TfL Consultations and How to Influence Them

It has been apparent for some time that when Transport for London (TfL) undertake a public consultation they get many responses from cyclists and public transport users, but few from other road users. The result is that the ensuing consultation report shows a very biased picture of the views of the general public.

Why is this? It’s because TfL prompt responses by sending out emails. For example they sent out over 400,000 emails about the Hackney Cycleway proposals (described here: https://tinyurl.com/y6fxezmq ).

How did people get on their email contact list for this consultation? From an FOI Act request I can give you the answer. Some 81 people were bespoke to the consultation and were selected from “TfL’s Local Communities and Partnership” team. Another 4,875 came from statutory consultees (police, fire service, etc) and others who asked to be kept informed on TfL consultations. But the vast majority (473,210 to be exact) came from their Customer Database. That means everyone no doubt who has an Oyster Card or Freedom Pass or has opted to receive TfL travel information. So you can see why the result of the public consultations is biased towards public transport users.

How can private car users, taxi users, PHV users or LGV/HGV users influence the consultations? All you need to do is register to receive consultations by signing up on this web page: https://consultations.tfl.gov.uk/sign-up/0f3971fe/ . In addition you can sign up here for news updates: https://tfl.gov.uk/travel-information/social-media-and-email-updates/email-updates .

Adding your name to both those lists should ensure that you get information on new consultations and enable you to have your say. MAKE SURE YOU SIGN UP NOW!

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The Latest On Hammersmith Bridge

Hammersmith Bridge in west London has been closed since April due to critical safety problems. This was a key part of the road network in west London and was used by 20,000 vehicles per day including many buses. There has been discussion between TfL and the London Borough of Hammersmith and Fulham on what to do about the bridge, and it could cost as much as £120 million to restore the bridge to support previous traffic levels, or even more if it was substantially reinforced.

Construction work may not start until 2021 and it might take 3 years to complete so it looks like local residents will have to put up with the closure for some considerable time. However there is one alternative which gives a better solution. That is to build a temporary bridge alongside the existing one. This might only cost £5 million and could be put up very quickly. See https://tinyurl.com/y4fyrjwj for an article in the New Civil Engineer for more information. The Mayor says it is seriously being considered.

I am sure all readers will support prompt action on this matter, and a commitment to fund the projects. But note that tolls may be imposed on the bridge to fund the work required.

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Driverless Vehicles, Air Pollution Claims and Scrappage Scheme

Streetwise Vehicle Ed

Residents of the London Boroughs of Croydon and Bromley need to look out from today (24/10/2019) because for the first time, driverless cars will be present on their roads. These will be operated by company FiveAI and may carry passengers but will always have somebody at the wheel ready to take over. These are basically trials run by a consortium named Streetwise.

How will they cope with the problem that London’s roads are very unlike the West coast of the USA where most such trials have been conducted to date. Stan Boland, CEO of FiveAI said “We have lower lighting, higher rainfall and greater density of road users and we also have to deal with erratic, medieval street plans that are nothing like the grid systems of the US”. However these trials are not quite so revolutionary as first appears because they will actually be on a “fixed route” – see  https://tinyurl.com/y4n8zfnq for more details.

Comment: Mr Boland did not even mention the occasional fog and snow. I remain sceptical of the general applicability of this technology when even my very intelligent TomTom satnav sometimes gets lost in central London. There are claims that it might save lives from reduced accidents, but Gill Pratt, CEO of Toyota Research has recently acknowledged that driverless cars might actually kill people. They may reduce accidents overall by removing driver error which is the cause of many accidents, but it seems software errors may still be  problem.

