Response to Kensal Corridor Improvements consultation

This is the response from Brent Cyclists to the consultation on the Kensal Corridor Improvements. We are the local group of the London Cycling Campaign in Brent. We represent directly about 200 paid-up members who live in the borough, and we also attempt to represent all those who cycle or would like to cycle in the borough.

We do not support the proposals for any of the three sections.

We think these proposals will not achieve the stated objectives of the scheme, and particularly, will not encourage more cycling. This is because the proposals are largely cosmetic, and do not address the fundamental issue of too much motor traffic using the corridor. Continue reading “Response to Kensal Corridor Improvements consultation”

Response to the consultation on the London Plan

Responses below to various sections in the draft London Plan, with the links to the relevant sections at the top
T2 “We support this move to prioritise active transport over motorised transport.”

10.2.2 “Targets for active tranport, separate from public transport use, are required.”

10.2.6 “Distance possible by cycle is not purely dependent upon linear distance, but on ease of travel. Making more routes safe will make longer journeys possible and more inviting due to the lower stress environment. in turn this can reduce pressure on public transport. Specifying “long” and “short” journeys is unhelpful.”

T5 “We support moves to increase access to cycling through infrastructure. We support reallocation of space to cycle parking from other uses such as on-street car parking. We suggest that reallocation of space from other uses such as on-street car parking to cycle infrastructure / routes should be included.”

Table 10.2 “We support these increases in required cycle parking for new developments. The plan must include requirements for cycle parking in all re-development, upgrades, other planning, and existing development cases with a timed implementation plan.”

10.5.1 “We support this plan for a London-wide network of cycle infrastructure.”
Figure 10.2 “This figure looks very weak. This is taken on a borough level, not on a neighbourhood level. Therefore sharp divisions can exist at borough boundaries, where cycling levels may be very similar.”

10.5.3 “The Mayor should not just “support” higher levels in Mini-Hollands and Liveable Neighbourhoods or Opportunity Areas, but mandate higher levels.”

T6 “We support restricting car parking for the reasons given, this should be termed “motor vehicle parking” to include non-car vehicles. Provision for Ultra-Low Emission vehicles must not be at the expense of cycle users: ie. must not be on-street.”

10.6.2 “PTAL assessment should also include level of cycleability in the area.”

10.6.3 “Do not use the word “quantum”.”

10.6.7 “Support, as above using the term “motor vehicle parking” would avoid this confusion.”

10.6.8 “This means nothing, must all new parking provide for ULEV charging, or a %, or all by 2050?”

Table 12.1 “The target of mode share for walking, cycling and public transport at 80% by 2041 is commendable, however it is weak. There must be additional (yearly) interim targets, within mayoral terms. The target must have minimum active travel levels. This must be measured locally and London-wide, and significant local differences from the target must be highlighted.”

SD7 “We support the identification of Town Centres, however are concerned that this misses existing centres in Brent of local and international importance. 1. Wembley is a international centre, as are developments in Stratford. 2. Brent Cross is missing as a Metropolitan Town Centre.”

SD10 “We support the indentification of areas for regeneration, and suggest highlighting that transport poverty is one of the specific causes of deprivation, and that improved facilities for active travel can help overcome this.”

D7 “We are concerned about the suggestion that new developments will include “on-street parking”, on-street parking must not be the norm for new developments. We are concerned that an emphasis on “public realm” leads to unsafe and unsuitable proposals such as the shared space on Exhibition Road, it must be specified that “public realm” improvement does not mean removing infrastructure (e.g. kerb separation) used to promote safety.”

SL1 “The risk of air quality to active travel users should be considered, in addition to areas with low active travel, but high pollution, areas with high active travel, but lower relative pollution levels should be a focus due to the total impact over the people present.”
9.1.9 “If a development cannot meet Air Quality Neutral standards it should not be allowed to proceed, mitigation or payments are not a suitable solution for the Londoners who will be killed through the resulting air pollution.”

