London Borough of Hackney response to draft Mayor's Transport Strategy
Summary
The draft Mayor's Transport Strategy contains a number of positive proposals that Hackney supports such as encouraging cycling, improving the public realm and improving orbital interchanges. However most of these proposals have been previously publicised and overall we feel that the strategy is not ambitious enough and offers few innovative or forward thinking proposals.
The document states that unless additional demand management measures such as road user charging are implemented London will not meet the objectives of the strategy, specifically the target of 60% reduction in carbon emissions by 2025 and reducing traffic congestion. The document states that without additional road user charging traffic congestion traffic will increase by 15% to 2031. However the Mayor has already publicly announced that he will not implement road user charging while he is in power.
These outcomes are disappointing considering the scale of the congestion and air pollution problems in London and the vulnerability of the city to climate change and rising sea levels. The fact that the majority of population and employment growth in London between now and 2031 will occur in inner East London areas mean that Hackney will be disproportionately affected by additional traffic congestion, public transport overcrowding and poor air quality and this document is not ambitious enough to counter these problems.
We also consider that the MTS2 consultation document fails to fully embrace the commitments towards the Olympic and Paralympic Legacy in the East London, as set out in the Five host Borough Strategic Regeneration Framework. The vision of the Strategy states that within 20 years the residents who will host the world's biggest event will enjoy the same social and economic chances as their neighbours across London.
Some of the strategic transport issues across London will be discussed on a sub-regional level. There are five of these, all of which have what is called `fuzzy boundaries', in recognition that transport issues not end at a defined boundary. Unfortunately, Hackney is at the border of three sub regional partnerships: East, North and Central. Being actively involved in two or three partnerships in London is difficult within current resources, and this need to be given some consideration.
Main issues for the London Borough of Hackney
|
MTS Proposals to manage and enhance the transport system
National Rail, Crossrail, Thameslink, Overground, DLR, Thameslink
Proposal 3 - Support the development of National Rail routes that relieve London of freight without an origin and destination in the Capital. Proposal 5 - Seek to ensure that Crossrail is delivered by 2017 and that it is fully integrated with the rest of London's public transport system. Proposal 6 - Consider future extensions of Crossrail that reduce congestion and improve connectivity on London commuter routes. Proposal 7 - Deliver the committed improvements to the rail network and services in London as set out by the DfT's High Level Output Specification for the period 2009-2014. Proposal 8 - Seek further capacity across London's rail network, beyond those schemes already committed. Proposal 9 - TfL will undertake a review of the safeguarded alignment for the Chelsea Hackney line to ensure it is providing the maximum benefits and value for money. Proposal 11 - Seek to deliver capacity enhancements at some of London's most congested stations. Proposal 14 - Investigate the feasibility of providing extra capacity to assist orbital movement on the Overground network and review potential benefits of extensions to the network of services. Proposal 15 & 16 - Investigate the feasibility of further capacity and network expansion of the DLR and of providing extra capacity on Tramlink. |
We are pleased by the inclusion of the commitment to Chelsea Hackney Line (CHL) and the commitment to improve orbital routes such as London Overground particularly the fact that Hackney Central/Downs Stations are classified as a strategic orbital interchange. We strongly believe that the Strategic Review for CHL is brought forward and completed in a shorter timescale than the 5 years suggested by the DfT and it should be along the currently safeguarded route. The post 2018 timescale for CHL should also be brought forward.
We support Crossrail but oppose use of Planning Contributions from developments in Hackney to fund the scheme.
The document includes reference to London Overground and West Anglia routes as being the highest priorities for capacity increases beyond committed funds which should have a positive impact upon Hackney.
The scale of growth in London during the lifetime of the strategy, particularly in inner East London requires continued investment in public transport post 2018 as demand will continue to outstrip capacity particularly in the radial corridors in north east London so there need to be further aspirational public transport schemes outlined in the MTS. If CHL cannot be delivered within the lifetime of the strategy then interim public transport enhancement projects need to be considered for the north east London radial corridors.
London Underground
Proposal 17 - Seek to deliver upgrades to all Tube lines in a phased programme to provide a significant increase in network capacity. Proposal 19 - Develop and implement a prioritised programme to deliver station capacity and accessibility enhancements at London's most congested Underground stations. Proposal 22 - Seek longer-term enhancements and extensions to the Underground network. |
We support the upgrades to interchanges such as Finsbury Park and Highbury & Islington which are both used by Hackney residents to access the Underground network.
