Stag Brewery – we’re not happy

We’ve responded to the Stag Brewery consultations, and we’ve objected.

Whatever you may think of the development itself, our concern is that it fails to support active travel, and it utterly fails to making walking and cycling compelling options for the area.

The consultation has three parts – the main site, the school, and Chalker’s Corner.

Our responses are below. Please take a moment to tell the council they aren’t good enough on these links:
Application A – the main site
Application C – Chalker’s Corner

Application A Response

I am responding to this planning application on behalf of Richmond Cycling Campaign, the local branch of London Cycling Campaign.

We object to planning application A on the following grounds:

On transport issues, Application A does not meet LBRUTs own requirements as set out in the LBRUT Development Management Plan .

In particular the proposal does not address the requirements to:

  • Create or improve links with the local and wider transport networks, including links to the cycle and pedestrian networks (see page 101)
  • Protect maintain or improve the pedestrian environment (see page 103) for the increased number of pedestrian movements on & off the site
  • Maintain and improve conditions for cyclists (see page 105). With the increased population & increased number of journeys, conditions on the roads & towpath are likely to be worsened for cyclists.
  • Ensure that excessive parking demand  is not created which could have an adverse impact on the local highway/ traffic conditions (see page 106)

In general, we object to the overall failure to ensure that active travel is a core element of this development: as a dense development in an area with good access to a wide range of facilities, this is a design which should have all the key elements of active travel ‘baked in’ at this early stage. Until we see designs which included dedicated cycling facilities through and around the site, sufficient cycling parking for all residents and visitors, and the prioriitisation of links for people walking over people driving, we do not believe this application should pass.

Application C Response

Dear Richmond Council.

I am responding to this planning application on behalf of Richmond Cycling Campaign, the local branch of London Cycling Campaign.

We object to planning application C on the following grounds:

  1. It is in breach of the Mayor’s Transport Strategy goals because it fails to support the aims for reduction in motor traffic, and proper support for walking and cycling.
  2. The design utterly fails to provide suitable conditions for walking and cycling, and prioritises the movement of large volumes of motor traffic over all other uses at the junction.
  3. The overall design for the area and the development does not have any provision for walking and cycling from the development to any destination. Only the existing provision (of pavements, and small sections of unsafe cycle lane) remains.
  4. For a site with a 1,200+ person school, the absence of active travel provision is unacceptable. (Whatever the size of the school, there is clearly insufficient capacity for the increase in footfall or cycling which would be required to not turn the entire area to gridlock.
  5. We believe that any plans for Chalker’s Corner needs to be part of a wider traffic strategy in the area which is designed to move through traffic away from non-trunk roads, and which “bakes in” segregated cycling provision and safe walking provision to provide local people with genuine options for how they move around our borough.
  6. The plans and design are not in compliance with council strategies on air quality and traffic.
  7. The designs do not meet the requirements set out in the council development management plan: In particular:
  • Create or improve links with the local and wider transport networks, including links to the cycle and pedestrian networks(see page 101)
  • Protect maintain or improve the pedestrian environment(see page 103) for the increased number of pedestrian movements on & off the site
  • Maintain and improve conditions for cyclists(see page 105). With the increased population & increased number of journeys, conditions on the roads & towpath are likely to be worsened for cyclists.
  • Ensure that excessive parking demand  is not created which could have an adverse impact on the local highway/ traffic conditions(see page 106)
  1. The proposal is not compliant with TfL’s ‘Streetscape Guidance’, the London Cycle Design Standards (LCDS), nor does it include a Healthy Streets check. It is our opinion that the designs would fail both an LCDS review, and a Healthy Streets check, with Chalker’s Corner including a number of ‘critical fails’ in the LCDS review.

In general, the failure to provide for active travel is a fundamental failing of this plan. If we build dense new developments like this, which assume high levels of car use, then that is what we will get.

Local Elections – Call your Candidates!

Here’s what we’ve written to the leaders of all the parties in Richmond’s up-coming elections.

