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

Twitter: https://twitter.com/Drivers_London

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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

Twitter: https://twitter.com/Drivers_London

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Motorists Fuming and Heathrow Expansion

The SUN newspaper has reported on the concerns of London drivers over the Ultra Low Emission Zone (ULEZ) under the headline “FUMING!”. The article says that London diesel motorists will have to buy a new car or face paying thousands in a new pollution tax – see https://www.thesun.co.uk/motors/8241278/motorists-new-car-pollution-tax/ . The article includes good quotes from me and from Howard Cox, Gareth Bacon and Shaun Bailey.

Interesting to note that TfL previously claimed that the capital cost of extending the ULEZ to the North/South Circular was £38 million. But it seems that TfL Manager Paul Cowperthwaite is now suggesting it could be between £90 million and £130 million. On a cost/benefit analysis that will make it even more uneconomic than was even forecast previously (see our previous articles on that issue). Mr Cowperthwaite’s comments about the alleged air quality crisis and his estimate of what it costs are just figments of his imagination that bear no relation to reality. As I am quoted in the SUN article, “The ULEZ is a giant con to raise more taxes to fix the Mayor’s budget problems”.

A big contributor to air pollution, particularly in west London is from aircraft landing and taking off at Heathrow airport. The airport is planning to increase the number of such aircraft numbers even prior to their proposed construction of a third runway. They plan to do this by using new technology to alternate runway use. This could mean an additional 25,000 flights per year with the associated pressure on the road network as most passengers arrive via vehicles.

It may also mean more aircraft noise affected more London residents as landing and take-off flight paths will change. There will still be no ban on night flights that disturb residents. Will the Mayor and TfL be objecting? I hope so.

See https://afo.heathrowconsultation.com/ for more information and to respond to the public consultation.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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20 Mph Zones Are a Waste of Money, or Worse

The Sun Newspaper has reported on the success, or rather failure, of 20-mph wide area speed limits, to reduce accidents. They have obtained figures from 20 local councils using the Freedom of Information Act where £11 million of taxpayers’ cash was spent on the lower limit. But in some cases, rates of serious accidents (Killed and Serious Injuries – KSIs) have actually gone up they reported.

AA President said that the schemes were a “waste of money”, effectively implying that if the money had been spent on other road safety measures, more lives and serious accidents would have been saved.

Examples the Sun gave were Bath where £804,000 was spent but a 2016 report revealed that the KSI’s went up in 7 out of the 13 zones where speeds were cut, and in Manchester £1.7 million was spent on a heavily criticised scheme while in Hampshire other schemes showed no benefit in terms of accident reduction.

The ABD has of course reported similar problems before including in the City of London where a blanket 20 mph scheme has resulted in more minor injury reports.

20s Plenty founder Rod King called the articles “sloppy journalism” (one also appeared in the Daily Mail on the same subject). 20s Plenty has tried to debunk the reports of a number of local councils on their 20 mph schemes – for example they called the Bath report “biased, lacking in statistical rigour and not meeting several local authority duties on competency and equality”. But anyone who has surveyed all the evidence on such schemes will know that simply putting up signs typically reduces traffic speed by only 1 mph and that can have no significant impact on road casualties. In reality it seems to have the opposite effect in many cases as pedestrians no longer take so much care when crossing the road.

Rod King and 20s Plenty are like all fanatics – they ignore the negative impact of their policies and fail to see the truth. They are blinded in their zeal to reduce speed limits in the false presumption that reducing speeds are the answer to all road safety problems. But cutting road casualties is not as simple as that.

We still await a Government report on a more comprehensive study of 20 mph schemes.

In London, Transport for London (TfL) continue to finance such schemes in local boroughs and must have spent millions to date on them. Another example of unwise policies and reckless expenditure by TfL and Mayor Sadiq Khan, plus his predecessors. It is a great pity that money was not spent on road engineering to improve the safety of roads and junctions.

The Mayor actually wants to impose 20 mph speed limits on many major roads in London under his “Vision Zero” road safety plans. UKIP Transport Spokesperson Jill Seymour has challenged TfL to provide undisputed evidence of the justification for such proposals, as reported in the last national ABD Newsletter (OTR). She said “The authorities have strangled the main roads, and made them the most congested and slowest of any city in Europe. London is a mess when it comes to transport…..the London authorities, led by Sadiq Khan, appear to have a vendetta against personal transport and the car, and do everything they possibly can do to discriminate against it”. That’s definitely the truth of the matter.

