- what’s behind the seriously underpublicised consultation?



The Mayor’s Transport Strategy (MTS) will determine the future of transport in London. Some of its proposals are very controversial. In June, Mayor Sadiq Khan opened a crucial consultation on it.


·        During the summer, the Alliance of British Drivers (ABD) spoke to several members of the public and found that hardly anyone was aware of it. Some felt that it had been seriously under-publicised.


There have been occasional tube station posters, but they were very bland, mentioning housing and employment but not the quite drastic policies planned against drivers.


For some reason, none were seen in seen in stations like Earls Court, South Kensington and Hammersmith, where there had been much opposition to the old Congestion Charge extension zone. However some were spotted at stations in trendier BBC heartland (White City) and Notting Hill Gate. One was even spotted at Theydon Bois tube station, which isn’t even in Greater London!


An advertisement with the same design as the poster did feature in the Evening Standard. (Click for 3MB JPEG graphic to read the wording)


·        Khan feels that drivers should pay more, having amazingly claimed that they pay too little to use the roads and they are subsidised by public transport users (p265). Our research provides evidence to the contrary - that drivers pay four to five times over to use the roads and our taxes in fact subsidise public transport.


As author of the MTS, the Mayor’s Office was challenged to provide some evidence via a Freedom of Information Request*, but could produce none.


This is doubly strange as the central GLA function it covers includes strategic and economic planning sections. You would expect them to have projections on the extra revenue to be made and the financial impact on the travelling public and businesses operating in London. Independent estimates from CEBR and a GLA member see a big impact from road pricing alone.


(*FOI Request: MGLA280717-2452.  Failure to respond properly breaches both GLA and wider Local Government standards.


e.g. The Mayor is determined that the GLA leads the way in openness and transparency.”)


·        ABD London Chairman Roger Lawson has experienced similar evasion from Mayor Khan’s aides at Transport for London. Roger asked for basic financial information on the costs and benefits of the ULEZ proposals, but no budgets or estimates of the costs have been provided.


(FOI Request: FOI-0071-1718 – currently subject to a complaint to the national monitor, the Information Commissioner.)


·        It is questionable whether the Mayor’s under-publicised MTS consultation meets legal expectations.


Cabinet Office consultation guidelines include:

Consultations should provide sufficient information to ensure the process is fair.”


The Supreme Court ruled in 2014:*

The demands of fairness are likely to be higher when the consultation relates to a decision which is likely to deprive someone of an existing benefit.”


(*UKSC56, Haringey v Moseley)


In a more recent case*, Justice Patterson reiterated the principles upheld by the Supreme Court case that a consultation will be fair if it:

1. communicates the public authority’s proposal to those with a potential interest;

2. explains why that proposal is being considered;

3. provides the consultees with sufficient information to make informed responses to the proposals.


(*R (Angharad Morris and Donna Thomas) v Rhondda Cynon Taf County Borough Council [2015] EWHC 1403 (Admin))


Yet the MTS fails to give proper ballpark figures for what will certainly be the large sums of money Mayor Khan plans to take from those who can currently afford to drive in London or the substantial cost of implementing his schemes.


·        Sadiq Khan’s 2016 manifesto promised (p36).

to maintain the Congestion Charge at its current level”.


So why does the MTS raise the prospect of extending the Congestion Charge? Why would it even be mentioned if there was absolutely no intention to do so?


·        As for reaching interested groups – particularly drivers who stand to lose in several ways from the MTS - there were no engage-the-public roadshows as in the 2009 consultation. The events to publicise the MTS* either involved very select audiences or were organised by a third party with TFL providing a speaker.


(*FOI-1319-1718/GH; events organised by the GLA group shown in yellow)


·        Printed reference copies of the MTS were supposed to be available in public buildings across London, including many libraries. However, a number of calls to a library or a helpdesk revealed that they didn’t seem to be aware of the MTS, let alone able to point a caller to where it could be read.  


·        Despite paying lip service to the principles of ‘robust’ and ‘compelling’ evidence, the MTS proposes draconian measures on environmental grounds, sidestepping the GLA’s own evidence and the reservations expressed by experts.



Mayor Khan is not exactly being straight with Londoners. It would be wrong to assume silence from an unsuspecting public is ‘approval’ for under-publicised and uncosted schemes – or worse still, a blank cheque.




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