Can you contact your candidate and ask them? Use this link!

And if you’d like to know more about what a great Liveable Neighbourhood is, LCC & Living Streets have put these excellent documents together.

Liveable London banner

Dear Councillors and candidates,

London Cycling Campaign and Living Streets are urging you to support better walking and cycling in our borough.

The borough already has some of the best stats for ‘people who at least cycle occasionally’ in the whole of London, as well as a good modal share of cycling (at 7%), compared to many outer London boroughs. You may also have seen the recent data from TfL showing just how many journeys are walkable or cyclable, based on their distance.

For too long, we’ve focused the borough’s energies on making it easier to drive a car – we think it’s about time the focus became ‘easier to walk and cycle’. The ‘Liveable Neighbourhood’ ask from LCC and Living Streets is that we commit to a bid which does this. It’s all TfL money, so it’s not even something we need to pay for – but the only way we get the money is by showing real commitment.

To our thinking, almost as important as the fact that we don’t need to find this money ourselves in these tough times, is the strong emphasis from TfL that public consultation is crucial. The TfL Liveable Neighbourhoods plans include a specific allocation for public engagement, and for making the case for walking and cycling.

But as well as the Liveable Neighbourhoods bid, we’re asking you, as prospective councillors, to speak out about all the benefits of walking and cycling. We know from more than five years of consultations in this borough and across London that projects like this struggle badly if local councillors and officials don’t understand or don’t support measures for walking and cycling.

Great cycling facilities enable everyone to cycle, so please take the time to look at the documents LCC and LN have prepared, and think about how you can help make our borough a better place for everyone.

Borough Coordinator, Richmond Cycling

Quietway Consultation Response

This is our response to the Ham Quietway (QW1) consultation
ou can see the drawings in this PDF. We urge you to make your own response: you can fill in the questionnaire, or email the council team directly at

Richmond Cycling Campaign generally supports the changes proposed in this consultation, but we have specific concerns which we think need to be addressed in order to maximise the appeal of this route to people who cycle now, or who are considering it.

Taking the individual sections:
Ham Gate to Upper Ham Road
At 2.5m this is probably a minimum width to be shared between walking and cycling, and we predict that on busy days there will be conflict between the two modes because of the width.
The entrance to the park is also a potential area for conflict, as the design seems to suggest cycling joins the main road at this point.
The priority for this path over the driveways and crossings on the route is a very welcome change for the borough, and should benefit both walking and cycling.

At the traffic lights at the end of Ham Gate Avenue, we feel this is a poor experience for people cycling and walking. The design offers low capacity for these movements. It also requires someone cycling from the park to make two movements, whereas a driver needs only to make one. The design to then join Ham Common provides a very real likelihood that waiting traffic will block this junction, making it even harder to cross the road.

Fundamentally, if Ham Common is good enough to cycle on, then so is Ham Gate Avenue. If Ham Gate Avenue isn’t appropriate for cycling, then neither is Ham Common.

Even if we accepted the proposed movement, the designed turn from Ham Common onto the cycle route has extremely low capacity if – as is likely – someone arrives with a family, a cargo bike, or any other larger cycle. Again, conflict is being designed in if this route is used by the volumes we are hoping for.

Once on Ham Common, we welcome the change in design at Martingales Close, which provides a significantly better pedestrian experience. We are concerned that there are no parking changes on this road, however, because the volume of traffic here and the parking on alternate sides makes for a needlessly complex cycling environment which will especially deter less experienced and younger cyclists.

Risks around traffic volume persist on Lock Road. Although potentially suitable by volume and designed speed (20mph), this has some features – such as the speed cushions and build outs – which have a likelihood of causing conflict: we’d like to see some more analysis of how to make sure cycling gets clear priority in this area.

We applaud the proposed changes to the Broughton Avenue / Hardwicke Road crossings, as likely to make this significantly more inviting to cycling.

