Response from Jenny Jones to Mayor's Transport Strategy statement

							Date: July 2009

Consultation Response to Mayor’s Transport Strategy Statement of Intent
Comments from Jenny Jones, member of the London Assembly


Boris Johnson
Mayor of London
The Queen’s Walk
London SE1 2AA


(This response sets out my individual views as an Assembly member and not the agreed
views of the full Assembly.)

The key challenges remain the same as under the existing Transport Strategy. It is
understandable that the proposed solutions and priorities have shifted with the new
Mayor. The delivery of many new projects and innovations is also clearly constrained by
the recession’s impact on TfL finances and the failure of the PPP on the tube. The
overall impact of these changes to mayoral policy is to open up an even larger gap
between the scale of the challenge and the inadequacy of the proposed delivery.

The gap between the demand for transport services and supply already manifests itself
in over crowded trains, tube lines and buses. The impacts of this gap on the roads are
congestion and pollution. It is therefore remarkable that London grew and thrived
between 2000 and 2007 whilst reducing traffic by 2%, at a time when it increased by
10% in the rest of the country. The policy mix of carrot and stick measures has led to a
drop in the proportion of journeys made by private motorized transport from 44% to
38%. This Statement of Intent threatens this success by:

•   dropping a package of improvements delivering a further 10% increase in public
    transport capacity, ahead of 2025;
•   proposed abandoning of western extension of congestion charge;
•   making motoring cheaper in London, whilst public transport fares are raised above
    inflation.
•   increasing capacity on the roads through traffic light rephasing;
•   proposed increase in car parking in outer London town centres;
•   stopping schemes like Parliament Square which shift priority from private motorised
    transport to walking, cycling and buses;
•   three year freeze in expansion of the bus network.

Traffic reduction
Most significantly, the targets for restricting traffic growth are not mentioned and
apparently abandoned. This seems odd, given the obvious desirability of traffic
reduction and the success with which TfL and the previous mayor had exceeded their
targets. There are three big reasons to focus efforts on traffic reduction:

    1) cycling, walking and mass transit reduce congestion because they are more
       efficient ways of using existing road space than private motorised traffic;
    2) it directly reduces all the impacts of traffic, including CO2 emissions, air
       pollution, noise and road casualties;
    3) it improves the feel of the city;



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I welcome the Statement of Intent’s expectation that modal shift will continue and also,
the Mayor’s aim of

“Balancing capacity and demand for travel through increasing public transport capacity
and/or reducing the need to travel."

However, the policy won’t mean anything without a clearly stated plan for bridging the
gap between demand and supply. The size of the gap is indicated, but the implications
for increased public transport investment, or reducing traffic demand through road
pricing, should be spelt out in detail.

Para 170 "London’s growth will increase demand for transport by around an extra two
million trips a day by 2031. Simply providing for this increase in demand would entail
provision of significant further public transport capacity and potentially more road
capacity.”

The consequences of a growing gap between supply and demand should be made clear
for congestion and over crowding in different areas of London.

It is stated clearly that the existing proposals in the business plan “will not fulfil the high
level outcomes [set out in table 10], that outcomes will deteriorate between 2017 and
2031, and therefore more needs to be done to meet challenges which remain
unaddressed by TfL’s business plan...”

This honest assessment of the scale of the problem is welcome. However, the
consequences of this assessment is that the draft strategy will need to include new, big
ideas which either increase capacity (like the cycling schemes), or reduce demand (like
road pricing). These ideas can’t wait until 2017 to mature. Planning and preparation are
essential in the short to medium term, if the next generation of schemes and projects is
to win government backing. That is why the mayor has made such a big strategic
mistake by dropping the package of infrastructure schemes promoted by the previous
administration. The mayor should reinstate the following schemes in the draft Transport
Strategy and aim to attract government and private funding to them:

•   Oxford Street Tram,
•   Greenwich Waterfront Transit,
•   Docklands Light Rail extension to Dagenham Dock,
•   Croydon Tramlink extensions,
•   Step free access at 24 stations which have been deferred,
•   East London Transit extensions, to Rainham, Romford, and Collier Row
•   Public space proposals at Euston Station, Victoria Embankment, and the route
    between central London and the Olympic park.
•   Station at Surrey Canal.

