Ahead of the planning committee meeting which took place on Monday 29th March, we submitted this joint response with Harrow Cyclists – Healthy Streets for Harrow. This sets out our main concerns and makes recommendations as well as proposes an alternative design.
You can also read an account of the committee on the Wembley Matters website.
This is the joint response from Brent Cycling Campaign and Harrow Cyclists, two local groups of London Cycling Campaign, to the committee report for case number 20/0700, development of ‘Land adjacent to Northwick Park Avenue, London, HA1’ . We represent over 300 supporters and attempt to represent the interests of all who cycle or would like to cycle in NW London. We have some concerns about the planned development and have suggested some potential improvements, which we would be grateful if the council could consider.
Comments on the proposed development
1. Two-way spine road. / para 259
It is stated that this will be shared space with pedestrians. However, this is non-compliant with the latest guidance (LTN 1/20) ‘Cycles must be treated as vehicles and not as pedestrians. On urban streets, cyclists must be physically separated from pedestrians and should not share space with pedestrians. Where cycle routes cross pavements, a physically segregated track should always be provided. At crossings and junctions, cyclists should not share the space used by pedestrians but should be provided with a separate parallel route’.
Current guidance states that this should be a segregated cycle lane, and if this is to be a two-directional lane it must be at least 2.0m wide, ideally 3.0m wide for peak capacity of <300/hour.
2. North and south crossings junctions with Watford Road.
The new shared cycle lane along Watford Road should now be redesigned as a segregated cycle lane, and it should be continuous and not interrupted by access to the hospital grounds. We have
We do welcome the removal of the central access junction as this would mean fewer junctions where cyclists and pedestrians may come into conflict with motor vehicle traffic.
3. Toucan crossings over the north and south entry roads.
The proposed staggered Toucan crossings over the north and south entry roads should be straight as this will interrupt pedestrian flow. If it shared space with cyclists it may not accommodate adapted and larger/cargo bikes. This may be discriminatory.
We propose a straight, segregated pedestrian crossing and reducing the car lanes to just one lane in each direction to make crossing safer for pedestrians. Please refer to LTN 1/20 and Gear Change ‘Cycle infrastructure should be designed for significant numbers of cyclists, and for non-standard cycles. Our aim is that thousands of cyclists a day will use many of these schemes’
4. Parking spaces
Whilst we welcome the move to reduce staff parking spaces by 145, however this may result in increased parking on surrounding residential side roads.
TFL note: It is understood that the combined proposal would result in an overall reduction of approximately 150 car parking spaces compared to the existing. This relatively small reduction is due to a separate proposal by Northwick Park Hospital to re-provide a multi-storey car park (MSCP) in lieu of existing on-street staff parking to be lost for the purpose of this proposed development. TfL strongly encourages that Northwick Park Hospital down-size its MSCP proposal to minimise parking on site, even though the MSCP proposal does not form part of the proposed development being discussed.
We urge Brent Council work with surrounding boroughs to develop interconnected cycle routes to promote car free travel to the site.
5. Air quality
The air quality in the area is currently below legal WHO limits. With the increase in road traffic that this will bring, it is critical to significantly improve sustainable travel to site.
6. Right turn into site from northbound Watford Road.
By allowing right turns into the site by northbound traffic the development further encourages people to drive, and may increase congestion on Watford Road. Moreover, the new right turn filter lane increases the amount of space allocated to motorists along this stretch of road and prevents adequate space being provided for people walking and cycling.
There is limited footway space alongside the northbound carriageway, which is the site of a bus stop and is shared with cyclists. This unsatisfactory and cramped arrangement persists in the new design. It would instead be better to allocate space and resources to other modes of transport.
7. Raising the speed limit on Spine Road
(Para 257) Raising the speed limit from 10 to 20mph is dangerous for all vulnerable road users. DfT data from 2019 shows that under free flow conditions 87% of cars exceeded the speed limit at the 20mph sites. 22% exceed the speed limit by more than 10mph.
