WLS response to Wandsworth Council’s draft Local Implementation Plan

Introduction:

Each London borough council must produce a Local Implementation Plan (LIP) saying how it will deliver the Mayor of London’s strategy at borough level. This is the third round of LIPs, with one having been produced for each Mayoral Transport Strategy (MTS) to date.  Wandsworth Council’s draft LIP, in line with the Mayor’s Transport Strategy, covers the period to 2041, with a focus on the first three years to 2022.  The draft LIP and associated documents – which can be accessed here Local_Implementation_Plan: have Your Say – set out how the London Borough of Wandsworth will work towards achieving the MTS goals of:

Healthy streets and healthy people

A good public transport experience

New homes and jobs

Wandsworth Living Streets’ response to the consultation on Wandsworth’s Draft LIP is below:

Wandsworth Living Streets response to draft Wandsworth LIP3, 11 January 2019

Comments on Objectives, summarised at pages 62-64:

Tend to support

While the objectives are broadly commendable in themselves, we note that they are rather vague (and not SMART), they lack ambition, and in some cases are a repetition of objectives given in LIP 2 (for example, MS1 and MS2 on ‘facilitate’ active travel modes).  Whilst open spaces can assist with creating  active travel networks, we wonder whether the reference to these in MS2 reflects a reluctance on the part of Wandsworth Council to reallocate carriageway space on roads to cycling.  The ‘mode share’ objectives are particularly crucial since they are fundamental to the MTS, but it is not clear from the LIP how we would know that we have met them.

img_20180907_104425Key mode shift targets of Mayor’s Transport Strategy

On MTS Outcome 1, ‘Active’, MTS1a, we think that ‘considering’ Healthy Streets indicators is weak.  The use of Healthy Streets indicators should be an integral part of all current and planned schemes.  It is our impression that MTS1b needs more fundamental review, given the stagnating mode share of cycling in the borough (see for example Table 2, WBC paper 18-405 and Section 6, WBC paper 17-183).  We recommend that MTS1c be strengthened – it is not enough to ‘limit’ volumes and speeds of motor traffic in residential areas; these need to be reduced.

We suggest the addition of a further Objective, to review relevant ‘streets related’ policies to ensure that they fully support mode shift to active travel modes and Healthy Streets.  Wandsworth Council policies currently favour car (and motorbike) use, including car parking, as the default, suppressing mode shift to walking and cycling and the creation of residential streets which provide a range of amenities for local people.

On MTS Outcome 2, ‘Safe’, we think that more is needed to ensure that streets are made safe and – crucially – feel safe for people using active travel modes.  Although the LIP acknowledges a continuing failure to reduce road danger (reflected in the growing proportion of people not in cars who are being killed and seriously injured on roads in Wandsworth), there is no reference to the most recent pedestrian casualty data for Wandsworth, which shows an alarming 22% increase from 2016 to 2017.  Pedestrians are the only road user group in Wandsworth to show such a dramatic increase in casualties; we suggest that this should trigger a fundamental review of causes (and causes of causes), with a view to more effectively reducing road danger at source, for the benefit of residents and visitors to the borough. In particular, we think the LIP should highlight the role of Low Traffic Neighbourhoods (for more information please see here ) in helping to reduce road danger on residential streets, which form the majority of roads in Wandsworth road network. MTS2a although welcome, given the disproportionate danger that HGVs present to other road users, does not cover the much greater overall danger presented by people driving.  We suggest that MTS2a and 2b would benefit from a wider range of measures to ensure delivery e.g. use of Intelligent Speed Adaptation in the Council’s procurement via council and council-contracted vehicles, a requirement for ISA to be incorporated in car club vehicles, asking TfL to prioritise the roll out of bus ISA on bus routes operating in the borough.

img_20180417_114643    Mode filter, Franche Court Road at its junction with Burmester Road

Wrt MTS Outcome 3, ‘Efficient’, we think that the objectives should more strongly reflect the fact that private cars are an inefficient use of highway space.  Whilst the council’s planning policy cited in 2.4.22 (relating to requiring new developments to be car-free) is welcome, this will only cover a small minority of the borough’s area.  Much more focus is needed on ‘retrofitting’ – to make better use of public space, by reducing use of cars (parked and moving) and by reallocating road space to cycleways, cycle parking and parklets.  Measures such as road user charging and the introduction of a workplace parking levy – not mentioned in the LIP – could both reduce car use and generate funding for use in supporting and encouraging more space-efficient and sustainable modes. We therefore recommend that Wandsworth Council carries out feasibility studies into RUC and WPL.