London's bus network
Proposal 23 - Keep the development of the bus network under regular review. Proposal 24 - Improve bus passengers' journeys by measures including bus priority at critical locations and implementing the Countdown 2 project. Proposal 25 - Appoint bus manufacturers as part of the New Bus for London project by the end of 2009. |
The proposals only offer vague and non-specific commitments about developing the bus network to match growth and demand. However TfL's updated 2009-2018 Business Plan reveals that bus subsidy and bus route kilometres are being decreased and bus fares will rise at the Retail Price Index plus 2%, this is against a background of increased population growth which can only result in increased overcrowding. People's choice to use the bus network is heavily influenced by the frequency, reliability, and cost of the service; any reduction in frequency, and reliability, or increase in cost is likely to lead to a significant decrease in bus use and potentially corresponding increase in car use.
There is no mention of how the Mayor and TfL will cover the cost of replacing the articulated buses with the new Routemaster bus and how it may impact on road congestion due to the need to increase number of vehicles operating on these routes because capacity per vehicle is lower.
There is a commitment to improving bus passenger experience, however the proposal only mentions introducing bus priority at critical locations rather than the whole route corridor approach.
The previous reference to undertaking a fundamental review of the London bus network in the Statement of Intent (SOI) seems to have been removed. We feel that this is still necessary due to the large number of huge redevelopment and regeneration projects of such as Stratford, King's Cross and Woodberry Down which will have a massive impact on trip patterns.
Taxis and community transport
Proposal 26 - Support improvements to the taxi service through measures including continued access to bus lanes and the provision of ranks and facilities at interchanges. Proposal 29 - Encourage and support the community transport sector's contribution to the development and provision of transport services in London. |
The document commits to continuing support for Dial-a-Ride however there is no similar commitment to the Taxicard scheme.
Managing the road network
Proposal 30 - Introduce measures to smooth traffic flows by, for example, investing in intelligent traffic control systems, allowing motorcycles and scooters to use TLRN bus lanes for a trial period and implementing a targeted programme of road network improvements. Proposal 31 - Seek to minimise the impact of planned interventions on the road network by for example, developing a new roadworks permit system and developing the concept of `lane rental' charges for utilities. Proposal 34 - Take a criteria-based approach to road schemes which would allow them to go ahead if there is an overall net benefit. Proposal 35 - Work in collaboration with the boroughs and other stakeholders to cost-effectively maintain London's road network assets in a good state of repair. |
Smoothing traffic flows is welcomed as long as it does not generate additional traffic growth. Hackney believes that the proposal needs to be undertaken alongside travel demand management measures to ensure that freeing up traffic movement on roads does not attract additional car journeys.
Hackney does not support two powered wheelers in bus lanes and allowing motorcycles to use the bus lanes on the A10 conflicts with the objectives of the cycle superhighway scheme which is due to be implemented on this corridor. The Mayor needs to review the conflict between the Cycle Superhighways and allowing motorcycles in bus lanes on these routes.
We would strongly support the pedestrian countdown proposals and the streetworks permitting scheme which we have been working on with TfL.
We would support new road network improvement schemes as long as they do not result in any additional traffic generation (even if they result in reduced congestion in the vicinity of the scheme).
With regards to the commitment to good repair of road network - we support this proposal as there is a definite need to reverse the trend of last few years on TLRN, sections of which is currently in a poor condition.
River crossings
Proposal 39 - Progress a package of river crossings in East London, including a new fixed link at Silvertown, local links to improve connections for pedestrians and cyclists and support for maximising the impact of new rail links.
|
We support new river crossings as long as they do not increase traffic congestion on the wider east London road network and where they promote and improve sustainable transport options and support the regeneration of East London.
The proposed pedestrian and cycle links from the Isle of Dogs across the Thames is particularly positive, especially if they are implemented prior to the 2012 Games.
A more accessible transport system
Proposal 40 - Improve the physical accessibility of the transport system by prioritising step-free access at strategic interchanges, improving street accessibility in town centres and around accessible stations and maximising the accessibility benefits of new transport schemes, such as Crossrail. Proposal 44 - Support Dial-a-Ride services for people with mobility problems who require this form of transport service. |
Nothing new - the Mayor has not addressed the need to increase funding for accessibility improvements to the public realm prior to 2012, specifically to cater for mobility impaired visitors and athletes attending the Paralympics Games.
The document offers a commitment to support Dial-a-Ride services however there is no direct reference to continuing to fund the Freedom Pass or the Taxicard scheme.
Integrating London's transport system and services
Proposal 46 - Prioritise improvements to strategic interchanges that will provide opportunities for orbital transport services and provide opportunities to accommodate population and employment growth, with developer contributions towards the interchange improvements sought in appropriate circumstances. |
This is a very positive proposal as it identifies Hackney Central/Hackney Downs stations as a strategic orbital interchange therefore making it more likely it will be prioritised for improvement, specifically implementation of the direct interchange project. We would like to see a commitment to funding this project prior to 2012 in time for the Olympics rather than the post 2018 timescale this proposal is given.