Similarly, the widening of the more obvious crossing is also a welcome change which we think will make a real difference to people cycling in the area.

Cycling Liaison Group – An Emasculated Quietway?

Richmond is going to get dockless hire bikes, but won’t get the full planned quietway. 14 separate roads are being lined up for contraflow cycling, North Sheen station will get a cycling channel on its bridge, the A316 quietway-or-superhighway-or-something-else isn’t going to happen any time soon, Twickenham Stadium will clean up their act on cycling signage on match and event days, and an improved design for Cross Deep junction to make it safer for cycling has been sent to TfL.

And every new transport scheme should now go in front of the cycling officer, so we’re hopeful that we will see fewer designs which go to great lengths to discuss car parking, but consistently fail to provide cycle parking, let alone anywhere nice to actually cycle …

Will this get some improvement?

Dockless bikes

The council seems to be running this a bit like a procurement exercise, even though they’re not planning to part with any cash. This has been in analysis for months, and we heard some slightly surprising things about what the council is worried about: bikes not being very nice, how good the apps are, and so on.

There are reasonable questions too: how do we try to keep pavements clear? How do we ensure bikes are picked up if left in places where no-one wants them? The good news is that Councillor Buckwell, the Cabinet Member for Transport, undertook that at least one company would be in trials by April – keep those eyes peeled!


The quietway plans managed once again to dominate the meeting with, in our opinion, appalling manners shown to the councillors and officers. The route was ridden by Will Norman, the walking and cycling commissioner, late last year, and he has refused funding for the Teddington High Street portion – according to the meeting this was essentially because he felt it was not good enough to be a quietway.

However, the council has persuaded TfL to go ahead with the other two parts of the route: from Richmond Park’s Ham gate to Ferry Road, and from …. to Bushy Park. While we would like to see a complete route, and we think Teddington High Street should be an important section, the scheme has basically foundered on NIMBY local opposition.

You may think we’re harsh to say ‘NIMBYs’ with such a broad brush, but it’s quite clear that neither the Teddington Society nor many of its members are overly interested in having people cycling along their High Street if that means they can’t drive or park. This is a shame, as it’s directly in contradiction to the Mayor’s stated goals around healthy streets, liveable neighbourhoods, and air quality improvements.

When we read things like this from members, though, it just reinforces our determination to make the case for good, safe, cycling through Teddington itself, for locals and for visitors. One member from Ham wrote this:

“I tried to cycle with my son to his swimming lesson at Teddington Pool on Saturday.  We gave up just beyond Ferry Road and (sadly unable to teleport) we walked, with our bikes, on the narrow pavement to disgruntled looks from pedestrians.  I can imagine that most people would resort to the car at this stage, which means going via Kingston or Richmond or not patronise Teddington’s shops and services.  We will walk but it will take twice as long and makes Teddington a less appealing destination than it would otherwise be. “


A total of 14 streets are in safety assessment for contraflow cycling. We hope they’ll come to consultation in March or April. Each of these will only be a small project, but we believe that building a proper network for safe cycling across the borough is going to need dozens of small schemes like this, all of which eventually link together.

The A316

This has been mooted for far too long, and we don’t have good news on it. There’s no schedule for when things are likely to happen, and we know already it’s been downgraded from a potential super highway to a quietway. We do know proposals are still being developed, so will be keeping our eyes open.

New transport schemes

For a long time, the council has been producing consultations where they seem to have either forgotten cycling, or stuck it in as a band aid afterwards – East Twickenham, Star and Garter [Richard Reynolds], and now East Twickenham.

As a direct result of Richmond Cycling Campaign lobbying, every scheme will now go before the cycling officer before it comes to consultation. Some of what we hope will result is:

  • Cycle parking considered as a matter of course
  • Better and more realistic analysis of ‘shared space’
  • Reducing conflict between walking and cycling

The RFU & Twickenham

As many of you will know, Twickenham and Richmond get very busy on match and event days. To deal with these, there are road closures, crowd barriers, and various other changes.