Wrt MTS Outcome 4, ‘Clean and Green’, MTS4c could entail the creation of Low Traffic Neighbourhoods to physically prevent rat-running through boundary street networks.  The arrival of ULEZ represents a major opportunity to reclaim local streets for people, a measure which has proved popular in the past e.g. in local streets west of Putney Exchange.  Whilst electric vehicles have zero tailpipe emissions, they have all the other drawbacks of motor vehicles, without the health benefits of increased physical activity via active travel.  We are concerned about the effects of MTS4d (expansion of EV charging points) on active travel modes, particularly pedestrians.  It is clearly perverse for Wandsworth Council to continue to reallocate space from pedestrians to users of electric cars in the borough.  We would like this objective to be qualified to require provision of charging points either off road or on footway build-outs, as has been done in other London boroughs.  We recommend further that the Council investigate the feasibility of installing public electric bicycle charging points on carriageway and in off-road locations.

img_20180510_135322 Electric vehicle charging points on busy footway of Grant Road outside Clapham Junction station

Wrt MTS Outcome 6, ‘Accessible’, we agree that this is an important set of objectives in enabling sustainable travel modes by everyone in the borough.  We suggest that it is not only public transport operators who could assist in improving provision of public transport information to users (MTS6c); given the free availability of real-time information such as Bus Countdown, other organisations e.g. health centres, hospitals, cafes and other public places could be invited to host a screen giving such information.  This is the norm elsewhere and can be seen even in other UK cities such as Coventry.  We agree that there is scope for improving interchange between public transport modes; Earlsfield station is one example of a station where interchange from buses (travelling southbound) seems unnecessarily difficult for people walking, requiring often lengthy waits at side road crossings.

We agree that, given the considerable development planned and underway in the borough, there is considerable scope for ‘locking in’ healthy travel modes as part of new developments (MTS8 – Sustainable Growth, MTS9 – Unlocking), we think that these objectives should be modified to ensure that associated streetworks, which may take years to complete, do not in the interim worsen conditions for people walking and cycling.  There are numerous examples across the borough where walking and cycling infrastructure, including routes, has been and continues to be, disrupted, with little apparent consideration of the discouraging effects that such measures have on active travel, and particularly on mobility impaired people.  This point cross-references to Objectives listed under MTS6, ‘Accessible’.

Comments on Delivery Plan, p. 56-84

Tend to support / Neither support nor oppose

We highlight some comments on specific delivery elements below.

(a) 3.3.5 “… The rollout of electric vehicle charging points will also support the wider uptake of zero emission vehicles.”

We are concerned that the current programme to remove footway space and reallocate it to motorists is currently and will, if continued, worsen conditions for people walking.  As well as its practical effect, this measure sends a clear message that driving is prioritised over walking, a clear conflict with the Healthy Streets approach underpinning the Mayor’s Transport Strategy.

(b) 3.3.8 (Complementary works in Nine Elms)

We welcome provision to upgrade public transport provision in this area.  We emphasise the need to prioritise active travel modes over private motor traffic in Nine Elms Lane area, in order to ensure that multimodal journeys can be undertaken ‘seamlessly’ and thus compete effectively with driving.

3.3.11 (Improvements to District Line)

We welcome complementary works to improve interchanges at East Putney and Southfields.  We note however that the Southfields scheme has been designed to worsen provision for commuter cycle parking, and that cycling access to the station has an unresolved ‘critical fail’.

