The Battersea Society: Planning Committee submission The Battersea Society website 

Planning Committee Submission

Added on: 3 October 2017 at 09:45:46

Draft Mayor’s Transport Strategy 2017

Comments from Battersea Society Planning Committee


This strategy is both lengthy and detailed.  It contains some 103 proposals and 24 policies.  Overall we support its aims and its ambitions. It is nevertheless a highly aspirational document.  It will only have worth if its proposals are given priority, and are backed up by a strong commitment from the GLA, boroughs and all other agencies with statutory responsibilities.

We have one over-riding concern which is that the inter-relationship of the effects of separate policies on one another are inadequately explored and assessed.  For example the effect of more cycle lanes on another equally valid policy, more reliable bus journeys, is neither acknowledged nor addressed.   Another example is that of densification of development and accessibility to public transport hubs.  As far as we can see there is no mention of the existing capacity problems on trains, buses or on the roadway itself.

We consider that PTAL measures are no longer fit for purpose in that there appears to be no requirement for the Local Planning Authority to review the capacity of the Public Transport accessible to new developments.

We look forward to participating in further consultations on individual proposals as these come forward.

Q 1.  Sustainable Transport System

Overall the challenges are correctly identified but insufficient weight has been given to the need for integration of measures and the effect of one measure on another.  Currently it appears that bus and cycle lanes are in competition, there is no acknowledgement that road capacity, even with reduction in private car and freight traffic, is finite and that further limitations such as low bridges can reduce the size of buses.

Traffic light phasing can appear eccentric.

Clapham Junction already operates at capacity or above at peak times.  Longer platforms and trains will help but congestion is likely to remain a problem.  It is notable that the Overground line across the Cremorne rail bridge is cited as accessible for major new developments at Wandsworth Town Centre, Grant Road, York Road, Lombard Road and across the river at Imperial Wharf and Earls Court.

We are concerned at the increase in private car parking provision on ‘Red routes’.  We understand that the Red route designation is no longer supporting bus, cycle and other traffic priority but merely notes that this is a road managed by TfL rather than the local authority.  We can very rarely see the justification for there to be private car parking on Red routes.

Q.2  Overall vision

We support the aim that by 2041 at least 80 per cent of Londoners’ trips will be made on foot, by cycle or using public transport as opposed to the 64 per cent of trips currently made by one of those modes.

Q3  Further strategic aims

We are not sure that it is part of a transport policy to ensure that at least 20 minutes of active travel is undertaken by all Londoners each day. 

We can hardly object to the aim of zero deaths by bus and for deaths and serious injuries to be eliminated.

We are unclear what precisely is meant by ‘the principles of good growth’.

We support all other aims in this section.

 Q.4. An improved environment for walking and cycling.

The need for safe spaces for cyclists is vital and an increase in cycling as a mode of transport is an excellent aim.

We are, however, concerned at the way in which walking and cycling are bracketed together and the lack of understanding of the need for shared spaces to be engineered to be safe and pleasant for both.  For example, where bus stops are separated from the pavement by cycle lanes (e.g. at Elephant and Castle and proposed along Battersea Park Road and Nine Elms) pedestrians face unfamiliar layouts.  They have to cross cycle lanes in which cyclists may be travelling quite fast, and in both directions.  Clearer pedestrian crossing area markings should be included for these.

The majority of cyclists are thoughtful and use the roadway and any cycle lanes provided.  Where using the roads they observe traffic signals and drive at a safe speed.

This is not universally the case and little seems to be done to counter the use of the footway, breaches in observing traffic signals and, in the case of courier cyclists, sheer speed both within shared spaces and on the road.

Much more needs to be done to learn from the experience of other countries, such as Denmark and Canada, where there is a longer history of managing shared spaces.

Proposal 6.  We would welcome more clarity about the cost to the London council tax payer of the cycle hire scheme.  In some cases racks of cycles have been placed on the footway, in at least one instance in Battersea requiring pedestrians to detour onto a non-paved area.

It could be good for the health of Londoners to walk to a pedestrian crossing or managed traffic lights rather than increase the number of zebra and other crossings.

Differentially phased traffic lights, eg at the junction of Battersea Park Road with Latchmere and Battersea Bridge Roads are at best disconcerting and at worst potentially dangerous.

5.  Reduce road danger and improve personal safety and security

While overall we support these aims we are concerned about some aspects of the proposals.  The majority of the 16 points outlined on p.55 are excellent but we have a caveat about lighting.  While good lighting is important a deserted street, however well lit, does not feel safe late at night.  Light pollution is a growing problem for residents and for wild-life.  20 mile speed limits are rarely enforced and we are not in favour of traffic humps with the stop/start effect on traffic noise.

