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.


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.


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.