9.1.10 “This statement should read “Where there have been significant improvements to air quality resulting in an area no longer exceeding air quality limits, development should not take advantage of this investment and worsen the local air quality.” Extent of worsening should not be considered, any worsening should not be allowed.”

AN3 “We are horrified by the highlighting of Brent Cross as an area of high growth. All the proposals for Brent Cross area completely unsuitable for active travel, will cause the area to continue to breach air quality guidelines, and will not reduce motor vehicle use. The Mayor must not continue to support developments in Brent Cross as long as they continue to breach London Plan requirements.”

Pentavia housing development planning application (Barnet)

The planning application for this site between the A1 Watford Way and Bunns Lane in Mill Hill is here. Further information on the Barnet Cycling Campaign website.

This is a response to the application from Brent Cyclists, the Brent group of the London Cycling Campaign.

We wish to object to this application, as the unsatisfactory cycle access it proposes is inconsistent with the Mayor’s Transport Strategy and the planning brief for the site. It does not create ‘new pedestrian and cycle links that contribute to the integration of the site with Colindale and Mill Hill’, as required in the brief. Critical to doing this would be creation of a good-quality cycle link to Bunn’s Lane, usable by all types of cycles and all cyclists without dismounting, plus improvements to the very poor cycling environment of Bunn’s Lane. The links to the (itself poor-quality) cycle track (shared pavement) on the east side of A1 from the site will also remain very poor and uninviting, with steep indirect ramps and an intimidating tunnel with blind bends, none of which were ever designed with cycling in mind. We would expect a residential development here to be used as an opportunity to fix these long-standing problems, but current plans fail to do this, hence our objection.


Response to 2017 TfL Oxford Street consultation

This is the response from Brent Cyclists to the consultation that ended on 3 January 2018.

We do not support these proposals.

We support the removal of all motor traffic from Oxford Street, but we believe cycling could and should be accommodated safely on Oxford Street with a clear design that uses a central, two-way 4m wide cycle track, with low kerbs and distinctive surfacing, and designated pedestrian priority crossings. This track could also be used for servicing the street utilities and businesses with light electric vehicles out-of-hours.

TfL said in the previous consultation that they will produce plans for a parallel cycle route. There is still no plan. One parallel cycle route is not enough unless there is a track on Oxford Street, therefore two parallel routes (one on Wigmore St , Cavendish Place, Mortimer Street and Goodge Street , one on Upper Brook Street, Grosvenor Square, Brook Street, Hanover Street, Great Marlborough Street, and Noel Street) should be provided, with cycling fully separated from motor traffic. TfL state “we propose to make some modest improvements to Wigmore Street, Harewood Place and Holles Street for cyclists, amongst other users.” As these changes means road narrowing and new bus stops, they will make things worse, not better for cycling. Baker Street and Wigmore Street will be two-way, without cycle infrastructure, effectively narrowing these roads for cycling.

Despite supporting the principal of removing motor traffic from Oxford Street, therefore, the sheer lack of consideration shown for cycling in these proposals means that, on behalf of our members, we must oppose them outright.

Preston Road 20mph zone

A response to this consultation, closed 15 December 2017.

Do you agree with the proposed 20 mph zone?

Do you agree with the proposed zebra crossing facility near junction with East lane and three zebra crossings at The Avenue junction with Preston Road?

Do you agree with the proposed four uncontrolled crossing facilities in Preston Road with double yellow lines?

Do you agree with the proposed removal of two parking bay outside 11-12 The Broadway, Preston Road and extension of the double yellow lines ?

Do you agree with the proposed two flat top speed tables at the existing Pelican and Zebra crossings?

This is the response from Brent Cyclists, the local group of the London Cycling Campaign.

We agree with the aims of the scheme but we do not wish to see road narrowings between pavements, or pavement build-outs, and central islands that create lane gaps in the 3-5m range, as these create locations where cyclists tend to get passed at a dangerous distance by impatient motorists unwilling to wait until they can give the overtaking space required in the Highway Code. We therefore do not want extra central islands introduced on to the road, or pinch-points unless short segregated cycle lanes past them are created. We are also opposed to speed cushions, as these cause competition for flat road space and unpredictable horizontal manoeuvrings of vehicles, and can push cyclists too close to parked vehicles.

