LB Barking and Dagenham Response to Replacement London Plan

1

DearMr Johnson,

LB Barking and Dagenham Response to Replacement London Plan

Thank you for giving the London Borough of Barking and Dagenham the opportunity to respond to the Mayor’s Transport Strategy Public Draft (MTS). The Council’s response follows the order of the MTS.

Whilst there is much to commend in the MTS around walking, cycling and the public realm the Council has fundamental concerns about whether the MTS will help Outer London maximise its economic potential and its approach to the London Riverside Opportunity Area.

Given that the MTS looks forward to 2031 the Council is very disappointed by the strategy’s lack of ambition for this part of East London and can see little evidence of the necessary commitment to measures which will help address alleviate the borough’s worsening deprivation.

We would welcome the response to discuss these issues with you in more detail

Yours sincerely

Jeremy Grint

Head of Regeneration and Economic Development

Appendix 1

LB Barking and Dagenham Response to the Mayor’s Transport Strategy Public Draft

Chapter 3

Context

Figure 1 – Mode share

The Mode Share comparisons between 2006 and 2031 are not ambitious enough and demonstrate that the MTS will have little impact on modal shift. Indeed when the increase in overall trips made over the same period is factored in it appears that the total number of private motorised transport trips will be little different in 2031 from 2006. (9.99 million against 10.32 million). This compares to the 5% modal shift achieved from the car between 2000 and 2007 as highlighted in paragraph 159. In this regard we would challenge the contention in the same paragraph that the modal shift targets are challenging.

Figure 2 – Proposed outcomes

There is potential for these outcomes to be smarter, for example:

• Whilst we support measures to improve people’s access to jobs, it is particularly important to improve people’s access to local jobs to minimise the need to travel, reducing commuting time and improve quality of life. Moreover improving public transport access to local employment areas can help generate local jobs by boosting business confidence.
• Increased walking and cycling are just two measures which will help improve the health of Londoners; reducing the need to travel, improving air quality and increasing accessibility to employment opportunities will also address health inequalities

Figure 3 – Enhancements to London’s Transport Infrastructure

This diagram needs to be supported by a table showing what the intended outcomes are for these transport enhancements. We maintain that the DLR extension to Dagenham Dock is necessary to deliver 10800 new homes, to serve what is fast becoming London’s home for green technologies, to unlock investment in South Dagenham and to take pressure of the C2C line. The regeneration benefits for the other enhancements is not clear and this is the place to remedy that.

3.1.3 London-wide travel

Figure 6

Whilst we accept that London will continue to draw its workforce from far a field, the MTS needs to ensure that Londoner’s can compete on a level playing field to access local jobs. This means ensuring local people have the right skills to compete for jobs and also the means to get to them. It is for example easier to get from Southend to Fenchurch Street as it is to get from Marks Gate to the River Road employment area. The MTS must not loose sight of the real difficulties local people can face in accessing local jobs.

East London Sub Region

Paragraph 74

It is not clear why Canary Wharf has been singled out as showing the “potential for transformational improvement”. The three key regeneration areas in Thames Gateway Barking and Dagenham (Barking Town Centre, Barking Riverside and South Dagenham) have the potential to deliver 20,000 new homes and to become London’s centre for green technologies. We are the next chapter in the Thames Gateway success story. Therefore we suggest amending the last sentence of paragraph 74 as follows:

“The decline in the use of London’s Docklands East London’s riverside areas for industry, power generation and the movement of freight has led to significant regeneration initiatives and opportunities – with London Riverside and Canary Wharf showing the potential for transformational redevelopment.”

Figure 9 London-wide transport connectivity

This diagram shows that in comparison to the Opportunity Areas in north and west London that London Riverside is poorly served by public transport. We are pleased to see Dagenham Dock identified as an interchange and a Major Employment Hub and this diagram shows the necessity for the DLR extension from the UEL green square to the Dagenham Dock red triangle to remedy an obvious gap in public transport access. We will say more about this later.

This diagram also shows the potential for improved links between Barking and Stratford.

3.2.3 Outer London

Paragraph 95

We are pleased that the MTS recognises that significant areas of deprivation exist in Barking and Dagenham and that there is a need to improve access to jobs, services and opportunities to tackle deprivation, encourage inward investment and local job creation. However the MTS lacks any clear measures in this regard. Naturally through the sub-regional transport planning process we are willing to work with the Mayor to identify the measures to do this. These range from major schemes such as the Docklands DLR extension to Dagenham Dock to quick wins such as improving bus services to the River Road and Dagenham Dock employment areas.

