Category Archives: Transport and Infrastructure

The Richmond Society urges Mayor of London to refuse the latest Homebase, Manor Road proposals

The Richmond Society and The Kew Society jointly submitted a statement of reasons objecting most strongly to the latest proposals to develop the Homebase site in Manor Road.

The two Societies’ joint submission in advance of a GLA hearing sched-uled for 1 October can be read by clicking the image or this link.

The Secretary of State for Housing, Communities and Local Government has issued a holding direction to the Mayor of London confirming that he will call in the application if the Mayor approves the application.

Homebase Site, Manor Road: new GLA consultation – update

The Richmond Society has formally objected to the latest proposals for the Homebase site as part of the consultation closing on 3 September. After Richmond Council refused the application (to which the RS also objected) the Mayor of London exercised his powers to take over as the planning authority and indicated that more affordable housing was required. The current proposals are the second version submitted by the developer to meet that objective.

A public hearing is set for 1 October and the RS and Kew Society are proposing a joint submission given that we are likely to be allowed 5 minutes.

RS’s objections remain the same as originally expressed: over-development of the site because of density, excessive height and pressure on services which already cannot cope in the form of utilities (old gas and water pipes), a reduced bus service round Manor Circus resulting from TfL implementing its proposals to be done in December 2020 and an inadequate train station at North Sheen.Details of the current proposals are available in this press release on Richmond Council’s website. The public consultation runs from 6 August to 3 September 2020 and full details are available on this page on the GLA website.

Copies of the latest proposals are available to view on this page on the GLA website

The texts of the RS’s objections are set out below:

“I write on behalf of the Richmond Society with 1300 members to object to the latest revisions to the Application which are the subject of the current consultation. The proposed changes do nothing to alleviate our original concerns in our objection of 11 May 2019– indeed the problems are exacerbated by the increased height and density proposed with resulting pressure on local services.

The new proposals envisage increasing the number or residential units by 69 to 453 – even greater density.

One block will be 11 storeys, one 10 and two 8 each (compared with the original proposal of 3 blocks of nine storeys each) with additional unspecified height for plant. The new proposals would mean towers nearly double the maximum of six storeys envisaged under the Local Plan. The area surrounding the Homebase site comprises low rise buildings so the addition of the proposed four towers will change the character of the area significantly and result in the site being overdeveloped.

The increased density will put further pressure on local services and amenities just after TfL announced in June 2020 that it will implement changes on which it consulted. These will result in fewer buses in the Manor Road vicinity when the new plans envisage more than 1000 extra residents: surely a lack of a coherent plan. This is quite apart from the financial predicament of TfL and the uncertainty surrounding current rail franchises which threaten the current provision of services.

A development of this size will put additional pressure on the current infrastructure. Water supply here is in poor condition with many of our chalk streams being drained; there are inadequate sewage treatment facilities (the number of CSO spills is appalling); cold water mains, and old gas pipes are unable to cope with existing demands. Indeed in January a large part of central Richmond was without gas for several weeks when an old water pipe burst next to an old gas pipe. 

May 2019 objection: The Richmond Society supports the principle of a residential led mixed use scheme for this site and its contribution to the borough’s affordable housing stock. However, while we recognise the high quality architectural design, we are concerned that the density of development and its consequent height and mass results in the site being overdeveloped. In particular, three buildings of nine storeys (plus the extra unspecified height for plant) is significantly taller than the six storeys envisaged under the Local Plan as the maximum for this location. Furthermore, we understand that the Council has required a car free development for the site, but this suitability must be re-confirmed before a planning consent can be given because TfL’s plans to reduce bus services to Manor Circus. If the bus service cuts are implemented, then it would cause the site’s PTAL (Public Transport Accessibility Level) to fall below 5 – i.e. below the Council’s accepted threshold. Residents have also questioned whether the applicant’s parking stress survey is realistic and this should be verified by reference to the Council’s parking surveys commissioned by the Highways Department for CPZ proposals in 2015. Finally, there is conflicting information in the documentation regarding the site’s red line boundary and it is unclear whether the bus terminus requires s106 protection. That position should be explicitly confirmed noting that The Richmond Society supports improvements to the bus, rail and cycle facilities locally” 

Homebase Site, Manor Road: new GLA consultation

The Mayor of London is running a public consultation on the proposed development of the Homebase site at Manor Road in Richmond..

Last year, Richmond Council’s Planning Committee refused an application for the redevelopment of the Manor Road site currently occupied by Homebase.  There had been 717 objections to the application.

The council’s refusal was based on several grounds, including:

  • the design and scale being visually intrusive, dominant and overwhelming
  • failure to deliver maximum reasonable amount of affordable housing
  • the quality of the proposed accommodation
  • the impact on surrounding properties
  • The Mayor of London subsequently called in the planning application and is now running a public consultation with a view to a public hearing later in the year, provisionally scheduled for Thursday 1 October.

    Details of the current proposals are available in this press release on Richmond Council’s website. The public consultation runs from 6 August to 3 September 2020 and full details are available on this page on the GLA website.

    The Richmond Society will be submitting its comments on the latest amendments made to the application by the developers, Avanton. Copies of these documents are available to view on this page on the the GLA website. Comments should be sent by email to the Greater London Authority at ManorRoad@london.gov.uk by 3 September 2020.

Infrastructure Survey 2020 – Report

Overview

The Richmond Society sought feedback around several current infrastructure concerns using a survey on the Society’s web site. The survey ran for three weeks from June 1 to June 21 and consisted of 10 questions with respondents having a free text response. Its initial promotion was via a Chairman’s email to members followed by periodic mentions using our social media channels.

In total 89 responses were received of which 49 were from members (55%) and 40 from non-members (45%). Some of those non-members joined the Society immediately after completing the survey.

Responses were anonymised before evaluating how the answers addressed the specific theme(s) pre-determined as underlying each question. This evaluation was confirmed using a panel of three Trustees members and two sub-committee members. The anonymisation of responses coupled with a panel review helped to reduce personal preferences being applied to the interpretation of responses.

The aim of the survey was to seek broad reactions and, because the methods and small sample size do not offer statistical assurance, the analysis is presented only with a commentary. The detailed results will however be used to guide the Society’s Executive Committee when forming policy and responding to council consultations.

Results

Question 1

Please comment as a motorist, cyclist or pedestrian about the effectiveness of the social distancing measures currently in place and any problems you have encountered with them.

Objective

To establish whether respondents felt the council’s temporary COVID-19 measures had been effective.