3.3.17 (Wandsworth gyratory aka town centre)

Whilst the scheme proposals will result in some improvements on Wandsworth High Street for active travel modes, which are welcome, these have been watered down from the original proposals and will for example still permit north-south motor traffic movements across Wandsworth High Street, a source of danger and pollution to people walking and cycling in the town centre. We are concerned that the proposals pre-date the MTS and do not take full advantage of this opportunity to improve access for people using active travel modes e.g. in showing modelled increases in journey times for walking and cycling, and apparent abandonment of the Wandle Trail in central Wandsworth.  These weaknesses currently remain unresolved, which – given the centrality of Wandsworth town centre in the borough – is likely to compromise the borough’s ability to meet headline mode share and road danger reduction targets in the MTS

3.3.20 Tooting town centre

We welcome Wandsworth Council’s willingness to consider complementary measures to this scheme.  We have made the point that the scheme requires significant reductions in permeability for motor traffic on side-roads of the A24 through Tooting in order to work safely for people walking and cycling, and LIP or other appropriate funding could be used to progress this, creating Low Traffic Neighbourhoods as part of the process.

Under para 3.4.5. we note that “The Council collects around £25.7m in parking revenue every year. The majority of this revenue (£14m) goes towards the cost of concessionary travel paid for by the Council, including the Freedom Pass. Parking revenue is also used to cover the costs of the parking service, including enforcement, along with road and footway maintenance, street lighting and Wandsworth Community Transport…”.

We think that there is scope for reviewing parking charges and restrictions, to better reflect the harms and loss of amenity caused by motor vehicles e.g. introduction of differential charges for diesel vehicles (to help reduce air pollution), or for larger cars (to discourage greed in appropriation of public space).   This review should incorporate timings of parking restrictions at weekends, it being notable that on Sundays, the ability to walk, cycle or travel by bus through town centres such as Wandsworth and Tooting is noticeably compromised by the presence of on-street car parking.  A surplus thereby generated could fund practical measures such as the offer of an annual bulky household refuse collection to car-free households in the borough, to better support and encourage the [nearly half] of Wandsworth’s households who do not own a car or van.

3.5. Long term interventions to 2041

We note that these are listed as Cremorne Diamond Jubilee and Nine Elms – Pimlico Bridge.  We agree that these are important infrastructure projects to address severance caused by the River Thames.  These projects underline the importance of improving active travel route networks in their respective localities, in order to maximise their benefits.  Given the acknowledged delay likely in delivering such infrastructure, we suggest that it might be more productive to earmark associated funding (where feasible) to shorter term, disseminated measures, which would benefit borough residents as a whole e.g. narrowing and raising the entrances to all side streets to require turning movements to be taken more slowly; developing a programme to invite local residents to submit bids for on-street parklets, so that there is a parklet on every street.

img_20180210_164759Guerilla ducks in tree pit in residential street in Wandsworth

We recommend that the Council adds the Wandle Trail to this list, a much neglected part of Wandsworth’s green and active travel infrastructure with major discontinuities which limit its usefulness especially to families with young children.

3.6. Three-year indicative Programme of Investment

We note (see Table 5) that there is only one reference to Liveable Neighbourhoods (a Mayoral flagship programme), in relation to the bid for Putney Town Centre.  We recommend that a high quality Liveable Neighbourhood proposal be submitted for each of the next three funding years, prioritising the areas with the greatest need, such as least green space.

Table 6: LIP Risk Assessment for three-year programme 2019/20-2021/22 and Table 8: LIP Risk Assessment for annual programme – 2019/20 both highlight High or Medium-High of risk of Lack of local support for delivery of schemes, e.g. after consultation.  We agree strongly with the stated need for early engagement with the public, in order to mitigate this risk.  However, we think that the terms of consultation need to be fundamentally changed if this is to be successful.  There are growing numbers of examples in London of such a fundamental shift in the terms of public consultations, for example the early use of the Healthy Streets approach by Hounslow Council in its committee paper on a trial street partial closure in Isleworth, an approach which has gained that Council public recognition, see here

We note that Waltham Forest Mini-Holland – which similarly (but on a larger scale), faced and had to address a backlash from residents content with the status quo, has received over 50 awards, hosts frequent study visits from all over the world, and has already demonstrably reduced air pollution and increased physical activity of its residents.  The rewards for borough residents, councillors and officers of such leadership are there to be seen.

