-Capital Transport Campaign draft

Friends of Capital Transport (Andrew Bosi – secretary – andrewbosi@aol.com )

Draft of response to London Plan transport chapter (at the end of the document) and the Mayor’s (TfL) Transport Strategy

This is a draft, posted here by permission.

On the TfL Strategy:

4.2.1 Supporting sustainable population and employment growth

London’s growth [when were these projections made?  do they take long-term account of the recent downturn?  If so, please say so}

120 The London Plan also seeks to support the development and growth of Outer London in appropriate locations, such as the town centres (and thus closer to where people live) and strategic development centres. This requires improvement in radial connectivity to central London as well as improving transport links into metropolitan and other Outer London town centres. [this is the first, welcome reference to reducing the need to travel]

4.2.2.4 Delivering transport improvements within central London

131 Given the high levels of demand and the pressures on transport infrastructure and space, it is unsurprising that there remain significant transport challenges within the CAZ, despite the high levels of investment. It is essential that the currently planned capacity investment in Crossrail and the Tube is delivered; however, this will also pose challenges in terms of managing the disruption caused during construction. [good to see this recognised, but what is your solution?]

4.2.2.6 Orbital connectivity

138 London’s transport system provides for orbital travel through existing orbital bus services, orbital London Overground and National Rail suburban services and orbital roads such as the North and South Circulars. However, planning and undertaking orbital journeys can still be difficult. The strategy will seek to improve Londoners’ awareness of orbital public transport options as well as making improvements to the services themselves, where value for money can be demonstrated. The strategy will also seek to improve orbital road links. [this will just encourage car use.  what about improving orbital public transport links, by creating them where they do not now exist?]

140 The Mayor will also review opportunities to improve orbital travel opportunities by better linking radial services to Outer London town centres, for example, by combining two separate services or by improving interchange between the services.  [good, pity it comes after para 138]

Policy 7: The Mayor, through TfL, and working with the DfT, Network Rail, train operating companies, London boroughs and other transport stakeholders, will seek to increase public awareness of existing and planned orbital public transport connectivity in Inner London and seek to improve orbital connectivity in Outer London, particularly between adjacent metropolitan town centres, where shown to be value for money. This policy is taken forward by proposals: 14, 15, 16, 23, 34, 39, 45 and 46. [shd be specific about linking bus routes]

4.2.3.1 Integrating land use development with transport planning

144 Using land use policies contained within the London Plan, the Mayor will encourage patterns and forms of development that improve accessibility of services and reduce the need to travel. High trip generating development will be encouraged in areas with good public transport access and sufficient existing or planned public transport capacity. In east London, in particular, a priority is to maximise development opportunities around existing or committed transport infrastructure, making the best use of available capacity (for example, the Royal Docks).  [second welcome reference to this]

145 Through setting appropriate parking standards, encouraging smarter travel planning and making public transport more attractive, the Mayor will encourage the use of public transport, walking, cycling and car sharing. [the danger is that encouraging car sharing will simply encourage car use and public transport will be used less]

Policy 9: The Mayor, through TfL, and working with the DfT, Network Rail, train operating companies, London boroughs and other transport stakeholders, will use the local and strategic development control processes to seek to ensure that:

a) All high trip generating developments are located in areas of high public transport accessibility, connectivity and capacity (either currently or where new transport schemes are committed)

b) The design and layout of development sites maximise access on foot, cycle and to public transport facilities, for example, via safe walking and cycling routes and provision of secure cycle parking

c) Access for deliveries and servicing, maximise the opportunities for sustainable freight distribution where possible

d) Land for transport use is safeguarded in line with London Plan policy and Supplementary Planning Guidance

e) Planning contributions are sought for transport improvements where appropriate

This policy is taken forward by proposals: 2, 9, 15, 22, 38, 45, 47, 48, 49, 50, 53, 56, 57, 59, 96, 98, 118 and 125.  good, but a) is not happening in practice.  How are Boroughs to be compelled to implement e)?

Policy 10: The Mayor, through TfL, and working with the DfT, Network Rail, train operating companies, London boroughs and other stakeholders including the private sector, will seek to improve the efficiency and effectiveness of the operation of the transport system, bring transport assets to a good state of repair and then maintain them in that condition. This policy is taken forward by proposals: 10, 11, 12, 13, 17, 18, 19, 21, 23, 24, 30, 31, 32, 33, 35, 39, 45, 46, 114, 115, 116, 117, 118, 120, 121, 122, 128 and 129. [what about people who need to travel on Sundays?]

