Air Quality Action Plan – Just not good enough

This is the Richmond Cycling Campaign Response to the Council’s Air Quality Action Plan.

You can see the consultation here – you have until October 30th to respond. The actual plan is a PDF, here

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(Pollution in Richmond. Image courtesy )

The council correctly identifies that the primary source of air pollution in the borough is motor transport but, unlike the Mayor’s Transport Strategy, or TfL’s Liveable Neighbourhoods plans, or Greenwich and Camden’s Air Quality Plans, our council doesn’t think that persuading people to use other modes of transport is a good way to deal with this.

Early in the document, we’re told that the most polluted place in the borough – George Street in Richmond – would need traffic reductions of up to 75% to bring its air into line with the required threshold. The problem is that virtually none of the actions identified in the document would help to achieve this.

We think the document has a number of problems.

Money

Other councils haven’t allocated specific budgets for specific activities, but Richmond attempts to do this. Which means that there are an awful lot of actions which require people to do things, but include budgets of £0. Since there’s no commitment to increase staff numbers to support the plan, we must assume that the dozens of £0 actions will fall on the shoulders of either the Director of Public Health, or the Air Quality Manager.

We think that the proposal needs to include a proper allocation of either money or staff time for each proposal.

Measuring

Not a single proposed action has any attempt to measure the effect that it may have on air quality in the borough. Whilst we understand that some things are going to be quite hard to quantify, such as ‘Consider further local restrictions on bonfires’, we must surely need to understand where the worst problems are, in order to actually address them.

As an example, there are actions on the fleet of vehicles used and own by the borough. We know how many vehicles there are, we know what their emission ratings are, and we know what the emission ratings are for newer/different vehicles.

We think many of these actions need meaningful measures. In order for people to be able to reply in a useful fashion to the consultation, we also believe that the actions could at least show relative value to Air Quality changes. (For example, if people knew that campaigning on Heathrow would make more of an impact than putting up electric charging stations, they would be able to choose the former over the latter with some evidential backing.)

Incentives

Very few of these actions discuss the incentives that parties have in order to comply with them, and much of the monitoring involves items which fail to measure the actual changes involved. For example, the plan wants to ‘encourage’ local HGV, coach, van and taxi operators to sign up to FORS or other schemes, but the whole activity has £6,000 allocated, and has no proposal how this encouragement might happen.

Missing Ideas

Section 2 (p4) describes how boroughs have an important role to play in dealing with air quality, and mentions five key policy ‘levers’ available to the council:

  1. Emissions based parking charges
  2. Reducing pollution from new developments
  3. Improving the public realm for walking and cycling
  4. Targeted measures at pollution hotspots
  5. Supporting infrastructure for zero-emission vehicles

Of the five, (a) is completely ignored, and (c) and (d) appear to have no meaningful action associated to them.

Inspection of plans from Camden and Greenwich as examples, shows a slew of activities which they’re planning, that most people would be able to look at and say “I can see how that would improve air quality in my area.”

These include:

  • enforcing anti-idling. (i.e. requiring people to switch their engines off when stopped in traffic, at level crossings, etc.)
    Richmond’s proposal for this at least has some teeth, with an apparent plan to actually begin enforcement
  • Persuading people not to drive
    In both plans, there is a stated aim to persuade fewer people to use cars for some of their journeys in the borough. Richmond, although recognising the contribution of motor transport to air pollution, has no plans to do this, either directly or in-directly.
  • airtext service. Promotion at doctors’ surgeries
    Both boroughs suggest more active ways to warn people about pollution. This includes more substantial communications – like at doctors’ surgeries – that does not rely on poorly used websites or passive notification
  • encourage mode shift from diesel with parking charges
    Camden and Greenwich envisage using their car parking zones to encourage people not to have diesel cars through higher charges for owners of the most polluting vehicles. We recognise council claims that this may weigh unfairly on the owners of such vehicles, but it is at least a policy which has identifiable benefits which can be quickly realised. Perhaps, though, when we worry about the owners of these vehicles, we could also worry about the 25% of the borough who don’t even have a motor vehicle, or the majority of children and young people required to pay with their lungs for our lack of action.
  • explore emissions based parking charges
    Both boroughs propose using parking charging at council car parks, etc., to persuade people not to bring highly polluting vehicles into the borough. Richmond has no plans at all n this area
  • Car free / pedestrian priority days
    Greenwich and Camden are both planning to trial these as ways to improve air quality in key areas. No such ideas are present for Richmond.
  • 20mph
    Greenwich and Camden correctly identify that increasing the areas with 20mph limits will reduce pollution. Why isn’t Richmond doing the same?
  • LBCC “London Borough Consolidation Centre” … supporting this. Are we? Don’t know

