research surveys.

This report undertakes a reasoned critique of the consultation process as described in the “Consultation Report” and the “Consultation Response Analysis Report” which were both published in November 2003.

Its aim is to analyse the following:

• The aims and objectives of the consultation,
• To what extent did the consultation keep to the stated aims,
• The appropriateness and robustness of the chosen methodology,
• The accuracy of the findings,
• To what extent were the reported conclusions in keeping with the findings, and last,
• Whether the conclusions and findings were reported correctly.

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What were the aims of the consultation?

The aim of the consultation on the Transport Gateway Bridge proposal, as stated in the Consultation Report was “to give all groups and individuals affected by the proposed Thames Gateway Bridge the opportunity to comment on the proposals, based on the information available”.

The principles of the consultation policy were laid out by Transport for London. The principles were taken into consideration in the undertaking of the Thames Gateway Bridge consultation (although only in draft form as policy was only formally adopted by Transport for London after the Thames Gateway Bridge consultation had ended) . The Greater London Authority has produced two documents to guide staff of the Greater London Authority and the other Greater London Authority group organisations (Transport for London, The Metropolitan Police Authority, the London Fire and Emergency Planning Organisation, London Development Agency) on how to carry out consultation with the public, businesses and other stakeholders. These two documents are: "Consulting London" and "Listening to London".

"Listening to London" sets out the three overarching principles of consultation:

• Proportionality:
  Deciding on the resources and time to be spent on consulting ;
• Making a Difference:
  Consultation is only worth doing if it is done well and if it makes a difference. It needs to add value to the policy process ;
• Impact on decision-making:
  The success of a consultation exercise is to demonstrate that it has influenced decision-making .

However, further to the main aim of the consultation, Transport for London added a further 6 objectives for this specific consultation exercise:

• To raise awareness and understanding of the Thames Gateway Bridge;
• To promote participation in the consultation process;
• To identify key issues for those affected who have local knowledge and expertise;
• To inform the Mayor’s decision making process;
• To ensure an understanding of decisions and the reasons for them;
• To win the trust and confidence of stakeholders.

It is unclear how far the last two of the objectives mentioned above are set for the purpose of consultation or are for the purpose of persuading the public and the stakeholders to support the plans.

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Did the consultation keep to the stated aims?

To a large extent the consultation process followed the aims and targets that were set. There were however some omissions and deviations from the principles of the consultation policy which have grave consequences on the entire consultation process.

The following are the main failures in the adhesion to the aims of the consultation process:

Lack of options

The draft Transport for London policy statement (that was taken into consideration in the undertaking of the Thames Gateway Bridge consultation) sets out that the consultation process must provide more than one option. It states, “we will seek public input into the design of options as well as consulting on specific proposals” and “we will provide full explanation of options and proposals...”.

There were no options presented to the public or the stakeholders at any time throughout the consultation process, with the exception of the possible closure of the Woolwich Ferry. Only a single design of a 6 lane road bridge was proposed and consulted on and no other options were given for the proposed East London river crossing. No alternative bridge designs were proposed for the Thames Gateway Bridge.

The lack of options has been criticised by a number of organisations including the London Transport Users Committee which decided in July 2003 to call for the proposal to “be shelved in order to allow the public to express its preference between a wider range of options, including one or more schemes which would not provide for private road traffic to use the crossing” .

Unbalanced

The draft Transport for London policy statement has an overarching aim to achieve honest and fair consultation. It states, “We will ensure that what we say in our proposals and feedback is accurate and balanced...”.

