Appendix A
Consultation Questions
The Mayor is seeking views on his vision for London’s transport system and on the range of proposals set out in the draft strategy. For each of
the six broad policy areas the Mayor has asked for views on the measures and proposals and the top priorities together with suggestions for other
measures that should be included in the strategy. A suggested response to these questions is contained below.
1. Managing and Enhancing the Transport System (Proposal 1 to 49)
The City’s main priorities for enhancing the transport system are for the completion of the major rail projects such as Crossrail, Thameslink and
East London Line with the completion of the upgrade of the Underground network and continued maintenance and investment in the
infrastructure. In terms of future programmes of work, the City would support the reinstatement of the Cross River Tram into the TfL business
plan post 2017.
No.
Proposal Comment
4
The Mayor and TfL support the development of a national high- The City is supportive of the development of a national high speed rail
speed rail network and will work with the DfT, Network Rail, network, and believes it could bring many benefits. There are many
High Speed Two and other transport stakeholders to ensure that issues to consider, including the London terminus as highlighted in
the London terminal for any new high-speed line is centrally the proposal, but other issues, such as route alignment, connections to
located, well-connected to the existing public transport network, Heathrow etc are also important factors, and should be mentioned in
and widely accessible in order to maximise access to jobs and the proposal in order to make it comprehensive.
London’s population. It is currently considered that Euston best
meets these criteria and further evaluation will be made of this
and other locations.
5
The Mayor, through TfL, and working with the DfT, Network
The City is a strong supporter of Crossrail and it is a high priority to
Rail, train operating companies, freight operating companies,
see it delivered by 2017 with minimal impacts on residents and
boroughs and other transport stakeholders will seek to ensure
businesses during construction. The City would be keen to see future
1
that Crossrail is delivered by 2017, and that it is fully integrated
extensions of Crossrail aiding commuter routes, and making full use
with the rest of London’s public transport system; that the
of the new central London infrastructure
impacts of construction on residents and businesses are
minimised so far as possible; and that the future benefits
Crossrail brings are monitored to ensure the rail link achieves its
objectives.
6
The Mayor, through TfL, and working with the DfT, Network
Rail, train operating companies and other stakeholders, will
consider future extensions of Crossrail that reduce congestion
and improve connectivity on London commuter routes.
7
The Mayor, through TfL, will seek to ensure that Network Rail It is important to the City that the planned improvements to the rail
and the train operating companies deliver the committed network and services in London are delivered within the HLOS period
improvements to the rail network and services in London as set to 2014. These schemes, such as the increase in rolling stock and the
out by the DfT’s High Level Output Specification for the period completion of the East London line, will ensure reliability and
2009-2014.
increase capacity during the period leading up to the completion of the
major Thameslink and Crossrail schemes.
8
The Mayor, through TfL, and working with the DfT, Network Crowding and congestion on certain rail corridors, in particular in to
Rail, train operating companies, boroughs and other transport Liverpool Street, show no signs of improvement despite the HLOS
stakeholders, will seek further rail capacity across London’s rail and TfL investment plan. Figure 32 of the document (page 119)
network, beyond those schemes already committed. The highest shows that the rail corridors in 2017 and 2031 show little if any sign
priorities are to further increase capacity on London of improvement. Some rail corridors, such as those through London
Overground, southwest routes, the West Anglia Main Line and Bridge and into Fenchurch Street show signs of relief at 2017, but are
at congested stations.
back to being severely stressed by 2031. The outlook is bleak unless
significant investment is found for the new spending plan post 2017.
The City will support TfL and Network Rail in lobbying for adequate
funding for capacity enhancements including such schemes as the
‘eight tracking’ of the approach into Liverpool Street Station.
9
The Mayor supports new rail capacity in the broad southwest to The City is supportive of the proposal to build the Chelsea Hackney
northeast corridor, for example, new lines or services using the line, and therefore the review of the safeguarding of the route.
Chelsea Hackney line safeguarded alignment. TfL will However, with no funding available and the long timescales involved
2
undertake a review of the route to ensure it is providing the the City does not see this as a high priority at present.
maximum benefits and value for money.
11
The Mayor, through TfL, and working with the DfT, Network
The City, is supportive of this proposal, and believes that Liverpool
Rail, train operating companies and boroughs, will seek to
Street Station should be included in the Central London termini
deliver capacity enhancements at some of London’s most
programme. Cannon Street, London Bridge, Blackfriars and
congested stations. The highest priorities include:
Farringdon Stations are all being improved by Thameslink, Crossrail
a) Central London termini station congestion relief and onward
or development of the site above the station. There are no major plans
distribution enhancements (the potential of all onward modes
for such improvements to the existing rail station at Liverpool Street,
will be considered)
even with Crossrail.
b) Clapham Junction station capacity enhancement (new
improved links between platforms, additional
entrances and more ticketing facilities)
c) Improved capacity at National Rail stations with severe
congestion, including Finsbury Park, Bromley
South, Wimbledon, Vauxhall and Barking
d) Improved capacity at National Rail stations with moderate
congestion, including Willesden Junction,
Balham, West Croydon, Norwood Junction and Surbiton
14
The Mayor, through TfL and working with DfT and Network The City supports orbital movement, but is not directly served by the
Rail, will investigate the feasibility of providing extra capacity “Overground” network. Orbital links reduce the need for some
to assist orbital movement on the Overground network and will passengers to have to enter central London first in order to travel to
review potential benefits of extensions to the network of their destination. This will allow for some reduced congestion on
services.
some lines, but it is unclear as to the numbers of people that would be
taken off of the radial network. Whilst the City is supportive, this is a
much lower priority for us than completion of the Tube upgrades.
