On 11 January 2019, the Richmond Society responded to the London Borough of Richmond upon Thames’s consultation about the Third Local Implementation Plan for the Mayor’s Transport Strategy.

Questions 1 and 2 covered the details of who we are. Our answers to the subsequent questions comprise our response.

3. To what extend do you support or oppose the objectives of the LIP?

Tend to support.

4. Please tell us the aspects of the Objectives section that you particularly like and why:

We support initiatives that facilitate more walking and cycling – most especially for shorter journeys and when supplemented by a better public transport provision for longer journeys, or when active travel options are not practical or desirable.

We support the aspirations for developing “Healthy Routes” to schools although it may prove hard to derive a tangible benefit at schools located in areas of high traffic flow and pollution.

The move to online shopping and decline of high streets has led to more freight traffic using residential roads and we would welcome action to promote the consolidation of delivery services. We would expect residents of car-free developments to place a high reliance on supermarket and similar household delivery services. We therefore support Council action to obtain a better understanding of freight deliveries and gain tangible evidence in advance of trying to implement changes that may have economic repercussions.

5. Please tell us the aspects of the Objectives section that you particularly dislike and why :

The LIP does not seem to promote an integrated transport strategy – most especially one that recognises the impact of the proposed large scale housing development in Mortlake, Kew and North Sheen. It’s all very well to give blanket support for car free developments in high PTAL areas, but this is a crude indicator that does not consider where residents want to travel to for work, schools and for shopping and social reasons.

Reducing overall levels of car ownership and supporting public transport are admirable objectives but we have some concern about the Council using CPZ’s as “a key mechanism for the borough to influence the number and type of vehicles owned by residents”. For some residents this will be construed as a further tax on the less affluent while those with off-street parking would be exempted. Furthermore, the Council allows motorcycles to park in a CPZ without a permit, but it is unclear whether encouraging a shift to P2W vehicles is a desired policy objective or unintended consequence. It will also be a simple matter for residents of car free developments with s106 restrictions on CPZ permits to park their P2Ws in a CPZ space.

There is an important distinction that is not well made between reducing people’s use of private cars versus their ownership of a private car. While discouraging ownership might be a good thing, not every trip can be accomplished on public transport – moving heavy things or taking the elderly to hospital for example. For those type of journeys car clubs and taxis provide an important public service. However, because the Mayor doesn’t consider car clubs, taxis or private hire vehicles to fall within the “Public Transport” category any trips using these methods are meant to be subject to the modal shift aims when this may not be appropriate.

Average bus speeds are quoted in the LIP as being typical for outer London but the Council nevertheless intends (yet again) to review the operational hours of existing bus lanes. The slower and more unreliable aspects of a bus journey for a passenger will often be time spent at bus stops and in taking convoluted routes of no benefit to most riders. An origin and destination study to evaluate the appropriateness of bus routes and, most especially, to establish the feasibility of express bus services may be a better use of resources and ultimately prove a better way to entice more bus passengers.

6. To what extent do you support or oppose the delivery plan?

Tend to support.

7. Please tell us the aspects of the Delivery Plan section that you particularly like and why.

We welcome the Council’s desire to increase understanding around freight and servicing activity. However, we are concerned about comments in the text that pre-suppose a desire to reduce freight traffic before knowing the economic impact.

We are pleased that the council intends to work with local community groups to ensure that projects are in the right locations and include the improvements most needed by local people.

8. Please tell us the aspects of the Delivery Plan section that you particularly dislike and why:

Walking issues

The LIP gives no priority to improving the physical condition of local pavements which is disappointing given that they are an essential requirement for this purpose. Uneven and/or narrow and/or cluttered pavements make it unappealing to walk particularly for older or disabled people, or those with children and pushchairs, or with parcels to carry. There are locations where poor management of street trees has made it impractical for many people to use the footpath and this should be addressed.

In delivering the MTS objectives for walking, cycling and public transport the Council should give close attention to the needs of older people across the borough. What a younger person may see as an easy journey can include insurmountable obstacles for the elderly. Furthermore, even the most able bodied may occasionally need vehicles to move large or multiple items.

CPZ issues

We are not comfortable with CPZs being used as a tool to implement Council policies and to raise excess revenue from those who are simply struggling to find on street parking space near where they live. Not everyone who parks on the street is affluent and properties with off-street parking would not be subjected to the same constraints.

Some residents need vehicles to work, not only those who may be employed at some distance from the borough, but also those who provide support services locally. That can include care workers visiting elderly or disabled residents in their own homes and trades people such as plumbers and electricians who provide essential support services. The cost of services to residents is also increased when there is a requirement to pay for parking in a CPZ. Furthermore, car dependency tends to be higher in areas of the borough with lower PTAL ratings.

