Integration of the three strategies - to ensure there is consistency between the objectives of the three strategies and that they complement each other.

Robustness of the population and employment forecasts and scenarios upon which the plans are based - there are some concerns that the population forecasts may underestimate employment growth - e.g. Ealing Council have done some work on population projections taking account of actual Council tax records and have agreed with the GLA that revisions need to be made for Ealing. These have not been included in the population forecasts used in the London Plan.

The importance of clarity on and commitment to the transport investment - There needs to be a coordinated approach to the delivery of transport investment alongside realising housing and employment growth through new developments. We are particularly concerned that population and employment growth and development and regeneration opportunities, set out in the London Plan as specific Opportunity Areas and Areas of Intensification, will be frustrated by lack of transport investment. The emphasis in the MTS2 should be on identifying and providing appropriate investment such that this growth and these opportunities can be achieved. Early commitment to transport schemes that will increase capacity and accessibility in regeneration and opportunity areas needs to be made otherwise there is a danger that development in these areas will be stymied compromising the growth potential in London. We suggest a coordinated area-based approach across the three plans will help in the delivery of the full potential of each of the regeneration and opportunity areas.

Capacity of networks - This primarily relates to the capacity of the road network. An increase of 8.9% in population and 5.5% in employment over the lifetime of these strategies, together with background growth in travel demand from existing residents and workers, leads to a massive increase in the demand for travel on already congested road and public transport networks. Capacity will be increased on parts of the rail and tube network, though these are shown to be subject to the same or increased levels of crowding within the lifetime of the plan. There are aspirations for a greater modal share for walking and cycling but no targets. However, TfL's Business Plan to 2017/18 assumes a growth in operated bus mileage by only 8%, compared to a 60% increase between 1991/2 and 2007/8 and the draft MTS2 offers little investment in increasing the capacity of the road network. It is our concern that the policies and proposals set out in the London Plan, Economic Strategy and in particular the draft MTS2 will not provide sufficient transport capacity to meet forecast demand and so congestion on all modes will reach unacceptable levels, stifling economic and population growth.

No specific policies and proposals for taking forward the recommendations of the Outer London Commission - we welcome the recommendations of the Outer London Commission for development of hub and spoke networks in outer London, however there does not appear to be specific proposals about how to take this forward. For example the importance of orbital links are mentioned across each strategy however there are no specific proposals in the Transport Strategy. Orbital public transport in West London is focussed on the West and North London Lines and there are no proposals to improve orbital public transport elsewhere in West London even though the draft MTS2 recognises the need for orbital travel to Heathrow and the growth that is planned in metropolitan town centres. In this respect it would be better for the MTS2 to provide a policy supporting orbital public transport links and, if necessary, mention the West and North London Lines as an example.

There is a lack of detail on the nature and scale of the investment. The objectives set out in the strategies are all welcome, however there is a lack of detail about how they will be taken forward.

There is no MTS ambition to reduce journey times or support for removing bottlenecks on the road network (except through smarter travel initiatives).

While the Outer London Commission recommendation of developing a hub-and-spoke network based on existing town centres and employment locations is mentioned, there is little in the way of policies and proposals to support this.

There is no detail in the MTS on how town centres, Opportunity Areas and major developments are to be served with transport infrastructure and public transport services to support development; if these details are to be identified in specific Opportunity Area Planning Frameworks based on the sub-regional plans then this should be stated in the MTS2.

Investment in orbital public transport in West London is completely focussed in MTS on the North and West London Lines but there has been no attempt to connect this orbital transport provision in West London with Crossrail at the Old Oak Common interchange proposed by the London Borough of Hammersmith & Fulham.

There are no proposals to improve orbital public transport elsewhere in or near Ealing, even though the draft MTS2 recognises the need for orbital travel to Heathrow and the growth that is planned in metropolitan town centres: there is no mention of the West London Orbital scheme proposed by West London Business or the Wembley - Park Royal - Acton express bus proposal developed with the Park Royal Partnership.

Figure 39, instead of showing a good orbital bus network (paragraph 329), demonstrates how poorly Ealing, and London generally, is served by orbital bus routes. There is a need for much better communication and partnership working with TfL over the development of bus services which meet the needs of population and economic growth.

MTS recognises the need for orbital public transport links to support Crossrail though funding for these links is not included in the MTS Implementation Plan; there needs to be a review of the existing bus network and of proposals that provide improved connectivity to Crossrail.

There is no draft MTS2 reference express bus services: in the absence of orbital rail links there is a major potential role for orbital express buses on key corridors in Ealing serving town centres, housing and employment areas and stations (especially those served by Crossrail).

The draft MTS2 definition of strategic interchanges excludes interchanges at Heathrow and on tube lines in town centres in Ealing; this definition should not determine investment priorities for interchanges in London.

Some major interchange proposals already in the public domain and of significance to Ealing are not mentioned in the draft MTS2, for example the interchanges at Park Royal, Old Oak Common and West Ruislip.

There is no explicit draft MTS2 comment on the need for Transport for Sustainable Communities or any explicit linkage to the Government's national plans for a Sustainable Transport System.

There is no mention of encouragement in the draft MTS2 for 20mph zones, schemes constructed to Manual for Streets guidance and shared-space schemes

There is a lack of plans for improving accessibility at Ealing's stations: the cancellation of the half-completed project to provide step-free access at Greenford Station is considered deplorable.

There is no mention of the need to follow best practice in responding to major incidents on the main road network.

Aviation plans are not satisfactorily detailed in the draft MTS2. Ealing does not support the expansion of Heathrow and would support fully developed proposals for alternatives.

There is no attempt made to reform smarter travel initiatives to reduce carbon emissions by focussing on those movements that are carbon intensive; that is long-distance commuter travel, business travel, visitor travel and fleet and goods movements.

The role of freight quality partnerships in addressing freight problems, in relation to provision of facilities, efficiency of deliveries and safety of operation is not mentioned.