15
The Mayor, through TfL, will investigate the feasibility of
The City has been working with the DLR for some time on the
3
further capacity and network expansion of the DLR including an feasibility of a westward extension from Bank towards Charing Cross
extension to Dagenham Dock, as part of the housing proposals
and Victoria. The City is supportive of the concept and will support
for Barking Riverside, and further network extensions, including TfL in lobbying for funding to progress this opportunity to provide
options south of Lewisham, west of Bank and north of Stratford
valuable new links and interchange opportunities whilst helping to
International.
distribute passengers away from the existing Bank terminus.
17
The Mayor, through TfL, will seek to deliver upgrades to all
These two proposals are intrinsically linked and very important to the
Tube lines in a phased programme to provide a significant
City. It is vital that the Tube enhancement programme is completed
increase in network capacity. This will involve a combination of
and that once complete is kept in a good state of repair. Many
new rolling stock and/or signalling systems and other asset
commuters are faced with overcrowding on their journey to and from
replacement. As part of this, continued investment to bring the
work; the least that can be offered is a reliable service which is
network to a good state of repair and maintain it at that level will regularly maintained to reduce the risk of failures. Reliability will be
be supported.
an increasingly important factor as patronage continues to increase,
and more of the network will be running at its optimum without buffer
18
The Mayor, through TfL, will continue to deliver an ongoing
zones for failures.
programme of Tube station refurbishments
and asset stabilisation to ensure stations are operable and deliver
customer service requirements, as well as continuing to improve
station accessibility over the life of the strategy.
19
The Mayor, through TfL, and working with the London
The City is keen for the development of station capacity and
boroughs and other transport stakeholders, will develop and
enhancement programmes at congested stations. The City has been
implement a prioritised programme to deliver station capacity
working closely with London Underground regarding a long term
and accessibility enhancements at London’s most congested
congestion relief programme for Bank station and in securing a new
Underground stations, including:
entrance to the Waterloo and City Line. The City supports TfL in its
a) Congestion relief schemes to complement Tube line upgrades
quest to raise funding for the Bank Station masterplan, and will
and/or integrate with Crossrail at the key central London
continue to facilitate where possible.
interchanges of Victoria, Tottenham Court Road, Bond Street,
Paddington (Hammersmith & City) and at Bank
Moorgate station is in need of improvement as it is an ‘overflow’
station for Bank station on the Northern line and suffers from
overcrowding. Completion of the Northern line capacity
4
b) Schemes at further strategic Tube interchanges that are
enhancement will put more pressure on Bank and Moorgate and the
critical to London’s transport system (e.g. Vauxhall, Finsbury
completion of Crossrail is also likely to put more pressure on the
Park, Highbury & Islington, Holborn, Camden Town, Oxford
demand for north/south interchange at Moorgate. The City would like
Circus, Edgware Road and Northern line City branch, in
to see some timescales as to when the programme of works will be
particular Old Street and Moorgate)
developed so that it gives a clear indication of intent.
c) Major strategic multi-modal/National Rail interchanges on to
the Underground network to disperse onward demand arising
from National Rail proposals (HLOS2 and HS2 proposals), e.g.
London Bridge, Euston, Liverpool Street, Paddington, Elephant
& Castle and Waterloo.
20
The Mayor, through TfL, will implement the following
Over 90% of the City’s working population commute by public
measures in order to cool the Underground:
transport. Climate scientists predict that climate change will make
prolonged heat waves a regular event that could happen every other
a) New air-conditioned rolling stock across the sub-surface
year by the 2030s. The Sub Surface lines will benefit from air-
(Metropolitan, Circle, Hammersmith & City and
conditioning, but the strategy does not explain what is going to
District) lines, introduced progressively from 2010
happen with the deeper tube lines such as the Northern and Central
Line which are major transport arteries for City accessibility. The
b) Improved ventilation shafts and replacements of out of City appreciates the difficulty in identifying how the deep lines and
service fans
stations will be cooled, but it is important that a strategy for this is
established soon and that comprehensive contingency plans are put in
place in the interim.
22
The Mayor, through TfL, and working with the DfT, Network
The prediction, that despite the Northern line upgrades and other
Rail, train operating companies, boroughs and other stakeholders transport investment, there will be severe pressure on north-south
will seek longer-term enhancements and extensions to the
routes, through the City by 2031, resulting in congestion levels very
Underground network, including:
similar to that experienced today, is a disappointing outlook. The City
a) A further upgrade of the Northern line (Northern line Upgrade welcomes the Northern line upgrade 2, but there are concerns
2) to significantly increase train capacity through the City
regarding the overcrowding of stations, particularly at London Bridge,
Bank and Moorgate; station congestion relief needs need to be
b) A privately funded extension of the Northern line to Battersea considered for these stations as well as Camden Town. The recasting
to support regeneration of the Battersea/Nine Elms area
of the train pattern on the Northern line may create a further 20%
5
capacity by 2020, but the station platforms, escalators and exits need
c) A potential southern extension to the Bakerloo line will be to be able to cope with the assumed increase in patronage.
