Dear Mr Johnson,

LB Barking and Dagenham Response to Replacement London Plan

Thank you for giving the London Borough of Barking and Dagenham the opportunity to respond to the Mayor's Transport Strategy Public Draft (MTS). The Council's response follows the order of the MTS.

Whilst there is much to commend in the MTS around walking, cycling and the public realm the Council has fundamental concerns about whether the MTS will help Outer London maximise its economic potential and its approach to the London Riverside Opportunity Area.

Given that the MTS looks forward to 2031 the Council is very disappointed by the strategy's lack of ambition for this part of East London and can see little evidence of the necessary commitment to measures which will help address alleviate the borough's worsening deprivation.

We would welcome the response to discuss these issues with you in more detail

Yours sincerely

Jeremy Grint

Head of Regeneration and Economic Development

Appendix 1

LB Barking and Dagenham Response to the Mayor's Transport Strategy Public Draft

Chapter 3

Context

Figure 1 - Mode share

The Mode Share comparisons between 2006 and 2031 are not ambitious enough and demonstrate that the MTS will have little impact on modal shift. Indeed when the increase in overall trips made over the same period is factored in it appears that the total number of private motorised transport trips will be little different in 2031 from 2006. (9.99 million against 10.32 million). This compares to the 5% modal shift achieved from the car between 2000 and 2007 as highlighted in paragraph 159. In this regard we would challenge the contention in the same paragraph that the modal shift targets are challenging.

Figure 2 - Proposed outcomes

There is potential for these outcomes to be smarter, for example:

Figure 3 - Enhancements to London's Transport Infrastructure

This diagram needs to be supported by a table showing what the intended outcomes are for these transport enhancements. We maintain that the DLR extension to Dagenham Dock is necessary to deliver 10800 new homes, to serve what is fast becoming London's home for green technologies, to unlock investment in South Dagenham and to take pressure of the C2C line. The regeneration benefits for the other enhancements is not clear and this is the place to remedy that.

3.1.3 London-wide travel

Figure 6

Whilst we accept that London will continue to draw its workforce from far a field, the MTS needs to ensure that Londoner's can compete on a level playing field to access local jobs. This means ensuring local people have the right skills to compete for jobs and also the means to get to them. It is for example easier to get from Southend to Fenchurch Street as it is to get from Marks Gate to the River Road employment area. The MTS must not loose sight of the real difficulties local people can face in accessing local jobs.

East London Sub Region

Paragraph 74

It is not clear why Canary Wharf has been singled out as showing the “potential for transformational improvement”. The three key regeneration areas in Thames Gateway Barking and Dagenham (Barking Town Centre, Barking Riverside and South Dagenham) have the potential to deliver 20,000 new homes and to become London's centre for green technologies. We are the next chapter in the Thames Gateway success story. Therefore we suggest amending the last sentence of paragraph 74 as follows:

“The decline in the use of London's Docklands East London's riverside areas for industry, power generation and the movement of freight has led to significant regeneration initiatives and opportunities - with London Riverside and Canary Wharf showing the potential for transformational redevelopment.”

Figure 9 London-wide transport connectivity

This diagram shows that in comparison to the Opportunity Areas in north and west London that London Riverside is poorly served by public transport. We are pleased to see Dagenham Dock identified as an interchange and a Major Employment Hub and this diagram shows the necessity for the DLR extension from the UEL green square to the Dagenham Dock red triangle to remedy an obvious gap in public transport access. We will say more about this later.

This diagram also shows the potential for improved links between Barking and Stratford.

3.2.3 Outer London

Paragraph 95

We are pleased that the MTS recognises that significant areas of deprivation exist in Barking and Dagenham and that there is a need to improve access to jobs, services and opportunities to tackle deprivation, encourage inward investment and local job creation. However the MTS lacks any clear measures in this regard. Naturally through the sub-regional transport planning process we are willing to work with the Mayor to identify the measures to do this. These range from major schemes such as the Docklands DLR extension to Dagenham Dock to quick wins such as improving bus services to the River Road and Dagenham Dock employment areas.