Sadiq Khan, Mayor of London, has published claims that the ULEZ scheme in central London has reduced air pollution very substantially. He claims roadside NO2 pollution has fallen by 36% in the zone with no increase in the surrounding area. He attributes this to a large reduction in the number of older or polluting vehicles entering the central zone. This is hardly surprising as operators of older LGV vehicles will have found it financially wise to change their vehicles. But we doubt the claims about the actual reductions in emissions which we believe are estimates based on vehicle numbers rather than actual air quality measurements. We have submitted an FOI Act request to obtain more information. There is likely of course to have been some reduction due to renewal of the vehicle fleet over time (newer vehicles generally have lower emissions) and specific changes in the bus fleet and a strong focus on higher polluting commercial vehicles such as HGVs. But many of the pollutants in the air come from other than road transport vehicle sources and much blows in from elsewhere in the central zone.

The Mayor has also announced a £25 million scrappage fund for low-income Londoners. This is aimed at helping them move to less polluting vehicles. Motorists will be able to get up to £2,000 for scrapping older, more polluting vehicles. How many people will be able to take advantage of this scheme? Only a minority in essence because only people who are receiving means-tested benefits or disability allowances will qualify and as the fund is limited in size it may be on a “first come, first served” basis. In addition it’s probably needless to point out that £2,000 does not buy you a new car, and not even a good second-hand one. The conclusion is only people on benefits with cash in the bank to help buy a new vehicle may find it helpful. It’s surely a token political gesture which is what we tend to see from Mayor Sadiq Khan.

The latest scare story about air pollution is that on high pollution days in London it might cause an extra 87 cardiac arrests per year, an extra 144 strokes, and 74 children and 33 adults ending up in hospital with asthma-related issues. This is a claim made by researchers at King’s College London based on a study relating high pollution days to medical events.  NHS England boss Simon Stevens said it was evidence of “a health emergency”. But this is a very simplistic analysis of complex data. Such days might also be very hot ones which are known to trigger medical events. Even the claimed numbers are very small. In London. For every 100 cardiac arrest ambulance call-outs on low-pollution days, they would expect to see 102 on high-pollution days. It’s basically a statistical fraud derived from epidemiology.

Regrettably we seem to be suffering from air pollution hysteria at present. Few people look at the evidence from an unbiased scientific viewpoint and most of the claims made do not stand up to scrutiny by anyone with a scientific background.

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Westminster Proposes 20 MPH Limit Everywhere

The City of Westminster is proposing to implement a 20 MPH speed limit on all its roads. The only exception will be those roads they do not control which are TfL controlled roads and where TfL may impose such a limit anyway. This move is despite the fact that a report published by the Department of Transport shows there is no road safety benefit in signed-only 20 MPH limits and there is also no evidence of any other benefits.

Readers should oppose this move, which is in essence a waste of money that would be better spent on other measures, by responding to the public consultation here: https://www.westminster.gov.uk/20mph

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Londoners May Face £100 For Engine Idling and Decriminalisation of Speeding Offences

London Boroughs may gain powers to fine motorists £100 who leave their engines running under a Bill introduced in the House of Lords. That’s up from the maximum £20 at present. In addition those who run diesel generators when air pollution is high may be banned – Extinction Rebellion please note as they ran a portable generator recently to support a demonstration.

The installation of new ‘combustion plant’ machinery, which includes gas boilers, solid fuel boilers, combined heat cooling and power plant, and stationery generators would only be permitted if the amount of nitrogen oxides (NOx) and particulate matter (PM) emitted by the plant did not exceed a limit set by the Secretary of State.

These measures are aimed at overcoming the defects in the current Clean Air Act that are ineffective in controlling some pollution when non-transport related emissions are likely to become the majority very soon. Note that the Mayor of London is also looking for more powers in this area but it would surely be better if such powers were given to the boroughs rather than the Mayor.

Comment: these measures are not unreasonable although the impact on air pollution of engine idling is probably minimal even though it causes a lot of annoyance to residents when people park outside their homes and do it. But enforcement is difficult so little practical impact may be the result. See https://tinyurl.com/y2meb4s4 for more details. There is also no mention of wood-burning stoves which are one of the biggest problems at present.