reviewed further to utilise spare line capacity, improve
connectivity and journey times, while providing relief to The City is not convinced that the proposed possible extension to
congested National Rail approaches to central London from the Battersea to aid the development at Vauxhall/Nine Elms/Battersea
south/southeast, subject to resources and the results of further Opportunity area will be beneficial to the existing Northern line and
study
its passengers. The City would stress that the degradation of existing
services on the Northern line would not be welcome. Within the draft
d) A link at Croxley to join the Watford branch of the London Plan (Policy 6.5), the Mayor identifies the extension of the
Metropolitan line to Watford Junction (funding to be secured by Northern Line as a scheme which could be part funded through
Hertfordshire County Council in conjunction with the DfT).
developer contributions in the same way as funding is currently being
sought for Crossrail. The City believes that Crossrail should remain
the Mayor’s priority and that the potential funding for any Northern
Line extension should not compromise the funding of Crossrail.
A southern extension to the Bakerloo line, whilst providing new
connections for an area with deprived transport links, would not be an
adequate substitute for the Cross River Tram. The business case for
the Cross River Tram is still very relevant and should be considered
for funding in the next business planning round.
23
The Mayor, through TfL, and working with the London Keeping the bus services under review is not sufficient. A full ‘grass
boroughs and other stakeholders will keep the development of routes’ approach needs to be undertaken, particularly in central
the bus network under regular review to cater for growth in London to assess whether the existing routes are the right ones. A
population and employment, maintain ease of use, attractive comprehensive review may well find savings that can be used to
frequencies and adequate capacity, reliable services, good reduce the existing subsidy. The City suffers from daytime
coverage and good interchange with other modes. All proposals congestion, often bus movements with few passengers, which leads to
for change will be appraised to ensure that they deliver good congestion and poor air quality. Particular corridors such as Ludgate
value for money and that the funds available are being invested Hill and Bishopsgate can appear ‘over-bussed’, and is commented on
in optimum service improvements.
by our stakeholders. The City would urge the inclusion of a
comprehensive review of bus routes and services in London in this
proposal.
6
26
The Mayor, through TfL, and working with the London
Allowing taxis to use bus lanes can work in some instances, but due to the
boroughs and other stakeholders will support improvements to
City’s traffic composition, in most cases it would be detrimental to the bus
the taxi service through a number of measures, including:
services. Access for taxis needs to be undertaken on a case by case
a) Continued highway priority for taxi services, for example,
basis.
access to bus lanes
The City believes that this strategy should clarify a plan for reducing taxi
b) Reduce taxi vehicle emissions and develop low emission taxis emissions. Taxis make up around 40% of traffic in some parts of the City
and have an impact on the air quality. A clear structured plan of how taxis
c) Provision of parking and waiting facilities, including rest
are to reduce their emissions and how this will aid the air quality targets
facilities
would be beneficial.
d) The provision of ranks and facilities at interchanges
The City has noted in its response to the Air Quality Strategy, that taxis
are one of the largest contributors to local emissions of both NOx and
e) Taxi marshalling
PM10 in the City and we would welcome further controls on their
emissions where possible. A requirement for all new taxis entering the
f) Action against touting and illegal cabs
fleet from 2012 to be Euro 4 seems rather under-ambitious. It appears that
significant emission reduction gains could be made if this was changed to
g) Improved driving behaviour, to be encouraged through the
Euro 5 and as a consequence, the City would like the Mayor to consider
licensing procedure of taxi drivers
this.
The City is supportive of Taxi Marshalling in the Square Mile, and taking
h) Ensuring regulated taxi fares changes allow drivers and
action against touting and illegal cabs (including PHV’s).
owners to continue to recover the costs of providing the taxi
service and provide a sufficient incentive for taxi provision to
.
meet demand, in particular at night
i) Continuous process improvements to provide a modern and
cost effective licensing service
29
The Mayor, through TfL, and working with the London
The Air Quality Strategy proposes a 15 year age limit for taxis from
boroughs and other stakeholders will encourage and support the
2012. Given the amount that the taxi fleet contributes to local
community transport sector’s contribution to the development
concentrations of PM10 and NO2, the City would like this to be tightened
and provision of transport services in London.
7
to 10 years from 2012.
30
The Mayor, through TfL, and working with the London
Smoothing of traffic flow is welcomed in principle as it will benefit those
boroughs and other stakeholders will introduce measures to
elements of the business City that rely on smooth road traffic for reliable
smooth traffic flows to manage congestion and improve journey
travel and deliveries and should also benefit air quality. However, care
time reliability for all people and freight movements, and
should be taken to ensure that any potential for increasing delays for
maximise the efficiency of the road system from a business and
pedestrians and cyclists particularly at signalled crossings is mitigated.
individual perspective by, for example:
This could generate a tension as other policies in the document which are
a) Investment in intelligent traffic control systems and the
encouraging a ‘cycling revolution’ and ‘making walking count’ aim to
infrastructure to support it
increase the numbers within these modes. In conclusion the City is
supportive of improving traffic flow because of its business and air quality
b) Allowing motorcycles and scooters to use TLRN bus lanes
benefits providing there remains a fair balance between vehicle-based
for a trial period and evaluating its impact
business needs and the safety of pedestrians and cyclists.
