New TfL Consultation Hub

Transport for London (TfL) have launched a new “Consultation Hub” where you can give feedback on new projects in London – see https://haveyoursay.tfl.gov.uk/ . You can also register to receive notifications of new consultation events.

This is not just about consulting on future projects but also submitting comments on live ones – such as the trial of E-Scooters that is currently running.

The new consultation “hub” will replace the existing consultation web site (see https://consultations.tfl.gov.uk/ ) which contains consultations on Streetspace schemes, bus lanes and other matters at present.

Is this a big improvement or is there any reason for the change? It’s not obvious how this change will help and moving and renaming a web site is never a good idea.

Readers are advised to register with the new site so as to be sure of being informed on new consultations.

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The Mayor of London’s Agenda and New York’s Congestion Charge

Our new Mayor of London, Sadiq Khan, has issued a tweet that spells out his priorities. This is what he said:

Okay—here’s the plan:

🔨 Create + protect jobs
💰 Help businesses grow
🌳 Tackle the climate crisis
🏠 Build new homes
🚓 Invest in policing
🎬 Create opportunities for young people
🏆 Celebrate diversity
💪🏽 Root out inequality
⚽ Deliver an amazing Euro2020

<END>

These are all fine words, but rather like the Government’s policies as outlined in the Queen’s Speech, rather short on detail. It also contains phrases like “celebrate diversity” that are not just meaningless, but do not lead to specific actions or budget allocations. Many people would argue that there is too much diversity in London and that leads to social incoherence, and why should the Mayor be spending time or money on celebrating it anyway? We all know that the population of London is now very diverse and we have all come to accept that. So what is there to celebrate?

One big issue is certainly the comment that he plans to “Tackle the Climate Crisis”. Is there one? If you look at many London boroughs who have introduced Low Traffic Neighbourhoods they have justified this on the basis of tackling climate change. They argue that it is important to cut emissions from vehicles when doing so will have minimal impact on the climate. Climate may be influenced by man-made emissions (although some dispute that) but cutting vehicle emissions in London will have a negligible influence. Emissions in London come from many different sources and directly relate to the population of London and their requirements for buildings, heating and transport. The Mayor’s policies imply more businesses, more buildings to accommodate them, more homes for the workers and more infrastructure to support them so this is all contradictory.

Only if the Mayor adopted a policy of reducing the population of London while providing more infrastructure – particularly in terms of transport – would the environment be improved.

New York, New York

It’s interesting to look at another major city which has similar transport problems – a heavily congested road network and a public transport system in deficit. Just like the impact of the Covid epidemic on the budgets of Transport for London, New York is facing a major problem. The Metropolitan Transportation Authority (MTA) budget (which covers the subway and some bus services and is equivalent to TfL in London) is projecting a deficit of $16 billion for the period 2020 to 2024, even after major cuts in services.

New York is planning to introduce congestion charging to cut traffic and of course generate some income for the MTA – as much as $15 billion by charging $10 to $15 dollars per day for those entering Manhattan. But the adjacent state of New Jersey, from which many people commute into New York City, is threatening retaliation. Senator Laguna and Assemblyman Tully are developing legislation that would impose tolls on non-residents driving between New Jersey and New York. Mr Tully said “We should not be used to fund the MTA”.

This is equivalent to Essex or Kent imposing a tax on Londoners who drive into their counties if Sadiq Khan imposed a toll on those who drive into London from outside the M25 – as he is proposing. This is surely a very good response to such a threat!

County Councils that border the M25 should surely be asking the Government for such legislation, or asking the Government to stop this taxation without representation.

Roger Lawson

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Congestion Charge Extension – Who Is Telling the Truth?

Readers are probably aware of the financial difficulties of Transport for London (TfL) and hence Sadiq Khan. The fall in income has been devastating as people have avoided public transport because of the epidemic while TFL have continued to run the same frequency of services on buses and the underground. As these services are the main sources of income to TfL while costs have remained unchanged, the result has been a ballooning operational deficit. The Mayor is now asking for billions of pounds to keep TfL afloat.

He alleges that the Conservative Government is forcing him to extend the Congestion Charge (a.k.a. Tax) as a condition for supplying more money while the Government says that is only one of several “proposals” that they are asking the Mayor to consider to put the finances back in a stable position.

