Dear Sadiq,
Thank you for your email 30th July 2019. It was great to meet you too.
On 29th October 2018, DfT wrote to Glynn Barton, Chris Hall and myself to confirm that: “Decisions on where to place Keep Clear markings are for TfL to make”. I am therefore extremely disappointed to read that TfL decided not to try to progress the use of a type of Keep Clear road markings for kerbside bus shelters on London’s most polluted roads.
How are TfL going to reduce children’s air pollution exposure whilst they wait at kerbside bus shelters next to the exhaust pipes of start stop vehicles every school day?
Here are 12 facts you / TfL may not be aware of which should be considered when TfL direct adults, children and people with babies to wait by the kerb on roads with illegal and often toxic levels of air pollution.
1. Diesel engine exhaust is carcinogenic to humans (Group1 like tobacco)
2. You can breathe five times the nanoparticles next to the road than by walking on the building side of the pavement
3. Standing at a busy roadside, you could be exposed to magnetic nanoparticles that can go directly to the brain through the olfactory nerve
4. Any motor vehicle braking/accelerating releases particulate matter (microscopic bits of plastic, rubber, metal and oil) from, tyre and road surface wear
5. An idling vehicle produces almost twice the emissions as a moving vehicle
6. Accelerating from a stationary position creates around ten times the exhaust emissions
7. While air pollution is harmful to us all, people who are older, live in deprived areas, have pre-existing conditions or live near busy roads are at greater risk
8. One in six people dying of lung cancer in UK are non-smokers
9. Exposure of pregnant women to air pollution is linked with higher risk of premature birth, low birth weight and adverse respiratory outcomes
10. Infants and babies in buggies can be exposed to 60% more air pollution and breathe 3 times more toxic air than adults
11. All children may become more prone to coughs, wheezes and lung infections, and may be at heightened risk of developing asthma, if they are frequently exposed to air pollution.
12. The UK has the highest prevalence of childhood asthma in Europe and children who live, travel and attend schools near busy roads are significantly more likely to have asthma
I have responded below to each of the concerns TfL have raised
Nationwide application
Any proposal for a new road marking would have to apply across the UK, so the DfT would have to consider in detail whether the measure was practical and feasible.
Response: People across the UK wait at kerbside bus shelters with vehicles idling next to them. They too need protection. This is a low cost solution – practical and feasible to implement across the UK.
Ambiguity
It would be unclear to motorists why the area near a bus stop should be kept clear. Without obvious purpose, there is a high chance that such markings will be ignored.
Keep clear and yellow box markings at junctions because it is clear why those areas should be kept free from obstruction, so drivers can see the conflicting traffic movements that would otherwise block the road. A different style of marking would need to be devised (as the purpose of this idea is not to remove conflict), and this would need to be explained to drivers clearly. This means other information, such as an accompanying sign or public information campaign, would be required.
A public information campaign would be costly and would require proper research to validate the objectives.
Response: Why is it assumed that a keep clear or yellow box road marking at a bus shelter would be unclear to motorists? They are used effectively outside fire stations set back from the road when 99.9% of the time there is no conflicting traffic movement.
Drivers see the marking and stop and wait until they can drive past without braking, idling and accelerating in that area. That is the same requirement for bus shelters so a different style of marking would not need to be devised and no requirement for accompanying sign or a costly public information campaign or ‘research to validate objectives’.
Yes, there is a chance that some drivers will ignore the sign just as some drivers ignore the current keep clear road markings.
Behavioural
Traffic signs and road markings are used to convey information on how a highway should be used with regard to safety, regulations and direction.
The type of marking being proposed in front of bus stops would be seeking to influence road user behaviour and encourage drivers not to idle in front of bus stops. Because there are so many behavioural requirements of road users in The Highway Code, these are not signed or marked as it would lead to a plethora of signs on streets.
Again, to explain what we are asking drivers to do when they encounter these road markings would require an extensive communications campaign, and my comments above concerning the cost and validity of the message apply.
Response: The road marking would be used to convey information on how a highway should be used with regard to safety. The drivers are being asked to stop and wait until they are able to drive past without braking, idling or accelerating in the area. That’s not a new behavior. That’s exactly the same as they are currently asked to do for keep clear and yellow box road markings. Keep Clear road markings or yellow boxes do not require extensive, costly communications campaigns.
Enforcement
There are no powers to enforce this restriction. We would have to give consideration as to how this restriction would be applied to vehicles with no emissions or stop-start technology as there would be no need for these vehicles to “keep clear” of the bus stop area. Exemption for such vehicles would result in confusion for drivers whose vehicles were not exempt.
Response: There are no powers to enforce Keep Clear road markings so why would powers suddenly be needed? Keep Clear and yellow box road markings apply to all motor vehicles so no confusion about any vehicle being exempt. All motor vehicles produce emissions including EVs (from tyre and road surface wear) and vehicles with start stop technology also produce spikes in emissions when the vehicle accelerates from stationary.
The reasoning being put forward by TfL is without real merit. DfT have said: “Decisions on where to place Keep Clear markings are for TfL to make”. There is no ambiguity or behavior change requiring a costly public information campaign.
TfL currently direct vulnerable members of the public and children to wait by the kerb on illegally polluted roads, forcing them to breathe concentrated vehicle exhaust fumes which are carcinogenic (group1 like tobacco) and stunt children’s lung growth and shorten lives.
Experts have described bus stops as pollution hotspots and provided research to demonstrate that people and particularly children are at great risk when by the roadside. Waiting at kerbside bus shelters on congested roads is arguably the highest/peak air pollution exposure for many people yet TfL have taken no action to warn the public or to stop vehicles idling right next to their customers.
How many of the 9,000 Londoners who die prematurely each year have their greatest exposure to air pollution whilst spending time on the highly polluted roads TfL manage? How many of the children with reduced lung capacity were exposed to toxic air whilst waiting at a TfL bus shelter every day, twice a day 190 days a year. Why are these deaths and serious injuries not a part of vision zero?
If not road markings, what are you and TfL going to do to reduce air pollution exposure at these dangerously polluted bus shelters? Please don’t say ULEZ as asking people to pay to pollute will not stop vehicles idling next to bus shelters and many of the worst polluted roads are outside the ULEZ and outside the proposed ULEZ expansion in 2021.
It’s right that you ask people to leave their cars at home, to walk, cycle and use public transport but It is also imperative that you make it as safe as practically possible for them to do so. Allowing vehicles to stop, idle and accelerate next to people directed by TfL to wait at kerbside bus shelters on London’s most polluted roads is asking people to put themselves and their children in harms way.
We deserve better. You must demand better from TfL. In time the public will realise that waiting by the kerb next to congested idling traffic is their peak exposure to toxic air and they will learn that TfL had a simple low cost solution to significantly reduce their air pollution exposure but chose to do nothing. They will rightly view this as negligence.
Please pilot the keep clear or yellow box markings at a suitable kerbside bus shelter and see for yourself whether this works to reduce air pollution exposure.
Kind regards,
David