London's airports
Proposal 47 - Opposes any further increases in capacity at Heathrow. Proposal 49 - Seek to improve access to London's airports for passengers and staff by public transport. |
Hackney believes that continued growth at Heathrow is unrealistic and unsustainable and therefore alternative options need to be seriously considered.
Proposals to encourage more walking and cycling
Cycling
Proposal 51 - Work with the London boroughs that are keen to pilot the `Biking Borough' approach to develop the Biking Borough scheme including measures such as cycle hubs and marketing initiatives to promote cycling. Proposal 53 - Deliver improvements to cycling infrastructure and training including the London Cycle Hire Scheme in 2010 in Central London, 12 Cycle Superhighways, enhanced cycle links to the Olympic Park by 2012 and increased provision of secure bicycle parking facilities. If the initial schemes are successful and there is sufficient demand cycle hire schemes and cycle superhighways will be introduced elsewhere, particularly in Outer London. Proposal 54 - Encourage changes to be made to the Highway Code that improve conditions for cyclists. Proposal 55 - Press for specific primary legislation to establish an effective legal framework for pedicabs, including specific licensing powers for the boroughs. Proposal 56 - Use the Mayor's planning powers to provide cycle parking to an appropriate standard and promote the co-location of key trip attractors to make cycling a more viable and attractive travel option. Proposal 57 - Aim to implement minimum levels of cycle parking provision at any new station or as part of any comprehensive station redevelopment works.
|
Generally positive proposals about encouraging cycling in London however the Mayor's outcome target for increasing cycling mode share from 2% to 5% by 2031 is not particularly challenging and Hackney has already surpassed this target with 8% mode share for cycling. We would like to see a more challenging target for cycling proposed particularly for inner London boroughs.
Hackney would be keen to bid for `Biking Borough' status because we believe that with our already high mode share for cycling we can help other boroughs replicate our success. We welcome the aims of this proposal but strongly criticise the fact this proposal seems to be focused only on Outer London boroughs rather than all boroughs and would like to see further detail of how the proposal will be funded.
Hackney would like to see a commitment to funding and implementing additional infrastructure improvements in the Cycle Hire area to counter safety concerns.
Cycle superhighways - we support this proposal however there needs to be full consideration of ways to overcome permeability barriers such as the Stoke Newington Gyratory. It is also disappointing that the proposed A10 route does not continue past Liverpool Street through the city to London Bridge as this is also a major trip attractor for cyclists.
Highway Code changes - we support this proposal in theory but further details are required, currently we are not certain what these changes entail. At the Borough and London-wide level, effective enforcement of the Highway Code where, for example, drivers illegally stop in cyclists' ASL areas could also improve conditions.
We support the proposal to introduce minimum cycle parking standards for stations, which should be of a adequate provision to cope with substantial growth in demand over the lifetime of the strategy.
Home/residential cycle parking is also major barrier to many local families uptake of cycling. There have been some excellent home cycle parking schemes retrofitted on housing estates in recent years in Hackney, and we believe this could be developed further across London.
Whilst funding for training related to the Cycle Hire Scheme is welcomed, this funding is specifically for additional requests generated by the Scheme. Paragraph 469 of the draft Strategy outlines `A comprehensive cycle training programme for schoolchildren, complemented by life-long training options'. However, changes to LIP funding have meant that there is no longer a ring fenced budget for ongoing cycle training, and departments have to compete with each other for funding. In Hackney our cycle training budget has had to be reduced. If the Mayor is to deliver this programme to its full potential, there will need to be ongoing, ring fenced funding for cycle training.
Walking
Proposal 59 - Improve the walking experience by enhancing the urban realm and taking focused action to ensure safe, comfortable and attractive walking conditions, including development of the Key Walking Route approach, providing direct, convenient pedestrian access where appropriate, enhancing pavement space for pedestrians and removing guardrails and other obstacles. Proposal 60 - Improve the quality and provision of information and resources for walking by measures including an online one-stop walking resource linked to an enhanced Journey Planner with advanced walking options and a roll out of Legible London. |
We support the proposals in the document and Hackney is already implementing most of them. We believe that there is a need for the Mayor to offer ring fenced funding for the implementation of Legible London proposals in town centres.
Proposals to improve safety and security
Improving road safety
Proposal 63 - Seek to achieve any new national road safety targets and such further road safety targets as the Mayor may set. Proposal 64 - Develop a new Road Safety Plan to reflect any new road safety targets to be set by the Government or the Mayor and review progress every five years. Proposal 67 - Improve safety for cyclists in the vicinity of HGVs by encouraging the Government to amend legislation and working to increase the number of HGVs with sideguards or electronic warning devices. Proposal 70 - Implement targeted physical engineering and other design considerations to improve road safety across London's road network. Proposal 71 - Encourage the early introduction of voluntary `intelligent speed adaption' subject to the outcome of trials. Proposal 72 - Continue implementing effective enforcement measures, targeted at locations with poor collision records, including trialling new time-distance cameras. |
Currently the document does not set specific targets at this time, just a commitment to review targets, aim for reductions and develop a new Road Safety Plan. We support the aims of these proposals however we would like to see a commitment to delivering it with funding and innovative ideas.