The Prime Minister alleged in the Commons that TfL had been put into a state of “bankruptcy” which was “entirely the fault of the current Labour Mayor of London” due to his policy on fares. But the Mayor described the Prime Minister as lying and has defended his financial record, blaming the problems purely on the Covid-19 epidemic. It’s basically a “blame game” so beloved of politicians.

But the reality is that I wrote negatively in January (i.e. before the epidemic hit) on the subject of TfL budgets and finances (see Reference 1 below). The article included these comments:

“Despite cutting operating costs, one of the few good things reported, there will be deficits of £307m, £493m and £513m in TfL (after “capital renewals”) for this year and the two following ones and barely break-even in 2022/23. As a result, the Mayor will have to substantially increase borrowing to cover that and large amounts of capital expenditure for both Crossrail and other network improvements. That includes £2.2 billion this year and next year, followed by £1.2 billion each year in subsequent years. Total borrowing will reach £12.3 billion within 2 years” and “…..the Business Plan may be totally unrealistic. In summary the Business Plan and Budget demonstrate an incompetent Mayor and senior management at TfL who wish to get us all cycling, walking or using public transport while the road network gets worse”.

But ignoring the blame game and past history, what can the Mayor realistically do to avoid TfL becoming bankrupt? These are the main options as I see them:

  1. Reduce services and cut staff (the major proportion of their costs) in TfL so as to match income.
  2. Increase bus and underground fares substantially, a politically unpopular choice as the Mayor has lauded his past fare freezes.
  3. Increase the Mayor’s precept on Council Tax, which would raise Council Tax for all Londoners. A politically unpopular choice for the Mayor as he comes up for re-election in May 2021 and local councils would blame the Mayor for the increases in Council Tax they have to impose.
  4. Expand the Congestion Charge over a wider area, or increase the charges on that or for the ULEZ – the latter is already planned to expand to the North/South Circular in October 2021.

Expanding the Congestion Charge zone would be deeply unpopular with drivers and there are enormous numbers of people who live within the North/South Circular and drive vehicles (about 3 million people with probably 50% of households owning a car).  This is what Deputy Transport Mayor Heidi Alexander said at a recent TfL meeting: “Neither the Mayor nor I can see how it would be right to charge people £15 to drive a mile from Wandsworth to Clapham, or from Catford to Lewisham from October of next year …”.

There have already been over 100,000 signatures on a petition opposing an expansion of the Congestion Charge – see http://chng.it/7zNp6sHhm8 . Please sign it!

The Mayor is therefore faced with some very tough choices, hence his approach of blaming the Government no doubt. But it is his responsibility to make the choice.

I suspect there is going to be a mixture of all the above, or some other compromise, if the Government simply refuses to hand out more cash with no view of when TfL finances will be stable. That is something it should definitely not do.

The ABD has of course consistently opposed the Congestion Charge, a tax under another name. It is very expensive to collect and has not reduced congestion as claimed. See this web page for an analysis of the Charge and why the ABD still opposes it: https://www.freedomfordrivers.org/congestion.htm

We suggest the Mayor should choose options 1 to 3 only. It is not clear to us why drivers should pay to keep public transport afloat – they already pay billions more in taxes than the cost to maintain the roads. In reality part of the problem is that transport in central London is heavily used by commuters from outside London who do not pay the realistic costs of the provision of bus and underground services. Buses for example are subsidised by almost £1 billion per year in London, which is no doubt politically popular (even Boris Johnson bottled bringing it under control when Mayor). But that is one lunacy that should surely be stopped.

TfL Budgets have been driven by political populism for many years when it is in essence a business and should be run like one. Why should TfL who obtain income from public transport also have control of the road network? The result is bias against other forms of transport. It is surely time to remove TfL from the Mayor’s control.

Griff Rhys Jones wrote a very interesting article for the Spectator recently about the dire London transport situation. One of his comments was “The most effective planet-saving reforms would be to prevent commercial ‘centres’ and to spread ‘live-work’ across the entirety of London. Instead, we are once again pursuing outmoded and outdated ‘visions’. (Or ‘fantasies’, as London-wide protests by ordinary working people are calling them.) Our capital is a success because people inhabit it”. See Reference 2 below.

The Mayor’s Transport Strategy has certainly been very defective, apart from the budget lunacy and that is one reason why London was so vulnerable to the virus.

