WANDSWORTH BRIDGE ROADASSOCIATION

REBUTTAL OF LBHF PRESENTATION

MADE ON 16TH DECEMBER 2020

BY JOHN GLASWORTHY

IN RELATION TO

USE OF IMPERIAL/TOWNMEAD ROAD AS THE SOUTHBOUNDTHROUGH-ROUTE IN THE SOUTH FULHAM TCPR SCHEME

Rebuttal issue date – 31st January 2021

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LBHF PRESENTATION SLIDE 1:

WBRA COMMENTS:

The Wandsworth Bridge Road Association (WBRA) wholeheartedly promotesthe implementation of the Road User Hierarchy. However, the South FulhamTCPR Scheme causes a converse shift in the Road User Hierarchy onWandsworth Bridge Road (WBR). Rather than promoting walking, cycling andpublic transport as priority modes of transport, priority is being given to usertypes that should be considered last according to road user hierarchy policy:‘other motor vehicles’ and ‘freight transport’.

Over 500 responses to the WBRA SW6 TRAFFIC SCHEME SURVEY werereceived last year (https://wbrassociation.org.uk/survey). A couple of keystatistics from the survey:

• 79% of people answered ‘Harmed’ to the question: ‘How do you thinkthe 1000+ residents living on the WBR have been affected’?

• 74% of respondents gave 8/10 star rating or higher in response to thequestion: ‘How important is WBR to you as a local High Street’?

Pedestrians: The TCPR has directly and significantly increased trafficcongestion on the WBR. This has resulted in a detectable increase of airpollution being concentrated on the WBR and roads to the West of WBR.

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Residents of WBR and residents across South Fulham now consider theWandsworth Bridge Road to be a more unpleasant walking route, due to theworsened air and noise pollution caused by the significant traffic congestion.

The road serves as the main pedestrian thoroughfare for over 2000 childrenattending 6 local schools either side of theWandsworth Bridge Road (Thomas’sFulham, Hurlingham Academy, Marie-d’Orliac, Fulham Bilingual, Ecole desPetits, Langford Primary). Overwhelmingly, children live locally to the schoolsand walk, scoot or cycle to school. The developing organs of children areparticularly susceptible to concentrated levels of vehicular pollution on mainroads

Cyclists: Cyclists are particularly vulnerable to increased air pollution. Cyclingincreases the respiration rate and heart rate and increases the body’s demandfor oxygen. Cyclists are suffering indirect discrimination due to the illegal levelsof air pollution on Wandsworth Bridge Road that are not being improved underthis scheme.

WBR is a busy N/S cycle route, and the cyclists’ experience and health mustbe prioritised over motor vehicles. The WBR is the direct "bee-line" route forcyclists travelling from South of the River up to New Kings Road and beyond.No practical parallel routes exist for cyclists to use as an alternative.

The current LBHF proposals for WBR provide no separated cyclinginfrastructure on the WBR and no physical modal filters to make cycling anadvantageous mode of transport.

Since the scheme was implemented, cycling accidents with motor vehicleshave been observed due to the reduced visibility of cyclists using the verynarrow and unprotected advisory cycle lanes alongside log-jam traffic queues.

According to the Department for Transport’s ‘Gear Change’ Document 1 ,‘cyclists must be physically separated and protected from high volume motortraffic’, ‘schemes must be easy and comfortable to ride’, and ‘routes should bedesigned only by those who have experienced the road on a cycle’.

Further to this, according to the core design principles of the statutory LTN 1/20document2, cycle routes must be ‘Coherent’, ‘Direct’, ‘Safe’, ‘Comfortable’ and‘Attractive’.

None of these principles are being achieved on the Wandsworth Bridge Road,the current scheme does not provide for any improvement to the pre-existinginadequate and dangerous cycling provisions.

1 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/904146/gear-change-a-bold-vision-for-cycling-and-walking.pdf

2 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/906344/cycle-infrastructure-design-ltn-1-20.pdf

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Not only does the WBR fail on allcounts for the provision of cyclingLTN1/20, the current LBHF TCPRproposal actually exacerbates thesituation since it proposes to furtherprioritise local car use through thecreation of yellow box junctions cuttingacross the narrow advisory cycle lane.

Cycling is being made less appealingand more dangerous on this routeunder the current scheme.

The WBRA request mandatory cyclelanes along the WBR to ensure cyclingis prioritised over vehicular transport.

Public Transport Users:

Under the current scheme, bus journey times have been significantly impacted.LBHF (and TfL in a meeting organised by our MP) have consistently under-reported or mis-represented bus delays to the WBRA since the implementationof the TCPR. However, datasets provided to the WBRA by TfL reveal the trueextents of the traffic congestion3.