Good Stuff

There is good stuff in the proposal, in our opinion.

The document highlights the objective ‘to enhance travel choice and reduce congestion’. We’d like to see this even more clearly as an aim in the AQAP, as providing this has benefits for wider public health, as well as air quality.

The document identifies (p4) that ‘road transport [contributes] more than 50% of the overall emissions of nitrogen dioxide and particulate matter within the borough.

We welcome the interest in the TfL STARS project (on school transport, p6), as anecdotal evidence suggests that travel to and from school has a significant effect on borough congestion and air quality. We would like to see more concrete council action on this: every school in the borough has a transport plan, and almost all have asked for specific measures which will make active travel safer and more attractive. The council needs to act on these. (Examples include 20mph zones outside schools, providing proper cycle routes outside schools, improving pedestrian facilities, etc.)

Not So Good …

Page 6 has nine ‘key priorities’ for the five years of the new Air Quality Action Plan. It is very disappointing that not a single one of these priorities is to actually improve air quality by a measurable amount. Unfortunately the priorities, like many of the proposed actions, involving talking, meetings, or measuring / documentation. Whilst all of these are key elements, the absence of concrete actions is worrying, because it implies that there is no ambition to actually improve air quality in the borough to at least the current standards.

There’s not much talk about ‘Active Travel’. We would like the AQAP to follow the draft guidance from the Mayor of London on promotion of active travel, and discouragement of motor vehicle use.

Electric vehicles: much store is set by encouraging greater use of electric vehicles. While this will make a significant difference to the level of exhaust pollution, there is a growing body of evidence that air and particulate pollution comes not merely from exhaust gases but from brake, tyre and other wear and activity.

Combined with the fact that an electric car takes up just the same space as a normal car – and therefore causes the same level of congestion – we would expect to see an Air Quality Action Plan providing more imaginative and useful proposals for the most congested roads, and the worst pollution areas.

Summary

This isn’t good enough. Richmond Cycling Campaign does not support this document as an acceptable response to the current public health crisis, for all the reasons detailed above. The council should be ashamed not merely of its failure to take action thus far, but also of its basic proposals to do virtually nothing of any substance for the next five years, unless someone else does it for them (TfL and buses, for example).

 

 

Rides for Everyone : Crane Park new link : Saturday 21st October

new path

The path  from Twickenham Station to Crane Park should have been open in September but wasn’t. This Ride will either use it or send a photo of us at the locked gates to the press. (there is a by-pass) Meet Twickenham Station 10.15.

I am looking at this route that looks at a few newish paths in Hounslow as well. (Coffee in Feltham ?

8 miles flat and 6 of them traffic-free.

Contact .- rides@richmondlcc.co.uk

Rides for Explorers – Surrey Woodlands – Sunday 8th October

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Meet at Twickenham Riverside 10.00. We head out across Bushy Park and through Thames Ditton to Littleworth Common and Ardbrook Common to reach Cobham. Crossing the Mole we follow lanes to Bookham Common and up to to NT cafe outside of Polsden Lacy. On the way home we add Oxshott Common and Claygate woods.

37 miles mostly away from the traffic.

Route

Just 3 of us met up. The conditions were great and fairly dry across the commons so that ,even with  a half hour visit to the gardens at Polsden Lacy , we were back in Twickenham by 14.30.