c) Upgrading, optimisation and rationalisation of equipment at
More detailed information is necessary before the City can fully
signal controlled junctions
understand the implications of this proposal.. We have concerns that in
certain areas of the City, if green times for pedestrians are reduced this
d) Working with the DfT to pilot and develop the concept of
may cause overcrowding of the footway, but the suggestion of a
pedestrian countdown at traffic signals to optimise the amount of pedestrian countdown may be beneficial in such areas. The City would
‘green time’ for both pedestrians and road traffic
welcome discussions about how this proposal will be implemented.
e) Implementing a targeted programme of road network
Figure 26 in the document shows the anticipated highway congestion for
improvements, potentially including junction upgrades, to
2031. After completion of planned improvements, the figure suggests that
improve traffic flow on the most congested sections and to
most of the City will be experiencing greater than 2 minutes of average
improve conditions for all road users
vehicle delay per vehicle km. This is not a prospect the City wishes to see
as this will significantly affect City businesses and our local environment.
f) Working with utility companies to reduce the impact of their It is not just the flow of traffic that needs to be tackled but significant
street works on traffic congestion
reduction in the number of vehicles being used. This can only be
achieved by measures such as road user charging and enforced service and
delivery plans which use consolidation centres, as proposed in the
document.
8
31
The Mayor, through TfL, and working with the London The City is fully supportive of co-operative working to minimise
boroughs and utility companies will seek to minimise the impact disruption and already feeds into TfL's LondonWorks system, and is a part
of planned interventions on the road network on the movement of the new permit system which will start on 11 Jan 2010.
of people and goods by:
a) Utilising ‘LondonWorks’ to provide a way of improving 'lane rental' is an interesting concept which may bring large benefits to
street works planning and coordination
minimising disruption to the road network, and the City would be happy
to work with the Mayor to investigate this. However, it would also be
b) Developing a new roadworks permit system
sensible to assess the impact of the new permit system before developing
a detailed concept of ‘lane rental’.
c) Developing the concept of ‘lane rental’ charges for utilities to
reflect the value of their temporary possession of road capacity
(in terms of cost of delay to the road user)
32
The Mayor, through TfL, and working with the London The City is fully supportive of this proposal and we already work with the
boroughs and other stakeholders, will improve the realtime London Traffic Control Centre to deal with incidents. Any improvements
management of unplanned interventions and incidents on the to this facility and process would be welcomed.
road network, and improve communications to minimise the
disruption and improve public satisfaction with road network
management.
33
The Mayor, through TfL, and working with the London The City would welcome any improvements to traffic control systems in
boroughs and other stakeholders, will utilise advances in ITS the City.
technology to better manage the road network, improve realtime
traffic management capability and lay the foundations for
communication with in-vehicle systems, with the aim of
developing a state-of-the art traffic signal control system for the
21st century.
34
The Mayor, through TfL, and working with the London
The concept of a criteria based approach to road schemes is welcomed in
boroughs and other stakeholders will take a criteria-based
the main. However, in Central London in particular, local authorities have
approach to road schemes which would allow them to go ahead
had difficulties in the past with getting TfL to approve schemes that
if there is an overall net benefit, taking into account the
affected the Strategic Road Network due to the Network Management
9
following factors:
Duty. How will this criteria based approach work in parallel, and will TfL
a) The contribution to London’s development/regeneration
still be responsible for making these final decisions? Such a lot of money
has been spent assessing schemes in great detail and using expensive
b) The extent to which congestion is reduced
modelling procedures, for TfL to delay making a decision and asking for
yet further information. The process by which these schemes are approved
c) How net benefit to London’s environment can be provided
also needs to be revised, not just the criteria.
d) How conditions for pedestrians, cyclists, public transport
users, freight and local residents can be improved
e) How safety for all is improved
36
The Mayor, through TfL, and working with the Port of London The City is a member of the River Concordat and continues to support the
Authority, the ODA, boat operators, pier owners, riparian development of river services and infrastructure
boroughs and other interested parties will continue the River
Services Concordat to work together to enable the development
of London’s river services to reach their full potential and to
better integrate river services into the overall transport network.
37
The Mayor, through TfL, and working with the London
boroughs and other stakeholders, will encourage the provision of
more pier capacity, particularly in central London and will seek
financial support for new piers when considering development
proposals in the vicinity of the Thames. The Mayor, through
TfL, will also work with the Port of London Authority, boroughs
and operators to identify and promote suitable boat yard
facilities in London.
47
The Mayor recognises that adequate airport runway capacity is
The City has previously stated that it does not think that Heathrow should
critical to the competitive position of London in a global
be ignored as a possibility for future expansion, until all other options
economy, but opposes any further increases in capacity at
have been assessed. We are supportive of the continued investigations for
Heathrow.
additional capacity in the south east to ensure the competitive position of
10
London.
2.
Encouraging more cycling and walking
The City is supportive of encouraging more sustainable modes of transport such as cycling and walking, and has been working with TfL to
accommodate the Cycle Hire Scheme. Whilst increasing the numbers of people cycling and walking will have many benefits, the City is often
reminded by stakeholders of the conflict, particularly between these two modes. The is a need to ensure safer cycling practices and so education
is an important part of making these proposals work as well as providing the right information and infrastructure. Cycle parking forms an
integral part of the Mayor’s “cycling revolution” and this is reflected in numerous parts of the strategy. The City has almost exhausted its on
street cycle parking opportunities and is now looking at the possibilities for providing alternative off street provision.