For the No. 28 bus, we have looked at the following key time periods (split into20 day intervals):

- 01JUL – 20JUL NO LOCAL CONFOUNDING FACTORS- 21JUL – 09AUG BRIDGE WORKS, NO TCPR- 10AUG – 31OCT BRIDGE WORKS & TCPR

Disruption to buses is summarised as number of instances of the following:

- Journey time between Tyrawley Road bus stop and Bridgend bus stop(1.1. miles) greater than 30mins/45mins/60mins/90mins/2hours .

- Service terminated due to traffic congestion.- Bus diversion due to traffic congestion on WBR.

Each instance of journey time >30 minutes, termination or diversionrepresents an ‘exceedance’.

3 Appendix A provides summary listings of the daily No. of Trips, min. and max. journey times for bus routes 28 &295 between Tyrawley Road and Townmead Road bus stops between 01Jul & 30Oct.

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To briefly summarise the data:

Prior to the bridge works being started, between 1st-19th July (baselineperiod) there were only 27 instances of bus journey times exceeding 30minutes, 2 instances of journey times exceeding 45 minutes, and 1instance of the bus service being terminated.

With the commencement of the bridge works on 20th July, the delaysincreased to 65 instances of journey times exceeding 30 minutes, 33instances of journey times exceeding 45 minutes, 8 instances of journeytimes exceeding 60 minutes and 29 instance of the bus service beingterminated due to congestion.

This represents a 4.5-fold increase in the exceedances compared tobaseline. This reinforces what residents have reported was experiencedon the WBR at the time - slightly increased traffic at peak times due to lanechanges on the bridge and associated bridge works.

However, the more significant change occurs as soon as the TCPR went‘live’ on 10th August.

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In the period 10th-30th Aug, the TCPR caused over 12 times the numberof exceedances compared to baseline, and ~3 times the number ofexceedances than were experienced when just the bridge works werein place.

In the subsequent 19 day interval, the following was recorded:

• 50 instances of journey times exceeding 30 minutes,• 28 instances of journey times exceeding 45 minutes,• 23 instances of journey times exceeding 60 minutes,• 8 instances of journey times exceeding 90 minutes,• 108 instances of bus operated on diversion (Imperial Road)• 156 instance of the bus service being terminated due to congestion.

This represents a clear, evidenced and substantial disruption to publictransport as a result of the TCPR scheme.

However, it is not only the quantum of delayed journeys that increased withthe TCPR but also the extent of the delays that were occurring: more delaysand longer delays.

In one instance, the time it took a bus to travel from Tyrawley Roadbus stop to Bridgend bus stop was 2 hours and 17 minutes – adistance of 1.1 miles. Average speed of less than 0.5mph.

Please note that this analysis covers only one bus route (the No.28),travelling in one direction (Southbound only). We assume very similarresults are true for the No.295 Southbound, and indeed to a lesser degreethe Northbound services of the No.28 and No.295.

Considering traffic congestion increases traffic density and the amount oftime cars are travelling in a stop-start nature (the most inefficient way ofrunning an engine), this data should be considered strong evidence thatcontrary to the council’s assertions, pollution was significantly increased onWBR from 10th August.

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LBHF PRESENTED:

WBRA COMMENTS:

There are a number of fundamental inconsistencies between the proposalpresented by LBHF at the meeting on 16th Dec, and the WBRA Proposal. Thekey principles of the WBRA Scheme are as follows:

1.) The scheme must not involve increasing capacity, WBRA supports theobjective to reduce traffic across South Fulham. As such, Southboundthrough traffic will be removed from WBR rather than opening up bothroutes to through traffic and traffic volumes controlled in both routes tocontrol the volume of traffic on each road, avoiding congestion.

2.) The WBRA’s proposal does not involve the re-introduction of a righthand turn from New Kings Road (turning South onto Imperial Road willonly be possible when coming from the East).

3.) Both through-routes will be restricted to one lane, retaining the oppositetraffic lane for cycle, bus, taxis and local access (I.e., WBR is theNorthbound through-route with local access restrictions Southbound andImperial/Townmead Rd (I/TR) is the Southbound through route with localaccess restrictions Northbound).

4.) Nodal controls to be implemented on both routes e.g. I/TR through-routewould be limited to 400 cars/hr (as per data provided for the capacity ofthe junction at Townmead Road xWandsworth Bridge on 16Dec), similarcontrols would be implemented at Wandsworth Bridge to ensure the rate

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at which cars enter the road does not exceed the rate at which cars canleave the road at the junction of New Kings Road.

