This is the response from Brent Cycling Campaign to the consultation above referenced.

Brent Cycling Campaign is the local group of the London Cycling Campaign. We directly represent about 250 supporters in Brent, and we represent all those who cycle or would like to cycle in the borough. We speak up for a greener, healthier, happier and better-connected environment.

We oppose this scheme.

Whilst addressing the need to make this area nicer, the proposal is shockingly poor for cycling. This scheme will not deliver on the objectives originally set out, nor lead to changes in accordance with the
Council’s own target of 5% cycling modal share by 2025 as detailed in Brent Council’s own Long-Term Transport Strategy .

This proposal does not align with the Mayor’s Transport Strategy which aims at 70% of people living within 400m of a high-quality cycle route by 2041. Any new schemes should closely follow those principles in order to meet these objectives. With 13,190 vehicles per day on the Kensal Corridor, this proposal also goes against TfL’s own guidelines for cycling provision quality criteria , which recommend against mixing cycling with level of motor traffic over 500vph at peak times without separation. On
Chamberlayne Road, in the morning, there are 710vph going southbound, and 429vph going northbound and in the evening it’s 781vph/826vph. Through motor traffic represents 50% of all traffic and buses 5% of
this.

This scheme does not follow the Healthy Streets approach, failing partly or completely on most indicators: inclusive; clean air; relaxed; things to do and see; feel safe; people choose to walk or cycle; not too noisy; places to stop and rest; shade and shelter; and easy to cross). We also note that the objectives have changed from the first plan (2016) which were:
● Number of buses, impact on the local environment, and air quality,
● Congestion,
● Road danger.

Objectives (2019)
Improve bus facilities, movement and accessibility.

The latest design proposal and subsequent meetings with consultants have failed to demonstrate how this objective will be achieved. The main cause of delays for bus movement is the excess of private motor through traffic vehicles using Chamberlayne Road. This scheme does not seek to address this.

Improve Kensal Rise station access / interchange.
Apart from cosmetic improvements, pedestrians and bus users will not see a big change when accessing the station. For people cycling, the idea of a contraflow on Station Terrace to access the station directly from Chamberlayne Road seems to have been dropped. Instead, it has been suggested that people would have to go around the back streets. This is not acceptable. Cycling is a mode of transport in its own right. In addition, contrary to driving private motor vehicles, cycling is part of the solution for any urban environment improvements. Cycling needs to be made convenient and direct.

Improve the environment and provide improved crossings for local residents, businesses and visitors/Widen pavement to facilitate walking

A few more crossings will not change the fact that the volume of motor vehicles, with all its unpleasantness of noise, pollution and road danger, will remain the same. Local residents and visitors will have to make do with new inset parking bays, taking space from the newly widened pavement. Even with time restrictions for parking, the issue as always will be enforcement. The scheme fails to demonstrate how the environment will be improved. Buses currently using Chamberlayne Road are diesel. They are
often idling either at a stand or stuck in traffic. Since through-motor traffic is not addressed, congestion will continue to occur and so will stationary, stop-start polluting traffic.

Add new bus shelters and widen waiting areas

The priority should be to shield bus users and other road users from pollution. This proposal fails to reduce or remove pollution as its main cause (excess through motor traffic) is not addressed. We are concerned that the scheme may encourage users of the Kensal Corridor to spend more time exposed to pollution.

Reduce congestion and associated pollution

The scheme and subsequent meetings with officers and consultants failed to demonstrate how this is going to be achieved. There is no evidence that straightening and narrowing a road lay-out will lead to reduced congestion and pollution. There is plenty of evidence that the way to achieve this is to reduce through-traffic and prioritise people over motor traffic. Having cleaner buses would help too.

New cycle lanes, cycle parking and improved accessibility

The proposed provision for the very short and disconnected protected cycle lane makes little sense and will not improve conditions for people cycling. As proposed, buses and individual motor traffic will be allowed to drive over the cycle lane leaving Station Parade. This will create conflict and damage the surface of the narrow lane. This will deter children and less confident people from cycling on Chamberlayne Road just as it is at present. Where there will be no provision, It will make it more dangerous for people cycling as the road will be narrower and straightened. This will make aggressive close passes more likely and there is a risk that motorists will go faster.

When we queried the absence of provision on the rest of the corridor with the consultants, the reply has consistently been that “ people should cycle in the middle of the road as it is their right.” This is not only wishful thinking, but denotes a serious failure to understand the reality of cycling in a road with over 700 vehicles per hour at peak times, which is a cause for grave concern.

The painted cycle lane will not provide the protection needed on this specific location with the level of traffic recorded. It does not connect to anything. Chamberlayne Road has been identified by TfL in its Strategic Cycling Analysis as a high potential cycling route, it is therefore a missed opportunity that the current improvement scheme isn’t more ambitious and doesn’t aim to implement changes now that would benefit the entire area, in line with the Mayor’s Transport Strategy and Healthy Streets’ core principles. We understand the restrictions due to width and requirements for bus traffic, but the solution then, should be to reduce the level of motor traffic with measures that are proven to work.