I welcome the fact that TfL are assessing the scale of the impact of the soft measures
on reducing demand (page 80 of business plan). This study should be made public,
along with the estimated costs and benefits. Many of the smarter travel schemes and
innovations are still in their early years and require further development before they are
as effective as they can be. There should be a comparison made between investment in
soft measures and taking forward infrastructure proposals. As pg 80 of the TfL business
plan states:




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“ At a time when hard financial choices need to be prioritised, ‘smarter travel’ measures
offer a cost effective way of encouraging greater use of public transport, cycling and
walking, and their associated health benefits, as well as tackling congestion and
reducing CO2.”

I welcome the Mayor’s fine words on minimizing the need to travel, but there is little in
the existing business plan to make this a reality. The draft Transport Strategy will need
to have targets for each of the demand management measures. For example, Transport
for London has previously estimated that achieving the aim of half of all Londoners
having a car club vehicle within a 5 minute walk and three quarters of Londoners having
a vehicle within a ten minute walk would require, on average, investment of over a
million pounds a year for four years.

I welcome the fact that the Statement of Intent regards road pricing as an option and
believe that it will be an essential tool for achieving the tough targets on reducing
congestion and CO2 emissions.

Policy 175 “If required to address the challenge, managing the demand for travel
through pricing incentives on roads and public transport systems (through fares, road
pricing and other potential charging regimes) to balance the supply and demand for
travel…”

The growth of freight, especially light goods vehicles, needs to be recognized.
Nationally, there has been a 40% rise in van use over the past decade. Few policies in
London, or nationally, have directly addressed the problems and impacts which this
change has caused. TfL’s freight transport strategy is a worthy attempt to deal with the
problems. Existing measures in the TfL business plan:

“…. should reduce freight traffic in the morning peak to 2006 levels [by 2017/18],
even with the growth of population and jobs."

The draft Transport Strategy should contain all the targets and solutions contained
within TfLs’ freight strategy. However, there should also be recognition that this is not
enough and that we need further measures which are particularly targeted at light
goods vehicles.

A tightening of parking standards is also essential, as the existing regime of lax controls
will lead to around 400,000 extra cars being parked in new residential developments by
2025. The key aim should be a progressive reduction in the percentage of households
owning one vehicle and also in those wishing to own two or more vehicles. Virtually car
free developments should be encouraged in areas with excellent public transport
connections, only allowing parking for people with disabilities and car club vehicles.

The draft Transport Strategy will need to show the extent to which the gap between
supply and demand can be bridged by a combination of infrastructure and demand
management. I believe that more emphasis should be placed on demand management
than new infrastructure, as this is the better environmental option. However, my view is
that both will be necessary.

The impacts of population and economic growth on CO2 emissions from transport are
spelt out, but the impacts on air pollution, noise and road casualties should be made
equally clear. Traffic reduction has a significant impact on all of these. For example, if
PM10 pollution from tyre and brake wear is seen as a major problem, then traffic



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reduction is the only proven solution and will have to be a significant part of the Air
Quality Strategy. I oppose the removal of the Western Extension of the Congestion
Charge, as it will lead to an increase in traffic and air pollution.




Planning, Thames Gateway and outer London
A three pronged approach to achieving the high level outcomes is proposed with: land
use planning; more capacity and demand management. I agree that planning is key, as
much of the transport investment in London is currently having to mitigate the
problems caused by failures in the planning system. Much of the need for capacity
increases could be avoided if the planning system aimed to create a more sustainable
city. This would involve:

•   Designated local centres to provide specified range of every day facilities;
•   All local centres to be well-connected to neighbouring local centres and a nearby
    ‘metropolitan’ centre with facilities requiring a larger catchment area;
•   All homes to be within 500m of basic facilities such as food shops;
•   Tight control on development which could undermine local centres and their
    economies;
•   Many traffic-free public places and streets, including designation of an extensive
    network of strategic walking routes across central London, and in outer areas;
•   A pattern of development which fosters proximity of home, work, services and
    amenities, for ease of accessibility and to reduce the need to travel;
•   A major shift in the allocation of road space to walking, cycling and public transport;
•   Priority for public transport schemes which link residents to local jobs and facilities,
    including orbital public transport;

Thames Gateway
The mayor does appear to be shifting the focus of land use planning to outer London –
with less emphasis on the Thames Gateway.

