A23 Brighton Road – Purley Knoll – BUS LANE EXTENDED
Request ID: FOI-0227-2425 Date published: 03 May 2024
You asked
Dear Transport for London,
The northbound bus lane on the A23 Brighton Road approaching Purley Knoll has recently been extended to start much further south.
This has involved providing two lanes northbound, and narrowing the road for southbound traffic.
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QUESTION – Please provide detailed plans of the A23 Brighton Road between Old Lodge Lane and Purley Cross, to include the first 30m of each side road.
The first to show the road markings and signs before the bus lane extension works were done.
The second to show the road markings and signs after the bus lane extension works were done.
The file – presumably PDF – should be the plans used for the works or similar.
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QUESTION – Please provide copies of the relevant Order, and the Public Notice.
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QUESTION – Please provide the reasoning behind this proposal.
What analysis, such as traffic counts and congestion observations, was performed to inform the Decision made?
Please provide a summary of this analysis and data.
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QUESTION – It is an observed fact that the previous bus lane caused more harm than benefit to buses, due to it preventing traffic from entering the nearside lane, and so needlessly tailing back alongside the bus lane.
This blocked buses from leaving the bus stop.
It also harmed general traffic using the road, by needlessly reducing throughput at the junction.
This then meant traffic moving more slowly than necessary further back, delaying buses as well as general traffic.
Instead of having two lanes of traffic – 2x12 cars for Banstead Road tailing back around 60m from the stop line, and all clearing each cycle, there were around 4 cars over 20m in lane 1 and 24 cars over 120m in lane 2, and some not clearing.
What analysis was done to evaluate the case for simply removing the bus lane altogether, as this would have greatly benefited buses and general traffic?
What analysis was done to evaluate the case for removing the old bus lane, and introducing two lanes for all traffic northbound - as this would have benefited buses and general traffic even more?
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QUESTION – Under the previous layout, when a car or van wanted to turn right into Lansdowne Road, traffic was easily able to move ahead by passing on the nearside.
Under the new layout, the bus lane prevents this, so traffic going ahead is blocked, leading to long tailbacks.
On Sunday 7-4-24 at 1906:33, we have a van blocking northbound movement.
The blockage began before this time, as traffic is already backed up badly – SEE PHOTO:
http://webdefence.global.blackspider.com/urlwrap/?q=AXicY3BmUGFmYAgUZWQoyqk0ME3RKy4q08tNzMxJzs8rKcrP0UvOz2UwMfb0MfSIDDcyNDI1NWRIy890KEnL0UvPL9MrzWbIKCkpKLbS108uLSnRy6nU9yk3rSoo8PRnYGDQ0mFgAABrYxxo&Z
By 1907:54 the queue of traffic has still not cleared, and traffic is not yet flowing freely.
There is a bus way back unable to get into the new bus lane due to the blockage of traffic ahead – SEE PHOTO: http://webdefence.global.blackspider.com/urlwrap/?q=AXicY3BmUGFmYAgUZWQoyqk0ME3RKy4q08tNzMxJzs8rKcrP0UvOz2UwMfb0MfSIDDcyNDI1NWRIy890KEnL0UvPL9MrzWbIKCkpKLbS108uLSnRy6nUDy03rUosTDJmYGDQ0mFgAABrUBxg&Z
Thus the bus lane has caused more than 1½ minutes of traffic delay, including delaying a bus – to absolutely no purpose or benefit.
What assessment of the risk of this type of delay was made, and why were no steps taken to avoid this?
Are drivers allowed to enter the bus lane to pass a right-turning vehicle in this situation – Duress of Circumstance?
Is this case covered by TFL’s pledge not to issue fines where the driving in the bus lane is only for a very short distance?
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QUESTION – Approaching the northern junction of Purley Rise, the bus lane only ends a very short distance before the turn – SEE PHOTO: http://webdefence.global.blackspider.com/urlwrap/?q=AXicY3BmUGFmYAgUZWQoyqk0ME3RKy4q08tNzMxJzs8rKcrP0UvOz2UwMfb0MfSIDDcyNDI1NWRIy890KEnL0UvPL9MrzWbIKCkpKLbS108uLSnRy6nUdy83rUoMDS5mYGDQ0mFgAABq3xxn&Z
This means that traffic wishing to turn left is unable to pull into the nearside well before the turning – as is normal safe practice, as per Highway Code - and has instead to cut sharply across the bus lane and possible approaching buses.
It also has to slow right down in the general traffic lane, causing an unsafe obstruction.
It is difficult to see approaching buses – or cyclists – when turning left from lane 2.
There is no possible objection to having the bus lane end about 30m before the junction, allowing traffic turning left to make the turn in safety.
The A23 Brighton Road here is a busy main road, with traffic including buses moving at 25mph or more.
The Traffic Signs Manual, Chapter 3, REGULATORY SIGNS – offers Diagram 877 as a safe way to manage such a situation – bus lane ends more than 30m before turn.
The layout on top of the left of Diagram 9.1 is only suitable for roads where traffic is moving slowly – bus lane ends less than 10m before turn.
TFL has discretion to vary the distance where necessary for safe turning.
