This is the response from Brent Cycling Campaign (first posted on 24 May 2021, to the above consultation (this section of the council’s website has been transferred to this new platform and there is no longer access to previous consultations…). However, the council is consulting again and this is the new link.

[22/09/2021 – UPDATE: We received a response from officers, on Tuesday 21 September – added in bold and italic below. Scroll down to ‘Summary’. These are the exact words used. You can draw your own conclusions as to whether or not Brent Council is committed to improving conditions for “all” road users as claimed. However, based on this, you would be forgiven to think that 1/the assumption is that everybody drives everywhere, all the time, and 2/Advanced Stop Lines are not only a suitable junction treatment but the only one available… In 2021. After Gear Change and LTN 1/20].

Overall verdict

We oppose the scheme. We are immensely disheartened to find the scheme’s proposed improvements for walking are heavily counterbalanced by regressive measures, adding danger to the junction and a considerably more unpleasant experience for cycling including mobility cycling.

We outline this as follows, including a summary, finishing with our recommendations.

Brent strategy context

As per the Brent Transport Strategy, Brent Cycling Strategy, Brent Walking Strategy, Brent Covid-19 Transport Recovery Plan, Brent Climate Emergency Strategy and Brent Equality Strategy, Brent Council is obliged to prioritise the safety and convenience for people of all ages and all abilities to travel by cycling and walking, including wheeling (wheelchair use) and mobility cycling (trikes, handcycles, etc). We use the term ‘active travel’ to include all these modes of travel.

It includes for instance, enabling with safety, comfort and convenience:

• children to cycle to school
• disabled people using a mobility cycle to the shops
• elderly people using a mobility cycle to a place of worship

Strategic network context

Transport for London’s Strategic Cycling Analysis recognises the route between Bridge Road and High Road Wembley as amongst London’s “high potential connections”.

As per the Mayor’s Transport Strategy, the route must be developed as a “healthy streets corridor” for safe active travel, together with a safe means for people to actively travel to it.

A scheme to modify this junction for pedestrians provides the perfect opportunity to develop it as part of the healthy streets corridor. It only makes sense to do it at the same time.

Local destinations

This is a strategic, key local junction connecting several shopping, public amenities, entertainment venues and the new, large residential developments.

To the South we have:

• London Designer Outlet, a large pedestrian shopping and entertainment complex containing 70 shops, restaurants, coffee shops and a 9-screen cinema.
• Wembley Library (within the Civic Centre), one of only 3 remaining libraries in North Brent.
• Brent Civic Centre, the administrative centre of our borough, containing key public services such as the Registrar and Housing.
• Box Park with numerous restaurants.
• Wembley Stadium.
• The SSE Arena.
• Wembley High Road shops and restaurants
• Wembley Central Tube station which is also on the national rail network.
• Park Lane Primary School
• King Edward VII Park
• The new Harrow Road pop-up cycle lane

To the North we have:

• Several nurseries primary and secondary schools including, but not limited to Wembley Primary, Wembley High Technology College, East Lane Primary, North Wembley shops and restaurants
• North Wembley station, served by both the Bakerloo and Overground.
• Preston Road shops, restaurants, and tube station.

To the North East we have:

• Wembley Park Station
• Asda Supermarket

Enabling active travel

Last month Brent Council launched the ‘Shop Safe, Shop Local’ scheme. The objective was to aid the post-pandemic recovery of local businesses by encouraging residents to support local shops and restaurants, and to use active travel as their first transport choice. There is plenty of evidence that businesses easily accessible by active travel perform better and Brent must be commended for their intentions, however residents need safe infrastructure to be able to use active travel.

65% travel to the shops in Brent by sustainable travel, 45% by walking and cycling. (TfL’s Travel in London report 13)

Furthermore, Brent has recently published their Climate Emergency Strategy and have identified active travel as a key part of this:

‘Pursuing active travel as the preferred mode of travel in years to come will be crucial in helping to tackle the climate emergency in Brent, through increased uptake of walking and cycling.

We understand the scale of the challenge. By 2030, it is likely that the following shifts will need to have occurred in order to achieve carbon neutrality:

• The number of trips made by walking needs to increase to 37-45%, up from 28% in 2017-18.
• The number of trips made by cycling needs to increase to 7-10%, up from just 2% in 2017-18.

To ensure that active travel is embedded as a priority mode of transport across our borough, both now and into the future, this will again require behaviour change. The promotion of walking and cycling across different communities and sectors will be essential, as will seeking to secure funding for the relevant infrastructure to support this and being strategic

with the resources that are available.’ 

High quality Cycling infrastructure and hence modal share is relatively poor in North Brent. As the council is now looking to redesign this junction, it would be an excellent opportunity to use these funds to provide safe cycling for all ages and abilities, to meet their obligations for post-pandemic recovery and climate change.

The scheme’s changes for walking and wheeling

Removing and paving the sharp left-turn slip lanes would immediately improve the experience in safety and convenience for pedestrians and wheelchair users. As too would the introduction of much needed pedestrian signals.

The scheme’s changes for cycling

Purely from the perspective of someone cycling or hoping to cycle, what would be the effect of the scheme’s changes?