5.) Protected cycle lane Northbound on WBR and Southbound onI/TR. Cycling in opposite directions on these roads shares the localaccess lane.

Below is a schematic of the WBRA proposal:

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LBHF PRESENTED:

WBRA COMMENTSIt should also be noted that the inconsistencies between the WBRA proposaland what was presented to the 3 Working Groups on 16th December could havebeen circumvented had the slides been shared with the Working Groups inadvance of the meeting, as was requested at the Working Parties meeting of3rd Nov.

The WBRA believe that the diversion of Southbound through-traffic to I/TRprovides a unique opportunity for meaningful relief to be provided to the centralhigh street that has long-suffered from high levels of pollution.

The diversion of Southbound out of borough through-traffic onto I/TR willsignificantly enhance theWBR retail zone, providing the required relief to revivethis important high-street and achieve the required air quality for this busy socialzone. This diversion will also re-establish vital access from the New KingsRoad to businesses at Imperial Wharf and on Townmead Road. Thesebusinesses have suffered from having their road access effectively cut-off fromthe North and East under the current scheme due to the prohibitive congestionto reach them via WBR, severely reducing the market catchment. The WBRAhas contacted businesses to understand the impact that the scheme is having:

Harbour Club, Townmead Road: “It is clear now that the traffic queues at peaktimes (which link to peak usage times of the club [9am-11am, 3pm-7pm]) arehaving an enormous impact on the viability of the business. If something is notdone quickly in order to allow our members access to the club I fear the worst

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for the future of the club and it’s 150 employees and over 100 self-employedcontractors”. In response to hearing of our scheme to re-open I/TRSouthbound, they responded “It is great to hear that there is a counter proposaland which would work really well for us!”

Cemex, Townmead Road: Cemex lorries previously used the Imperial Roadroute in preference to WBR. Now all Cemex lorries, unless they are deliveringto the Gas Works Development, have to take WBR and have experiencedregular delays to journey times of 30-60 minutes.

The one-way couplet scheme will also allow for a bus routes to be maintainedwith access to both lanes on both routes, thereby improving journey times andreliability which will naturally increase and encourage patronage of publictransport in South Fulham and further remove unnecessary local car journeysfrom the area.

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COUNCIL STATEMENT (LBHF PRESENTED):

WBRA COMMENTSThe above list is generic and non-specific to the WBRA-proposed scheme. The"Pros" stated within this slide are disingenuous since they are the directopposite of what WBRA is seeking to achieve.

However, please see general comments below:

Pros:1. Disagree with many of the pros – the aim is not to increase capacity,

speed, or volume. As described in other sections, the aim is to simplymove the same (or lesser) Southbound capacity from WBR or I/TR inorder to reduce the current illegal levels of air pollution on WBR, createa balanced environment between pedestrians/cyclists/vehicles allowingfor the local area to thrive as a residential & retail high street.

2. Speeds travelled by vehicles on the empty I/TR have been observed asdangerously excessive since the implementation of the TCPR, and re-opening of this route would therefore likely improve speeding from thecurrent experience of the experimental closure.

3. Pros related to the proposed scheme should instead refer to ensuringthe success of scheme by protecting the residents of WBR, avoiding theconcentration of air pollution on just one residential main road, movingpollution to the downwind perimeter of the borough, and closer to riverand rail open spaces.

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Cons:1. No increased capacity. The council maintain they can "contain" capacity

on WBR so they can do so for I/TR as well.2. Speed limits of 20mph on all roads can be controlled & enforced3. Both routes would remain two-way (albeit to restricted local access), so

there should be no significant increase pedestrian and cyclist accidents.Indeed the reduced volume of traffic on the busy WBR should see areduction in accidents.

4. The creation of a protected cycle lane Northbound on WBR andSouthbound on I/TR will significantly improve cycle safety andencourage bike use.

5. No new cut-through routes created – nowhere to go due to the uniquegeography of the area being bounded by river (South), railway (East)and the private Hurlingham Club (West).

6. "Isolated streets" - Considered a pro for LTNs to influence modal shift7. "Extended journeys" Considered a pro for LTNs to influence modal shift8. Conversely, the one-way couplets will allow businesses at Imperial

Wharf, and Townmead Road to re-establish access that was restrictedunder the Experimental Traffic Order.

