Bus Services (No. 2) Bill

We have submitted evidence to the Bill Committee dealing with the Bus Services Bill (no. 2) which is currently making its way through Parliament. This legislation is generally about bus services outside London. However, a small number of campaigners opposed to protected cycling infrastructure have sought to add amendments which would ban bus stop bypasses across England, including in London. We felt it was important to highlight our view to the Committee.


  1. Most people will not cycle if they are expected to share space with high volumes of motor traffic—particularly buses. The differential in mass and kinetic energy between a person cycling and a bus is many orders of magnitude larger than that between a cyclist and a pedestrian. People do not need training or safety gear to “man up” on the road—they need fully separated, protected cycle tracks, which are the only way most people will feel comfortable cycling to destinations on main roads.
  2. Bus stop bypasses, or “floating” bus stops, are a pragmatic solution to bus/bike conflicts. They reduce harm by eliminating dangerous crush movements between people cycling and buses pulling into the kerb at bus stops. They are established best practice in other European countries with dense, well-used bus networks, such as the Netherlands.
  3. Newham was the site of some of the first BSBs in London, on Stratford High Street, installed in 2012/13.Even though they don’t meet modern best-practice standards and the ergonomics could be improved, these bypasses have proven successful at eliminating bus/cycle conflicts.
  4. We can only find a report of one collision between a pedestrian and cyclist (pp. 14) at a BSB in Newham, at the Warton Road stop on Stratford High Street. This collision was categorised “slight,” i.e. not requiring hospital treatment. The BSBs are some of the safest parts of Stratford High Street for walking and cycling. By comparison, the stretches where the protected cycle track disappears (including unprotected cycle lanes and junctions, and a “traditional” unprotected bus stop in a lay-by) have a very poor safety record for both pedestrians and for cyclists.
  5. More BSBs have since been built in Newham, in Stratford Town Centre, the Royal Docks, Westfield Avenue, and Romford Road. These examples have better sightlines and ergonomics to make it easier for cyclists and bus users to navigate the space. We are glad that Newham is one of several councils leading the way in safer bus stop design in Britain.
  6. We acknowledge, and empathise with, Disabled bus users who find interactions with cycling intimidating—especially those with sensory impairments (including blind, low-vision, and d/Deaf people.) We understand why they may feel apprehensive at BSBs. Designers should ameliorate these issues by improving tactile guidance marking, colour contrast, level delineation, avoiding shared footways wherever possible, and removing obstacles and visual clutter to make it easy for cyclists to see (and give way to) bus users crossing to and from the island. This should go hand-in-hand with physical bus priority measures to deliver measurable, meaningful improvements to bus services, and education and behaviour change campaigns to improve compliance.
  7. On the other hand, “traditional” unprotected bus stop designs—the “status quo” where buses and cycles are expected to dodge each other—present inherent problems for inclusivity. For those who may prefer to cycle slowly, or who experience fear about a collision with motor traffic—including less experienced cyclists, Disabled cyclists using cycles as a mobility aid, children, older people, and families—BSBs are the only way they can cycle on a street also served by a bus route in a relaxed way. We highlight from charity Wheels for Wellbeing’s briefing on BSBs“Bus stop bypasses are presently an essential part of inclusive active travel networks that enable (pan-impairment) Disabled people to make journeys […] Banning bus stop bypasses would cause ongoing exclusion of Disabled people from active travel and bus use, and additional deaths/injuries in motor vehicle collisions.”
  8. We note and highlight Dr Harrie Langton-Spencer’s 2024 paper “Disabled people’s access needs in transport decarbonisation” in IPPR Progressive Review, which highlights the need for collective placemaking and understanding the diversity of Disabled voices in resolving seemingly incompatible access frictions. Dr Langton-Spencer specifically highlights bus stop bypasses as an example. She writes: “Instead of striving for an unobtainable ‘fully accessible’, which obscures access frictions […] is a better outcome not one in which […] nobody is excluded and everybody has the best experience possible?”
  9. A ban on “floating” bus stops would be a gross overreaction to a small risk, and be damaging to those who rely on cycling and buses.
    1. A ban would make building fully protected cycle tracks impossible.
    2. This would in turn make targets around sustainable transport, decarbonisation, and road danger reduction impossible.
    3. A ban would disproportionately exclude inexperienced cyclists, children, older people, and Disabled people using cycles as mobility aids from cycling, pushing them back into expensive car ownership or needing to be driven around by someone else. This changes the character of cycling from a mode of transport to an extreme sport.
    4. It would lead to an increase in bodged and disproven non-”solutions” such as shared pavements and 2-tier provision, which are less satisfactory—both for people cycling, and for Disabled pedestrians and bus users with sensory impairments.
    5. A ban would frame interactions with cycling as more risky and dangerous to bus users than interactions with motor vehicles. Casualty data from STATS19 shows this is simply untrue.
  10. We caution the Bill Committee of cherry-picked evidence used as a “gotcha” to support a claim that all “floating” bus stops are dangerous (for instance, video of a particularly busy stop in a tourist area where people unfamiliar with UK traffic rules regularly walk into the path of all kinds of traffic; or a photo of a legacy paint-on-the-pavement cycle lane that isn’t representative of modern standards.) One could do the same exercise with “traditional” unprotected bus stops, or for other street design features—such as advanced stop lines, or indeed many bus stations. The evidence on the efficacy and safety of BSBs must be taken as a whole, and compared to other options in the highways design toolkit—which have overwhelmingly failed to deliver positive outcomes for bus patronage and for the safety of people cycling.
  11. We urge the Bill Committee to reject amendments that would ban bus stop bypasses. Other European countries show that BSBs are a key component of comprehensive, well-used, and inclusive bus networks that are fit for the future. England should follow their lead, and focus on measures to make buses better—rather than a logically incoherent ban on BSBs that would only serve to make cycling worse.

