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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Motorists Fuming and Heathrow Expansion

The SUN newspaper has reported on the concerns of London drivers over the Ultra Low Emission Zone (ULEZ) under the headline “FUMING!”. The article says that London diesel motorists will have to buy a new car or face paying thousands in a new pollution tax – see https://www.thesun.co.uk/motors/8241278/motorists-new-car-pollution-tax/ . The article includes good quotes from me and from Howard Cox, Gareth Bacon and Shaun Bailey.

Interesting to note that TfL previously claimed that the capital cost of extending the ULEZ to the North/South Circular was £38 million. But it seems that TfL Manager Paul Cowperthwaite is now suggesting it could be between £90 million and £130 million. On a cost/benefit analysis that will make it even more uneconomic than was even forecast previously (see our previous articles on that issue). Mr Cowperthwaite’s comments about the alleged air quality crisis and his estimate of what it costs are just figments of his imagination that bear no relation to reality. As I am quoted in the SUN article, “The ULEZ is a giant con to raise more taxes to fix the Mayor’s budget problems”.

A big contributor to air pollution, particularly in west London is from aircraft landing and taking off at Heathrow airport. The airport is planning to increase the number of such aircraft numbers even prior to their proposed construction of a third runway. They plan to do this by using new technology to alternate runway use. This could mean an additional 25,000 flights per year with the associated pressure on the road network as most passengers arrive via vehicles.

It may also mean more aircraft noise affected more London residents as landing and take-off flight paths will change. There will still be no ban on night flights that disturb residents. Will the Mayor and TfL be objecting? I hope so.

See https://afo.heathrowconsultation.com/ for more information and to respond to the public consultation.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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20 Mph Zones Are a Waste of Money, or Worse

The Sun Newspaper has reported on the success, or rather failure, of 20-mph wide area speed limits, to reduce accidents. They have obtained figures from 20 local councils using the Freedom of Information Act where £11 million of taxpayers’ cash was spent on the lower limit. But in some cases, rates of serious accidents (Killed and Serious Injuries – KSIs) have actually gone up they reported.

AA President said that the schemes were a “waste of money”, effectively implying that if the money had been spent on other road safety measures, more lives and serious accidents would have been saved.

Examples the Sun gave were Bath where £804,000 was spent but a 2016 report revealed that the KSI’s went up in 7 out of the 13 zones where speeds were cut, and in Manchester £1.7 million was spent on a heavily criticised scheme while in Hampshire other schemes showed no benefit in terms of accident reduction.

We have of course reported similar problems before including in the City of London where a blanket 20 mph scheme has resulted in more minor injury reports.

20s Plenty founder Rod King called the articles “sloppy journalism” (one also appeared in the Daily Mail on the same subject). 20s Plenty has tried to debunk the reports of a number of local councils on their 20 mph schemes – for example they called the Bath report “biased, lacking in statistical rigour and not meeting several local authority duties on competency and equality”. But anyone who has surveyed all the evidence on such schemes will know that simply putting up signs typically reduces traffic speed by only 1 mph and that can have no significant impact on road casualties. In reality it seems to have the opposite effect in many cases as pedestrians no longer take so much care when crossing the road.

Rod King and 20s Plenty are like all fanatics – they ignore the negative impact of their policies and fail to see the truth. They are blinded in their zeal to reduce speed limits in the false presumption that reducing speeds are the answer to all road safety problems. But cutting road casualties is not as simple as that.

We still await a Government report on a more comprehensive study of 20 mph schemes.

In London, Transport for London (TfL) continue to finance such schemes in local boroughs and must have spent millions to date on them. Another example of unwise policies and reckless expenditure by TfL and Mayor Sadiq Khan, plus his predecessors. It is a great pity that money was not spent on road engineering to improve the safety of roads and junctions.

The Mayor actually wants to impose 20 mph speed limits on many major roads in London under his “Vision Zero” road safety plans. UKIP Transport Spokesperson Jill Seymour has challenged TfL to provide undisputed evidence of the justification for such proposals. She said “The authorities have strangled the main roads, and made them the most congested and slowest of any city in Europe. London is a mess when it comes to transport…..the London authorities, led by Sadiq Khan, appear to have a vendetta against personal transport and the car, and do everything they possibly can do to discriminate against it”. That’s definitely the truth of the matter.

Roger Lawson

Sun article here: https://www.thesun.co.uk/news/7253694/20-mph-zones-cause-more-deaths/

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Changes to Congestion Charge – PHVs Targeted To Raise Money

The Mayor of London and TfL have announced proposals to change the Congestion Charge (a.k.a. Tax) so as to raise more money. The main change is that PHVs (minicabs) will no longer be exempt from paying this tax. Uber and other drivers will no doubt be up in arms about this and it will mean their clients pay a lot more.