The 2009 DfT Road Safety Consultation Document, `A Safer Way', contains the following statement on casualty reduction targets “To improve health, the environment and congestion, we are keen to encourage more walking and cycling. We wish to reduce the risk to the individual walker or cyclist, and to take into account expected growth in activity - we are therefore proposing a target based on the rate of casualties: to reduce by at least 50% by 2020 the rate of KSI per km travelled by pedestrians and cyclists, compared with the 2004-08 average”. As the TfL 2009 Travel in London report has recently identified Hackney as the Borough with an exceptionally high volume of cycle trips, adopting a rate-based system of monitoring casualties is particularly pertinent here. The Mayor's Road Safety Plan should adopt this system in line with the DfT.
As a further measure, if barriers to cycling, both physical and psychological, are to be removed, it would also be useful to monitor Londoners' perceptions of the dangers of cycling as part of future surveys, both London-wide and in the Boroughs.
In particular, a publicity campaign encouraging drivers of all motor vehicles to share the road safely with cyclists could have the dual function of improving road safety and increasing rates of cycling, through reducing fear of motorised traffic in potential cyclists. For example the Highway Code emphasises giving cyclists plenty of room when passing them, and time and space to move at traffic light controlled junctions. Encouraging drivers not to stop in cyclists ASL (Advanced Stop Line) areas could also merit a publicity campaign.
The document references the serious problem regarding accidents involving HGVs and cyclists and commits to getting the Government to introduce legislation but again no specific targets are set. The Mayor's decision to close down the specialist HGV unit based at the Metropolitan Police seems to contradict these policy objectives however.
The Mayor needs to make a specific commitment to reduce casualties on the TLRN (his own road network) through targeted physical engineering schemes. Significant progress has been made with reducing casualties on borough's own roads however there continues to be serious accident and casualty problems on the red route network.
We are very supportive of the proposals to implement new time-distance cameras and Hackney is about to trial this technology on Stoke Newington Church Street to enforce a new 20 mph speed limit.
Enforcement of existing speed limits is the key to reducing the likelihood and consequence of collisions.
Reducing crime, the fear of crime and antisocial behaviour
Proposal 73 - Establish a statutory community safety partnership for transport and travelling in London. The partnership will develop and implement a rolling three-year community safety strategy to tackle crime, fear of crime and antisocial behaviour. Proposal 75 - Integrate local policing structures on the transport system; improve coordination and deploy resources collectively. Proposal 81 - Seek to reduce the likelihood and impact of potential terrorist attacks on the transport system. |
Hackney agrees that there is a need for better and fuller partnership between Transport Providers, BTP, Met Police and Local Authorities across London. LBH Community Safety have in the past organised a Safer Transport Group that met quarterly, this was pivotal in the joining up of Hackney CCTV and Transport Providers CCTV, providing seamless coverage of the borough. It was useful in the use of resources such as FlashCams and pro-active operations, sighting and location these in Hotspot areas identified by a number of Transport Providers and a joined up approach in areas such as the GLA's `Know What Your Getting Into' campaign that we ran in the Shoreditch area over two years.
Proposal 75: As above, agreed that this process would assist in greater prioritising of resources and highlighting issues across providers and organisations. Bring better and more concise public message and reassurance. We are currently meeting and working with Transport Hub Teams to achieve this.
Proposal 76: ASB across the transport network, especially around Bus Transport hubs and school dispersal, we have as stated in this proposal undertaken education around ASB and young people on the Transport network, a requirement for a prolonged approach to this problem is something that we would support and is an area of concern.
Proposal 77: We currently undertake and have placed a Designing Out Crime Officer with Planning and Transportation in Hackney, station and transport hub improvements are an area that Community Safety advice is taken on all occasions, we support a statutory obligation as in Section 17 CDR Act, to undertake this work.
Proposal 78: This is being undertaken with Planning and Transportation in Hackney, further to this we are undertaking a review of the data currently available to increase Transport input into Strategic Assessment, this is an area we support and wish to expand.
Proposal 79: We have and support this type of work, an annual campaign in Nightime economy hotspot areas such as the Shoreditch Triangle is something we are keen to support and undertake.
Proposal 80: We are engaged with ODA on looking at potential terrorist and Crime and Disorder issues around the Olympics and Olympic Build, we also plan and respond to instances and threats through LBH Emergency Planning, this is an area we support, although some better joining up of projects and proposals would be welcomed.