Comments

There was the entire spectrum of responses ranging from “fantastic” to “not working” but, on balance, the views were positive with more than half of members who answered the question supporting the measures. Negative comments tended to suggest that people’s individual experiences might be affected by how seriously other people that they encountered were (or were not) applying the social distancing guidelines.

Several people commented that the one-way arrangement on Richmond Bridge was often not followed and a few cyclists observed that the barriers on George Street had forced them into the traffic stream in a dangerous way.


Question 2

To what extent would you support pavement widening/road narrowing on George Street once social distancing is no longer expected? How might your views change if traffic volumes are not sufficiently reduced and the measures led to more congestion in the town, or displacement to Richmond Green and/or residential areas around Richmond Hill? Do you have suggestions for managing this?

Objective

To gauge the level of interest in wider pavements and less traffic through the town.

Comments

If wider pavements carried no repercussions for traffic, we would expect most people to prefer more space to walk. If a respondent qualified their support with concerns about the impact for traffic displacement and/or increased congestion, they were recorded as preferring to retain the pre-COVID-19 situation.

After applying this criterion, the majority view was opposed to pavement widening due to the concerns about the traffic repercussions. A few people felt that creating a more difficult passage for vehicles through the town might reduce traffic volumes and bring improved air quality while others noted that a single traffic lane could cause traffic hold ups behind buses at their stops.

The council is evaluating different methods for reducing the overall traffic volume passing through George Street. This will seek to encourage vehicles to bypass the town on alternative routes with cameras used to enforce restrictions on certain types of town centre traffic. Those restrictions are not published but may initially be based on levels of exhaust emissions.

As a stakeholder member of the council’s Town Centre Advisory Group (“TCAG”) the Richmond Society has not opposed traffic reduction measures for the town provided traffic is not simply displaced somewhere else and provided business servicing requirements are accommodated. If the planned measures to reduce traffic prove successful and traffic volumes fall significantly, then some people who gave their qualified support for wider pavements are likely to become outright supporters.


Question 3

Should controls be introduced that would require vehicles to give way to pedestrians wherever they choose to cross George Street? If not, do you think additional crossing points are needed and where should they be located?

Objective

To assess the extent of concern about the perceived ease of crossing and whether this was considered enough of a problem to endorse any pedestrianisation initiatives.

Comments

Over half of respondents did not indicate problems crossing between shops on each side of the road wherever they wished. Partly this is because there are sufficient gaps created in the traffic flow due to it being “pulsed” down George Street thanks to the formal crossing outside House of Fraser. There were several comments opposing anything that would require more street clutter and a number along the lines of “leave it alone”.

A couple of people specifically highlighted the dangers crossing Eton Street at The Square. The Society has long flagged this location as a high priority for attention and more recently has supported ideas from the council’s consultants for a road treatment and new layout that would indicate this is shared space where vehicles have a lower priority relative to pedestrians.


Question 4

Do you have suggestions for relieving pavement overcrowding (most especially around the bus stops near Waterloo Place and outside RBS)?

Objective

Free form answer to see what suggestions materialise. Common themes were grouped together.

Comments

Nearly 40% of respondents either did not answer this question, or offered no suggestions. Of those who did give a view, most members suggested moving the bus stops while most non-members suggested wider pavements.

Neither solution is straightforward because TfL sets minimum and maximum distances between bus stops which limits the flexibility for moving them and widening the pavement is awkward where the road width is constrained. However, a few suggestions about moving the Waterloo Place stop to Eton Street might be achievable and remain within the distance limitations if this can be safely included into a redesign of The Square.

Perhaps the most practical suggestion as suggested by three members would be to mark up the pavement with hatching and/or a suitable message e.g. “don’t wait here” or “keep clear”. Coupled with the removal of street clutter and some A’ boards this could provide an easy win.


Question 5

Do you think the right amount of space has been allocated for waiting taxis? If not, should there be more or less space? Are additional taxi ranks needed anywhere else in the town?

Objective

To assess the strength of feeling behind frequent complaints about the space given over to taxi ranks.

Comments

Many people did not answer this question or did not have a view but, of those who gave a view, a small majority was unhappy with the current arrangements and there was no support for increasing the space given over to taxis. Some people commented that formal taxi ranks seem anachronistic in the days of Uber.


Question 6

Does the balance between pedestrians and cyclists on the towpath feel about right? If not how and where should priorities be changed?

Objective

To ascertain the imperative for change given comments about cyclists increased use of the towpath.

Comments

Virtually all respondents answered this question which clearly struck a chord. People tended to show a preference for either the cycling or walking viewpoint with many comments related to behaviours which were often forthrightly expressed.

A strong majority of those who gave a view indicated concerns with the balance of interests between pedestrians and cyclists using the towpath. Complaints were levelled by both cyclists and pedestrians with evident frustration at the current situation expressed by both groups.

Several respondents commented that co-existence on the towpath worked acceptably when cyclists adopted an appropriately low speed in the presence of walkers and there was mutual respect and courtesy. A few people pointed out that the situation was more difficult during lockdown due to cyclists being barred from Richmond Park. Exercising cyclists were therefore having to compete for space with recreational and family cycling groups and with more walkers too.

The tow path is narrow in many places and a few cyclists commented on the danger arising from dogs, while pedestrians referred to being “bullied” and “frightened” by aggressive and rude cyclists (and the risk of injury to their dogs). There were some calls for dedicated cycle lanes and several suggestions that pedestrians should be asked to keep to one side or the other of the path. This latter idea might help to reduce conflict if walkers predictably moved over to the same side of the path until a cyclist has passed and it could allow cyclists to take a safe position earlier instead of trying to negotiate a route through pedestrian groups.

While there were many requests for emphasising pedestrian priority over cyclists, someone did point out that actions tended to be directed AGAINST cyclists and rarely do they seek to remind pedestrians of the need to exercise caution in shared spaces.

After this survey had closed, a petition was started on July 1 asking the council to erect “cyclists go slow shared path” blue signs along the Richmond to Teddington Towpath. The Richmond Society is not in favour of adding signage to the towpath itself, but signage at the entry points to the towpath might be acceptable. The ownership of the towpath is unclear in several stretches and, while it has the status of a public footpath throughout its length, cycling on a footpath without the owner’s consent is not permitted. The council has in the past therefore not wanted to erect signage that could appear to condone cycling where it does not have authority and potentially also give it a liability for maintenance and safety.


Question 7

A secure cycle parking hub is due to be installed in the car park at Richmond Station with significant benefits for cyclists who also commute by train. Given that George Street is one way, are the cycle routes to and from the station adequate? Would you support cycling contraflows – for example on King Street, Duke Street, Richmond Green, or Clarence Street, to enhance connectivity of the town’s cycle network? What measures would you expect to enable these contraflows to operate safely?

