TfL Consultations and How to Influence Them

It has been apparent for some time that when Transport for London (TfL) undertake a public consultation they get many responses from cyclists and public transport users, but few from other road users. The result is that the ensuing consultation report shows a very biased picture of the views of the general public.

Why is this? It’s because TfL prompt responses by sending out emails. For example they sent out over 400,000 emails about the Hackney Cycleway proposals (described here: https://tinyurl.com/y6fxezmq ).

How did people get on their email contact list for this consultation? From an FOI Act request I can give you the answer. Some 81 people were bespoke to the consultation and were selected from “TfL’s Local Communities and Partnership” team. Another 4,875 came from statutory consultees (police, fire service, etc) and others who asked to be kept informed on TfL consultations. But the vast majority (473,210 to be exact) came from their Customer Database. That means everyone no doubt who has an Oyster Card or Freedom Pass or has opted to receive TfL travel information. So you can see why the result of the public consultations is biased towards public transport users.

How can private car users, taxi users, PHV users or LGV/HGV users influence the consultations? All you need to do is register to receive consultations by signing up on this web page: https://consultations.tfl.gov.uk/sign-up/0f3971fe/ . In addition you can sign up here for news updates: https://tfl.gov.uk/travel-information/social-media-and-email-updates/email-updates .

Adding your name to both those lists should ensure that you get information on new consultations and enable you to have your say. MAKE SURE YOU SIGN UP NOW!

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Consultations in Name Only and “Safer Speeds”

I covered the issue of Transport for London (TfL) doing public consultations that do not provide enough information and are already decided in a previous note (see https://abdlondon.wordpress.com/2019/06/24/consultations-in-name-only/#comments ).

Subsequently I used the Freedom of Information Act to ask TfL for their consultation policy documents and guidelines, plus information on the costs and any cost/benefit analysis of the “Safer Speeds for London” proposals. That’s the proposal which will slow traffic to 20 mph on many major London roads and where there was a short (now closed) public consultation which did not contain evidence for justification.

TfL has supplied the information on their consultation policies and procedures and if anyone would like a copy, please let me know. In Principle 3 of the TfL Consultation Policy it says “We must provide consultees with enough information to understand what we are proposing so that they can respond on an informed basis”. That was certainly not done on the Safer Speeds proposal.

As regards my request for costs and cost/benefit data on the Safer Speeds proposal, TfL rejected my request on the basis that it is exempt information because the information requested “is intended for future publication” – see Section 22 of the FOI Act, and that it was not justified in the public interest. What is the point in publishing that information after the public consultation has ended? It looks like a simple attempt to avoid answering, or are they saying that they have not looked at the costs and costs/benefit before putting forward the Safer Speeds proposal? Either way, it is unreasonable so I am appealing.

This is of course the typical run around one gets with TfL when they don’t wish to disclose information. TfL are a secretive organisation that likes to develop proposals and present them as a fait-accompli with only public consultation on trivia. It has been that way ever since Ken Livingstone was in charge. It surely needs to change!

But according to a report in Local Transport Today (LTT) TfL is heading in the opposite direction. The report said that TfL is changing the way it engages and consults on active travel schemes. There will be “a greater emphasis on local engagement either in advance of, or potentially instead of, formal consultation”. It is suggested that to get the 73 safety critical road junctions in London improved they need to push through with projects and the public “has a limited ability to influence our proposals” – so there is no point in statutory consultations. But It also suggests road users will have less opportunity to comment, and of course a non-statutory consultation leaves little ability to mount a legal challenge.

Roger Lawson

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Consultations in Name Only

Recent public consultations by Transport for London (TfL) have typically omitted any costs, or cost/benefit information, about the proposed schemes. For example on the “Safer Speeds” proposals for many more 20 mph speed limits in London, or Cycleway schemes. Nor do they ask a simple question as to whether people support the proposals overall or not.

I complained about those omissions in the ABD’s response to TfL and got a note back from Esme Yuill (Lead Consultation and Project Communications) which contained much waffle but did say “consultation is not usually about the principle of a project, but the proposed design”. In other words, the consultation is usually based on the project being a fait accompli and TfL have already decided to push ahead with it. That is not a consultation in the usual sense of the word, and clearly undermines the democratic principle that consultations should not assume pre-conceived notions.

Indeed this approach is contradictory to that laid down by the Government in their Consultation Principles where it says: “Consult about policies or implementation plans when the development of the policies or plans is at a formative stage”. See https://tinyurl.com/ycb3mwvk

That document also says: “Give enough information to ensure that those consulted understand the issues and can give informed responses. Include validated impact assessments of the costs and benefits of the options being considered when possible…..”. Neither of the recent consultations I referred to in my complaint (the “Safe Speeds for Central London” and the “Wood Lane/Notting Hill Gate” schemes) contained any costs or cost/benefit analysis and that has been a consistent omission in recent TfL consultations.

TfL has been one of the most impervious and undemocratic bodies since it was set up by Ken Livingstone. They do not listen to anyone. Indeed was it not Ken Livingstone who said “Consultation is a good thing when people agree with you, and a waste of time when people don’t agree with you” and TfL are clearly still following that principle. By avoiding consulting on the key questions as to whether projects should be done at all, and not informing respondents on the costs and cost/benefits, they are avoiding any meaningful consultation.

Is that the way that you think the body that runs transport in London and has one of the biggest budgets in the world should run consultations? I do not and I will be pursuing this matter.

Roger Lawson

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