Mayor's Transport Strategy - Public Draft (October 2009)

Mayor of London

Response on behalf of London Borough of Croydon

The council also welcomes the simultaneous publication of the draft revised London Plan and Economic Development Strategy, which should ensure that these three important documents are aligned as a means of reducing the need to travel in the first place and to ensure that transport investment and site development are properly integrated.

Croydon council feels that the strategy does not address this need adequately and believes that local transport services should be prioritised. The MTS needs to set out how this will be achieved.

It is important therefore that the MTS acknowledges this and links with the specific policies and proposals.

Responses to Specific Transport Proposals

2.1 Rail

The council welcomes the strategy's call for greater Mayoral powers over national rail in London, as a borough that is dependent on `heavy rail' for longer public transport journeys and looks forward to greater TfL involvement in and funding for rail station and service improvements in the borough.

i) Although Croydon's rail lines are not currently within the Mayor's remit, other than the overground stations along the East London Line extension between West Croydon and Crystal Palace, we have a number of concerns and hope TfL can bring pressure to bear on the TOCs/ Network Rail with regards to these.

ii) Croydon has been officially recognised as an Opportunity Area. Croydon also has an aspiration to be recognised as London's third city, supported by its growing economic prominence within Greater London. Croydon Council would therefore welcome the opportunity to discuss with the Mayor, through TfL, improved services between South London and the sub-regions as well as the provision of High-Speed Rail services directly available to/from central Croydon and to/from other areas of London apart from Central London and Stratford.

iii) Croydon supports the proposal to seek further rail capacity across London's rail network, beyond those schemes already committed and also supports the recognition that the issue of congested stations must be addressed. However Croydon is deeply concerned at capacity issues which affect longer-distance services using the Brighton Main Line which are more serious than appears to be generally recognised, due to inherent flaws in Network Rail's consultation draft Sussex Route Utilisation Strategy where there is:

Croydon therefore believes that serious early consideration is needed for more radical interventions, having regard to the necessary lead time for implementing major infrastructure enhancements.

The council is also concerned that there appears to be a missing link in the prospective regional and sub-regional rail network, in that the West Coast Main Line (WCML) will have no direct Thameslink connection, and the existing inter-regional connection between WCML and Gatwick Airport faces serious capacity issues where it joins the Brighton Main Line immediately South of Clapham Junction.

iv) Croydon supports the proposal to seek station capacity enhancements at some of London's most congested stations. However, Croydon is deeply concerned that severe congestion issues at East Croydon station appear to have been completely overlooked:

v) Croydon expects work to address the accessibility and capacity issues at West Croydon station to be prioritised. Croydon seeks TfL's support for West Croydon station works to be prioritised in DfT's and Network Rail's investment plans.

2.2 Tramlink

Croydon council welcomes the commitment in investment and maintenance, renewals, upgrades and capacity enhancements planned for Tramlink between now and 2015.

The council also welcomes the statement that consideration will be given to looking at further extensions of Tramlink, with a strong focus on a potential north-south axis, in order to accommodate Croydon's future growth needs. This however falls short of the aspirations of many Croydon residents who see this extremely efficient, ecologically friendly and highly accessible form of transport as a preferable means of travel to that available to them at present.

We would therefore like to see a stronger commitment than just “consideration be given at further extensions”, recognising the potential to improve east-west links to neighbouring Outer London town centres and its significance in enhancing orbital connectivity.

Given that TfL Business Plan to 2017/18 funds have already been accounted for, it is imperative that tram extension studies are completed and funded in future business plans. Croydon expects to see an explicit commitment that Tramlink extensions will be a top priority for the TfL's Business Plan after 2017/18.

2.3 Bus network

Croydon council supports the proposal to keep the development of the bus network under regular review to cater for growth in population and employment, maintain ease of use, attractive frequencies and adequate capacity, reliable services, good coverage and good interchange. This is particularly important in outer London boroughs where buses are the only viable and attractive public transport alternative to the private car for medium and longer journeys.