Proposals to improve London's environment
`Better Streets'
Proposal 82 - Use the principle of `better streets' to seek to improve town centres,for example, by removing clutter and improving the layout and design of streets, increasing the permeability of streets and creating clear and easily understandable routes and spaces to make it easier for cyclists, pedestrians and disabled people to get ahead. Proposal 83 - Introduce accessible for all `better streets' initiatives. Consideration will be given to trialling the removal of traffic signals where safe and appropriate. |
This proposal is mostly positive, it reflects much of what Hackney already implements on its own roads however further details of what this initiative will entail is required including how it will be funded. We are also disappointed that this proposal seems to be focused on town centres in Outer London rather than all of London.
We are supportive of `Shared Space' schemes and the removal of traffic lights where safe and appropriate to do so however TfL needs to streamline and smooth processes for doing this with direct funding provided. Currently there is no motivation for Councils to remove traffic signals because the process is so time consuming and costly for them.
Improving noise impacts
Proposal 85 - Target the provision of noise mitigation measures in areas significantly affected by transport noise. Proposal 86 - Explore opportunities to use the London Lorry Control Scheme to encourage companies to operate quieter vehicles and to promote improvements in air quality. |
We welcome proposals by the Mayor to reduce transportation noise in London. We however note that the document does not address noise from idling buses and we feel this something that needs to be examined.
Improving air quality
Proposal 90 - Promote behavioural changes to reduce vehicle emissions by measures such as promoting walking and cycling and the use of car clubs. Proposal 91 - Introduce measures to reduce emissions such as cleaner buses, taxis, PHVs and passenger boats and further rail electrification. Proposal 92 - Take further action to reduce private vehicle emissions including supporting the uptake of low emission vehicles, such as electric cars and vans, incentivising of low emission vehicles through pressing for changes to vehicle excise duty and parking regulations. Proposal 93 - Introduce targeted local measures at air quality hotspots to reduce emissions and improve local air quality. Proposal 94 - Continue to operate the existing London LEZ, including introducing phase four (introducing a further tightening of emission standards for HGVs, buses and coaches) in 2012 and deferring operation of phase three covering LGVs and minibuses to 2012. The Mayor will work with boroughs that wish to take local action to address air quality through local LEZs or similar measures. |
Traffic on the TLRN is a major contributor to poor air quality in London and Hackney is disappointed that TfL is not taking a more proactive approach to reducing particulates and nitrogen dioxide levels originating from vehicles on the TRLN.
The proposals place a lot of emphasis on voluntary measures many of which have been in place for a number of years, the council is of the view that at this stage when the time limits for achieving air quality objectives have been missed the emphasis should be more fiscal and compulsory measures that will achieve the objectives by the extended timescale.
Hackney agrees that a proportion of the air pollution affecting London arises from outside the Greater London area, however as the figures in the strategy point out the vast majority of the Nitrogen Dioxide and PM10 in London comes from emissions in London, and it is appropriate that the primary focus for addressing this must be effective action taken London wide.
Hackney welcomes the proposal to implement eco driving and would suggest that this proposal is strengthened through the use of vehicle tracking devices to monitor driver performance with retraining for drivers whose performance falls outside of acceptable limits.
Hackney welcomes the proposals to promote eco-driving for the public, freight drivers and tackling emissions from unnecessary idling.
Hackney welcomes the proposals all new buses post 2012 to be diesel hybrid buses, and would wish to see information on the number of new buses to be introduced each year included in the strategy.
Hackney welcomes the proposals to provide better information about emissions from the public transport fleet, and we would wish for comparative information on the performance of the bus operators made available, and displayed on buses and incentives/disincentives put in place to improve performance.
Hackney welcomes the proposals for targeted local action to deal with hotspots, and we would welcome the GLA and TfL to work with the council to improve air quality in the PM10 hotspots identified by DEFRA as remaining in 2011. We are aware that there are areas of predicted PM10 2011 exceedence elsewhere in the capital that are more widespread and may not lend themselves to hotspot action.
Hackney welcomes the proposals for the retention of the existing LEZ.
Hackney does not agree with the proposals for deferring Phase 3 of the LEZ and is of the opinion that other assistance, for instance the scrappage scheme could be put in place to assist affected operators. Again this is contrary to EU air quality targets.
Hackney welcomes the proposals for introducing an emission standard for NOx into the LEZ.
Hackney welcomes the proposals for additional LEZ measures should they prove necessary.
Hackney welcomes the proposals for assistance with local LEZs, but we would be concerned about the efficacy of a local LEZ on air quality.
Hackney would also suggest that measures are included to reduce emissions from excessive speeding on the major arterial road network that occur outside of peak hours, and the use of average speed cameras should be considered.