3.3 Planning for London's development

Figure 14 - Spatial distribution of population growth to 2031

Figure 15 - Spatial distribution of employment growth to 2031

These figures concern us greatly. Figure 14 shows that Barking Riverside will only experience a growth of 2-3000 people by 2031 and South Dagenham will only experience a growth of 0-1000 people. This is at odds with the London Plan which identifies a capacity for 25,000 new homes in London Riverside. Of these approximately 20,000 will be in Barking and Dagenham and these are reflected in the borough's housing target of 1510 new homes per year. Similarly figure 15 shows that Dagenham Dock will experience a decline in employment by 2031 despite the fact that good progress is being made with implementing the Sustainable Industrial Park. These figures must be revisited. Investment decisions should not be made on the basis of this data.

The MTS makes clear in paragraph 104 that it is determined to improve the provision of public transport and place more emphasis on the economic development of Outer London yet figures 14 and 15 depict a very different story. They suggest the MTS has no ambition for Barking and Dagenham one of the most deprived areas in Outer London.

Paragraph 106

In the light of figures 14 and 15 we are concerned by the insistence that in Outer London growth should be concentrated in already successful areas and should not start from scratch. It needs to be clarified what is meant by “starting from scratch”. We would be very concerned if this is intended to refer to public transport improvements to Barking Riverside and South Dagenham. If it is not intended to improve public transport to London Riverside beyond committed investment then the 20,000 new homes which are planned here many of which are affordable and family sized will not be achieved. In this regard the avowed support of the MTS and London Plan for the Thames Gateway, for raising the economic performance of Outer London and for integrating land-use and transport planning is empty rhetoric.

Chapter 4

Challenges and strategic policies

Figure 18 - 2006 PTAL

Again this shows that London Riverside has very low PTAL levels and demonstrates the case for the DLR extension and other improvements to this area.

The MTS should include a 2031 PTAL map alongside the 2006 copy so boroughs can see how the policies and proposals impact on PTAL levels, in the same way that figures 67 and 68 compare crowding levels at 2031 with 2006.

Policy 4

The MTS is short on detail for what will happen beyond the current Business Plan. There will come a point when capacity on radial rails link is exhausted, then what? Figure 22 shows that's in 2031 the C2C service will remain one of the most overcrowded in London despite the fact that at this point it will be operating a 12 car service. The MTS needs to set out options for what happens when this point is reached. In this regard the Council is interested that figure 67 which takes into account improvements beyond the business plan shows reduced overcrowding on the C2C line through the borough. Given that Figure 22 takes into account the 12 car upgrade the Council would appreciate knowing what further plans are intended for the C2C service.

In this regard the Council considers that will be a need for schemes which take pressure of the main radial rail links. In this regard a rail link from Stratford through Barking must be explored which will in line with the findings of the Outer London Commission help improve links between Outer London Town Centres. Figure 67 shows that this can take advantage of less overcrowding on the link from Stratford to Liverpool Street which in 2031 would be underused due to Crossrail services being routed via Whitechapel. Also the DLR extension to Dagenham Dock by providing increased access to Crossrail at Custom House will help take pressure of current radial links. This may be factored in to Figure 67 but again this is not clear, as the DLR extension beyond Beckton which is shown in Figure 67 at 2031 does not appear to connect to the C2C line.

Policies 7 and 8

The Council considers that there is too much focus on Metropolitan Centres and not enough focus on Major Centres. Whilst the Council accepts and supports the need to improve access to Metropolitan Centre this needs to be complimentary to rather than compete with plans for Major Centres. For example Policy 8 highlights the need to improve links between Metropolitan Centres whereas we consider that improving access between a Metrpolitan Centre and its hinterland is more important. Again in this regard we would support improvements in access between Barking and Romford through improvements to the number 5 bus service and between Barking and Stratford through enhanced rail connectivity.

