Request ID: FOI-2117-2324 Date published: 20 October 2023
You asked
Dear Mr Khan,
I am the Director of a small business that organises coach holidays and day tours, occasionally into London.
Our vehicles are equipped with ‘Euro 6, ultra-low emission’ engines. 95% of our customers are picked up in
walking distance from their homes in Worcestershire and the Black Country. I am sure you will agree that this
is the most environmentally friendly form of transport—up to 49 people travelling on a single vehicle.
I recall in recent weeks you stated that “clean air is a human right”. With due respect sir, your transport planning
in London is not commensurate with this statement. Over the past seven years, there has been a deterioration
in our experience of journeying to and away from central London, as well as a reduction in parking options
for our vehicles.
The objective of our tours predicate our route to London. For instance, if we have a group booking for Buckingham
Palace, Kensington Palace, a visit to Westminster etc, we would approach London from the M40. If we
are headed to East London, Tower Hill, Southwark, etc, we would approach London via the M1. In both
instances, the journey from the end of the motorway to the setting down would take up to 45 minutes. This
year, neither journey has been achievable in les than 60 minutes, and usually takes up to 90 minutes. London
has gone from one of the best cities to visit by coach, to the worst in the UK.
Let me provide the following example: on Saturday 12th August, our planned visit to the Tower of London
journeyed down the M1. We left the motorway at Junction 2 (Hendon) at 11:05 and followed the A1 towards
Islington and then journeyed through Whitechapel in order to be able to enter the coach park at Tower Hill,
where we arrived at 12:35. 95 minutes to travel 9 miles on the most direct route. Due to the layout of the
roads around Tower Hill, our outward journey followed the river, turned up the Strand and the Kingsway
towards Swiss Cottage and the A41, briefly joining the North Circular at Brent cross and the M1 at Junction 1.
This took 65 minutes, a journey of around 10 miles.
As well as the high volume of traffic, the reasons for the slow journeys were multiple instances of the
following, which your authority has control over:
1) Truncated and only occasional/inconsistent bus lanes across the entire arterial route.
2) Bus lanes blocked by parked vehicles and/or construction vehicles (examples, Kingsway, Holloway Road,
Finchley Road).
3) Dedicated cycle lanes dominating an unreasonable and unsafe amount of road space (example, Archway
Road).
4) Temporary traffic lights at highly congested areas (examples, Commercial Street, Holloway Road, Finchley
Road).
5) Dedicated crossing points for cycle lanes causing regular stoppages—often with no cyclists using them
at all, making the stoppages for traffic futile (example, New N Road/Shoreditch Park).
6) Poorly phased traffic lights, allowing only 2-3 vehicles through at a time and/or only allowing one direc-tion of traffic to move at a time (examples, Holloway Rd/Hornsey Street crossroads. Kingsway/Remnant Street crossroads).
Whilst your objective of making London a cycling and walking haven is commendable, you are doing so at to the detriment of those using one of the greenest forms of transport: coaches. Your ever-increasing Urban Low Emission Zone charges are doing nothing to address the root cause of the problem: volume of traffic. The more stoppages and obstacles that are imposed on roads, the more vehicles are going to be stationary, and more CO2 emissions are going to be infuse the environment. It is a simple multiplication effect.
I would appreciate an answer to the following questions. You may treat this as a Freedom of Information re-quest if it obtains accurate answers:
1) Have you considered marking out dedicated bus lanes for the entirety of the arterial routes into central London, such as the A1, A40, A4, etc? If not, why not?
2) Why are vehicles allowed to park in bus lanes at weekends?
3) What criteria has to be met to get authorisation to block/close a bus lane? Specifically, please advise why highway contractors were authorised to close the bus lane and one further lane on Kingsway on the afternoon of Saturday 12th August 2023, thus constricting the traffic flow from three lanes to just one?
4) When your authority has installed cycle lanes, what measurements are taken to ensure they can be safe-ly passed by coaches, buses, lorries etc? Have any coach operators or representative bodies of the coach industry been consulted at the design stage for these cycle lanes?
5) When your authority installed the crossroads specifically for cycle lanes throughout the city, what impact study was undertaken in respect of the effect on traffic flow and the consequent impact on air quality? Further, were representatives of bus and coach operators consulted at the design stage? Examples of such crossings include Bayswater Road, New N Road, and Parliament Square.