Roger Lawson

Reference 1: TfL Budgets. https://freedomfordrivers.blog/2020/01/17/tfl-business-plan-and-budget-for-the-next-5-years-more-of-the-same/

Reference 2: Spectator Article: https://www.spectator.co.uk/article/london-s-war-on-motorists-isn-t-helping-anybody

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Sadiq Khan and TfL Bailed Out

Blackfriars Bridge at Lunch TimeAfter threatening the Government that TfL would have to make deep cuts to public transport in London unless they came up with some money by the close of yesterday, they did agree a bail-out. But with some conditions attached.

The Government has agreed to provide TfL with £1.5 billion in grants and loans to enable TfL to continue operating for at least a few months. With most of TfL’s income coming from bus and underground fares, the collapse in usage as people avoid public transport in the virus pandemic has resulted in massive losses at TfL which are still continuing. In addition the Mayor’s previous decisions to suspend increases in public transport fares, which he made to ensure election, have been enormously damaging to TfL finances and meant they were already budgeting massive deficits even before the epidemic hit.

The suspension of the Congestion Charge and ULEZ has also not helped, plus the fact that you can avoid paying bus fares by entering through the central door as is now required. Even TfL’s advertising revenue has fallen as advertisers’ budgets have fallen and they won’t pay when far few people are using public transport. With social distancing required, even the capacity of buses and the underground will be severely restricted for some time, even if people can be persuaded to use it.

The details of the agreed deal have not yet been disclosed, but the BBC reported that it includes a commitment to raise public transport fares by inflation plus 1%, two seats on the TfL board and a complete review of its finances. TfL has also committed to run a full service when previously they were cutting to 75%.

Mr Khan as usual blamed the Government rather than his own financial incompetence. This is what the BBC reported as being said by someone in the Mayor’s office: “They have forced ordinary Londoners to pay a very heavy price for doing the right thing on Covid-19 by hiking TfL fares, temporarily suspending the Freedom Pass at busy times and loading TfL with debt that Londoners will pay for in the long run”.

Grant Shapps, Transport Secretary, said it was wrong for the rest of the country to be bailing out Londoners but in fact Londoners who never use public transport will be paying a lot of the bill anyway via the Mayoral Council Tax Precept and in other ways.

What should the Mayor have done instead of running up a large deficit, and what should he do now?

Clearly many TfL projects have been very expensive. Building cycle superhighways has not come cheap and schemes such as Crossrail have very marginal cost/benefit ratios. The Mayor’s office and TfL management costs have also grown as the Mayor built an empire at taxpayer’s expense. It seems likely that a number of projects such as to expand the underground network will now have to be cancelled. Subsidies to bus operations which have been running at about £1 billion per annum could never be justified except by the desire of the Mayor to win popularity and elections.

The Mayor and TfL have actually cut their bus income by introducing road schemes that slowed traffic including buses, thus cutting bus ridership. You cannot solve these problems by simply encouraging cycling. The average distance travelled by a London commuter is 13 miles per day with many travelling much longer distances. That makes it impractical for many people to cycle even if they had an inclination to do so. The danger of cycling puts many people off using it for long journeys. Department for Transport (DfT) figures show that there are 1,139 serious injuries and 29 deaths for every million miles cycled, while for car drivers the figures are only 27 and 2 respectively.

The Mayor and central Government should face up to realities and work on the following:

  1. Free up the road network to enable more commuting via cars/taxis and improve bus services. Stop reducing road space.
  2. Provide more parking facilities at low cost.
  3. Encourage more tele-commuting by investing in broadband services and support.
  4. Encourage businesses to relocate out of congested central London into the London suburbs and elsewhere.
  5. Retail facilities and hotels/restaurants should be relocated similarly.
  6. We should move away from the concentration of businesses and facilities in central London to have a wider distribution so we are not reliant on public transport so much.
  7. Bus and underground services should pay for themselves. Handouts for political reasons (such as the Freedom Pass) should be severely restricted to those who really do need travel support, i.e. those who cannot afford to pay.
  8. The ULEZ and Congestion Charge should be scrapped as they don’t really provide a sensible return on the investment and operating costs. They are simply a financial burden on Londoners with very little benefit.

All it needs is strong and wise leadership from the Mayor of London to get Londoners through the current crisis, but will we get it? It seems unlikely from the current Mayor.