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LBHF PRESENTED:

WBRA Comments

The WBRA has reviewed applicable road-facing properties on bothTownmead Road and WBR and according to 2011 Census data:

WBRA COMMENTS:

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Imperial and Townmead Roads are currently closed under an experiment trafficorder. Meanwhile, residents of WBR are suffering illegal levels of air pollution(as has been the case since records began in 2017). The re-opening of theI/TR route Southbound and closure of WBR Southbound to out of boroughtraffic should be considered a necessary adaptation under the council’sresponsibilities to implement measures to reduce emissions under Local AirQuality Management Legislation and report this significant measure in the localAir Quality Action Plan.

Population data was provided by LBHF to counter this position, as indicated inthe above slide. Note: The presentation of this data is not considered by theWBRA to be a rationale for moving the traffic onto the lesser-inhabited I/TRroute per se since every resident should have an equal right to clean air.

Notwithstanding, the data presented by LBHF does not appear to correspondto the streetscape of the roads and as such requires confirmation. Reportingof all addresses on Townmead Road for example would not be appropriateconsidering buildings on this road span the areabetween Townmead Road andthe River Path.

It should also be noted that under the WBRA proposal, only Southboundthrough-traffic traffic would be re-routed to I/TR, with WBR retaining itsessential Northbound through-route function. The WBRA consider this I/TRproposal a necessary intervention to meet legal air quality thresholds on WBRwithout compromising the same standards on I/TR. Air quality on WBR cannotrealistically be expected to fall within legal limits under the TCPR schemewithout this adaptation due to the high demand for river crossings meaning thatthe roads will not realistically experience any ‘evaporation’ of traffic, andconsistent 2-way congestion on WBR cannot be sustained.

On 20th December, the WBRA requested to receive the source dataset for theinformation presented (data source cited as LLPG/ GLA), i.e. to verify theproximity of the included households to the main roads. As of the date of issueof this document, we have not received the requested data.

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LBHF PRESENTED:

WBRA COMMENTS:

The reported constraints of the Townmead Road/Wandsworth Bridge junctioncould conversely be considered an opportunity to reduce even further thevolume of through-traffic that passes Southbound through South Fulham. Thetraffic lights at the junction with NKR can be phased to ensure that capacity atboth junctions is at a suitable exit to entry ratio (for example 350 cars/hour atthe NKR junction and 400 cars/hour at theWandsworth Bridge junction) in orderto avoid standing traffic and avoidable pollution on the route.

It should also be noted that LBHF did not request TfL to change the phasing ofthe lights at WBR/Townmead/Carnwarth Junction to meet the needs of thealtered travel patterns arising from the scheme, thereby failing to protect WBRand Carnwath Road from unnecessary congestion and further highlighting theneed to tackle traffic, congestion and pollution in a holistic approach across thewhole of South Fulham.

We hereby urge LBHF to request immediate changes to the phasing of thelights to help clear congestion from the WBR. Townmead Road is currently aTCPR-protected road, taking substantially less demand. Further light-phasingchanges can be made when further alterations to the TCPR are made.

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LBHF PRESENTED:

LBHF PRESENTED:

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WBRA COMMENTS:• Townmead Road already has filter lane for traffic turning right onto WBR.• LBHF andWBRA are in agreement not to increase capacity, so therefore

we should embrace the opportunity to reduce Southbound through-trafficto 400 vehicles per hour.

• Whichever direction traffic is coming from, the shortcomings of thisjunction at present require addressing and as such do not make amaterial difference to the proposal.

• WBRA would very much welcome pedestrian priority improvements atwhat has been a long-standing hazardous junction. The recent death ofa young man crossing the similarly car-centric junction of BatterseaBridge this month demonstrates how necessary this is. Please work withTfL urgently to achieve this and provide priority to the most vulnerableroad users. This action must not be delayed due to Working Partynegotiations.

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LBHF PRESENTED:

WBRA COMMENTS:

Roads North of Townmead and West of Imperial Roads would be restricted topermit holder access only. This can be arranged either via more ANPRcameras, or via strategic ‘No Right Turns’ out of the N/S roads onto TownmeadRoad (If No Right Turns are implemented, residents of the N/S roads from De-Morgan to Elbe Street will access Wandsworth bridge and similar routes viaWBR or via Watermeadow Lane and William Morris Way (these roads also willrequire an ANPR camera to prevent out-of-borough rat-running).

On this point, it should be noted that the WBRA does not support the provisionof Yellow Box Junctions on WBR since this will increase local vehicles rat-running between access-restricted traffic scheme ‘zones’ e.g. rat runningbetween Sands End East and Sands End West which will result in increasedlocal traffic, reduced safety on the residential roads, speeding on these 20mphroads, and is not in the spirit of a traffic reduction scheme.