Objective

(a) To understand how people perceive the current provision of cycle routes (with a particular interest in the issues for cyclists wanting to travel west from the station).
(b) To collect views about cyclist contraflows given that the council is considering installing these to facilitate connections with Richmond Green and a possible contraflow through The Green. Enabling connections to Richmond Green avoids the need for cyclists to follow the one-way system up Eton Street and it might mitigate against cyclists adopting the George Street pavements as the alternative.

Comments

Nearly half of respondents did not answer the first part of the question about the adequacy of cycle routes to and from the station. Those who did respond supported better provision.

The second part of the question to collect views in response to the council’s emerging ideas for cyclist contraflows elicited more responses than the first part. Among all those who gave an opinion most were opposed to contraflows. A concern commonly expressed related to the inherent danger for both cyclists and pedestrians particularly when narrow road widths reduce the margin for accomodating human error.


Question 8

Do you think the provision of segregated cycle lanes around the town is too little, too much or about right? Would you be willing to see on-street vehicle parking reduced to release road space?

Objective

(a) Segregated cycle facilities in the town are extremely limited and this question seeks to capture perceptions around the standard of provision.
(b) Given that most roads around Richmond are relatively narrow the second part of the question seeks to understand whether respondents are prepared to trade off the provision of segregated cycle facilities with the loss of roadside parking.

Comments

The views for and against having more segregated cycle facilities were mixed, with members who gave a view opposed.

People largely did not respond to second part of the question but, of those who did, the loss of parking to install segregated cycling facilities was accepted. Members who tend to visit the town on foot might be less concerned about the loss of some parking.


Question 9

The Council has suggested locating lockable on-street bicycle parking units on the highway at four places around the town. Up to six spaces inside the locker could be rented by cyclists who do not have secure parking at home. The locker itself will use less than one car parking bay. What are your views about the concept and its design?

Objective

(a) To ascertain support for the principle of having on-street secure parking for bicycles.
(b) The council’s proposals for Bikehangars around Richmond would locate them all in conservation areas and a planning consent would therefore be expected. Residents’ views about the design are therefore of interest.

Comments

There was support for the Bikehangar as a concept, but with concerns regularly expressed about the risks of the Bikehangar attracting theft, vandalism and graffiti and some suggestions that car parks would offer a better and more secure location.

Members mainly avoided the second part of the question relating to the Bikehangar’s design but those who did give a view were deeply opposed to its utilitarian appearance. Several specifically commented that it would be an incongruous addition to the street scene around Richmond Green.


Question 10

Would you support the provision of an electric shuttle bus operating a circular route linking the station with Richmond Park via Richmond Hill? This could help residents with shopping locally and also assist visitors to Richmond Park. To what extent do you think it might ease traffic or parking congestion in Richmond? How should it be funded in the long term?

Objective

This question simply seeks to understand the level of support for an idea that has been mooted before but is not currently in active consideration. Facilitating a link into Richmond Park has gained added relevancy now that the Royal Park’s has announced plans for reducing traffic.

Comments

An electric shuttle bus was the most strongly endorsed idea in the whole survey with more than three quarters of respondents who gave an opinion supporting it. Opposition mainly arose from concerns about the extent of demand, particularly where the route might overlap with bus route 371.

Suggestions for funding a shuttle ranged from the council using parking income to provide a subsidy to a user pay as you go system.

After the survey had closed a Twickenham resident has promoted the idea to the Twittersphere where it also received positive feedback.

The council’s recent action to remove parking on Kew Road prompted some suggestions for extending the route to enable a link for visitors between Richmond Station and the Royal Botanic Gardens Kew. Bus route 65 does of course cover this route with reasonable frequency.

Richmond Society requests urgent holding direction for Manor Road development approval

On 4th February, Stephen Speak on behalf of the Richmond Society wrote to the Planning Casework Unit requesting that the Secretary of State for Housing, Communities and Local Government issue an urgent holding direction to allow a call in of the Mayor of London’s expected consent of the proposed Manor Road development. Here’s his letter.


Richmond Society logo

Dear Sir/Madam,

I write on behalf of The Richmond Society to ask the Secretary of State to place an urgent holding order, with a view to calling in the Mayor of London’s expected consent of a planning application by Avanton Richmond to build 433 residential units at 84 Manor Road, Richmond, TW9 1YB (currently a Homebase and Pets At Home stores).

The Richmond Society is a civic amenity group with over 1,300 members across an area of benefit that incorporates the site.

BACKGROUND

The original proposal for 385 units was refused by London Borough of Richmond (“LBRUT”) in July 2019 under their reference 19/0510 which cited failings under the NPPF, the London Plan and the Local Plan. Subsequently the Mayor of London used his powers to call in that decision and has taken over the duties of the Local Planning Authority.

On 22 November 2019 the developer submitted new proposals directly to the Mayor which are significantly different from, and materially worse than, those previously refused by LBRUT. Despite the 12% uplift in total units, increases in the heights of several blocks, a different community provision and the addition of a new block the Mayor is treating these plans simply as an amendment. There has been no further consultation between the developer and residents regarding the new proposals while administrative errors by the Mayor’s office has meant that previous objectors were informed late about the changes (or in some cases have not been advised at all).

As highlighted below we are concerned that, in the effort, to reach his affordable housing targets for London the Mayor has taken a pre-determined position over this development. His intervention is inhibiting proper scrutiny of these significantly amended proposals, ignoring multiple planning breaches and facilitating the unsustainable overdevelopment of the site. Details of the amended proposals are on the GLA website and can be accessed through this link: https://www.london.gov.uk/what-we-do/planning/planning-applications-and-decisions/public-hearings/homebase-manor-road-public-hearing (or as a shortened version here: https://bit.ly/2RVE0qU).

A public hearing is not expected before February 17, but we are aware that the Mayor has given his planning consent very quickly after call-in hearings having previously agreed the s106 contributions with developers. An urgent holding order from the Secretary of State would appear to be the only way of ensuring that the developer’s amended plans are sustainable and can meet the NPPF’s economic and social objectives.

The key economic concerns relate to weaknesses in the transport infrastructure at this location while the social objective failings pertain to the negative local impact of the design’s height and mass. The principle of building homes on this brownfield site is accepted, although the loss of two major retail outlets is regrettable.

The NPPF expects planning decisions to ensure that developments:

  1. add to the overall quality of the area;
  2. are visually attractive as a result of good architecture, layout and appropriate and effective landscaping;
  3. are sympathetic to local character;
  4. establish or maintain a strong sense of place, using the arrangement of streets, spaces, building types and materials to create attractive, welcoming and distinctive places to live, work and visit;
  5. optimise the potential of the site to accommodate and sustain an appropriate amount and mix of development (including green and other public space) and support local facilities and transport networks; and
  6. create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

In refusing the original proposals LBRUT planning officers found failings under all these criteria and the revised proposals are worse.