4.2.3.3 Changing travel behaviour

Policy 11: The Mayor, through TfL, and working with the DfT, Network Rail, train operating companies, London boroughs and other stakeholders, will seek to reduce the need to travel, encourage the use of more sustainable, less congesting modes of transport (public transport, cycling and walking and the Blue Ribbon Network), set appropriate parking standards, and through investment in infrastructure, service improvements and promotion of smarter travel initiatives and further demand management measures as appropriate, aim to increase public transport, walking and cycling mode share. This policy is taken forward by proposals: 50, 51, 52, 53, 56, 58, 60, 61, 82, 114, 115, 119, 124, 126, 128 and 129. [good, but completely undermined by the new business plan]

Policy 14: The Mayor, through TfL, and working with the DfT, Network Rail, train operating companies, London boroughs and other stakeholders, will seek to improve transport’s contribution to the built and natural environment. This policy is taken forward by proposals: 82, 83, 84, 89 and 112. [this sounds fine but what is the reality?  Money is tight e.g. to build CrossRail, so the stations have a minimalist architectural approach]

4.3.4 Improving air quality

177 Air quality is critical for health and wellbeing. It has been estimated that Europeans each lose an average of eight months of life expectancy due to the impact of air quality. Many vulnerable people, such as children, older people and people with existing heart and lung conditions, are restricted in the range of activities they can undertake as a result of air pollution. Approximately 690,000 people in London have asthma, which is exacerbated by high levels of air pollution.

178 The highest concentrations of particulates (PM10) and oxides of nitrogen (NOx), the two main types of harmful air pollutants in London, are found around busy roads, diesel railways and Heathrow. Transport is responsible for more than two thirds of PM10 emissions in London and nearly half of NOx emissions.

179 The Mayor has a legal obligation to work towards meeting national and European targets for air quality, and a statutory duty to have an Air Quality Strategy. To protect human health the EU has set ‘limit values’ for PM10 and nitrogen dioxide (NO2). Despite improvements in recent years, London is at risk of not meeting PM10 limit values by 2011 at some central London locations. Longer-term, the Mayor has an ambition for London to have the cleanest air of any major European city. Due to road transport in particular being a large source of these air pollutants, the transport strategy will play a key role in supporting the Mayor’s Air Quality Strategy, thereby helping the UK to meet these limit values and improving quality of life.

180 Air quality is currently known to have adverse effects on habitats including European designated sites of nature conservation importance. The Mayor’s commitment to a reduction in emissions from transport also aims to reduce the impact on such sites.

Policy 15: The Mayor, through TfL, and working with Defra, the DfT, Network Rail, train operating companies, freight operators, London boroughs and other stakeholders, will seek to reduce emissions of air pollutants from transport. This policy is taken forward by proposals: 25, 90, 91, 92, 93, 94, 102, 104, 107, 112, 128 and 129.   {this too is fine, but it is secondary to achieving modal shift    away from the private car towards public transport.  Again the effect of the business plan is modal shift in the wrong direction}

4.3.5 Improving noise impacts

182 Noise is a quality of life issue as it can significantly affect health and wellbeing. It can lead to increased annoyance, anxiety, sleep disruption and can be associated with cardiovascular disease, through increased hypertension. More people in London are more bothered by noise from transport than by loud neighbours. The Mayor has a legal duty to address ambient noise (ongoing unwanted sound in the environment such as transport and industry) and is required to have an Ambient Noise Strategy. The transport strategy thus can contribute to a better noise climate within London, enhancing the health and wellbeing of all.   {A recent Mayor’s answer suggested that it is sufficient to check the noise level of new buses.  Most of the criticism and concern relates to buses after they have been in use for two or more years}

236.  If cars become “essential” in outer London people in inner London who visit outer London will need them too.  Must emphasize public transport and ensure at least a bus orbital link.

265.  Proposal 6 is probably necessary, but it would be good to hear something about encouraging GLA residents into jobs and thereby reducing the need to travel.