                      Water Lane consultation

                      Newham Council are consulting on this scheme to add a parallel crossing for walking and cycling to Water Lane, connecting the Cycleway link between Manbey Grove and Louise Road. The deadline for responses is Friday 1st November.

                      We support this scheme and hope that it will go together with a wider scheme to improve both the C-link and the Water Lane area, which is blighted by high volumes of high speed traffic despite not being a main road. We are very aware that there was recently a fatal crash here (two Fridays ago.)

                      We’ve asked for clearer visual priority for people walking and cycling, with a continuous surface treatment, to make more likely that drivers will give way to people crossing (as they legally should.)

                      You can find our response below, and use that to inform your own response to the survey.

                      Consultation response: Blackwall and Silvertown Tunnel road user charge

                      Transport for London has consulted on their proposals to introduce a user charge for drivers at the Blackwall and Silvertown Tunnels. The proposals were for:

                      • a £4 charge at “peak times” for drivers using the Blackwall and Silvertown Tunnels. Peak times are northbound 0600-1000 and southbound 1600-1900 on weekdays only
                      • a £1.50 charge at “off peak times” for drivers. Off-peak times are all times between 0600-2200 that are not peak
                      • no charge overnight
                      • At the same time TfL announced details of a “green and fair package of supporting measures”, including: free bus journeys on routes 108, 129 and SL4 for “at least 12 months”; free DLR journeys between Cutty Sark-Island Gardens and Woolwich Arsenal-King George V for “at least 12 months”; free travel for those cycling on the Silvertown tunnel cycle bus for “at least 12 months”, with the service guaranteed to run for at least 3 years.

                      We neither supported nor opposed the proposals.

                      • Generally we support a fair and equitable system of road user charging. But this requires practical alternatives for people to make their journeys without driving.
                      • TfL has no coherent strategy for non-motorised river crossings in east London, meaning there is no practical alternative to driving for many journeys. Future political campaigns and administrations will target the user charge for abolition, allowing unfettered cross-river motor traffic.
                      • We continue to oppose the Silvertown Tunnel as a crossing for private motor traffic. It is a 1960s-quality urban motorway project that shouldn’t have been approved. We still have no confidence in TfL or the current Mayor ever delivering a viable cycle crossing east of Tower Bridge, despite the clear need for one.