Rides for Explorers : Burnham Beeches : Sunday 12th November

P1010957aMeet Twickenham Station before 10.05 to catch the 10.15 to Staines.(arr 10.30) We cycle through Staines Moor then via Colnbrook , through Langley Park and past Black Park to  the woodlands of Burnham Beeches in their autumnal splendour. After lunch in a woodland cafe  we head down to the Jubilee River path which takes us to Datchet and so back to Staines. About 30 miles mostly tarmac with some smooth gravel paths. Quite scenic / hilly.

Route

Strategic Cycle Routes

I have been banging on about deficiencies in the borough’s plans for some time. To push some more I have written a brief paper that I hope to get onto the agenda for the next CLG.

Richmond Cycle Routes

What I have tried to produce is the draft for a system that would provide safe , reasonably direct, routes for all bike users  8-80+ across the borough and into adjacent boroughs at least during daylight hours and that is realistically achievable.

Any constructive comments gratefully received

Paul rides@richmondlcc.co.uk

Rides for Everyone – New Path from Twickenham to Crane – Sat 30th September

new path

UPDATE – RIDE POSTPONED: PATH STILL CLOSED !!

As can be seen the path  from Twickenham Station to Crane Park should now be open in September so we can have a celebratory ride. Meet Twickenham Station 10.15.

I am looking at this route that looks at a few newish paths in Hounslow as well. (Coffee in Feltham ?

8 miles flat and 6 of them traffic-free.

Contact .- rides@richmondlcc.co.uk

Cycling Liaison Group – a Shopping List

CLG Notes – July 2017

We’ve got quite a few things for the Cycling LIaison Group, and for the council.

(a) The “Walkway” seems to be the route by the Old Sorting Office site development from Twickenham station – to Craneford Way playing field. The question is will it be (when finally open) officially a cycle route – and if not why was that not demanded as part of planning permission.

(something similar seems to have happened in Hampton Wick when the riverside route was initially going to be a cycle route but then acquired a gate.)

The Wellesley Rd – Fifth Cross Rd link for connecting Strawberry Hill station to Crane Park shared use path requires more than just signing. (interestingly it appears on the Borough Cycling Strategy map.)

(b) The need for a working party to be set up to look at the case for establishing and publicising a Richmond Cycling Network. (There is a map in the council’s documents, but it shows too many routes which are clearly not appropriate for everyone to cycle on.)

(c) RUTC to give proper consideration to the impact on cyclist safety of the road restrictions and closures in place during RFU events

(d) The need for RUTC to arrange for traffic Wardens to stop motorists from parking on double yellow lines, particularly at corners, where the reduced visibility of passing traffic puts cyclists and pedestrians at risk. Additionally, double yellow lines often protect stepless pavement access, which is important for wheelchairs, prams, and a variety of other pavement users.

(e) Parking at Kew station. We’ve asked about this before – the station needs more bike parking on both sides, but especially on the North Road side.

(f) The council recently consulted on changes to the Star and Garter roundabout. According to email discussions with the council, this is being considered for possible 20mph zoning. We’d like to know why we only hear about these things via email, and what the process is for this.

(g) Also on the Star and Garter consultation, we are very disappointed by the entire consultation process, as well as the proposed designs. The consultation failed to clearly show the proposed changes, didn’t show what analysis had been undertaken, and didn’t offer any options. Most importantly from our point of view, it offers no improvements at all for cycling.

(h) We looked at the minutes from January 2016 (here). It’s hard to see what progress has been made on virtually any of the items listed:

  • Kingston to Hampton Court cycle links
  • Rocks Lane cycle route
  • Mini Holland funded cycle routes
  • Sheen Road cycle route
  • Fifth Cross Road / Wellesley Road cycle route
  • Contraflow cycle routes
  • Simultaneous green junction

(i) In a consultation on the Uxbridge / Hampton Road junction, pavement and park space is being taken away to increase road space for queuing cars. Why are we sacrificing park space for traffic? Why are there no options on the table beside having more cars in the area?