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LBHF PRESENTED:

WBRA COMMENTS:

Due to the prevailing South-Westerly winds in SW London, it should be notedthat moving traffic congestion to the Eastern boundary of the borough willprotect more residents than only those on WBR, since it will reduce thedispersal of pollution from WBR across Sands End East. The land to the Eastof I/TR is largely Industrial or currently under development or has beendeveloped to provide modern new build apartments with sealed windows andintegrated ventilation systems. East of Imperial Road is also largely LondonOverground railway tracks at the perimeter of neighbouring RBKC. Similarly,Townmead Road is not expected to experience a canyon effect potentiatingpollution locally as is the case for WBR due to the orientation of the road to theprevailing wind, and since this road is protected from this effect by the largeexpansive areas of industrial, park and derelict land to much of the South of theroad and leading further to the open spaces of the River Thames.

It should also be noted that this route would be restricted to 400 cars/hour, andas such it is not anticipated to breach legal ambient air quality limits.

According to the ‘Every breath we take’ report from the Royal College ofPhysicians4, ‘Everyone has some responsibility for reducing air pollution. Realchange will only occur when everyone accepts this responsibility and makes aconcerted effort. This includes European, national and local government,business and industry, schools and the NHS, aswell as individuals in societyat large.’. The recommendations for action provided by the Working Partyreport include: (next page)

4 https://www.rcplondon.ac.uk/projects/outputs/every-breath-we-take-lifelong-impact-air-pollution

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“Put the onus on the polluters. Polluters must be required to take responsibilityfor harming our health.”

“Monitor air pollution effectively. Air pollution monitoring by central and localgovernment must track exposure to harmful pollutants in major urban areas andnear schools. These results should be communicated proactively to the public,in a clear way that everyone can understand. When levels exceed EU limits orWorld Health Organization guidelines, local authorities must immediatelypublish serious incident alerts.”

“Act to protect the public health when air pollution levels are high. When theselimits are exceeded, local authorities must have the power to close or divertroads to reduce the volume of traffic, especially near schools.”

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LBHF PRESENTED:

WBRA COMMENTS:

The above data does not consider the nodal controls and traffic interventionssuch as bus boarders that WBR has been offered, which could be applied toboth routes. It also ignores the maximum stated capacity of I/TR at 400vehicles/hour.

WBR would also provide a Southbound route for cycle, bus and local access.

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LBHF PRESENTED:

WBRA COMMENTS:

1. ONE-WAY COUPLETS – 1000’s more residents benefit from restrictedflow one-way. Current closure is experimental and should not beconsidered a fait accompli. The status quo was both routes open to alltraffic 2-ways.

2. 400 VEHICLES/HOUR – Restricting out of borough through traffic to 400cars/hour should be celebrated as it is in line with LBHF’s own aims andobjectives of this scheme.

3. TAP – 400 cars/hr would be welcomed.4. NEW ROAD USAGE – Not accepted – the local access roads would be

access restricted via ANPR cameras or ‘No Right Turns’.5. PEDESTRIAN SAFETY – is our priority on all roads - putting additional

pedestrian crossings should be seen as a welcome addition. Issuesraised directly contradict concerns for pedestrians on WBR.

6. POLLUTION – WBR has exceeded legal limits since records began.I/TR are largely open to one side with little scope for canyoning. South-Westerly orientation of Townmead Road is expected to aid pollutiondispersal and the route is bounded by river and railway. Imperial Roadis at the Eastern inhabited perimeter of the borough and as such theprevailing South-Westerly winds will reduce the exposure of air pollutionto residents.

7. 1+1 =/ 2 – Measures are to be incorporated to avoid any increase in roadcapacity – restricting entry to Imperial Road to 400 cars/hour.

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Other Considerations…• Refuse lorries will be able to take I/TR Southbound and WBR

Northbound. This statement also implies that WBR is not a residentialstreet.

• Sainsbury is currently inaccessible from the North/East without usingWBR – therefore access will be improved. Queuing traffic is a frequentoccurrence between WBR and Sainsburys car-park.

• Businesses contacted on Imperial Road, Townmead Road and ImperialWharf welcome the counterproposal as it will reinstate access fromNorth/East that was cut-off under the experimental traffic order.

• Bus routes will not be impacted since buses will retain access on theoriginal route WBR or I/TR regardless of access to out of borough traffic.

• MULTI-MILLION POUND INFRASTRUCTURE – Funds from Road andParking fines should be used to directly contribute.

