London Borough of Greenwich

Response to the Mayor’s Draft Transport Strategy

The top-line goals set out in the Mayor’s Draft Transport Strategy are broadly in line with Greenwich Council’s aspirations for the Borough’s future transport provision, however; Greenwich’s development, regeneration and ability to deliver the maximum benefit to residents is compromised by a lack of any long term committed infrastructure investment or strategic over-view for the Thames Gateway or South East London. Without these commitments there is a question over the Borough’s ability to support the delivery of the housing numbers set out in the Draft London Plan. The Strategy needs to be clear in its acknowledgement that the provision of a strategically developed transport infrastructure is a key component in London’s ability to develop its full potential for growth and economic development in a sustainable manner.

It is imperative that if Greenwich is to be able to develop its housing and regeneration potential to the full, both bus and fixed rail links to the south of the Borough (with its current lack of orbital connectivity), have to have a strategic long term delivery plan which links the south to the transport hubs in the north of the Borough.

The support given to Crossrail is welcomed, and support of the additional safeguarding for its future extensions in the South East to Gravesend and the potential this provides for links to High Speed 1 at Ebbsfleet. However, with the exception of Crossrail and planned main line rail platform extensions, there is no commitment in the Strategy to any future major transport infrastructure project within the Borough (current improvements such as the DLR 3 car extension and Jubilee Line Upgrade are scheduled to complete before this Strategy is formally adopted).

Neither Crossrail nor the Inner London Orbital Rail Enhancements improve links either to Thamesmead and the Thames Gateway or south toward Eltham from Woolwich or North Greenwich. The extension of DLR from Woolwich into both the Thames Gateway and south towards Eltham and beyond would provide the basis of the missing orbital links and help future proof capacity and connectivity. The 2006 Public Transport Accessibility Levels (PTAL) map in the document clearly demonstrates this with ‘hot-spots’ around the transport hubs, but a lack of connectivity to the rest of the Borough.

Although the inclusion of the river crossing study is welcomed, there is insufficient detail in the Strategy and no firm implementation plan or detail of funding provision and timescales for the delivery of the schemes. Given the reliance on Blackwall Tunnel as the current primary east London cross-river road link, the Strategy needs to include measures to address local congestion caused by the tunnel’s acting as a traffic attractor and include contingencies for managing the added burden imposed on the network when the tunnel is closed in situations such as the vehicle fire in early December this year.

Bus-based movement is the key South East London public transport mode. Greenwich Waterfront Transit’s committed funding is removed from the Strategy, and no alternative links to transport hubs are offered. Although there is mention of bus prioritisation (in proposals 23, 24 and 25) there is no strategic Bus Route Development Plan or inclusion of express/orbital bus routes. The Borough would wish to see a strategy that developed routes in the area and which reflected the Borough’s development patterns and potential. Any suggestion of a reduction in bus service levels is strongly opposed.

As a signatory to the Rivers Concordat and direct supporter of River Services with the Woolwich Extension subsidy, Greenwich Council would hope to see firm commitments to the development and support of this service eastwards as part of any long term transport strategy.

From June 2010 the Borough will have direct connections to StratfordCity and Stratford International Stations via both DLR and the Jubilee Line; these will give links from two areas of the Borough to the interchange with High Speed 1 and direct links to the south east and Europe. Ensuring the new London terminal for High Speed 2 had interconnectivity with both High Speed 1 and Crossrail by locating it at Stratford would enhance orbital connectivity and reduce capacity requirements on the Central London underground system.

Policy and Proposal Specific Comments:

Policy 4 seeks to place the new high-speed rail terminal in Central London and is currently considering Euston, Greenwich would ask for consideration of Stratford International or Paddington as these are alternatives which could benefit from new High Speed 1, 2 and Crossrail interfaces.

The Council has concerns over proposal 126’s support of Park and Ride schemes in Outer London. Abbey Wood, the south eastern terminus for Crossrail, borders Greenwich and Bexley and the lack of public transport connectivity to the station could potentially give rise to ‘rail heading’. The provision of Park and Ride at this site through Bexley’s designation as Outer London could further act as an unwelcome attractor to traffic.

Traffic saturation remains an issue in the Borough and improvements to the Woolwich Ferry will act as an additional attractor. A package of measures need to be brought forward to resolve these matters including specific proposals for further river crossings.

Policy 8, which supports transport improvements to Metropolitan Centres should be widened to include Woolwich, which is designated a Major Centre and Orbital Interchange and (with its inclusion in the London Plan [A1.1.33]) as a potential future Metropolitan Centre.

Policy 9, which requires new residential developments to provide 20% of parking spaces (with an additional 20% reserved) as electric vehicle charging points, although supported in principle, seems unrealistically high given the current levels of available technology. The provision of a certain number of car club bays as part of the total (with local decisions on the emission based choice of provider) would seem a more viable option.

Policy 10 seeks to bring the transport assets into, and maintained at, a good state of repair, and while it is agreed that this is desirable there is no explanation of the funding model required to achieve this.

