Central London Bus Services Review Sustrans response to Transport for London November 2018 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. Key points Thank you for inviting Sustrans to comment on the Central London Bus Services Review. We are broadly supportive of Transport for London s (TfL) proposed changes to central London bus services. An efficient network of bus routes in central London can play an important role in encouraging active travel, reducing car use and congestion, and enhancing air quality in the capital. However, we also wish to raise concerns regarding areas where TfL should provide either mitigating measures or pursue a more ambitious approach related to the proposed changes. These areas include: Road safety Air quality Accessibility Active travel
Road safety Like all large vehicles, buses present particular safety concerns for vulnerable road users, with collision patterns likely to be similar to those with general traffic. Accordingly, we support measures which reduce the number of buses in central London while improving or maintaining passenger capacity, but register our concern regarding ongoing safety issues surrounding the buses that remain. We support the Mayor s Healthy Streets approach to transport, which encourages the use of active travel modes, and his focus on Vision Zero for road danger reduction. However, we believe that more robust bus safety measures could be implemented sooner. Pedestrian and cyclist safety TfL data shows pedestrians account for an average of 26% of those killed and seriously injured by bus/coach collisions; standing at 63 people in 2015 1. Additionally, cyclists account for on average 8% of those killed or seriously injured in bus/coach collisions; 11 people in 2015 2. This is potentially disproportionate when cycling represents less than 3% of all trips 3, suggesting that more can be done to pursue bus safety. On much of London s road network, cyclists share bus lanes and general traffic lanes with buses. In addition, bus stops are particular conflict points; buses regularly pull in and out, bringing them into conflict with cyclists on the kerb side, while cyclists must also overtake into busy traffic. For many this is a barrier to starting cycling and, for people already cycling, exacerbates risk, while near misses with buses can cause some people to stop cycling altogether 4. Given the risks to vulnerable road users associated with buses, we support the proposed changes to the bus network which would result in fewer buses in central London. Not only will risk from buses be reduced at source, but a drop in bus-on-bus congestion could make cycling more attractive on the affected routes. In order to minimise risk for people who currently cycle, and to make cycling more attractive to those who do not currently do so, we urge TfL to implement further safety measures and initiatives for buses still on the road. We recognise that TfL are working towards improving bus safety, with the newly implemented London Bus Safety Standard (BSS) providing an 1 Transport for London, (2016), Bus/Coach casualty trends 2006-2015 2 ibid 3 Transport for London, (2016), Travel in London Report 9 4 Aldred, R. and Crosweller, S. (2015), Investigating the rates and impacts of near misses and relative incidents among UK cyclists, Journal of Transport & Health, 2 (3) Central London Bus Services Review: Sustrans response 2
innovative approach to improving safety for passengers, drivers and vulnerable road users 5. Nevertheless, we encourage TfL to pursue a more ambitious approach for their roadmap for implementation of safety measures; presently, safety measures are due to be introduced by a preferred date, whereas we believe that suppliers should be obliged to meet a required date for introducing fleet safety innovations. Air quality London is currently suffering from an air quality crisis. We recognise the need for urgent action to be taken to tackle harmful emissions and support measures to remove polluting buses from badly affected areas of central London. However, we urge TfL to take tougher action on the harmful emissions from the buses that remain. London air quality and buses Air pollution in London is a public health emergency, with Nitrogen Oxides (NO x) and Particulate Matter (PM 10 and PM 2.5) estimated to have caused up to 9,400 equivalent premature deaths in 2010 6. Approximately half of NO x and PM 10 emissions can be attributed to road transport sources, with diesel vehicles the single biggest cause of NOx emissions in the capital. Legal limits for pollutants on the busiest roads are regularly breached within a few days of the New Year, and the situation has prompted the introduction of mitigating measures such the Low Emission Zone, Ultra Low Emission Zone and the interim T-Charge for the current Congestion Charge Zone. As large diesel vehicles, TfL have identified buses as a major contributor to NO x emissions and many of the service changes highlighted in the proposal pass through some of the most polluted roads in central London, such as Oxford Street, Euston Road and the Strand. Accordingly, we welcome the consolidation of bus services in central London as this is likely to result in improved air quality via the removal of polluting vehicles and a potential reduction in congestion. We have concerns regarding emissions from the buses that will remain on the network following the service changes. TfL plans to introduce 3,000 Ultra Low Emission double-deck buses in central London by 2019 and over 250 Zero Emission single-deck buses by 2020 7, but we urge the Mayor to show more ambition and ensure that all London buses are zero emissions before the current target of 2037. 5 Transport for London (2018) Bus Safety Standard, Executive Summary 6 Kings College London (2015) Understanding the Health Impacts of Air Pollution in London 7 Transport for London (2018) Improving buses: Cleaner, greener buses Central London Bus Services Review: Sustrans response 3