All that is likely to happen is that the TfL deficit will continue to grow after this short-term bail-out unless someone really gets to grips with the underlying financial problems.

P.S. Government announcement here: https://www.gov.uk/government/news/government-grants-transport-for-london-funding-package?   They apparently still think the problems can be solved by encouraging cycling.

Roger Lawson

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Sadiq Khan Asks for £1 Billion Bail-Out

Sadiq Khan may be asking for as much as £1 billion to bail-out Transport for London (TfL). He did not deny it when interviewed on BBC television. The organisation is haemorrhaging cash as most of its income comes from bus and tube fares and usage of those has severely declined. It may be unable to pay its staff very shortly without some Government support and has already “furloughed” 7,000 staff from today. TfL will be able to access funding from the Government’s Job Retention Scheme for those staff, saving the organisation millions of pounds every week, but that’s only a short-term and temporary solution to the Mayor’s financial problems.

How did the Mayor get TfL into the position where it cannot survive the problems caused by the coronavirus epidemic? In essence because the Mayor is financially inept and has allowed TfL to run up massive deficits so it has minimal reserves to cope with such an event. We have commented on this issue repeatedly – for example here on the TfL budget in January: https://freedomfordrivers.blog/2020/01/17/tfl-business-plan-and-budget-for-the-next-5-years-more-of-the-same/

Total borrowing was forecast to reach £12.3 billion within 2 years because of delays to Crossrail and other issues, and that was before the impact of the coronavirus. A lot of the problem is caused by the Mayor spending money on programmes such as cycle schemes, Active Travel, Healthy Streets, Vision Zero road safety, the ULEZ and other policies for which there was no cost/benefit justification provided in this Mayor’s Transport Strategy (MTS). Now we are seeing the result of this financial incompetence and inability to manage the budget.

The ABD suggests that before the Government hands the Mayor any cash, they should lay down some conditions on how it will be used and insist on some changes to the MTS. Scrapping the expansion of the ULEZ would be a good starting point.

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Travel in London Survey – How It’s Being Made More Difficult

Transport for London (TfL) have released their latest survey of travel patterns in London.  It’s a mine of statistics but the “spin” put on the data is generally grossly misleading. For example, it says “Londoners and visitors make increasingly sustainable choices for how they get around, choosing to walk, cycle and use public transport”.  Walking and cycling have slightly increased – see comments below, but how is public transport “sustainable”? A high proportion of public transport is buses and diesel London buses are a major contributor to air pollution while air pollution on the London Underground is worse than on London’s streets so how is that “sustainable”? Of course there is no definition of “sustainable transport” in the Report  – it’s simply a way for TfL to claim some things as good and others bad.

Total travel demand in terms of number of trips taken has been flat for the last three years despite the continuing growth in the population. In reality Londoners are choosing to travel less simply because traveling in London has become more difficult. Public transport has become overcrowded while private transport (cars and PHVs) are being discouraged in numerous ways.

Bus journeys declined by 1.8% last year probably due to the same reasons as the decline in use of cars – traffic congestion has slowed journey times, making it quicker to walk in many cases.

Cycling in terms of cycled kilometres rose by 5% it is claimed but still only accounts for 2.5% of all trips despite the massive expenditure on cycle superhighways and other cycling facilities. This figure is also distorted by using distance cycled instead of number of trips by that mode. You can see the data more clearly by looking at this chart from the Report:

Per Person Trip Rate

This shows clearly that cycling has not been growing and any alleged increase is simply down to the growth in the population of London. This is what one person had to say on Twitter: “The same tiny number of people cycled 5% further because the weather was a bit nicer than usual that year; at a cost of £millions to taxpayers, while record numbers of Londoners sleep rough and get murdered. In any other setting this would be surreal: but not in Sadiq Khan’s London”.

The Report also claims success in the Mayor’s objective of promoting more “active travel” such as cycling and walking to make us more healthy. As regards walking the above chart shows how walking has declined over the last ten years. And Figure 5.2 in the Report shows that the percentage of people achieving 20 minutes per day of active travel is basically unchanged in the last ten years.

The big trends over the last ten years have been increases in underground patronage – up 25.6% – and national rail usage – up 41.5%. Which explains why you cannot get a seat on the trains or the underground and during rush hours you’ll either be squeezed into the carriages or can’t even get into the station. This has arisen because of a failure to match public transport provision with the growth in London’s population which incidentally is mainly from immigration as the Report spells out.

