Submission by the Planning Committee of the Chelsea Society
29th September 2017
THE BIG PICTURE
In this 151-page document the Mayor of London sets out his proposals for enabling people to move around safely and conveniently in London in the foreseeable future. The document contains many proposals with which we would agree, but the challenge will be overwhelming if the number of people living in London, working in London, and visiting London, continues to increase as rapidly as in recent years.
Essentially anyone in the United Kingdom, or indeed almost anyone in the world, who wishes to come to London may do so. This is a national issue, and the Mayor has no power to control it, but there is no need to spend public money on encouraging people to come to London. Far too much of the wealth, population, and economic activity of the United Kingdom is already concentrated in London, and more of it needs to be distributed to other parts of the country.
The Mayor says; “Growth is good for London, and it is important that all of the city’s current and future residents feel its benefits.”
“New public transport services will be vital in creating the 1.2 million new jobs and more than 1 million new homes the city needs by 2041.”
“Making streets work for people will provide huge economic benefits not only through revitalising town centres and attracting business to London.”
Growth is not necessarily good for London, and increasing pressure on transport, housing density, education, water supply, sewerage and all other public services and on the environment, makes it almost impossible to improve, or even maintain, the quality of life for Londoners. Construction and demolition works to provide for an increasing population have themselves a major impact on quality of life.
London is already the largest city in Europe, and we question whether it needs more people.
TRAFFIC CONGESTION AND AIR QUALITY
Congestion is a problem in itself, as more and more time and money is wasted as people try to move around London, but congested traffic is also the cause of massive air pollution and waste of fossil-fuels, as thousands of engines are running with vehicles going nowhere. The Mayor believes that lowering speeds is fundamental to reducing road danger, but the problem in central London is that average speeds in many places are not much higher today than when cars had to have a man walking in front with a red flag.
Poor air-quality is linked to around 9,400 deaths per year in London, and air-pollution causes more than twice as many deaths as road traffic accidents. Two pollutants of particular concern are nitrogen oxide, which aggravates symptoms in asthmatics, causes inflammation of the airways, and reduces lung development and function; and particulate matter (PM) which contributes to the risk of cardiovascular and respiratory diseases such as lung cancer. There is also evidence that exposure to traffic fumes contributes to dementia.
For many years, the Royal Borough of Kensington & Chelsea (RBKC) has experienced high levels of NOx and PM. The “Understanding the Health Impacts of Air Pollution in London” report (King’s College, 2015) estimated that in 2010, 8.3% of early deaths in the Borough were attributable to fine particulate air-pollution (PM2.5) along with a further 16.6% of early deaths attributable to NOx. This figure is the highest in London together with Westminster. The impact on children is of particular concern as there are a number of schools close to roads where pupils are exposed to high concentrations of NOx and PM.
Often vehicles do not achieve the test specifications for emissions, because actual drive-cycles are different from test-cycles. We share the concerns of the Council of RBKC about real-world diesel emissions of Euro 6 vehicles in light of findings on Euro 4 and 5 vehicles, and we propose that the ULEZ standards and all other measures should be reviewed regularly to take into account actual emissions.
Traffic congestion causes far more pollution than allowing vehicles to make optimal progress at reasonable cruising speeds. Improving junctions is crucial, and parking off the highway is also an important aim. Given London’s road system congestion will only be reduced with fewer vehicles on the roads at peak times. With regard to road humps, there is evidence that by forcing drivers to slow down before speeding up again, road humps cause vehicles to produce a greater amount of harmful emissions from their engines, and particulate matter from their brakes.
The more that vehicles have to slow down and speed up, and stand in traffic, the worse the emissions performance is likely to be. Older vehicles do not have cut-outs at traffic lights and other stops, and these are matters which newer vehicles and operating methods can help address.
Most of the air-pollution in central London is caused by exhaust from motor vehicles, and in particular from buses, taxis, and delivery vehicles. Three major east-west roads run through Chelsea – the Embankment, the King’s Road and the Fulham Road, and they are often heavily congested, producing high levels of pollution from stationary and slow-moving vehicles. The BBC website identified the King’s Road as one of the most polluted streets in London based on 2016 figures.