For some months we’ve been trying to persuade the RFU that they need to be better at managing traffic on event days – that they shouldn’t be using ‘cyclists dismount’ signs, that there are other barriers and layouts they should consider, and that they should be more actively supporting and thinking about cycling as a way to deal with some of the transport issues on event days.

Thanks to persistence by local members, the council is meeting the RFU, and has promised to share a proper traffic plan before the next event.

Cycling Channels

These allow you to get your bike across footbridges without having to physically lift them. We first asked for these under the previous cycling champion, the utterly useless Katherine Harborne. With the help of the cycling officer, these are finally being fitted to more and more bridges, and the next one will be the footbridge over Manor Road, at North Sheen station.


We’re told that part of the towpath along the Thames around Petersham is going to be upgraded. While this isn’t going to be the full improvements we’ve been asking to this for a number of years (details here) it’s a small step in the right direction.

Remember, things only happen when we ask, so we need your help to do so. 

East Twickenham Consultation – another poor scheme from Richmond

This is the response of Richmond Cycling Campaign(RCC) to the council plans for East Twickenham. (

RCC represents London Cycling Campaign members and over a thousand supporters in the borough. We campaign for walking and cycling provision for everyone, so that these are transport modes available to all.

With some minor exceptions we oppose the proposals for East Twickenham and will be urging TfL not to fund them. This is because the plans fail to provide meaningful improvements for walking and cycling, in defiance of both council and Mayor of London policies which call for support for active travel.

The section of Richmond Road involved in this consultation will soon be home to a primary school of over 450 children, It also provides a route currently busy with cycling, and identified in the Mayor’s Transport Strategy as a key corridor for improving cycling. Despite fairly high volumes of pedestrians – obviously likely to increase significantly with a new Lidl and new school, the plans offer little for either mode of transport.

The road design in its proposed form has a poor general score (around 23/100) and multiple ‘critical fails’ using TfL’s ‘Cycling Level of Service Tool’. In continuing proposals for 1.5m (or less) cycle lanes the council is seeking to double down on useless designs installed in 2011 (see here).The design could also include ‘Copenhagen style’ side crossings as used in Waltham Forest and other boroughs, to prioritise walking and cycling, and should have better designs at the end of Richmond Road – removing cyclist/pedestrian conflict rather than maximising it.

We think this scheme should also be the subject of a Healthy Streets analysis (see the toolkit here): it is our suspicion that the road already scores poorly, and that the changes in this scheme will only result in marginal improvements.

  • The design includes a total of seven new car parking spaces, with no justification provided for why these are more important than walking and cycling provision.
  • The pedestrian crossing on Richmond Road appears to have no traffic light or pedestrian control on one side, and requires pedestrians to cross in two movements, whereas vehicles only require a single movement at any part of the junction.
  • The left turn from Richmond Road towards Twickenham unaccountably includes shared space markings for part of the area, with no explanation as to what route is supported by this.
  • On all parts of this design, cycling has no priority with the sole exception of the short contraflow lane from Rosslyn Road. Failure to provide priority will ensure that cycling will continue to be unpleasant in this area, and the TfL proposed route from the Mayor’s Transport Strategy is unlikely to come to fruition.
  • No explanation is provided as to why this area is being looked at or consulted on: is there a wider strategy it will feed into?
  • The shared space which the contraflow cycling lane feeds into is also inappropriate – adding pedestrian / cyclist conflict
  • The design for cyclists feeding from Rosslyn Road is very poor – the shared space ends before the cycle lane markings on Richmond Road, effectively ensuring a neat segue from one type of conflict for cyclists to another
  • 1.5m wide cycle lanes which are unprotected and not mandatory do not qualify as acceptable cycling facilities
  • Although there is clear analysis offered for parking of cars, there’s none for parking bicycles, whether analysis of required capacity of possible location
  • The council has policies which talk about improving air quality, yet this appears not to be under consideration in this consultation
  • A stated objective of the consultation is to ‘improve traffic flow’ – we feel that (especially with a new school opening), the goal of any changes in this area should be to actively discourage through traffic, which in most circumstances should be using the A316