The aforementioned Bill is being introduced in the House of Lords as a private members Bill so progress is not guaranteed. Another Bill being introduced in that way is one to decriminalise speeding offences. That should surely be opposed as it would lead to an even greater number of fines for speeding with the sole motivation of extracting more money from motorists. That is what happened when parking offences were “decriminalised” so that Local Authorities could enforce them. See https://tinyurl.com/sr37oef   for more information

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No Justification for 20 MPH Limits in Safer Speeds Proposals

I have written previously on the proposal to introduce a 20 MPH speed limit on major roads in central London, and probably in the rest of London later. I criticised the failure by Transport for London (TfL) to publish any cost/benefit justification and submitted an FOI Act request to obtain that information which TfL refused. See References below for the full story.

After appealing to the Information Commissioners Office (ICO) about the refusal by TfL to provide the requested information, which should have provided a justification for their proposals in advance of the public consultation, I have had my complaint upheld by the ICO and have now received the requested information. See Reference 5 below which contains the Business Case published very recently. This is very similar to a draft published in 2012 which was available well before the consultation was launched and hence should have been made available (See Reference 6). However, the numbers in the later version on which the cost/benefit is calculated were much different with the capital cost being reduced very substantially and the collision reduction benefit almost doubling. The outcome is of course a very clear positive benefit as a result.

It is clear that TfL deliberately concealed the earlier version because it provided marginal benefits. But both versions are seriously defective because they do not include all the costs in the analysis. For example, they do not include:

  • The economic costs of increased journey times. Although average speeds during a lot of the day are less than 20 mph on these roads, they are higher at other times and ignore the fact that between junctions and traffic lights/pedestrian crossings, the speeds are higher.
  • No costs are included for enforcement of the 20 MPH limits.
  • No costs imposed on drivers from paying fines for exceeding the limits are included, which will likely be quite substantial.
  • They discount the suggestion that lower speeds would increase emissions from vehicles and hence have not evaluated it which is contrary to readily available evidence on that issue.

In other words, TfL concealed the original “Business Case” on spurious grounds thus defeating a fair public consultation and then adjusted the numbers to give the required answer while not including all the associated costs. This demonstrates exactly why TfL are not to be trusted and should be reformed.

But one moral for readers is do not accept refusals to FOI Act requests. Such refusals are often unreasonable and are just a mechanism to delay answering and hence concealing information until it is too late to be useful. This is of course unprincipled in the extreme. TfL do this repeatedly and perhaps the ICO will deal properly with this issue if they get enough complaints.

In the meantime the Mayor of London, Sadiq Khan, who is a party to this dubious activity should ensure TfL act more responsibly. I will be sending him a complaint on this issue.

Reference 1: Consultations in Name Only and Safer Speeds: https://tinyurl.com/y3gqh5hh

Reference 2: Consultations in Name Only: https://tinyurl.com/y6lpuusp

Reference 3: 20 MPH Speed Limits in London on Major Roads: https://tinyurl.com/y5ntxu4a

Reference 4: 20 MPH Speed Limits Spreading in London: https://tinyurl.com/y3r9bddp

Reference 5: Business Case 2019: https://tinyurl.com/yxt9fy2d

Reference 6: Business Case 2012: https://tinyurl.com/y2zd7hko

Roger Lawson

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Pelican Crossing at the War Memorial Junction in Chislehurst – Council Decision

As mentioned in a previous blog post (see https://tinyurl.com/y56v2rty ) a petition signed by over 3000 people was submitted to Bromley Council for a Pelican crossing to be installed on the War Memorial Junction in Chislehurst. The previous blog post gives a full analysis of why it was not necessarily a good idea.

Tonight the full Council met to consider the petition. Chris Wells who promoted the petition was allowed to speak for 5 minutes but clearly did not convince Councillors to change their minds. He reiterated his past arguments on the need for a pedestrian crossing phase. A resolution was passed by a very large majority of Councillors to let the previous response from the Council stand. In addition a motion from Councillor Dunn to require the Environment Portfolio holder to submit a proposal within 6 months was also defeated.

Councillor Huntington-Thresher who holds that position explained that the junction had been the subject of several studies but most were unable to be progressed due to the restrictions on land usage imposed by the Chislehurst Commons Trustees. However, they will continue to look at the junction but no immediate change is proposed.