Hackney would also suggest that action is taken to reduce exposure in areas where vulnerable people are present e.g. outside schools by the use of pedestrianised areas.
Proposals to reduce transport's contribution to climate change and improve its resilience
Reducing CO2 emissions
Proposal 96 - Support, promote and improve sustainable, low CO2 emitting transport and reduce the need to travel through integration of transport and land use planning. Proposal 97 - Support expansion of car clubs and encourage their use of ultra low carbon vehicles. Proposal 101 - Implement a package of measures to reduce road traffic emissions by smoothing the flow of traffic and optimising the efficiency of London's road network. Proposal 102 - Encourage the purchase and/or use of low CO2 emitting road vehicles and low carbon fuel sources where feasible. Proposal 104 - Enable and support the development and mass market uptake of low carbon road vehicles (including electric vehicles) through, for example, the delivery of infrastructure required for the distribution of alternative transport fuel sources, including electric recharging points by 2015. Proposal 106 - Deliver additional low/zero carbon electricity-generating capacity and investigate the potential for microgeneration at sites on the transport system. Proposal 108 - Keep under review the option of road user charging and/or regulatory demand management measures to influence a shift to more CO2 efficient private and commercial road vehicles and to walking, cycling and public transport.
|
Hackney supports the Mayor's proposals for promoting electric vehicles and encouraging Car Club operators to adopt low carbon vehicles however the document lacks information on how this will be implemented. We believe that the Mayor also needs to take a lead with suppliers of parking equipment to encourage them to develop Pay & Display units to be combined with electric vehicle charging points.
The Mayor talks of installing Light Emitting Diodes (LED) in traffic signals to reduce power consumption by 60% but he makes no reference to street lights and lit street furniture. There is a need to reduce illuminated street furniture where possible and where lighting is indispensable such as street lights then LED bulbs should also be used. TfL is a major consumer of electricity for street lighting through its management of the TRLN and Hackney is disappointed that the introduction of this technology is not happening faster and TfL does not seem to be tacking the lead.
The document states that unless additional demand management measures such as road user charging are implemented London will not meet the objectives of the strategy, specifically the target of 60% reduction in carbon emissions by 2025 and reducing traffic congestion. As illustrated by Figure 58 in the MTS document a policy gap in exists between the impacts of the current proposals in the MTS and the Mayor's 2025 CO2 emission's reduction target which equates to approximately 2 million tonnes of CO2. The document goes on to state that road user charging has the greatest potential to fill the policy gap however the Mayor has already publicly announced that he will not implement road user charging while he is in power, seemingly disregarding what is set out in his own draft strategy document. This is disappointing considering the scale of the congestion and air pollution problems in London and the vulnerability of the city to climate change and rising sea levels.
Adapting to climate change
Proposal 110 - Prepare adaptation strategies to improve safety and network resilience to threats posed by climate change. Proposal 111 - Ensure the transport system is developed with climate change in mind by, for example, introducing energy efficient air-conditioned rolling stock where feasible and ensuring that all new buses entering the fleet will feature specific climate change adaptation measures. Proposal 112 - Plant an additional 10,000 trees on London's streets by 2012 with the ambition of another 2 million by 2025. |
We support the Mayor's proposals for climate change impact assessment for major infrastructure schemes and an assessment of the vulnerability of transport infrastructure to climate change.
Planting additional trees is supported however if the Mayor is setting a target for the number of trees funding to boroughs must be sufficient to cover the cost of ongoing maintenance not just the initial installation.
Proposals to manage the demand for travel
Better journey planning and smarter travel for people and goods
Proposal 115 - Use smarter travel initiatives across London to facilitate more efficient use of the transport system, achieve modal shift and encourage the take-up of healthier travel options. Proposal 116 - Improve the efficiency and effectiveness of freight operations through the promotion of `delivery and servicing plans' and other efficiency measures. |
We support the proposals here but are disappointed that there is nothing very new or innovative and the commitments to smarter travel initiatives and travel planning are generally vague and non-committal. We support the proposals to require Construction Logistic Plans and Delivery, Servicing Plans for new larger developments in London.
The Mayor's prioritisation of cycle hire and electric vehicle charging points (and specific parking provision for low-emission cars) are welcomed in principle as they encourage more sustainable measures of transport. However, parking spaces are at a premium in central London (in Hackney, the area Hoxton, Shoreditch and Old Street areas) and care must be taken to avoid creating additional parking pressures when locating these on the carriageway, especially in the short-to-medium term while the schemes are being embedded. On this basis, it is important that boroughs are given the flexibility to implement such schemes in a manner that is phased, relates to local demand and is informed by local knowledge.