The Building Better Building Beautiful Commission was appointed under the late Sir Roger Scruton to advise the government. Its report issued on January 30, 2020 recommends interalia:

Stewardship: Quick profits should not be taken at the cost of beauty and community: “Hence places, not units […], not faceless architecture that could be anywhere.”

Neighbourhoods: create places not just houses. “Too much of what we build is […] overly dense ‘small flats in big blocks’ (on brownfield sites)”.

The amended development proposals are exemplars of exactly the failings that the Commission is urging the government to avoid!

TRANSPORT INFRASTRUCTURE

Census data shows that residents of the local area are already heavily reliant on public transport for travel to work (at 47%).

Network Rail objected to the original application due to concerns over the anticipated levels of rail trip generation. They also expressed concerns that the uplift in rail users and pedestrians will significantly impact on the safe and efficient operation of the level crossing on Manor Road immediately next to the southern boundary of the site. We understood that the expected provision of CIL funds did not overcome the harms identified and it remains unclear whether the developer will adjust this through s106 funding for the new proposals.

The Draft London Plan calls for car free parking provision in all areas of PTAL 5-6. The site currently has a Public Transport Accessibility Level rating of 5 (“excellent”). However, this rating is entirely dependent upon bus services to Manor Circus (just north of the site) being maintained. In December 2018 the Mayor, though Transport for London, issued proposals for cutting certain bus services which, if implemented, would result in the site’s PTAL falling one notch. At PTAL 4 the site would no longer meet the car free standard and the proposed housing density is unsustainable. The Mayor should therefore be required to give a formal undertaking to retain a range of frequent bus services sufficient to ensure that the site’s PTAL 5 rating can be maintained in perpetuity.

LBRUT’s Transport Officer raised concerns over the validity and findings of the developer’s parking survey which was not undertaken in accordance with recommended methodology. Local parking stress was therefore understated and, despite the car free and CPZ proposals associated with the development the reasonable parking needs of its visitors, carers, trades people and similar is simply not available in the wider area.

HOUSING MIX

The draft New London Plan, as amended by the inspectors, sets a 10 year housing target for Richmond borough of 4,110 units. This site on its own would therefore be contributing more than a year’s housing requirement for the whole borough. This intense level of development, plus the recently approved proposals for the nearby Stag Brewery development on the other side of the South Circular Road, plus the nearby sites identified in the Local Plan, is adding cumulative pressure onto a community and physical infrastructure already struggling to cope.

The developer’s revisions mean that the plans now provide for 40% affordable housing and qualify for fast track determination by the Mayor without providing viability information. It is unclear to what extent Mayoral grant is supplementing the developer’s profit at the expense of the community.

Of the 40% affordable homes, 50% are intermediate (split between shared ownership and London Living Rent) with 50% social (affordable rent) broken down by units as follows:

Affordable Housing Mix Studio 1 bed
2 person
2 bed
3 person
2 bed
4 person
3 bed
5 person
3 bed
6 person
Total Units
/ Hab Rooms
Affordable Rent 0 12 21 15 19 8 75
Shared Ownership 0 23 12 23 0 0 58
London Living Rent 0 22 10 6 0 0 38
Total 0 57 43 44 19 8 171 / 483

The developer’s statement goes on to state that gross annual income requirements for the Shared Ownership and London Living Rent are as follows:

Unit Type London Living Rent Shared Ownership 2019/2020
One Bedroom £50,614 £62,765
Two Bedroom £56,271 £80,072

Richmond has met its housing targets under the London Plan and, while more genuinely affordable housing is welcome, the majority of the provision from this development requires that occupants earn salaries out of reach for many in local housing need. The plans are not providing enough of the social rent housing that the borough requires. With so many units directed towards high earners they will (of necessity) need to commute to the better paid jobs in central London. This will load incremental demand onto the already over stretched train network that is accessible from the station nearest to the development at North Sheen.

HEIGHT AND MASS

The developer engaged with Richmond’s Design Review Panel which reported in February 8, 2019 “that the development as a whole represents a jump in scale from the surrounding suburban context. The Panel feels that the proposed height of the scheme density is still overly ambitious.”

Against NPPF and local planning expectations the Panel’s comments appear to have been ignored by the developer and by the GLA. The amended plans have increased the height of three blocks which further emphasises the jump in scale to make the development proposals even more incongruous in the context of the surrounding area.

The unrelenting scale and mass is more commonly found in an urban context and is inappropriate for this suburban location. The nearby conservation areas will always restrict the maximum allowable height of surrounding buildings and cause this development to appear in perpetuity as a monolithic mass.

Vies showing the bulk of the proposed development in the context of the landscape overallIn their planning statement the developer asserts that “mature trees within the Royal Botanic Gardens World Heritage Site at Kew will prevent the amended proposals from being seen.” And “the uppermost parts of the development will be visible from the top of the Grade I listed Pagoda in Kew Gardens.” The picture above shows the view towards the site from the top of the Pagoda. The development will be clearly visible in this panorama as a clustered mass behind and to the left of the Towers. Three of the buildings in the development are equivalent in height to the Towers and so it is apparent that significantly more than just the uppermost parts will in fact be visible. Furthermore, many of the mature trees that the developer expects to block the view from Kew Gardens will lose their leaves over winter. We therefore disagree with the developer’s opinion that the visitor experience and significance of the Royal Botanic Gardens would be unaltered.

While not a locally designated view, the vista from Manor Circus to the greenery of Richmond Park is important and incorporates the spire of St. Mathias church on the horizon as a reference. This view will be blocked due to the height of the development.

Many of the objections raised by LBRUT to the original development are unaddressed by the developer’s amended proposals and have been made worse. In particular we highlight the following comments made by professional planning officers relating to height and mass: (paragraph numbers refer to the LBRUT officer’s report provided to the Planning Committee):

107. The site is not located within an area identified for tall or taller buildings and, overall, it is considered that the scheme fails to demonstrate a thorough understanding of the character and built form context of the immediate area, which the site forms a part.