1. Banning the sharp left-turns from Wembley Hill Road will also apply to people cycling. So what are cycles expected to do? This is a huge inconvenience. And will inevitably result in some cycles to behave in undesirable ways, which may be dangerous to themselves and others.
2. Currently, on the Wembley Hill Road northbound approach to the junction, cycles can make their way to the front. Brent Council’s scheme will instead implement a left-turn filter lane, meaning two side-by-side motorists can block arriving cycles from safely accessing the front. Whether the cycle chooses to wait behind and amongst other motor vehicles, or chooses to make their way to the front either by squeezing through narrow gaps between vehicles, or using the oncoming lane, all of these choices are significantly more dangerous compared to the current arrangement.
3. Currently, when Wembley Hill Road has a green light, there are 2 southbound + 1 northbound traffic lanes in motion. The scheme would allow 2+2 traffic lanes simultaneously. This makes the centre of the junction significantly more hazardous, for all, and especially for cycles.
4. The proposed advanced stop lines for cycling are negligible. There’s no provision, such as a feeder lane, for people cycling to safely enter that space. And also they’re routinely occupied by vehicles anyway, with no noticeable enforcement.

Given the strategic priorities to enable active travel, and that TfL identify this route as a high potential connection to be developed as a healthy streets corridor, we are saddened that Brent Council’s scheme proposes changes that in combination make it considerably more dangerous for cycling including mobility cycling.

What assessment has Brent Council carried out in relation to all potential cycling movements through the junction? Was the Junction Assessment Tool used? If not, what was the assessment tool used? What were the scores for this scheme? It’s plainly obvious no such assessment has been undertaken. This appalling oversight is indicative that Brent Council has no consideration for cycling.

Increased risk of collisions

The scheme notes that “Six of the collisions involved cars, one involved a pedestrian, one involved a cyclist and one involved a powered two wheel vehicle. A fatal pedestrian accident also occurred in January 2017.”.

As in point (c) above, from the current arrangement of 2+1 traffic lanes in motion, the scheme will change this to 2+2 traffic lanes in motion.

The majority of traffic collisions occur at junctions. By introducing additional capacity for more motorists to simultaneously navigate through the centre of this junction, it becomes more hazardous, increasing the risk of collisions. For example, it will lead to frequent instances of some impatient drivers using the additional lane to undertake or overtake, often contrary to the lane’s intended purpose. Some will do this in a dangerous manner and/or at an unsafe speed.

Another typical occurrence of driver behaviour at junctions is ‘beating the red light’. Too often, anticipating the traffic signal about to change to red, and even after it’s already changed to red, drivers accelerate through the junction at unsafe speeds, even tailgating others doing the same. The scheme would enable two side-by-side motorists to do this on the northbound approach, as well as on the southbound approach. This means 2+2 motorists all accelerating to ‘beat the red light’. And if each is followed by one tailgater behaving the same way, that’s potentially 4+4 = 8 motorists all simultaneously accelerating unsafely through the heart of the junction as the signal turns red. This is a staggering increased potential for danger for such a local junction in a residential area.

Capacity for more driving

Moreover, introducing this additional capacity for motorists also has another effect. The aim of reducing congestion by increasing capacity is terribly misguided. The reduced congestion is short-lived as people soon realise that driving has become more convenient. Hence it has the effect of inducing more driving journeys, leading to more congestion. This is evidenced by the study The Fundamental Law of Road Congestion by Gilles Duranton & Matthew Turner.

Clarendon Gardens

Why now introduce a left-turn filter lane into Clarendon Gardens, which will further exacerbate that rat-run? The rat-running roads, including Clarendon Gardens, Llanover Road, Pembroke Road, are all very narrow roads with cars parked on the pavements, causing unpleasant, dangerous experiences for vulnerable people.

Encouraging drivers to use Clarendon Gardens goes against Brent Council’s own Covid-19 Transport Recovery Plan, where it has already identified the Clarendon Gardens area as a desired low traffic neighbourhood (LTN) designated as PM28. Surely changes to this junction now should be designed to complement such plans.

Summary

The scheme claims the measures will “create a safer environment for all road users”. But Brent Council has forgotten that people cycling, including mobility cycling, are also road users, who have been neglected. The scheme does nothing whatsoever to shift people’s travel mode towards cycling. Instead it does the reverse, making cycling considerably more inconvenient and dangerous.

OFFICER’S RESPONSE: The scheme proposes to introduce safer and protected crossing facilities for pedestrians and upgrade the existing traffic signals to enhance the operation of this junction by coordination with adjacent traffic signals in the area for optimum operation and minimise congestion.

The scheme will increase driving capacity through the centre of the junction, leading to a significant increase in hazardous scenarios, for all road users.

OFFICER’S RESPONSE: The proposed scheme will not have a significant impact on the overall capacity of this junction. The improved signal coordination and revised signal timings (including a pedestrian phase on all arms) will lead to a slight reduction in capacity at peak times.

The scheme ignores and makes no steps towards achieving Brent Council’s own desire for a Low Traffic Neighbourhood (LTN) designated as PM28 to be implemented in the Clarendon Gardens area.