Similarly, restricting the use of lanes (for example bus lanes, the Olympic Route Network) can further increase parking stress. Expansion of these networks and any further measures (for example, the proposed cycle superhighways) should be carefully considered in the context of their effects on local parking supply.
Fares and ticketing
Proposal 119 - Ensure that fares provide an appropriate and necessary level of financial contribution towards the cost of providing public transport services. Proposal 120 - Keep the range of concessions for which the Mayor is responsible under review to ensure they are focused on where they will be most effective at helping those in most need of them. Proposal 121 - Seek to conclude the creation of a fully-integrated fare collection system for London that covers both TfL and National Rail services. |
Hackney is concerned by the lack of commitment to keeping the Freedom pass in its current form, and the language relating to concessionary fares can be interpreted in any number of ways, providing no guarantees for low income residents currently reliant on it for accessing services.
Parking and loading
Proposal 123 - Seek to ensure fair and consistent enforcement of parking and loading regulations across London, together with consistent regulations, clearer signage, and more advance information regarding parking availability. Proposal 124 - Encourage implementation of pricing differentials based on vehicle emissions, including banded resident parking permits and other on and off-street parking charges, including incentives for electric vehicles. Proposal 126 - Support those park and ride schemes in Outer London that lead to an overall reduction in congestion, journey times and road vehicle kilometres.
|
The rules for parking signs and lines are set by statute. The Mayor's Transport Strategy should not recommend clearer signage as councils have very limited scope to dictate the format of parking signs.
While consistency can help motorists understand the regulations, councils also must prioritise parking space according to the needs of local residents and businesses - which requires local restrictions to suit local challenges. We feel the Mayor's Transport Strategy should explicitly acknowledge the need to balance the two.
Other than the above, we generally support the proposals outlined here but again but little detail is provided and much of what is proposed already occurs, for example Hackney already applies differential parking charges based on engine size and alternative fuels.
Road user charging for economic and environmental aims
Proposal 127 - Remove the Western Extension of the central London Congestion Charging zone after putting in place such measures in mitigation of negative impacts as are both desirable and practicable. Proposal 128 - Operate and monitor Congestion Charging in the original central London Congestion Charging zone, with periodic reviews to enable the Mayor to make variations. Proposal 129 - May consider road user charging schemes if other measures are deemed insufficient to meet the strategy's objectives. Any scheme would need to take account of local conditions. The Mayor will also consider imposing charges or tolls to support specific infrastructure improvements, such as river crossings. |
The removal of the Western Extension is a concern to Hackney because of the predicted impacts on bus journey times and the increased traffic generation/congestion which will likely result in poorer air quality for London as a whole. This action contradicts the Mayor's proposals to improve air quality, reduce CO2 emissions and the need to generate income to fund transport improvements in London.
The document leaves options open to possibly introduce additional road user charging schemes where appropriate if traffic increases and congestion worsens which the document states is inevitable (by up to 14% by 2031 even with the successful implementation of proposals and schemes such as Crossrail, cycling improvements and smoothing traffic). However the Mayor has since stated publicly that there will be no expansion of congestion charging while he is Mayor - contradicting his own policy proposals and suggesting that this consultation exercise is futile and he does not plan to be guided by his own policy document.
Hackney believes that the implementation of a London wide road user charging scheme is essential to reduce traffic congestion, improve road safety, encourage mode shift to sustainable modes of transport, improve air quality and help London meet its carbon emissions reduction targets
Of all the different measures that are proposed, please give your views on what the top priorities are for London.
Hackney believes the top priorities include:
Enhancing London's transport system and connectivity to support population and employment growth particularly in regeneration areas of east London which are predicted to experience the greatest growth in population and jobs - specifically the following proposals:
The development of the Chelsea-Hackney Line along the safeguarded route at the earliest opportunity, ensuring the strategic review of scheme is completed as soon as possible
Integrating London's transport system, particularly by enabling new orbital public transport trips by prioritising the upgrade and improvement of strategic orbital interchanges such as Hackney Central/Hackney Downs stations, Highbury & Islington station and Finsbury Park.
Capacity improvements to the West Anglia Line routes and London Overground routes
Managing the road network to maintain it to a good standard, street works permitting and trial of pedestrian countdown signals.
We feel that the following measures should also be included in the strategy:
Fundamental review of the bus network to take account of trip pattern changes due to the impact of major strategic developments such as Stratford City, King's Cross and Nine Elms.
