Response to Brent Council Draft Local Implementation Plan (LIP3)December 16, 2018 0 COMMENTS
We recently responded to Brent Council’s Draft Third Local Implementation Plan (LIP3). LIPs are one of the main routes for council funding outside of specific TfL schemes. The London Cycling Campaign has a a lot of guidance on LIPs and how to respond as a local group.
We responded in detail to the relevant sections of the Draft LIP.
This is the response of Brent Cyclists, the local group of the London Cycling Campaign in Brent. We represent circa 200 Brent resident members, 300 supporters, and anyone else who cycles or would like to cycle more in the borough.
Overall the Brent Council Draft Local Implementation Plan 3 is poor. It plans to miss many of the targets set by the Mayor of London including for road safety, cycle infrastructure, pollution reduction, and active travel. The wording of the bulk of the report is promising, highlighting the problems associated with motor vehicle culture, and the role of cycle infrastructure can play in improving society. However, there are few if any concrete proposals which will achieve some the aims described.
Overall the strategy misses key objectives which must be included for Brent to ever be considered a borough which treats active travel users well:
– The strategy must have a target to build a defined distance of protect cycle track on main roads.
– The strategy must have a target to deliver a defined number of cycle parking spaces.
– The strategy must state where new or improved crossings of main roads for pedestrians and cyclists will be built.
– The strategy must highlight where new school streets are proposed for Brent’s school children to walk or cycle to school.
– The strategy must consider introducing a Low Emissions Zone, possibly within the entire borough, or within the North Circular.
– The strategy must state how road works will consider active travel users, for example not requiring pedestrians to cross busy roads, and not using “Cyclist Dismount” signs.
– The strategy must state that all new cycle routes will meet a minimum standard, preferably the London Cycle Design Standards.
– The strategy must state the borough will consider making all one-way roads two-way for cycling as standard, with limited exceptions.
– The strategy must consider freight consolidation to reduce HGV movements on local roads.
– The strategy must state that all new developments will be car free, and that no new on street parking will be created in Brent.
– The strategy must state that Brent will actively work to reduce on street car parking.
– The strategy must consider the road user hierarchy proposed in the Mayor’s Healthy Streets plan, prioritising active travel.
– The strategy must propose 20 mph as the standard speed limit for all borough roads, with few exceptions.
We comment in detail on sections of the report below.
2.3. Changing the transport mix
We support the aim to change the transport mix in Brent. We support highlighting the role motor vehicle culture plays in poor air quality, congestion, deprivation, safety, and public health. This section fails to highlight some key points:
– if 68% of households in the N. of Brent own at least 1 car, then 1/3 of all households in the N. own no car, typically disadvantaged households who can be left in transport poverty by lack of choice.
– Brent has seen a 45% reduction in KSIs over an 8 year period, however this may be due changes to safety of motor vehicle occupants, not improvements to the safety of vulnerable road users. In fact vulnerable road users may have been scared away from areas where KSIs occurred previously.
– This section completely fails to mention the need to restrict motor traffic and improve physical and subjective safety for vulnerable road users. e.g. filtering local roads, building cycle infrastructure, improving pedestrian crossings.
2.4.3. Outcome 1: London’s streets will be healthy and more Londoners will travel actively
– We are supportive of the statement that “the council will prioritise and promote walking and cycling for short trips” (22.214.171.124.5.). This must focus on “Developing and maintaining safe, convenient, efficient and attractive transport infrastructure conducive to cycling and walking.” The word “promote” should be removed from (126.96.36.199.5.), promotion has no effect on public choice, only infrastructure and motor traffic restriction will make cycling and walking more attractive.
– We are concerned with (188.8.131.52.6.). There is no obvious attempt by Brent Council to build a network, only disjointed routes or minor changes. A network means joined up thinking and joined up safe infrastructure.
– We support the inclusion of (184.108.40.206.9.)