Para 95 “He [the Mayor] is keen to see whether a more ‘polycentric’ pattern of land use
and economic development and in particular a focus on a number of strategic Outer
London development centres can sustain London’s economic success, reinvigorate and
enhance Outer London town centres and deliver a more inherently sustainable pattern
of development through reducing the length of journeys and/or need to travel at all.”

Whilst I support the shift towards a polycentric city, rather than concentrating on an
over heated central London, this new approach does not have to be done at the
expense of investment in the Thames Gateway.

Given the large scale availability of brown field sites in East London and the need to
deal with social inequality, it would be a major error to abandon the focus on matching
new transport infrastructure with the areas of economic regeneration. The failure of the
Statement of Intent to show the linkages between transport and regeneration is a major
flaw and is illustrated by the Mayor’s decision to cancel the DLR extension to
Dagenham Dock.

The principal policy on Thames Gateway transport infrastructure in the three proposals
documents (Transport Strategy, London Plan and Economic Development Strategy) is
‘support for the provision of appropriate transport in the Thames Gateway’. This is


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clearly inadequate. My fear is that development will go ahead without adequate public
transport infrastructure and the result will be a growth in private, motorized traffic. This
shift is being facilitated by proposed changes to the London Plan which will allow
increases in road capacity.

Transport for London’s report on options for East London river crossings states:

4.3 …The current London Plan policy makes it difficult to justify building any new road
scheme; the regeneration benefits have to far outweigh any traffic or environmental
effects.

4.4 A suggested revision is included in the London Plan Statement of Intent which
sets out the conditions where it would be acceptable to build new road capacity…

I oppose any new bridge or tunnel at Silvertown, a new Gallions Reach Bridge, and
improvements to the Dartford Crossing.

Outer London
TfL needs to give the same degree of attention to improving sustainable transport and
reducing traffic in areas of outer London, as they put into proposals for Thames Gateway
river crossings. The draft Transport Strategy has to provide direction and to map out a way of
achieving the Mayor’s objectives, in partnership with the boroughs.

I welcome the realism shown in the Statement of Intent towards the Mayor’s desire to
put more emphasis on outer London. I consider that in order to have economic recovery
without environmental and social damage London requires:

•   the dispersal of economic activity to centres of inner and suburban London, with a
    reversal of the current very strong trend towards centralisation;
•   tough policies to prevent the financial and business sectors from overwhelming
    central London and to steer these sectors to areas with capacity, and require them
    to meet clear environmental and social standards;
•   positive support for other UK regions with low development pressure, including
    policies to encourage some economic development to locate in other regions;
•   a city of interconnected thriving urban villages, which could be combined with
    excellent provision for walking, cycling and public transport, to enable most
    journeys to be made on foot, by cycle or by public transport.

To support the creation of new jobs outside central London and Docklands better public
transport links will be required to those other employment centres. This should take the
form of better links to each of those centres from its surrounding area and improved
links between those centres, which in some cases will be orbital links and in other cases
will be links across the centre of London. I share the view set out in the Statement of
Intent, which proposes.

Para 97 “Locating more employment growth in Outer London can reduce trip lengths
and bring about reductions in central London crowding and congestion. However,
higher growth in Outer London, without any change in transport provision, could lead
to more congestion and a small overall rise in London wide transport based CO2
emissions. This is because existing trip patterns within Outer London to central London.
On its own therefore, such a change of development focus does not achieve a wholly
better transport outcome.”



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I also agree with your analysis that if the London Plan does shift development to outer
London:

Policy 182 “… without specific interventions in Outer London, this would be at the cost
of generating additional car trips and congestion in the area. Further investment in local
transport infrastructure and demand management would be needed.”