(j) Cycling information is buried on the council website – it’s virtually impossible to find the cycling liaison group and it is poorly publicised.

(k) The Mortlake Brewery and St Mary’s University developments seem to have no council plan for walking and cycling. Why? These are excellent opportunities to push for more active travel and to provide attractive active travel options, but the council has done nothing.

(l) Twickenham Riverside. Why is cycling not included? Why is there no cycle parking, no cycle routes? We have spoken to the council about this for more than 3 years, and yet still designs never include walking or cycling properly.

Star and Garter – stop making sense!

This is an email thread with the council about the council’s Star and Garter consultation. You’ll need to read it from the bottom. But the things that worry us:

  1. Someone actually thought about cycling, then realised they couldn’t even design in a painted on bike logo
  2. Someone else is apparently thinking about 20mph in the area. Which is news to everyone we know.
  3. The council doesn’t understand the point of consultations. This provides no options, no analysis, doesn’t accurately show what is changing, and assumes that interested parties are going to try to go to the planning portal to understand the context for these things. There’s surely no better way to make sure no-one responds.
  4. Honestly, the council has no idea what makes for acceptable cycling conditions.

________________________________

Dear RCC,

As stated in my previous email, the changes being made directly outside the Star and Garter development were agreed as part of the planning application. Members of the public would have been given an opportunity to comment on these as part of this planning application.

The main alteration here is the addition of a new footway outside Ancaster House, which is highlighted on the consultation plan. The remaining changes consist of minor elements to bring the layout in line with the current standards. These type of changes usually addressed through our maintenance programme, but will be undertaken as part of this project while we are working in the area.

The ‘build out’ you refer to on the roundabout is a form of horizontal deflection. This is a requirement on mini-roundabouts to prevents vehicles speeding through the junction or failing to give-way. This is a safety feature that benefits all road users, including cyclists.

You refer to the road widening, but the overall carriageway width here has actually be reduced to accommodate the development works. Although this has been mitigated by removing the central hatching, to maintain the required lane widths.

As previously mentioned the 20mph proposal has not fully been investigated, and as such is not ready to be consulted on.

Regards,

[Council]

 

From: Borough Coordinator [mailto:info@richmondlcc.co.uk]
Sent: 05 July 2017 21:31
To: [Council]
Subject: Re: Star and Garter Consultation.

[Council],

I apologise if I didn’t make it clear, but I think there are a number of questions to be answered here.

  1. Why does the consultation document and diagram fail to explain what changes are actually being made to the road layout?
  2. Why is there a build out on the roundabout? What is its purpose? Did anyone think how this might affect cycling?
  3. Why does this road need widening at this point?
  4. Why was there so much information offered subsequent to the consultation which wasn’t included *in* the consultation?
  5. If there’s a 20mph plan, why is this the first we’re heating about it?

You may be aware that the Cycling Liaison Group is on 25th July. I would hope the council can provide some of these answers in advance of the meeting.

Sincerely,

Borough Coordinator, Richmond Cycling

 

On 6 Jun 2017, at 23:17, Borough Coordinator <info@richmondlcc.co.uk> wrote:

Dear [Council],

Thank you for taking the time to write back. I’m afraid i still don’t understand a number of things about these plans.

Firstly, the consultation document doesn’t actually show what changes are being effected to the junction area, with most changes un-noted. I don’t think it is reasonable for people to expect a clear statement here of what is changing. As an example, the roadway is being widened by a significant amount, through the removal of central ‘hatching’ on the approach to the gate, but this isn’t shown.

Secondly, there is a small but important new build out on the roundabout opposite Star and Garter. What is this for? Why are we – at a clear pinch point – forcing cyclists further towards motor traffic?

Thirdly, can you explain to me why the road needs widening at this point anyway? If you’re not prepared to put in cycle lanes, then widening the road isn’t going to make cycling better, I would suggest.

Finally, you provided a lot of useful information in your email – and I think it’s fair to say that this should all have appeared on the consultation: you’re asking us to accept these changes in the context of potential larger plans, so why is none of this mentioned?