From our point of view, the light-controlled crossing near the station is in the wrong location. It should be actually outside the station: its offset nature encourages many pedestrians to cross slightly away from it. This is particularly relevant in relation to the location of the cycle parking on the east side of the bridge.

Kingsbury Town Centre Proposed Public Realm Improvements Scheme

This is the response of Brent Cyclists to the consultation on Kingsbury Town Centre Proposed Public Realm Improvements Scheme (closed 1 December 2017).

We approve of this scheme, which is a major improvement on previous proposals, and on the existing design, but have some concerns on the design of the cycle facilities, as follows.

1) Surface and kerbs
The cycle lanes or tracks are said to be ‘on footway with coloured surfacing to match paving’. Quite what this means is not clear to us, but we see it as important that the cycle space is distinctive and obvious to all road users. We think the tracks should be a definitely different colour to the footways, and have a smooth surface. The current two-way cycleway on the south footway is green asphalt, but we think the best surfacing to use is reddish asphalt, as on the recently-completed cycleways on Lea Bridge Road, Waltham Forest. This is the most generally-recognised colour for cycleways internationally, and actually corresponds to some previous practice in Brent. (In both the Brent River Park and the open space behind Cambridge Close in Neasden, cycleways next to footpaths were coloured pink).

An issue with the current cycle track is that pedestrians walk in it a lot, as it is at the same level as the footway. The improved placement of the track in the current plan will help with this, but we believe using kerbs and a small level change, along with a distinctive surface colour, is the best way to make clear to all (including the visually-impaired) where cyclists are supposed to be.

2) Width of the cycle tracks
The 1.5m width specified seems un-generous, given the total amount of space available here. 1.5m is insufficient for one cyclist to overtake another with safety, and 2.0m should be the norm for one-directional cycle flow. If there are particular obstructions that are difficult or impossible to remove, then going down to a 1.5m minimum is acceptable in such places, but 2m width should be achieved where possible.

3) Priority of the cycle tracks
As they follow a main road, the tracks should have priority over side-roads and entrances (London Cycle Design Standards Sect. 5.3.4). The track surfaces should be continuous and flat across junctions and not be interrupted by kerbs. This applies to:

  • The exit from the the service road at the NW end of the scheme
  • Berkeley Road junction
  • Brampton Road junction
  • The driveway just west of Manor Close
  • Manor Close junction
  • The entrance and exit roads to the car park on the south side
  • The entrance to the service road at the SW end of the scheme

Paralleling the priority and continuity of the cycle tracks, that we would like to see, all these junctions could have continuous, uninterrupted footways also, for the best ’state-of-the-art’ public realm for a town centre street of this character. This was one of the things that was suggested in the ‘Imagine Kingsbury’ consultation process in 2016.

4) Bus stop bypasses
We are pleased to see that bus stop bypasses are envisaged for the stops at the NW and SE ends of the scheme. It is therefore unsatisfactory that they are not envisaged for the other two stops – the one outside the station, and the one just west of the park entrance on the north side. Ejecting cyclists from the tracks at these points into the carriageway to pass around the outside of stopped buses severely damages the whole scheme, breaking the continuity of the protection for cyclists, and removing much of the usefulness of the tracks.

The reason for this would appear to be the desire to maintain two flowing lanes of motor traffic when buses are stopped. As the road is only one lane in either direction, this results in a lot of wasted carriageway space ahead of the bus stops. This was not the approach taken in the Carlton Vale cycle scheme, and also the Walm Lane public realm scheme (on another town centre A-road), where a lane is blocked when a bus stops – an increasingly acceptable concept in street design, so much so that bus stops are sometimes moved out into the carriageway, so that buses moving off do not have to pull out into a stream of traffic.

