ABD Response to Mayor’s Transport Strategy

The Alliance of British Drivers has published its formal response to the public consultation on the Mayor’s Transport Strategy (MTS).

The Mayor’s proposals are completely distorted because he does not seem to understand what roads are for. This is our answer to the first question posed in the consultation: “It states on page 11 that “London’s streets should be for active travel and social interaction….”. This is nonsense. Streets are built and maintained at great public expense to provide an efficient and cost effective transport system for people and goods. If people need exercise, or social interaction, there are many other ways they can obtain that without taking up scarce road space. The priority should be on providing a transport network in London that meets the business needs and preferences of the public. It should not be distorted to meet other objectives.”

The full document is present here: ABD-Response. It’s well worth reading.

The MTS has a very heavy emphasis on environmental issues and one useful contribution on the debate about air pollution in London and how to tackle it has recently been published by the GLA Conservatives. It is present here: Clearing-the-Air . It shows there are good alternatives to the Mayor’s proposals which would not put such a heavy financial burden on London’s residents and businesses.

You can already see the impact of some of the Mayor’s policies in the news from TfL that license fees for Uber to operate in London will rise from £3,000 to £3 million for a 5-year license!

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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What Has the Mayor Got To Hide?

N.B. For more information on the Mayor’s drastic proposals in his transport strategy and an easy means of objecting to them, please visit www.cantpaywontpay.london

The national ABD has issued the following press release on this subject:

In June, London Mayor Sadiq Khan opened a crucial consultation that will decide the future of transport in London. The Alliance of British Drivers (ABD) has spoken to several members of the public and found that hardly anyone was aware of it. Some felt that it had been seriously under-publicised.

There have been occasional tube station posters, but they are very bland, mentioning housing and employment but not the quite drastic policies planned for drivers. For instance, the Mayor’s Transport Strategy threatens the extension of the Congestion Charge across Greater London and new taxes to force drivers out of their cars.

Congestion charging spokesman Brian Mooney asks: “What has the Mayor got to hide?

He amazingly claims that drivers pay too little to use the roads and they are subsidised by public transport users. Our research provides evidence to the contrary – that drivers pay four to five times over to use the roads and our taxes in fact subsidise public transport. The Mayor’s office was challenged to provide some evidence via a Freedom of Information Request, but could produce none.” [1] [2] [3] [4]

If he thinks that the overtaxed driving public will support him forcing us to pay even more – or worse still depriving us of using the roads we’ve paid for – then he should at least be upfront with us over his plans.

It would be quite unacceptable if he takes silence as approval for his uncosted proposals  – or even a blank cheque. Particularly as he was elected on a promise not to extend the Congestion Charge. [5]

I challenge the Mayor to appear on a mainstream phone-in with me to face the public over this important issue. This should be within the next three weeks to meet the consultation deadline.” [6] [ENDS]

Notes for Editors

[1] The claim is on p265 of the Mayor’s Transport Strategy consultation draft. “…the fundamentally inadequate and unfair way in which road use is paid for in London, with motorists paying too little, and in effect being subsidised by public transport fare payers.” https://www.london.gov.uk/what-we-do/transport/our-vision-transport/ draft-mayors-transport-strategy-2017   Evidence to the contrary illustrating the net tax paid by drivers is on http://www.fairdealforthemotorist.org.uk/2017mts4.htm#_FOOTNOTE

[2] FOI request: MGLA280717-2452, correspondence available on request.  Failure to respond properly breaches both GLA and wider Local Government standards. “The Mayor is determined that the GLA leads the way in openness and transparency.” https://www.london.gov.uk/about-us/governance-and-spending/sharing-our-information/openness-and-transparency https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/522205/Local_government_transparency_code_FAQ.pdf

[3] ABD London Chairman Roger Lawson has experienced similar evasion from Mayor Khan’s aides at Transport for London. Roger asked for basic financial information on the costs and benefits of the ULEZ proposals, but no budgets or estimates of the costs have been provided (FOI Request Ref: FOI-0071-1718) – it is currently subject to a complaint to the Information Commissioner but the delays alone have frustrated democracy.

