TRANSPORTATION DEPARTMENT Director of Transportation: Martin Low This matter is being dealt with by: Hugh Brennan, Transport Policy

Direct Line: (020) 7641 2936 Malcolm Murray-Clark/ Michèle Dix Directors of Congestion Charging Fax no: (020) 7641 2658 Transport for Email: [email protected] Windsor House My ref: T/ 640.60b 42-50 Victoria Street Your ref: London SW1H 0TL Date: 15 July 2005

Dear Mr Murray-Clark & Dr Dix,

CONSULTATION ON THE DRAFT ORDER FOR THE WESTERN EXTENSION OF THE CONGESTION CHARGING ZONE

I am writing in response to the public consultation on the proposed western extension of the congestion charging zone, which follows up the City Council’s response to the Stakeholder consultation. The City Council remains strongly opposed to:

S The existing congestion charging zone scheme; S The £8 charge increase that was introduced on 4 July 2005; and S The proposed western extension.

I set our below our reasons for submitting that the proposal should not be agreed. I then set out why the Council considers you should hold a Public Inquiry before taking any decision to approve the scheme. Finally, I set out the Council's views on the details of the scheme, and the ways in which it should be modified if it is to proceed notwithstanding our representations.

1. WHY THE SCHEME SHOULD NOT PROCEED

The public response to the consultation on the variation to the Mayor of London’s Transport Strategy that was needed for the western extension proposal demonstrated that the Mayor of London’s plans were not supported by the general public. The findings of the original consultation in April 2004, showed that 62% were opposed to the proposal and 72% of businesses also expressed opposition. The City Council urges the Mayor of London to abandon the proposed western extension in the light of this overwhelming public opposition to the scheme, or holds a public inquiry to examine the issues.

1 The consultation document shows that the western extension will result in an increase in traffic in the existing zone and is unlikely to produce additional revenue for investment in transport.

Transport for London has received a copy of the report presented to the City Council’s Transport and Infrastructure Overview and Scrutiny Committee at its meeting on 28 June 2005. That report sets out some of the City Council’s concerns in more detail. I also attach an extract from the draft minutes of the meeting as they include details of the discussion that took place at the Committee.

Impact on local business The City Council disagrees with TfL’s advice, which predicts that the western extension would have a neutral impact on the local economy. Since there has been little respite in the fortunes for some local businesses in central London as a result of the original zone, it is hard to comprehend that a western extension would not lead to a similar trend moving westwards.

Since February 2003, the City Council has received regular contact from many local traders who typically report that business has suffered in the region of a 10-20% reductions in overall sales. Although many businesses have not been affected by the central zone scheme, it is also profoundly disappointing that others that have downsized, moved or closed down and seem to be regarded by the Mayor of London to be an expendable outcome of a greater congestion charging scheme.

Taking account of TfL’s own predictions that state that the levels of congestion would be much less in an extended zone compared to the original central zone, it is feared that local businesses in the area would suffer the triple blow of:

S an overall reduction in turnover as customers and clients stay away in order to avoid paying £8 per visit during chargeable times; S negligible savings in delivery times for goods and services; and S the imposed need to pay a congestion charge to undertake day to day business compared to competitors elsewhere.

The City Council has been provided with reports on the business impact of the existing charge undertaken for local traders. For reference, I enclose a copy of the report, from The Centre for Economics and Business Research Ltd and a written summary from John Lewis Partnership, which are submitted with that company’s consent.

The Centre for Economics and Business Research (CEBR) report, July 2005, predicts some worrying trends in the potential levels of employment and consequent reductions in turnover if the western extension were to go ahead. This view is drawn from the following findings:

S Since the central zone commenced in February 2003, in terms of employment turnover, if positive levels in public sector, construction and

2 the finance and business sectors are removed from the employment trends, employment in the congestion charge zone actually fell by 6,000 in the year after introduction, compared to a marginal reduction in the year before. Those employed in these sectors outlined above depend less on the car for journeys to work and journeys for work in central London and almost all commute by public transport already; and S The CEBR report concludes that the period of evaluation around the 2003 introduction date of the central zone is considered to be too unstable to draw meaningful conclusions from.

This reflects the City Council’s belief that those companies who do depend more on the car and light van for journeys to and for work have suffered considerably because of congestion charging. This includes the vital retail, tourism, hotel and restaurant sectors that characterise the vibrancy and variety of central London independent shops, eateries etc.

Drawing together its research the report recommends that businesses in the western zone could suffer a £236m net reduction in turnover and the retail and restaurant sector would be hit the hardest.