However, if the designers here are determined to keep motor traffic flowing when buses are stopped, there is still space for cycle track bypasses of all the bus stops in this scheme. We don’t know if the omission of a bypass outside the station is connected with the blue block on the plan marked ‘Phase 1’, as if something else remains to be designed. In the case of the eastbound stop near the Roe Green Park entrance, a possible solution could be to move the edge of the park (which is marred here by an informal dirt track and the remains of some identifiable piece of old infrastructure, where the edge of the park is indented for about 1.7m distance) slightly inwards, and the bus stop slightly outwards (into the carriageway), to make space for the bus stop to be bypassed. This would make the transition from the eastbound cycle track back to the road at this end of the scheme much better.

5) Pedestrian crossings
We are concerned that the priority for cyclists and pedestrians is unclear where pedestrians must cross the cycle tracks in order to use the two signalised crossings of the road (near the west end, and west of Manor Close), and this could lead to conflict and possibly danger. We recommend the cycle tracks be continuous but have zebra markings across them at the crossing points. This would make it clear that cyclists should give way to crossing pedestrians.

Hyde Town Centre Proposed Public Realm Improvements

This is the response of Brent Cyclists to this consultation (closing 4 December 2017).

This is the response on this scheme from Brent Cyclists, the local group of the London Cycling Campaign. We have to oppose this scheme because we want to see segregated cycle tracks on the length of the A5 through Brent and beyond, to support inclusive cycling on this critical link. The A5 through Brent and Barnet as far north as Edgware is already designated as the ‘LCN+ 5 cycle route’, which already means that cycling should be given a high degree of consideration here (but is not). There is sufficient room for cycle tracks in the width of the street in most places, including, and indeed especially, at The Hyde, where, currently, a vast amount of the road space is given over to long-term parked motor vehicles. As the A5 is already a major artery for cycling, and especially as it has been identified as a priority corridor for future cycling investment in TfL’s recent ‘Analysis of Cycling Potential’ document, it is essential that any developments now should contribute, if only in a small way, to the creation of a protected cycle route all along the A5 from Edgware to Marble Arch.
Though this scheme tidies up The Hyde area somewhat, we find it unacceptable for it to be planned that so much of the width of the road will be devoted to car parking, with no specific provision whatever for cycling. The current parking on the islands between the service road and the main road needs to be dealt with, but can be dealt with anyway, without any scheme, as it is simply illegal. We urge a re-think of the use of this whole area of road, with the need to allocate dedicated space to cycling in mind, and to accommodate parking only when that, and the needs of other moving traffic, including pedestrians, have been adequately addressed.

Cycle Superhighway 9 Consultation

This is the response by Brent Cyclists to this consultation.

1. Do you support our overall proposals?


2. Do you have any comments on our overall proposals?

Overall these proposals are good, however some details fail to meet the high standards required for a comfortable, attractive cycling route. In particular the route fails to provide a link to existing cycle infrastructure, for example the E-W CS in Hyde Park. Therefore this route must be extended through the Borough of Kensington and Chelsea.

3. Do you support the proposals for Hammersmith Road?


Comments: Junction at Blythe Road should be tightened. Additional protection should be given at junction of Brook Green (e.g. additional raised kerbs after pedestrian crossing on North side of road. The route must not stop suddenly on Kensington High Street, there is sufficent width to continue the route along this road Eastwards.

4. Do you support the proposals for Hammersmith Gyratory?


Comments: These proposals provide no protection for cyclists heading South from the gyratory. The entrance to the protected tracks by crossing two traffic lanes on QUEEN CAROLINE STREET is dangerous, a crossing of the slip road South of Blacks Road should be included. Eventually plans must be made to remove the gyratory.

5. Do you support the proposals for Beadon Road?


Comments: none.

6. Do you support the proposals for King Street (East)?


Comments: A new zebra crossing by the bus stop should be provided to provide easy pedestrian crossing to the bus stop and reduce the likelihood of pedestrians standing in the cycle lane waiting to cross the motor traffic lane.

7. Do you support the proposals for King Street (West)?


Comments: Cycle access to Studland Street appears inadequate.