Another change is that the Ultra Low Emission Discount (ULED) which currently applies to vehicles that emit less than 75g/km of CO2 will need to have zero emission capability by 2019 and by 2021 only electric vehicles will qualify. That means that many of the 20,000 vehicles currently registered for the ULED will need to be changed if the owners wish to continue to qualify for the discount.

A Blatant Lie

What’s the justification for these changes? The consultation announcement says that the Congestion Charge “was a huge success”. It claims a reduction in traffic and a 30% reduction in congestion as well as improvements in air quality since it was introduced. These claims are simply spurious. There was a short-term reduction in some vehicles entering the central zone, but the numbers of taxis, PHVs and buses increased. The result was that congestion soon returned to what it was before the tax was introduced and has since got substantially worse. Neither was there any improvement in air pollution which was never expected to happen and did not. See this web page for the facts: http://www.freedomfordrivers.org/congestion.htm

The claims made by TfL are downright lies. But traffic delays have been increasing which is the justification put forward by TfL for the proposed changes.

Why Should Taxis Be Exempt?

One controversial aspect of the original scheme was that registered taxis (black cabs) and PHVs (private hire vehicles) were exempt from the congestion tax. It was never very clear as to why some vehicles should be exempt while others are not. Why should private car occupants pay the charge while people using other vehicles for similar journeys should not? Even more puzzling is why PHVs are now proposed to be taxed while taxis are not. What is the logic of this? Note that the increase in PHVs due to the popularity of services such as Uber has led to many more vehicles entering central London of late and hence have contributed to congestion significantly in the last couple of years. But will the tax now proposed actually reduce their numbers? That is surely unlikely for the same reason that the congestion charge scheme did not reduce congestion. The unsatisfied public demand is such as to soon soak up the capacity released by people unwilling to pay the tax. You cannot solve congestion via taxation!

It’s About Money

The conclusion must be that these proposals are more about raising money for the Budget of Mayor Sadiq Khan. He desperately needs it. See previous blog posts for coverage of that topic.

A Timely Announcement

One might ask why the Mayor chose to announce these changes on a Friday lunchtime when the news channels will be dominated by the Brexit decisions and the England World Cup match for the next 48 hours. This might enable him to escape the opprobrium of PHV drivers for a few hours but not much longer I suggest.

More Information

See this web page for more information and to respond to an on-line consultation: https://consultations.tfl.gov.uk/policy/private-hire-charge-exemption/?cid=ccyourviews

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The Cost of Khan

Gareth Bacon, leader of the GLA Conservatives, has published a very interesting document entitled “The Cost of Khan”. It supplies a half-term report on the regime of Mayor Sadiq Khan and the negative impact he has had in certain areas (crime, planning, parking, housebuilding for example). In essence he suggests one of the key problems is financial mismanagement.

Of particular interest to our readers will be his comments on the activities of TfL (Transport for London) and the budget for that organisation. It covers:

  • Cancellation of new tube trains for the Jubilee and Northern Lines that would have provided much needed extra capacity. That might have saved £600 from the TfL budget but that’s desperately needed after Khan’s expensive promise to freeze public transport fares which cost at least £640 million in foregone revenue. Even that promise was only partly kept.
  • The pay of executive staff in TfL. The number who are paid more than £100,000 p.a. increased by 25% last year so there were 576 such employees. Is the Mayor really cutting the flab out of TfL budgets as he promised to do?
  •  The “T-Charge” which was introduced last October and will cost Londoners £23 million a year despite the Mayor’s own Impact Assessment saying it will have only a negligible impact on pollution (and that has been borne out by real data since).
  •  Nominee passes which you may not be aware of are highlighted. These allow TfL employees to nominate family members and anyone who resides in the same household to obtain free travel. Even flatmates qualify! There are 39,884 people who are nominees and the cost might be equivalent to £32 million in lost revenue per year.

Those and other reports show how the Mayor has been so wasteful of financial resources with the result that he is desperate to raise money from the T-Charge and the ULEZ charge which will impose major unnecessary costs on Londoners. In the personal view of this writer TfL continues to be a massive and very expensive bureaucracy which is unaccountable to the public. It formulates transport policy that will increase the bureaucracy and then does public consultations designed to get the right answers. TfL needs major reform but the Mayor does not seem to have it under control.

