Question received from Mr Benjamin Counsell to the Cabinet Member for Energy, Waste, Transport and Public Realm.
‘Much is being made by the council about LTNs tackling climate change, but where is the evidence that LTNs reduce the amount of overall fuel burnt, rather than simply deterring a small proportion of short journeys by making everyone else drive further and queue longer, resulting in an overall increase in fuel burnt? LTNs demonstrably increase traffic, pollution and congestion on boundary roads which are often bus routes. The slowness of bus services is a common reason for people not choosing to travel by bus. Why does the council choose to slow them further by funnelling all the traffic into bus routes? Given that buses disproportionately serve poorer members of the community, surely undermining the viability of buses increases inequalities.’
Deputation received from Cathy Philpot on behalf of the Motorcycle Action Group.
Deputation: Parking permits review 2022
The proposals for powered two wheeler (PTW) parking charges in the most recent consultation “Have your say on the future of parking permit prices’, are not fair, proportionate, rational or evidenced based. The assumption has been made that a regime that applies to cars can be mapped across to PTWs,
leading to massive overcharging of PTWs. This is a result of the flawed decision by Hackney to align PTW charging with car parking charges in February 2021, which itself was based on incorrect information:
? The entire banding structure and the way it is applied to PTWs is inappropriate. Although many PTW manufacturers report CO 2 emissions, these are not recorded by the DVLA for most PTWs. The majority of PTWs will therefore be charged according to their engine size under this structure, which does not bear the same relationship with emissions as in cars.
? The proposed bands set out in the consultation overestimate PTW emissions, as they appear to be based on car emissions so are inevitably not applicable to PTWs. For example, the most popular PTW in the UK falling within band 11 is the BMW R1250 GS, for which the manufacturer reports CO 2 emissions of 110 g/km, far below the 191-225 g/km range for this band as stated in the permit price tables. This discrepancy would mean a rider paying £433 in year 5 for a residents pass, as opposed to £136.
? Under the proposed charges e-PTWs and e-cars will be charged the same. The justification for the charges for electric cars is that they are a significant source of non-exhaust particulate emissions. Whilst this may be true for electric cars, which are often heavier and larger than standard ICE cars, the same does not apply for e-PTWs. Non-exhaust PM emissions, such as brake and tyre wear are roughly proportional to the weight of a vehicle, e-PTWs are much lighter than electric cars. In fact, the combined weight of an e-PTW and rider is far closer to that of a pedal cycle and rider, than to an e-car and driver.
? In addition, the argument is made that pedal cycles paying for parking in cycle hangars should not pay more than any cars. In application to electric PTWs however this is not comparable as there is no plan to install equivalent hangars for PTWs. Pedal cycles do not in fact pay for using parking facilities such as on-street cycle racks and bollards, which are comparable to facilities available for PTWs.
? The overall charging structure does not take into account a number of relevant factors including space taken up and effect on congestion, both of which are fundamental to effects on pollution and road danger.
? Combining emission and space impacts the proposals overcharge PTW riders by around a factor of 30, effectively asking riders to massively subsidise car parking in the Borough.
Additional concerns:
? The relevant councillors and officers have not engaged sufficiently on this
? The consultation was done in such a way as was unlikely for PTW riders to understand that the charges will apply to them. The lack of any efforts to engage with PTW riders until the final day of the consultation period seriously undermines the consultation process itself.
? The charges represent a massive and unaffordable increase for riders, in the middle of a cost of living crisis
Minutes:
Question received from Mr Benjamin Counsell to the Cabinet Member for Energy, Waste, Transport and Public Realm.
‘Much is being made by the council about LTNs tackling climate change, but where is the evidence that LTNs reduce the amount of overall fuel burnt, rather than simply deterring a small proportion of short journeys by making everyone else drive further and queue longer, resulting in an overall increase in fuel burnt? LTNs demonstrably increase traffic, pollution and congestion on boundary roads which are often bus routes. The slowness of bus services is a common reason for people not choosing to travel by bus. Why does the council choose to slow them further by funnelling all the traffic into bus routes? Given that buses disproportionately serve poorer members of the community, surely undermining the viability of buses increases inequalities.’
A written response was provided to the Questioner as set out below:
Dear Benjamin
Thank you for your question intended for the September Cabinet meeting regarding Low Traffic Neighbourhoods (LTNs). As you’re aware, following the death of Her Majesty Queen Elizabeth II and in line with protocols, the Cabinet meeting went ahead with only urgent items on the agenda, to reflect the fact that we were in a period of national mourning; all questions and non-essential business were removed from the agenda. As a result, I understand you were offered a written response which you agreed to.