108. The proposed height across the site is significantly taller than the predominant building height in the area. In particular, the 9 storey buildings in the centre of the site are wholly excessive in height, which will be dominant, overwhelming, unrelenting and visually intrusive, and will result in a looming impression, in particular from Manor Grove, Manor Road, Trinity Road and Dee Road. Nor is it deemed the townscape appraisal and visual assessments provide design justification to warrant such height. [The height as amended is increased to 10 storeys with plant on the roof]

115. The site is within close proximity to designated (Sheendale Road Conservation Area) and non-designated (BTMs on Manor Road, Trinity Road) heritage assets and the height, scale, mass and uniform design of the development would result in an imposing presence and a harmful visual impact on these heritage assets, ultimately resulting in harm to their setting in conflict with the NPPF and LP 3, LP 4 of the Local Plan.

158. The applicant’s Planning Statement identifies the need to protect neighbourhood amenity but does not adequately address considerations regarding the visual impact on surrounding properties. These concerns were expressed to the applicant throughout the course of this application and earlier pre-application process. The applicant has elected not to modify the proposal.

The officer’s conclusion in paragraph 158 rather reflects the developer’s disdain for the local planning process and for affected local residents. The developer has instead made clear from an early stage that they have preferred to work with GLA officers knowing that the plans would ultimately be subject to Mayoral approval. The GLA’s written advice to the developer to build taller in contravention of local policies is suggestive of Mayoral pre-determination for a political aim which would be an abuse of process.

DAY LIGHT / SUNLIGHT

The developer dismisses much of the Daylight/Sunlight impact on surrounding buildings (especially those to the north) because they consider the local VSC component to be atypical for an “urban setting” due to the underdeveloped nature of the site. This disregards the actual situation as experienced by residents and also the fact that it is a suburban site and should be treated as such.

Of great concern to existing residents is that the increased heights and addition of Block E will cause even greater harm especially to nearby properties in the area known as the “Trinity Triangle” to the northwest of the site. The developer’s own reports show their amended development proposals would reduce the proportion of windows in surrounding properties that comply with strict BRE Guidelines (VSC loss of under 20%) from 84% to 79%. Furthermore, residents’ analysis of these reports has highlighted that windows in some affected properties have been excluded – which understates the impact.

IN CONCLUSION

The amended proposals remain in conflict with the NPPF, the New London Plan and numerous policies in LBRUT’s Local Plan.

Paper based Mayoral affordable housing targets are being used to justify the site’s overdevelopment with unsustainable repercussions for the community. The affordable housing contribution does not include enough social rent housing and that should not overrule NPPF expectations for sustainable developments that are subject to proper scrutiny and comply with adopted planning rules.

We request that the Secretary of State issue an urgent holding notice to the Mayor concerning these amended proposals while he considers whether, or not, they should be called in for further scrutiny. We will of course provide further assistance and evidence as required.

Yours faithfully,

Stephen Speak
Trustee

Response to LBRuT Active Travel Strategy Consultation January 2020

GENERAL OBSERVATIONS

The Society supports active travel modes for personal health benefits and the promotion of a better quality of life for the wider community by virtue of improvements to air quality, more reliable journey times and reduced congestion.

Most people fail to register that EVERY journey begins and ends with an element of walking (even if only to walk to or from a parked bicycle or bus stop) and, while it may not constitute the main component of their journey it is integral element of all journeys.

The Mayor’s Heathy Street indicators are a fine aspiration, but they often lump walking with cycling and therefore fail to make a proper distinction between their differing needs and priorities.  This reads across into the council’s active travel plans and targets with walking too often appearing to be the poor relation.

In considering some of the Healthy Street indicators for example:

  • PEOPLE FEEL RELAXED / PEOPLE FEEL SAFE – Pedestrians cannot relax when walking through shared cycling space, or crossing a cycle lane, because they must remain alert to faster moving cyclists.  The increased risk of a collision, most especially for less mobile and visually impaired pedestrians, makes these areas feel less safe and less attractive for those on foot.  In the Richmond specific context these considerations gain extra relevance when the enjoyment of a walk along the towpath is regularly disrupted by demands from cyclists travelling fast and sometimes aggressively;
  • PEOPLE FEEL SAFE / EASY TO CROSS – One-way streets with a contra flow lane for cyclists adds risk to pedestrians crossing such roads.  Cyclists coming from the opposite direction of travel to motor vehicles will be close to the kerb and that leaves little opportunity for either party to take evasive action.  Cycle lanes along the length of a pavement (such as along the A316) require added caution when using pedestrian crossings or alighting from buses;
  • EASY TO CROSS – High levels of kerb side cycle parking can make roads harder to cross by reducing the free space that is available at the edge of the road.

The council’s 2024 target for number of Healthy Streets completed (page 24) therefore does not indicate whether the council will prioritise its investment towards addressing pedestrian or cyclist needs.  Given that this Healthy Streets numerical target is immediately followed by the number of cycle parking places installed and kilometres of cycleway completed, it suggests that pedestrians will not be the primary beneficiary.

However, we also note from the data presented on page 12 that more pedestrians were fatally injured than cyclists both in absolute terms and as a proportion of total injuries for these modes.  The safety imperative for pedestrians should therefore receive high levels of attention.

The following points respond to specific headings in the strategy.

WALKING INFRASTRUCTURE (Page 10)

The council correctly notes the problems for walkers that arise from tree roots and trunk girth, but the strategy does not offer a plan for addressing these.  We are aware of residents in wheelchairs, or parents with buggies, who must leave the footpath and compete with vehicles on the road to get past street trees.

The active management of the Borough’s street trees to reduce this impediment to active travel could legitimately be included as a strategic objective.

STRATEGIC CYCLE CONNECTIONS (page 11 and page 23)

In the context of the Richmond Society’s area of benefit it is unclear why the A316 cycleway that connects the town and Chiswick Bridge appears to have been omitted from the borough’s strategic network map.  This segregated facility already exists and, because TfL has long promised improvements for this section, its omission from the map becomes a curiosity!  It also gives an impression that the local cycle network is less well connected than the situation on the ground.

We are already discussing various cycle route options thorough Richmond Town with officers, but additionally note from this consultation that the council has started design work to make A307 (Kew Road) a strategic cycle route by 2024.  A cycle lane already exists along both sides of this road for much of its length, but the narrow road and pavement widths between Kew Gardens Road and Mortlake Terrace and around Kew Green (when it becomes the South Circular) will make it a challenge to build a continuous segregated facility along the full length of the road and link with CS9.  It’s unclear how the council can overcome this constraint but would question if the absence of a cycle lane through the more dangerous part of Kew Road may negate any benefit from upgrading the rest of this route.  Furthermore, parking is currently allowed in the north bound cycle lane from 10am between Lion Gate Gardens and Kew Gardens Road.  This part time parking is very well used and the arrangement seems to work well balancing the use of the cycle lane for Brentford bound commuters in the morning peak against the parking need later in the day of an increasing numbers of visitors to the Royal Botanic Gardens at Kew (including those that arrive by coaches).  The council must carefully evaluate the repercussions for RBG Kew visitor numbers and the consequences of displaced visitor parking for many residents in North Richmond and Kew if the current volume of on street parking cannot be reprovisioned acceptably elsewhere.