Poor Integrated Thinking

The MTS does not consider Private Hire Vehicles to be part of “public transport” in spite of their benefits in reducing levels of private car ownership and helping to offer an integrated transport solution, especially in areas with low PTALs.

The draft LIP advises that the Council expects to control car ownership and drive public transport use through supporting car-free developments in high PTAL locations. The Council also seems to indicate support for TfL “re-shaping” the bus network to meet changing patterns of demand. Unfortunately, TfL’s recent consultation about curtailing bus services to Manor Circus suggests there is a disconnect between the Council and TfL on these issues. Reducing the PTAL around Manor Circus would work against the Mayor’s objectives for car free housing while also reducing the public transport experience.

The LIP states that the Council will seek to minimise the impact of the level crossings on pedestrians and cyclists but doesn’t mention working with Network Rail and the train operators to reduce dwell times for motor vehicles. This seems like an odd omission given the significant benefits for reducing congestion and pollution.

The funding submission to TfL (as detailed in Appendix 2) does not appear to be following the current MTS categories.

Cycling

The LIP indicates multiple benefits arising from the recent introduction of dockless bikes, but the evidence raises doubts about Ofo’s operational capability and whether the scheme is viable in the longer term.

There is no discussion about the growing number of electric scooters including whether they should be supported as a part of the local travel mix with rights to use pavements or cycle lanes.

The LIP confirms the Council’s wish for more contra-flow cycle lanes and greater use of filtered permeability, but we would request that these only be implemented having taken full account of local knowledge and support.

ULEZ

The LIP states in several places that the Council supports the expansion of the ULEZ to the South Circular. Previously the Council has pushed for the ULEZ boundary to be located further out and has consistently opposed using the South Circular as the ULEZ boundary because it would bisect the borough, put Townmead dump inside the ULEZ and divert higher polluting vehicles into areas that already struggle with poor air quality. We are opposed to the South Circular becoming the ULEZ boundary and consider that the Mayor is simply taking a cost/benefit decision that requires Richmond to bear the costs without any benefits.

This is The Richmond Society’s response to the Council’s consultation about implementing a borough wide 20mph speed limit. The Society is a civic amenity group representing over 1,200 residents across an area of benefit extending from the Thames in the west to Chalker’s Corner in the east and including Richmond’s town centre and part of the A316.

The Society has promoted the Council’s consultation and associated press releases to its members throughout the process but will not take a position either for or against 20mph limits. We do, however, want to comment on the consultation itself.

General Observations

The relevant element of the consultation consists of only three questions (numbered 3 to 5). Questions 3 and 5 ask respondents for a personal and subjective view and, as such, are reasonable.

Question 4 asks respondents about the extent of their agreement or disagreement that the introduction of a 20mph borough-wide speed limit would:

i. Reduce the incidence and seriousness of road traffic accidents;
ii. Reduce car use by encouraging alternative forms of transport;
iii. Improve air quality.

Quite rightly the Council provides summary evidence to help residents who want to form an objective opinion on these issues. However, it is somewhat disappointing to find that, throughout virtually the entire three month consultation period, the Council only promoted information that tended to endorse 20mph limits. Most residents will be unaware of contradictory evidence, or that some of the Council’s extracts from research and data should have carried a qualification.

The choice of questions was very limited in scope and did not encourage residents to consider whether they might rate alternative solutions more highly to achieve equivalent aims. These could have included targeted interventions (e.g. 20mph outside schools, or by re-engineering accident black spots), or to gauge residents’ support for alternative ways of encouraging modal shift and reducing air pollution. The value of running an expensive consultation becomes questionable if the Council only wants to hold up a mirror that reflects a pre-determined position.

Caveats ought also to be attached to the consultation’s results due to the ability of anyone to submit an anonymous response online and without any apparent control to prevent multiple submissions.

The quality of the consultation results has also been affected by releasing different evidence and reference information during the time that it has been open and at “Community Conversations”. New material provided after the start of the consultation means that respondents had different information on which to base their opinion at different times within the consultation period. This might be unavoidable when important new information emerges but, in this case, it feels more like the consultation was started prematurely – or perhaps that, early responses were slow to arrive or not in line with the expected outcome, and more effort was needed.

In that regard, the report from Public Health dated November 28th was added more than two months after the consultation started and the DfT commissioned report on the effectiveness of 20mph limits (also published in November) was added about a week before the closing date. As possibly the most extensive study of 20mph limits across the country, the DfT report was long awaited and ought logically to be a key reference.