However, the council is greatly concerned at the Mayor's intension of cutting bus budgets as part of his “efficiency savings” and the effect this will have on implementing his proposals. This will inevitably mean the reduction of bus services/frequencies on an already congested system, with little scope for increasing capacity and network coverage to cater for the projected growth in housing and population growth as well as employment and retail activity in outer London. It is important to ensure that such growth does not lead to an increase in private motor vehicle trips, as well as undermine the `suburban character' of outer London. The strategy must address this major issue.

Bus standing facilities are an important part of enhancing and developing the bus network and as such must also be addressed by the strategy.

The council is also concerned regarding the reliability and fairness of the overall service change consultation process. Local views must play an important role in service provision.

In order to attract more car users onto buses the journey experience must not only be as comfortable and convenient as possible, but also safe. The safety aspect including fear of crime are important considerations which are overlooked. Croydon council run a pilot scheme where night time marshals were used on a limited number of late night services used by visitors to Croydon's night time economy. Though the scheme was an overwhelming success it was not supported financially beyond the pilot phase. The Mayor should give serious consideration to safety on public transport and finance initiatives which support this.

2.4 Taxis / Minicabs / Community Transport

Croydon council welcomes the Mayor's support for improvements to the taxi service. Taxis are a safe and quick way of making door-to-door journeys and are particularly valuable for disabled people.

The council also welcomes the Mayor's commitment to support community transport services and to look at ways to closer coordinate them with transport facilities provided by TfL. However, the strategy makes no mention of dial-a- ride, mobility buses and the taxi-card, which play an important part in transport provision for the mobility impaired and therefore should be addressed.

2.5 Managing the road network

The council supports the principle of `smoothing the traffic' in terms of reducing congestion and stop-start driving as long as this is not at the expense of pedestrian and cycle crossing times or convenience and doesn't encourage more traffic or speeding. There is also a need for a review of all traffic signal timings to reduce unnecessary delay to traffic and ensure consistency and an equitable balance of priorities between private motor traffic and other modes.

Adequate funding for road and infrastructure improvements is essential in order to reduce ongoing and frequent works on poorly maintained roads which contribute to congestion and impact on reliability of journeys.

Better real time information for drivers about congestion/disruption and planned closures and road works will also assist in advance route planning and traffic congestion reduction.

Targeted physical measures at bottlenecks could also assist in smoothing traffic flows.

2.6 Airports

The strategy states that the Mayor recognises that adequate airport capacity is critical to the competitive position of London in a global economy. However, Croydon council believe there should be a greater emphasis on demand management, reviewing the taxation regime for aircraft fuel, encouraging greater use of high speed rail for short haul journeys and regional airports as opposed to London hubs. There also needs to be a review of rail fares, avoiding pricing which could deter use of rail services which have spare capacity.

Croydon is concerned that the increase of surface access trips likely to be associated with the potential doubling of [unconstrained] air passenger volumes at London's airports between 2006 (140M) and 2031 (290M) would be potentially catastrophic from both air quality and road congestion standpoints.

Croydon council is seriously concerned at the loss in December 2008 of Gatwick's only direct inter-regional rail service, and the further loss in September 2009 of direct and reasonably frequent regional rail services between Gatwick Airport and Watford. Watford is served by the West Coast Main Line, which itself serves a very large customer base in the Midlands and northwest England but has no direct Thameslink connection. Many users of the discontinued rail services, while possibly neither living nor working in London, now have no practical choice but to:

2.7 A more accessible transport system

Croydon council supports the proposals to improve the physical accessibility of the transport system by prioritising step free access at strategic interchanges. Step free access from street to platform benefits mobility impaired passengers. Passengers travelling with young children and larger pieces of luggage will also benefit from improved accessibility.

Accessibility should be `mainstreamed' and not seen as an `add on'. Platform to train accessibility, both on the underground and national rail networks, remains a key problem that needs addressing. Access to stations alone without accessibility at stations themselves is only part of the solution.