Congestion (and consequent pollution) is also a problem in localised areas such as the north end of Sloane Street at its junction with Knightsbridge, and we are seeking measures with RBKC, TfL, and other stakeholders to improve these. It is essential that improved traffic management schemes are introduced to keep the traffic moving, and the hours during which commercial vehicles can make deliveries in busy streets should be restricted. We note that there are proposals to relocate the long-distance coach terminal from Victoria to outer-London, which should reduce air-pollution in Chelsea, and we support the Mayor’s intention to identify and deliver replacement facilities for Victoria Coach Station through the provision of one or more hubs.
Effective action to clean up the air, requires replacement of a lot of older technology in buses, trucks, vans, trains, and cars, which will also cut running costs and demand for fossil-fuels. Better scrappage and financing schemes, instead of working up a new series of penalties for owners of older diesel cars, would provide a range of incentives to tackle the problem in a broad-based way, removing the oldest buses, lorries, cars and boilers would do the most to improve the situation.
Much of the traffic we have to endure in central London is not local private-car use but vehicles in transit. We believe nevertheless that RBKC should progressively increase the cost of residents’ parking permits for vehicles with large capacity engines and/or for households wanting more than one permit. RBKC has sought to remove car-club permit eligibility for diesel cars in order to incentivise car club operators to move to cleaner fleets. They have also introduced a campaign against drivers who run their engines while parked, but this needs to be better enforced.
The Mayor has proposed an Ultra-low Emissions Zone whose western boundary is Grosvenor Place and Park Lane, but we consider that an expansion of the ULEZ to include RBKC will be necessary in order to deliver a significant reduction of air-pollution in Chelsea from motor vehicles. We would like to see this implemented by 2019 instead of 2020. Measures need to be devised to prevent non-compliant heavy-goods-vehicles (especially from abroad whose drivers may not be familiar with the restrictions) entering the zone.
We agree that sufficient and appropriate charging and refuelling infrastructure should be put in place to support the transition from diesel and petrol-powered vehicles to ULEVs, including ensuring that London’s energy-generating and supply system can accommodate and manage the increased demand associated with this transition. Incentives should certainly be given to use electric and hybrid vehicles, but consumers also need to be protected from excessive costs for the vehicles and for the use of battery- charging points. RBKC is already planning for charging points in the Borough.
Major pollution is caused by dust and other particulate matter produced by building works, much of which is abrasive dust which is very damaging to our lungs. Construction Management Plans and Construction Traffic Management Plans must pay particular attention to air-quality, and must be strictly enforced. Efforts also need to be made to curb any more large-scale building developments in RBKC and in the eastern part of Hammersmith & Fulham, which serve to aggravate levels of congestion and pollution, and further overload not only the roads but the infrastructure as well.
We agree with the Mayor that freight vehicles, especially construction vehicles, are a significant contributor to road congestion and danger. We agree with his aspiration to reduce the amount of construction traffic in central London by five per cent by 2020, and reduce overall van and lorry use in central London in the morning peak by 10% by 2026.
We agree with the Mayor that many van and lorry trips could be avoided or re-timed if freight and servicing activity were better organised. Regional consolidation and distribution centres at the edge of London are needed to serve central London. These can be coupled with micro-distribution centres in central London, from which deliveries will be made by low and zero-emission vehicles, such as electric vans or cargo bikes. Local businesses also need to make and receive deliveries and dispose of waste materials, but we agree with the Mayor that this traffic must be consolidated, rescheduled and switched to more efficient and sustainable vehicles, including making more use of the Thames.
Essential projects to increase the capacity of the water, gas, and sewerage infrastructure will cause massive traffic disruption over the next few years and it will be of crucial importance for the existing road system to be managed more effectively to avoid the already alarming levels of congestion and air-pollution increasing still further over the coming years.
In addition to motor vehicles, pollution is caused by gas and oil boilers in buildings, and all new or replacement boilers must be required to meet stringent emission standards. Building owners should also be encouraged to install solar panels for heating water and generating electricity, in places where they would not impair the visual amenity of the locality.
Pollution is also caused by the hundreds of airliners which fly low over London every day emitting noise and spent aviation-fuel. We agree with the Mayor that three runways at Heathrow would have severe noise and air-quality impacts and that alternative airport-expansion options must be considered.
We also agree with the Mayor’s wish to reduce air pollution from river vessels.
We will consult our members on an extension to include the whole of RBKC, coupled with a significant increase in the charge to make it more effective, but we would expect that local people would have a discount. However, extending the CCZ would put more pressure on the Underground and the buses, and could have an adverse impact on local businesses, whose customers need a car to transport their purchases. Any extension of the existing zone would need to be a good deal wider than before if it is to be at all effective. We really don’t want the western part of Chelsea once again excluded and the Embankment/Earls Court One-Way System turned back into the primary route around the Zone.