In outer London walking is the dominant mode for trips up to 1km in length but for
trips over 1km car use far exceeds all other modes put together. Yet most of these trips
are less than 10km in length. Over that sort of distance public transport, bus,
underground, tram or rail, should be capable of satisfying most people’s demand for
travel but clearly it is not. Cycling therefore has a major role as the flexible and
sustainable alternative to the car in outer London.

The draft Transport Strategy needs to pay far more attention to non commuter trips
(which make up the majority of trips), travel which does not end in central London, and
in how transport provision can itself encourage greater dispersal of economic
development. The concentration of existing schemes addresses capacity problems in
transporting people to central London and Docklands. This needs to be balanced by a
new set of far reaching proposals to address serious transport challenges in London’s
suburbs.

I believe that there is a lack of provision for orbital trips by public transport in outer
London and this gap must be addressed by the draft Transport Strategy. The current
pilot of an orbital bus scheme is inadequate and more research is urgently needed into
the demand for services in different areas of London. I reject any solution based upon
journeys that run into and then out of inner London, as this approach will merely
compound overcrowding on radial routes. I accept that some increases in the provision
of orbital tram, train and bus services may be based upon incremental improvements to
services linking particular town centres, but there should be a strong desire expressed in
the draft Transport Strategy for this to be a long term goal. Well designed and modern
interchanges will be crucial to orbital journeys made by utilising different transport
modes.

Light rail and transit should be considered for many areas of outer London. The success
of the low carbon Tramlink in Croydon should be replicated in other parts of outer and
east London.

One long term strategic goal could be to make rail journeys in London much faster and
more convenient by the creation of a web of rail lines. Like a spiders web this would
consist of many lines radiating out from the centre and a series of concentric circles
linking with the radial lines. This would provide convenient access from anywhere to
anywhere else in London. Currently the radial lines do not go all the way to the centre
and there is only one orbital line, the LU Circle line, very near to the centre. The web
needs to be completed by the provision of lines through the centre, more orbital lines,
increased capacity and improved interchanges between the radial and orbital lines.

Unlike the orbital motorway, the M25, which tries to avoid town centres and built up
areas, Orbital rail links aim to pass through town centre stations because that is where
the greatest concentration of potential passengers is likely to be found. Such stations
also tend to offer the best interchange with other modes of public transport such as
buses and light rail, again contributing towards an integrated transport network. Some




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bus services could be diverted to serve the proposed new rail stations and those existing
stations which would gain more services as a result of these proposals.

Climate change
Sticking to the existing London targets for cutting CO2 emissions is particularly
welcome. However, there is a considerable gap between the reduction in CO2 emissions
from ground-based transport which current plans will bring about (10 per cent) and
what is needed to achieve the Mayor’s 2025 target (50 per cent).

This gap was addressed in the Climate Change Action Plan and I believe that an update
of that action plan should form the basis of targets, projects and innovations within the
Transport Strategy. Given the urgency of climate change and the failure of London to
reduce its CO2 emissions, it is regrettable that many of the measures contained in the
Climate Change Action plan have been abandoned, without any solid replacement
projects being put into place. At best, there will be a delay in delivery, as new measures
are piloted and rolled out. At worse, the replacement measures will not deliver the
required scale of change.

The draft Transport Strategy needs a substantial modal shift away from the private car
and a determined effort to decrease the number of vans and lorries in London.
However, I recognise that a radical shift towards a zero-emissions vehicle fleet, will help,
but only if the energy/fuel is from renewable sources.

The draft Transport Strategy should set out the relative contributions of minimizing the
need to travel, modal shift and a cleaner vehicle fleet. If a shift towards electric vehicles
is to make a significant contribution, then the Strategy should indicate what proportion
of vehicles in London would need to be electric to meet the target and where the
energy will be sourced from. If an element of modal shift is going to be required, the
draft Strategy should include potential measures to reduce car use and plans for
investment in high capacity, low CO2 modes. Plans for investment in mass transit need
to consider the relative environmental impact of potential schemes and prioritise modes
like trams, as having the lowest CO2 impact.