In addition to the adverse impacts on local businesses, the existing scheme has also had an impact on large retailers. With respect to the John Lewis Partnership and the impact that congestion charging has had on trading at its flagship Oxford Street store, the following concerns have been raised with the City Council concerning the company’s position on the proposed western extension:

S The transport case for the extension has not been made; S Public transport in the extended zone does not offer an adequate alternative; S The financial case is weak and the scheme represents poor value for money; S New technology means the scheme could be obsolete within two years of implementation; and S The Economic and Business Impact Assessment and Cost Benefit Analysis pose more questions than they answer: a detailed assessment of the business impacts, based on hard evidence is required.

A fuller explanation from the John Lewis Partnership to the above is attached for reference.

The City Council considers that evidence presented to it from local businesses, the conclusions of the CEBR report, the ongoing difficulties experienced by John Lewis Partnership and other reports, including that published by the Royal Institution of Chartered Surveyors (RICS) underpins its belief that the retail sector of the business community in particular has suffered as a result of the central charging zone. The City Council is extremely concerned that this outcome will continue if the Mayor of London extends the charging zone. In particular that the western extension will amplify

3 the problems and extend into an area where local businesses operate on marginal profit and largely employ local people.

The financial case for the scheme The City Council’s submission of 22 February 2005 to the Stakeholder Consultation outlined its concern over the financial viability of the western extension proposal. This belief remains. There is considerable doubt whether the western extension represents best value for the tax payer of London, let alone the already over-charged motorist.

Since the set-up costs of the western extension scheme are estimated to be some £125m, it is bewildering that revenues raised from the £8 charge may not be in a position to deliver funds for investment in the transport network for at least five years, a time frame cited by the Association of London Government. Given such a long lead-in time, it is questioned how complementary measures such as improved bus services, interchange facilities, pedestrian and cycle schemes will be funded to meet the projected increase in demand for these modes.

The Mayor of London is probably aware that the City Council has experienced a severe drop in parking income within the existing zone since its introduction in February 2003. The consequence of this loss in income has already affected the ability to fund measures, including Taxicard and a range of traffic management initiatives, which are entirely complementary to the Mayor of London’s transport objectives. This loss of funding has never been made up through the Borough Spending Plan process or through the precept funding award from central Government.

The City Council’s projections on the effects that a western extension would have on the Parking Service indicate that a further potential loss of revenue is very probable. Thus the scheme will continue to damage the finances of an Excellent rated flagship local authority. It will seriously affect its ability to provide services to its businesses and residents and the many visitors, which swell its daytime population to 1.1m people each day.

2. THE NEED FOR A PUBLIC INQUIRY

The City Council requests in the strongest possible terms that the Mayor of London immediately calls for an impartial binding public inquiry to:

S ascertain a fuller understanding of public support from those residents and businesses that would be directly affected as opposed to a range of interested parties and groups, the majority of which would not be materially affected by such a proposed scheme; S undertake an independent study of the western extension proposal in respect to the potential detrimental impacts to local businesses drawing upon the evidence of those businesses and traders who have suffered in the existing central zone; S have a clearer understanding of the socio-economic impacts that a western extension would have on dividing vulnerable communities that

4 surround Harrow Road and the north of Westminster, which is one of the poorest areas of the capital; S ensure that the views of Londoners are known. The City Council is concerned that the distribution of leaflets to households appears to have been poor. We have received numerous complaints that the leaflets were not received and that residents did not therefore know how to respond to the consultation. The Council has worked with TfL to try and enhance awareness, but it is concerned that some people may have missed the consultation despite those joint attempts; and S The Council would in any event ask that Transport for London continues its recent road shows throughout the remainder of July and extends the deadline for consultation to 31 July 2005.

3. OUR VIEWS ON THE DETAILS OF THE SCHEME

In summary the City Council considers that if the Mayor of London decides to proceed with the extension of the congestion charging zone:

S A 90% discount should be available for all residents of the to match the concession given to all residents of the Royal Borough of Kensington and Chelsea; S The scheme should finish at 6pm now and 1pm after the extension; S A larger charge-free area should be designated around St Mary’s Hospital and Station by extending the proposed area westwards to include Westbourne Terrace and the whole of Sussex Gardens; S Harrow Road must receive substantial investment in advance of the western extension; S The free flow route should be carefully considered to ensure that traffic congestion does not occur; and S Adequate improvements to public transport must be provided and developed well in advance of the western extension, so that the community is fully consulted on those yet unknown bus services measures.