Photo of cycle channel showing some of the problems mentioned in the textRetrofitting “wheel rails” (or alternatively cycle channels/gullies) over pedestrian bridges does enhance cyclist facilities and improves network connectivity but, in many cases, this comes at the expense of a degraded pedestrian experience.  Although a cycle channel is not being used most of the time their constant presence reduces the useable width on the steps which can be a problem on busier and/or narrower bridges for opposing pedestrian flows.  They also make it harder for anyone unsteady on their feet to use the handrail and, because some bridges are poorly lit, the cycle channels are often difficult to see in the dark creating a hazard that can trip, graze or otherwise injure an unwary pedestrian.  Cleaning under the cycle channel is generally desultory which results in an accumulation of decaying leaves, moss and litter.  Cycle channels do offer a solution for cyclists unable to carry their bike, but we urge the council firstly to consider the other options (that may also offer a better cyclist experience) before retrofitting a cycle channel to a footbridge that has been designed for pedestrians.

LOW TRAFFIC NEIGHBOURHOODS (Page 21)

The Society will support interventions that reduce rat running, enhance safety and make neighbourhoods more liveable provided that they are not manifestly unfair to other residents and have predictable consequences.  The council’s recent experience with the East Sheen LTN tends to suggest that it may be a mistake under this strategy to expect to start “most schemes” with experimental traffic orders followed by formal consultation.  We would be concerned that sequencing schemes in this order may cause avoidable neighbourhood angst with the potential for wasting more money resolving and possibly reversing an implementation.  We therefore suggest that LTNs are not imposed on unwilling residents and that there should be a buy in through a consultation process once the ramifications are broadly understood by those most affected.

OFF ROAD WALKING AND CYCLING

We have already noted that in a few places aggressive cycling is harming the enjoyment of walking off road.  For this reason, it will often not be appropriate to remove existing gates and bollards so that cycling is made easier, most especially those installed specifically to slow down cyclists!  At some locations the worthy aim of facilitating better wheelchair access by widening restrictive gaps would also facilitate faster cycling and possibly more use of such paths by powered two wheelers.  With misuse in mind, the council should recall that many gates and bollards were installed at the request of the police or community to ensure that some paths do remain “off road”.

Cycling on the footpath where not permitted is illegal and, because this is a growing concern in and around Richmond town, the Society would support the council enforcing this rule with the same rigour as is applied to a moving traffic violation.

LINKING TO PUBLIC TRANSPORT (Page 26)

We support the council’s aims in the section, particularly in the context of improved wayfinding and cycle parking at Richmond Station, but note that this should not run counter to the long-standing objective of reducing the street clutter in Richmond town.

SUPPORTING OTHER TYPES OF ACTIVE TRAVEL (Page 27)

We absolutely support and encourage the council to pursue a policy of “no loose tiles” in the footpath, but also to extend this policy to cover the timely elimination of trip hazards caused when slabs lift.

Furthermore, there should be more enforcement against vehicles parking on pavements illegally.  Not only does this block the footpath, but heavy vehicles often damage paving slabs.  Photographic evidence from residents should be accepted whenever possible and particularly when the council can make a claim against a land owner for damage caused by construction traffic.

We feel that the strategy is weak in this section because it does not give enough consideration to pavement condition.  This is a particular concern when many Richmond residents are older people who do not want to fall and find that uneven pavements are a major impediment to being able to leave their home independently.  Similarly clearing streets of leaf litter before it turns to mulch and makes pavements slippery is vitally important.  The council might therefore consider adapting the autumn leaf sweeping frequency at specific locations where leaves from certain tree species turn to mulch under the weight of pedestrian footfall faster than they are cleared.

These are public health considerations for older residents that may justify using a share of this budget for pavement improvements.

We note also that a number of roads and pavements around Richmond are increasingly prone to flood.  This is a particular problem for pedestrians who need to leap over puddles and/or risk being soaked by a passing vehicle.  The essential ongoing maintenance that ensures the continued delivery of a good pedestrian experience should also be an integral requirement of the Active Travel Strategy.

CONCLUSION

There is much to support in the Active Travel Strategy and we welcome this effort and opportunity to respond. We do however feel that the strategy gives cycling too much emphasis and a disproportionate amount of time and money relative to the more modest improvements that could enhance the walking experience for more residents.

Heathrow Expansion Public Meeting on Tuesday 23rd July

7:30pm at Duke Street Church, Duke Street, Richmond, TW9 1DH

Heathrow Airport is consulting on its “preferred masterplan” for expansion of the airport and the environmental impact. The plans include the construction of a third runway, modernised use of airspace and additional flights before the runway opens.

Richmond Heathrow Campaign (RHC) is organising a public meeting so that residents, and in particular those from Kew and Richmond, can learn about the plans and the consultation.

Key topics:

  • Heathrow’s expanded operations
  • Noise
  • Air pollution from surface traffic and aircraft
  • Impact on climate change

The panel:

  • Chair, Professor Ian Bruce, CBE
  • Nigel Milton, Director of Communications, Heathrow Airport Limited
  • Cllr Martin Elengorn, Richmond Council, Chair of the Environment, Sustainability, Culture and Sports Services Committee
  • Cait Hewitt, Deputy Director, Aviation Environment Federation
  • Peter Willan, Chair, Richmond Heathrow Campaign

Please email questions in advance to action@richmondheathrowcampaign.org. There will also be an opportunity to ask questions on the night.

Please pass on this information to your friends and neighbours – we look forward to seeing you at the event.

Peter Willan
Chair, Richmond Heathrow Campaign
www.richmondheathrowcampaign.org

Richmond Heathrow Campaign represents three amenity groups in the London Borough of Richmond upon Thames: The Richmond Society, The Friends of Richmond Green, and the Kew Society, which together have over 2000 members.

Local Transport Strategy Implementation consultation response

On 11 January 2019, the Richmond Society responded to the London Borough of Richmond upon Thames’s consultation about the Third Local Implementation Plan for the Mayor’s Transport Strategy.

Questions 1 and 2 covered the details of who we are. Our answers to the subsequent questions comprise our response.

3. To what extend do you support or oppose the objectives of the LIP?

Tend to support.

4. Please tell us the aspects of the Objectives section that you particularly like and why:

We support initiatives that facilitate more walking and cycling – most especially for shorter journeys and when supplemented by a better public transport provision for longer journeys, or when active travel options are not practical or desirable.