6.  Reduced risk of crime or fear of crime

We support these aims but again where there are concerns, a visible law enforcement or transport staff presence is necessary.

7.  Prioritise space-efficient modes of transport.

These are good, common-sense proposals.  We welcome the increased use of rail and river for freight and the proposal for a Construction Consolidation Centre.  We do not think the need for the inevitable increase in postal shopping and delivery vehicles has been fully recognised. There is a need, for example, for all new developments to provide off-road parking space for delivery vehicles.

8.  Road User Charging

We are not clear whether the re-introduction of the Western Congestion Charge area would allow for residents in that area to access the Central Zone.  If this was the case it would have a possible detrimental effect on traffic in the central zone.  However if this were not the case there might be merit in a re-introduction.  There are some drivers who are undeterred by parking fines or congestion charging.

9.  Localised Traffic reduction strategies.

Makes good sense10. Reduced Emissions

Vitally important and we welcome all measures designed to address this.  We can see no reference to the pollution and noise nuisance caused by coaches, minicabs and delivery vehicles leaving their engines running while parked.  This is a particular problem near schools, minicab offices and park playing fields.  We would like to see heavy fines imposed for recurrent offenders. 

Re proposal 27 – will this include tourist buses which appear to add considerably to both pollution and congestion?

11.  Protect the natural and built environment

Welcome all measures to protect the environment, increase tree planting and reduce noise.

Proposal 42.  We are concerned that local government funding constraints appear to be reducing effective and regular gully cleaning.  Local authorities should put in places measures to reduce or halt the installation of non-permeable garden surfaces.

12. Attractive Whole Journey Experience

Proposals make good sense

13.  Affordable fares and good customer service

The drive to keep fares down should not be at the expense of staffing.  The lack of ticket offices is to be deprecated.   Staff reductions have gone too far. 

14.  Accessible transport

Improvements are to be welcomed.


15.  Improved bus network

Proposals are welcomed.  Bus lane extensions and bus lane priority are strongly supported.  But note comment on cycle lanes and on private car parking on main roads above.

16.  Improved rail services

We are concerned that the measures proposed will be insufficient – see introduction and comments re proposal 75 below

17.  Integrated transport

Overall this is good sense.

Proposal 72 suggests that some traffic from Victoria Coach Station might be relocated.  This proposal is counter to an earlier one proposing increased access to the Coach station.  It could make sense to have a satellite coach facility with good access to rail or underground to reduce the quantity of coaches travelling out of London from Victoria.

We welcome the proposal (73) to limit the number of private car vehicles.  We have been told that Uber’s ability to respond fast is because drivers wait on busy roads in defiance of waiting regulations and if this is the case, it must increase congestion and pollution. 

18 New Homes and Jobs

We are very concerned about the proposal that densification should be encouraged (proposal 75).  We are also uncertain whether this is properly part of a Transport Strategy rather than being part of a holistic issue for strategic development in the capital.

To repeat our comments within the introduction, PTAL measures are no longer fit for purpose in that they are concerned merely with notional access rather than capacity.  We fear it will take an accident, at Clapham Junction or elsewhere, for this to be recognised.

It is quite clear that new and approved developments from Lambeth Bridge to Wandsworth Town Centre via Nine Elms, Battersea Park and York Roads do not fulfil the espoused principles of good growth.  The new developments are in no way creating an attractive environment where they border directly on to main routes.  Many buildings run to the edge of their land leaving narrow pavements.  A poor and unsafe environment is being created for pedestrians trying to access the often heavily overloaded public transport stops. This is an existing problem which will be with us well through the period covered by this strategy.

It is essential (proposal 77) that all new developments provide off-road short term parking for delivery vehicles.  Increasing postal shopping is inevitable.

Battersea Park Station is no longer fit for purpose with frighteningly steep stairs up to very narrow platforms.  This station is likely to have increased use as developments are occupied in this part of Nine Elms/Battersea Park Road.  Urgent work is needed.

19.  New Rail links, extensions etc.

We broadly welcome these proposals.

We welcome the support for the Millennium Bridge at the Cremorne Railway Bridge.

We ask that you consider opening up or reinstating rail stations, such as that at Battersea High Street, as well as planning new ones.

 20.  Heathrow Expansion

We are opposed to Heathrow Expansion on the grounds of noise and air pollution and support your policy on this.  We are far from convinced that the proposed transport infrastructure is feasible or would be put in place in sufficient time.