The Anderson Shelter: The ITA’s Response to the Installation of a Bus Gate on Wapping High Street.

In October the ITA outlined reasons why taxis should be permitted to use the bus gate on Wapping High St

The ITA is a pressure group that aims to raise awareness about policies that coerce, discriminate or do not reflect public opinion.

Wapping Bus Gate

ThIs document is in response to the proposed bus gate on Wapping High St (Document Reference: 5318 Date 15.05.19) and is on behalf of those who seek a greener lifestyle, who don’t own a car, but require - or need - a demand responsive door-to door-service.

The scheme is likely to improve cycling, walking, living and working in the Wapping area, and has the potential of reducing volumes of through-motor traffic. Currently only buses and bicycles will be exempt during operating times (weekdays 5.30am - 10.30am and 4pm - 7pm). There are concerns however that the consultation was flawed due to the response options being recommended by Tower Hamlets Council, thus leading the survey applicant.

Despite these concerns, the analysis confirms that there is 70% support for the Bus Gate. However, this statistic is used to justify a Bus Gate with no exemptions for residents. Further analysis confirms only 22.5% support a Bus Gate with no exemptions. 70% is achievable only if support allows exemptions.

Our own research found that both residents and commercial business owners within the area feel strongly that their views have been dismissed by the council; most notably the decision taken to not exempt taxis from the scheme.

Taxi Overview

- Taxis (Hackney carriages) are public transport vehicles which are licensed to ‘ply for hire’.

- London has one of the most developed taxi service in the EU Transport for London (TfL) is the authority in charge of granting taxi licences both to drivers and vehicles under the London Cab Order 1934. Vehicles must have a licence to operate as black cabs and these are

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also issued by TfL provided that certain criteria are met. Among other requirements for a cab licence, London cab drivers are required to pass the well- known (and notoriously difficult) Topographical Knowledge of London examinations. The purpose of which is to ensure a safe, efficient, transport service.

- Stringent requirements are also imposed on its purpose-built vehicle and London is the only city in the EU which provides 100% wheelchair accessibility for all the vehicles used as taxis. There are also added features such as a hearing loop and illuminated hand grips for the hearing and sight impaired.

- The Knowledge test has the advantage of acting as a natural quantitative restriction barrier where take up is based on socio-economic criteria, such as the number of inhabitants, the number of tourists and business travellers. The taxi market is also geographically controlled since licences are valid only for the area of the issuing municipality, thus allowing supply to determine the demand.

- Taxis are hailed in the same way as buses, without the need to be pre-booked even though there is provision for this. Fare regulation prevents price gouging in the street hail market. The pricing structure also provides passengers with more certainty about the price they will be charged. The tariff is based on the cost-index of maintaining the aforementioned purpose-built vehicle.

- New IT technologies and web applications, which provide potential passengers with real time information have the ability to display heat maps indicating intense passenger availability areas where Wapping is regularly displayed. The use of technologies often correct the asymmetry of information between passengers and service providers during busy periods. However, the lion-share of the market prefer the convenience and freedom of a non- intermediary, demand responsive service.

- In June 2018, the average number of taxis entering central London was 11,259 and there are approximately 400 taxi drivers who are residents of Tower Hamlets. All drivers are independent sole traders local to London with no intermediary tax liabilities based overseas.

The manipulation of data is highly coercive and such instilled distrust in Tower Hamlets summary documents has led us to conduct our own research findings. By pushing unverified ideas into the public front the Council risks generating the same resistance that occurred with the aborted Tredegar Road Bus gate.

Tower Hamlets own findings concluded that;

74% (2,370) of all responders would allow taxis access through the gate, this is supported by 68% (1,528) of respondents from within the consultation area.

Only 26% stated that taxis should not be permitted through the gate. Significantly, three quarters of Wapping residents and total respondents want taxis to be allowed an exemption.

The Council’s decision not to exempt taxis does not reflect the views of the majority of Wapping residents or that of total respondents.

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According to the analysis, many of the free text comments mentioned that taxis are a vital part of travel within the Wapping area. Many residents quite rightly class this mode as part of public transport. There are several comments suggesting that taxis are preferred to the 100 bus, due to its sporadic service. A lot of responders stated that if taxis were to be barred from passing through the gate that they would be unable to get around the area with ease.

The evidence from ‘heat maps’ confirm that Wapping High Street is a vibrant area and is well served by the taxi trade. The intention of the bus gate is to tackle traffic which travels through the area with no business there ( to avoid congestion on the Highway). During the 24hr traffic survey the data revealed that 46 motor vehicles enter and exit Wapping in less than 10 minutes, indicating there is a ‘rat running’ issue. However, the most gaping discrepancy is that the traffic survey did not differentiate between vehicle types and only refer to aggregate data.

The council is incorrect to suggest that taxis use Wapping High Street as a through route to avoid congestion on The Highway. There is a bus lane on the Commercial Road that taxis are permitted to use. The Highway is a bypass and it does not make economic sense to sit in the congestion. Taxi drivers use the local roads in Wapping to transport passengers or to ply for hire. If there wasn’t the demand there, they wouldn’t use it.

Values

- A survey involving 200 drivers determined that 76% use the area to transport customers and 23.5% use the area to ply for hire. Those using the area as a through route amounted to less than 1%.

- On average, 72% of drivers said they were likely to pick up passengers after they had dropped off in the area. Likability spiked during the morning rush and again during busy evening periods. This mirrors the London wide average.