As with balancing capacity and demand, I consider pricing incentives are likely to be
required to meet the challenge of reducing transport’s CO2 emissions. However,
potential options for schemes need to be made available so their potential merits can be
assessed. The draft Strategy is the appropriate place to present the costs and benefits
of potential schemes in order that they are subject to proper consultation. It should also
include a framework for deciding when the introduction of pricing to meet CO2
reduction targets would be required. I believe that the emissions charging scheme
should be reinstated, with a £25 charge for gas guzzlers entering central London.

I regret the decision to cancel the 60 hydrogen vehicles being procured for London and
believe that hydrogen has a role in the draft Transport Strategy. It would be wrong for
the Mayor to exclusively push electric vehicles at the expense of the hydrogen option. It
is not clear which technologies will produce the best results in the future and choosing
one technological path could be a big strategic error.

It is also my view that TfL has dragged its feet on implementing energy saving measures
for the tube system. Given that the tube system consumes 2% of London’s electricity,
ambitious targets for energy reduction on the tube system need to be inserted into the
draft Transport Strategy. Whilst London Overground have developed their thinking at a
far faster pace, there is still a need for the Mayor’s office to push them towards delivery.



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I’m also concerned that the Crossrail may not deliver an energy efficient and sustainable
addition to the transport network. Crossrail should be able to show that it is well ahead
of anything on the existing network. The draft Transport Strategy must therefore
include clear projects and specific targets for sustainable energy on the tube/rail
system.

The four key means for achieving a reduction in CO2 within the transport sector are:

•   Reduction in total energy used on the underground and rail system. The
    introduction of energy conservation measures and regenerative braking must be
    written into all the franchise arrangements and the PPP contracts. Trains must also
    be designed to be as low energy as possible with a financial incentive system to
    encourage operators to use less energy.
•   Reduction in energy use in TfL’s own fleet. In the short term this means all new
    buses being hybrids, with the longer term aim (2012 onwards) of switching towards
    fuels which are 100% renewable. The same approach should be applied to other
    vehicles owned by TfL and its contractors, with new long term regulations brought
    in for black cabs and mini-cabs. By 2025, all of the TfL controlled fleet should be
    zero carbon vehicles.
•   Introduction of ‘polluter pays’ for London vehicles. I regret that the Mayor
    abandoned the aim of applying the polluter pays principle to the congestion charge.
    Reducing climate change should be a key policy goal of road pricing, which I
    support being extended across London. The same approach should apply to parking
    policy, with financial incentives to encourage drivers to switch to zero emission
    vehicles.
•   Traffic reduction.

TfL should be setting tougher targets for the areas which are directly under its control,
especially its own operations. The aim should be to achieve zero carbon for TfL’s own
operations by 2025, but this may include off-setting. However, the aim should be a
progressive reduction in the amount of off-setting used, with further reductions in
energy use and a switch to 100% renewable energy.

Finally, I disagree with any expansion of aviation capacity in South East England and
reject the idea that the current limits on capacity could “have the effect of limiting
London’s economic growth and putting its competitive position at risk”. Current
projections of aviation growth show that the most dramatic increases in CO2 emissions
within the transport sector will come from aviation and these are likely to negate even
the most radical action by TfL to reduce CO2. I therefore reject the idea of a new airport
in the Thames Estuary to supplement the existing Heathrow airport.

Cycling
I welcome the fact that the target of a 400% increase in cycling has been retained and
is a Mayoral priority. Also, that the flagship schemes of cycle hire and cycling commuter
routes (superhighways) are being taken forward. However, it is not clear that the third
and most vital element in the strategy - town centre cycling zones (cycling hubs) – have
any serious backing.

Given that 70% of the potential new cyclists identified by TfL are outside of inner and
central London, it is shocking that the Transport Strategy has no clear plan for cycling in
the suburbs and outer London. The mayor’s cycling hubs have become “.. centres of
excellence in outer London” and LCN+ is not mentioned.



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I know from my previous work on the 400% target can only be achieved if the flagship
schemes are properly funded and additional to existing schemes such as the London
Cycle Network+. I am therefore aware that the approach outlined in the Statement of
Intent will fail to achieve the desired result.