OFFICER’S RESPONSE: The proposed scheme is following Brent Council’s policy of reducing personal injury accidents for all road users and working towards Vision Zero.

Other than for walking and wheeling (wheelchair), the scheme makes no effort towards enabling active travel. It’s as if Brent Council have designated it as a walking and driving scheme only, while at the back of the mind thinking at some indefinite future time they hope to win some cycling-specific funds, to then maybe revisit the same junction for cycling. This is incredibly wasteful of time, resources and local people’s patience, requiring their consultation about the same junction again. Brent Council keeps failing to integrate cycling including mobility cycling into its transport schemes.

OFFICER’S RESPONSE: This junction is a critical intersection, located centrally to the Wembley High Road, Wembley Park Station, Wembley Stadium and London Designers Outlet. Also within a mixed land use including the residential, commercial and educational amenities in close vicinity of this junction. The junction layout and traffic control with protected pedestrian crossing facility was in need of a total upgrade and improvement. The proposed improvements will not only provide safer pedestrian crossing facility but will also improve overall junction operation with revised method of control, signal timings and close coordination with other signal controlled junction in the area. This will benefit for a better and improved traffic control for this area.  

The scheme ignores Brent Council’s own strategic aims of enabling cycling including mobility cycling.

OFFICER’S RESPONSE: The proposed scheme retains all advance stop lines for cycles at this junction.

The scheme ignores the Mayor of London’s and TfL’s Strategic Cycling Network aims for cycling including mobility cycling.

Brent Cycling Campaign has found it a painfully obvious judgment to oppose this Brent Council scheme.

OFFICER’S RESPONSE: This junction provides for and has been designed with all road users in mind. It is for the mutual benefit of all road users alike. The proposed scheme is not designed for the benefit of one specific mode of transport. 

Brent Cycling Campaign recommendations

Very short term – the junction

In the very short term i.e. this year, since Brent Council is right now just looking at this junction urgently to make it safer for pedestrians, changes must be complemented to make it safer for cycling too.

• Banning the sharp left-turns should allow exemption for cycling. This can be achieved by repurposing the current sharp left-turn slip road for motorists into a cycle lane including for mobility cycles.

OFFICER’s RESPONSE: This option was considered but due to geometric layout and capacity constraints it was not included.

• Wembley Hill Road on the southbound approach has two approaching lanes. The left lane could be repurposed into a cycle lane including for mobility cycles.

OFFICER’s RESPONSE: This option was considered but due to geometric layout and capacity constraints it was not included.

• Wembley Hill Road on the northbound approach, instead of Brent Council creating a new left-turn filter lane, they could instead create a cycle lane including for mobility cycles.

OFFICER’s RESPONSE: This option was considered but due to geometric layout and capacity constraints it was not included.

• Remove the junction’s motor access with Clarendon Gardens – both entry and exit. This would greatly simplify the junction, plus make it safer. It would also be a step towards implementing the PM28 Low Traffic Neighbourhood (LTN) in the Clarendon Gardens & St John’s Road area.

OFFICER’S RESPONSE: This option was also considered but found not suitable as it would lead to much longer diversions and inconvenience to the local residents of Clarendon Gardens.

This can all be done immediately (after consultation of course).

Short to medium term – LTNs

The above recommendations reduce driving capacity in the locality, so are likely to cause some reduction in driving. There are growing bodies of evidence of traffic evaporation, such as this comprehensive study, Disappearing traffic? The story so far, by Sally Cairns, Carmen Hass-Klau, and Phil Goodwin. However, an unwanted side effect will be some extra traffic using minor roads. This will soon need rectifying too.

The recognised means to remove traffic from minor roads is by Low Traffic Neighbourhoods (LTNs). This means ensuring through traffic remains on main roads. Measures should be implemented to prioritise and maximise the safety, convenience and comfort for people to use all forms of active travel throughout the inside of the LTN, without needing to interact with thoroughfare traffic. The boundaries of the LTN are the main roads and hard borders such as the Bakerloo line. The local LTN boundaries can be according to these pink, red (Wembley Hill Road) and yellow (Park Lane & Wembley Park Drive) bold lines in this map:

Medium to long term – healthy streets corridor

The Park Lane & Wembley Park Drive (yellow) roads are too narrow to cater for safe cycle lanes together with 2-way traffic. These roads also contain destinations requiring safety for vulnerable people and active travel, notably Park Lane Primary School, Learning Stars Montessori Nursery, St Christopher’s School, King Edward VII Park, Wembley Park Medical Centre, Church of Jesus Christ of Latter-day Saints and Park Lane Methodist Church.

The roads are very residential, and appear less capable of handling thoroughfare traffic compared with Empire Way A479. So, through traffic could be removed from Park Lane & Wembley Park Drive. This will allow these roads to form the necessary “high potential connection” of TfL’s Strategic Cycling Network between Bridge Road and High Road Wembley, and our healthy streets corridor, as required by the Mayor’s Transport Strategy.

OFFICER’S RESPONSE: The above suggestions are outside the area and scope and design brief of this junction improvement scheme.