- Of those surveyed, 78% were residents who lived within the area and 22% were there for business or leisure.

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- As expected, 100% of taxi users felt that taxis should be permitted access through the gate and 79% of residents or visitors surveyed on the street were in agreement, which closely reflects the council’s own positive findings.

Feedback from residents deemed taxis to be a necessary part of the equation as other modes of transport – most notably the No.100 bus - doesn’t service the rider's destination or, is too inconvenient when the route involves two or more transfers. We consider it to be an illogical decision to exclude taxis from gates that are open to buses. Doing so discourages people from using a combination of public transit vehicles and taxis in place of automobile ownership.

We also consider the restriction of access to breach of the Equalities Act 2010, (Pt2. Chapter 1 protected characteristics/ Chapter 2 prohibited conduct).

The Governments Ministerial Forward states;

“While many take for granted the ability to travel easily from A to B, this is not the reality for everyone. For our ageing population, and the fifth of people who identify as having some sort of disability, access to transport can be far from straightforward. That is why this Government is determined to make sure that disabled people have the same access to transport as everyone else, and that they are able to travel easily, confidently and without extra cost. We have a manifesto commitment to get a million more disabled people into work by 2027, and this Strategy will help to deliver that.

I have been encouraged by the increasing awareness among transport operators of the need to design and deliver their services in a genuinely inclusive way, in particular the greater recognition that less visible disabilities such as autism, dementia or anxiety can be just as much of a barrier to travel as a visible disability”.

The Department for Transport’s Strategy (achieving equal access for disabled passengers) states that taxis should;

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“…be as accessible to disabled passengers as it is for those who are not disabled. This should mean not only that vehicles are sufficiently accessible to provide for people with a range of access needs, but that the means of hiring them is accessible, that passengers can be picked up or dropped off at a location convenient to them, and that no disabled person is ever left at the kerbside or charged extra for their journey. We also want LLAs to understand their role in helping this to happen, both through the licensing system and through other areas of influence, such as traffic”.

Taxis provide the public with the only demand responsive door-to-door service in London. The taxi division of Taxicard enables over 80,000 members in 32 participating boroughs to take around 1.3million trips per year. The Taxicard scheme offers London residents with mobility impairments or who are sight impaired subsidised travel.

The scheme enables members who may have difficulty using public transport, such as+ buses, trains and tubes, to get out and about and enjoy the city. It is a matter of personal liberty and accessibility.

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The scheme is for all journey types, including social trips such as shopping, visiting friends and family or going out to events.

If licensed taxis are prevented from using the bus gate, what provision has the local authority put in place to ensure those with mobility issues are not forced onto costly, time-inefficient routes? Mobility is a concern for the elderly, frail, wheelchair-dependent, sight impaired, anxious, and those carrying heavy luggage or shopping.

The council haven’t yet expressly clarified if their equality assessment addressed disabled taxi users as well as the elderly who use taxis in the area during the bus-gate’s operational periods. The council stated that the bus-gate was being introduced following requests from residents and businesses in the local area, adding that the impact on those businesses was considered as part of the consultation analysis. Yet the findings suggest that businesses would be adversely effected if taxis were not exempted from the scheme.

Although social media presents an arena of animosity between cyclists and taxi drivers the data shows that both cyclists and licensed taxi drivers share a very safe relationship. The taxi driver is fully conversant with the layout of London’s infrastructure which enables him or her keep their full attention on the road ahead without being distracted by various GPS systems. Taxis are factually the safest public transport option in the capital.

The cab fleet is rapidly moving towards electric with nearly three thousand in operation in the space of just eighteen months (unlike buses that are allowed to run on diesel until 2030). All new taxis have to be zero emission capable. The trade agrees that we need to plan for the future and reduce its collective detritus but creating unnecessary barriers for taxi drivers could economically disadvantage them, impeding on his or her progress to invest in a more sustainable vehicle. It’s also worth remembering, that taxis have always conformed to the EU Emissions Strategy, and are stringently tested twice a year to ensure they uphold rigorous emission standards.

Permitting taxis to access the bus gate is not about prioritising the driver’s needs but allows those who have chosen not to use their car (or better still, not to own one) to access transport that delivers an efficient, accessible, door-to-door service. In 2015, the *European Court of Justice ruled that the practice of permitting, in order to establish a “safe and efficient transport system, Black Cabs were to use bus lanes on public roads during the hours when traffic restrictions relating to

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those lanes were operational”. The restriction on taxis increases inefficiency and demotes the promotion of connected ‘public transport’

Black Cabs are subject to the rule of ‘compellability’, which requires that where a taxi has agreed to pick up a customer at a taxi rank or in the street, the taxi must take the passenger where he or she wishes to go [Act of 1831 ss. 35-36; Act of 1853 ss. 7/17; Act of 1968 s. s3; Order of 1934 art. 34]: it cannot therefore be at the discretion of the driver to determine if a passenger has a mobility issue or not. Again, crating binaries for those with mobility issues is diametrically opposed to the Dept. of Transport’s ‘inclusive’ policy and is a retrograde step that seeks to restrict legitimate freedom of choice from residents.

The Council's decision has ignored the needs and the views of those who were consulted and is inharmonious with the findings of the consultation report. Further more, the Council has not considered the Equality Act 2010 and disregards the intentions of the Government’s Inclusive Strategy. With that, we urge the Council to reconsider their decision and exempt licensed taxis from the Wapping Bus Gate proposal.

Wapping Bus Gate Report