It is of some concern that the first consultation leaflet sent to residents did not specify the costs of the scheme stating only: “There will be no extra charges passed onto residents to pay for this.” Clearly there are costs with any proposal and, if there is to be no extra charge on residents, then funds must inevitably be diverted from other budgets. Later in the process the costs were announced at £0.7m – £1.5m but it remains unclear what other Highways projects must be scaled back (or stopped, or not progressed) to cover this expenditure. Residents’ views about these costs and alternative budget options were not sought. No estimate of the higher costs of maintaining repeater signage, or roundels painted on the road, has been provided.

The council measured speeds across a cross sections of roads to compute an average borough speed of 21.9mph but only released this information after the start of the consultation. We would request that, prior to completing the Cabinet report, the data underlying this computation (i.e. to include the survey dates, the individual roads tested and average speeds recorded) be published alongside other 20mph reference sources. This data can then be considered to represent a base case against which progress in reducing speed and accident rates could be measured in a few years.

Comments on the Component Elements of Section 4

i) Reduce the incidence and seriousness of road traffic accidents

The laws of physics dictate that, because slower speeds allow more reaction time, some accidents may be avoided and that, in the event of a collision, personal injuries and/or property damage are much reduced. It is therefore difficult for respondents to disagree that 20mph would not reduce the incidence and seriousness of accidents making the value of this question somewhat doubtful.

The Council’s initial leaflets, commentary and presentations have reiterated that improving safety is a key objective for introducing 20mph limits across the borough. However, the historical accident statistics used by the Council included TfL and Royal Parks routes although these are not part of the 20mph proposals.

This created a material mis-representation of the safety gains achievable given that, over the last three years, about 25% of KSI accidents and 37% of slight injuries occurred on TfL roads. The latest leaflet hand delivered to residents has compounded this mis-representation by stating that fatal and serious accidents (including TfL routes) have risen by 12% in the borough over the last three years. Although serious accidents on TfL roads are 88% higher in this period and a major contributor to the statistics, the leaflet rather misleadingly concludes that “You can stop this.”

The Atkins report commissioned by the DfT recognises the public’s concern about the lack of police enforcement and is inconclusive about the benefits of 20mph limits on reducing collision rates. It reports that there is tentative evidence to support concerns that lowering the speed limit may increase driver frustration and distraction as evidenced by a significant increase in the proportion of collisions that have been categorised as ‘careless / reckless / in a hurry’.

In this regard it is important to recognise that a borough wide 20mph limit may restrict opportunities to draw drivers’ attention to areas of vulnerability (particularly near schools) where a 20mph sign that currently helps to flag the need for care is removed. Ideally this loss would be offset by installing alternative signage.

If 20mph limits result in modal shift then it must be expected that, perversely, the number of incidents involving cyclists will increase. Headline accident rates may therefore not reduce as desired and with a risk that they include a greater number of vulnerable road users.

ii) Reduce car use by encouraging alternative forms of transport

Throughout essentially all of the consultation period the Council has only promoted a single viewpoint and most respondents do not have the wherewithal to look in detail at the evidence presented.

The Council’s first leaflet stated that “in Bristol, slowing speed limits from 30mph to 20mph contributed to increasing walking and cycling by over 20%.” This disregards the caveat in the UWE’s BRITE report that it is not possible to state with certainty that the 20% modal shift to cycling and walking was related to the introduction of 20 mph.

Anecdotal evidence in Richmond similarly seems to show significant increases in the numbers of people cycling locally since 2012. This has been achieved in the absence of 20mph limits although, because cyclists justifiably prefer lower vehicle speeds, it is impossible to know if uptake might have been higher.

The Atkins report for DfT suggests a net 1% of people cycling more as a consequence of 20mph limits, but that walking and cycling rates are essentially unchanged.

The Council has gone to some lengths to show that 20mph limits should not materially increase car journey times and so, by applying this logic, lower speeds should not of itself cause a driver to abandon their car. This question therefore seems to miss an opportunity to probe drivers about adopting alternative travel modes.

iii) Improve air quality

Most pundits agree that vehicle type and driving style have far more influence on reducing air pollution than lower speeds. Lower levels of braking and acceleration with 20mph limits should reduce particulate pollution, but the evidence linking 20mph to improved air quality remains fairly inconclusive.

Again the Council has presented information selectively. The first Council leaflet highlights the April 2013 research on behalf of Cross River Partnership which found lower emissions by diesels at 20mph. However, this statement has not been qualified by the fact that the same research also found emissions are 8% worse for petrol vehicles.

Conclusion

How this consultation presented its questions and the underlying evidence suggests a desire from the Council to drive responses that would show support for 20mph limits.

Given that 20mph limits has cross party political support locally this consultation seems to have missed a valuable opportunity for collecting feedback from residents that might have better helped the Council with its active travel planning.