This is probably a pointless exercise, but I finally tried to read the documents around the Twickenham Action Plan. They’re all soul-destroyingly dull, repetitive, impenetrable and long, but I managed the following submission.
In essence, the council’s plan seems to be to talk about cutting congestion and removing car dependency, while actually *doing* the opposite. How that makes a ‘sound’ action plan is anyone’s guess.
I’m writing about the Twickenham Action Plan and the associated Street Scenes and Highways Consultation.
http://www.richmond.gov.uk/home/transport_and_streets/transport_planning/transport_planning_consultations/twickenham_street_scene_highways_consultation.htm and http://www.richmond.gov.uk/publication_twickenham_aap_reduced_file_size.pdf
I am writing as a local resident, and as a local Ambassador for the Cycling Embassy of Great Britain.
First of all, I believe the plan not to be sound. (http://www.richmond.gov.uk/twickenham_aap_representations_guidance_note_july_2012.pdf)
I believe this is the case, because the plan does not appear to have a robust and credible evidence base, in its assessment of traffic of all types, and their needs and impacts.
Specifically, the plan talks, throughout the ‘transport’ section about the need to reduce the impact of car traffic, to improve sustainable transport patterns, and improving the pedestrian environment. The plan offers no evidence of analysis of traffic volumes, journey analysis, waiting times, economic impact of journey types, or environmental impact of different modes of transport. In order to be ‘sound’, I would expect such a plan to record and interpret this current data, in order to understand how the proposed plan would change such metrics.
Furthermore, the plan is not positively prepared. it appears to lack objectively assessed development and infrastructure requirements, and it fails to provide for any meaningful way to get to the town centre by more than walking distance except by car. (The current street scenes design removes cycling provision, increases lane provision for cars, removes bus lanes, and maintains car parking facilities).
In the ‘Principles for Transport’, the document talks about the removal of unnecessary or redundant street furniture ‘including … cycle racks’, and then mentions ‘enhance[d] cycle parking’. No analysis is shown for volumes of parking required, whereas car parking is guaranteed at levels at least to the current volumes. It also seeks to ‘improve interchange between transport modes’, without actually providing any analysis as to what this might mean – is this merely shorthand for ‘making it easier to park one’s car’?
By page 20, “The Transport Strategy [is to] maintains cycle routes throughout the town”, yet it is being consulted on at the same time as a street scene plan which removes all cycle routes through the town, including a valuable segregated facility on the bridge.
So, looking at the tests of soundness in the guidance note:
Positively prepared – the plan appears not to reflect an overall London goal to reduce reliance on car-born transport and maximise access by non-car means. In fact, the accompanying street scene plan provides greater space for car traffic through the removal of cycle and bus facilities. Numerous studies since the 1950s have shown that if you provide more road space you get more traffic …
Justified – the local community, according to the plan, seeks better pedestrian facilities, and a diminution in the dominance of traffic (page 19). Nothing in the plan shows any attempt to achieve this diminution, nor does the plan include any evidence that research has been undertaken around modelling for any form of traffic (as mentioned above).
Effective – the plan contains no targets, measures, or any evidence to suggest that there is a concept of what a successful delivery might look like. Nor does it publicise existing data for residents or interested parties to be able to make their own judgements.
Additionally, I question the sustainability assessment (http://www.richmond.gov.uk/sustainability_appraisal_publication_twickenham_aap.pdf)
This discusses sustainable modes of transport, and reducing the dominance of traffic, but appears not to be reflected the the street scene plan. In fact, none of the public documentation appears to make any meaningful analysis around sustainable transport modes, adjustment to modal share, or the environmental impact of these different modes. I note (3.2.16) that there is emphasis on reduction of harmful gas emissions, yet this doesn’t seem to apply to vehicles, which would seem to be a better way to meaningfully address our area’s emissions.
Best of all, on page 42, the sustainability appraisal’s answer to issues around traffic congestion and unreliable journey times talks about encouragement of travel choice, whilst being issued at the same time as a plan which removes facilities for those seeking to cycle through the main shopping / business hub, and promises to make bus journeys less reliable, by removing facilities specific to public transport!
In an overall sense, it is my opinion:
1. That the action plan is not sound, as discussed above.
2. That the sustainability assessment is, at least in much of the transport section, useless. It contains no data on existing transport modes, no targets to change these, and no measurable actions for any such targets.
3. The street scene plan appears not to actually reflect most of the transport goals that might be inferred from the action plan: its design increases traffic by providing more space for it, removes cycle facilities (despite the sustainability appraisal calling for “the provision of safe and convenient access for cyclists” p58), and it offers no meaningful alternative to the current car-focussed options for arriving in Twickenham.
Yours sincerely …