                      We do not believe the proposed road user charge is high enough to deter people from making unnecessary journeys or switching to a more sustainable mode. We also think the alternatives are too expensive and too impractical.

                      It is particularly concerning to us that the proposed off-peak tunnel user charge of £1.50 is 25p cheaper than a single bus fare. Even at peak times, the tunnel user charge for cars is £2 cheaper than the Cable Car fare, and 10p cheaper than the Doubletree Rotherhithe ferry. At off-peak times, the Cable Car fare is a whopping four times the price of the charge a driver would pay.

                      We are disappointed that the “green and fair” package that TfL has supposedly already agreed for pedestrians and cyclists only guarantees free river crossings for those without a car for the first year, and only in specific circumstances. We maintain our scepticism about the practicality of the cycle bus, particularly considering it will finish at 9:30pm.

                      To apply a crude analogy: the stick is not big enough to be a deterrent, but is big enough to be annoying. Meanwhile, the carrot isn’t substantial enough to get people to move to a mode other than driving.

                      We urge TfL to work with the national Government to invest in and urgently progress the desperately-needed walking and cycling river crossings that east London has needed for decades.

                      Consultation response: Chobham Manor phase 2

                      Newham Council and LLDC consulted last month on some measures to improve some junctions in the Chobham Manor area.

                      The proposals are to

                      • straighten out the zebra crossing from Honour Lea Avenue over Olympic Park Avenue into the Olympic Park, and add a parallel crossing to formally allow people to cycle across it with priority
                      • add a mode filter at the junction with Temple Mills Lane and Abercrombie Road, only allowing buses and coaches
                      • add speed cushions on Abercrombie Road and Olympic Park Avenue.

                      We were pleased to support these proposals, although we had reservations about the use of speed cushions which are not in line with best practice for cycle routes. We suggested the use of sinusoidal humps instead, and consultation with local stakeholders who use three-wheelers.

                      Take Action: East Village Cycle Connections

                      A map of East Village in London. Anthems Way, Celebration Avenue, Liberty Bridge Road, Temple Mills Lane, and Penny Brookes Street all have blue lines indicating cycle tracks; junction improvements at Temple Mills/Celebration Ave, Celebration Ave/Liberty Bridge, Celebration Ave/Penny Brookes, and Penny Brookes/Montfichet Road.

                      Newham Council are consulting on a long-term plan for cycling in East Village (the ex Olympic athlete’s village on the “new” side of Stratford). The designs are a step-change for the Olympic Park, an area whose cycling infra has been outdated from the moment it was built. The proposals include safer cycle tracks, continuous pavements for most of the streets in the area, and fixes for dangerous junctions.

                      We support the scheme, but would like Newham to do a little more to make sure everyone can benefit from it—particularly children cycling to school at Chobham Academy.

                      The consultation is open until Sunday 17th March: we recommend you support the scheme, but ask Newham to:

                      1. Deliver the scheme quickly, obtaining funding from the many housing and commercial developments in the area to do so.
                      2. Find a way for kids to cycle safely to school on Liberty Bridge Road over the railway line, where the designs currently dump people cycling out into the carriageway due to a width restriction. We’d like to see a bus gate, or an extension of the school street on Cheering Lane. Doing nothing is not an option.
                      3. Fix the Mirabelle Gardens-Elis Way-Cheering Lane rat run. Drivers leaving Westfield often use this as a shortcut to avoid the traffic lights on Celebration Avenue.

                      Remember: your own views and experiences will carry the most weight in consultations.

                      Take Action: Say YES! to the Romford Road cycleway

                      Newham Council are consulting on their full plan for cycleways on Romford Road. This is a long-awaited extension of Cycleway 2 to the edge of Ilford.

                      Artsy visualisation of Romford Road with with-flow cycle tracks on either side of the road. A mother with a pram and a lady on her phone cross the street on a zebra crossing, while pedestrians and a kid with a kick scooter use the footway.

                      We are delighted to see the designs are super high-quality! Continuous cycle tracks. Fully protected Dutch-style junctions. More planting and trees. New sections of 24-hour bus lane. It looks similar to the Lea Bridge Road cycleway in Waltham Forest, but in some ways (e.g. at bus stops) it’s even better!