He stated they had modelled traffic flows at the junction (which Chris Wells claimed had not been done) and if a pedestrian phase was added the traffic queues could triple in length. [Comment: that would certainly be a major annoyance to many people as they could stretch for much more than a mile and would also generate a lot of “rat-running” down side roads which was a concern for road safety]. Councillor Huntington-Thresher said we need a “holistic” solution.

He also stated that despite the claims of road safety danger, the relevant section of the A222 was actually only the 40th most dangerous in the borough. There was no trend in accidents and there were no injury accidents in 2018. In other words, resources might be better spent elsewhere to improve road safety. He also said it was not necessarily possible to submit a proposal within 6 months so opposed Mr Dunn’s motion.

Councillor Katy Boughey who represents the Chislehurst Ward spoke in support of the aforementioned response and said that they were actively working with all relevant parties to find a solution. Council Leader Colin Smith seconded the motion to make no change to the previous response and referred to regrettable “excitable hysteria” on Twitter on the subject.

The above is a brief summary of the meeting to debate on this subject. Let us hope that those who support Mr Wells actually listen to reason and engage with councillors, council staff and other local stakeholders to develop a good solution to improve this junction. Any solution needs to take into account road safety issues, traffic congestion problems and the interests of both pedestrians and road users. Any criticism of councillors or council staff would be misguided. You don’t solve road safety and traffic management issues by emotive hysteria.

I hope the above is a reasonably accurate note of what happened but anyone else who was there can correct me or add further comments if required.

Roger Lawson

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Sadiq Khan’s Election Manifesto – Have Your Say

The Labour Party are inviting everyone to have their say on Sadiq Khan’s Manifesto for re-election as London Mayor in 2020. You can read about his achievements to date and submit answers to their questions via this web page: https://tinyurl.com/y29yu999 . It is of course a very biased document like all consultations that Mr Khan presides over, but anyone can respond – you don’t need to be a Labour Party member.

Perhaps the Mayor is short of ideas to ensure he gets re-elected. His last big vote winner was freezing public transport fares but after three years of holding the tide back of inflation in King Canute fashion he has managed to dig a deep hole in Transport for London’s finances which simply cannot continue. Bus services are being reduced as a result while traffic congestion increases. His policies on Congestion Charging and the ULEZ will impose higher costs on many Londoners with minimal public health benefit. He has also clearly failed to tackle rising violent crime and not solved London’s housing problem – indeed his only proposal for the latter is to introduce rent controls which would make matters worse.

But he does admit to increasing the Council Tax Precept (what you pay to the Mayor from your local council taxes) to the maximum allowed. No thanks Mr Mayor. All his other claimed achievements are quite trivial in relation to the problems Londoners perceive as key issues.

All the way through the document, the Mayor emphasises that he has limited powers over many aspects and clearly wants more. But it would be very dangerous to give him more.

Here are some of the questions and how you may care to respond to them (I have only covered those questions that are relevant to transport):

Environment and Climate Change:

Question: How do we take the next steps to clean up London’s air and oversee a massive shift from polluting cars to walking, cycling and electric vehicles at the same time?

Answer: concentrate on fixing the vehicles over which you have control and which are major contributors to air pollution, i.e. diesel buses. You also need to tackle air pollution on the Underground. Otherwise any measures should be justified on cost/benefit grounds and scare-mongering over an imaginary public health crisis as the justification for higher taxes should be stopped. The expansion of the ULEZ to the North/South Circular should be halted and the introduction of more Cycling schemes that create more traffic congestion (and hence air pollution) should be halted.

Transport:

Question: How else can Sadiq make London’s transport system affordable and accessible to all Londoners?

Answer: Stop wasting money on schemes with very poor cost/benefits (such as the proposed Rotherhithe bridge and most of the Cycle Superhighways the finance for which has to come out of public transport fares. He needs to stop spending money and imposing taxes on road users to make the transport system more affordable for everyone. That includes halting the investment in 20 MPH speed limit schemes and cycle schemes that have poor cost/benefits. He should also cease support of road-pricing and workplace parking levies.