[4] There is other evidence that the Mayor’s MTS consultation does not meet legal expectations. Cabinet Office consultation guidelines include: “Consultations should provide sufficient information to ensure the process is fair.” https://www.gov.uk/government/publications/consultation-principles-guidance  https://www.gov.uk/government/uploads/system/uploads/attachment_data /file/255180/Consultation-Principles-Oct-2013.pdf  The Supreme Court ruled in 2014 “The demands of fairness are likely to be higher when the consultation relates to a decision which is likely to deprive someone of an existing benefit.” (UKSC56, Haringey v Moseley) https://www.supremecourt.uk/cases/search-results.html?q=Moseley%20v%20Haringey  In a more recent case, Justice Patterson reiterated the principles upheld by the Supreme Court case that a consultation will be fair if it: 1. communicates the public authority’s proposal to those with a potential interest; 2. explains why that proposal is being considered; 3. provides the consultees with sufficient information to make informed responses to the proposals. (R (Angharad Morris and Donna Thomas) v Rhondda Cynon Taf County Borough Council [2015] EWHC 1403 (Admin)) http://www.burges-salmon.com/practices/disputes_and_litigation/publications/public_consultation_does_not _necessarily_need_to_set_out_alternative_options_moseley_revisited.pdf

[5] The 300 page MTS document fails to give proper ballpark figures for what will certainly be the large sums of money Mayor Khan plans to take from those who can currently afford to drive in London or the substantial cost of implementing his schemes. Sadiq Khan’s 2016 manifesto promised (p36) “to maintain the Congestion Charge at its current level”. http://www.sadiq.london/a_manifesto_for_all_londoners  The MTS threatens a range of punishing measures including: – Extending the Congestion Charge (road pricing) London-wide, with drivers being charged to use local roads – New and higher motoring taxes to stop drivers using our cars – A ‘workplace parking levy’ – a tax on going to work – Reduction in the availability of parking – Measures to remove road space from drivers who’ve paid for it – Gratuitous ‘car-free days’, road closures and speed restrictions www.cantpaywontpay.london

[6] This offer is specifically aimed at the Mayor, not an underling or lobbyist substitute, as he made his promise in a personal manifesto. The timescale would be between now and 20 September to allow listeners adequate time to respond to the consultation which concludes on 2 October. Brian Mooney is due to be away in late September. Mainstream phone-ins would be on recognised London radio stations like LBC or TalkRadio, between the hours of 7am and 10pm, and at reasonable (at least 24 hours’) notice. The offer is made by Brian Mooney.

Forcing Implementation of the Mayor’s Transport Strategy

An article in the latest edition of Local Transport Today (LTT) made interesting reading. It reported on how London boroughs will be in the “frontline to deliver Khan’s traffic reduction goal”.

As readers may be aware, local boroughs in London have control over local roads, but they have to produce a “Local Implementation Plan” (LIP) to show how they are going to follow the Mayor’s Transport Plan (see http://www.freedomfordrivers.org/against-mts.htm if you are not yet clear how damaging it could be). Each borough has to submit their LIPs by October 2018 at the latest and they have to be approved by Transport for London (TfL).

The boroughs have been issued with guidance on how to write their LIP, and Valerie Shawcross, Deputy Mayor for Transport has said in the foreword that “Traffic reduction should be a central theme of borough LIPs, with the aim of creating pleasant places for residents of every part of the city. This means providing alternatives to car use, discouraging unnecessary trips, looking at how street space is used most efficiently, supporting car-free lifestyles, and taking action to reduce and re-time freight trips.”

Now we all know what “discouraging unnecessary trips” implies. It means that journeys that you consider worth taking may not be by some bureaucrat in TfL. In other words, your freedom to choose when and how you travel are going to be constrained if the Mayor has his way. And comments such as “looking at how street space is used” surely suggests it could be reallocated as we have seen so much of in the last few years in central London – road space reallocated to cyclists and pedestrians from vehicles.