Twickenham Riverside – Our Response

This is the text of our response to the Twickenham Riverside planning application. Please take a moment to pop down the sherry and add your opposition! You can make your comment on the planning website

We oppose the application on grounds of its failure to comply with LBRUT, Greater London Authority and Government policies:

Twickenham Area Action Plan 2013 (‘TAAP’) sets out LBRUT’s policy framework for the site. TAAP includes a principle to improve the pedestrian environment and reduce dominance of parked and moving traffic ( TAAP states that the whole area should be changed in a comprehensive way, and that each phase must take account of the overall future layout ( TAAP aims to improve the environment of the Embankment including reduction in car parking (

LBRUT’s Core Strategy 2009 includes spatial policy CP9 which aims to revitalise Twickenham Town Centre, creating a high-quality district centre serving residents, workers and visitors, founded on the principles of sustainability. Transport considerations include improving pedestrian and cycle links to and from the centre, and improving traffic management to manage flows and reduce dominance of vehicles on the town centre environment.

The Core Strategy is in the process of being revised and incorporated into LBRUT’s Local Plan. The Local Plan states (LP 44 B) that the council will ‘ensure that new development is designed to maximise permeability within and to the immediate vicinity of the development site through the provision of safe and convenient walking and cycling routes, and to provide opportunities for walking and cycling, including through the provision of links and enhancements to existing networks.’

The London Plan 2016, published by the Mayor’s Office, states that London should be ‘a city where it is easy, safe and convenient for everyone to access jobs, opportunities and facilities with an efficient and effective transport system which actively encourages more walking and cycling and makes better use of the Thames’. The Plan encourages patterns of development that (1) reduce the need to travel especially by car, (2) improve the capacity and accessibility of sustainable travel modes such as public transport, walking and cycling, and (3) encourage shifts to more sustainable forms of transport.

Healthy Streets For London 2017 (‘HSL’) published by the Mayor’s Office, a core element in the Mayor’s overall plan for London, states ‘Walking and cycling are the healthiest and most sustainable ways to travel, either for whole trips or as part of longer journeys on public transport… This will only happen if we reduce the volume and dominance of motor traffic and improve the experience of being on our streets.’

The National Planning Policy Framework 2012, (‘NPPF’) seeks to ensure that the transport system is balanced in favour of sustainable transport modes. Developments should be located and designed to give priority to pedestrian and cycle movements, and should create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians.

Specific failings:

Failings in regard to TAAP
The application is not a comprehensive plan as required by TAAP. The site borders Water Lane and the Embankment, yet the plans do not consider any of the improvements of these thoroughfares anticipated by TAAP, for example reduced car parking along the water-front. The application’s car parking will increase traffic on the Embankment in contravention of TAAP.

Failings in regard to the Core Strategy and the Local Plan
The application encourages cars by excessive provision of car parking. Increased parking will increase the dominance of cars in the town centre environment in contravention of the Core Strategy. The application offers no improvement to cycling between the riverside and King Street, a requirement of the Core Strategy. The application fails the requirements of the Local Plan in not considering the riverside cycle route to Richmond or between the riverside and King Street which would have provided permeability to the site.

Failings in regard to the London Plan and HSL
The provision of cycle spaces at the rear of the basement does not encourage cycling as required by the London Plan as there is no improvement of cycling infrastructure in the immediate area; notably no northbound cycling on Water Lane to link with King Street. The application does nothing to reduce car travel, a requirement of the London Plan and HSL. The application does not improve the on-street experience or create a space where walkers and cyclists are free from manoeuvring cars.

Failings in regard to NPPF
The application gives no priority to cycle movements as required by NPPF. The car parking spaces within the development and the access via the Embankment will lead to increased conflict between pedestrians and cyclists on the one hand and traffic on the other, in contravention of NPPF.