The “school run” is also a significant generator of traffic, and perhaps a Congestion-charge would reduce this.
However, tradesmen visiting premises in the CCZ would simply increase their charges to cover it.
Private cars are a very safe, comfortable, convenient, and flexible way to travel in all weather conditions, and for a family they are much more affordable than public transport. In our opinion, private cars are not quite the villains that the Mayor perceives them to be.
Many people do not use their cars to drive around London, as congestion is so bad and parking so difficult, preferring instead to use the excellent public transport system. The cars therefore remain parked for most of the week in residents’ parking zones or in car parks, and do not during that time contribute to congestion or pollution. They do however remain available for people who need their car for journeys to destinations outside London for which public transport is not suitable eg in bad weather or for carrying heavy luggage and other goods.
We do not agree with the Mayor that there should be a reduction in the availability of private parking. His proposal to limit residents’ parking would serve no useful environmental purpose and would penalise the majority of residents who can’t afford a garage. We consider that all major new residential buildings should have adequate off-street parking for the people living in them, but only for genuine permanent residents, not for temporary occupants of properties or for properties left mostly unoccupied. There is however a case for discouraging the private car as a means of commuting to and from the workplace.
Some people are blaming diesel cars as the main cause of pollution, and are urging higher taxes or restrictions on them, but it is a good idea first to examine what we know about the sources and causes of pollution in London. The London Assembly researched the sources of NOx in London in 2015 and found the following:
Bus, coach and rail transport 18%
Goods vehicles 17%
Gas heating systems 16%
Non-road mobile machinery 14%
Diesel cars 11%
Petrol cars and motorcycles 8%
The TFL study in 2016 showed a similar pattern, with both bus and coach, and goods vehicles, each accounting for much more than diesel cars. The new Euro 6 standards for engines require both petrol and diesel engines to emit less than 5mg per km of particulates. They allow just 80 mg of NOx for diesels compared to 60 mg for petrol, but they allow petrol engines to emit more carbon monoxide (which is poisonous) than diesels (100mg versus 50mg).
We need to take into account the amount of use made of various categories of vehicle. A motorist who averages 8,000 miles a year, uses his private car for a total of just thirteen whole days per year, but a commercial vehicle such as a bus or a delivery van or a taxi may well operate for more than ten times that amount of time – over 130 whole days a year. That means we will get a far bigger saving of exhaust-pollution if we replace more of the old commercial vehicles than of the old cars.
We welcome the Mayor’s proposal that from 2018, all new double-deck buses will be hybrid, electric or hydrogen; that in central London, all double-deck buses will be hybrid by 2019 and all new single-deck buses will emit zero exhaust emissions by 2020. His aim is for the whole TfL bus fleet to have zero exhaust emissions by 2037 at the latest.
With regard to taxis, we support the Mayor’s plans to accelerate the transition from diesel-powered to Zero Emission Capable taxis by providing financial incentives and necessary infrastructure. We also agree that all new private hire vehicles younger than 18 months need to be Zero Emission Capable (ZEC) from 2020, and private hire vehicles older than 18 months at time of first registration should be ZEC from 2023. We agree that the GLA and its functional bodies should lead by example in the use of ULEVs in their own vehicle fleets and that the Boroughs, the police and ambulance service, and national government organisations, should do the same.
The Mayor says that “Too often streets are places for cars, not people” but cars do not drive around empty. They contain individuals and families who are using the road for a legitimate purpose. Creating “traffic-free zones” is not always beneficial, because the traffic which they have displaced adds to the congestion in nearby streets, and these zones can become dreary wastelands outside shopping hours. It is however important that policies for pedestrians are developed and there are a number of junctions on major routes where the safety of pedestrians should be improved.
As pavements represent 80% of public space in London the plans and priorities of TfL should show greater respect for pedestrians because there are still far too many junctions at which no protection is available for pedestrians (and in particularly wheel chairs, baby-buggies etc) and too many pedestrian crossings are still not light controlled on major roads (in the interest of both drivers and pedestrians).