The material that was produced for the consultation process had to tread a fine line between providing useful information on the proposed bridge and being propagandist. The consultation documents that were made most widely available were the “flyer”, a single A4-page folded consultation leaflet, of which 460,000 copies were produced and distributed and the “brochure”, an 8 page leaflet providing more detail, of which 76,600 copies were produced and distributed. The material presented whilst not being inaccurate was in many places misleading, tendentious and omitted unpalatable facts for the proponents. The main such points are:

• No environmental consequences are mentioned since the Environmental Statement was completed only after the consultation had ended.
• It is suggested that the Thames Gateway Bridge will bring wealth. The “brochure” states, “there are 27 crossings between Vauxhall and the M25 in the West, the area containing some of the wealthiest parts of the UK. To the East, from Tower Bridge to Dartford, which includes some of the least prosperous areas, there are just nine”. This statement associates the number of river crossings to economic prosperity and is misleading.
• To present the scheme as public transport friendly the brochure states that the bridge would be “designed so that it would be possible for trams and light rail to use it”. Yet it does not mention that light rail use of the bridge would mean that the trains would take over the “bus lanes” and force the buses into the general traffic lanes.
• The bridge is presented as a 650 metre crossing over the river complete with a pedestrian lane. Yet in reality, incorporating the approach viaducts the distance between useful entry and exit points would be over 1.8 kilometres long and 50 metres high and thus would be quite unsuitable as a bridge for pedestrians. By contrast the Woolwich foot tunnel is 370 metres long and about 15 metres deep. Thus the proposed Transport Gateway Bridge would be about 5 times as long and require 3 times as high climb and descent. The Transport Gateway Bridge would be quite unsuitable as a pedestrian crossing.
• Although this would be a tolled bridge, this is not mentioned prominently. The planned level of the tolls for local residents is never mentioned nor is it ever mentioned that they would be higher than at Dartford Crossing.
  

Inconsequential

One of the three overarching principles of consultation as stated in the "Listening to London" document is the demonstration that the consultation process has influenced decision-making.

The Thames Gateway Bridge consultation exercise has been a “take or leave it” approach. It has not enabled the public to engage in the decision making process. There have been no opportunities to propose alternatives or modifications to the plans.

Furthermore, following the consultation “the result of the consultation” was not “reported back to participants” as is stated is necessary in the "Listening to London" document. It is claimed that this post consultation reporting “is particularly important as Londoners tell us that feedback helps them to feel that consultation is worthwhile and that their views have been taken seriously”. But as the consultation did not meet its objective of influencing decision making, there would be no point in reporting that back to the public.

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How appropriate was the chosen methodology?

The main problem in conducting a consultation exercise on the Thames Gateway Bridge was that the public had no awareness of it. In the initial phase of the consultation (September, October, 2002), a face-to-face questionnaire survey was carried out throughout the Greater London Area and a second face-to-face questionnaire survey was carried out in the seven most affected boroughs (November and December, 2002). The level of awareness of the Thames Gateway Bridge proposal was negligible in the London wide sample and only 7% in the affected area (the seven boroughs). The same lack of awareness was registered in the 20 focus group discussions that were held in September and October 2002 and in February and March 2003.

Thus it became obvious that it was imperative to make the proposal known to the public. The methods chosen of a household distributed “flyer”, a “brochure” that was also to be handed out at road shows, static displays, adverts in the local papers and meetings with stakeholder groups were somewhat effective but insufficient. In the post campaign face-to-face questionnaire survey that was carried out in the same seven boroughs, awareness had risen from 7% to 17%.

However the biggest weakness in the adopted methodology was to combine the raising awareness campaign with the consultation proper. Thus the great majority of people were asked to comment on proposals they knew nothing about. The consequence is that the quality of responses are poor. Under such circumstances it may be quite possible that interviewers will tend to voice an opinion in agreement with what they perceive the interviewer may want to hear. However, the strength of this opinion is going to be weak since it is made with no or little knowledge of the subject matter.