Policy 11, removing the need to travel and the creation of transit orientated developments are only successful if provided with the necessary levels of pubic transport provision to support them. A successful example is seen with GreenwichMillenniumVillage on the Peninsula which has monitored commuter rates of 85% by public transport and as such is higher than Inner or Central London averages.

Policy 12 seeks to improve rail freight distribution which the Council agrees in principle, but would require assurances that the proposed distribution centre at Howbury Park Freight Terminal would not have a detrimental effect on rail capacity in the Borough.

Policy 13, sites the whole of Chapter 5 as the delivery proposals and like Policy 1 seeks to make improvements to delivery and quality of service over all modes, including road users. While it forms a laudable aspiration, its deliverability as a measured out put and within current spending profiles is questionable.

The improvement of transport’s contribution to the built environment which forms the basis of Policy 14 is desirable and can be effective (as has been demonstrated with the Woolwich Town Centre Interchange and Supercrossing), however its deliverability, as well as its future maintenance, without committed and adequate funding, is questionable.

Policies 15 and 16 look to manage the reduction of pollutants (both emissions and noise) from transport and while supportive of this policy the Council would ask for clarification on TfL’s own policy for the prioritisation of replacement of bus fleets with ‘cleaner’ vehicles. Currently it would appear articulated vehicles are being phased out (for example route 38 vehicles are replaced with double decked vehicles on 14th November this year) before many older and more highly polluting vehicles.

Policy 17 promotes healthy options (cycling and walking), however beyond fixed rail the MTS2 relies heavily on cycling to address capacity issues. In Greenwich where radial routes cause severance and the topography acts as a disincentive (especially to north – south routes) the ability to deliver the modal change envisaged by MTS2 is questionable. The mode delivery is further hampered by the cancellation of GWT’s funding and the huge improvements the scheme brought along the length of its route for cyclists. Replacement proposals need to be brought forward.

Policy 18 (Reducing Crime, Fear of Crime and Anti-Social Behaviour on the transport system). Proposal 18 refers to the ongoing upgrading of the tube system. There need to be safeguards to ensure that these works are not carried by starving other modes of transport of much needed funding, bearing in mind that we only have one tube line and station in the borough. Residential growth in Greenwich needs to be supported by improvements and additions to other modes such as additional bus services. Delaying funding some items of tube improvement could usefully fund measures which will directly benefit Greenwich residents.

Policy 21 looks to increase physical accessibility to the network and transport information for all Londoners.

Proposal 22 refers to the potential of extending the tube system, including a southern extension of the Bakerloo line. The current route options should include an extension of the Bakerloo Line into the south west of the Borough or acknowledge the need for an extension of the Jubilee line running south from North Greenwich as far as Eltham and beyond.

Proposal 23 refers to reviewing and adding to the bus network. Whilst specific tube proposals are listed, there is no similar list for the bus network. The proposal should refer to the introduction of rapid transit/express services to partially compensate the loss of GWT’s delivery. Similarly orbital and local connection services should be included.

Proposal 24 refers to the implementation of the Countdown 2 system for providing bus information to passengers. There is a current lack of any Countdown 1 information or even bus shelters to accommodate its deliverability in areas of the Borough such as West Thamesmead.

Proposal 25 refers to the upgrading of the bus fleet with newer buses having lower exhaust emissions. Whilst this is welcomed, the removal of bendy buses in preference to older, more polluting buses should not be a priority.

Policies 22 and 23 look to improve connectivity and support regeneration in line with the London Plan, within this:

Proposal 17 refers to the programme to upgrade the tube system. The tube benefits only part of London, and south east London is particularly poorly served by this mode. The tube’s upgrading should not be at the expense of other more needy schemes to improve public transport, such as additional bus services.

Proposal 22 and 23 as above.

Proposal 53 refers to the improvement of cycling infrastructure. Whilst this is broadly welcomed, the proposed schemes will need to:

  • follow consultation with the relevant borough;
  • balance the needs of other road users with the needs of cyclists;
  • include cycle training for all people but with priority given to younger cyclists.

Policy 24 relates to measures required for meeting reduction of ground based emission targets.

Proposal 17, 23, 25, as above

Proposal 30 refers to smoothing traffic flow. There are particular problems in the Thames Gateway area with its limited river crossing points. A problem on any of these crossings has a severe effect on traffic flows and journey reliability, not only for those crossing the river, but also east/west flows. If journey reliability is to be improved there needs to be a concentration of available funding to the Thames Gateway area for a package of further river crossings and associated measures.

Proposal 129 refers to tolls or charges to support infrastructure improvements such as river crossings. Local drivers in East London should not be unfairly penalised by being charged to cross the river Thames while in West London drivers cross without charge. A structure of charges which allow the transit of local businesses and residents at a reduced rate should be part of this proposal.

Finally, the Council's private sector partners on the Board of the Greenwich Waterfront Regeneration Agency have met to discuss the draft Transport Strategy and are in agreement with this response, emphasising the need to recognise that growth and economic development depend on further improvements in transport infrastructure and in particular supporting all the river crossing options, enhancements to bus services and further development of river services."

- 1 -