Bus journeys declined by 1.7% last year and have actually declined by 0.6% over the last ten years. It seems that nobody likes buses. Perhaps it’s that standing in the cold or rain waiting for a bus or unreliable bus arrival and trip times that puts them off – it certainly does this writer.

Motorised road travel declined slightly in inner and central London but rose slightly in outer London. Londoners are apparently reluctant to give up car use despite the ever increasing restrictions on them. One change though is the use of PHVs (mini-cabs) has risen to offset the decline in private cars. For example it is estimated that as much as 40% of car traffic in central London at certain times is accounted for by PHVs, but their numbers are forecast to fall substantially due to removal of the exemption from the Congestion Charge (a.k.a. Tax) and the new ULEZ tax.

The Report notes how serious road traffic casualties increased last year which shows how the Mayor’s “Vision Zero” strategy is failing. But interestingly it also notes that injuries in the London Underground increased by 6% last year to 3,968 while bus passenger injuries declined by 8.6% to 4,889. These are surprisingly high numbers but still less than those injured in road traffic accidents.

Only 56% of London households have access to a car with an even lower proportion in inner London. But this proportion has not substantially changed in the last ten years (see Figure 4.12 in the Report).

The report gives some data on air pollution and in particular of NO2 emissions which mainly come from transport. This has been falling substantially, particularly in central London, mainly due to changes to newer vehicles in the vehicle fleet. See chart below taken from the Report.

NO2 Trends

The Report goes on to claim an impact from April 2019 from the introduction of the ULEZ in central London but in reality the trends in the above chart will simply have continued so any claim for an impact from the ULEZ is a figment of TfL’s imagination. It is simply too early to claim any impact as reliable data is not yet available. And just to remind you, there is no clear medical evidence of any negative impact of NO2 on human health.

In summary although this TfL Report contains some useful data, it misinterprets the trends in London travel patterns and the impact of the Mayor’s Transport Strategy. Most of the changes in travel trends in London have probably occurred from a rising and ageing population.

The report is very selective in both data reporting and interpretation. For example there is no data on traffic congestion which from most users experience has worsened considerably in recent years. That degradation has taken place from policies pursued by TfL which has meant removal of road space from cycle lane installation, widening of pavements, junction changes, more pedestrian crossings and traffic lights and other negative changes.

However an interesting section of the Report is on future travel demand and possible “Scenarios” in Chapter 14. One of the three scenarios is “Accelerating London” with high levels of population growth and immigration, high housing costs and rising crime rates, i.e. more of the same. A second scenario is a “Rebalanced London” with lower economic growth, a stable population size with actual falls in inner London and a slower pace of life. It sounds positively utopian if you read it. The third scenario is “Innovating London” where there is a focus on more technology both in employment and facilitation of travel. It does not say which the Mayor of London might back however.

Regrettably as with anything the Mayor or TfL issue, the Report is more of a public relations document than an unbiased analysis of the trends in London travel and its causes.  It should be read with caution.

You can find the Report here:

http://content.tfl.gov.uk/travel-in-london-report-12.pdf

It just remains to wish readers of this blog Best Wishes for the New Year and a belated Happy Christmas

Roger Lawson

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Uber Licence Cancelled in London

Transport for London (TfL) and Mayor Sadiq Khan are terminating Uber’s license to operate in London after deciding they are not a “fit and proper” organisation to run such a service. This cancellation is after a two-month extension to the license to allow a new application to be submitted and previous legal action by Uber. Uber intends to appeal the decision and can continue to operate in the meantime (for the next 21 days only from the 25th November).

Uber provides a service valued by many people in London, and termination would put over 40,000 drivers who operate the service out of a job, many of whom are from immigrant backgrounds. However there are alternative “app” based services as well as traditional black cabs and other phone booking based PHV (mini-cab) services.

The exact reasons for termination seem somewhat trivial as given in the TfL press release – see below. It includes technical glitches in the Uber software that allowed drivers to upload photos to other drivers accounts and hence operate as them. However there is no evidence provided of any harm to passengers that resulted. Such technical issues should be easy to fix.

One has to question whether TfL are attacking Uber, and will attack other operators similarly, purely on the grounds that they are unhappy with the number of PHV vehicles that are now on the streets of London.

