Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes June 2017
About Sustrans Sustrans is the charity making it easier for people to walk and cycle. We are engineers and educators, experts and advocates. We connect people and places, create liveable neighbourhoods, transform the school run and deliver a happier, healthier commute. Sustrans works in partnership, bringing people together to find the right solutions. We make the case for walking and cycling by using robust evidence and showing what can be done. We are grounded in communities and believe that grassroots support combined with political leadership drives real change, fast. Join us on our journey. www.sustrans.org.uk Anne Madden Policy & Communications Manager, Northern Ireland Sustrans Ground Floor Premier Business Centres 20 Adelaide Street Belfast BT2 8GD Sustrans Registered Charity No. 326550 (England and Wales) SC039263 (Scotland) VAT Registration No. 416740656 1 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
1.0 Introduction Sustrans is a sustainable transport charity and has been in existence now for forty years. We promote active travel, making it easier for people to walk and cycle. We also support and encourage the development of public transport and see the introduction of the Belfast Rapid Transit (BRT) system as a revolutionary step in the provision of public transport in our city. Over the last number of years we have frequently defended the introduction of BRT and bus lanes, on television, radio, the press and social media, often as a lone voice. In this response we are therefore concerned both about the potential impact on cyclists and pedestrians of introducing taxis in bus lanes but also the significant potential impact on the new BRT system. We are an evidenced based organisation and the trial and its measurable impacts will be the focus of our response. 2.0 Background 2.1 Bus Lanes The purpose of bus lanes is to provide sustainable transport corridors to improve the efficiency of moving people around an urban area, while reducing congestion and air pollution. They are used by buses, Powered Two Wheelers (motorcyclists) and cyclists, as well as a limited number of taxis. In simple terms, Belfast, like most urban centres, has a finite capacity for private vehicles on our roads, including taxis. 2.2 Taxi Numbers We understand that currently approximately 500 taxis are permitted in bus lanes, including North and West Belfast taxi buses which provide for car-sharing of multiple passengers and Wheelchair Accessible Vehicles. Allowing all taxis into bus lanes is likely to increase this to several thousand which will lead to taxis greatly outnumbering buses using the lanes. 2.3 BRT In September 2018 Belfast Rapid Transit will become operational on the East West routes through the City Centre. This 90m flagship project along with a new ticketing system has the potential to transform public transport in Belfast for generations to come - a fast, efficient service with higher frequency and shorter journey times delivered by a fleet of purpose-built buses. 2.4 Bus Drivers Bus drivers themselves are opposed to opening BRT lanes to private hire vehicles. Unite the Union, the UK s largest union with over 1.4 million members, has stated a decision to allow all taxis in bus lanes will undermine the investment in the new transport system. Deputy Regional Secretary of Unite, Jackie Pollock said: Our members who will drive BRT buses report that taxis using the dedicated BRT lanes will undermine the entire rationale for this investment by impeding and slowing down the rapid bus services. 2.5 Cyclists and Bus Lanes In the absence of a comprehensive, fully segregated cycling network in the city, bus lanes currently provide an essential relatively safe environment for cycling, commuting cyclists and those using the public bike share scheme. The relationship between bus drivers and cyclists, while not perfect, has benefitted from cyclist awareness programmes for Translink drivers. 2 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
The main issue from a safety perspective of cyclists using bus lanes is the actual width of most lanes being 3m. A cyclist in a lane should be approximately 1m from the kerb edge to ensure a safe, visible position to other users. With a safe passing distance of 1.5m there clearly is no space for either buses or taxis to pass. In Dublin, where taxis have been permitted to use bus lanes, cyclists report near misses between them and taxi drivers as their biggest issue of concern. 2.6 PSNI Cycling Safety The PSNI are very aware of the issue around the safety of cyclists on our roads. They are carrying out an education campaign to ensure drivers leave a 1.5m gap when passing cyclists. Passing a cyclist any closer than this is considered careless or dangerous driving. Currently plain clothed officers on bikes fitted with cameras are monitoring this issue and those who are caught are being given warnings. In future this could lead to prosecutions. Creating the environment in which cyclists and private hire vehicle drivers are potentially in conflict in bus lanes would be a reckless decision. 