Most funding for new transport schemes in local boroughs are funded by TfL because they have the tax resources and central Government funding while local boroughs have very small transport budgets from their own cash resources. Such funding from TfL has historically been focussed on certain “streams” that they consider priorities, although there was some local discretionary funding.

This is what it says for example in the Interim Guidance from TfL: “In line with the Healthy Streets Approach, a new Liveable Neighbourhoods programme will replace the LIP Major Schemes programme to deliver transformational improvements in walking and cycling provision, road safety and road danger reduction and mode shift from private car use”.  

There will also be more money for bus priority measures (i.e. bus lanes), cycling and air quality programmes. In addition, the LIP guidance suggests that TfL will be working more closely than in the past in preparation of the LIPs. Does that mean they are going to provide more support, or simply want to ensure they toe the line? If you are in any doubt, it also suggests that TfL will be providing more services to deliver major projects within boroughs – and that includes design and traffic modelling or even “construction oversight”.

It would appear that there will be even more interference in local boroughs in local traffic and road safety schemes by TfL than ever before. This is despite the fact that TfL do not have the local knowledge that is required to develop good schemes – even local boroughs often do not know as much as local residents about road network issues.

Will there be resistance from local boroughs to these plans? Perhaps. But it shows why it is so important to get the proposals in the Mayor’s Transport Strategy kicked into the long grass. TfL continue to wish to impose a centralised, dictatorial manifesto on local boroughs and take even more control over their activities and funding. This writer thinks it should be opposed.

Roger Lawson

Mayor’s Transport Strategy – An Attack on Private Transport with Dubious Economics

London Mayor Sadiq Khan published his draft Transport Strategy (MTS) on the 21st June. We gave some initial comments previously but we have now published a more detailed analysis – see below.

Here’s a brief summary:

The Mayor is concerned about “car dependency”, an emotive phrase used to describe people’s preference for private vehicle transport in some circumstances. He plans to fix that by making the use of cars more and more difficult over the next few years. 

He is also going to fix our health problem (he claims) by getting people out of their cars and walking or cycling instead. Or if they can’t do that, by getting them to use public transport even though he admits that underground and surface rail is often grossly overcrowded and cannot be fixed in the short term. Or of course you can travel by bus even though bus ridership has been falling as it is slow and unreliable (and getting worse).

The Mayor even suggests that the elderly and disabled are too dependent on car use, so they will have to face the same treatment.

Even Private Hire Vehicles (PHVs) are subject to attack on the basis that they have made congestion worse due to their increase. The Mayor proposes to limit their numbers, and/or remove their exemption from the Congestion Charge.

As in the Livingstone era, we now have a Mayor who clearly hates cars – even zero emission ones. His target is to reduce car use and increase public transport use (the latter is currently 64% of all journeys in London, but his target is 80%). Indeed, if you are not using public transport he will be encouraging you to walk or cycle. And there will be more vehicle free zones and car-free days.

To further restrict car use, parking provision will be restricted in new developments or even be “car-free”. Yes we could be back to the regime where inadequate parking provision in new housing developments creates excessive on-street parking. In addition, access to kerb space (on street parking including permit parking) may be restricted or usage discouraged by pricing.

There is a target of a zero-emission transport system by 2050. But he wants to have zero emission zones in central London and the suburban town centres by 2025. This means that unless you have an electric vehicle, it may be prohibitively expensive to drive around much of London in just a few years’ time. That’s much sooner than the vehicle population will change.

Pay-per-mile road pricing (as recently advocated by the EU) will be considered. Effectively replacing and extending the current “Congestion Tax” and emission taxes such as the ULEZ. He will also allow local boroughs (there are 32 in London) to introduce congestion charging schemes so we could end up with a horrendous patchwork of restricted zones. The Mayor repeats the claim that the Congestion Charge was a success in reducing congestion which is simply wrong – as the ABD has repeatedly said. The evidence is here: http://www.freedomfordrivers.org/Congestion.htm.