We are strongly opposed to raising the speed limit to 20mph as this is likely to result in more collisions, with serious injuries or deaths.
8. Northwick Park Roundabout (para 258)
We welcome the introduction of a signalised pedestrian and cycling traffic scheme for the roundabout and would like to be involved in any consultation and design. We would also like to have details about potential timeframes as this junction has been raised as concern by local active travel groups for many years, without any resulting changes.
Para 325 also discusses the roundabout, but only mentions a staggered pedestrian crossing on the East side arm with Kenton Road. Providing a staggered crossing on this busy junction does not prioritise pedestrians. We would recommend a ‘people first’ approach to facilitate easy pedestrian access.
There is no mention of a cycle crossing in this paragraph, and would recommend that a fully signalised pedestrian and cycle crossing is constructed here, prioritising walking and cycling to encourage modal shift.
9. Pedestrian crossings for Watford Road (para 260).
Making this a staggered crossing prioritises car traffic over pedestrians, making pedestrians wait in the middle of a busy road. We would recommend a straight-across crossing for pedestrian comfort.
Furthermore, there is no mention of a cycle crossing at this junction. We would recommend a segregated crossing for cycles.
The report highlights the importance of Watford Road as a key distributor road, and TfL regards this road as a high priority cycling route. As such we would recommend that a segregated cycle lane is built on this road. We welcome that development is ‘low car’, but this would necessitate significant improvement of surrounding cycling infrastructure. We will detail this later in our comments.
10. Residential cycle parking
We welcome that cycle parking has been provided. We hope that it is secure for long term residents and also caters for adapted and larger/cargo bikes.
11. Delivery, servicing and construction traffic
We have huge concerns about the impact of this on the surrounding roads and congestion it may cause. The surrounding main roads, Watford Road, Kenton Road and Sheepcote Road suffer from significant congestion. We would recommend interconnected, pop up cycle lanes on all of these roads to reduce personal car trips, freeing up road capacity for necessary vehicular traffic.
12. Impact on wider road network
Up to 3952 daily trips from the development are predicted, with 254 of these being by car. This excludes trips by taxi and delivery vehicles. As such the actual number would be much higher. This will add considerable strain on already congested road network, resulting in rat-running through local residential areas.
We urge both Harrow and Brent councils to improve alternative travel options, namely walking and cycling to the site to reduce car use as much as possible. This will also encourage other passing traffic to switch to sustainable modes.
13. Northwick Park station
It is noted that the subway tunnel is very narrow (1.26m) at its southern end. Furthermore it contains a barrier at the southern end.
The barrier is discriminatory as it impassable for adapted bikes often used with those with disabilities. We recommend its immediate removal. This would aid disabled access as well those with larger/cargo bikes.
This is currently the only safe route north from the park so its improvement is a priority.
As widening this subway is not feasible, we strongly recommend an alternative, segregated accessible route along Watford Rd, Northwick Park Roundabout and then Sheepcote and Kenton Road
3.18 states ‘LBB, TfL and the London Borough of Harrow (LBH) are currently progressing proposals for a new Cycleway between Wembley Park and Harrow Weald via Northwick Park station. The Site would be well-placed to access this new route along Northwick Avenue.’ However, this route would not suitable at night and the station subway, as discussed above is not fully accessible with cyclists required to dismount.
14. Road safety on surrounding roads
According to the Transport Master Plan – K Swept Path Analysis, there have 129 collisions in local area for the 3 years to 31st December 2018.
This includes 2 fatalities and 19 serious collisions.
This is a cause of great concern and currently road safety in this area is poor, especially for vulnerable road users.
15. Wider transport issues
Transport Master Plan – B scoping document
ATZ of 20 minutes by cycle covers a very wide area ranging from Edgware, in Barnet, to Northolt in Ealing, but due to poor, interconnected and segregated cycling infrastructure the mode share of cycling is very low. For example, in Brent it is about 1%.