2.7 Government The Draft Programme for Government Outcomes is to grow numbers using public transport and engaged in active travel. Earlier this year Infrastructure Minister, Chris Hazzard, stated: Encouraging greater use of the bus and rail network will help to support local communities and businesses, drive economic growth and reduce congestion. Mr Hazzard s progressive policy stressed the importance of moving people and goods, not vehicles in the city. Indeed he went as far as stating in the foreword of the Draft Belfast Bicycle Network Plan that traffic is killing us. He supported using the bike as a mode of transport. However, people who cycle are very reliant on bus lanes in the absence of a fully-realised bicycle network on our roads. The Department for Infrastructure s strategy was announced by the Minister in January as his 3-five- 10 plan to place walking, cycling and public transport at the heart of transport policy. In other words encouraging people taking three mile journeys to walk, doing five miles to cycle and take public transport for longer journeys. Minister Hazzard said: Investing in public transport, walking and cycling must be at the heart of our transport policy. It is the only way we can address congestion in our key urban centres, enable people and goods to move easily and ensure the north remains an attractive place to live, work, shop, visit and invest. He did not mention taxis. 2.8 Planning Policy Belfast City Council Community Plan and Local Development Plan One of the key environment issues identified in the Community Plan is reducing reliance on private transport which is what private hire taxis are. While taxis may complement a public transport system, they cannot do this when they are hindering bus services and sustainable transport options and alone, are not a sustainable method of travelling in urban areas. Belfast City Council s Draft Local Development Plan states: We will support an efficient integrated transport network, offering travel choices that minimise congestion and pollution. Encourage expansion of green infrastructure networks for walking and cycling to encourage Active Travel and improve air quality. Promote increased use of public transport whilst retaining suitable provision for cars. 2.8 City Centre Vitality Belfast celebrated its most successful Christmas in years after Belfast City Council heeded Translink s call in December 2016 not to offer free car parking in the city centre but instead invested in public transport incentives. As a result, there were more than half a million more journeys by public transport, taking 312,500 cars from local roads & significantly cutting down on congestion. It is no 3 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
coincidence that sales and footfall in the city centre at Christmas were the best they have been in years. The Belfast on the Move scheme, which introduced bus lanes, has been a resounding success. According to an impact survey on the scheme there are 11,000 less cars in the city centre each day. This doesn t mean the city centre is less busy, in fact there are an increased number of people entering the city centre. For the first time more than half of people commute to the city centre by bus, train, cycling or on foot. This is a trend we should be encouraging for the sake of future generations and the vibrancy of the city. Belfast City Centre is being transformed into a much more pleasant, safer public realm; with reduced car traffic and less noise. However, there is still a long way to go to encourage more people out of their cars and on to public transport or to take up cycling or walking for shorter journeys. By allowing private hire vehicles in bus lanes, this is a visible promotion of the private car over public transport. 2.9 Air Quality and Health Improving air quality has been high on Belfast s agenda for over 40 years. Vehicle transport was identified as a major source of air pollution such as NOx (which includes Nitrogen Dioxide NO 2 and Nitrogen Oxide). Other air pollutants are Carbon Monoxide and Particulate Matter PM10 and PM2.5, which is caused by tyre and brake wear emissions. It is only in recent years that research has confirmed the serious impact of air pollution on people s health. An estimated 40,000 people die prematurely in the UK each year due to air pollution, mainly caused by traffic emissions. Cities such as Paris and London are proposing a ban on diesel cars by 2025. A policy to introduce more private vehicles in Belfast s bus lanes should be set in the wider context of other world cities which are considering bans or restrictions on diesel vehicles. A survey of the number of diesel taxis would help inform this discussion. Belfast City Council produced an Air Quality Action Plan 2015 2020 in order to monitor levels of air pollution in the city and ensure it remains below EU limits. Some parts of the city continue to exceed the European Limit Values for NO², which can lead to hefty fines. Promoting public transport, including the new Belfast Rapid Transit System, supporting cycling in the city and reducing private car use are all key measures in this plan. Allowing all private hire vehicles into bus lanes completely contradicts this plan and jeopardises its success. 2.10 Other motorists Consideration must be given to other motorists who will be understandably frustrated during peak time commutes to see taxis driving along bus lanes while they are in general traffic. The question will arise, if you let all taxis use bus lanes, why not the ordinary, hard-working motorist or private delivery vehicle? 