Ultra Low Emission buses will be diesel-hybrids, and conform to Euro VI emission limits, a standard implemented in 2014. By 2019 this standard will be five years old, and we urge the Mayor to adopt a commitment to introducing buses which utilise best available technology when new standards are introduced. This will ensure that if fully electric double-deck buses are not available, London buses will still lead the way in terms of clean public transport. We also have concerns that polluting buses on routes earmarked for declassification will simply be reassigned to other routes in the capital, thereby shifting pollutants from one area to another. The introduction of Low Emission Bus Zones in areas outside central London will hopefully see an improvement in air quality where implemented, and we would also welcome the expansion of the zones into pollution hotspots in more central areas. Accessibility We appreciate that walking and cycling are not always viable transport options for some people or some journeys in central London. Here, public transport offers an alternative solution. Accordingly, we are concerned by the number of proposed service amendments which are forecast to have high detrimental impacts on protected groups, as highlighted by the Equality Impact Assessment (EqIA) provided in the additional documentation. We urge TfL to ensure that mitigating measures are put in place in order to make sure that using buses is not made more difficult for passengers. Constrained accessibility For some people, elements of London s public transport network, such as London Underground services, can be physically inaccessible or the cost prohibitive, and bus services are the most viable option. Any changes to the bus network in central London should therefore improve or maintain accessibility opportunities for these users to ensure that they do not need to rely on using cars, taxis or private hire vehicles to access services and facilities, or simply miss out altogether. Reduced access to services and facilities can result in social exclusion for some people 8, while others can be forced into car dependency or transport poverty 9. Additionally, any resulting increase in car use can have a detrimental impact on road safety, air quality and health. 8 Lucas. K, (2012) Transport and social exclusion: Where are we now?, Transport Policy, Vol 20 pp.105-113 9 Sustrans (2012) Locked out Central London Bus Services Review: Sustrans response 4
The EqIA highlights 7 out of 17 route amendments as having potentially high impact on protected groups, with the remainder designated as medium impact, and we raise our concern that these impacts will make it more difficult for protected groups to use bus services if robust mitigating measures are not put in place. The EqIA outlines several mitigating measures to reduce the potential impacts of changes to services on protected groups, which have provided only high-level detail at this stage. We urge TfL to provide further detail of the mitigating measures: Work with passenger groups and disability groups to make passengers aware of changes to services and understand how mitigating measures would work best in practice Undertake audits of pedestrian facilities at sites where interchange will be necessary and take mitigating action where appropriate (e.g. installing controlled crossings, introducing lower speed limits) Consider stationing TfL staff at interchange points when changes are initially implemented to assist passengers to complete their journey Active travel By making the bus network in central London more efficient, safe and less polluting, it is likely to become more attractive as a transport option for short trips within the city. However, bus trips should not be promoted as a replacement for active travel trips. As many trips as are viable should be made by walking or cycling, in order to realise the potential economic, social and environmental benefits that come with this. We encourage TfL to continue to promote walking trips alongside the newly revamped bus services, providing information and wayfinding on alternative walking routes. TfL have already produced an alternative walking map for the tube network, showing where journeys on foot are quicker or very similar to the equivalent journey on London Underground services, and a similar map could be created for the central London bus network too. Central London Bus Services Review: Sustrans response 5