Information over the segregated cycle lane has been patchy and unclear. The illustration provided doesn’t seem to relate to a kerb intervention. We reiterate the need for good practice with regards to protected infrastructure. In addition to providing protection to vulnerable users, they should make it very clear that they preserve priority for people cycling on main roads with dense traffic and they should have an absolute minimum width of 1.5m.

In the absence of details with regards to the kerb we would like to point out the need for a ‘forgiving kerb’ to avoid the risk of wheel clipping, angled at less than 45° to level, and preferably at ~30° to level. This benefits people cycling, who can use the full width of the track, and people walking, who can cross the road more easily. Given the narrow width of the proposed mini protected cycle lane, we suggested that perhaps some intermittent wand orcas might be better than a kerb. The space in between would allow faster riders to, choose to take the main carriageway to overtake others cycling on the narrow protected lane.

The risks of left hooks, where motor vehicles turn left into a cyclist proceeding straight ahead, has not been addressed at any locations and this is a significant concern. Advanced Stop Lines do not count as improved cycling conditions. These are often inaccessible or occupied by motor vehicles and they lead to dangerous situations because they encourage people cycling to approach junctions in the blind-spot of large vehicles.

We suggested during a visit on site in the summer of 2018 the addition of a parallel crossing leading to Ibert Street. This would enable people cycling to cross safely over the filtered road in Westminster. We reiterate this suggestion. The filtered road is currently not usable due to parking, we suggested the removal of one parking space and reallocation of that space for people cycling.

We welcome the additional cycle parking facilities. We pointed out to the need to also provide inclusive facilities to accommodate non-regular cycle users and referred to the latest Inclusive Cycling Guide published by Wheels for WellBeing.

Improve road safety

This proposal will do little to reduce road danger. Danger comes from motor traffic, the level of which will be the same. Vulnerable road users, who represent half of all victims of road crashes at this location,
will still have to move along the road with the same level of traffic. Furthermore, the pavement level parking bays will blur the distinction between pedestrian space and motor traffic space. There’s also the
risk of abuse prompted by the lack of enforcement.

Introduce a 20mph speed restriction between Mortimer Rd and Harrow Rd junction making the whole corridor 20mph.

This is welcome, however enforcement is the key in such restriction. We suggest a borough wide approach to 20 mph rather than the piecemeal approach continued by this scheme.

Improve parking and loading facilities for local businesses
What evidence has been used to determine that parking for motor vehicles is necessary on Chamberlayne Road? There is plenty of research that shows the economic benefits that a pleasant shopping destination has on businesses. Where shoppers and visitors can stay longer, where shops are
conveniently accessible with a low risk of road danger, where people can shop and rest at will without stressing or being exposed to pollution. Given the current climate emergency, which Brent has recently declared, every effort must be made to enable people to leave their cars at home and spend time enjoying their local high street rather than driving to distant shopping complexes. One of the key pledges in the Mayor’s Transport Strategy is that 80% of all journeys in London will be done by walking, cycling or taking
public transport, not by car or taxi or private hire vehicle by 2041. Any new schemes should take this into consideration.

Improve the public realm and provide quality including new pavements and carriageway resurfacing
Quality pavement will not be enough to mitigate the effects of the current impact of through traffic and associated pollution. One of the most polluted primary schools in London is located on Chamberlayne Road, and even if the children walking to school will enjoy the new pavement, we are confident they would prefer fully working lungs as well as being free from respiratory illnesses that will affect their entire life. This must be prioritised over cosmetic changes.

Develop community greening schemes including greening to Station Terrace and a series of pocket gardens along the high street
The proposed pocket parks will be where the existing modal filters are. We have been given mixed answers over the fate of those fully functioning bollards. Since they do not appear on the design available for this consultation, we are concerned that this omission will result in the construction team removing them and not replacing them with anything to ensure the current effective filtered permeability.

Pocket parks are nice, but given the most urgent issue of the level of motor traffic, road danger, lack of active travel, and pollution, we suggest these purely cosmetic changes are not a sensible use of funds.

We understand that some members of the local community are happy to be involved with the greening schemes however, it is surprising that maintenance and upkeep will be left under the responsibility of
local residents. One would have thought that with the level of funding awarded for this scheme, there would be some provision to ensure continuity of care from the council rather than relying on the good
will of local residents.

Declutter redundant signage
This is to be expected as part of any scheme and it is surprising to see this as an objective.

Work with TfL to optimise the operation of traffic signals at existing junctions.

We haven’t been given many details over this and the leaflet which will form the basis upon which residents will decide whether to support this scheme or not does not contain any information about this.

Other relevant statistics from the Council’s Long-Term Strategy (2015-2035) (1):
● 84% in Brent support more walking and cycling (1)
● 94% place “road safety” as the main barrier to cycling (1)
● 92% in Brent want high streets to be more attractive (1)
● 89% in Brent want better air quality (1)
● 50% of Brent households do not own a car (London Transport Demand Survey, 2016/2017)

For reference, here’s our response to the consultation last year.
We would like to reiterate the urgent need to think again and address the fundamental issue of cutting through motor traffic as this is key to successfully implement the objectives as set out by this scheme.

Although a beautification exercise is certainly welcome, this should not be the priority, reducing pollution, reducing road danger and enabling active travel must be Brent Council’s priorities on the Kensal Rise Corridor.