Policy 9

Paragraph 144

Here the priority of the MTS in east London is to maximise development opportunities around existing or committed transport infrastructure making the use of existing capacity. Special mention is made of the Royal Docks. However this is not consistent with the London Plan. The London Plan as a result of the SHLAA incorporates capacity for 25,000 new homes in London Riverside and due to this we have a housing target of 1510 new homes per year, the sixth highest in London. The forward to the MTS states that the Mayor “wants the best of both worlds”. This appears to be the strategy for London Riverside, the London Plan wants to achieve 25,000 new homes yet the MTS does not want to provide the investment necessary to deliver these. As written the MTS undermines investor confidence in London Riverside making clear that it wants growth focused in the Royal Docks. In the process the MTS is abandoning one of Outer London's most deprived areas, denying the opportunity to make a real difference to the lives of these Londoners.

To add insult to injury the MTS uses the development of the Docklands as a Case Study, highlighting that without the DLR and Jubilee Line Extension and road connection improvements the Docklands would not have developed as it has. The MTS in this instance is using an example from the past it does not support in the future.

The Council suggests rewording the last sentence of paragraph 144 as follows:

”In East London, in particular, a priority is to maximise development opportunities around existing or committed, or proposed transport infrastructure making the best use of available capacity (for example the Royal Docks), and some of London's largest brownfield land opportunities (for example London Riverside).

Policy 9d

We support the need to safeguard land for transport uses and hope that the Mayor will support the borough in safeguarding land for the Docklands Light Railway extension to Dagenham Dock.

Figure 25 - Highway Congestion 2006

Figure 26 - Highway Congestion 2031

Congestion is a major issue on the A13. This is caused by the at grade junction at Renwick Road and the Lodge Avenue flyover. This congestion makes access from the Dagenham Dock and in particular Rippleside and River Road Employment Areas particularly difficult, and businesses are telling us they cannot continue to operate in this location due to this. It is no coincidence that over 1.3 million square feet of B8 warehousing is vacant in Dagenham. This is the only at grade junction between the end of the Limehouse Link and Benfleet in Essex. The Lodge Avenue flyover is a temporary structure. Buses and HGVs breakdown on this flyover with regular occurrence. At peak hours this can cause tailbacks to the Limehouse Link and cause gridlock on surrounding streets. Figures 25 and 26 evidence this. Providing a grade separated junction at Renwick Road and replacing the flyover at Lodge Avenue are necessary to improve traffic flow and increase resilience and reliability along this stretch of the A13. This will in turn improve investor confidence which has been severely dented by the delays currently experienced on this stretch of the A13. Page 243 of the MTS mentions that there will be a 60% growth in container traffic at the London Gateway Port in Essex and therefore will further increase freight transport to and from London. This heightens the need to remedy the current bottlenecks at Renwick Road and Lodge Avenue.

Case study - page 91

This case study is of great interest to the Council. We are currently, albeit without success so far, trying to secure a direct bus service from Barking to Queen's Hospital. Barking does not have a hospital therefore residents must travel to either King George's or Queen's. However it is likely that many services will be transferred from the former to the latter next year therefore increasing the importance of a service from Barking.

Policy 17

Paragraph 186

One of the most significant impacts on health is stress, and the experience that people have travelling to and from work can be a major determinant in this regard and this should be recognised at this point of the MTS.

Policy 21

The Council supports this policy that supports the regeneration of Opportunity Areas as described in the London Plan. However at paragraph 213 it appears to prioritise investment in inner East London despite the fact that this borough in Outer East London is similarly deprived (as mentioned at paragraph 95) and has comparatively poor public transport access as evidenced by figure 18. We suggest rewording the beginning of paragraph 213 as follows:

“Neighbourhoods in need of regeneration are found across London but are concentrated in Inner London, particularly to the east. Significant areas of deprivation also exist in Barking and Dagenham. These neighbourhoods represent…

We support paragraph 214 and look forward to working with the Mayor to ensuring that London Riverside gets the investment in new public transport necessary to unlock its development potential.