Question: What are the future major schemes that Sadiq could focus on delivering?

Answer: The Silvertown Tunnel is one which will be a major benefit for east London. Repairing the Hammersmith Bridge is another for West Londoners. Improving major east-west and north-south road routes such as the Embankment rather than degrading them with 20 MPH speed limits and cycle lanes should be another key objective.

Question: What more can be done to promote walking and cycling?

Answer: Some youth elixirs for the elderly and inform would help and concealing the dangers or cycling is another. That is of course just a witty response to a proposal that is unnecessary and has major disbenefits.

Question: When asking for more powers and devolution from Government on transport issues, where should Sadiq focus his energies?

Answer: Give the Mayor powers to introduce policies to reduce the population of London so as to reduce pressure on the transport, housing and public health systems. Specifically redistribution of business and people out of London and powers to reduce immigration and encourage birth control.

He should also argue for a commitment to devolve more powers to local boroughs so as to avoid TfL dictating local borough policies and more funds financed by central Government to be given to local boroughs solely to be used on improving the road network in London. In addition the Mayor should be given the power to set sensible minimum parking standards for new developments (not maximum ones) in London boroughs.

Those are just a few ideas to help Mr Khan, or indeed his opponents, to get elected.

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Press Release: London and Paris Have The Same Problem: Their Mayor

Smog

Paris ‘smog days’ have increased from 5 to 22 per year in the past 4 years as a direct result of the Mayor’s anti-car policies and despite a low emission zone (Ref. 1).

Paris now has fewer cars, but emissions have increased due to more congestion caused by cycle lanes, pedestrianisation and 8000 construction projects. Hamsa Hansal, who owns a fleet of 10 cabs, describes the Mayor of Paris as “a hysteric. Nothing but bicycle lanes and construction sites. Total chaos. Such BS. Traffic jams 24/7” (Ref. 2).

It’s well known that increasing congestion increases emissions. This fact seems to have escaped successive London Mayors and the Mayor of Paris, who seem hell-bent on grinding economically essential traffic to a halt – traffic that can’t be replaced by walking and cycling. This results in a vicious circle of increasingly punitive air quality measures against drivers costing orders of magnitude more than even the claimed benefits. It seems that obstructing traffic and raising revenue from drivers takes priority over improving air quality.

Notes for Editors:

(1) Paris Low Emission Zone (ZCR):

https://www.lez-france.fr/en/information-about-the-critair-vignette/french-environmental-zones-zcr/paris-zone-zcr.html

(2) New York Times – The Greening of Paris Makes Its Mayor More Than A Few Enemies:

https://www.nytimes.com/2019/10/05/world/europe/paris-anne-hildago-green-city-climate-change.html

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Is a Pelican Crossing Justified at the War Memorial Junction in Chislehurst?

OLYMPUS DIGITAL CAMERA

A petition signed by over 500 people has been submitted to the London Borough of Bromley. It requests a push-button request for pedestrians (a “Pelican” crossing) be installed at the traffic light junction on the A222 – the Chislehurst war memorial junction. The petition is to be discussed at a full council meeting on the 14th October.

Is such a change justified and what would be the impact?

Anyone familiar with the junction will be aware that this is a heavily congested part of the road network in Bromley. It is key route between Sidcup and the A20 into central Bromley and vice versa. During rush hours queues of traffic back up from the existing traffic light controlled junction to the A20 in the mornings, and back down Summer Hill in the evenings. This already causes some vehicles to take routes on narrow roads around the junction, e.g. via Bull Lane/Church Lane/Watts Lane or via Prince Imperial Road/Ashfield Lane. Traffic on the other arms of the junction (the A208) also experiences lengthy queues during busy times of the day.

However, there are common complaints that pedestrians perceive it as unsafe or difficult to cross at the junction, e.g. schoolchildren heading for Coopers School or St. Nicholas Primary School from central Chislehurst, or disabled people. The schools have clearly supported this petition.