This is a common fear when residential road closures are installed which assumes that trips which used to pass along a road simply divert to other roads in the immediately surrounding area and problems are shifted to those other roads. This misses the fact that roads are designed for different purposes. Roads in residential areas are not designed to carry through traffic which is better accommodated on main roads. It also misses the phenomenon of ‘traffic evaporation’ where some short car trips will not divert when the journey becomes slightly less convenient because of road closure. Instead the person making the trip might decide to walk or cycle instead of using a car or they might decide not to make the trip at all.
The concept of “traffic evaporation” reflects the fact that, when changes such as modal filters and low traffic neighbourhoods are introduced, some drivers change their travel choices to alternative forms of transport, while others (i.e. through-traffic) make diversions further away to avoid the locality altogether.
The concept was established in academic research carried out by Sally Cairns, Carmen Hass-Klau, and Phil Goodwin in 1998 and followed up in 2002 and has since been widely observed in scheme evaluations. Cairns et al looked at 70 case studies and found that in half of the case studies examined, where road space for traffic was reduced, there was an 11% reduction in the number of vehicles across the whole area, including on the main roads.
Initial analysis of the impact of the LTNs in Hackney have seen a significant drop in the number of trips within the LTNs. The same analysis did show some roads experiencing higher levels of traffic. However, the analysis points to evidence of an overall reduction in traffic volume on the boundary and main roads across Hackney. Air quality modelling based on traffic counts shows that this reduction in traffic has improved air quality at all modelled receptors.
To understand whether the schemes have had an overall impact on bus passengers, bus speeds have been analysed using pre-pandemic performance as a benchmark. Bus speeds increased during each of the lockdown periods and decreased in between when traffic returned to the roads.
At the end of the 2nd lockdown in mid-2021, with the LTNs still in place, speeds had broadly returned to pre-COVID levels closely shadowing broader London trends. On a borough-level, the bus speeds in Hackney track the trajectory of bus speeds across London and do not show an impact from the introduction of LTNs on speeds.
I hope that this response is helpful, but if you have any further questions please do come back to me.
Yours sincerely
Cllr Mete Coban
Cabinet member for environment and transport
Deputation received from Cathy Philpot on behalf of the Motorcycle Action Group.
Deputation: Parking permits review 2022
The proposals for powered two wheeler (PTW) parking charges in the most recent consultation “Have your say on the future of parking permit prices’, are not fair, proportionate, rational or evidenced based. The assumption has been made that a regime that applies to cars can be mapped across to PTWs,
leading to massive overcharging of PTWs. This is a result of the flawed decision by Hackney to align PTW charging with car parking charges in February 2021, which itself was based on incorrect information:
? The entire banding structure and the way it is applied to PTWs is inappropriate. Although many PTW manufacturers report CO 2 emissions, these are not recorded by the DVLA for most PTWs. The majority of PTWs will therefore be charged according to their engine size under this structure, which does not bear the same relationship with emissions as in cars.
? The proposed bands set out in the consultation overestimate PTW emissions, as they appear to be based on car emissions so are inevitably not applicable to PTWs. For example, the most popular PTW in the UK falling within band 11 is the BMW R1250 GS, for which the manufacturer reports CO 2 emissions of 110 g/km, far below the 191-225 g/km range for this band as stated in the permit price tables. This discrepancy would mean a rider paying £433 in year 5 for a residents pass, as opposed to £136.
? Under the proposed charges e-PTWs and e-cars will be charged the same. The justification for the charges for electric cars is that they are a significant source of non-exhaust particulate emissions. Whilst this may be true for electric cars, which are often heavier and larger than standard ICE cars, the same does not apply for e-PTWs. Non-exhaust PM emissions, such as brake and tyre wear are roughly proportional to the weight of a vehicle, e-PTWs are much lighter than electric cars. In fact, the combined weight of an e-PTW and rider is far closer to that of a pedal cycle and rider, than to an e-car and driver.
? In addition, the argument is made that pedal cycles paying for parking in cycle hangars should not pay more than any cars. In application to electric PTWs however this is not comparable as there is no plan to install equivalent hangars for PTWs. Pedal cycles do not in fact pay for using parking facilities such as on-street cycle racks and bollards, which are comparable to facilities available for PTWs.
? The overall charging structure does not take into account a number of relevant factors including space taken up and effect on congestion, both of which are fundamental to effects on pollution and road danger.
? Combining emission and space impacts the proposals overcharge PTW riders by around a factor of 30, effectively asking riders to massively subsidise car parking in the Borough.