3.3 Planning for London’s development

Figure 14 – Spatial distribution of population growth to 2031

Figure 15 – Spatial distribution of employment growth to 2031

These figures concern us greatly. Figure 14 shows that Barking Riverside will only experience a growth of 2-3000 people by 2031 and South Dagenham will only experience a growth of 0-1000 people. This is at odds with the London Plan which identifies a capacity for 25,000 new homes in London Riverside. Of these approximately 20,000 will be in Barking and Dagenham and these are reflected in the borough’s housing target of 1510 new homes per year. Similarly figure 15 shows that Dagenham Dock will experience a decline in employment by 2031 despite the fact that good progress is being made with implementing the Sustainable Industrial Park. These figures must be revisited. Investment decisions should not be made on the basis of this data.

The MTS makes clear in paragraph 104 that it is determined to improve the provision of public transport and place more emphasis on the economic development of Outer London yet figures 14 and 15 depict a very different story. They suggest the MTS has no ambition for Barking and Dagenham one of the most deprived areas in Outer London.

Paragraph 106

In the light of figures 14 and 15 we are concerned by the insistence that in Outer London growth should be concentrated in already successful areas and should not start from scratch. It needs to be clarified what is meant by “starting from scratch”. We would be very concerned if this is intended to refer to public transport improvements to Barking Riverside and South Dagenham. If it is not intended to improve public transport to London Riverside beyond committed investment then the 20,000 new homes which are planned here many of which are affordable and family sized will not be achieved. In this regard the avowed support of the MTS and London Plan for the Thames Gateway, for raising the economic performance of Outer London and for integrating land-use and transport planning is empty rhetoric.

Chapter 4

Challenges and strategic policies

Figure 18 – 2006 PTAL

Again this shows that London Riverside has very low PTAL levels and demonstrates the case for the DLR extension and other improvements to this area.

The MTS should include a 2031 PTAL map alongside the 2006 copy so boroughs can see how the policies and proposals impact on PTAL levels, in the same way that figures 67 and 68 compare crowding levels at 2031 with 2006.

Policy 4

The MTS is short on detail for what will happen beyond the current Business Plan. There will come a point when capacity on radial rails link is exhausted, then what? Figure 22 shows that’s in 2031 the C2C service will remain one of the most overcrowded in London despite the fact that at this point it will be operating a 12 car service. The MTS needs to set out options for what happens when this point is reached. In this regard the Council is interested that figure 67 which takes into account improvements beyond the business plan shows reduced overcrowding on the C2C line through the borough. Given that Figure 22 takes into account the 12 car upgrade the Council would appreciate knowing what further plans are intended for the C2C service.

In this regard the Council considers that will be a need for schemes which take pressure of the main radial rail links. In this regard a rail link from Stratford through Barking must be explored which will in line with the findings of the Outer London Commission help improve links between Outer London Town Centres. Figure 67 shows that this can take advantage of less overcrowding on the link from Stratford to Liverpool Street which in 2031 would be underused due to Crossrail services being routed via Whitechapel. Also the DLR extension to Dagenham Dock by providing increased access to Crossrail at Custom House will help take pressure of current radial links. This may be factored in to Figure 67 but again this is not clear, as the DLR extension beyond Beckton which is shown in Figure 67 at 2031 does not appear to connect to the C2C line.

Policies 7 and 8

The Council considers that there is too much focus on Metropolitan Centres and not enough focus on Major Centres. Whilst the Council accepts and supports the need to improve access to Metropolitan Centre this needs to be complimentary to rather than compete with plans for Major Centres. For example Policy 8 highlights the need to improve links between Metropolitan Centres whereas we consider that improving access between a Metrpolitan Centre and its hinterland is more important. Again in this regard we would support improvements in access between Barking and Romford through improvements to the number 5 bus service and between Barking and Stratford through enhanced rail connectivity.

Policy 9

Paragraph 144

Here the priority of the MTS in east London is to maximise development opportunities around existing or committed transport infrastructure making the use of existing capacity. Special mention is made of the Royal Docks. However this is not consistent with the London Plan. The London Plan as a result of the SHLAA incorporates capacity for 25,000 new homes in London Riverside and due to this we have a housing target of 1510 new homes per year, the sixth highest in London. The forward to the MTS states that the Mayor “wants the best of both worlds”. This appears to be the strategy for London Riverside, the London Plan wants to achieve 25,000 new homes yet the MTS does not want to provide the investment necessary to deliver these. As written the MTS undermines investor confidence in London Riverside making clear that it wants growth focused in the Royal Docks. In the process the MTS is abandoning one of Outer London’s most deprived areas, denying the opportunity to make a real difference to the lives of these Londoners.