Chapter 5

Transport proposals

Proposals to manage and enhance the transport system

Proposal 1

A direct rail link between Barking and Stratford would, in line with the recommendations of the Outer London Commission help increase access from Barking to this future Metropolitan Centre. It would also help make best use of largely existing infrastructure.

Proposal 2

The Council is surprised that no mention is made here of the proposed Strategic Freight Interchange at Rippleside which is included within the Council's Local Development Framework, and which takes advantage of High Speed 1 connections.

Proposal 3

The Council supports this proposal

Proposal 4

The Council supports this proposal

Proposal 5

The Council fully supports Crossrail which will help improve accessibility to other parts of London from Chadwell Heath.

The Council also supports Crossrail being fully integrated with the rest of London's transport system and in this regard the DLR extension to Dagenham Dock will help increase access to Custom House.

Proposal 6

The Council supports this proposal and in this regard considers that the business case should be developed for running services from Stratford via Barking and to the rest of the Thames Gateway.

Proposal 7

The Council supports this proposal which will see 12 car services introduced on C2C services.

Figure 32 - National rail and tube stress on radial corridors into central London

The Council is concerned that the C2C and East Anglia corridors will remain severely stressed in 2031. This is another reason to implement the DLR extension to Dagenham Dock. This increases the importance of maximising the employment potential of Outer London and questions the strategy of focusing employment growth in the CAZ and Isle of Dogs. Again increasing public transport access to the Strategic Industrial Locations south of the A13 will be important in this regard.

Figure 33 - Further capacity needed on radial rail routes to central London

Figure 31 identifies that 12 car trains are committed on the LTS line so the Council would like clarification as to why figure 33 shows that even longer trains will be introduced. This emphasises the importance of thinking beyond capacity improvements as many lines by 2014 will be at capacity. The Council supports the identification of DLR extensions and capacity enhancements in this regard as shown on Figure 33 which will help take the stress of radial rail routes.

Proposal 10

The Council supports this proposal

Proposal 11

The Council is pleased that mention is made of Barking station. The DfT recently identified it as one of the 10 worst stations in the country and therefore as a station which would benefit from targeted funding. Please see Figure 11 of the DfT publication “Better Rail Stations”.

Proposals 12 and 13

The Council supports this proposal. At off peak times including weekends C2C often run shortened trains, in many instances only 4 carriages. Which can mean that even during off peak periods overcrowding occurs.

Proposal 14

The Council supports this proposal. However mention should be made of the MTS support for the electrification of the Gospel Oak line as mentioned earlier in the MTS.

Proposal 15

Naturally the Council supports the extension of the DLR to Dagenham Dock however it is dismayed that it appears to have been relegated so that it appears alongside other DLR improvements with less clear cut regeneration benefits. Paragraph 289 is also of concern, as the MTS fails to take the opportunity to recognise that Barking Riverside is a key component of his housing plans not only the Governments. There is also more to the DLR extension than unlocking 10800 homes. It also improves access to the Dagenham Dock Sustainable Industrial Park, to the South Dagenham West site, improves access to the future Custom House Crossrail station, and takes pressure of the C2C line which will remain severely stressed in 2031. For all these reasons the extension of the DLR to Dagenham Dock should be a proposal in its own right as follows:

Proposal 16

“The Mayor supports the extension of the DLR to Dagenham Dock and through Transport for London will do what he can to ensure this is implemented during the lifetime of the Strategy.”

The Council also suggests that paragraph 289 be reworded as follows:

An The extension of the DLR to Dagenham Dock has been identified as is necessary to deliver 10,800 new homes at Barking Riverside and therefore is a key component of the Mayor's Government's housing plans for Barking Riversideas set out in the London Plan. It will also help increase access to the Dagenham Dock Sustainable Industrial Park, maximise accessibility to Crossrail services at Custom House and relieve stress on the London Tilbury Southend Line. The Mayor will lobby for the necessary investment to complete this essential link.