267.  Despite the widespread acceptance of HLOS, TfL appears to have dropped funding for the SLL.

268.  The Mayor previously berated his predecessor for not getting Oyster accepted before end 2009.  Now it has slipped to December 31st 2010.

Gauge enhancements to the Barking-Gospel Oak line are less important that electrification.  I am not convinced it can take more freight; the first priority is to raise capacity to meet passenger demand.  This is why the provision about Nuneaton-Felixtowe is so important to London and Londoners.

270.  Welcome words, somewhat removed from practice where the SLL is concerned.

274.  I am all in favour of keeping the pot boiling on Hackney-Chelsea, or Crossrail2, but having another review of the route is reminiscent of Cross Rail 1.  Countless reviews consistently resulted in a decision that the original plan was the best.  Heaven knows how much money was wasted on this.

279.  Proposal 11.  The priorities seem to be designed with who pays in mind, i.e. demoting the stations for which TfL has more responsibility.  Ealing Broadway is the most overcrowded station in London; Finsbury Park is inappropriate for the volume of passengers once TL2000 is complete.  Of course, there is a scheme for Finsbury Park, which TfL has undermined by opting out of making the tube part of the station step-free accessible.

280.  and Proposal 12.  I am pleased to read this: Sunday travel is a nightmare and for those of us who travel more that day than any other public transport is now very poor value.  What does the Mayor propose to do to put the words into practice?

286.  There is widespread all party support for the Overground developments.  However, rather than look for extra lines, attention could be given to stations and interchange with passing lines.  The Barking/Gospel Oak line crosses eight railways and interchanges at Walthamstow and Hackney could be achieved at relatively low cost.

299.  (& Proposal 17) Work cannot be achieved overnight, but there has to be a balance at weekends between getting the work done and maintaining essential services.  The deep tubes are often underneath main roads and the replacement bus service is relatively efficient, compared with replacement buses for the Overground.  In its case there are often low bridges crossing the most direct alternative roads, or else the roads are at right angles to the rails.  The best alternative is often a quite circuitous alternative rail route; there is double jeopardy if that too is out of commission.  More thought needs to be given to the knock-on effects of one closure on users affected by another.  Sometimes more intensive work over a shorter stretch of line might meet the case.

303 & Proposal 18.  We recognise that there is more to access than being “step-free”.  However, when Network Rail are introducing lifts in their part of a shared station as at Finsbury Park, it is cost effective for TfL to do the same.  Where a space has been created for a lift as it Shepherd’s Bush, it makes no sense to defer or cancel planned work.  There is little point in fine words in a Plan if they are contradicted in practice.

308.  It is a bit of a hostage to fortune to list examples of congested stations because everyone will raise the circumstances of their own local stop.  However, as an occasional user of Ealing Broadway it does seem that it is more congested than those listed.  It would be sensible to have criteria, like footfall per square foot per hour per pound needed to be spent.

316 – proposal 21.  It would be nice if the information extended to cover local heavy rail services.

322.  The volume of buses on Essex Road and Walworth Road put these at the head of the need list for tube expansion and it is good to see the latter addressed here.  It is also pleasing to see that the Mayor has not lost sight of the importance of the Croxley link to London, even though it falls outside the GLA boundary.  The cooling of trains will be expensive; it would be good to read of ways of capturing the heat and making use of it.

333.  It is unclear whether cuts in services are ruled out, and if not, less clear how they would be determined.  The preamble talks about the value of a simplified service in terms of passenger understanding, but there is no doubt that service patterns differ at weekends and that this simplification has come at the cost of lower occupancy rates – despite the fact that the average of 15 per bus, if it is still true, is well ahead of elsewhere in the UK.

339.  This needs to be revisited before submissions are made because action is promised within the consultation period.  Word is that any iconic Bus for London will bear little resemblance to the competition winners and perhaps this is why the section about this is unnumbered.

5.6.2  Smoothing traffic flow

364.  What does this mean?  The text talks about motorists planning their journey times – what about public transport users, who are also pedestrians at the origin, destination and between modes?  A much better objective, consistent with all the environmental targets, would be to seek to minimise μ + 3σ where μ is the mean and σ the standard deviation.  Reducing the average journey time of a bus does not necessarily achieve this, most obviously if you take out all the intermediate stops.