90% residents’ discount The City Council urges the Mayor of London to extend the 90% residents’ discount to all residents of the City of Westminster. It is considered that the access to transport and social issues are broadly similar to those in the Royal Borough of Kensington and Chelsea, whose residents will all become eligible for the full 90% residents’ discount. It is unacceptable that the remaining residents of the City of Westminster are not afforded the same discount as the extension of the scheme will have similar adverse effects upon them. It is not equitable for a resident living in the City of Westminster to pay the same £8 charge as someone commuting from elsewhere.

The National Indices of Deprivation, 2004, which provides a measure of deprivation for every local authority area in England has revealed that the City of Westminster is ranked as the 39th most deprived district out of 454 across England and 9th out of the 33 London Boroughs. The national indices identify that the north-west corner of the City of Westminster (north of Harrow Road)

5 contains three wards in the top 20 most deprived wards in London, namely Queen’s Park, Westbourne and Harrow Road. These wards will all be affected by the north/south divide of the western extension.

In the north-west corner of the City of Westminster unemployment is double the national average. Queen’s Park has the highest unemployment rate in the City of Westminster at 6.3% and Harrow Road and Westbourne wards are close behind (5.4% and 5.1% respectively). This is against an average in England of 2.3% and a Westminster average of 2.8%. Work by the Office of the Deputy Prime Minister’s Social Exclusion Unit shows that many people living in concentrations of worklessness have extremely narrow travel horizons. Imposing charges to travel to nearby areas will further discourage unemployed residents to consider employment opportunities outside their neighbourhood.

This is particularly prevalent given that these wards are primarily residential with limited employment opportunities demonstrated by travel to work figures showing that 84% of residents travel outside their wards boundaries to work with over 17% of residents using a car to get to work. Additionally lower income residents from these areas will pay proportionately more for car use than those on higher income - somewhat at odds with the Mayor’s policies to reduce poverty.

The extension will also make it costly for employed residents to go into the zone. This will reduce opportunities for the large proportion who have jobs in the night time economy or as cleaners working unsocial hours. For many of these people one leg of their journey has to be by car (as there is no public transport) and the other leg has to be at congestion charge times, limiting their travel options.

The City Council presses the Mayor of London to reconsider the boundary to include these socio-economically vulnerable areas in an extended residents’ discount zone rather than isolating them further and creating real hardship with a weekday £8 congestion charge to undertake essential journeys to services and employment opportunities south of the boundary.

Whilst we recognise that it is proposed that some residents of the City of Westminster who reside outside the zone will get the residents’ discount, including those:

S south of Harrow Road; S south of Grosvenor Road; S in the area bounded by Marylebone Road/ Old Marylebone Road/ ; and S around St Mary’s Hospital and Paddington. the City Council is extremely concerned that our residents will not receive the same 90% discount that is to be granted to all residents in the Royal Borough of Kensington and Chelsea.

6 On 6 July 2005, the City Council received a copy of a petition to Councillor Melvyn Caplin from Dr. Sophie Botros of Little Venice requesting that an area bounded by Harrow Road, Edgware Road, The Grand Union Canal / Blomfield Road and Westbourne Terrace be excluded. This was forwarded to Dr Michèle Dix on 8 July 2005. The City Council wholeheartedly supports this request as it will improve access to the Westway for residents living north of the extended zone.

If the Mayor of London decides that a 90% discount will not be extended to the entire City of Westminster, that the boundaries will remain unchanged, it is requested that there are further discussions with the City Council.

The City Council welcomes the intention to bring forward the 90% discount for those residents living in the area adjacent to the north-west corner of the existing congestion charging zone to December 2005. It is understood that this area is bounded by Sale Place, Praed Street, Marylebone Road, Old Marylebone Road and Sussex Gardens. The Council would also like the residents living in the City Council’s F1 controlled parking zone to be treated in a similar way. This area is bounded by Bayswater Road, Edgware Road and Sussex Gardens.

Reduce the operating hours to 1pm The City Council welcomes the proposal to reduce the hours of operation of the existing and extended zone by ending the scheme at 6pm. However, the City Council considers that this should be brought forward and implemented for the existing zone as a matter of extreme urgency in order to assist the restaurant and theatre trade in central London.

Since many of these affected businesses in the retail, hotel and restaurant sectors trade through the afternoon and into the night across the West End, the City Council continues to press its case that the Mayor of London’s current proposal to reduce the time limit to 6pm is unobjectionable in itself, but should go further.