Final Comments

Table 9: Borough outcome indicator targets

We note the lack of interim targets for: mode share, proximity to Londonwide strategic cycle network, traffic volumes measured by vehicle-kilometres, car ownership, COemissions, NOx  emissions, particulate emissions, daily trips by public transport, time disadvantage of step-free access to public transport, and bus journey reliability.

We recommend the addition of Interim Targets in order that progress may be effectively monitored.

In Table 9, under Outcome 2: ‘London’s streets will be safe and secure’, we note that the 2022 borough KSI target is ‘Down to 46 or less’ and the equivalent target for 2030 is ‘Down to 30 or less’.  Given that Figure 13 shows that in 2016 the number of KSIs in Wandsworth went off trajectory (at 98 KSIs, according to TfL in 2017) and that the number of KSIs in Wandsworth in 2017 increased dramatically to 147, it does not seem credible that the borough will meet these interim targets without a much more rigorous approach to reducing road danger and volumes of motor traffic. Measures that could help with this would include support for road user charging, Low Traffic Neighbourhoods (to remove rat-running from residential streets) as mentioned earlier, and protected cycling provision on all distributor/main roads.

img_20161024_152610Aftermath of death of Lucia Ciccioli on Lavender Hill in October 2016

Paragraph 2.4.21 refers to a drop of 33% licensed vehicles in the borough of Wandsworth from 2001 to 2017.  This should surely have provided a strong incentive for a commensurate move to reallocate road space from private motorised modes to active travel modes as well as to place making.  The introduction of the Healthy Streets approach to underpin the MTS and borough LIPs provides further support for reviewing use of highway space across the borough.  We suggest therefore a review of the Council’s parking policy to better understand and address the barriers (literal, in the case of pavement parking) to active travel that its policies and practices currently present.  Given the gradual increase in size of private cars, the status quo means that space is gradually being reallocated to drivers, contrary to the Mayor’s Transport Strategy and Wandsworth’s stated objectives. A useful step would be to commit to a percentage of removal of on-street car parking on an annual basis. Concomitant with this, all frontagers would be offered amenities using the freed up space e.g. parklets, as mentioned earlier, bike hangars including parking for cargo bikes, trikes and adapted cycles, and so on.

img_20180316_105721Cargo bike in use on Battersea High Street

We summarise the benefits of Parklets as follows:

  • Providing rest points every 50m is critical for older, pregnant and disabled people to be able to walk outdoors and visit shops and amenities. This provides valuable opportunities for exercise which is otherwise impossible if no seating is provided along streets. Many footways are too narrow to walk on let alone wide enough for regular seating.
  • Having a community focal point on a street will bring communities together, facilitating community interaction. This will reduce social alienation, isolation and mental ill-health for many in the community.
  •  Allowing residents to apply for and create their own Parklet will harness people’s creativity and resources and allow them to invest in the public realm. This will enable a scalable programme.
  •  Non-car owners currently have no stake in their street. It is car owners who are out there on the street washing their cars. Providing space for Parklets will allow all residents to go out onto the street to clean, maintain and use it.
  •  Well-designed Parklets on quiet streets can provide a secure place for smaller children to play together and read outdoors.
  • Parklets with exercising opportunities can provide active people with gym and other exercise equipment.
  • Parklets provide an excellent opportunity for greening and visually livening up the street, instantly adding colour, plants and enjoyment to the street.
  • Allowing people to apply for a space to park their own bicycles, or for community cycle parking will add variety and choice of parking vehicles other than cars at the kerbside.
  • Parklets could also be used for many commercial and community uses. Some of these could be sponsored by companies.