No. Proposal Comment
53
The Mayor, through TfL, and working with the boroughs and
e) A preliminary, informal survey among businesses in the City has
other stakeholders, will deliver improvements to cycling
suggested that about 10,000 commuters would take up cycling as their
infrastructure and training to support the cycling revolution,
mode of transport if adequate parking facilities were available. The City
including:
is developing plans to address this issue locally, but the bicycles need to
a) The London Cycle Hire Scheme in 2010 in central London
be stored at the origin of the journey and other stops of multi-leg
journeys as well. The Strategy, in connection with the London Plan,
b) Twelve Cycle Superhighways will be developed for commuters should ensure that all new residential developments provide adequate
and others to cycle to central London, improving the capacity of
cycle storage opportunities. Also, the Strategy needs to emphasize that
the radial network
cycle parking at key destinations needs to be placed strategically (e.g.
near the edges of pedestrian zones, close to supermarkets, shopping
c) Enhanced cycle links to the Olympic Park by 2012 and the
centres and leisure facilities) and be adequately signposted.
development of a wider network of Greenways across London
d) Cycle hire schemes and cycle superhighways introduced
elsewhere, particularly in Outer London, if the initial schemes are
11
successful and there is sufficient demand
e) Increased provision of secure bicycle parking facilities,
particularly at stations, workplaces, schools, retail and leisure
sites
f) Improving the permeability of the road network for cycling
g) Delivering road enhancements to make cycling easier and
safer, including managing car access to residential areas, through
physical or design measures, to create pleasant and safer cycling
environments
h) Offering cycle training for people of all ages
55
The Mayor, through TfL, and working with the London boroughs
The City supports the proposed licensing of pedicabs.
and other stakeholders, will press for specific primary legislation
to establish an effective legal framework for pedicabs, including
specific licensing powers for the boroughs.
59
The Mayor, through TfL, and working with the London boroughs
The City has been improving its street environment for several years to
and other stakeholders, will improve the walking experience by
make the City a more pleasant place to walk, however there is still much
enhancing the urban realm and taking focused action to ensure
work that needs to be done, particularly in managing the conflict
safe, comfortable and attractive walking conditions, including:
between pedestrians, cyclists and vehicles and finding the right balance
a) Development of the Key Walking Route approach
across the City. Education and other proactive measures to ensure safer
cycling will also make the street environment a safer more pleasant
b) Providing direct, convenient pedestrian access (for example,
place for pedestrians. The City is supportive of the approach to improve
with surface crossings) where appropriate
the pedestrian experience, and in trying to encourage people to walk
more as part of their daily routine to improve their health.
c) Street audits to identify pedestrian needs and guidance (such as
pedestrian comfort levels)
d) Completing the seven Strategic Walking Network routes
12
e) Training for those involved in the design and delivery of
walking schemes
f) Enhancing pavement space for pedestrians and removing
guardrails and other obstacles
g) Seeking to manage car access to residential areas, through
physical or design measures, to create pleasant and safer walking
environments
h) Tackling the fear of crime and feeling unsafe on the streets
i) Supporting major projects such as high street revitalisation
through good quality urban realm designed to
support regeneration of small businesses and encourage local
shopping and activity
j) Improving access and safety between the station and
surrounding areas for pedestrians (and cyclists) to encourage
active and smarter travel
k) Encouraging the extension of a network of linked green spaces
(ie a green grid approach) throughout London
60
The Mayor, through TfL, and working with the London boroughs
The City is supportive of improved information to aid the take up of
and other stakeholders, will improve the quality and provision of
walking
information and resources for walking, especially at stations,
interchanges and in town centres, by:
a) Creating an online one-stop walking resource to facilitate
walking, linked to an enhanced Journey Planner with advanced
walking options
13
b) Developing consistent wayfinding formats and making use of
new wayfinding technologies
c) Roll out of Legible London to other areas
3.
Improving Safety and Security (proposals 62 to 81)
The City takes safety and security of its communities very seriously and generally supports the direction of the MTS proposals. The City
believes that the policies encouraging an increase in cycling and walking activity need to be accompanied by a pro-active approach to road
safety. Education and design will be crucial tools to minimise conflicts of interest on busy streets and pavements. The City of London Police
are working with TfL, the British Transport Police and the Metropolitan Police forces to provide a coordinated and consistent approach for the
travelling public.
No. Proposal Comment
62
The Mayor, through TfL, and working with the London boroughs, Bus driver training needs to be improved and more emphasis on cyclist
Network Rail, train operating companies and other stakeholders,
awareness included.
will seek to reduce accidental fatality and injury rates on
London’s transport system further; and will aim to reduce London
Bus road user fatality, major and minor injury rates.
63
The Mayor, through TfL, and working with the London boroughs, The proposed new national casualty targets are not appropriate for
Highways Agency, road safety partnerships and other
London. The Mayor, through TfL, should seek to reduce casualties
stakeholders, will seek to achieve any new national road safety
further and set higher targets.
targets and such further road safety targets as the Mayor may set
from time to time.