To add insult to injury the MTS uses the development of the Docklands as a Case Study, highlighting that without the DLR and Jubilee Line Extension and road connection improvements the Docklands would not have developed as it has. The MTS in this instance is using an example from the past it does not support in the future.

The Council suggests rewording the last sentence of paragraph 144 as follows:

”In East London, in particular, a priority is to maximise development opportunities around existing or committed, or proposed transport infrastructure making the best use of available capacity (for example the Royal Docks), and some of London’s largest brownfield land opportunities (for example London Riverside).

Policy 9d

We support the need to safeguard land for transport uses and hope that the Mayor will support the borough in safeguarding land for the Docklands Light Railway extension to Dagenham Dock.

Figure 25 - Highway Congestion 2006

Figure 26 - Highway Congestion 2031

Congestion is a major issue on the A13. This is caused by the at grade junction at Renwick Road and the Lodge Avenue flyover. This congestion makes access from the Dagenham Dock and in particular Rippleside and River Road Employment Areas particularly difficult, and businesses are telling us they cannot continue to operate in this location due to this. It is no coincidence that over 1.3 million square feet of B8 warehousing is vacant in Dagenham. This is the only at grade junction between the end of the Limehouse Link and Benfleet in Essex. The Lodge Avenue flyover is a temporary structure. Buses and HGVs breakdown on this flyover with regular occurrence. At peak hours this can cause tailbacks to the Limehouse Link and cause gridlock on surrounding streets. Figures 25 and 26 evidence this. Providing a grade separated junction at Renwick Road and replacing the flyover at Lodge Avenue are necessary to improve traffic flow and increase resilience and reliability along this stretch of the A13. This will in turn improve investor confidence which has been severely dented by the delays currently experienced on this stretch of the A13. Page 243 of the MTS mentions that there will be a 60% growth in container traffic at the London Gateway Port in Essex and therefore will further increase freight transport to and from London. This heightens the need to remedy the current bottlenecks at Renwick Road and Lodge Avenue.

Case study – page 91

This case study is of great interest to the Council. We are currently, albeit without success so far, trying to secure a direct bus service from Barking to Queen’s Hospital. Barking does not have a hospital therefore residents must travel to either King George’s or Queen’s. However it is likely that many services will be transferred from the former to the latter next year therefore increasing the importance of a service from Barking.

Policy 17

Paragraph 186

One of the most significant impacts on health is stress, and the experience that people have travelling to and from work can be a major determinant in this regard and this should be recognised at this point of the MTS.

Policy 21

The Council supports this policy that supports the regeneration of Opportunity Areas as described in the London Plan. However at paragraph 213 it appears to prioritise investment in inner East London despite the fact that this borough in Outer East London is similarly deprived (as mentioned at paragraph 95) and has comparatively poor public transport access as evidenced by figure 18. We suggest rewording the beginning of paragraph 213 as follows:

“Neighbourhoods in need of regeneration are found across London but are concentrated in Inner London, particularly to the east. Significant areas of deprivation also exist in Barking and Dagenham. These neighbourhoods represent…

We support paragraph 214 and look forward to working with the Mayor to ensuring that London Riverside gets the investment in new public transport necessary to unlock its development potential.

Chapter 5

Transport proposals

Proposals to manage and enhance the transport system

Proposal 1

A direct rail link between Barking and Stratford would, in line with the recommendations of the Outer London Commission help increase access from Barking to this future Metropolitan Centre. It would also help make best use of largely existing infrastructure.

Proposal 2

The Council is surprised that no mention is made here of the proposed Strategic Freight Interchange at Rippleside which is included within the Council’s Local Development Framework, and which takes advantage of High Speed 1 connections.

Proposal 3

The Council supports this proposal

Proposal 4

The Council supports this proposal

Proposal 5

The Council fully supports Crossrail which will help improve accessibility to other parts of London from Chadwell Heath.

The Council also supports Crossrail being fully integrated with the rest of London’s transport system and in this regard the DLR extension to Dagenham Dock will help increase access to Custom House.

Proposal 6

The Council supports this proposal and in this regard considers that the business case should be developed for running services from Stratford via Barking and to the rest of the Thames Gateway.

Proposal 7

The Council supports this proposal which will see 12 car services introduced on C2C services.