Proposal 30b.  I do not share the (two) Mayors’ enthusiasm for motorcycles.

Proposal 38.  We support the use of the canal and river for freight and leisure trips.

5.9 A more accessible transport system: proposal 40.  While it is good to see the Mayor looking beyond “step free” access to meeting other access needs, the evidence in practice of planned schemes being halted is deeply worrying and belies the fine words here.

The reference to bus stop accessibility and clutter ignores the biggest problem, that over the years stops have moved further and further from the desire point which is the junction.  People giving friends a lift drop them off at junctions: why should buses not stop there?  They are carrying dozens of people, the cars that might be slightly delayed as a result carry on average approximately 1.1 people.

430.  The proposals on door-to-door transport are fine, but the text here reads as a threat to them

5.10.2 Strategic interchanges: proposal 46.  The proposal is welcome, but only if not implemented at the cost of severing direct radial routes.

Proposal 54.  We should welcome the attempt to address the bad behaviour of a minority of cyclists and linking it to improved conditions for cycling.  It does not though need a change to the highway code to implement a contra-flow cycle lane, which would be the safe means of achieving two-way cycling in a one-way street.

5.17 Better Streets

Figure 51: I do not like starting with a blank canvas: the traditional building line is important in defining the street.

5.18 Noise impacts

Most people find the emergency service vehicle sirens unnecessarily intrusive.  They are sounded even when the road is clear, and why do we have to copy America?  What was wrong with the two tone siren that said simply, “I need to reach an emergency, please move aside”, instead of “another crime in your neighbourhood, despite what we say about reduced crime levels”.

Emissions from public transport

601 & Proposal 91.  We warmly welcome the strong support for railway electrification, in particular the Barking/Gospel Oak line.  It is unfortunate that paragraph 642 refers only to lobbying as the means at the Mayor’s disposal: what about funding in part through a business rate?

Reducing transport’s contribution to climate change

Reading these paragraphs, and looking at figure 58, it is impossible to avoid the conclusion that road user charging is essential if we are serious about the emissions target.  So the text is too timid.  Worse, we understand the Mayor has already ruled out road user charging even though his own document makes so compelling a case for its introduction.  Car clubs are a drop in the ocean in comparison to buses; up to 4 people can share a car, over 90 can share a bus.

632.  The report is again in denial when it comes to aviation.  Growth is not essential to our place in the global economy.  If aviation continues to pollute at an ever faster rate, there will be no global economy because there will be no globe.

Paragraph 647 and proposals 107 & 108 need to be far more robust if the mayor wishes to demonstrate “innovation and leadership”.  For instance, there have been more than five hydrogen powered buses before this consultation began.

Proposal 112 would be improved if it referred to a net increase in trees: planting 10,000 is of little consequence if more than that number have been uprooted.

Managing demand for travel

This is absolutely fundamental to delivering a decent transport infrastructure, yet there is no cross reference to the spatial development plan to emphasize the value of mixed development in bringing jobs close to people’s homes.  There are two ways of dealing with the mismatch between jobs and skills, namely training and providing more of the jobs that people can do locally, yet the latter is almost always ignored.

A minor point: spider maps are of little help for longer distance bus travellers, and none at all to pedestrians who used to be able to use bus maps to find their way on foot.

Freight in London

A ready made resource for high value small size freight goes unused in the form of the Post Office railway.  Why is the strategy looking for ways of bringing it back into use?

5.23  Fares

Proposal 119 is disingenuous, and policy 32 in chapter 8 vague..  The strategy should indicate what is a fair division between government subsidy, Council tax payer and fare payer.  There should also be a constant relationship between bus and tube fares, unless there are dramatic improvements in services from one mode, in which case any differential increase should be linked to that change.  What we are seeing now are disproportionate increases in bus fares at the same time as cuts in bus mileage are proposed.  Fares in inner London where tube and overground services exist are suddenly cheaper than buses.  The fare increase thus falls more heavily on Outer London, which is most vulnerable to adverse modal shift.

Proposal 122 (reducing the cost of revenue collection) needs more work, to ensure that the effect is not to discourage use of public transport or accidental overcharging of fare paying passengers.

5.24 (7) Park & Ride

707. & Proposal 126.  The Mayor needs to be wary of schemes which encourage people to drive to a park and ride node where previously they would have walked to a local but less well served railway station.