What’s Going on in Richmond?

This is a copy of an ongoing document we’re working on, showing what we’re currently aware of in the borough. It’s not complete, and we need input from others, so if you have anything you want to add, please let us know! If you want to comment, you can also add your notes to our Google Document, here

There are four quietways in some form of plan. The current details we have are here: Quietway 3, Quietway 1, Quietway 4. Quietway 2

The Ham to Teddington route (quietway 1)  has been consulted on, and is now in detailed planning.
10/12/17: This will go to a final round of consultation some time soon.

Bushy Park to Kingston (QW2) is the second which is likely to go to consultation, but we haven’t yet got any dates.

Liveable neighbourhoods: Richmond town centre bid for some money, but wasn’t successful

10/12/17 TfL will feedback to the council.  Our suspicion is that the bid failed because it had insufficient plans to look at how traffic-dominated the area is, but this is only a suspicion at the moment.

As LCC we have requested the borough become a member of CLOCS.

10/12/17: Members have written to the council, and we are assembling a group request as part of the LCC work.

Corridors. These are routes where the council will look at walking, cycling and other modes at the same time, and try to fix an overall route, rather than do piecemeal changes.

The proposed corridors are:

C1) A305 Richmond Road (j/w Aragon Rd – Richmond Bridge)

C2) A305 Sheen Road (j/w Church Rd to TLRN URRW)

C3) A306 Castlenau & Rocks Lane (j/w URRW – Hammersmith Bridge)

C4) A313 Park Rd, Hampton Road & Teddington High Street (j/w Uxbridge Rd – Kingston Road)

C5) A311 Hampton Hill & Hampton Road (j/w Upper Sunbury Rd – Heath Rd)

C6) A310 Kingston Road, Strawberry Vale & Cross Deep (j/w Kingston Bridge rdbt – King St)

C7) A3004 St Margarets Road (j/w Richmond Road to boundary)

C8) A307 Kew Road (Richmond Circus – TLRN Mortlake Rd)

C9) A305 Staines Road / The Green (j/w A316 – Heath Rd/The Green)

C10) A308 Upper Sunbury Rd & Hampton Court Rd (borough boundary to j/w Kingston Bridge rdbt)

C11) B358 Nelson Rd, HBR & Sixth Cross Rd (j/w Hanworth Rd – Hampton Rd)

C12) A3003 Mortlake High Street & B350 Lonsdale Rd (j/w A316 – Castlenau)

C13) A312 Uxbridge Road (j/w Hampton Hill HS – boundary)

Schools. The council provides basic training for all children in year 6 of primary school, and has various things it does to support school cycling. This does not seem to include:

– audits of bike parking

– ensuring routes to schools are safe

– 20mph outside schools

– detailed planning support to help families get to school

Schools. We’re concerned at reports from places like Teddington School, where they have been talking about aggressive and inappropriate management of children cycling to school. We’ve asked the council to find out what’s going on.  

10/12/17: apparently council safety officials have visited the school to discuss this. We don’t have details of the meeting, but our expectation is that schools are being made fully aware of what they can and can’t do in relation to cycling.

Towpaths: these are being partially upgraded in some areas, but the council is unwilling to say ‘we’ll make these proper places to cycle’. A good example is the use of gates, poor surfacing, and absent or inconsistent lighting.

Cross Deep. This has been to the Cycling Liaison Group a number of times, with no proper proposals. We hope to have a proper engineer’s report at the next CLG

Road Safety Week, Bike Week, and other activities where national campaigns are run: currently the council doesn’t get involved in any of these. In 2017 Bikefest didn’t happen, because it had previously run through the effort of volunteers.

River Crane: we’re waiting for a route through here. Apparently soil contamination has to be dealt with before council will take over responsibility.

10/12/17: We perhaps need to check with planning enforcement, as this is a condition of the planning application that it’s fixed.