64
The Mayor, through TfL, and working with the Highways
We welcome the opportunity for further consultation on the new Road
Agency, boroughs, road safety partnerships and other
Safety Plan.
stakeholders, will develop a new Road Safety Plan to reflect any
new road safety targets to be set by the Government or the Mayor
14
and review progress every five years.
66
The Mayor, through TfL, and working with the London boroughs, Liaison with borough Road Safety Officers needs to be improved, the
the DfT and other stakeholders, will undertake public information
infrequent Pan London meetings are not sufficient, with increased
and engagement to improve road user behaviours and reduce the
consultation on new proposed road safety education and publicity
risk of collisions
initiatives.
67
The Mayor, through TfL, and working with the DfT, boroughs,
Agreed - with additional increased provision of cycle training and cyclist
road freight operators and other stakeholders, will improve safety
awareness campaigns.
for cyclists in the vicinity of HGVs, by:
a) Encouraging the Government to amend legislation and remove
the current exemption for HGVs being fitted with sideguard
protection
b) Working to increase the number of HGVs with sideguards or
fitted with electronic warning devices that detect cyclists
4.
Improving London’s Environment (proposals 82 to 94)
The City is a strong supporter of improving London’s environment and supports the proposals below. It is felt however that these proposals
could be improved further by being more specific in some cases and clearly linking with the Air Quality Strategy so that targets can be achieved
in tandem.
No. Proposal Comment
85
The Mayor, through TfL, and working with the London boroughs
The City supports the proposals for mitigating transport related noise, in
and other stakeholders, will target the provision of noise reduction particular quieter buses and replacing road surfaces with low noise
measures and noise mitigation measures in areas significantly
surfacing where possible. However, the strategy is lacking in timescales
affected by transport noise, to improve perceptions of noise and
for the introduction of quieter technology. It would benefit from
reduce the impacts of noise by:
specific measurable targets and referencing the priority areas for
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a) Timely and effective rail maintenance and replacement works
deploying quieter buses and road surfacing.
b) Working to the TfL Health Safety and Environment policy
The proposals for noise mitigation would also benefit from being
assessed and undertaken alongside the air quality management targets so
c) Ensuring all new transport projects consider noise mitigation
that the two policies can be addressed in tandem.
d) Introducing road maintenance programmes to replace road
surfaces with low-noise surfacing where possible
e) Improving traffic management and signal control techniques
f) Introducing speed enforcement measures which do not
encourage noisy, rapid acceleration and deceleration
g) Introducing quieter buses
h) Procuring new quieter public sector service vehicles,
potentially through joint procurement to achieve efficiency
86
The Mayor, through TfL, and working with the London councils,
The City supports the investigation into opportunities to use the London
London boroughs, freight industry, and other stakeholders, will
Lorry Control Scheme to encourage companies to operate quieter
explore opportunities to use the London Lorry Control Scheme to
vehicles and the encouragement of quieter driving.
encourage companies to operate quieter vehicles as well to
promote improvements in air quality and reduce CO2 emissions.
88
The Mayor, through TfL, and working with DfT, the national air
The City would welcome the coordination of aircraft flight paths so they
traffic control service, and the European Commission will:
minimise their impact on London and the development of quieter
a) Encourage the development and use of quieter aircraft
aircraft.
b) Seek to coordinate flight paths so they minimise their impact
on London
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89
The Mayor, through TfL, and working with the DfT, Highways
Improving the quality and diversity of London's natural environment is
Agency, London boroughs, Network Rail, and other stakeholders, welcome, although this proposal is a little vague as to the detail of what
will work to make the most of open spaces across the transport
is hoped to be achieved. This proposal could benefit from being more
system (eg green spaces alongside roads, rivers, cycle Greenways, specific. There does not appear to be any funding identified for
strategic walking routes, green grids, roof tops, and railway lines)
potential projects related to biodiversity. Funding streams should try to
to improve the quality and diversity of London’s natural
be identified. This proposal should also be specifically linked to draft
environment.
London Plan Policy 2.18 which seeks to apply Green grid principles
across London.
90
The Mayor, through TfL, and working with London boroughs,
The City welcomes the implementation of ‘ecodriver’ training for
transport operators and other stakeholders, will promote
drivers of vehicles within the Mayor’s authority, and the potential for
behavioural changes to reduce vehicle emissions by:
rolling this out to members of the public. The City is considering
a) Promoting walking and cycling, the use of car clubs, car
introducing a similar scheme for its employees, both drivers and desk
sharing, the use of fuel-efficient vehicles and smarter driving
bound staff.
techniques and raising awareness about air quality
.
b) Implementing eco-driving training for all GLA/functional body
and bus drivers
c) The Mayor will also reduce emissions from the wider fleet by
supporting eco-driving training for members of the public, freight
drivers (through the existing FORS scheme) and tackling
emissions caused by unnecessary idling
d) Providing better information about emissions from the public
transport fleet
91
The Mayor, through TfL, and working with the London boroughs, Whilst the City supports the proposal to reduce emissions from the
DfT, Network Rail, train operating companies, and other
public transport fleet, no specific targets or measures have been set. For
stakeholders, will introduce measures to reduce emissions,
example, buses and taxis contribute to a significant amount of local air
including:
pollution in the City and need to be tackled, this strategy agrees with
a) Cleaner buses which pollute the air less
that, but doesn’t take us any further forward on how or when this will be
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achieved.
b) Cleaner taxis, PHVs
The reduction of NOx (52% by 2015) and PM10 (25% by 2015) detailed
in figure 56 and 57 is ambitious, and the measures detailed in this
c) Further rail electrification, including the recently announced
strategy are unlikely to achieve these reductions.