The City Council believes that 6pm would have little impact on the desperate need to encourage more customers and clients to visit local businesses during the later half of the day. A concession that would effectively address this concern would be to adjust the scheme to finish at 1pm rather than 6pm. The Marylebone Association has suggested 4pm as an alternative.

This is likely to reduce the impact of the scheme on local businesses whilst maintaining the traffic reduction benefits achieved by charging drivers during the morning peak period.

St Mary’s Hospital and Paddington charge free zone The City Council welcomes the inclusion of the St Mary’s Hospital and Paddington charge free zone that it requested in response to the stakeholder consultation. This will also afford the 90% discount for those residents who reside there. However, the City Council is extremely disappointed that the zone proposed by TfL does not account for the range of essential trips that

7 are necessary in the area. For example, to ensure direct access to both St. Mary’s Hospital, the main Accident and Emergency centre for the area, and the strategically important Paddington main line station that is also the terminal for Heathrow Express.

The City Council requested in its response to the Stakeholder Consultation of 22 February 2005 that a charge free area should be bounded by Westbourne Terrace and Sussex Gardens to the west and south, as shown on the enclosed plan.

The current proposal will provide charge free access to St Mary’s Hospital from the west via Praed Street and London Street or South Wharf Road. However, those travelling from the east and south from Edgware Road will have a long circuitous route because the current proposal does not take account of the one-way eastbound working at the east end of Praed Street. The Council therefore would prefer that its suggested area is adopted.

By including Sussex Gardens inside the western extension to the congestion charging zone, motorists who intend to access the hospital via London Street or South Wharf Road, the only two accesses, without paying the charge will be to continue north on the long and often congested diversionary route of Edgware Road, Westway, Bishop’s Bridge Road, Eastbourne Terrace, Praed Street and then turning left at either London Street or South Wharf Road. Extending the charge free zone to include the whole length of Sussex Gardens as originally proposed by the City Council, would improve access.

Furthermore, given the acute pressure and poor street environmental conditions on Praed Street, by including Sussex Gardens as a charge free route, the inevitable traffic congestion on Praed Street and Eastbourne Terrace will be reduced.

The City Council considers that by extending the St Mary’s Hospital and Paddington zone to the west to include Westbourne Terrace rather than being bounded by Eastbourne Terrace would ensure a more efficient movement of traffic around Paddington. This would be especially advantageous when the proposed Crossrail works in the area are underway, as Eastbourne Terrace will be a works site for approximately five years.

Heathrow Express should play a significant role in transporting incoming visitors to the capital during the period up to and during the 2012 Olympics and having a slightly larger area will help reduce congestion by spreading the access routes in the local area.

The central free through route If the western extension proceeds, then the City Council recognises the value to some of its residents and businesses of the proposed ‘free’ through route along Edgware Road, Park Lane, Grosvenor Place and Vauxhall Bridge Road. However, it will also assist many motorists to freely drive to and through the centre of London without having to pay the charge. The City Council is therefore sceptical about TfL’s assertion that the creation of the free

8 route would result in a neglible change to traffic levels when compared to present levels. Given the strategic importance of this route through the heart of central London, the City Council would like to see the much needed public inquiry independently examine the potential impact that the western extension proposal would have on the proposed free route. This should take account of the significant development and traffic generation impacts of the sizeable Victoria Area Planning Brief proposals, the Edgware Road Action Plan and redesign of Marble Arch, both schemes that TfL are actively involved in.

The proposed Crossrail scheme will necessitate long term on-site works on a section of the central reservation of Park Lane north of Brook Gate and south of Marble Arch. Any reduction in capacity on this link caused by Crossrail works will need to be taken into consideration in the assessment of a free route down Park Lane.

The City Council expects that TfL will model the full impact of Crossrail construction works traffic in the context of the whole congestion charging scheme, including use of Harrow Road by Crossrail construction traffic to and from the proposed Paddington New Yard works site.

Whilst it is welcomed that the main vehicular access to the City Council’s underground car park on Park Lane will be part of the proposed free route it was surprising that the second exit onto North Carriage Drive in Hyde Park was not. The Council wants the scheme boundary to be modified, so that this exit can be used without paying the charge.

Harrow Road As already stressed above, some of the residents living in the area north of the Harrow Road boundary route are in some of the poorest wards in London. The imposition of a daily £8 congestion charge on those residents and local businesses who find themselves on the wrong side of the boundary would create some very real hardship.

