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London SW1H 0TL Dear Mr Murray-Clark & Dr Dix

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London SW1H 0TL Dear Mr Murray-Clark & Dr Dix 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 London 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
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