How much will a new system cost and why will it reduce congestion are surely the questions to ask.

There will be more “bus priority measures” to improve bus journey times and reliability – that means more bus lanes. But the Mayor seems not to recognise that bus lanes are already present on most key routes and are an inefficient use of valuable road space.

What is the cost of the proposed strategy? The Mayor does not say, but it will be clearly very expensive. Transport for London (TfL) have been evading even answering simple questions on the finances of the ULEZ scheme, and there is no cost/benefit analysis provided on the Mayor’s latest proposals, as with so many recent TfL schemes.

The Mayor even goes so far as to claim in the MTS document that public transport fare payers subsidise motorists. This is simply a lie. It is both inaccurate and grossly misleading. Public transport fare payers do not subsidise anyone.

They are subsidised themselves from local and national taxation. Motorists pay much more in taxes than is spent on the provision of roads. On a national basis, and in London, they subsidise public transport users, not the other way around.

It is very obvious from the contents of the MTS and the result of past promises by the Mayor (partly to help get elected no doubt) that TfL faces major budget problems. The Mayor proposes how to fix that though. He is asking for:

  • Revenue raising powers. (Note: the Congestion Charge and ULEZ proposals are not technically revenue raising regulations even though they have turned into a tax on motorists. In practice they have been distorted to perform that function). The Mayor is asking for more powers to raise tax than they alone provide.
  • A development rights auction model on major infrastructure projects. This expands the ability to obtain funding from developers (at present only covered by Section 106 agreements).
  • In addition, he is asking that revenue from Vehicle Excise Duty (VED) be “devolved to TfL”. That would include “powers to change how VED is levied” which means the Mayor could set the charge rate for London residents presumably, or charge it in a different way to an annual fee, i.e. based on a new road pricing model. 

Needless to point out that these proposals would give the Mayor the ability to build a financial empire and dictate the lives of Londoners much more extensively than at present. Such wide ranging and sweeping financial powers for someone who, once elected, has dictatorial powers is surely inappropriate.

However one looks at this, the financial plans to underpin the MTS look likely to be very dubious indeed. That hole can only be fixed by more taxation on Londoners as it seems unlikely central Government would wish to help.

Many of the London’s transport problems are being caused by the rapid growth in population, which the Mayor is happy to let continue – indeed to promote. But such growth increases air pollution.

MTS GraphicIt is interesting to look at the graphics that accompany the words of the Mayor’s vision (see example above). Barely a private car in sight, and no LGVs, with roads just full of cyclists and buses. And no congestion of course which we all know is totally unrealistic bearing in mind the projected population growth.

He expects more people to move to public transport when he concedes 71% of London Underground will be overcrowded in future in the rush hour and national rail and buses will not be much better, unless action is taken. The document reports that there is already severe overcrowding on some tube lines, as users know.

As usual, the advocates of public transport simply ignore the unpleasantness and overcrowding of public transport even though the Mayor concedes that is a problem. Anyone who has travelled on it in London in the recent hot weather will know just how obnoxious it is. Until air-conditioning, larger seats and capacity to avoid standing is provided (an impossible dream cost-wise of course), I for one will be ignoring the Mayor’s exhortations unless they are unavoidable.

In summary, the Mayor’s Transport Strategy contains not only a number of glaring defects, but is yet another missed opportunity to develop an integrated transport strategy. London has needed an improved road transport network for many years, but there is nothing in the document to support that. It is mainly about attacks on private vehicle owners and users (including PHVs).

This is of course a common approach by Mayors, and their advisory staff in TfL, who live and work in central London. They simply do not understand the problems faced by residents of the outer London boroughs.

The Mayor also seems keen to bully us into living a healthier life style. But that should be a matter of personal choice and it is not at all obvious how moving people onto overcrowded public transport will significantly assist. To get Londoners to be more active should be more about education than dictatorship. The freedom of individuals to choose their transport mode should not be constrained.