Why has TFL created this dangerous situation?
What assessment of risk was made when designing the layout here?
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QUESTION – Travelling south at the Grovelands Road junction, there used to be a marked right-turn pocket.
Why has this been removed?
The new layout means that anyone wishing to turn right into Grovelands Road is likely to wait to the left of the centre line that leads to the left of the traffic island, blocking the ahead movement.
There is a far from trivial movement right into this road.
What assessment has TFL made of the demand for this turn, and its likely impact on ahead-moving traffic?
Equally, there is nowhere for traffic wishing to turn right into Sydney Road to wait – other than by totally blocking the ahead movement – SEE PHOTO: http://webdefence.global.blackspider.com/urlwrap/?q=AXicY3BmUGFmYAgUZWQoyqk0ME3RKy4q08tNzMxJzs8rKcrP0UvOz2UwMfb0MfSIDDcyNDI1NWRIy890KEnL0UvPL9MrzWbIKCkpKLbS108uLSnRy6nUdy43rUqpDDBgYGDQ0mFgAABp-RxE&Z
Is this a planned final layout, or an interim layout?
What assessment was made of this location, to ensure that suitable pockets for turning traffic were provided in the middle of the road, allowing ahead moving traffic to pass on the nearside
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QUESTION – What was the consultation process for this major change to the road layout?
Who was consulted, how and when?
How was the general public who use the road made aware of the proposal, and given the opportunity to respond?
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QUESTION – How much did this work cost?
How is that broken down between resurfacing the road, moving any kerbs or other physical works, installing signs, and painting the road?
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QUESTION – What is the Benefit – Cost analysis and BCR ratio for this scheme?
How does this measure and account for delays to general traffic, any benefit to buses, and also the disbenefit to buses and other traffic due to the delays caused by the bus lane further south, notably near the Grovelands Road junction – and delays to southbound traffic caused here?
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QUESTION – How does TFL review schemes such as this, to check whether they are delivering benefits expected, and not causing adverse impacts such as those identified above?
Thank you for your request received by Transport for London (TfL) on 18th April 2024 asking for information about the A23 Brighton Road.
Your request has been considered in accordance with the requirements of the Environmental Information Regulations (EIR) and our information access policy.
I can confirm that we hold the information you require.
We have noted that this latest request follows a very similar tone, style and format to a number of other requests we have received via the What Do They Know website recently, including case references EIR-0069-2425 and EIR-0093-2425 which are both currently open, as well as a number of other cases received over recent weeks which have already been processed and are closed. These cases share a number of obvious similarities beyond the use of What Do They Know, including the following:
Similar subject matters and similar information being requested;
A tendency to mix requests for recorded information (which are rightly covered by FOI and EIR law) with requests for explanation (which are not covered by the FOI Act or EIR) and general comments and statements;
A large number of questions and large amount of information being requested, split into different sections using a single “ - “;
The use of identical wording in parts
All of this leads us to believe that these requests have been submitted by individuals acting in concert with each other or, more likely, a single person using different pseudonyms.
Whether the requests have been submitted by individuals acting together or by one individual acting alone, they nonetheless represent a sustained and cumulative burden and cost which we do not believe is proportionate to their value. The three requests referenced above are therefore being refused under Regulation 12(4)(b) of the EIR on the basis that they are ‘manifestly unreasonable’. In reaching this conclusion we have taken account of the Information Commissioner’s guidance on the use of Regulation 12(4)(b), which can be seen online here:
As you can see, the guidance includes the following:
“This exception can be used:
when the request is vexatious; or
when the cost of compliance with the request would be too great.”
“The purpose of the exception is to protect public authorities from exposure to a disproportionate burden or an unjustified level of distress, disruption or irritation, in handling information requests.”
“In assessing whether the cost or burden of dealing with a request is “too great”, public authorities will need to consider the proportionality of the burden or costs involved and decide whether they are clearly or obviously unreasonable.
This will mean taking into account all the circumstances of the case including:
- the context in which the request is made, which may include the burden of responding to other requests on the same subject from the same requester.”
“... there may be occasions where it permissible to consider a number of EIR requests together when deciding if they are manifestly unreasonable on the grounds of cost. This is in line with the approach to requests considered manifestly unreasonable on the grounds that they are vexatious, where the context in which they are made can be taken into account.”
The cumulative effect of these requests is that it ultimately creates a disruption and sustained burden to our colleagues across the organisation whose principal function is the running of transport services, or the support services required to make that happen, which ultimately comes at a cost to the public purse. Providing input to respond to information requests requires the re-allocation and diversion of their resources and places a burden on a small number of personnel. All of this leads us to believe that answering this latest series of requests, further to those already answered, is not a justified and proportionate use of our time, and that there is no wider public interest in doing so. A significant volume of information on all of the subjects that feature within your requests can be found on our published responses at the following link: https://tfl.gov.uk/corporate/transparency/freedom-of-information/search
Where you have questions or concerns that require the provision of advice, explanation or opinion we would encourage you to submit them to the relevant area of TfL by using the following contact pages: https://tfl.gov.uk/help-and-contact/
Please see the attached information sheet for details of your right to appeal.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