TFL: Pedestrian/ Cycle Access
The overall pedestrian/ cycle access strategy has yet been fully established at the time of meeting. TfL strongly encourage the applicant to develop a pedestrian/ cycle access strategy, which would maximise safety, legibility and permeability of the site.
Route Analysis (Transport Assessment Section 5 Active Travel Zone)
This highlights several areas of concern with local walking and cycling infrastrucuture:
1. Northwick Park roundabout
This has been repeatedly highlighted in the analysis as being poor for pedestrian access. When travelling west or north towards Harrow, the only crossing is using a subway. There were several concerns with this:
- The subway under the southern arm is unsuitable. The report states ‘ The subway can be an intimidating environment for vulnerable people as it is heavily graffitied, relatively quiet and appears unkempt’.
- ‘The roundabout is large and vehicle speeds are relatively high and so can be intimidating for pedestrians and cyclists. There are guardrails are not provided along the northern arm of the roundabout, increasing the feeling of exposure of vehicle traffic’.
The report recommends reallocated carriageway space towards pedestrians and cyclists,through reducing the junction’s size, would help to reduce the roundabout’s car-dominance.
We agree with the above and as has been previously noted, a complete redesign of the roundabout is necessary.
2. Northwick park station
The subway in its not a suitable long term solution for cycling and even pedestrian access. The report mentions several issues:
- It is too narrow and cluttered, especially due the barriers. These hinder cyclists who have to dismount, but also pedestrians with mobility issues.
- The barriers will discriminate against those who need adapted bikes
- At night, the station access from the south can be intimidating and there is often antisocial behaviour and drug dealing in the park.
We feel that this is not a suitable cycling route and is only suitable for pedestrians during daylight.
Widening the tunnel and improving lighting may help, but this may not be feasible from an engineering perspective.
3. Kenton Road
The report highlighted several concerns for both pedestrians and cyclists:
This road is very poor for both cyclists and pedestrians.
- It is 4 lanes wide with fast moving traffic so limits informal crossing, and is vehicle dominated.
- Road surface near Churchill avenue is poor maintained with faded road markings
- Cycling infrastructure is limited, toucan crossings are not available and it is often unclear where cyclists should route.
- The lack of clear cycling infrastructure does not instil a feeling of safety
- It lacks formal, protected cycling routes along its entire length
- There have been 2 fatalities on this road recently, one involving a pedestrian
- The environment is vehicle-dominated. NO2 and PM2.5 levels currently significantly exceed UK Government annual mean objectives
- Vehicle noise is increased at this location due to uneven road surfaces and high speeds
The report makes several recommendations:
- Improving signage for pedestrian and cycling routes
- Traffic calming such as raised pedestrian crossings, side street entry treatments/vertical deflections.
- Segregated cycle infrastructure and continuous footways at side streets along Kenton Road would serve to reduce vehicle speeds and increase the infrastructure’s focus on pedestrians and cyclists.
- Increasing the frequency and density of vegetation between the carriageway and footway could be considered to reduce noise.
We agree with the above recommendations. It is clear that Kenton road requires major improvements for active travel. It is a High Priority TfL route and Brent’s Covid Travel recovery plan and Climate strategy will necessitate its improvement.
Brent’s Commonplace portal had multiple comments requesting improvements.
4. Sudbury Court Estate
The report raised some concerns:
- Extensive on-street parking
- Large radii on corners which encourage high vehicle speeds
- Footway widths are relatively narrow which limits the potential to introduce new places to stop and rest.
- Cracked footways
- Speed cushions which force cyclists into the ‘door zone’
- the area of East Lane near Wembley High Technology College has NO2 levels exceeding UK Government annual mean objectives, Since this location is frequented by children the elevated NO2 levels present a particular issue.
The report makes some suggestions:
- The feasibility of new crossings could be explored to support pedestrian movement, in particular school children and other vulnerable road users. This could be done through providing build-outs with raised tables mid-link and at side streets to improve visibility, reduce crossing distances and serve as locations for additional planting.