Comment: This writer occasionally uses Uber and I have always been happy with the service. I think there will be a lot of irate customers as well as Uber drivers if this decision is allowed to stand. But it will no doubt please their competitors.

TfL Press Release on Uber: https://tinyurl.com/wt47lqv

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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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Consultations in Name Only and “Safer Speeds”

I covered the issue of Transport for London (TfL) doing public consultations that do not provide enough information and are already decided in a previous note (see https://freedomfordrivers.blog/2019/06/24/consultations-in-name-only/#comments ).

Subsequently I used the Freedom of Information Act to ask TfL for their consultation policy documents and guidelines, plus information on the costs and any cost/benefit analysis of the “Safer Speeds for London” proposals. That’s the proposal which will slow traffic to 20 mph on many major London roads and where there was a short (now closed) public consultation which did not contain evidence for justification.

TfL has supplied the information on their consultation policies and procedures and if anyone would like a copy, please let me know. In Principle 3 of the TfL Consultation Policy it says “We must provide consultees with enough information to understand what we are proposing so that they can respond on an informed basis”. That was certainly not done on the Safer Speeds proposal.

As regards my request for costs and cost/benefit data on the Safer Speeds proposal, TfL rejected my request on the basis that it is exempt information because the information requested “is intended for future publication” – see Section 22 of the FOI Act, and that it was not justified in the public interest. What is the point in publishing that information after the public consultation has ended? It looks like a simple attempt to avoid answering, or are they saying that they have not looked at the costs and costs/benefit before putting forward the Safer Speeds proposal? Either way, it is unreasonable so I am appealing.

This is of course the typical run around one gets with TfL when they don’t wish to disclose information. TfL are a secretive organisation that likes to develop proposals and present them as a fait-accompli with only public consultation on trivia. It has been that way ever since Ken Livingstone was in charge. It surely needs to change!

But according to a report in Local Transport Today (LTT) TfL is heading in the opposite direction. The report said that TfL is changing the way it engages and consults on active travel schemes. There will be “a greater emphasis on local engagement either in advance of, or potentially instead of, formal consultation”. It is suggested that to get the 73 safety critical road junctions in London improved they need to push through with projects and the public “has a limited ability to influence our proposals” – so there is no point in statutory consultations. But It also suggests road users will have less opportunity to comment, and of course a non-statutory consultation leaves little ability to mount a legal challenge.

Roger Lawson

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Consultations in Name Only

Recent public consultations by Transport for London (TfL) have typically omitted any costs, or cost/benefit information, about the proposed schemes. For example on the “Safer Speeds” proposals for many more 20 mph speed limits in London, or Cycleway schemes. Nor do they ask a simple question as to whether people support the proposals overall or not.

I complained about those omissions in the ABD’s response to TfL and got a note back from Esme Yuill (Lead Consultation and Project Communications) which contained much waffle but did say “consultation is not usually about the principle of a project, but the proposed design”. In other words, the consultation is usually based on the project being a fait accompli and TfL have already decided to push ahead with it. That is not a consultation in the usual sense of the word, and clearly undermines the democratic principle that consultations should not assume pre-conceived notions.

Indeed this approach is contradictory to that laid down by the Government in their Consultation Principles where it says: “Consult about policies or implementation plans when the development of the policies or plans is at a formative stage”. See https://tinyurl.com/ycb3mwvk

That document also says: “Give enough information to ensure that those consulted understand the issues and can give informed responses. Include validated impact assessments of the costs and benefits of the options being considered when possible…..”. Neither of the recent consultations I referred to in my complaint (the “Safe Speeds for Central London” and the “Wood Lane/Notting Hill Gate” schemes) contained any costs or cost/benefit analysis and that has been a consistent omission in recent TfL consultations.

TfL has been one of the most impervious and undemocratic bodies since it was set up by Ken Livingstone. They do not listen to anyone. Indeed was it not Ken Livingstone who said “Consultation is a good thing when people agree with you, and a waste of time when people don’t agree with you” and TfL are clearly still following that principle. By avoiding consulting on the key questions as to whether projects should be done at all, and not informing respondents on the costs and cost/benefits, they are avoiding any meaningful consultation.

Is that the way that you think the body that runs transport in London and has one of the biggest budgets in the world should run consultations? I do not and I will be pursuing this matter.

Roger Lawson

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