• ROAD USER HIERARCHY – current traffic scheme is an experimentaltraffic order. Therefore, the changes proposed are not materiallydifferent to the roads being opened in full as before. The proposedscheme also better supports the WBR in terms of pedestrian, cycle &bus priority.

• APPROVALS & COLLABORAITON WITH TFL – This is required for thechanges proposed for WBR regardless, so no material difference.Indeed TfL should have been engaged before the current scheme wasimplemented to the East of WBR. TFL are charged with implementingroad user hierarchy changes so should welcome our proposal. It is thecouncil procrastinating.

• MATCHDAY COACH PARKING – This cannot come before protectingresidents of WBR from illegal levels of air pollution.

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LBHF PRESENTED:

WBRA COMMENTS:

Reduce traffic across South Fulham – this objective must be measuredaccording to number of vehicles as well as the vehicle’s transit time through thearea (to include the impact of congestion on air quality). According to the Trafficmanagement Act 2004, local traffic authorities have a statutory duty to managetheir networks with the aim of ‘securing the expeditious movement of traffic’. Itcannot be considered a successful outcome if fewer vehicles are in standingtraffic with engines idling for longer.

Improve air quality, cut congestion – this objective must be amended to‘Improve air quality for all residents, cut congestion on all roads’. Air qualityon WBR has been consistently in breach of legal limits since the single NO2Diffusion tube on this road was first installed in 2017 (HF03)5:

WBR is the road with the highest recorded levels of NO2 in the entire SW6 area.WBR is a residential road, and residents of the road have been (and continueto be) subjected to long-term exposure of illegal levels of air pollution.

5 https://www.lbhf.gov.uk/sites/default/files/section_attachments/2019_lbhf_air_quality_annual_status_report_final.pdf

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Residents of WBR must be urgently protected from the ongoing threat ofadverse health effects of air pollution on the road. What has LBHF done forWBR since the NO2 exceedances were first recorded? The protection ofresidents of WBR is long overdue.

The Local Air Quality Management Framework is set out in Part IV of theEnvironment Act 1995. It requires local authorities to review and assess airquality within their boundaries, and to produce an annual report detailing anymonitoring results and any air pollution issues they have identified. Where anobjective for a specific pollutant is exceeded (as it is for NO2 on WBR), the localauthority must declare an Air Quality Management Area and produce AirQuality Action Plan to address the exceedance. Please therefore provide allsuch associated actions, plans and reports associated specifically with theexceedances reported on WBR since 2017 (the AQMA cover the entireborough, WBR is not an Air Quality Focus Area, and the Annual Status Reportsdo not appear to provide for any meaningful actions specific to WBR). Pleasealso confirm if an air quality impact assessment was carried out for the currenttraffic reduction scheme that was implemented on the East of WBR on 20th July2020. Please note that actions relating to WBR must also relate to tackling outof borough through traffic on this road since between 80 - 92% of traffic on theroad is from outside of the borough.

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Make Roads Safer for Pedestriansand Cyclists – this objective mustbe applied to all roads, and inparticular the busiest main roads,where most accidents happen:

Enhance WBR as a place to live,work and visit – The WBRA doesnot consider any of the measuresbeing offered under the forthcomingscheme as anything more thanmitigation against the detrimentalimpacts of the East (and futureWest) TCRP Schemes. WBRrequires meaningful benefit from thescheme, as would be provided interms of improved air quality andreduced traffic congestion shouldI/TR be opened as the designatedSouthbound through-route.

Support Local Businesses –Business have reported adetrimental impact through loss oftrade as customers are now unableto reach them, staff experiencingdifficulties reaching their place ofwork, and local residents choosing toavoid the WBR area due to noiseand air pollution. The WBRA has notbeen made aware of any localbusinesses benefiting from the scheme to date.

Ensure Public Transport Runs Smoothly – As described on pages 12 & 13,bus routes travelling alongWBR have been significantly impacted by the TCPR,as demonstrated by the relatively limited impact to journey times between 20Juland 10Aug, when bridge works were ongoing but the ANPR camera had notgone ‘live’ to enforce the Traffic Scheme.