Croydon's town centre is served by two mainline stations, both of which are inaccessible. East Croydon Station is one of the ten busiest rail destinations and the third busiest interchange station in the country, providing access to bus, tram and taxis, yet access to and from the platforms is only available via long steep ramps. West Croydon station is located next to a tram stop and bus terminus. Meanwhile the arrival of the East London Line extension will provide access to the London underground in addition to the existing overground and will increase the footfall, but cannot be accessed step free.

It is acknowledged that attitudes and procedures can provide barriers to disabled peoples' travel and therefore the proposals to improve the quality of information provided and the attitudes of transport staff and travellers towards each other is encouraging.

It is disappointing to note that the opportunity has been missed to enhance consultation and involvement of older and disabled people through the promotion of accessibility/mobility forums, as proposed in the previous MTS.

Bus Stop Accessibility and the safety challenges arising for people with mobility difficulties have also not been adequately addressed in the draft strategy.

2.8 Integrating London's transport system and services

Croydon council welcomes the Mayor's proposal to prioritise improvements to strategic interchanges which are essential to ensuring multi-modal journeys or journeys involving more than one public transport service are convenient, comfortable, safe and reliable.

The expected economic development and population growth in the Croydon Metropolitan Town Centre will inevitably require improvements to key interchanges, including West Croydon station (rail-tram-bus-taxis) & East Croydon station (rail-tram-bus-taxi-kiss & ride).

3. Encouraging more cycling and walking

Croydon council supports proposals to encourage more walking and cycling. Walking and cycling have a key role to play in any transport strategy that is sustainable, making good use of existing infrastructure and with links to improving health and a safe, secure and attractive public realm that is pleasant to use. Where funding is not available for major projects for Croydon/South London it is particularly important that funding for the small scale projects is made available quickly.

It should be recognised that not everyone is able to walk or cycle and separate account should be taken of the needs of people with restricted mobility. This often comes to the forefront around public transport interchanges so funding for station access, improved rail/bus/tram interchange and making all bus stops fully accessible is essential.

Croydon also supports the principle of cycling superhighways and the cycle hire scheme. However these are mainly focused in central London and will only be introduced more extensively in Outer London if the initial schemes in central London are successful. Croydon would therefore welcome additional funding and support to develop `feeder routes' into the proposed Superhighways and to expand the London Cycle Network + (LCN+).

Without additional interventions to those proposed, it is unlikely that Outer London boroughs will be able to contribute significantly in increasing the mode share from the present 2% to the expected 5% by 2031, even though the target itself is lacking in ambition given the priority cycling has in the strategy and the fact that many other cities already have much higher cycling rates.

4. Improving safety and security

The Council supports all the proposals relevant to road safety. In terms of reducing accidental fatality rates on London's transport system further, the Mayor of London, TfL and bus operating companies need to also look at the driving standards of drivers.

Road safety casualty reports need to be timely if they are to be any use in terms of performance monitoring of the casualty reduction targets and effective targeting of resources.  At present there is a 6 to 7 month delay in the reports.  Proposal 65 should include the word "timely" with an associated time specification.

The council supports the approach to road safety engineering. However, there is scope for the Mayor to give a clearer lead to boroughs on this, to hasten the move away from traditional engineering measures.

The role of the Metropolitan police service in improving road safety and security cannot be stressed enough and as such not naming them in the document is an omission. There should be more emphasis on traffic policing and enforcement, instead of relying on physical measures and cameras, although the latter are useful.

5. Improving London's environment

Croydon council fully supports the Mayor's principle for “better streets” and the concept of “shared” spaces. Public spaces are part of what helps to define a city and are vital to ensure the whole community can use the streets whilst moving away from a car dominated city. Given the substantial improvements that can be achieved quickly, it is important that appropriate levels of funding are made available.

The council supports the proposals for noise reduction, particularly vehicular noise, as it is an issue that concerns many people. In addition to the various measures identified in the document, there may be scope for further restrictions on vehicle movement and vehicle noise standards, especially motorbikes as well as emergency vehicle sirens.