Roger Lawson

Sun article here: https://www.thesun.co.uk/news/7253694/20-mph-zones-cause-more-deaths/

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Changes to Congestion Charge – PHVs Targeted To Raise Money

The Mayor of London and TfL have announced proposals to change the Congestion Charge (a.k.a. Tax) so as to raise more money. The main change is that PHVs (minicabs) will no longer be exempt from paying this tax. Uber and other drivers will no doubt be up in arms about this and it will mean their clients pay a lot more.

Another change is that the Ultra Low Emission Discount (ULED) which currently applies to vehicles that emit less than 75g/km of CO2 will need to have zero emission capability by 2019 and by 2021 only electric vehicles will qualify. That means that many of the 20,000 vehicles currently registered for the ULED will need to be changed if the owners wish to continue to qualify for the discount.

A Blatant Lie

What’s the justification for these changes? The consultation announcement says that the Congestion Charge “was a huge success”. It claims a reduction in traffic and a 30% reduction in congestion as well as improvements in air quality since it was introduced. These claims are simply spurious. There was a short-term reduction in some vehicles entering the central zone, but the numbers of taxis, PHVs and buses increased. The result was that congestion soon returned to what it was before the tax was introduced and has since got substantially worse. Neither was there any improvement in air pollution which was never expected to happen and did not. See this web page for the facts: http://www.freedomfordrivers.org/congestion.htm

The claims made by TfL are downright lies. But traffic delays have been increasing which is the justification put forward by TfL for the proposed changes.

Why Should Taxis Be Exempt?

One controversial aspect of the original scheme was that registered taxis (black cabs) and PHVs (private hire vehicles) were exempt from the congestion tax. It was never very clear as to why some vehicles should be exempt while others are not. Why should private car occupants pay the charge while people using other vehicles for similar journeys should not? Even more puzzling is why PHVs are now proposed to be taxed while taxis are not. What is the logic of this? Note that the increase in PHVs due to the popularity of services such as Uber has led to many more vehicles entering central London of late and hence have contributed to congestion significantly in the last couple of years. But will the tax now proposed actually reduce their numbers? That is surely unlikely for the same reason that the congestion charge scheme did not reduce congestion. The unsatisfied public demand is such as to soon soak up the capacity released by people unwilling to pay the tax. You cannot solve congestion via taxation!

It’s About Money

The conclusion must be that these proposals are more about raising money for the Budget of Mayor Sadiq Khan. He desperately needs it. See previous blog posts for coverage of that topic.

A Timely Announcement

One might ask why the Mayor chose to announce these changes on a Friday lunchtime when the news channels will be dominated by the Brexit decisions and the England World Cup match for the next 48 hours. This might enable him to escape the opprobrium of PHV drivers for a few hours but not much longer I suggest.

More Information

See this web page for more information and to respond to an on-line consultation: https://consultations.tfl.gov.uk/policy/private-hire-charge-exemption/?cid=ccyourviews

You may also wish to tell us how the ABD should respond to the consultation as we will certainly be doing so.

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The Cost of Khan

Gareth Bacon, leader of the GLA Conservatives, has published a very interesting document entitled “The Cost of Khan”. It supplies a half-term report on the regime of Mayor Sadiq Khan and the negative impact he has had in certain areas (crime, planning, parking, housebuilding for example). In essence he suggests one of the key problems is financial mismanagement.

Of particular interest to our readers will be his comments on the activities of TfL (Transport for London) and the budget for that organisation. It covers:

  • Cancellation of new tube trains for the Jubilee and Northern Lines that would have provided much needed extra capacity. That might have saved £600 from the TfL budget but that’s desperately needed after Khan’s expensive promise to freeze public transport fares which cost at least £640 million in foregone revenue. Even that promise was only partly kept.
  • The pay of executive staff in TfL. The number who are paid more than £100,000 p.a. increased by 25% last year so there were 576 such employees. Is the Mayor really cutting the flab out of TfL budgets as he promised to do?
  •  The “T-Charge” which was introduced last October and will cost Londoners £23 million a year despite the Mayor’s own Impact Assessment saying it will have only a negligible impact on pollution (and that has been borne out by real data since).
  •  Nominee passes which you may not be aware of are highlighted. These allow TfL employees to nominate family members and anyone who resides in the same household to obtain free travel. Even flatmates qualify! There are 39,884 people who are nominees and the cost might be equivalent to £32 million in lost revenue per year.