An important indication of the poor results that such an exercise can bring, was that there was only a 2% to 7% response to the post-back questionnaire. It is difficult to be clear as to what was the exact response rate to the postal questionnaire as this is not mentioned neither in the Consultation Report nor in the Consultation Response Analysis Report. We can infer that if there was a postal distribution to over 40,000 homes and businesses of the questionnaire and 2,777 were received (of which 2,711 answered whether they were in favour or not of the Transport Gateway Bridge), then the response rate would be 6.8%. If the remaining 36,600 were distributed at road shows and 685 were received (of which 664 answered whether they were in favour or not of the Transport Gateway Bridge), then the response rate would be 1.8%. It is a grave omission of the Consultation Report not to mention the response rate.

Keeping in mind what was mentioned above, the quality and accuracy of the results of the consultation are poor.

The main results of the consultation come from the analysis of the responses to the questionnaire, which is referred to as the “core to the consultation” in the Consultation Report.

Conclusions that are drawn from a questionnaire that had a response rate of between 2% and 7% can only but be dubious. There was no study to investigate how representative of the entire population were the questionnaires that were returned. We can only but assume that because the response was so low, the results are likely to be non representative, in that the ones who responded were those few who were most likely to be either very strongly for or against the proposal. As mentioned before the great majority of those questioned knew nothing or little about the Thames Gateway Bridge proposal.

Furthermore, there are two reasons that render the results untrustworthy.

The first, is the tendentious nature of the brochure that accompanied the questionnaire. The “brochure” was not a neutral presentation of the case for and against the Thames Gateway Bridge proposal explaining the pros and cons of its implementation. As was mentioned above, it was in many places misleading, tendentious and omitted unpalatable facts for the proponents. If the accurate opinion of the consultees was required then the “brochure” had to be an impartial presentation of the Thames Gateway Bridge proposal outlining the possible benefits and disbenefits that it would bring.

The second reason that leave the results wanting was the poor design of the questionnaire itself.

1. The initial question asks if “a bridge” should be built “at this location”. It is not a question as to whether the specific Thames Gateway Bridge as in the proposal should be built. At no point does the questionnaire ask if the specifically proposed Thames Gateway Bridge should be built.
2. The second question asks how frequently would the respondent cross the bridge. However no price (tolling charge) is given for the crossing, thus rendering the response unusable unless one were to assume no price elasticity of demand (that means, the level of the toll makes no difference to the propensity to cross).
3. Question 3 on the type of public transport desired is vague. It does not mention any specific schemes. It does not question if the respondents would want to see the proposed Greenwich Waterfront Transit and the proposed East London Transit link up over the bridge.
4. Similarly question 4 is also vague and muddled. It asks the respondents’ preference of traffic management schemes but does say on what type of road they would want to see them applied. Very different traffic measures are applicable to local residential roads than dual carriageways.
5. Question 5 caused a total confusion. It seems to ask respondents if they support or not differential tolling based on the length of the journey undertaken that uses the bridge (i.e. higher tolls for long-distance traffic). Yet many respondents as mentioned in the Consultation Report understood the question to ask if they were in favour of tolling.
6. The last question on the Woolwich Ferry was also confusing. It asked if the Woolwich Ferry should close if “some of the traffic using the Woolwich Ferry will use the bridge instead”. Surely that depends on how much of the traffic would switch.

The Consultation Report and the Consultation Response Analysis Report do not mention the methodology that was undertaken to create the questionnaire (the “core” to the consultation exercise). Were focus groups used to determine and test the proposed questions? Was a pilot survey undertaken to check on the viability, clarity and effectiveness of the questionnaire? The poor performance and design of the questionnaire lead to the assumption that neither were carried out.

It has also to be remembered that the consultation was also supplemented by comments from the Roadshows, responses from stakeholder meetings, written responses and market research surveys. Because of the different methodologies, weaknesses in the methodologies of some of the surveys and different target audiences, the results were often contradictory.

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What were the findings from the consultation exercise?

The Consultation Report presents the results under the following six headings: Level of Support, Traffic, Public Transport, Tolling, the Woolwich Ferry and the Environment.

Level of Support

The analysis of the questionnaire reported 85% support for building “a bridge”. About 90% of the stakeholders who were approached did not express an opinion. The written responses were overwhelmingly against building a bridge (over 90%). The market research surveys showed considerable support.