Mortlake Brewery and other developments: the council consistently fails to plan for large developments. Twickenham redevelopment, St Mary’s university, Brewery are all examples of where active travel (walking and cycling) don’t get a look in. There’s never anything to properly encourage cycling and walking somewhere, instead of driving.

Twickenham Riverside: We’d like to see it being possible to cycle to and from the site, as well as access to the Riverside being easier for walking and cycling than driving. In particular, we don’t want the riverside to remain a car park.

10/12/17: We need to respond to the planning application, which is still far from good enough.

Richmond Park: the park forms part of some quietway routes. In order for this to work, the routes need to be accessible for multiple types of bicycle, and for people with a range of mobility impairments. This isn’t currently the case.

Village centres: most of the village centres have had some kind of update, but virtually none of these updates include cycle lanes, or any meaningful calming of traffic

Copthall Road: recently consulted on. Again, no meaningful changes for cycling or walking. This area is used as a rat run, and the opportunity to stop this has been missed. (And local residents don’t like it, either … )

Star and Garter: recently consulted changes here again failed to do much for cycling, and just assume that narrowing a road makes it better for cycling. (Consultation link, our response, cyclescape)

Byfeld Gardens: this has been asked of as a opportunity for filtering. (Link or CLG minutes)

Kew Gardens station – just had a consultation on making the pedestrian environment better, but didn’t mention cycling at all! We asked the council to explain this.

10/12/17: told by the council that cycle parking will be improved as part of the scheme, but no actual details.

Radnor Gardens bridge: idea for a walking and cycling bridge across the river. Is a great idea, but council aren’t interested. See here

HPNF consulted on the proposal for a new walking and cycling bridge at the Neighbourhood Plan travel and streets workshop.  95% were in favour of a bridge. 90% favoured Ham Street to Orleans House connection, 10% favoured a new bridge at Teddington.  There was no support for a bridge at Radnor Gardens due to its limited use for utility cycling and concern that the unlit stretch across Ham Lands would not feel safe after dusk.

Cycle hoop installations: 6 have been consulted on, over 100 requests for other slots in the borough. Not sure what the next steps are.

Richmond Station upgrade to cycle parking – part of the Liveable Neighbourhoods bid, but it looks like this funding pot is separate. We are talking to the council about what we’d like to see here, and need to publish the initial list of requests.

Introduction of dockless bikes: council is looking at this at the moment. Apparently some kind of policy is being looked at, and they’re engaging with bike companies, but we think we’d like to see this happening in the borough. One key concern is that it will increase pressure on cycle parking, which is already busy in many key areas.

More cycle parking in & around Richmond Town Centre & on the waterfront. This is ongoing. Everyone can request parking, and the cycling officer is working to get this improved. However, it is ‘here and there’ rather than any substantial new parking initiatives anywhere, at the moment.

Policing / enforcing cycle lanes around the borough using parking enforcement officers to issue tickets to vehicles parked in them illegally. . This is probably not a ‘thing going on’. But it should be. (Observation: I think that parking is devolved to boroughs.)

Each park has a community group, but many of them have accessibility problems for cycling – like Palewell Park. SWLEN group looks like it talks about these things … In Palewell Park, there’s a kind of kissing gate towards one side which is impassable by wheelchair, pram or larger bike. Apparently these were installed to stop people riding motorbikes on the park.

Royal Parks walking and cycling group: Richmond Cycling Campaign wasn’t invited to this, which is something of a disappointment. Issues we’d want considered: accessibility of gates into the park, and use of rumble strips. There is also a wider discussion which needs to be had around how to deal with the volumes of traffic in the park.

Bridges list: this is online here. Anyone can comment, and we will use this to liaise with the council.

Cycle hangars: people should carry on requesting these. 6 more are to go to the cabinet member very soon, and others should follow in consultation.

Cycling strategy: this still hasn’t been adopted by the council. It’s not clear why, or what needs to happen here, but we understand that until it is adopted, it won’t be followed through.

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


(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.


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.


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.)


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.


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).



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