The other DLR improvements can be presented as a separate Proposal 16.

Proposal 17

The Council supports this proposal

Proposal 18

The Council supports this proposal

Proposal 23

The Council supports this proposal

Proposal 24

It would be useful to include a figure which shows the current availability of Countdown across London. Very few bus services in Barking and Dagenham benefit from countdown and this must change if modal shift is to occur in this borough. Therefore we suggest a rewording of Proposal 24 as follows:

d) Implement the Countdown 2 project evenly across London, to deliver expanded access to realtime information and develop further integration with digital communications to provide realtime bus information.

Proposal 26

The Council supports this proposal

Proposal 27

The Council supports this proposal

Proposal 28

The Council supports this proposal

Proposal 29

The Council supports this proposal

Proposals 30 and 34

The Council supports these proposals. With regard to the TLRN the single biggest issue facing the borough is congestion on the A13 caused by the at grade junction at Renwick Road and the Lodge Avenue flyover. This has already been detailed in this response. These two projects are the missing link in the A13 improvement scheme. With regard to Proposal 34 these improvements would provide net benefits for each of the five criterion listed.

Proposal 31

The Council supports this proposal

Proposal 32

The Council supports this proposal

Proposal 33

Whilst the Council supports this proposal this should not be a substitution for those improvements which are necessary to the road network such as on the A13 in Barking and Dagenham as previously detailed.

Proposal 35

The Council supports this proposal

Proposal 36

The Council supports this proposal and in due course would be interested in exploring the potential for river boat services from Barking Riverside to the Isle of Dogs and Central London.

Proposal 37

The Council supports this proposal and considers that Dagenham Dock has the potential to be a suitable location for a Boat Yard and is willing to explore this in more detail.

Proposal 38

The Council supports this proposal.

Proposal 39

The Council is pleased that the MTS recognises the need to progress a package of river crossings in East London. It rightly identifies the area's undue reliance on the Blackwall Tunnel and the gridlock that ensues when this is closed. In this regard whilst the Council recognises the need for an additional vehicular crossing to improve network resilience this must be done in unison with improvements to the A13 at Renwick Road and Lodge Avenue which are also severe points of stress on the strategic road network. Equally the Council would not want River Crossings to be progressed to the detriment of other schemes such as the DLR extension which may deliver greater regeneration benefits. For this reason the Council only supports additional River Crossings if they are self financing. Of the options presented on page 162, the Council favours a long term fixed link at Gallions Reach.

The Council also supports the MTS proposal to maximise the impact of new rail links including High Speed One on Crossrail. As previously explained the DLR extension to Dagenham Dock will help maximise accessibility to Custom House, and there is potential to use existing infrastructure to provide a direct rail link from Barking to Stratford.

Proposal 40

The Council supports measures to improve the physical accessibility of the transport system and considers that Barking Station is a particular priority in this regard.

Proposal 41

The Council supports this proposal however it is concerned at the relative (to other boroughs) lack of countdown facilities at bus stops in the borough and considers that more must be done to improve the availability of real time information on the borough's bus routes if the modal shift targets set out in the MTS are to be achieved.

Proposal 42

The Council supports this proposal.

Proposal 43

The Council supports this proposal.

Proposal 44

The Council supports this proposal.

Proposal 45

The Council supports this proposal to improve the customer experience and physical accessibility at interchanges across London. In this regard it is pleased that Barking is identified in figure 44 as a key strategic interchange.

Proposal 46

The Council supports this proposal to proritise improvements to strategic interchanges which will provide opportunities for orbital public transport services, provide interchange opportunities before arriving in central London and provide opportunities to accommodate population and employment growth. In this regard it considers that Dagenham Dock interchange as well as Barking Station should be prioritised as it has the potential to be an interchange between ELT, DLR and C2C services, taking stress of C2C services, helping support the growth of the Sustainable Industrial Park and unlocking Barking Riverside. In this respect it would not be too dissimilar too the Woolwich Arsenal interchange presented on page 172 of the MTS.

