This is the response to the consultation (ended 1 February 2021) from Brent Cycling Campaign, the Brent group of the London Cycling Campaign. We represent around 300 supporters and 200 members who live in Brent, and we attempt to represent the interests of all those who cycle, or would like to cycle, in NW London.

Brent Cycling Campaign welcomes any attempt to improve conditions for pedestrians and cyclists on Kilburn High Road. However, we feel that the current scheme does not do enough to improve the very poor cycling experience on this road.

Short, discontinuous sections of mandatory cycle lane operational for only limited times, as we see in the plan for the southbound side of the road, plus discontinuous, part-time bus lanes for the northbound side, are very disappointing proposals, at odds with the DfT’s latest instructions to councils in the Network Management Statutory Guidance (updated 12 January 2021):

Local authorities in areas with high levels of public transport use should take measures to reallocate road space to people walking and cycling.

…..They include:

• Installing cycle facilities with a minimum level of physical separation from volume traffic; for example, mandatory cycle lanes, using light segregation features such as flexible plastic wands; or converting traffic lanes into cycle lanes (suspending parking bays where necessary); widening existing cycle lanes to enable cyclists to maintain distancing. Facilities should be segregated as far as possible, i.e. with physical measures separating cyclists and other traffic. Lanes indicated by road markings only are very unlikely to be sufficient to deliver the level of change needed, especially in the longer term…..
  
• ‘Whole-route’ approaches to create corridors for buses, cycles and access only on key routes into town and city centres

The proposals we are asked to consider here amount, so far as they affect cyclists, only to road markings, as decried in the DfT instructions above. Though these instructions are a response to the COVID crisis, they are fully consistent with the ongoing guidance in the DfT Local Transport Note 1/20 Cycle Infrastructure Design:

On busier and faster roads, which are usually the most direct routes between places, it will be necessary to provide dedicated space for cycling. Facilities that provide physical protection for cyclists are preferable to cycle lanes. It might be necessary to reallocate some road space from moving and/or parked motor vehicles to allow good quality cycle facilities to be installed. Dedicated space for cycling should continue past bus and tram stops but here and in other places it is essential that the needs of pedestrians are taken into account, particularly disabled people. Cycle facilities should preferably be located between parked and service vehicles and the footway. Access for these vehicles will need to be considered in any design.

(Forward to Chap. 6)

In addition, the A5 (i.e. including Kilburn High Road) has been identified by TfL as one of its top priority strategic cycling connections in its Strategic Cycling Analysis report 2017 (fig. 2.4 p.23)

In view of all this, we call for (at minimum) a continuous segregated cycle lane on the southbound side of the road between West End Lane and Greville Place without any compromises for parking or loading. The response to this consultation from Camden Cycling Campaign has discussed in more detail the dimensions on the road and how this could be fitted in. There is no doubt that it could be. The plans show extra lanes for motor traffic between the junctions with Belsize Road and Cambridge Avenue, and also between Kilburn Priory and Kilburn Park Road. If cycling is to be genuinely encouraged and prioritised over motor traffic, this space should be allocated to cycling, not used to increase the motor traffic capacity of the road near junctions. This approach just ‘bakes in’ the current modal shares, by giving cycling ‘leftovers’ where convenient. In addition the central median islands proposed are a waste of space that should be given to cycle lanes. If a crossing point for pedestrians is required here, it should be a formal one, with a crossing of the road in one stage, rather than making pedestrians run between the pavement and a median refuge.

On the northbound side, the part-time operation of the bus lane, to be shared with cycling, is similarly an unsatisfactory half-measure. Again, the bus lane should not be displaced by extra lanes for general traffic at the junctions. It should be continuous, to prioritise both buses and cyclists.

The main problems encountered by those attempting to cycle on Kilburn High Road are obstruction, due to congestion, illegal stopping and loading, and buses and taxis stopping, making the cycling experience a frustrating, stop-start inefficient one, as well as stressful. At junctions, especially in this section on the southbound side, there is a problem of motor vehicles cutting left across cyclists’ paths. At night and at weekends there is less congestion, but there is a problem with fast and reckless driving that exposes cyclists to danger as they are forced into the middle of the carriageways by stopping and loading at the sides of the road. These problems can only be solved by giving cyclists protected space that cannot be invaded by motor vehicles stopping either legally or illegally. As both Camden and Brent have recently installed proper protected space for cycling on roads with similar problems elsewhere (e.g. Prince of Wales Road in Camden and Harrow Road in Brent), the failure of these boroughs to propose more radical and meaningful change for Kilburn High Road is particularly disappointing.

This is not just a case of ‘cyclists never being satisfied with what they are offered’: we can be quite certain that the measures proposed in this consultation will not work at all, and will leave conditions for cycling essentially as they are now, with continuous obstruction and danger, and conditions for pedestrians also little improved. The current proposals continue to prioritise motor-traffic carrying capacity above all other considerations. Significant increases in cycling on this corridor as required by both the DfT and TfL will not occur without the security and inclusivity offered by continuous, protected cycling space that is dedicated to that one purpose 24 hours a day, 7 days a week. Protected lanes should be accompanied by strong measures at junctions (such as advanced signal phases) to allow cyclists to safely continue forward without the risk of left-hook collisions with cross-turning vehicles. The Advanced Stop Areas proposed in these plans for the junctions offer cyclists little help and are considered the least effective measure in terms of protection in a list of 8 interventions given in LTN 1/20 (p111, para. 10.6.5).

Brent Cycling Campaign, February 2021