The results are wildly contradictory. It may be that the positive response in the questionnaire was because it questioned the desirability of “a bridge” while the negative responses were to the specific Transport Gateway Bridge proposal.

We may thus assume that there is public support for a bridge, but not for the one that is being currently proposed.

Traffic

It is unclear what was the purpose of the question on traffic management measures. The results of the questionnaire are quite unbelievable. 21% responded that they would use it almost every day and a further 26% at least once a week.

Assuming that the above responses translate to 21% of residents on average making 14 crossings a week and 26% of residents making 4 crossings a week, it would add up to over 300 million crossings a year. Transport for London’s transport model forecasts for the bridge are of a total annual vehicular flow of 20 million. Even if we assume that 40% of the respondents’ crossings are made by public transport (and we exclude them altogether) and on average each resident’s car carries two passengers, then we still have close to an annual 100 million private vehicle crossings.

This type of result is not surprising, since as was mentioned above, the respondents had little understanding of the scheme, no information on the level of the tolls proposed and there was a response rate of only about 5%.

Furthermore, 21% of respondents claimed that they expected to cross the bridge on foot. Presumably they did not understand that to cross the bridge would involve a walk of about 2 kilometres and a climb of 50 metres.

Public Transport

Over 50% of respondents mentioned that they would like to see rail based public transport (one or more of tube, train, tram and Docklands Light Railway) crossing the bridge.

Traffic management

As the Roadshow results show “the majority of comments were about traffic impacts on individual roads and general increases in congestion”. Thus there can be no useful interpretation from the results of the questionnaire survey.

Tolling

As mentioned above, the question on tolling caused a complete muddle. The results, if taken at face value, would suggest that 40% of respondents do not want to see higher tolls for long-distance traffic. However it is most likely that they did not understand the convoluted question that was posed and what they were trying to express was their opposition to any form of tolling.

Woolwich Ferry

Overwhelmingly consultees supported the continuation of the Woolwich Ferry as can be seen from the results of the questionnaire, the Roadshow comments and the market research.

Environment

There was no question regarding environmental issues in the questionnaire. It must be remembered that the environmental report had not been published as yet. Thus if the consultees knew little about the Thames Gateway Bridge scheme, they knew even less about its environmental consequences. The Consultation Report makes very little analysis of environmental issues arising from general comments on the questionnaire or the other consultation methods.

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Were the reported conclusions in keeping with the findings?

The Consultation Report, concludes “due to the variety of ways that response was encouraged as well as the length of time available for response, Transport for London considers that this was a thorough and comprehensive consultation process. All interested parties had full opportunity and sufficient information to make informed responses on the proposal and the volume of response indicates that large numbers took the opportunity to respond”.

The consultation process was not what the above statement states. The main flaws of the consultation process were:

• No choices were presented. Consultees did not have an option of suggesting any alternatives to the Thames Gateway Bridge scheme;
• There was very poor awareness of the Thames Gateway Bridge proposal. Instead of mounting an awareness campaign and following it with a consultation exercise, Transport for London attempted to do both simultaneously;
• There was a very low response rate of about 5% to the questionnaire which was distributed (the main element of the consultation process). This was largely due to the low awareness mentioned above,
• No environmental impact information was made available as this had not yet been produced. Consultees were giving their opinions without having the full facts;
• The information made available through the widely distributed “brochure” was in many places misleading, tendentious and omitted unpalatable facts for the proponents. It certainly was not an unbiased presentation of the benefits and disbenefits of the Thames Gateway Bridge proposal.
• The questionnaire, the “core” of the consultation process was very poorly designed and many of the responses led to unusable and unreliable results.

Although the Consultation Report presents the findings dispassionately, the use that is made of them leads to serious concerns.

