The Battersea Society: Planning Committee submission The Battersea Society website 

Planning Committee Submission

Added on: 7 November 2018 at 13:33:15

Response to TfL Central London Bus Services Review


The Battersea Society accepts the need for  a proper review of services within Central London but proposals in this review are partial, ill-considered, rushed and take no account of the negative impact on neighbouring areas within Zone 2.   They should be withdrawn and more work undertaken.

We concentrate on change proposed within routes which serve Battersea or are regularly used by Battersea residents, leaving user groups familiar with other areas of London to make objections to these proposals should they wish.

1.  Partial and inadequate review

 The review notes at the start that:  “These measures will help make bus services better to use, but we recognise that more needs to be done to re-shape and improve the bus network in Central London.”

There is no indication as to why these routes have been chosen for amendment or how this review forms part of a coherent plan of action for Central and Inner London bus routes.  There is no sense of a strategy being developed in relation to waiting and journey times for key routes across Central London linking to adjacent outer zones.  In particular an identification and statement of approach to areas regularly suffering bus lane congestion – for example Oxford Street, Fleet Street and the Strand – should have underlain this review. 

We do not agree that the measures proposed will have a significant impact on congestion or on the reliability of services.  In the case of Piccadilly they propose adding the 9 and the 22 to the congestion at Piccadilly Circus. and propose adding extra stops in Piccadilly which we assume will further increase the congestion from standing buses.  It seems likely that Piccadilly is set to become more like Oxford Street with an over-supply of slow moving buses.

It is our experience that the 14 and 19 are reliable routes with a welcome frequency for those travelling to and from Shaftesbury Avenue from Battersea and Chelsea.  Likewise the 11 is an extremely useful, and reliable, direct route from Chelsea via Victoria to the Strand, Fleet Street and through to St. Paul’s.

2. Ill-Considered

We can see no overall logic in the selection of individual areas nor, unless we are mistaken, can we find material showing the overall impact on the Central London Bus Map of all these proposals.  It would have made sense, for example, to show the cumulative impact of these proposals on key roads in Central London or at the least the cumulative effect on each road where the various proposals intersect.

This lack of coherence continues in the omission of the mention of other routes along key roads, for example in the King’s Road the 49, 211 and 319 run alongside the 11 and 19 and in Piccadilly the 6 (recently added) and the 38.

There appears to be no mention of a review of services in Oxford Street – one of the most frustrating and congested bus routes in Central London.

3.  Rushed

We have no confidence that this consultation could lead to changes given that the consultation closes on 9 November for implementation, we are told ‘early in 2019’. It would be better if more time was spent on considering the results of this consultation and bringing forward revised proposals for final consultation.

4.  Provision within Neighbouring Areas

Battersea is experiencing  major growth with a very substantial increase in population with major developments currently being built or already consented along the Nine Elms Lane, Battersea Park Road and York Road corridor together with more in Lombard Road and the riverside between Battersea and Albert Bridge Roads.  In addition consent was recently given for a change from office to residential for the Glasshouse at Battersea Bridge and a number of other office buildings in the area.

Rather than withdrawing a vital service, the 19, TfL should be reviewing the inadequacy of existing routes for the current residents – let alone those moving in to new residential developments.  The lack of capacity on the 170 is already a matter of concern for councillors and residents alike who await some improvement in this service.  The 44, while a welcome service to Victoria from further south, is frequently subject to delay.  The change in the route of the 44 has led to only the 344 travelling along Battersea Park Road west of Queenstown Road with no stop east of Queenstown Road allowing an interchange between the 44, 344 and 156.

To add to the insult of the lack of consideration of this major growth, the response by TfL is to put on hold a review of services along Nine Elms Lane and Battersea Park Road in favour of this set of proposals.

5.  19 Bus Route

The Chair of the Battersea Society has detailed our objections to these proposals fully in a separate letter, (to be found here).  This should be read as part of this response to this consultation.  The key points she makes are:

Loss of a bus route northward starting empty at Battersea Bridge will severely reduce accessibility both for existing residents and, in the future, for those living and working in the approved planned developments immediately south of Battersea Bridge.

  1. The level of journeys affected at 18% or 5,200 is unacceptably high

  2. An equality impact assessment of High is unacceptable

  3. Analysis is focussed on the King’s Road to Victoria and takes no account of journeys from the south side of Battersea Bridge and onwards to and from Shaftesbury Avenue.

  4. An implementation date of ‘early 2019’ for a consultation closing on 9 November suggests that no heed will be paid to the results of the consultation.

6.  Equalities Impact Assessment

As noted above, this is inadequate in its proposals and in its preparedness to accept high impact thresholds for those with reduced mobility.   Shelters and a seat are essential for those who are unable to stand for lengthy waits, yet have sufficient mobility to use buses. The conclusion that there is no shelter or seating at major interchange stops on 11 out of the 19 route changes is not acceptable.  The length of walk proposed from the 19 Battersea Bridge stop to the King’s Road across a dangerous and polluted major highway would be unachievable for many and onerous for all but the most fit.  It is cavalier in its dismissal of a large number of Battersea residents whose access to a bus route to Piccadilly and beyond would be severely hampered. 

6 November 2018