8. Do you support the proposals for Chiswick High Road?


Comments: Road can be narrowed to maintain pavement width. Access from Clifton Gardens and Fisher’s Lane onto CS9 is inadequate. Staggered pedestrian crossings should be replaced with straight across crossings to remove the need for a pedestrian island, and to widen the pavement and cycle path.

9. Do you support the proposals for Heathfield Terrace / Wellesley Road?

Do not support.

Comments: CS9 cannot be described as a “cycle superhighway” if bicycle users are expected to share space with motor traffic. Either: a) this road must be closed to through motor traffic (ie filtered), or b) separate infrastructure must be provided.

10. Do you support the proposals for South Circular Road (Kew Bridge Station)?

Do not support.

Comments: A bus stop bypass must be provided outside Kew Bridge station. A route must be provided from CAPITAL INTERCHANGE WAY onto CS9.

11. Do you support the proposals for Kew Bridge Road / Watermans Park / Brentford High Street (East)?


Comments: Junctions to the North of CS9 along this route must be narrowed to prevent motor vehicles from impeding the cycle route. Forcing bicycle users to use a bus lane and overtake a loading bay is unsuitable for a cycle superhighway, separate space for cycling must be provided.

12. Do you support the proposals for Brentford High Street (West)?


Comments: a Two stage right turn into Ealing Road would be preferable to passing the junction and then turning back to use a toucan crossing.

13. Do you have any comments on future proposals for CS9 from Brentford High Street to Hounslow town centre?


Comments: none.

Twyford Abbey Road – Road Safety Scheme

The following is our response to this scheme (consultation closed 7 August 2017) involving new and improved cycle lanes in Park Royal.

This is the response from Brent Cyclists, the local group of the London Cycling Campaign.

We support this scheme, but would make the following points:

1) The contraflow cycle lane on Rainsford Road and new connection from the canal towpath, via a cycle crossing of Twford Abbey Road, are very welcome. However, the junction of the proposed southbound cycle lane on Rainsford Road with Whitby Avenue does not look safe: it simply terminates, leaving cyclists to the right hand side of traffic turning out of Whitby Avenue. It may be better if the cycle lane were taken left round the corner and then crossed over Whitby Avenue on some kind of crossing.

2) A desired manoeuvre is for cyclists travelling south over the canal bridge, on the cycle track or shared pavement on Abbey Road, to then turn right into the bus lane on Twyford Abbey Road. There is no clearly-designated method of doing this. Although a right turn is permitted for cycles on the carriageway, getting into this, with railings in the way, even if there is no traffic, is impossible. This scheme does not appear to solve this problem.

3) While welcoming any upgrade of advisory cycle lanes to mandatory status, and recognising the budget of this scheme is going to be limited, we need to point out Abbey Road is such a busy road that the cycle lanes should really be truly segregated throughout. The best way to achieve this in the limited road width would be though construction of stepped cycle tracks, differentiated from pavement by a level change (similar to Camden’s solution on Pancras Road). The existing fragments of paint-segregated pavement-level cycle lane around the junction of Abbey Road and Twyford Abbey Road are poor-quality infrastructure, and will remain so even when ‘refreshed’. (Though the principal of minimising unnecessary cycle stops at traffic lights is correct.)

Elsley Primary School ‘School Development Scheme’

This is a response to this consultation, which closed 28 July 2017.

This is the response from Brent Cyclists, the local group of the London Cycling Campaign. This response has been agreed by our Committee.

We are objecting to this scheme because:
(1) If Gaddesden Avenue is to made one-way, as implied in the plan, there should be an exception made for cycles, so as not to inconvenience cyclists. This will affect how the no-entry end of the road is designed.
(2) If traffic-caliming is desired, there is no reason here to use speed cushions rather than the more cycle-friendly sinusoidal full-width humps, as specified in the London Cycle Design Standards. Speed cushions are fairly ineffective at controlling vehicle speeds, and cause unpredictable horizontal manoeuvres by drivers and riders that cause extra risk for cyclists, as well as sometimes pushing cyclists too close to opening car doors.
(3) The proposed 20mph zone is illogical in not including Nettleden Avenue and Tring Avenue, very small roads which should not have a 30mph limit.