We support the aspirations for developing “Healthy Routes” to schools although it may prove hard to derive a tangible benefit at schools located in areas of high traffic flow and pollution.

The move to online shopping and decline of high streets has led to more freight traffic using residential roads and we would welcome action to promote the consolidation of delivery services. We would expect residents of car-free developments to place a high reliance on supermarket and similar household delivery services. We therefore support Council action to obtain a better understanding of freight deliveries and gain tangible evidence in advance of trying to implement changes that may have economic repercussions.

5. Please tell us the aspects of the Objectives section that you particularly dislike and why :

The LIP does not seem to promote an integrated transport strategy – most especially one that recognises the impact of the proposed large scale housing development in Mortlake, Kew and North Sheen. It’s all very well to give blanket support for car free developments in high PTAL areas, but this is a crude indicator that does not consider where residents want to travel to for work, schools and for shopping and social reasons.

Reducing overall levels of car ownership and supporting public transport are admirable objectives but we have some concern about the Council using CPZ’s as “a key mechanism for the borough to influence the number and type of vehicles owned by residents”. For some residents this will be construed as a further tax on the less affluent while those with off-street parking would be exempted. Furthermore, the Council allows motorcycles to park in a CPZ without a permit, but it is unclear whether encouraging a shift to P2W vehicles is a desired policy objective or unintended consequence. It will also be a simple matter for residents of car free developments with s106 restrictions on CPZ permits to park their P2Ws in a CPZ space.

There is an important distinction that is not well made between reducing people’s use of private cars versus their ownership of a private car. While discouraging ownership might be a good thing, not every trip can be accomplished on public transport – moving heavy things or taking the elderly to hospital for example. For those type of journeys car clubs and taxis provide an important public service. However, because the Mayor doesn’t consider car clubs, taxis or private hire vehicles to fall within the “Public Transport” category any trips using these methods are meant to be subject to the modal shift aims when this may not be appropriate.

Average bus speeds are quoted in the LIP as being typical for outer London but the Council nevertheless intends (yet again) to review the operational hours of existing bus lanes. The slower and more unreliable aspects of a bus journey for a passenger will often be time spent at bus stops and in taking convoluted routes of no benefit to most riders. An origin and destination study to evaluate the appropriateness of bus routes and, most especially, to establish the feasibility of express bus services may be a better use of resources and ultimately prove a better way to entice more bus passengers.

6. To what extent do you support or oppose the delivery plan?

Tend to support.

7. Please tell us the aspects of the Delivery Plan section that you particularly like and why.

We welcome the Council’s desire to increase understanding around freight and servicing activity. However, we are concerned about comments in the text that pre-suppose a desire to reduce freight traffic before knowing the economic impact.

We are pleased that the council intends to work with local community groups to ensure that projects are in the right locations and include the improvements most needed by local people.

8. Please tell us the aspects of the Delivery Plan section that you particularly dislike and why:

Walking issues

The LIP gives no priority to improving the physical condition of local pavements which is disappointing given that they are an essential requirement for this purpose. Uneven and/or narrow and/or cluttered pavements make it unappealing to walk particularly for older or disabled people, or those with children and pushchairs, or with parcels to carry. There are locations where poor management of street trees has made it impractical for many people to use the footpath and this should be addressed.

In delivering the MTS objectives for walking, cycling and public transport the Council should give close attention to the needs of older people across the borough. What a younger person may see as an easy journey can include insurmountable obstacles for the elderly. Furthermore, even the most able bodied may occasionally need vehicles to move large or multiple items.

CPZ issues

We are not comfortable with CPZs being used as a tool to implement Council policies and to raise excess revenue from those who are simply struggling to find on street parking space near where they live. Not everyone who parks on the street is affluent and properties with off-street parking would not be subjected to the same constraints.

Some residents need vehicles to work, not only those who may be employed at some distance from the borough, but also those who provide support services locally. That can include care workers visiting elderly or disabled residents in their own homes and trades people such as plumbers and electricians who provide essential support services. The cost of services to residents is also increased when there is a requirement to pay for parking in a CPZ. Furthermore, car dependency tends to be higher in areas of the borough with lower PTAL ratings.

Poor Integrated Thinking

The MTS does not consider Private Hire Vehicles to be part of “public transport” in spite of their benefits in reducing levels of private car ownership and helping to offer an integrated transport solution, especially in areas with low PTALs.

The draft LIP advises that the Council expects to control car ownership and drive public transport use through supporting car-free developments in high PTAL locations. The Council also seems to indicate support for TfL “re-shaping” the bus network to meet changing patterns of demand. Unfortunately, TfL’s recent consultation about curtailing bus services to Manor Circus suggests there is a disconnect between the Council and TfL on these issues. Reducing the PTAL around Manor Circus would work against the Mayor’s objectives for car free housing while also reducing the public transport experience.

The LIP states that the Council will seek to minimise the impact of the level crossings on pedestrians and cyclists but doesn’t mention working with Network Rail and the train operators to reduce dwell times for motor vehicles. This seems like an odd omission given the significant benefits for reducing congestion and pollution.

The funding submission to TfL (as detailed in Appendix 2) does not appear to be following the current MTS categories.

Cycling

The LIP indicates multiple benefits arising from the recent introduction of dockless bikes, but the evidence raises doubts about Ofo’s operational capability and whether the scheme is viable in the longer term.

There is no discussion about the growing number of electric scooters including whether they should be supported as a part of the local travel mix with rights to use pavements or cycle lanes.

The LIP confirms the Council’s wish for more contra-flow cycle lanes and greater use of filtered permeability, but we would request that these only be implemented having taken full account of local knowledge and support.

ULEZ

The LIP states in several places that the Council supports the expansion of the ULEZ to the South Circular. Previously the Council has pushed for the ULEZ boundary to be located further out and has consistently opposed using the South Circular as the ULEZ boundary because it would bisect the borough, put Townmead dump inside the ULEZ and divert higher polluting vehicles into areas that already struggle with poor air quality. We are opposed to the South Circular becoming the ULEZ boundary and consider that the Mayor is simply taking a cost/benefit decision that requires Richmond to bear the costs without any benefits.

New Thames Bridge consultation response

On 4 January 2019, the Richmond Society submitted its response to the London Borough of Richmond upon Thames’s consultation about the possibility of building a new pedestrian and cycle bridge across the River Thames.

Questions 1 and 2 covered the details of who we are.  Our answers to the subsequent questions comprise our response.