Those and other reports show how the Mayor has been so wasteful of financial resources with the result that he is desperate to raise money from the T-Charge and the ULEZ charge which will impose major unnecessary costs on Londoners. In the personal view of this writer TfL continues to be a massive and very expensive bureaucracy which is unaccountable to the public. It formulates transport policy that will increase the bureaucracy and then does public consultations designed to get the right answers. TfL needs major reform but the Mayor does not seem to have it under control.

The “Cost of Khan” Report is present here: https://www.glaconservatives.co.uk/uploads/1/1/7/8/117899427/final_cost_of_khan__2_.pdf

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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Press Release: The Real Reason for the ULEZ – It’s About Money

The Alliance of British Drivers (ABD) has said before that we are suspicious about the reasons given for the Ultra Low Emission Zone (ULEZ) in London. The proposed measures, particularly the extension to within the North/South Circular, seemed disproportionate to the likely benefits from reductions in air pollution. This is particularly so, bearing in mind that emissions from vehicles are rapidly falling, as newer vehicles replace older ones.

Now we know the truth!

In April 2017 we asked for information on the financial budgets for the ULEZ – the likely costs and income the Mayor would get. The request was refused and we eventually had to appeal to the Information Commissioner’s Office (ICO). We have now received the requested data following a judgement in our favour. These are the figures received from Transport for London (TfL):

  • Implementation costs: £38.4 million.
  • Operating income and costs:
  • Impact of introduction of ULEZ on income (£m) over 5 years 2017/18 to 2021/22 inclusive. (+ve is net increase in income): £55.3 million.
  • Impact of introduction of ULEZ on costs (£m) over 5 years 2017/18 to 2021/22 inclusive. (-ve is net increase in costs): -£12.7 million.

But these figures make absolutely no sense as against the figures we have calculated for operating income based on data provided in the ULEZ consultation documents. For example we estimate income over five years as being £313.6 million rather than £55.3 million.

In reality TfL may be making a profit over five years of £300.9 million for a capital investment of £38.4 million. At a stroke Sadiq Khan will solve his budget problems with the ULEZ implemented.

The Mayor has great financial difficulties, as is apparent from his recently published budget for the next few years, where he begs for more financial support from central Government. But he surely will not need their support with this scheme in place, even though he does not have the funds to do it without more borrowing.

Just like the central London Congestion Charge (a.k.a. Tax), where charges were later raised (more than doubled), thus making it a very profitable for TfL, once the infrastructure, such as cameras are in place for the ULEZ, charges can then be raised. The scheme can also be extended way past when traffic air pollution ceases to be a problem, thus potentially introducing more general road pricing.

Will the health benefits outweigh the costs of the scheme to Londoners? The answer is no because they are only valued at £7.1 million over 5 years. This duplicity in justifying the ULEZ on health grounds, which few are likely to oppose, when the real reason may be to fund his empire, is surely typical of Mayor Sadiq Khan’s approach to politics and democracy. Who does not want cleaner air? But there are lots of ways to improve air quality from transport and other sources, without imposing such enormous costs on road users.

To remind readers, the ULEZ charge for non-compliant cars will be £12.50, imposed 24/7, and enormous numbers of people will need to buy new cars to avoid this cost.

Readers should make sure they oppose the extension of the ULEZ by responding to this public consultation before the 28th February: https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3b/?cid=airquality-consultation

More Information 

Our full analysis of the costs and benefits of the ULEZ are contained in this document: http://www.freedomfordrivers.org/Cost-of-the-ULEZ.pdf

The ULEZ proposals are part of the Mayor’s Transport Strategy which the ABD is vigorously campaigning against – see this web page for more information: http://www.freedomfordrivers.org/against-mts.htm

The unnecessary delays and obstruction by TfL in responding to the ABD’s reasonable request for information on ULEZ costs is documented in this blog post: https://abdlondon.wordpress.com/2018/01/09/press-release-tfl-forced-to-disclose-ulez-costs/

Our views on the ULEZ proposals and how the Mayor is scaring Londoner’s unnecessarily about air pollution and health are documented here: https://abdlondon.wordpress.com/2017/11/30/panicking-londoners-consultation-on-ulez-extension/

For more information on this issue, contact Roger Lawson on 020-8295-0378.