The council also supports the proposals to improve air quality, especially the targeting of `hotspots', which are significant in the borough. A feasibility study on hotspots has been submitted to TfL to improve traffic flow and air quality on the A23. It is imperative that funds are made available for these studies and the implementation of the resulting recommendations, especially in areas where the objective levels for air quality are already being exceeded.

6. Reducing transport's contribution to climate change and improving its resilience

The council welcomes the Mayor's proposal, through TfL, or otherwise, to work with the DfT to promote research, investment and regulation to achieve improved aviation carbon efficiency. At present any `sustainability' assessment would see a conflict between the carbon emission target and the acceptance of increased air passenger numbers. There is a strong economic case for supporting London's international airports, and Croydon could benefit from increased use of Gatwick if those passengers came to Croydon. However, a stronger alternative case can probably be made for enhancing public transport especially freight and passenger rail and extending tramlink, improving pedestrian and cycling environments especially in the town centre and making the borough more attractive for people and for business investment.

Croydon supports the development and mass market uptake of low carbon road vehicles (including electric vehicles) through, for example, the delivery of infrastructure required for the distribution of alternative transport fuel sources, including electric recharging points by 2015. A network of EVCPs will assist this so a good number are needed and the borough aspires to be a leading authority in this respect. However the carbon profile of the grid electricity is an issue which needs to be addressed if we are to achieve the claimed gains.

Road user charging and/or regulatory demand management measures to influence a shift to more CO2-efficient private and commercial road vehicles may be acceptable in principle but politically difficult. To date it has not been supported by the wider public and involves large scale complex systems to be put in place. However, it should be possible to achieve similar benefits through more voluntary changes in habits via Travel Plans, pool cars, cycling, walking and better public transport and information.

The council welcomes the proposal to plant an additional 10,000 trees on London's streets by 2012, with the ambition of an additional two million trees in London by 2025. In theory we are supportive but in practice it is more challenging. There is limited capacity for street tree planting in parts of the borough, especially those with existing limited tree cover. There may also be an issue due to lack of community support.

7. Managing the demand for travel

Croydon council supports better journey planning and smarter travel for people and goods. However there is a need to identify mechanisms and funding. Croydon's bid for a second Smarter Travel programme was unsuccessful. Without extra funding it will not be possible to deliver the entire range of travel awareness programmes.

The council welcomes the recognition of the importance of freight transport to London's economy and the need to make provision for it in street designs and road network planning. In this regard, the role of Freight Quality Partnerships (FQPs) in co-ordinating freight transport improvements should be recognised and adequate funds provided to continue the work of the London Freight Unit.

There also needs to be a mechanism to encourage local businesses and organisations to participate.

Croydon supports the proposal to ensure that fares provide an appropriate and necessary level of financial contribution towards the cost of providing public transport services to ensure that public transport continues to play a central role in London's transport system and overall economic development. However in 2007 bus fares were raised with the effect, if not the active intention, of discouraging some passengers from bus use thereby reducing overcrowding on buses. Croydon is concerned that possible further raising of fares, whether as a tool for managing passenger loadings or otherwise, could lead to a degree of modal shift away from public transport, with potential implications for traffic congestion, traffic noise, road safety and air quality. The effects would clearly conflict with a number of proposals in MTS .

There may however be a case for reviewing all concessionary travel to identify savings as well as reducing off peak fares to encourage public transport take-up.

8. Road user charging for economic and environmental aims

Although road user charging can be effective in altering travel patterns and can be tailored to support sustainable transport objectives, it is clearly a contentious policy. Therefore any schemes must be carefully considered to fit local conditions following extensive consultation.

In Outer London, the car is the dominant mode of transport for trips originating there, accounting for 52 per cent of all trips by residents. Croydon council therefore does not support demand management through road pricing (including the metropolitan town centres) in the absence of viable public transport alternatives.