- Speed cushions could be replaced by sinusoidal humps, junctions could be reduced in size and carriageway markings reduced to reduce vehicle speeds and improve the pedestrian and cycle environment
- Carriageway build-outs in place of on-street car parking could provide new places to stop and rest.
- Sinusoidal humps would improve the environment for cyclists.
- Restricting the movement of heavy vehicles before and during school start and end may help to mitigate the issue, as would measures to encourage travel to the school by active modes.
5. Sheepcote Road
Although this road is managed by Harrow Council, due to its proximity it is a key road for access. Since the Travel Report a pop-up cycle lane has been installed as part of emergency post-Covid measures. Whilst we welcome this, the cycle lane stops short of the roundabout so would need to extended as part of major upgrades to the area. We are concerned that Harrow council is considering removing the cycle lane because it is under-used; instead we recommend that Brent and Harrow Councils work together to improve and link up the cycle lanes.
Suggested improvements to Watford Road junctions
The junctions with Watford Road have been designed in order to minimise delay to buses. This means that they either maintain or increase motor vehicle capacity compared with the current arrangement, but this has led to compromises in the design for walking and cycling.
Specific issues include:
- Shared pedestrian / cycle paths will not have sufficient capacity to make walking and cycling comfortable and convenient. The Watford Road western footway is particularly cramped, as it is a shared footway with a bus stop and no additional space around the bus stop, and is frequently narrowed further by encroaching vegetation. The scheme does not improve this arrangement at all.
- Space is wasted in the road layout with central hatching, which may also encourage higher vehicle speeds. Removing the hatching will enable more space to be provided for walking and cycling.
- The narrow central refuges are inconvenient and will have insufficient capacity if more people walk and cycle. Under the Equality Act 2010, highway authorities must ensure public sector equality duty, and so be inclusive of wheelchair users. This means that walking and cycling routes need to be comfortable and convenient for users of wheelchairs and non-standard bikes. Forcing them into a narrow central refuge island is not inclusive.
- The new footway on the east side does not separate people walking and cycling, and could be set back further for the road for comfort, as there is plenty of space.
We understand that the concerns about motor traffic capacity have led to the decision to propose staggered junctions, but it is unclear what options have been considered. A separate all-red pedestrian phase would reduce the junction capacity for motor vehicles, but we suggest an alternative approach of separating the right and left (or straight) signals to allow a pedestrian/cycle green light in a particular direction parallel to traffic flow (see Appendix A). This can be done for at least two arms at each junction without too much impact on motor traffic, and we would recommend that any minor increase in wait time for motor vehicles (likely to be just a few seconds) is outweighed by the major reduction in crossing time and increase in capacity of the junctions for pedestrians and cyclists.A_watford_road_suggestion
A major junction outside Whipps Cross Hospital in Waltham Forest (which is also heavily used by buses) was recently re-designed with segregated cycle lanes and single stage pedestrian crossings, showing that such an approach is feasible in London. We have suggested a design for Watford Road inspired by Whipps Cross which includes single stage crossings and segregated cycle lanes along the section of Watford Road near the hospital, where there will be large numbers of pedestrians using bus stops (see Appendix B). These can connect up with existing shared use paths for the time being. Space is created by removing the central hatching and removing one of the extra northbound lanes at the North junction (as northbound flow could have two traffic light phases, so there should be sufficient capacity with just one lane, and the road is mostly single carriageway anyway).B_watford_road_redrawn
We would be grateful if the Council could consider this design, which follows current design standards (LTN 1/20 and the London Cyclng Design Standards), prioritises active travel, and improves conditions for bus passengers, in keeping with the Mayoral Transport Strategy. We are happy to be involved in further discussions to try to achieve the best solution for the future.
In summary, we view this development as an excellent opportunity to upgrade walking and cycling infrastructure to aid safer and sustainable travel. As there will be 1600 housing units, developing this infrastructure is critical to allow residents to travel from the site for work, healthcare, entertainment, and schooling.