3  Do you support the idea of a new pedestrian/cycle bridge across the River Thames in the borough?
Don’t know

4  Do you have a preferred location for a bridge from the five areas shortlisted in the feasibility study?
Bridge 13 (between Radnor Gardens and Ham Lands)

5  Of the five shortlisted locations, the feasibility report identified two potential sites as the most beneficial. Do you have a preference between these two locations?
Yes, bridge 13 (between Radnor Gardens and Ham Lands)

6  What do you think would be the benefits of your preferred location?
Provides Ham residents with easier access to the local facilities and greater transport options available in Twickenham. Strawberry Hill and Twickenham residents would gain easy access to green space at Ham lands. Allows easier access to a wide range of accommodation in Ham for St Mary’s students and staff.

7  Do you have any concerns about the sites and locations?

The capital cost comparisons appear to have been based on a cable tied construction with supports of up to 21m, approach ramps with a 1:20 gradient and a deck width of 4.5m. While this may not be the final design it is apparent that any option would require substantial space and be intrusive into the landscape. Furthermore, we understand that the height requirements of bridges in the tidal stretches may have been underestimated by up to 2m as they are not allowing for navigation during high tides. Based on a 1:20 gradient that adds significant extra length to the approach ramp requirements, most especially if they are also designed to offer a dry route during high tides.

At Richmond Bridge the police have expressed concerns about the risk of a pedestrian and cyclist collision resulting in someone being pitched into the river. This risk must be mitigated for these bridge proposals and open clearance of 3.5m on the over water deck may feel a bit tight for a combined two way flow of pedestrians, pets and cyclists.

With regard to bridges 15 and 13, the consultants appear to have used a narrow interpretation of the width of the protected views from Ham House and Richmond Hill and determined that neither of these bridge options would have an impact. We think this is optimistic and, while designs are yet to be produced and the impact is not known, The Richmond Society could not support any proposal that impinges on protected views. The views from the riverbanks back towards Richmond Hill are also important.

These bridges and their approach routes would need lighting at night. This creates concerns about light spillage into the river and/or into currently dark areas used by nocturnal wildlife (which includes protected species).

The report notes a possible impact of bridge 15 on Hammerton’s Ferry which would represent a loss of heritage and be contrary to the economic benefit aims. The Council should also consider the applicability of views raised during the campaign against developing a boathouse at Orleans Gardens..

8  How often do you think you might use a bridge at your preferred location?
Don’t know

9  Do you think a bridge would help you walk or cycle more?
Don’t know

10  Please tell us about any design elements that should be taken account of:

Designs must not impact on the views from Richmond Hill protected by an Act of Parliament.

Irrespective of any legal issues around permitting cyclists to use the towpath careful consideration should be given to mitigating the environmental impact that will arise from a more intensive use. There are particular issues at Petersham where the path is narrow, underwater at high tide and has retained its undeveloped appearance.

11  Please use the space below to provide any final comments or tell us of any considerations you think the Council would need to examine.
The Richmond Society is a civic amenity group representing over 1,200 residents across an area of benefit extending from the Thames in the west to Chalker’s Corner in the east and including Richmond’s town centre. None of the bridge proposals is physically located in the Society’s area of benefit and our concerns therefore relate principally to the visual impact from Richmond Hill and repercussions for the towpath.

Bus route changes consultation response

The Richmond Society has responded to Transport for London’s consultation about proposed bus route changes in Richmond.

1) Loss of service along the A316 corridor between Richmond and Manor Circus.

The proposals to withdraw the H22 and 493 service along this stretch would appear to remove 11 buses per hour between Richmond and Manor Circus during peak periods (a reduction of 40% in the current service).

TfL state that, because routes 190, 391, 419/110 and R68 offer 17 buses per hour, this will continue to provide sufficient capacity to meet demand. However, that capacity would only be available at a reduced frequency, meaning longer wait times and more passengers having to change buses to complete their journey.

It seems particularly inappropriate to consider reducing capacity when significant population growth is occurring along this stretch of the A316 corridor. The fact that Sainsbury’s large supermarket is located at Manor Circus, serves this expanded population, and is highlighted for residential development in the Local Plan should all be relevant considerations.

Furthermore, a loss in bus service frequency negatively affects the PTAL of other nearby development sites for which planning decisions have recently been taken, or are forthcoming. It would especially affect a current proposal to develop 400 units on the Homebase site immediately south of Manor Circus. This development (see www.avanton-manorroad.com) is proposed to be car free, but a reduction in bus services to Manor Circus potentially reduces the site’s PTAL from 5 to 4 – causing it to fall below the council’s stated threshold for acceptability as a car free development. Reducing bus services to Manor Circus therefore works against a coherent and sustainable Mayoral strategy for new housing.

2) Comments on specific routes

i) H22 – The loss of bus capacity connecting Richmond and Twickenham town centres via Marble Hill would be retrogressive and mean a reduced service to Orleans School and the Civic Centre. It is important to know what repercussions this change could have for a modal shift away from public transport, for congestion in both town centres and across Richmond Bridge and consequently also for the reliability of other bus routes.

ii) 493 – At present this route assists a significant population cluster around the A316 who need to visit the hospitals at Tooting and Roehampton. If the service to Manor Circus is withdrawn as suggested then TfL is expecting potentially less able residents to transfer buses and/or walk substantially greater distances to connect with an essential service. The Hopper Fare cannot be guaranteed in perpetuity and does not mitigate against the added difficulty while breaking a journey to transfer buses will never represent a better service.

iii) 419 – Incorporating this service into a substantially lengthened route 110 is a concern if the extended journey time negatively affects service reliability. However, the proposed routing via Chertsey and Whitton Roads is very welcome, not least because it simplifies the ability of Richmond students to reach the new Richmond upon Thames School on A316. However, Richmond residents travelling to and from West Middlesex Hospital will get a worse service.

iv) 371 – Although not part of this consultation, it is worth reiterating requests for this route to connect with Kingston Hospital. This becomes even more pertinent if travel to other hospitals is more difficult.

3) Existing service deficiencies are not addressed

These proposals do not address the poor bus service currently offered along the Lower Richmond Road (i.e. between Manor Circus and Mortlake). This existing service deficiency will become more acute once the large Stag Brewery development and secondary school are built in Mortlake.

We support the representations to extend the 219 bus service from the Avondale Road terminus, past the Stag Brewery site and Chalker’s corner either to Kew Retail Park (itself also due to be redeveloped for housing), or to Richmond. The Mortlake school is planned to serve students living in Kew and North Richmond and they will need a much improved bus service between these areas.

In summary the Richmond Society does not support curtailing existing services. We do not consider that this meets TfL’s stated objectives of providing a better bus service by improving the experience for customers, or in supporting housing growth.