Additional comments

We think there should be greater emphasis on quality of provision for active travel.  For example, while the commitment to improved accessibility for pedestrians referred to in Table 7 ( Proposed LIP Spending Submission for Wandsworth 2019/20-2021/22 ) is welcome, Wandsworth could work with TfL to review signalised crossings (wait time, time to cross, and other characteristics such as width) and scope for installing further diagonal crossings; the Council could review demand for zebra crossings and develop a programme to install these as low cost interventions to support walking.  In this vein, it is a concern that the LIP does not include a re-statement to use London Cycling Design Standards in all highway schemes.  Use of standards such as LCDS and the Healthy Streets toolkit would ensure that planning failures such as the proposed Quietway 4 route design at Earlsfield station and the poor quality provision on Magdalen Road could have been prevented at an early stage.

img_20181211_121629New zebra crossing outside Beatrix Potter Primary School on Magdalen Road, Earlsfield, on Quietway 4

img_20170807_121722Obstructed footway, Point Pleasant

The micro-environment is uniquely important to people walking, with degraded streets especially noticeable to people on foot.  We recommend that the Council develop an initiative to recover the costs of damage caused to street furniture by motorists, use funds reclaimed from drivers or the MIB to support active travelling. This could be carried out using mobile CCTV, a tech tool which could also be deployed more widely to tackle flytipping hotspots.

img_20190102_122559Broken guard rail, outside Henry Prince Estate, Garratt Lane, Earlsfield

We note the stated role of Healthy Streets champion cited in 2.2.20, from 2018 Business Plan: ‘Appoint a “healthy streets” champion that works to help reduce street clutter and create new pocket parks, as part of a total safety approach.’  This remit does not reflect the Healthy Streets approach, the thrust of which is about much more than clutter and pocket parks (welcome as these elements are). Such a narrow remit in our view does not reflect a serious commitment to the Mayor’s Transport Strategy.

Although community severance is recognised to some extent (the Thames as a barrier to active travel in particular – although it is of course also a major attractor for people using active travel modes, especially when seeking out low-pollution routes), we think that the final LIP should acknowledge the role of severance in suppressing active travel more strongly. Its existence is for instance reflected in the cited low active travel levels in Roehampton, a part of the borough carved up by large, busy roads.  Community severance by Penwith Road and Garratt Lane also underlines the importance of addressing Earlsfield Missing Link, mentioned above as a major borough weakness in the Wandle Trail and obvious inhibitor to families walking and cycling.

img_20181106_100449Air pollution poster outside Brocklebank Health Centre, Garratt Lane

Finally, we have noticed that the LIP contains only very limited reference to children.  The provision of Bikeability cycle training to children, while welcome, is clearly not enough in itself to enable children to cycle, as indicated by Wandsworth’s stagnant mode share of cycling to school over the past decade.  This clearly points to the need for meaningful infrastructure changes, including the introduction of a School Streets programme, as part of a broader programme of timed and temporary street ‘closures’. School streets would have multiple benefits for children’s health, in terms of reducing their exposure to air pollution and road danger, and enabling active travel.  We suggest that a ‘best in class’ quality School Streets programme is developed, building on experience gained from other London boroughs in the adoption of this initiative.

 

img_20160209_125327People of all ages need safe streets (Brookwood Road, Southfields)

Notes on Equality Impact Assessment

With respect to the accompanying Equality Impact Assessment, we are surprised at the apparent lack of recognition of cycling as a mobility aid displayed in Wandsworth’s draft LIP (see page 23) . This benefit could be extended to many more Wandsworth residents, including disabled people (who among all population groups find it most difficult to be sufficiently physically active to benefit their health) if the infrastructure was made more welcoming to people using all types of cycles.  For a recent example of cycling as a mobility aid by a resident of Battersea, please see https://www.bbc.co.uk/news/av/uk-england-london-46619856/who-is-battersea-s-chopper-biker

It should also be recognised (see page 26) that EV charging points on footways, while a particular problem for disabled people, especially those visually impaired, disadvantage all pedestrians unless the footway provides a high pedestrian comfort level i.e. is very wide; and trailing cables may present a trip hazard to anyone walking along or across a pavement.  The loss of ability to walk sociably side by side is a material loss of amenity to all pedestrians.

Dr Susie Morrow

Chair, Wandsworth Living Streets

11 January 2019

wandsworthlivingstreets.org.uk

@WandsLS