Local resident Rishi Shah has reviewed Brent Council's Long Term Transport Strategy LINK in detail and has written to Cllr Krupa Sheth (Lead Member for Environment, Infrastructure and Climate Action) with his comments:
1. How many iterations did this document go through before the final version?
2. On Pages 4 and 5 the LTTS is described as a strategy between 2015 – 2035 yet all targets on page 36 are aimed at 2041. Why? How can a strategy be aimed between a certain time frame yet all key indicators and goals are set beyond that time limit?
a. Why are there no incremental targets between 2022 – 2041?
i. This allows consecutive failures and allows for a “Hope for the best by 2041” where you are relying on consumers changing their habits without incremental delivery
3. Page 4 – The document states “Services and a safe and pleasant cycle network” What does a pleasant cycle network mean? This is just an ambiguous word without any reference to it means for a cyclist
4. Cycle lanes/ Cycle networks are mentioned 14 times throughout the document yet no goal, metric or targets are attached – why not? If funding is a requirement as per appendix 3 then why has the £xxm Cost not been attached?
a. If you do not know the funding requirements, why not? Surely knowing how much something is going to cost will allow you to plan for the future adoption and budgeting of spend
b. Appendix 3 – “Expand the cycle network beyond planned schemes” – Why is a metric or target not attached to this? Something as simple as “We will expand the cycle network by xxKM/ Miles by dd/mm”
c. There is no mention of cycle lanes owned by TFL vs Council (E.g. Brook Avenue) – which the council enables anyone visiting the borough on NON event days the ability to park without fear of tickets, meanwhile there is an approved barrat homes building to be built in the station car park, thus introducing more people and cars to the street.
5. Page 7 – There is a mention of the LTTS public consultation and feedback yet no link to the raw data and findings, nor any references in the appendix. Why not?
a. There is no mention of the number of participants who responded, so %’s imo are hiding the reality, I suspect low response rate. Am I right?
6. Pages 8 – 11. All data is pre pandemic, in parallel the section on the impact of covid (page 11) is “travel in London” – do you not think this is confusing because you have Brent level data up to 2020 meanwhile reference London travel as a whole up to 2021. Surely this confuses the reader.
a. Is there not any local level data in Brent on traffic trends (obviously increasing in traffic build up), number of speeding fines, traffic infractions?
i. If not, why not? Why has the council not studied changes in levels of above?
7. The document seems to consistently not mention and clearly not understand the financial benefits of reducing traffic and car usage in the borough, by enabling less spend on road network maintenance thus freeing up spend and budgets for other initiatives. Why is this not taken into consideration? Surely its in the interest of the council to spend less on fixing pot holes
a. And the reduction of financial burden when actively travelling, e.g. A daily driver of a small city car would save £xx because of not using fuel. Etc.
8. Pages 14- 19 – Why has the doc not got any data, mapping or heat maps to show the worst polluted areas of Brent?
9. Page 21 – The only mention of CPZ’s yet there is no mention of areas that do not have them and the contribution of on street parking problems for residents, causing further traffic because all these non residents drive into the borough and have the ability to park anywhere for free. Why was none of this negative impact assessed or documented as a negative impact on each community/ local area? (Same as point 4 above). E.g. Parking on surrounding roads by both Wembley Park and Preston Road station. Surely a mention should be for Barrat homes development to fund this for 10 years, or an ask for them to do so as part of the CILs?
10.Pages 28-29 – The document mentions inclusive areas, but this is a disguised mis-truth. For example all the public areas around the Stadium are not public, they are privately owned with access to the public. Why has the document not made this obvious? Seems disingenuous because private security can ask you to leave thus making not inclusive.
11.There is no mention of parking on single and double yellow lines, no data on the number of parking fines on a daily, weekly, monthly or yearly average. Nor any data around whether they have increased or decreased over the past few years
12.There is no mention of initiatives and costs for example adding TFL bikes which I know require sponsorship but this will radically reduce car usage and increase active travel. Why has this type of initiative not been considered, costed with uptake predictions based on other boroughs?
13.Referenced data for London has been used, rather than the improvements boroughs in East London have seen through their initiatives and changes. Why were these not referenced?
14.What about bad/ dangerous driving? – I met with you on Elmstead Ave and you literally witnessed a car mount the pavement, drive through the pavement to get around a blocking vehicle.
My overall comment of this document is that it seems to be deliberately confusing, mixed data without any baselines nor references to most of the data are missing from the appendix. The biggest benefit to the council is a reduction of maintenance costs which has been omitted from this document without any clear reason why? A simple argument will be “If we reduce private vehicle usage we will reduce our £xx budget thus enabling spending in social care” or whatever, why have costs and benefits analysis not been completed?
My biggest concern is the performance targets and indicators which are not in the stated LTTS timeframe, and there are no indicators whether the council is on target or not YoY. This to me reads as if you are hoping for the best because consumers will change their habits – and sure in a small % they will, but without a YoY indicator whether the change is occurring means you are hiding from the facts, additionally cherry picked targets seem to have been used. Some missing data e.g. “Planting X trees will reduce CO2, Co2 reduction YoY etc etc etc”