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Appendix A

Daily Averages28 & 295 Bus Journeys between Tyrawley Road and

Townmead Road1st July -30th October 2020

Route 28

DateNo OfTrips Min Actual Runtime Max Actual Runtime Avg Actual Runtime

01/07/20 110. 2.3 29.0 7.1

02/07/20 110. 2.2 11.3 5.3

03/07/20 106. 2.1 31.9 7.5

06/07/20 109. 2.1 7.9 4.6

07/07/20 103. 2.3 18.8 5.8

08/07/20 107. 1.9 21.6 6.0

09/07/20 110. 2.1 51.4 8.9

10/07/20 108. 2.0 33.5 8.3

13/07/20 111. 2.1 10.1 5.2

14/07/20 109. 2.0 8.6 4.9

15/07/20 107. 2.2 19.9 5.8

16/07/20 109. 2.2 18.1 5.8

17/07/20 109. 2.1 42.0 8.6

20/07/20 109. 2.1 8.8 4.8

21/07/20 109. 2.1 56.7 9.7

22/07/20 103. 2.0 46.8 9.0

23/07/20 104. 2.0 58.3 10.9

24/07/20 97. 2.1 57.7 9.3

27/07/20 110. 2.1 20.3 6.3

28/07/20 109. 2.1 36.9 7.8

29/07/20 109. 2.0 57.7 10.2

30/07/20 106. 1.8 64.5 9.5

31/07/20 109. 2.2 56.4 12.2

03/08/20 114. 2.1 23.3 6.2

04/08/20 119. 2.3 48.9 8.8

05/08/20 119. 2.3 37.6 7.8

06/08/20 115. 2.6 35.3 7.6

07/08/20 113. 2.1 25.9 7.7

10/08/20 121. 2.0 55.2 11.0

11/08/20 119. 2.8 59.1 11.9

12/08/20 110. 2.2 96.0 14.1

13/08/20 104. 2.0 104.0 12.8

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14/08/20 99. 2.2 77.6 14.1

17/08/20 120. 2.5 63.2 9.9

18/08/20 111. 2.5 59.4 10.2

19/08/20 91. 2.2 92.2 10.9

20/08/20 97. 2.6 72.6 13.0

21/08/20 89. 2.5 112.1 13.7

24/08/20 97. 2.6 95.4 8.7

25/08/20 97. 2.4 55.8 8.6

26/08/20 92. 2.9 92.0 12.8

27/08/20 85. 2.5 72.9 13.3

28/08/20 86. 2.4 69.3 10.8

01/09/20 89. 2.0 84.0 11.3

02/09/20 91. 1.9 108.0 10.4

03/09/20 95. 2.5 89.2 8.8

04/09/20 86. 2.6 74.0 9.8

07/09/20 109. 2.2 61.8 9.0

08/09/20 98. 2.3 121.2 9.1

09/09/20 95. 2.1 85.3 8.9

10/09/20 89. 2.6 51.5 6.6

11/09/20 86. 2.3 70.5 8.8

14/09/20 93. 2.4 96.4 8.7

15/09/20 88. 2.2 66.2 7.6

16/09/20 97. 2.2 67.0 7.4

17/09/20 88. 2.5 51.5 7.1

18/09/20 80. 2.7 86.8 8.4

21/09/20 100. 2.3 49.3 7.3

22/09/20 100. 2.2 68.2 8.6

23/09/20 89. 2.0 34.5 7.1

24/09/20 85. 2.2 45.1 8.5

25/09/20 63. 2.3 55.0 8.3

28/09/20 93. 2.3 28.5 6.8

29/09/20 93. 2.1 65.1 8.5

30/09/20 86. 2.4 34.8 7.4

01/10/20 73. 2.8 66.3 11.5

02/10/20 87. 2.7 60.8 12.2

05/10/20 104. 2.1 36.0 8.3

06/10/20 100. 2.7 37.2 8.1

07/10/20 103. 3.0 39.3 7.6

08/10/20 105. 2.5 25.4 7.4

09/10/20 88. 2.7 42.3 8.4

29 of 31

12/10/20 111. 2.5 25.1 6.9

13/10/20 108. 2.4 41.8 9.1

14/10/20 108. 2.8 36.2 8.6

15/10/20 72. 2.6 41.8 9.6

16/10/20 90. 2.7 39.0 10.0

19/10/20 121. 2.3 25.2 7.1

20/10/20 118. 2.2 31.5 9.3

21/10/20 123. 2.3 24.9 8.5

22/10/20 123. 2.3 32.1 9.7

23/10/20 108. 2.7 43.3 11.7

26/10/20 120. 2.2 30.4 8.3