The results are presented without adequate warnings of their shortcomings and have the effect of misleading readers. One good such example is the Environmental Statement on the Thames Gateway Bridge which was published in July 2004, eight months after the Consultation Report was published. It states “Transport for London undertook one of its largest ever public consultation exercises between May and August 2003. The results of the consultation showed that 85 per cent of respondents support the proposal for a bridge at this location. This is consistent with independent market research findings that show around 80 per cent of people in East London support the Thames Gateway Bridge”. No mention is made that the 85% is based only on a 5% response. No mention is made that 90% of the written responses were against this particular proposal.

Furthermore, there is concern that the support “of a bridge at this location” will be easily transformed to a “support the Thames Gateway Bridge” as is done in the Environmental Statement.

Kerry Hamilton is Professor of Transport Studies at the University of East London.

Caralampo Focas is a research associate in Transport Studies at the University of East London.

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References

• Elliott John, A Solution Looking for a Problem, Transport 2000
• Friends of the Earth, Thames Gateway: Sham consultation starts on motorway-style bridge, 2003 (May)
• Friends of the Earth, Why the Consultation was flawed
• Greater London Authority, Consulting London: a framework for the core GLA, LDA, LFEPA, MPA and Transport for London
• Greater London Authority, Listening to London: good practice guidance for the GLA group
• Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November)
• Transport for London, Thames Gateway Bridge: Consultation Response Analysis Report, 2003 (November)
• Transport for London, Thames Gateway Bridge: Environmental Statement: Main Report, 2004 (July)
• Transport for London, Thames Gateway Bridge: Environmental Statement: Non-Technical Summary, 2004 (July)
• Whitelegg John, Thames Gateway River Crossing: a social, economic and environmental assessment, 2002

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Notes

1. John Elliott, A Solution Looking for a Problem, Transport 2000, p.5.
2. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.11.
3. The Transport for London Consultation Policy Statement can be found in Appendix B of the Consultation Report.
4. www.london.gov.uk.
5. Greater London Authority, Listening to London: good practice guidance for the GLA group, p.3.
6. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.11.
7. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.78.
8. “ Thames Gateway Bridge: public inquiry” - paper presented at London Transport Users Sub-Committee on Strategy and Integration, April 2005. Similar arguments have also been made by John Whitelegg in the Thames Gateway River Crossing: a social, economic and environmental assessment, 2002, p.8.
9. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.79.
10. A copy of the “flyer” and the “brochure” can be found in Appendices D and A respectively of the Consultation Report, pp.100-103 & pp.64-73.
11. The Environmental Statement concludes that “some environmental aspects would experience a net slight or moderate adverse effect”. If this were made available at the consultation stage, the results could have been different (Environmental Statement: Non-Technical Summary, p.19).
12. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.69.
13. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.70.
14. Transport for London, Thames Gateway Bridge: Environmental Statement: Main Report, 2004 (July), p.5-5.
15. Greater London Authority, Listening to London: good practice guidance for the GLA group, p.3.
16. The seven East London boroughs were: Tower Hamlets, Redbridge, Newham, Havering, Greenwich, Bexley and Barking and Dagenham.
17. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.8 & p.56.
18. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.9.
19. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.56.
20. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.19 and Transport for London, Thames Gateway Bridge: Consultation Response Analysis Report, 2003 (November), p.2, p.23 & p.24.
21. Transport for London, Thames Gateway Bridge: Consultation Response Analysis Report, 2003 (November), p.1.
22. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.43 & p.45.
23. Transport for London, Thames Gateway Bridge: Environmental Statement: Main Report, 2004 (July), p.14-18.
24. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.41.
25. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.39.
26. Transport for London, Thames Gateway Bridge: Consultation Report, 2003 (November), p.54.
27. Transport for London, Thames Gateway Bridge: Environmental Statement: Non-Technical Summary, 2004 (July), p.5.
28. Transport for London, Thames Gateway Bridge: Environmental Statement: Non-Technical Summary, 2004 (July), p.5.

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