It is obvious that the current junction cannot cope with the current volume of traffic but plans to improve it have always been blocked by the Trustees of the Chislehurst Commons who are reluctant to give up land to enable widening of the junction.

The impact of incorporating a pedestrian phase into the existing traffic lights might be very significant and it would presumably need to be installed on all four arms of the junction. Traffic modelling could be undertaken to see the likely impact on traffic delays and vehicle throughput, but that is quite expensive to undertake.

How should one judge the merits of this proposal? Like all allegations of road safety hazards, one should start by looking at the accident record and try to determine the likely cost/benefit. The last time I looked at the detail statistics related to road traffic accidents in Chislehurst, this junction had been the scene of a number of accidents and the A222 is like many of London’s A roads in that it runs through heavily congested areas with pedestrians often present. Thus Perry Street has seen several fatal accidents and there was one at the Memorial junction when the traffic lights had failed in the night. You can see other accident information at the junction by looking at the Crashmap web site (www.crashmap.co.uk).

Many of these accidents are not at the junction itself but some distance away as pedestrians choose to cross elsewhere than at the traffic lights or vehicles collide for other reasons. Clearly a review of the latest police reports of road casualties (the STATS19 records) could be examined for more information, but I do not recollect that there have been any serious accidents involving pedestrians at the junction itself.

I suspect the answer would be, if such an analysis as I suggest be done, that the cost/benefit of spending money on a change to this junction would not be justified, particularly if the value of the additional delays to vehicles was taken into account as they should be. It is also unlikely that pedestrians would change their habit of not crossing at the junction lights.

There is one simple question that can be answered now though. Do pedestrians actually have any difficulty crossing at this junction? This writer has personally walked across the junction at the traffic lights at least once per week for the last 20 years. I do not find any difficulty in doing so. It just requires one to wait until the lights change.

One can argue that improving pedestrian facilities might encourage people to walk rather than use other modes of transport but I doubt that this would have any significant impact in this case. Nobody who can walk would be deterred from using that junction at present. Do the disabled or visually impaired have some difficulty in crossing this junction? Perhaps but that will be the case even if a Pelican Crossing was introduced and the rights of a minority cannot be taken solely into account. The thousands of other people that will be affected by the change have also to be considered. In practice even if a Pelican system was installed at these lights, disabled people would likely have to cross other unsignalized junctions to get to the war memorial crossing.

Readers might wonder who the organisation named Chislehurst Safer Streets are who organised the petition. It is led by Chris Wells who is also a supporter of 20sPlenty and who has campaigned for a wide-area 20 mph signed only speed limit covering Chislehurst. That suggestion has been rebuffed by both Bromley Council and the Chislehurst Society. You can see what Mr Wells had to say about that proposal on the Visit Chislehurst web site. This is what it says about the Atkins study of 20 mph zone published by the Department of Transport (DfT): “In summary, what Atkins found is that 20mph zones that are poorly implemented have little appreciable effect on traffic speed or accidents”. This is grossly misleading. The study was solely focused on signed-only 20 mph schemes and made no comments on how they were implemented – only signs can and are used in such schemes. This kind of special pleading is common among those who are less concerned with the truth than in arguing and winning their case.

Note that Bromley Council had already responded to the petition on the War Memorial junction by Mr Wells. They say that adding a pedestrian phase would “lead to exceedingly long queues at peak times resulting in increased pollution and likely diversion of vehicles into residential areas”. You can read their full response here with details of the Council meeting: https://cds.bromley.gov.uk/ieIssueDetails.aspx?IId=62672&PlanId=0&Opt=3#AI62776 . Clearly diverting traffic onto other narrow roads might be a road safety hazard in itself.

Readers are encouraged to attend the meeting as members of the public, as I shall be doing, or Bromley residents should contact their local councillors. It is important that those who shout loudest do not override a sensible and rational analysis of this issue and the needs and views of the vast majority of the residents of Bromley and its visitors.

Photo above shows long queues of traffic even at lunchtime on a Tuesday.

Roger Lawson

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