The ABD’s full analysis of the MTS is present here:

http://www.freedomfordrivers.org/Analysis-of-Mayors-Transport-Strategy.pdf

Make sure you respond to the public consultation here:

https://www.london.gov.uk/what-we-do/transport/our-vision-transport/draft-mayors-transport-strategy-2017

Roger Lawson

Travel in London – It’s Certainly Changing

A report that should be essential reading for everyone who has to travel around the London metropolis has recently been published by Transport for London (TfL). It’s called “Travel in London – Report 8). It shows how transport in London has been changing, partly as a result of the growth in population, partly from attempts to encourage cycling and “modal shift” in general and the impact of a buoyant economy. Here’s a brief summary of the contents, with some comments.

The population of London grew to a record 8.6 million people in 2015, the highest point since 1939. In 2014 total trips rose to 26.6 million in the average day – that’s 8% more than in 2008, and 2% more than the previous year. In other words, travel has been showing strong growth in London.

There is however a trend for falling private car use, but rising use of public transport and more cycling and walking. As it says “a feat unprecedented in any major city“, driven by “consistent policies”. The population of London is expected to continue to grow rapidly, but will feature more older people.

About half of all bus journeys in England are now made in London – an unbelievable figure which demonstrates just how much they are subsidised. But bus patronage has levelled off in recent years because of “a similar trend in service supply”, i.e. fewer buses are being run as subsidies have been slightly reduced so the consumption falls to put it in plain English.

London Underground, DLR and Overground rail services likewise show strong growth with more capacity on these lines supporting the growth.

Road traffic has fallen for much of the last decade, but has increased in the last two years. For example traffic volumes were up by 3.4% in central London in the most recent year, and 1.9% in outer London. This is thought to reflect population growth and economic trends, but the increase in traffic has brought pressure to bear as congestion rises from reduced road space and other causes. As the document says: “….effective network capacity for general traffic continued to be reallocated to other MTS (Mayors Transport Strategy) priorities“.  I think they mean changes to accommodate more cyclists, more bus lanes, removal of gyratories in the name of road safety and similar such measures. There was a sharp 13% increase in average traffic delay in 2014 according to the report, which won’t surprise anyone who has to drive in London – and that does not even reflect the changes made since the start of 2015.

The number of licensed taxis has remained stable, but the number of private hire vehicles (minicabs) has risen sharply – up by 19% in the latest year alone. That has had a significant impact on traffic congestion of course.

Cycling levels rose by 10.3% between 2013 and 2014, and walking has risen but only by the same trend as population growth. There could be more people commuting into central London by bike than by car soon, but that change is much less noticeable in the outer London boroughs.

There are positive trends in CO2, PM10 and NOX emissions (a lot of which come from transport vehicles) reflecting initiatives to improve local air quality.

Comment: this report shows the impact that Boris Johnson’s policies have been having on transport in London. Basically more people cycling, with cars discouraged by reductions in road capacity. Cycling has also been encouraged by sharp increases in public transport fares which have been rising faster than inflation making it one of the most expensive cities in the world for public transport – unless of course you are one of those who hold a Freedom pass where your travel is subsidised by the rest of the population for reasons which this writer finds difficult to understand. Originally introduced by the Greater London Council in 1973, it has remained a financial millstone around the necks of London boroughs even though the GLA was subsequently abolished by Margaret Thatcher.

Encouraging more cycling has had some unintended consequences because it is one of the less safe modes of transport, particularly when you get a lot of new, inexperienced cyclists on the roads or those who like to “pedal furiously” as is now a frequent sight on the roads of London. The end result is demands for more measures to improve the safety of cyclists, which can be very expensive.

Are all these changes of benefit? You might not think so if you are one of those increasing numbers of older people who are not able or willing to cycle. It seems unfortunate that Londoners have never really been asked what they would like as public consultations on these matters have been low key and certainly the cost/benefit of all these changes have never been spelled out. But it seems unlikely that this will be a debating topic for the competing Mayoral candidates.

Roger Lawson