I should probably also add that I’m am in no way looking forward to hearing of another Richmond cycling scheme which involves painting big bike roundels on the road and fantasising that it will make the blindest difference to people on bikes, or people who might be considering getting on a bike: it’s really disappointing that in 2017, the borough’s ambition is so spectacularly limited.

Sincerely,

Borough Coordinator, Richmond Cycling

 

[Council] wrote:

Dear RCC,

Thank you for your email.

The work being undertaken on Star and Garter Hill, Richmond is a relatively minor scheme, to implement the new bay outside the Star and Garter development. This will be a very limited stay drop off / collection bay for the residents here. The bay was previously agreed as part of the planning application for the development here.

The informal crossing facility is being removed was originally used by the support staff for the Royal Star and Garter home, that resided in Ancaster House. Due to the redevelopment of these sites, this is no longer a required movement. We have monitored this facility to ensure that it was longer used prior to proposing that it was removed.

The carriageway width in this location is too narrow to implement an on road cycle facility, however we are considering a 20mph speed limit/zone in this area. As this does not require any civil works we are not, restricted to the July construction window. Once this has been fully investigated and developed, this will be consulted on as a separate scheme. As part of this works we will be looking into the implementation of cycle symbols on the ground. Unfortunately we are unable to progress with element until the development of the 20mph works, as there will likely be some conflict around the locations of the 20mph roundels and the cycle symbols.

I hope this information useful

Regards

[Council]

www.richmond.gov.uk / www.wandsworth.gov.uk

From: Borough Coordinator [mailto:info@richmondlcc.co.uk]
Sent: 15 May 2017 23:06
Subject: Star and Garter Consultation.

Hello,

I’m writing on behalf of Richmond Cycling Campaign to complain about the poor proposals on Star and Garter Hill: http://www.richmondlcc.co.uk/2017/05/15/star-and-garter-yet-another-missed-opportunity/

I find it very hard to believe that the best engineers could come up with was wider traffic lanes, a new pinch point, and a consultation document which didn’t even show clearly half of the proposed changes.

This is a large sweep of tarmac which already tacitly encourages high speeds from vehicles not using the park entrances – and the proposals only make this worse, but providing an even wider lane heading into and out of Richmond. You could have included a proper pedestrian crossing on every arm of this roundabout, or used traffic lights to better allocate the space, or really marked any kind of cycling provision whatsoever. But instead, there’s a nice new loading bay outside Star and Garter – which seems not to look much different from the old one – and you’ve actually **removed** a potential pedestrian crossing point (here).

Before anything goes ahead, the very least the council can do is to clearly indicate **all** the changes at this junction, explain why walking and cycling hasn’t been included, and explain the schedule for any safety plans which are supposedly being looked at.

Sincerely

Borough Coordinator, Richmond Cycling
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RCC is a branch of London Cycling Campaign

Twitter: https://twitter.com/richmondcycling

Web: http://www.richmondlcc.co.uk/

Facebook: https://www.facebook.com/richmondcycling/

 

 

 

Ride for Everybody – Feeder Ride to London Freecycle

Saturday 29th July.

FreecycleFeederEnjoy a day in Central London free of motor vehicles.

We meet on Richmond Little Green 10.00 and head off via Putney Riverside, Wandsworth Park and Battersea Gardens and then up through Belgravia to join the Freecycle where Central London roads are traffic free. Leave London for the ride home at 15.00.

Our routes in and out.

About 80 of us met up and enjoyed a good ride up to London and saw some  parts of town that were new to many. The Freecycle route itself was busy, but not impossibly so, and, as usual, it was great to see so many cyclists, some very young, making full use of London streets. With rain starting only about 30 chose to join us for the trip home and we got back to Richmond by 16.30 in a damp but unbowed condition.

As one participant said “there should be a straightforward way of cycling into London” but there isn’t , at least not without battling one’s way through heavy traffic. Our circuitous route meant that we were little affected by traffic until we hit Barnes and Mortlake.

Thanks to Jim, Jean, Ian , Cameron and Tim for looking after everybody.