                      Romford Road is one of our most important main roads, and also one of the worst places in Newham to cycle at the moment. TfL’s Strategic Cycling Analysis shows there is huge demand for people to cycle here. Now’s your chance to tell Newham Council “yes please!” to high quality cycleways.

                      The consultation is open until Sunday 24th March. We recommend you support the scheme, and ask Newham to:

                      1. Deliver cycle tracks on Romford Road in full and as quickly as possible, without compromising on protection, width, or junction design
                      2. Co-ordinate with the Redbridge to allow the cycleway to continue to Ilford town centre
                      3. Future-proof the scheme for low traffic neighbourhoods on the nearby side streets, and for cycle tracks on the main roads that cross it—everyone deserves to live on a street that’s safe for cycling

                      We’ve posted our own response below for your reference, but remember: your own views and experiences will carry the most weight in consultations.

                      Lower Lea Crossing: Is that it?

                      TfL are consulting on changes to the Lower Lea Crossing and Aspen Way Roundabout. It’s not too bad—tweaking some crossings here, widening some cycle tracks there, etc.

                      But it’s also not especially transformative: there’s already a cycle track here, and it already provides an important connection to the Royal Docks. Some of the changes will be nice to have, but they could’ve been better. One arm of Aspen Way roundabout on the north side, amazingly, still won’t even have crossings!

                      The bad news is that this scheme ties in to the Tidal Basin Roundabout and the Silvertown Tunnel. The Tunnel will bring much, much more traffic to the Lower Lea Crossing and Aspen Way. Maybe these changes to the Lower Lea Crossing cycle track are an attempt to mitigate these negative effects—but they’re nowhere near enough.

                      The consultation is open until Monday 12th February. We recommend responding and telling TfL:

                      • The scheme won’t really make a difference to the number of people walking and cycling in the area.
                      • TfL should build crossings on all arms of the Aspen Way roundabout, and they should all be separated for walking and cycling (no shared areas please.)
                      • In the medium term, TfL should look at grade-separating walking and cycling at the roundabouts, like at the Green Man Roundabout.
                      • Where the cycle track is interrupted for servicing entrances, drivers of servicing vehicles need to be given adequate warning to watch for people walking and cycling.
                      • The main problem in the area will still be the Silvertown Tunnel, a 1960s quality urban motorway scheme which shouldn’t have been approved. This scheme, combined with the threadbare bus network and silly cycle shuttle bus, comes across as a tick-box exercise to let the Tunnel’s promoters pretend they’re doing something worthwhile for people who don’t have a car, don’t want one, or can’t afford one.

                      You can also read our consultation response here:

                      Silvertown cycle bus: Embarrassing

                      TfL are consulting on a long-awaited and much-needed new crossing of the Thames east of Tower Bridge. The bad news is, it’s not the bridge that got cancelled, or even a high quality RoRo ferry like the ones in Amsterdam. Why have an actual cycle crossing, or even a ferry you can cycle onto, when you could have… a bus with some bike racks?

                      A rendering of a bus stop with a futuristic-looking bus shelter, next to a single decker bus with bicycle racks on it and middle doors. Someone on a hand cycle is negotiating the entrance (although it's not clear how she'll be able to turn around once inside.) A commuter type wearing a tie, hi-vis jacket, and helmet, waits to load his bicycle on behind her. A woman sits on the bench holding a helmet, presumably waiting for other people to get onto the bus.