Great Western line electrification scheme, and the Barking to
The City would be pleased to see proposals for public sector bodies to
Gospel Oak line
have minimum emission standards in their respective fleets. As the City
has adopted NI194 into its Local Area Agreement, we have made a
d) Cleaner passenger boats and other river vessels, which use
commitment to reduce our own emissions both from our fleet and
more environmentally friendly fuels
buildings over the next two years.
The City believes that the MTS should include an explicit cross
e) Encourage the introduction of cleaner public service and local
reference to the policies in the London Plan and the provisions of the
authority vehicles
Mayor’s Air Quality Strategy.
92
The Mayor, through TfL, and working with the London boroughs
and other stakeholders, will take further action to reduce private
The City can see the benefit of having electric car fleets in terms of
vehicle emissions by:
minimising local air pollution from emissions. However, the City has
a) Supporting the uptake of low emission vehicles, such as
concerns that encouraging the take up of electric vehicles for private use
electric cars and vans
may encourage a shift of people that are currently travelling by public
transport into electric vehicles (particularly if they are provided with
b) Incentivisation of low emission vehicles through pressing for
reduced parking charges, and other exemptions). This will have a
changes to vehicle excise duty and parking regulations
negative impact on congestion. The City has already had to reverse its
policy of providing free parking for electric vehicles due to a massive
c) Working with the European Commission, the Government and
rise in the numbers of electric vehicle owners applying for free parking
vehicle manufacturers, the Mayor will seek new technologies
permits following the introduction of the congestion charge. The City is
which help vehicles be cleaner, such as better tyres which wear
keen to ensure that there is no modal shift away from public transport
less, more sophisticated abatement technology and automatic
towards private vehicles.
hybrid-switching
93
The Mayor, through TfL, and working with the London boroughs
The City would be pleased to work with the Mayor, through TfL, to
and other stakeholders, will introduce targeted local measures at
introduce targeted local measures at air quality hot spots to improve air
air quality hotspots to reduce emissions and improve local air
quality. However, in light of the very tight timescale in which to develop
and implement effective measures to achieve the PM10 Limit value by
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quality.
2011, the City of London would like to register its concern over the
apparent lack of proposals at very this late stage. Again there should be
an explicit reference to the London Plan and Mayor’s Air Quality
Strategy.
94
The Mayor, through TfL, will continue to operate the existing
The strategy suggests that London Boroughs may wish to develop their
London LEZ. The Mayor will consider further tightening of the
own Low Emission Zones, in addition to the London Wide LEZ. This
standards of the current LEZ, as well as the introduction of further approach seems rather impractical and potentially very confusing. In
emissions control schemes to encourage the use of cleaner
order to be effective, a LEZ would need to cover a wide area . The City
vehicles in London:
would like the strategy to explain why a Central / Inner London LEZ
a) The current LEZ scheme will continue to operate to reduce
covering, for example the Congestion Charge Zone, or within the North
emissions from the heaviest vehicles, and phase four will be
/ South circular was discounted.
introduced in 2012
The City is pleased to see that the Mayor proposes to introduce a NOx
b) The Mayor will defer the implementation of phase three of the
standard for the LEZ in 2015. Mayoral support for a national
scheme covering LGVs and minibuses (which was due to
certification and testing scheme for NOx retrofit equipment is also very
commence in 2010) to 2012
welcome.
c) In 2015, the Mayor will, subject to technical feasibility,
It is unfortunate that the Mayor intends to defer Phase 3 of the London
introduce an emissions standard for NOx (EuroIV) into the
Low Emission Zone to 2012. The Mayor will be aware that the
London LEZ for HGVs, buses and coaches (phase five)
European Commission has rejected the UK's application for an
extension for compliance with the PM10 objective to 2011. The
d) If necessary, the Mayor may consider introducing minimum
application included proposals for Phase 3 of the LEZ to be
requirements for other vehicles or tighter standards in particular
implemented in 2010, which would have been in time for the 2011
locations within London
deadline. The City is particularly concerned about the delayed
implementation of Phase 3 of the LEZ, as certain roads within the City
e) The Mayor will work with boroughs that wish to take local
continue to exceed the PM10 objective, and will do so beyond 2011,
action to address air quality through local low emission zones or
unless a coordinated suite of measures are implemented to reduce
similar measures
emissions. The City is aware that some options to control PM10 are
being considered by the Mayor and Transport for London, but nothing
concrete has been forthcoming to date. Given the European
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Commissions recent decision, this matter is now urgent.
5.
Reducing Transport’s contribution to climate change and improving its resilience (proposals 95 to 113)
The City of London is committed to reducing its impact on climate change. Achieving the regional and national emissions reduction targets will
require coordinated action on national, regional and local scale. The Mayor has an important role to play in coordinating such action across
London, thus enabling concerted local action that contributes to regional targets. Generally the City is supportive of the proposals in this section.