I am disappointed that the mayor has backtracked on the LCN+ because he regards it as
‘hard’ and ‘unpopular’. These safer routes for cyclists are necessary for the protection of
vulnerable road users and that should be a priority within the draft Transport Strategy,
even if some traffic planners claim that the LCN+ is hard to implement and unpopular
with some motorists.

The bulk of the unfinished LCN+ schemes are in the outer London boroughs and would
form a substantial part of any package of initiative designed encourage the bulk of the
potential new cyclists in London. As with the rest of the package of new measures for
cycling in outer London, the LCN+ is a strategic initiative and won’t be achieved if it is
left to boroughs to prioritise and fund.

I believe that cycling in London could ultimately take a larger modal share than the
London Underground (10%) and rail (7%). We are therefore suggesting a level of
investment in cycling over the next fifteen years which is comparable to that being
planned for rail and the tube.

It needs to be recognised that a rapid expansion in cycling numbers will require a scale
of investment in facilities and training which dwarfs existing plans. TfL needs to
consider what can be done to achieve the following by 2025:

•   a rolling expansion of both the London Cycle Network and the green routes
    schemes, covering three more five year periods;
•   a large scale and integrated marketing strategy for cycling in London which links
    advertising with the provision of cycle training and other services for new and
    returnee cyclists;
•   Regulations requiring expanded secure bike parking at all public venues and new
    developments;
•   capacity for bikes to be carried on all black cabs and mini cabs;
•   a comprehensive bike hire scheme for London, which expands beyond the proposed
    central London scheme;
•   well publicised and policed, fast commuter routes for cyclists;
•   cycling hubs/zones around town centres.
•   more facilities for carrying bikes on trains/DLR, so that a set percentage of
    passenger can carry them, including cycle spaces on board trains and access ramps
    at stations.
•   strict regulation and monitoring of freight vehicles in London to decrease deaths
    and serious injuries amongst cyclists.

Walking
Similarly, large scale investment is needed to urgently reverse the decline in walking
including:
• rapid introduction of London wide route-finding (i.e. Legible London) and borough
    walking maps;
• traffic free and calmed routes, including a central London pedestrian zone;
• walking zones around high streets and local centres;
• all public places, pavements and crossings designed and maintained for pedestrians;


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•   better signage for pedestrians to and from stations.

More road space needs to be provided for both walking and cycling. TfL should work
with user groups to identify improvements needed.

Given that walking accounts for a fifth of all trips, it is remarkable that there are no
major initiatives to improve the safety and environment of pedestrians, in the post 2012
period.

The boroughs
The draft Transport Strategy needs to address the problem of the boroughs being
expected to implement important goals within the mayor’s Transport Strategy without
either the funds, or desire to do so. Key areas of policy such as cycling, walking, road
safety and minimizing the need to travel, all rely on the partnership with local
authorities if strategic goals are to be delivered.

Whilst I agree with the London Mayor's emphasis on partnership with boroughs, I feel
that a new relationship with boroughs should be spelt out within the Transport Strategy
and based upon:
• supporting innovation and pilots run by boroughs with funding, expertise and a
    rigorous assessment process;
• rolling out proven local solutions to London wide problems, through coalitions of
    the willing;
• boroughs and TfL jointly identifying solutions to sub-regional problems and
    targetting resources at these programs.

The challenge for TfL's relationship with the boroughs is to harness the shift to localism
as a way of delivering big strategic goals. There is a danger that the current shift to
localism will be seen as an excuse to duck responsibility for key Mayoral goals, such as
boosting cycling in outer London, with borough receiving less money but having more
freedom to spend it on their priorities.

The decision to cut dedicated funding for the borough led LCN+ project is
an illustration of this approach and the result will be patchy progress on improving
cycling facilities in outer London. My concern is that other strategic goals, which require
borough delivery, will go the same way unless TfL take a more pro-active approach to
engagement with the localism agenda. That requires an open attitude to innovation, a
respect for local circumstances and a willingness to re-direct funding away from TfL led
programs, to those borough led programs which have strategic value.