6) Why are the traffic lights on arterial routes so poorly phased, allowing only a small number of vehicles to move at a time and thus causing congestion? The Holloway Road/Hornsey Street crossroads only allowed one direction of traffic to move at a time, why?
7) Do you consider London to be a coach-friendly city?
8) Are aircraft that fly into London airports or over London airspace liable to pay the ULEZ charge? If not, why not?
I look forward to your reply within 20 working days as per the terms of the Freedom of Information Act. Should you require a practical demonstration of the problems, I would be happy to arrange an inward journey from the M1 and/or M40 aboard one of our vehicles at a mutually convenient time. It will certainly help you to understand how the changes you have overseen are causing more congestion and thus increasing air pollution.
We answered
TfL Ref: EIR-2117-2324
Thank you for your request received by Transport for London (TfL) on 15th September 2023 asking for information about transport planning in London.
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. Your questions are answered in turn below (as explained previously, only Questions 3-5 of your correspondence constitute requests for recorded information. Our Customer Services team will respond to your other questions):
Question 3) What criteria has to be met to get authorisation to block/close a bus lane? Specifically, please advise why highway contractors were authorised to close the bus lane and one further lane on Kingsway on the afternoon of Saturday 12th August 2023, thus constricting the traffic flow from three lanes to just one?
Answer: There is no single set of criteria that has to be met to “to get authorisation to block/close a bus lane”. Rather, a bus lane can be closed when works and proposed traffic management measures require it. Works promoters submit traffic management plans, and these will be reviewed and approved if it is agreed that the proposals are safe, necessary and have the required mitigations. If this involves a bus lane closure then the bus lane is closed. That said, please note that Kingsway is not on the Transport for London Road Network - it is part of the London Borough of Camden’s network. I understand that there were lane restrictions put in place due to the resurfacing of the carriageway by contractors working on behalf of Camden Council. The attached “Notice of Event” provides some further detail.
Question 4) When your authority has installed cycle lanes, what measurements are taken to ensure they can be safe-ly passed by coaches, buses, lorries etc? Have any coach operators or representative bodies of the coach industry been consulted at the design stage for these cycle lanes?
Answer: TfL uses the ‘Accessible Bus Stop Design Guidance’ (https://content.tfl.gov.uk/bus-stop-design-guidance.pdf) as the basis for design of bus stops, and the ‘London Cycle Design Standards’ (https://content.tfl.gov.uk/lcds-chapter1-designrequirements.pdf) for the design of cycle facilities. These TfL documents are used in conjunction with national design guidance, such as Local Transport Note 1/20 ‘Cycle Infrastructure Design’. Internal TfL documentation also covers swept paths of vehicles and is used on schemes to determine how large vehicle movements are accommodated. In terms of discussions with operators, our design teams present and discuss layouts with internal stakeholders who represent viewpoints of bus and coach operators.
Question 5) When your authority installed the crossroads specifically for cycle lanes throughout the city, what impact study was undertaken in respect of the effect on traffic flow and the consequent impact on air quality? Further, were representatives of bus and coach operators consulted at the design stage? Examples of such crossings include Bayswater Road, New N Road, and Parliament Square.
Answer: Transport for London develops traffic models in line with our Traffic Modelling guideline (https://content.tfl.gov.uk/traffic-modelling-guidelines.pdf) to determine the impacts and benefits resulting from a changes to London’s road space. These guidelines were updated in September 2021. Commonly for major intervention like cycle lanes, Highway Traffic Assessment (HTA) will be used to consider the displacement of traffic and changes to traffic flows and routing. These flows and routing will then be used in local modelling including Microsimulation to refine the design and traffic signal strategy as part of the operational study. The traffic flow difference from HTA models can also be used to undertake Air Quality and Noise calculations.Design guidance documents are consulted on prior to adoption, including discussions with specialist internal teams that represent the views of bus and coach operators. Where new schemes vary the layout of the highway and seek to change permissible movements supported by a Traffic Order, these are subject to a statutory consultation process that requires notifications to be sent to a wide range of authorities including trade bodies where applicable.
If this is not the information you are looking for please do not hesitate to contact me.
Please see the attached information sheet for details of your right to appeal as well as information on copyright and what to do if you would like to re-use any of the information we have disclosed.
Yours sincerely,
David Wells FOI Case Officer FOI Case Management Team General Counsel Transport for London