Additional concerns:
? The relevant councillors and officers have not engaged sufficiently on this
? The consultation was done in such a way as was unlikely for PTW riders to understand that the charges will apply to them. The lack of any efforts to engage with PTW riders until the final day of the consultation period seriously undermines the consultation process itself.
? The charges represent a massive and unaffordable increase for riders, in the middle of a cost of living crisis
Response from Councillor Coban
I would like to thank you for your deputation, about the listening exercise undertaken by Hackney Council this summer, about permit prices in Hackney.
As I have stated previously, I recognise the important role that motorcycles, scooters and mopeds play in the Hackney economy, but we also recognise that all forms of vehicles, including motorbikes, produce emissions, and that a significant number of people commute into work in Hackney by motorbike each day.
As part of our strong commitment to improving local air quality and tackling the climate emergency, and following a full, six-month long public consultation in 2020, Cabinet agreed 18 months ago to place motorcycles on the same footing as all other vehicles, with permit prices based solely on the emissions they produce, as recorded by the DVLA.
These changes will allow businesses, delivery riders and other organisations that provide valuable services to continue to do so, while also discouraging the use of motorbikes for commuting, which contribute to local emissions.
In regard to the concerns you have raised, the final banding structure put forward for approval by Cabinet today recognises that there is a need to provide a wider range of charging bands for vehicles, including powered two wheelers, where permit prices are calculated on engine size. The final proposals now include 7 engine size charging bands, which will ensure fair charges for owners of mopeds and motorbikes.
This change, together with the move to a 13 band charging structure, will provide the right incentives for drivers of the most polluting vehicles to consider whether to keep using their vehicles in the longer term. This approach is also fair and proportionate - under it, the least polluting vehicles, including most powered two wheelers, will see permit charges seven to ten times less than drivers of the most polluting vehicles.
In relation to charges for electrically Powered Two Wheelers, electric cars, and electric bikes, we believe that our decision to treat all vehicles, in a consistent and fair way will - over time - lead to a growth in cycling, including the use of e-cycles, as drivers and riders alike make the switch to e-bikes, as well as cycling, and using public transport. These changes will benefit the borough as a whole, and the same rationale applies to our commitment to ensure that parking permit charges are not less than secure cycle parking storage.
On the point you raised about the space that scooters and motorbikes take up, I’m aware that officers have explained previously that Hackney Council has a long-standing policy of basing permit prices solely on the tailpipe CO2 emissions, with a surcharge for diesel vehicles, in order to encourage all residents and businesses to opt for the cleanest vehicle they can. The size of a vehicle has never been a factor that is taken into account.
In respect of the level of consultation on the proposals, it simply isn’t true to say that there has been insufficient engagement. The proposals on motorcycle charges were consulted on for 6 months in 2020, and received feedback from almost 5,000 people, including submissions from riders living, working, and commuting into Hackney. In addition, consultation on the Parking and Enforcement Plan 2022-27, has seen over 8,000 responses. These response rates highlight the lengths that we have gone to as a council to engage with the public on these issues, and I know that you and other campaigners have had regular communications with officers and myself over the last few months on these issues. This feedback has been taken into account, together with the feedback from other groups, ahead being submitted to Cabinet this evening.
If pressed on NOx and Euro standards you may have noted that we have not proposed the implementation of any additional charges based on NOx, nor have we used the Euro standards to apply such charges, and as such, the concerns you have raised around these points do not impact upon permit prices. Indeed we recognise that PTWs are better for the environment than larger, more polluting vehicles, and this is reflected in the permit prices set out in our emissions-based charging scheme.
People that need their motorbikes to be able to commute into work could be charged as much as £14,000 a year to park their bikeHackney Council has long been clear in its aim to discourage commuters travelling to work by any form of private vehicle. As part of the package of measures my colleagues and I agreed last February, we agreed to introduce maximum stay restrictions in all solo motorcycle bays, which will discourage their use by commuters, and provide more secure parking for powered two wheelers needing to make deliveries, or visit residents or businesses.
These changes mean that the £14,000 a year figure quoted is inaccurate, as it is based on the assumption that motorcyclists will be able to pay and park for 10 hours a day for those who want to commute to work, which won’t be possible in future.
This won’t prevent commuting by bike for those that wish to continue doing so, as a number of private car parks exist in Hackney and neighbouring boroughs, but we will not facilitate commuter parking on Hackney’s streets. This will not only reduce emissions, but it will also free up much needed space for local residents and businesses, particularly in Shoreditch and Hoxton, where kerbspace is at a premium.