Proposal 47/48 and 49

The Council supports these proposals which oppose any further increases in capacity to Heathrow

With regard to Stansted the Council considers that if the airport does significantly increase in capacity that improvements to rail links from Stratford must be introduce. This would relieve stress on the inadequate services which run from London Liverpool Street improve access to Stansted from this future Metropolitan Centre and the rest of East London.

Proposal 50

The Council supports the MTS approach to delivering the improvements necessary to create a cycling revolution in London

Proposal 51

The Council is keen to become a “Biking Borough”; the number of cycle trips has doubled in the borough in the last year.

Proposal 52

The Council supports this proposal and is committed to holding two major events in 2010/11 to help promote cycling, it would be willing to look at the potential to hold a Skyride event.

Proposal 53

The Council supports the measure listed in this proposal to deliver improvements to cycling infrastructure and training and has made significant progress in recent years in this regard. It is keen to promote the Cycle Superhighway and considers there is potential to extend it further east and integrate it into surrounding residential and employment areas.

Proposal 54

The Council supports this proposal

Proposal 56

The Council supports this proposal which is reflected in the policies in the Council's Local Development Framework.

Proposal 57

The Council supports this proposal to implement minimum levels of cycling parking at any new station or as part of any comprehensive station improvement.

Proposal 58

The Council supports the proposal to improve the walking experience in London.

Proposal 59

The Council supports this proposal, however it considers more work needs to be done to gain public support for the “naked street” concept.

Proposals 60 and 61

The Council supports these proposals.

Proposals to improve safety and security

Proposal 62

The Council supports this proposal.

Proposals 63-70

The Council supports these proposals.

Proposals 71-72

The Council supports these proposals. It wrote to the Mayor in October 2009 expressing its interest in piloting a borough-wide 20 mph zone on residential streets. Figure 49 demonstrates that through the incremental roll out of 20 mph zones that it has in comparison to other Outer London Borough's made significant progress in this regard.

Proposals 73-81

The Council broadly supports these proposals

Proposals to improve London's environment

Proposals 82-84

The Council supports these proposals which are focused on the application of “Better Streets” principles to town centres.

Proposal 85

The Council supports this proposal and in particular supports the use of low noise surfacing which has been applied successfully as part of the ELT1a project.

Proposal 86

The Council supports this proposal

Proposal 87

The Council supports this proposal.

Proposal 88

The Council supports this proposal however it should also consider whether further intensification of existing airports in urban areas is appropriate. For example there is already evidence that City Airport is causing increased disturbance of the residents of Barking and Dagenham and whilst we recognise its importance to the economy this must be balanced with its impact on quality of life.

Proposal 89

The Council supports this proposal

Figure 54 - NO2 annual mean concentrations 2006

Figure 55 - PM10 annual mean concentrations 2006

These figures clearly demonstrate the impact of the congestion caused by the at grade junction at Renwick Road and the delays caused by the Lodge Avenue flyover. Figure 55 in particular shows a market difference in annual mean PM10 concentrations on the A13 east and west of the Goresbrook junction.

Proposals 90 - 93

The Council broadly supports these proposals which are focused on improving air quality. In particular it supports the electrification of the Barking to Gospel Oak line. In due course when Barking Riverside is more established it would also like to work with TfL to explore the scope for river services to the Royal Docks and Central London. It also supports the use of cleaner buses and in particular considers that the ELT routes and the number 5 route would be suitable for hybrid buses. The Council understands a hydrogen refuelling facility will be opening in Leyton in Summer 2010 which would enable this. Whilst the first route to benefit is the RV1 the Council considers that local routes should also benefit. The East London Transit is meant to be a flagship scheme and using hybrid buses would be consistent with this status.