The “Cost of Khan” Report is present here: https://www.glaconservatives.co.uk/uploads/1/1/7/8/117899427/final_cost_of_khan__2_.pdf

Roger Lawson

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Press Release: The Real Reason for the ULEZ – It’s About Money

We have said before that we are suspicious about the reasons given for the Ultra Low Emission Zone (ULEZ) in London. The proposed measures, particularly the extension to within the North/South Circular, seemed disproportionate to the likely benefits from reductions in air pollution. This is particularly so, bearing in mind that emissions from vehicles are rapidly falling, as newer vehicles replace older ones.

Now we know the truth!

In April 2017 we asked for information on the financial budgets for the ULEZ – the likely costs and income the Mayor would get. The request was refused and we eventually had to appeal to the Information Commissioner’s Office (ICO). We have now received the requested data following a judgement in our favour. These are the figures received from Transport for London (TfL):

  • Implementation costs: £38.4 million.
  • Operating income and costs:
  • Impact of introduction of ULEZ on income (£m) over 5 years 2017/18 to 2021/22 inclusive. (+ve is net increase in income): £55.3 million.
  • Impact of introduction of ULEZ on costs (£m) over 5 years 2017/18 to 2021/22 inclusive. (-ve is net increase in costs): -£12.7 million.

But these figures make absolutely no sense as against the figures we have calculated for operating income based on data provided in the ULEZ consultation documents. For example we estimate income over five years as being £313.6 million rather than £55.3 million.

In reality TfL may be making a profit over five years of £300.9 million for a capital investment of £38.4 million. At a stroke Sadiq Khan will solve his budget problems with the ULEZ implemented.

The Mayor has great financial difficulties, as is apparent from his recently published budget for the next few years, where he begs for more financial support from central Government. But he surely will not need their support with this scheme in place, even though he does not have the funds to do it without more borrowing.

Just like the central London Congestion Charge (a.k.a. Tax), where charges were later raised (more than doubled), thus making it a very profitable for TfL, once the infrastructure, such as cameras are in place for the ULEZ, charges can then be raised. The scheme can also be extended way past when traffic air pollution ceases to be a problem, thus potentially introducing more general road pricing.

Will the health benefits outweigh the costs of the scheme to Londoners? The answer is no because they are only valued at £7.1 million over 5 years. This duplicity in justifying the ULEZ on health grounds, which few are likely to oppose, when the real reason may be to fund his empire, is surely typical of Mayor Sadiq Khan’s approach to politics and democracy. Who does not want cleaner air? But there are lots of ways to improve air quality from transport and other sources, without imposing such enormous costs on road users.

To remind readers, the ULEZ charge for non-compliant cars will be £12.50, imposed 24/7, and enormous numbers of people will need to buy new cars to avoid this cost.

Readers should make sure they oppose the extension of the ULEZ by responding to this public consultation before the 28th February: https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3b/?cid=airquality-consultation

More Information 

Our full analysis of the costs and benefits of the ULEZ are contained in this document: http://www.freedomfordrivers.org/Cost-of-the-ULEZ.pdf

The ULEZ proposals are part of the Mayor’s Transport Strategy which we are vigorously campaigning against – see this web page for more information: http://www.freedomfordrivers.org/against-mts.htm

The unnecessary delays and obstruction by TfL in responding to our reasonable request for information on ULEZ costs is documented in this blog post: https://freedomfordrivers.blog/2018/01/09/press-release-tfl-forced-to-disclose-ulez-costs/

Our views on the ULEZ proposals and how the Mayor is scaring Londoner’s unnecessarily about air pollution and health are documented here: https://freedomfordrivers.blog/2017/11/30/panicking-londoners-consultation-on-ulez-extension/

For more information on this issue, contact Roger Lawson on 020-8295-0378.

TfL Business Plan – Mayor Sadiq Khan Wants More Money

Just before Christmas, Transport for London published their proposed Business Plan for the five years to 2022/23. See http://content.tfl.gov.uk/fc-20171205-item10-draft-business-plan.pdf for the details, but what follows is a summary, with some comments.

The foreword by Mayor Sadiq Khan contains the usual whinging from him about the lack of central Government subsidy and his budget difficulties. It is true that TfL no longer receive a central Government grant for operating subsidies, but that was agreed by Boris Johnson on the basis that they would obtain extra income from the new Elizabeth line. There are still substantial capital grants though.

The Mayor is of course suffering from his self-imposed hair-shirt by promising to freeze public transport fares in London when campaigning to get elected. He has implemented that, at least as far as TfL controlled fares are concerned. He even goes so far as to say that this “will put £200 back in Londoners’ pockets by 2020”. Surely he is confusing stopping increases (which mainly covered inflation), with reducing fares?