– We support the introduction of dockless bike hire in Brent (220.127.116.11.3.2.). This should occur asap, preferably by Summer 2019.
– We support highlighting Carlton Vale in (18.104.22.168.3.3.), this must not be the limit of the Council’s ambition.
– We do not recognise the benefits of QW3 (22.214.171.124.3.4.), excepting the new path through Gladstone Park and minor road surface improvements.
– Overall (126.96.36.199.3.) does not commit the Council to building any new cycle infrastructure. This is a complete failure of opportunity.
– We support the aim to free kerbside space for cycle hangers (188.8.131.52.5.2.). The council should act actively to restrict the use of kerbside space by private motor vehicles.
184.108.40.206.1. – The borough has recognised the role of poor road safety and perceived safety in suppressing cycling.
220.127.116.11.19. – We support the aim to have clear, direct, walking and cycling routes through neighbourhoods.
– This section completely fails to identify the need for improve cycle and walking infrastructure for safety.
18.104.22.168.2. fails to recognise the role of active travel and public transport, only identifying low emissions vehicles, which have no impact on road safety, public health, or congestion.
We support the aim of (22.214.171.124.6.5.). Brent must aim to actively reduce on street parking to free space for active travel.
126.96.36.199. completely misses the role of cycling and walking as “sustainable modes”, and only discusses public transport, without even considering interchange between public transport and active travel.
3. Delivery Plan
We are very disappointed that only one cycling intervention is identified, and this a Quietway, which will amount to little more than signage (on previous experience). Brent must be more ambitious.
We are supportive of the inclusion of two Liveable Neighbourhood plans, in Kilburn and Park Royal. Brent must be ambitious in restricting and reducing motor traffic movements in these areas, and improving facilities for walking and cycling. A budget of £10m per liveable neighbourhood could include 20mph across entire areas, filter all residential roads to make them non-through-routes to motor traffic, and improve main road crossings for pedestrians and cyclists.
We are pleased to see a Borough wide 20mph strategy in the long term strategy. This should be brought forward as a way to help meet most of the transport and health aims of the LIP.
We hope that “Neasden Transport Improvements” will include a new pedestrian and cycle crossing of the North Circular.
We are supportive of identified funding for “Walking and Cycling Supporting Engineering Measures”. However, we are concerned that £220,000 pa will be insufficient to meet the aims of a cycling network.
We are concerned that no funding is allocated for the “Borough cycling programme”.
We note the inclusion of the LSCN in this section.
We are concerned that the borough is relying on changes to motor vehicle technology to meet air quality targets, not planning to limit motor vehicle movements.
The targets set in Table ST07 fail to meet the Mayor’s Transport Strategy, for example a woeful 33% of Brent residents doing “at least the 20 minutes of active travel they need to stay healthy each day”. Brent Council is effectively committing to 2/3 of Brent residents living an unhealthy lifestyle, forced upon them by the available transport modes.
The plan to set a target for the proportion of residents with access to safe and pleasant cycle network by defining this according to the already planned routes is completely back to front. Brent should observe the Mayor’s Trajectory Targets, and build cycle infrastructure to meet or exceed these targets. Further, claiming that a Quietway will meet the “safe and pleasant” requirement is setting this up for failure, Quietways, as built in Brent, do not reduce motor vehicle traffic sufficiently to be “safe and pleasant”.
The plan does not aim to eliminate all deaths and serious injuries from Brent streets, in direct conflict with the Mayor’s Transport Strategy. The plan aims to have 79 KSIs, that is aims to have 79 people killed on injured on Brent’s roads, in 2041, albeit a reduction from currently KSI rates. Accounting for differences between the Mayor’s plan and Brent’s plan, Brent aims that 328 more people will be killed or seriously injured than under the Mayor’s plan through to 2030.
Further, Brent plans to miss the Mayor’s targets for: reduction in motor vehicle kilometres driven; reduction in car ownership rate; trips by public transport; average bus speeds; reductions in CO2, NOx, and Particulate emissions.