                      This is part of the new Silvertown Tunnel scheme, a new crossing for cars and lorries (with a piecemeal bus network) that will run from the Royal Docks to North Greenwich. We oppose this scheme as it stands, and this—presumably intended to say the scheme does something for cycling—is frankly embarrassing. There are many reasons it won’t work:

                      • Larger cargo cycles unlikely to fit (meaning deliveries by car or van would enjoy an unfair advantage over zero-emissions last mile freight)
                      • Adapted cycles are unlikely to fit—especially if the bus eventually looks like a minivan with a trailer
                      • Unpredictable journey times
                      • Low capacity that doesn’t allow for large volumes of people cycling
                      • No clarity on what form the service will take, frequencies, operating hours, or whether a fare will be charged
                      • The physical awkwardness of dismounting and loading your cycle into racks when getting on/off. We find it hard to believe the Silvertown Tunnel would’ve been approved if drivers had to load their cars onto car transporters to be driven through the tunnel

                      We can’t support the cycle bus scheme because it’s not viable as a 24/7, step-free, accessible cycle crossing that people will be able to use independently. Historical precedent suggests it is doomed to failure. It’s a box-ticking exercise that allows the promoters of the Silvertown Tunnel to pretend they’re doing something for people who don’t have a car, don’t want one, or can’t afford one.

                      Because of this, we have no confidence in TfL or the current Mayor delivering a viable cycle crossing east of Tower Bridge—despite the fact we desperately need them. We would love to be proven wrong, so invite TfL to seek funding for and commit to things that would actually work, including:

                      • Increasing frequency and operating hours on the Woolwich Ferry, and removing the need for cyclists to dismount on the ferry decks
                      • Abolishing fares on the Cable Car and extending operating hours
                      • A new ferry at Rotherhithe, which TfL’s own modelling suggests could be very popular
                      • Pedestrianising the Rotherhithe Tunnel, or the Blackwall Tunnel’s original Victorian bore (by TfL’s own omission, not suitable for high volumes of motor traffic, and built with a bend to prevent horses from bolting)
                      • Building new fixed links—be that new cycle-only bores for the existing foot tunnels, or reviving the Rotherhithe Bridge proposal

                      Tell TfL to stop making excuses & do better

                      There’s a consultation open until this Sunday (10th September) where you can tell TfL what you think of these proposals. We’ve posted our response below in case you need inspiration, but we recommend telling them:

                      • East London is crying out for actual river crossings that don’t require a car
                      • A bus service that allows people to bring bikes as luggage is fundamentally flawed & won’t meet that demand
                      • TfL should be prioritising high-quality crossings that would actually scale to large volumes of cyclists—ferries at the very minimum, and fixed crossings in the longer term

                      Consultation response: Silvertown Tunnel bus network

                      We have responded to TfL’s consultation for its initial proposals for the Silvertown Tunnel bus network.

                      We oppose the Tunnel in general, and also specifically oppose these proposals.

                      They do not provide anything like a sufficient bus network to mitigate the effects of opening a new urban motorway funnelling traffic into Newham—only one of the new bus routes even serves Newham, and the other is an express from south east London to Canary Wharf.

                      We would like to see the Tunnel re-tooled as a crossing only for a more substantial public transport network, along with walking and cycling—for which 24/7 step-free links east of Tower Bridge are desperately needed but currently sorely lacking. The mooted cycle-bus trial is also missing from the consultation—so with the Silvertown Tunnel, active travel modes get absolutely nothing.

                      The consultation is open until tomorrow (11th Jan.) We encourage locals in Newham and beyond to respond with their own views.

                      Silvertown-Tunnel-bus-network-response-Newham-Cyclists

                      Consultation response to LLDC’s Carpenters Road designs

                      The London Legacy Development Corporation is consulting on highway designs for Carpenters Road, due to re-open with the East Bank/Stratford Waterfront development. The planning references are 22/00256/AOD and 22/00249/NMA and can be checked on LLDC’s planning register.

                      We have been consulted throughout the design process for this as part of LLDC’s Sustainable and Active Travel Group, and this early engagement has been welcome.

                      We support the principle of a cycleway on Carpenters Road, but are concerned about the details of the proposals. In particular, we worry that they repeat mistakes made elsewhere in the park (e.g. on Montfichet Road) and don’t adequately deal with speeding and rat-running, which was a major problem before Carpenters Road closed for construction (over 80% of vehicles exceeded the 20mph speed limit.) We think that a longer term solution must involve serious measures to reduce traffic, which would then unlock space for better walking and cycling provision.

                      You can read our consultation response PDF below.

                      Newham-Cyclists-Carpenters-Rd-consultation-response