TfL’s latest budgets are particularly constrained by a reduction in forecast public transport revenues. Bus usage for example has been falling, so revenue growth is anticipated to be lower than expected in previous budgets. Bus operating deficit was £599 million in 2016/2017 but will rise to £632 million this year and be has high as £647 million in 2022/23. These are enormous numbers.

Looking at the Financial Summary (page 30), shows that overall TfL will show an operating surplus before “capital renewals” and “financing costs”. After the latter they are running big deficits up until 2020/21. This is what one might term “political presentation of finance data”. Cash flow was negative to the tune of £1,353 million in 2016/17 and it only really becomes positive 4 years later. For someone with experience of looking at the finances of organisations, as this writer has, this looks a very unhealthy financial profile.

One result of this financial plan is that the Mayor is cutting funding for road maintenance that goes to local boroughs. This will not necessarily affect minor road maintenance but it will mean cuts to major projects. Part of the reason is because a lot of the money is going to support cycling initiatives, the redevelopment (pedestrianisation) of Oxford Street and other major projects that are mainly in central London.

Local boroughs are likely to be very unhappy with the cuts to funding of Local Implementation Plan (LIP) programmes, particularly as projects tend to be planned years in advance so abrupt changes in funds available may mean a lot of planning work is wasted.

The lack of major renewal work on roads will surely cause the proverbial “stitch in time” to come true. It will lead to expensive short-term fixes, and more major work in due course if proper maintenance is delayed. For example, bridges often require substantial work after many years of use and that cannot be deferred forever.

Big projects that are consuming the funds are more cycle superhighways, Vauxhall Cross, Wandsworth Gyratory, the Silvertown Tunnel and the Rotherhithe to Canary Wharf bridge (which I commented on negatively as regards its’ financial wisdom in a previous blog post).

The Mayor and TfL are complaining that the cost of operating and maintaining London’s roads of up to £350m per year are effectively being cross-subsidised by public transport fare payers and they need some of the money raised from Vehicle Excise Duty (VED) to pay for it. This is nonsense. The Mayor has very substantial income from business rates and other sources (such as congestion charging) – these more than cover the costs of operating and maintaining the road network.

All that is happening is that the Mayor is choosing to spend large amounts of money on cycling, on his “healthy streets” projects, on expensive remodeling of gyratories (past ones have introduced congestion where none existed before), on massive subsidies to bus travel when nowhere else in the country does this take place and while removing budgets from local London boroughs. This is not a formula that will please Londoners who understand what is happening, nor improve TfL’s financial position.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

 

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TfL Will Have to Disclose ULEZ Costs After All

In April 2017 I responded to a public consultation on the proposed extension of the ULEZ. However I criticised the lack of information on the cost/benefit of the scheme, indeed of any information on costs and likely revenues at all, which made making an informed response to the consultation difficult.

As Transport for London (TfL) refused to provide such information when requested I submitted a Freedom of Information Act request. TfL refused the request on the grounds of “commercial confidentiality” so I asked for a review and subsequently appealed to the Information Commissioner’s Office (ICO).

They have upheld my complaint and so I should get the requested information after all (unless they appeal to the First Tier Tribunal). But is it not disgraceful that TfL can obstruct and delay this legitimate need for such information?

TfL claimed it was commercially sensitive because they were already talking to possible suppliers but the ICO judged that there was insufficient evidence that such disclosure would result in specific harm to TfL that would justify refusal.

As I said originally, in my view, these proposals are out of proportion to the benefit to be obtained. The fact that TfL are apparently reluctant to disclose the financial budgets for this scheme suggests to me that it is more about tax raising than simply tackling the air pollution health issue.

The costs of the scheme may be so high that even with the additional taxes raised from vehicle users, it may be unaffordable. BUT WE DON’T KNOW BECAUSE TFL REFUSED TO TELL US.

It is unfortunately typical of late for the Mayor of London, Sadiq Khan, to issue public consultations in his name that are biased polemics of the benefits of his proposals while not disclosing the facts. Democracy is undermined when a public authority acts in this way.

It is further undermined when TfL refuse to disclose information and by doing so delay its release past the consultation due date when they know any appeal process will take many months.

More information will follow when I get the requested data; in the meantime you can read the ICO’s decision notice here: http://www.freedomfordrivers.org/ICO-Decision-ULEZ-Request.pdf

That was a welcome Christmas present from the ICO, and I wish all our readers a happy Christmas and a prosperous New Year.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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