The Mayor seems to prefer cycles to cars, but most bicycles carry only one person and have very little capacity for carrying anything. One bicycle does not occupy much road space, but the Mayor has set aside a huge amount of road space for cycle lanes. That space is denied to other traffic, causing serious traffic congestion on the remaining road space, and is often unused. Despite these efforts by the Mayor and his predecessor, cycling in central London is very dangerous, and will probably always be so. Nor will it be a healthy activity until the level of air-pollution has been substantially reduced.
The Mayor is right to encourage people to walk for at least 20 minutes per day if they possibly can, but again this is not a healthy occupation at present levels of air pollution.
Nobody would quarrel with the Mayor’s aspiration that deaths and serious injuries from all road collisions should be eliminated from the streets by 2041, but we doubt that it is achievable.
The Mayor also prefers buses to cars, but buses in central London cause substantial congestion, noise and pollution. A fully loaded bus makes good use of road-space, but all too often buses are not fully loaded, and are making a poor use of road-space. In addition, large amounts of road space have been set aside for bus lanes which are often lightly used, causing congestion on the remaining road space.
We support the Mayor’s intention to investigate ways of reducing noise from the loudest vehicles such as motorcycles and supercars. We do not think that such vehicles should be allowed in central London at all unless adequate silencers are fitted.
OBSTRUCTION OF ROADS
Substantial traffic congestion can be caused by road-works, which need to be much better co-ordinated so that the same stretch of road is not excavated sequentially by more than one utility company. Everyone agrees with this proposition, but it does not seem to happen in practice. We therefore support the Mayor’s commitment to coordinating road works and reducing the number of times streets have to be dug up, to limit disruption to bus services and other traffic. All too often we see the road obstructed by excavations on sites where nobody is working. On busy streets there is a case for saying that work must be carried on continuously around the clock until completion (provided that noisy work is not done while nearby residents are asleep), and if parts or special equipment are needed they should be sent immediately by special courier.
Highway authorities should give much more notice of intended roadworks, and provide clearly signed advice a long way back as to alternative routes where possible. The duration of the work should be clearly indicated and enforced. In other countries it is possible to carry out roadworks much more quickly, and it could be done here if the works were properly planned and sufficient manpower and equipment were made available, together with late night and early morning working where acceptable to local residents.
The King’s Road, Fulham Road, and many other main roads in central London are quite narrow, and it is particularly important that they should not be obstructed. There should be no parking or waiting whatsoever between 08:00 and 19:00 on Monday – Saturday on the main road and on the side-streets within say 30 feet of the main Road (so that traffic turning into the street does not back up on to the main Road), and this must be strictly enforced. It is notable that traffic wardens are active in the residential streets, but are much less active on the main roads. This needs to change – occasional visits by traffic wardens are not enough.
Traffic is obstructed by an almost constant flow of pedestrians across the pedestrian crossings at busy times, and many more crossings should be Pelican crossings (but without their annoying peeping noises, which should be replaced by a vibrating pad for the benefit of blind people).
Streets are often obstructed by building work, scaffolding, skips, and heavy vehicles, and these need to be kept to a minimum.
We agree with the Mayor, that unreliable rail services make journey-times unpredictable, wasting people’s time and even threatening their livelihoods. We do not however see, and the Mayor does not explain, why they would be any better if the overground were controlled by him instead of the Dept. of Transport. Serious disruptions of London’s rail services caused by industrial action are too frequent and sometimes for spurious reasons.
Trains often have their diesel engines running whilst waiting for considerable periods of time at stations, or when progress is obstructed, or to adjust service times, and the air at Paddington Station is particularly badly polluted. It is time for the main-line between London and South Wales to be electrified. Diesel trains have very large engines and are serious polluters, but drivers do not appear to have instructions to switch off the engines when stationery for extended periods of time.
The London Underground provides an excellent service, but step-free access is needed at many more stations, including Sloane Square and South Kensington. Some people think that there is far too much use of loudspeakers on the Underground, (and the overground) which adds to the noise and stress of this mode of travel.
The Overground line through the western part of Chelsea has proved a valuable addition to the network but urgently needs longer trains and more frequent services to cope with very high levels of demand.
We agree with the Mayor that Crossrail 2 would be very beneficial at many places on the route which has been indicated, but The Chelsea Society has explained at https://chelseasociety.org.uk/crossrail-2/ why, far from improving traffic flow and reducing pollution in Chelsea, a station on the Kings Road would make matters worse, and would have serious adverse consequences for the character and amenities of Chelsea.