The City Council will remain the highway authority for Harrow Road if the scheme is introduced and this makes it the only boundary route that TfL is not directly responsible for as highway authority. Taking account that this area is one of the most deprived in London, the City Council urges that special consideration is made to the Harrow Road community. The City Council is very grateful for the constructive approach being adopted by Peter Hendy and his senior managers who have expressed interest in bringing forward improvements along Harrow Road in advance of the proposed western extension. Complementary traffic management measures will also be required on the other proposed boundary roads in the Harrow Road and Paddington areas.

Part of this need could be addressed through TfL supporting the City Council’s regeneration plan for the area that includes the development of two new education academies on Harrow Road and Oakington Road. The forthcoming BSP submission for 2006/07 includes two significant area

9 scheme bids that amount to £1.3m. If successful, these would deliver much needed improvement to an area that the potential imposition of the western extension would have little or no discernible effect.

Improved bus and tube services A key outcome from the central congestion charging zone’s introduction in February 2003 was the sizeable package and quality of bus service improvements that were implemented at the same time to ensure that there was adequate capacity for any modal shift. The City Council believes that the bus is not considered to be suitable for the many shift workers, those key workers that travel longer distances and those who need a vehicle to transport items or meet a range of customers throughout the working day. However, it is certainly the case that improved bus services have had a positive impact for bus users when the central charging zone commenced.

Turning to the western extension proposal, it is surprising that only a 2% to 3% increase in the inbound morning peak is forecast for bus users if the scheme were to go ahead. This low rate is troubling when it is considered that congestion charging in London is supposed to be a means to reduce the number of car drivers and result in a transfer to more sustainable modes such as the bus and tube network. If this remains the case, then why is the predicted rate for modal transfer to the bus so low when the tube network is so crowded? The City Council fears that congestion charging is increasingly becoming a means to raise revenue rather than a traffic reduction tool.

A clearer and more comprehensive plan for improved bus and tube services would have greatly helped the City Council to understand what alternative journey opportunities could be available for residents, particularly in those economically vulnerable areas such as Harrow Road where people on lower incomes would be less able to afford the £8 charge.

To further emphasise this concern, I attach a copy of a recent letter, dated 6 June 2005, that was sent to Peter Hendy.

Technology The City Council is concerned that the Mayor of London is intending to implement the scheme in 2007, two or three years before a viable Tag and Beacon scheme could be available. The City Council considers that in order to maximise the efficiency of public finances the Mayor of London should consider delaying the implementation of any extension until this technology is available or allow for an automated payment system linked to credit cards, debit cards or the Oystercard.

Other Issues

The City Council is still very concerned that the public does not fully understand the scheme, particularly its hours of operation and the zone boundary. Consequently, some people are discouraged from coming to central London at times when the scheme does not apply. Transport for London’s publicity has helped, but the City Council would like an early

10 introduction of the automated payment scheme that it has been seeking for a long time and further publicity to ensure that drivers are aware that the scheme does not operate on Saturday and Sunday.

It is understood that this has been resisted by Transport for London because the existing CCTV cameras only detect about 90% of vehicles and so an honest motorist joining such a scheme would not be paying for all of their journeys. Waiting until 2009 for a “tag and beacon” scheme is far too long to wait and some of the recent 60% increase in the charge should be used to finance any such loss.

The City Council would like TfL to start the necessary 10 weeks consultation that it has been advised is necessary to bring back the hours of operation of the scheme from 6.30pm to 6pm or earlier, so that businesses and particularly restaurants benefit from the pre-theatre trade.

Yours sincerely

Martin Low Director of Transportation cc: Councillor Danny Chalkley Cabinet Member for Economic Development and Transport

Councillor Pamela Batty, Chairman of Transport & Infrastructure Overview and Scrutiny Committee

Enclosures:

Transport & Infrastructure Overview and Scrutiny Committee Report. Westminster City Council, 28 June 2005.

Minutes of Transport & Infrastructure Overview and Scrutiny Committee Report. Westminster City Council, 28 June 2005.

Plan of proposed charge free zone for Paddington Station and St Mary’s Hospital. Westminster City Council, February 2005.

‘Will tackling congestion empty west London’s tills?’. West London Residents’ Association and the Federation of Small Businesses, July 2005.

Summary of the views of John Lewis on the proposed western extension of the congestion charge zones. John Lewis Partnership June 2005.

Congestion Charging – proposed western extension and bus service improvement. Westminster City Council, 6 June 2005.

Copies to: All Members of the City Council Main Amenity Societies in the City of Westminster City Council’s Corporate Management Board

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