Encouraging more cycling and walking through new facilities and infrastructure, enhanced and safer public realm, specifically the following proposals:
Removing barriers to cycling and improving permeability through the removal of gyratories
Implementation of Cycle Superhighway as long as it fully considers the removal of barriers such as gyratories
Introduction of the central London Cycle hire scheme with associated permeability and public realm improvements
Olympic cycle routes and associated permeability improvements
Safer roads and public realm through reduced speeds enforced by new technology such as time-distance cameras and intelligent speed adaption, with increased active enforcement by the Police to catch drink drivers, uninsured and untaxed drivers
Use of planning powers to ensure developments provide appropriate levels of cycle parking and changing facilities
Enhancing the public realm through better design of streets, decluttering and permeability improvements
Shared space schemes and traffic signal removal where safe and appropriate
Implementation of Legible London in all London town centres.
We feel that the following measures should also be included in the strategy:
Using the planning system to promote car free developments and clear zones.
Improving safety and security - specifically we feel that the following measures should also be included in the strategy:
Particular emphasis on road safety engineering improvements on the TLRN
Blanket 20mph speed limit on all of London's residential roads
Improving London's air quality, reducing transport's contributions to climate change and adapting to climate change - specifically the following proposals:
Promoting behaviour changes and smarter travel initiatives to encourage mode shift to sustainable transport
Encouraging the uptake of cleaner vehicles, particularly electric vehicles as long as it does not promote electric vehicles at the expense of walking, cycling and public transport.
Introduce targeted local improvement measures in air quality hotspots
Planting additional trees where funding covers ongoing maintenance.
We feel that the following measures should also be included in the strategy:
Bring forward implementation of phases 3 and 4 of the LEZ scheme to 2010
Use the planning system to promote car free/low carbon zones
Actively pursue options for introducing a London wide road user charging scheme
Reduce the use and need for lit street furniture and replace highway street lighting bulbs with LEDs to reduce power consumption (street lighting).
Managing travel demand for travel - specifically the following proposals:
Smarter travel initiatives, travel planning, travel awareness campaigns
Construction Logistic Plans
Delivery and Servicing Plans
Local journey planning information
Differential parking charges
We feel that the following measures should also be included in the strategy:
Travel Plans required not just encouraged for all new developments over a certain size
Area wide travel plans in town centres, industrial parks and business estates.
Tackling theft, fraud and misuse of Blue Badges. Hackney has introduced a team dedicated to tackling Blue Badge fraud and is investigating expanding it to cover other parking permits and vouchers. Fraud can happen across borough boundaries and encouraging similar teams across London would help combat fraud, reducing the demand for stolen Blue Badges and freeing up parking space for genuine badge holders. Hackney also offers a free “Companion Badge” to Blue Badge holders. It allows holders to park in the same places as a Blue Badge, but is specific to one vehicle so is useless to thieves. The badge is currently limited to use inside Hackney, but the creation of a London-wide standard Companion Badge would further increase accessibility and guard against theft.
Road user charging for economic and social aims:
Hackney believes that the implementation of a fair London wide road user charging scheme is essential to reduce traffic congestion, improve road safety, encourage mode shift to sustainable modes of transport, improve air quality and help London meet its carbon emissions reduction targets.
Are there any areas proposed that you disagree with?
Hackney disagrees with allowing two powered wheelers to use bus lanes, particularly on the A10 which is due to become a Cycle Superhighway corridor.
We disagree with the proposals for `Biking Boroughs' to only be an option for Outer London boroughs rather than all boroughs.
We disagree with the focus on public realm improvements in Metropolitan town centres not all town centres.
The decision to defer introduction of Phase 3 of the LEZ.
The Mayor's statement that additional London wide road user charging will not be implemented during his term in office prior to the results of this consultation exercise.
The outcome of a 15% increase in traffic congestion by 2031.
The removal of the Western Extension is a concern to Hackney because of the predicted impacts on bus journey times and the increased traffic congestion which will likely result in poorer air quality for London as a whole. This action contradicts the Mayor's proposals to improve air quality, reduce CO2 emissions and the need to generate income to fund transport improvements in London.
Paragraph 694, p246, states “there is growing concern from drivers and stakeholders in London that enforcement can be unfair and unreasonable and that regulations across London are inconsistent and confusing.” From Hackney's perspective, it does not appear that there is a growing concern - rather, it appears motorists' acceptance of the system may instead be increasing. Compliance with regulations is increasing and complaints are decreasing, both in number and ferocity. The increasing percentage of PCNs contested could be seen as indicating greater public confidence in the system - that drivers understand how to appeal and have confidence that their appeal will be treated fairly. This may be a result of the greater transparency and consistency brought in by the Traffic Management Act, which came into force in March 2008.
The principle of a Drivers' Charter (paragraph 697) is fine, but the draft circulated by London Councils on 05 November 2009 was ambiguous and open to interpretation. The charter must be worded in a way so that any local authorities that sign up to it are able to deliver what it promises. This requires the charter to precisely state its requirements or to be suitably high-level that local authorities are given flexibility to apply the concessions it considers appropriate to meet the goals of the charter.