5.25 Road user charging

The cost of driving into the CGZ must remain higher than the cost of a daily zone 1-2 travelcard.  We would like to see data on the adverse impact (if any) of the Western Extension on the original zone, before any final decisions are taken.  Has there been an increase in car borne commuting between the old and new zones as a result of the Western Extension?

The admission in paragraph 712 that bus services fail adequately to provide a satisfactory alternative to the private car is astonishing.  It should be addressed and the effects analysed before any decision on the future of the Western extension.

We would contend that the loss of £70m. per annum from the TfL budget would have a significant negative impact on the mayor’s ability to meet his policies and proposals and that this alone prevents revocation under the terms of the GLA Act (see paragraph 721).

6.2  Anticipated outcomes.

There is no explanation offered for the lesser shift to sustainable modes put forward in figure 64 than had been planned when TfL published Transport 2025 three years ago, even though those targets were for 2025 and these are for 2031.

The criterion for enhanced transport connectivity (figure 65) is inappropriate.  Reduced average journey times could be achieved by taking jobs from people in Chingford and giving them to residents of Ashford. (see 6.6 of The London Plan)

It is clear from figure 66 that maintaining bus reliability (no hope of improving it) is dependent upon road user charging being implemented, given the planned cuts in bus mileage.

7.  Implementation plan.

We note that some of the dates quoted in the printed documents have already been put back before the close of the consultation period.  The phasing out of bendy buses by 2011 will also not be achieved although this is not one of the amendments which the Mayor’s office has subsequently published.

8.1.2 Capital Investment costs

The balanced investment profile referred to in paragraph 765 has already been undermined by the decision to abandon work on the development of schemes previously scheduled for the medium term.

8.2.3 Bus funding

The document (para. 774) repeats the false assertion that bus fares compare favourably with other modes.  Three adults in a car, one adult travelling from Hackney to Harrow … there are numerous examples to contradict this assertion. (see above for comment on policy 32).

8.2.4 Rail funding

Given the problems with the Central line upgrade, with Metronet and now Tubelines, it is surprising to see PFI upheld as a good thing in paragraph 781.

Chapter 6 of the London Plan

It is most welcome to see reducing the need to travel at the head of the strategic shopping list.  I much prefer the formulation in paragraph 6.6 to that in figure 65 of the Transport Strategy.

Policy 6.11.  The London Plan is consistent with the Transport Strategy in failing to shed any light on what “Smoothing Traffic flow means.  In particular, it is difficult to reconcile with the preceding policy about encouraging walking.

6.39  I would strongly support some refining of how Public Transport Accessibility Levels (PTALs) are calculated.  In particular, access on foot from origin to bus stop/ station is crudely assessed.  A tower block with only two lifts is less accessible than a terraced street of the same density.  A park is more accessible comprised of grass than with a canal running through it.


One Response to “-Capital Transport Campaign draft”

  1. This is a fine text but needs some critical refinement. I’m looking at 2 adjacent paragraphs:
    Managing demand for travel

    “This is absolutely fundamental to delivering a decent transport infrastructure, yet there is no cross reference to the spatial development plan to emphasize the value of mixed development in bringing jobs close to people’s homes. There are two ways of dealing with the mismatch between jobs and skills, namely training and providing more of the jobs that people can do locally, yet the latter is almost always ignored.”
    MY COMMENT. Good but actually nobody knows the extent to which “mixed use” areas reduce the need to travel. The chances of a Londoner having a job in the same development which (s)he lives in are minuscule. If there are some shops in the scheme then some longer journeys may be obviated. But it needs study. Most of London is NOT made up of new developments and the key thing is therefore to find out what changes help reduce the travel involved in all of us doing the shopping, getting to school, hospital, gym etc etc.

    “A minor point: spider maps are of little help for longer distance bus travellers, and none at all to pedestrians who used to be able to use bus maps to find their way on foot.”
    MY COMMENT: Yes but you are being very harsh. They are BRILLIANT devices when you are at the bus stop or planning a journey because they tell you exactly whether and how you can get where you want. They have to be combined with local area large scale plans to help pedestrians. Every tube station has those but for some reason bus stops never do (though they do on Germany and no doubt Holland).


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