3.0 The trial and current survey In February this year, just before the Assembly elections the then Transport Minister Chris Hazzard, with only four days notice, announced a 12 week trial, allowing Class A taxis / private hire vehicles to access and use a limited number of bus lanes in the city, namely the Belfast Rapid Transit corridors, the city centre and the route out to Titanic Quarter. It was not clear, then and now, whether this trial was intended to assess the impact on the current Translink services or the new BRT services, which of course won t be introduced until September 2018. Since it focused on the BRT routes, we can only conclude that it was intended to assess the impact on BRT. Given the difference between the current bus frequency, number of stops and journey 4 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
times against the proposed higher frequency and faster journey times with fewer stops, no meaningful comparison can be drawn from any data obtained. The trial was from the start fundamentally flawed. The trial was introduced without consultation before appropriate base line data, such as the number of cyclists using the lanes, could be measured and without any clear idea of the impacts to be measured. The 12 week time frame was totally inadequate in terms of both reflecting seasonal patterns of use but also gave inadequate time to bring about significant behavioural change. Sustrans attempted to assess the impact of taxis in conflict with cyclists over the period by recording personal journeys and experiences. We have concluded that even this is flawed in the context of an overall assessment of the trial. 4.0 What next for private hire vehicles in bus lanes? Given our assessment of the trial, it is highly unlikely that it provided any evidence on which a rational decision about the introduction of private hire vehicles into bus lanes can be made. Clearly no decision should be made until BRT is in place and operational. We cannot afford to risk the failure of this flagship project. As we stated from the outset, we are an evidence based organisation and would expect no less from the Department when making any decision such as this. This submission is in response to the Department s current online survey. While we welcome the opportunity to express an opinion, it is just that. We are really concerned that no evidence has been produced or presented and key findings from earlier studies such as the impact on bus journey times (Armey 2008 study) has not been presented. We would therefore recommend that the decision to allow private hire vehicles into bus lanes should not be based on majority opinions but rather on hard evidence and due process. We have concluded that the recent trial was fundamentally flawed and that no conclusions can be drawn from it. Real substantive evidence is required before a rational decision can be made. It is, however, interesting to note the unsubstantiated claims made by the private hire vehicle companies in response to the trial. These include: o Taxis in bus lanes have reduced congestion and traffic is moving quicker, therefore benefiting the environment. o Private hire vehicles are a vital public service or the fourth emergency service. o Drivers jobs are at risk if they cannot use bus lanes. Taxis are private hire vehicles which are not a substitute for an efficient public transport system. There is no evidence that private hire vehicles in bus lanes have reduced congestion; that traffic moved quicker during the trial; or they benefited the environment. There has been no evidence presented by the taxi industry showing the environmental benefits of private hire vehicles. The vast majority of people have to make their own way to hospital in private cars or public transport, and in an emergency they get an ambulance. While taxis can provide a useful service, not everyone travels to hospital by taxi, or can afford to, so why should private hire vehicle passengers get the privilege of using bus lanes. 5 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
Value Cabs in a recent newspaper report before the trial claimed that business is good, despite the arrival of rival company Uber, which contradicts claims that drivers could lose jobs without access to bus lanes. Christopher McCausland, managing director of Value Cabs, Belfast Telegraph, in September 8 2016 said: "We have been competing with Uber since they arrived, and have successfully grown our business since they have come to Northern Ireland. We now have more taxis on the road than before Uber arrived. 