27/10/20 123. 2.6 26.7 9.1

28/10/20 116. 2.1 30.1 10.0

29/10/20 118. 2.5 37.0 11.3

30/10/20 92. 2.5 76.0 13.6

Route 295

Date

No OfTrips Min Actual Runtime Max Actual Runtime Avg Actual Runtime

01/07/20 87. 2.1 27.5 7.0

02/07/20 88. 2.1 11.0 5.1

03/07/20 89. 2.4 32.4 7.8

06/07/20 81. 2.2 7.3 4.5

07/07/20 93. 2.3 17.8 5.8

08/07/20 92. 2.1 21.1 5.9

09/07/20 90. 2.0 50.8 9.0

10/07/20 90. 1.8 31.8 8.0

13/07/20 123. 2.6 11.6 5.0

14/07/20 122. 2.3 8.4 4.9

15/07/20 121. 2.6 19.0 6.1

16/07/20 123. 2.5 21.0 6.0

17/07/20 113. 2.7 41.5 8.8

20/07/20 103. 2.2 6.5 4.5

21/07/20 120. 1.9 53.3 10.1

22/07/20 117. 2.6 46.1 8.7

23/07/20 104. 2.2 56.4 8.6

24/07/20 103. 2.3 56.8 10.1

27/07/20 122. 2.4 18.7 6.4

28/07/20 122. 2.4 39.1 8.2

29/07/20 121. 2.6 63.9 10.8

30/07/20 123. 2.2 60.3 10.3

30 of 31

31/07/20 115. 2.7 55.8 12.4

03/08/20 114. 2.1 23.3 6.2

04/08/20 119. 2.3 48.9 8.8

05/08/20 119. 2.3 37.6 7.8

06/08/20 115. 2.6 35.3 7.6

07/08/20 113. 2.1 25.9 7.7

10/08/20 121. 2.0 55.2 11.0

11/08/20 119. 2.8 59.1 11.9

12/08/20 110. 2.2 96.0 14.1

13/08/20 104. 2.0 104.0 12.8

14/08/20 99. 2.2 77.6 14.1

17/08/20 120. 2.5 63.2 9.9

18/08/20 111. 2.5 59.4 10.2

19/08/20 91. 2.2 92.2 10.9

20/08/20 97. 2.6 72.6 13.0

21/08/20 89. 2.5 112.1 13.7

24/08/20 97. 2.6 95.4 8.7

25/08/20 97. 2.4 55.8 8.6

26/08/20 92. 2.9 92.0 12.8

27/08/20 85. 2.5 72.9 13.3

28/08/20 86. 2.4 69.3 10.8

01/09/20 89. 2.0 84.0 11.3

02/09/20 91. 1.9 108.0 10.4

03/09/20 95. 2.5 89.2 8.8

04/09/20 86. 2.6 74.0 9.8

07/09/20 109. 2.2 61.8 9.0

08/09/20 98. 2.3 121.2 9.1

09/09/20 95. 2.1 85.3 8.9

10/09/20 89. 2.6 51.5 6.6

11/09/20 86. 2.3 70.5 8.8

14/09/20 93. 2.4 96.4 8.7

15/09/20 88. 2.2 66.2 7.6

16/09/20 97. 2.2 67.0 7.4

17/09/20 88. 2.5 51.5 7.1

18/09/20 80. 2.7 86.8 8.4

21/09/20 100. 2.3 49.3 7.3

22/09/20 100. 2.2 68.2 8.6

23/09/20 89. 2.0 34.5 7.1

24/09/20 85. 2.2 45.1 8.5

25/09/20 63. 2.3 55.0 8.3

28/09/20 93. 2.3 28.5 6.8

29/09/20 93. 2.1 65.1 8.5

30/09/20 86. 2.4 34.8 7.4

01/10/20 73. 2.8 66.3 11.5

02/10/20 87. 2.7 60.8 12.2

05/10/20 104. 2.1 36.0 8.3

31 of 31

06/10/20 100. 2.7 37.2 8.1

07/10/20 103. 3.0 39.3 7.6

08/10/20 105. 2.5 25.4 7.4

09/10/20 88. 2.7 42.3 8.4

12/10/20 111. 2.5 25.1 6.9

13/10/20 108. 2.4 41.8 9.1

14/10/20 108. 2.8 36.2 8.6

15/10/20 72. 2.6 41.8 9.6

16/10/20 90. 2.7 39.0 10.0

19/10/20 121. 2.3 25.2 7.1

20/10/20 118. 2.2 31.5 9.3

21/10/20 123. 2.3 24.9 8.5

22/10/20 123. 2.3 32.1 9.7

23/10/20 108. 2.7 43.3 11.7

26/10/20 120. 2.2 30.4 8.3

27/10/20 123. 2.6 26.7 9.1

28/10/20 116. 2.1 30.1 10.0

29/10/20 118. 2.5 37.0 11.3

30/10/20 92. 2.5 76.0 13.6