Streets for people
One of the main ways of achieving an increase in cycling is the introduction of slower
speeds through 20mph zones. Whilst I have supported the gradual expansion of 20mph
zones, there is a strong case for following the Portsmouth example and introducing
20mph as the default speed limit on all residential roads. This would be considerably
more cost effective than the current approach and has the potential to create a cultural
shift in the attitude of drivers to speed. The draft Transport Strategy should support
borough wide 20mph areas, covering residential roads, with some exemptions for major
roads.

I welcome the trial of speed limiter technology on London buses and taxis, but the draft
Transport Strategy should indicate the way in which this will be rolled out, if successful.
Only by introducing speed limiters on public sector vehicles can London achieve a


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critical mass of vehicles travelling within the speed limit on the TLRN. Such a critical
mass of vehicles would have the effect of making all other vehicles stay within the
speed limit and I therefore ask for the rapid spread in the use of speed limiters to be an
aim within the Transport Strategy.

Another strategic aim should be the conversion of London’s major gyratories, back into
two way working. This should be the starting point for discussing the future of many of
London’s public spaces.

The proposed improvements to Parliament Square and the Victoria Embankment should
go ahead, as should the development of a central London pedestrian zone.

Air Quality
The European Commission is preparing to take legal action against the UK Government
for its breach of the 2005 limit values for PM10s. Whilst the Mayor only has a duty to
work towards meeting the limit values, the GLA family has a clear role to play in any
action program to bring London into compliance.

The draft Transport Strategy needs to outline a coherent programme of action for
addressing both the issue of PM10 and NO2, pollution. There should also be
recognition that matters are made worse by some of the policies outlined in the
strategy, as there is clear evidence that emissions of PM10s will get slightly worse as a
result of:

•   dropping six monthly black cab inspections;
•   scrapping the western extension of the congestion charge.

However, the biggest backward step would be delaying stage 3 of the Low Emission
Zone, which is one of the few examples of a serious attempt to deal with the impacts of
the rapid growth in the number of light goods vehicles in London needs greater
recognition by both transport planners and policy makers.

I welcome the Statement of Intent’s recognition that further LEZ schemes and charging
systems may be necessary.

Policy 191 “If required to address the challenge, using further emissions control
schemes (eg LEZ) include charges or restrictions on movement for vehicles that do no
meet minimum emission standards.”

Smaller, LEZ schemes with tighter emission standards are essential to deal with PM10
hotspots in central London. However, these higher standards should also deal with
NO2, as that is a far greater challenge for the mayor in future years.

Disability access
I regret the backtracking on physical accessibility to public transport for those with
mobility difficulties. The plans for step free access which have been recently dropped
should be reinstated and a case made to government to provide the money to complete
these projects. It is a significant failure of the mayor’s approach to equalities that 24
underground stations have had plans for step free access deferred until after 2017/18.
Also, the Statement of Intent only seeks to raise the number of accessible bus stops
from 45 per cent in 2009 to just 75 per cent in 2017/18. Given the relatively low cost of




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replacing kerbside facilities, I feel that these should all be completed within the current
business plan period. 1

Investment to improve access to the transport network for passengers with mobility
impairments has been cut, mainly as a result of the severe cost pressure on London
Underground. Hard choices clearly need to be made but the apparent fragility of
commitments to disabled passengers is concerning. Whilst I understand that other
spending areas are also at risk, care should taken to ensure schemes to improve
accessibility are not the first to go when funding is constrained.

Rail priorities
I support TfL’s programme of relatively small scale capacity improvements to relieve
over crowding and to run a metro style service throughout London’s rail system. I
believe that the plans to lengthen platforms, trains and to build additional lines
alongside existing sections of the system are the priority for expenditure. Whilst I
support Crossrail in principle, my priority is completing the package of smaller
improvements, rather than big plans for new links. I feel that the priority for London’s
rail system should be to:

•      relieve over-crowding;
•      establish a metro style service with at least six trains an hour; and
•      improve the orbital links.




Jenny Jones AM
Green Party Member of the London Assembly

Note: This letter sets out the individual views of Jenny Jones in his capacity as London
Assembly member, and not the agreed views of the full London Assembly.




1
    Response to Way to Go, paras 4.20-4.22


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