1 We understand there is no precedent for private hire vehicles using bus lanes in any other UK city. 5.0 Where are we now? We have concluded that the trial told us nothing about the impact the introduction of private hire vehicles would have either on the current bus service or BRT, when introduced in September 2018. However, from a cyclist perspective it has highlighted the inadequacy of the current cycling network and the over-reliance on bus lanes as an alternative. While the situation currently is adequate, the potential for conflicts between BRT and cyclists from September 2018 is recognised. The introduction now of private hire vehicles into bus lanes would immediately create a dangerous and unacceptable environment for cyclists and in the longer term put at risk the success of BRT. 6.0 What next for cyclists? BRT will be introduced in September 2018, providing an East West service across and through the city centre. It is essential that proper alternative segregated cycle lanes that parallel BRT routes are in place, offering cyclists a safe, much needed alternative to the use of bus lanes. In the case of East Belfast, this would involve significant improvements to the Comber Greenway. The completion of the link along Middlepath Street and Island Street, junction improvements, new local linkages and lighting of the urban section. In West Belfast the extension of the West Link route through the Bog Meadows and onto the Colin Town Centre Transport Hub, a local cycling network should also be developed around the Hub. This infrastructure is required as a matter of urgency. At the same time we want to see the necessary resources in place to develop and deliver the whole Belfast cycling network within the next five years. This should be seen as a cross-departmental city-wide flagship project that will deliver many of the Draft Programme for Government outcomes around health and well-being, environment and air quality, active travel and the economy. A Cycling Network team should be set up to deliver the project with appropriate funding available and a 5 year time frame to deliver. 7.0 Further research required A significant amount of research is required to fully inform this critical public policy area and truly assess the overall impact: 1 http://www.belfasttelegraph.co.uk/business/news/uber-getting-around-rules-says-boss-of-belfast-taxi-firmvalue-cabs-35029997.html 6 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
How many taxis of all categories actually operate in Belfast (including Uber) and how has this number changed annually since the introduction of bus lanes? How many taxis use diesel fuel? What verifiable impact on private taxi employment have bus lanes had since they were introduced (distinct from other economic factors)? What verifiable impact will bus lanes have on private taxi employment in the future (distinct from other economic factors)? Will prioritising private hire motor vehicles actually improve air quality in Belfast? How will this potential policy change affect levels of investment in wheelchair accessible taxis and taxi bus services, and linked employment? Will shifting an unknown number of private hire vehicles into bus lanes reduce the number of vehicles in general traffic lanes or lead to an overall net gain through induced demand? A wide survey of health care users to determine the modal access to service points i.e. what percentage of people every day travel by public transport, private car, different classes of taxis, walking and cycling? A survey of bus passenger attitudes (and Bus Rapid Transit attitudes, once launched and bedded in) to bus lane access to determine their informed view on the journey speed and reliability issues. What impact will this change have on fragile cycling levels while the Belfast Bicycle Network remains unconstructed? An evaluation of safety perception and outcomes for the vulnerable users of bus lanes, those on bicycles and motorcycles. What is the economic case for allowing one private service industry (taxis) free utilisation of a public utility (bus lanes) over other critical private service industries (logistics, deliveries)? Survey of people who cycle and monitor journeys in bus lanes. Carry out a general safety audit for the mix of vehicles in bus lanes. Carry out an equality impact assessment. Present the findings to the DfI Committee for scrutiny. Present the issues and findings to the general public in a normal consultation process. 8.0 Summary and Conclusion 8.1 The recent trial was fundamentally flawed and clearly cannot provide substantive evidence on which to base a new policy decision. 7 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes
8.2 The trial has highlighted the dependence of cyclists on bus lanes and the safety issues associated with introducing taxis into these lanes. It has also highlighted the future potential impact cyclists might have on the efficient running of BRT when introduced in 2018. 8.3 If a new trial is considered it must be planned and implemented within proper guidelines in relation to gathering baseline information and measuring agreed impacts over an appropriate time-frame. It would then require a further consultation, including an Equality Impact Assessment to be carried out before a decision can be made on this policy. A new trial should not be considered until BRT has been operational. 8.4 There is an immediate requirement to provide appropriate, safe, segregated cycle routes parallel to the East/West BRT route before it becomes operational in 2018. 8.5 The Belfast Bicycle Network Plan should also be delivered within the next five years by a dedicated design and delivery team, properly resourced and funded. 8.6 If our recommendations above to invest in and promote public transport and active travel are fully implemented, then these will go a long way to deliver the cross-departmental Outcomes set out in the Draft Programme for Government to improve health, air quality, reduce congestion and boost the urban environment and economy. 8 Sustrans Response to DfI trial of private hire taxis in Belfast bus lanes