No. Proposal Comment
99
The Mayor, through TfL, will introduce automatic train control (a The City supports the introduction of automatic train control across the
tool that can optimise energy efficiency through driving style)
tube network which will generally make for a more reliable service and
across the Tube network. Drivers of non-automatic railways, such smoother journeys for passengers.
as London Overground, will be given training on energy efficient
driving style, as will London’s bus drivers.
101 The Mayor, through TfL, and working with the London boroughs, As per proposal 30
Highways Agency, and other stakeholders, will implement a
package of measures (including the rephasing and coordination of
traffic signals) to reduce road traffic emissions by smoothing the
flow of traffic and optimising the efficiency of London’s road
network.
107 The Mayor, through TfL, and working with the London boroughs Regarding item c) –
and other stakeholders, will promote CO2 standards for vehicles
and infrastructure controlled, procured or regulated by the Mayor, The City has noted in its response to the Air Quality Strategy, that Taxis
GLA Group and/or other public sector bodies (eg public transport
are one of the largest contributors to local emissions of both NOx and
vehicles, taxis, street and station lighting and infrastructure
PM10 in the City and we would welcome further controls on their
embodied carbon) to reduce emissions from existing and new
emissions where possible. A requirement for all new taxis entering the
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vehicles and infrastructure, including the following specific
fleet from 2012 to be Euro 4 seems rather under-ambitious. It appears
measures:
that significant emission reduction gains could be made if this was
a) The Mayor, through his functional bodies, will have an
changed to Euro 5 and as a consequence, the City would like the Mayor
increased electric-powered vehicle fleet by 2015
to consider this whilst introducing a lower carbon taxi.
b) All new buses entering fleets operated on behalf of the Mayor
from 2011/12 will be lower carbon
c) Completion of the Low Carbon Taxi Development Programme
by 2012, working with vehicle manufacturers and the taxi trade to
develop a new low carbon and low air pollutant version of the
London taxi
d) A three-year trial of at least five hydrogen-powered buses from
2010
e) Trialling of low energy station lighting and automatic meter
reading
f) LED traffic signals preferred to conventional technology when
replacing life-expired signal sets and trialling of LED street
lighting
g) Major infrastructure schemes will conduct a carbon footprint
assessment
112 The Mayor, through TfL, and working with the London boroughs, Trees are very important features of urban areas and provide
Network Rail and other transport infrastructure owners, will plant
unparalleled benefits relating to biodiversity, climate change and air
an additional 10,000 trees on London’s streets by 2012, with the
quality. Given that there is very limited space available in the City, trees
ambition of an additional two million trees in London by 2025.
must be chosen and placed strategically to provide maximum benefit.
The Open Spaces directorate is currently developing a City Tree
Strategy. The Mayor’s Strategy should make reference to specific
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benefits to be considered in the choice of tree species to be planted,
particularly biodiversity, climate change and air quality.
6.
Managing the Demand for Travel (Proposals 114 to 129)
Proposals for managing demand are important, considering that the predictions are for continued growth of demand without sufficient capacity
to improve travelling conditions for passengers in the long term. Provision of information is an important element of this, as is encouraging
modal shifts to walking and cycling, however public transport fares are a critical part of attracting businesses to London and therefore large
increases in fares would discourage future investment. The City, whilst supportive of the concept of managing demand, can see that it is also
one of the more difficult areas to achieve a noticeable difference.
No. Proposal Comment
114 The Mayor, through TfL, and working with the London boroughs, The City fully supports the improvements to the public information on
DfT, Network Rail, train operating companies, and other
journey planning and will aid this where possible. The City publicises
stakeholders, will enhance the provision of information to
its own public transport guide which is also available on-line.
improve customers’ knowledge and understanding on service
availability, delays and other information to improve customer
satisfaction and the way in which Londoners use public transport
and make travel decisions by:
a) Upgrading the TfL web-based Journey Planner, allowing
further improvements to realtime performance, accuracy and
personalisation
b) Providing customers with a range of paper-based information
(Tube, cycle and bus ‘spider’ maps, timetables, fares and service
changes)
c) Raising public awareness and knowledge of existing public
transport provision, particularly, orbital public transport services
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d) Further development of journey planning, including web-based
information, for local trips to town centres
e) Developing town centre journey planning tools
116 The Mayor, through TfL, and working with the London boroughs, The City is interested in how to improve the efficiency and effectiveness
and other stakeholders in the public and private sectors, will
of freight operations and has been taking part in research with ‘London
improve the efficiency and effectiveness of freight operations
Remade’ regarding our own freight movements and would support
through the promotion of ‘delivery and servicing plans’,
measures to encourage private sector bodies in the City to consider their
‘construction logistics plans’, the Freight Operator Recognition
own impact of freight movements.
Scheme and other efficiency measures, across London.
119 The Mayor will ensure that fares provide an appropriate and
Whilst the City agree that public transport fares should be appropriate in
necessary level of financial contribution towards the cost of
order to contribute towards the cost of providing services, the City does
providing public transport services to ensure that public transport
not think that large increases in fares would be acceptable, particularly
continues to play a central role in London’s transport system and
when the Strategy suggests that overcrowding will continue to be a
overall economic development.
problem despite further transport enhancements. If public transport
fares are seen to be too expensive, this will impact on the attractiveness
of investing in London.
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