Proposal 94

The Council broadly supports the MTS proposals with regard to the future operation and extent of the LEZ

Proposals to reduce transports contribution to climate change and improve its resilience

Proposals 95 - 97

The Council broadly supports these proposals however the MTS is short on detail as to how the 60% reduction in London's CO2 will be achieved by 2025 and in this regard the Council does not consider that the modal shift targets, particularly for walking and cycling are ambitious enough, given for example that this borough has seen the number of cycling trips double in the last year.

It also considers that the first aim must be to minimise the need to travel by for example improving employment opportunities in Outer London and supporting the co-location of complimentary activities. This does not feature strongly enough in this section. In this regard the three themes listed in paragraph 622 need to be amended so that minimising the need to travel is the first priority, carbon efficient travel behaviour is the second and improved operational efficiency is third. The Council is concerned that the MTS is relying too much on improvement to technologies, particularly lower carbon vehicular propulsion systems to achieve his targets. The danger in this is that it may disincentivise the adoption of more sustainable travel patterns and behaviour.

Proposals 98 and 99

The Council broadly supports these proposals.

Proposal 100

The message in this proposal is mixed. On the one hand the MTS says that strict limits on aviation growth are not tenable and therefore a breakthrough in aviation efficiency or significantly lower than forecast growth is needed to meet the targets. On the other it supports the expansion of rail based alternatives to short haul flights. The Council considers a more balanced approach is needed here which recognises that aviation growth can be controlled to some extent.

Proposal 101

The Council supports this proposal. Again it would like to stress the importance of providing a grade separate junction at Renwick Road and improvements to arrangements at the Lodge Avenue flyover to improve the flow of traffic alongside this stretch of the A13 and therefore to reduce CO2 emissions.

Proposal 102

Whilst the Council supports the use of low CO2 emitting road vehicles the first priority must be for organisations to reduce the amount of travelling that their employees need to do. The MTS must recognise that home working, video conferencing, work crèches, use of satellite offices and other measures can limit the need to travel. More significant CO2 reductions will be made if travel demands are moderated and only low CO2 emitting road vehicles used for the residual essential journeys.

Proposal 103

The MTS must define what he means by “sustainable biofuels”. The Council is concerned that some biofuels are actually more damaging to the climate than their fossil fuel equivalents. In addition, unchecked biofuel production poses a threat to vulnerable communities at risk from spiralling food prices, land grabs and human rights abuses, and to wildlife habitats worldwide.

Proposal 104

The Council supports this proposal however it is essential that a unified electric vehicle charging infrastructure is put in place across London. At present this Council's experience is that different approaches are being adopted in different boroughs which will frustrate rather than enable electric vehicle use.

The Council supports the eletrification of the Gospel Oak to Barking line. However it considers that the MTS should be equally supportive of the Dagenham Dock DLR extension and has suggested amendments to paragraph 289 and proposal 16.

Proposals 105 and 106

The Council supports these proposals

Proposal 107

The Council supports this proposal. However it takes a narrow perspective. London not only has the potential to be an early adopter of new technologies it also has the potential to be a centre of excellence for Research and Development into low carbon products and for their manufacture. In this regard good progress is being made in establishing the Institute for Sustainability which is part of the wider Sustainable Industrial Park, and is at the heart of the proposed Green Enterptise District as set out in Policy 4.10 of the London Plan.

Proposal 108

The Council supports this proposal and considers that road charging should be considered as an option on the A13 through for example the creation of a dedicated lane for commercial vehicles.

Proposals 109 to 113

The Council generally supports these initiatives

However it considers that Figure 61 is inaccurate and does not reflect the latest Strategic Flood Risk Assessments done in the Thames Gateway area by individual boroughs. Whilst Barking and Dagenham accepts that there are areas at significant risk of flooding in Barking and Dagenham it finds it surprising that other parts of the Thames Gateway are presented as having a low likelihood of flooding given that many parts of the Thames Gateway are in flood zone 3a.

Proposals to manage the demand for travel

Proposal 114

The Council generally supports this proposal

However it is concerned by the relative lack of countdown facilities in the borough.

Proposal 115

The Council supports this proposal

Proposal 116

The Council supports this proposal however the acronyms need to be explained

Proposals 117 and 118

The Council supports these proposals

Proposals 119-122

The Council generally supports these proposals. However it is concerned that current ticketing arrangements have a disproportionate effect on those travelling by bus in outer London who often as a matter of course have to change buses to reach their destination. Currently a new ticket must be bought for each separate leg of the journey. The Council considers that tickets should be time based rather than route based. It is clearly inequitable that a journey from Romford to Canning Town on the number 5 bus service is less expensive than a bus ride from Barking to Queen's hospital which requires a change at Becontree Heath.

Proposals 123 - 124

Parking regulations and parking charges should remain a borough issue, the Council would not support any proposal which involved it loosing these important powers.

Proposals 125

The Council supports this proposal

Proposal 126

The Council supports this proposal

Proposals 127-129

The Council considers that where tolling/road charging is introduced that this does not create any spatial disadvantages either between different parts of London, for example between one town centre and another, or between London and surrounding areas for example, A13 in London and A13 in Essex.

If tolling is introduced for a new river crossing at Gallions Reach surplus receipts should be ringfenced to new transport infrastructure in the surrounding areas.

Chapter 6

Expected outcomes of the transport strategy

6.1 Analytical approach and 6.2 Anticipated outputs and outcomes

The Council considers that the employment and population projections shown in Figures 14 and 15 are inaccurate and therefore questions how robust the outcome projections, sensitivity analysis and scenario testing actually is. The Council demands an explanation on this specific issue. The GLA have appeared to taken the line of least resistance in that it has not forecast any significant employment or population growth in Barking Riverside or South Dagenham on the basis it does not foresee the necessary infrastructure being implemented to enable this. Again given that the MTS runs to 2031 the Council's objects to this in the strongest terms. On this issue there is a clear difference of opinion between the London Plan, the Mayor's Economic Development Strategy and the Mayor's Transport Strategy on what will happen at Barking Riverside and South Dagenham over the next twenty years.

Figure 64 - How the strategy would support population and employment growth

It is odd that no mention is made of the London Plan Opportunity Areas where much of London's economic development and employment growth will be focused and no mention made of any commitment to provide the necessary infrastructure to support their regeneration. It is also odd that no mention is made of Outer London given that one of the key recommencations of the Outer London Commission was the need to maximise the economic development potential of Outer London.

Figure 67 - anticipated change in crowding levels on the National Rail network by 2031

Figure 68 - anticipated change in crowding levels on the Tube and DLR network by 2031

The Council is very pleased to see that Figure 68 2031 shows the DLR extension to Dagenham Dock. However for accuracy this should be shown as connecting to the London Tilbury Southend Line.

Chapter 7

Implementation Plan

Paragraph 740

An additional sentence should be included to read

”Where appropriate the Mayor will work with the relevant agencies to implement the Long-term schemes prior to 2021 if at all possible”

Rail

The Council supports the identification of further capacity increases on the Thames South Essex route beyond the committed 12 car upgrade.

DLR

The DLR extension to Dagenham Dock should be listed as a separate scheme and the third column should read 2020-2031 so it is consistent with paragraph 740.

Buses and bus transit

East London Transit phases 2 and 3 should be included.

Roads

Given the severity of the congestion on the A13 the Renwick Road/Lodge Avenue works should be shown as a separate scheme to be completed 2020-2031.

Policy 28

The Council supports the intention to prepare sub regional transport plans.

Chapter 8

Cost, resources and funding the strategy

Paragraph 8.2.1 Funding sources

This list should include European Investment Bank funding which has helped fund the DLR Woolwich extension

Policies 30-35

The Council generally supports these policies

However development contributions should be linked to the development they are secured from. The Council would not support the use of developer contributions on schemes from which the development they were secured derived no benefit and therefore meant funds were diverted from local transport improvements.

13