Emission Zone Consultation

I filled-in the form that says "do you want to pay more tax by being fined for small contraventions?"  At the top it says

Have your say on changes to the
Ultra Low Emission Zone &
Low Emission Zone

There is some evidence here
http://content.tfl.gov.uk/mts-supporting-evidence-challenges-opportunities.pdf

There is a form here
https://consultations.tfl.gov.uk/environment/air-quality-consultation-phase-3b/consultation/confirm_submit


A lot of people fill-in these forms and write
"yes: I want to be part of a big bossy system without thinking of better options".
Shitbags. Which may sound rude but that's what the people who want more fines and rules and zones think of the typical person who gets fined, and of course they get fined themselves now and then as well because we all do by mistake.

So this is what I wrote on the final "further comments" section:

I am against everything!
I need to write a more careful response based on the headings of your evidence document, but I probably won't, or won't be well informed, so here is something off the cuff.

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PLANTING

I think there must be a lot more to be done to trap particles in plant leaves, because I see no new hedges or schemes at all. No honeysuckle, no virginia creeper, nothing. I can't remember the name of the dutch plant developed for the purpose, with a name that's a pun on dope smoking, so I googled and saw that "plants to reduce particle pollution levels the most", "how do trees reduce air pollution", and  "pollution preventing plants" are common searches and guess that there are plenty of expert advisers who could suggest the best possible plants to use as hedges while something is planted anyway, perhaps in pots to remove when a better plant can be found to make a hedge on the central reservation of Edgeware Road or the crash barriers of Westway.

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PARKS

I hoped to see something about the need for safer parks with more wilderness and undergrowth - something that happens at near zero cost. What I see day to day is councils cutting-back undergrowth to prevent gay cruising and suit the tastes of politically active local groups, such as Friends of Barnes Common or Friends of Tower Hamlets Cemetery (set up under Mayer Rahman). I'm told that Hyde Park has police patrols at night to prevent or reduce cruising after dark, despite the cost to the police budget and the effect of gay cruisers in making parks safer places. I think I saw that the Royal Parks still discourage cycling for no reason at all in some cases as well. Hampstead Heath, run by the City Corporation, has teams of people on public money cutting back the undergrowth to discourage gay cruisers, all paid-for out of our taxes and reduced public services.

So I think there is a need to embarrass and arm-twist councils and the Royal Parks into spending less money on this, promoting wilderness that is good for the environment, and promoting gay cruisers as people who make the streets and parks safer at night.

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VEHICLE TYPES

What scares me is that a visitor or somebody without the internet who is not clued-up will face a big fine by mistake, just for driving an old banger because unable to afford something new.  I think a lot of us have been fined or had a near-miss for driving in the congestion zone by mistake.

I am scared that tired international lorry drivers of travelers or Uber drivers or Hermes delivery people will end-up facing fines, and that the people who can't make a living as mini cab drivers will make even less of a living because of higher costs and difficulty of complying with the system.

I don't have an immediate solution but some kind of first warning system, by which those who broke the rules were given free advice on how to comply with the law, with a possible extra tax on all drivers related to a particular company or customer if
it's believed that that system encourages new drivers to try to use ignorance and poverty as ways of competing more cheaply.

I don't have an immediate response to the types of vehicles allowed to congest, except to say that I don't understand, so that maybe the problem is one of presentation. If the rule where presented as "electric only - and a long list of detailed exceptions", then I might take to it more.

(PS That's one of the scares among other more obvious ones like the zone getting to where I live and me having to pay more.)

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PATTERNS OF STUDY, or TOURISM

I suggest that a lot of the jobs done in central London are pointless. The person who comes to your table at a pub and says "how was your soup?". The person who changes your bed linen in a hotel. The tourist who stays in the hotel without realizing that Cardiff would be cheaper. The visiting head of state, entourage, and police. The culture or sport event like the Olympics (promoted by the Foreign Office to promote Soft Power abroad., as imagined by someone paid more than double the average wage by the Foreign Office, who lives in the home counties when in the UK and does not much use UK public services.)

There is a list of the top 20 degree-awarding colleges by numbers of international students they attract. It's easy to get a number of international students at these colleges in London, I think, and the number is about the same a the number of long distance commuters who commute between regions the UK in or out of the London region. It is a number with the same number of noughts after it. So, a system to encourage international students to go to Lampeter or Coleraine or West Highlands and not the usual boring courses that home students avoid in central London would be good all-round. Maybe the people who promote these courses should co-operate with those from Ireland who do the same thing.

All of these jobs could be discussed more in some way that I don't know off-the-cuff but maybe a series of lectures and discussions or TV programs.

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GLOBAL SOURCES & VAN DELIVERIES

I glanced at the evidence document and saw that the pattern of buying things from China or an intermediate warehouse, rather than from a walk-in chainstore that imports from China or even one that buys from the UK, is likely to lead to more van deliveries over time, with emissions and congestion attached, and so a need for more zones and taxes.

There are different ways of responding to this.

GLOBAL SOURCES & VAN DELIVERIES:

reducing the value of the pound to increase home production

I suggest that the government needs more ways of reducing inflation than simply waiting for the Bank of England to put the exchange rate up (high interest rates leading to high exchange rates) and killing-off UK manufacturing. The effect is for more people in the UK to seek service jobs that are traditionally based in the south, London, Edinburgh, and not the North East or Gwent. So I think it is in Londoner's interest for more ways to be found of reducing inflation when the Monetary Policy Committee thinks there is a danger of it. The job is to un-pick their reasoning, encourage debate, and put to the problem to the public as part of that debate. Oddly enough, some of the economics courses that attract international students to the centre of London are no good at that. That's why the LSE is the second least popular degree-awarding institution on the Guardian University Guide's list by student feedback, second only to University of the Arts.

GLOBAL SOURCES & VAN DELIVERIES:

promoting services like click and collect

I suggest that the regional government of any over-crowded city should try to advertise click-and-collect services at local newsagents and such, as a way to prevent people expecting a delivery at home when they might not be in, so that someone on low wages has to keep driving round and ringing door bells.

That's all I can think of off the cuff.

budget

London Economic Development Strategy consultation -

(including the Cultural & Education District (CED))

The Mayor's Budget ... is now open for consultation until Thursday, 12 January 2017.Please email your responses to: GLAbudget a t london.gov.uk My response was an earlier, shorter draft of this page - https://archive.is/zFYd6 ,

two responses

1. how to get more self-critical lobby documents,

2. reconsider the partners for the cultural and education district, currently London College of Fashion, University College London and Saddlers Wells.

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1. Introductory quotes in the Greater London Authority budget: response with
a suggestion down the page.

At the same time, I am determined to help London’s future economy grow and create new jobs and opportunities for Londoners.

That is why I am investing in skills, and supporting new and innovative businesses to invest in London.

In addition, I will continue to invest in London’s cultural and creative offering, and in particular the Cultural and Educational District (CED) in the Queen Elizabeth Olympic Park.

Mayors tend to shake a lot of hands and maintain a high media profile. And represent the public to just a few public services, such as regional transport. So any Mayor of any big town will end-up on a round of meetings and activities about the less factual, more lobby-related things. I don't know which Mayors personally make many decisions and which rely more on their officials, but each Mayor certainly nods when decisions are whisked-past at "meetings with senior officials" days or "briefing" in the diary - a diary which is now published for the London Mayor:
https://www.london.gov.uk/about-us/governance-and-spending/sharing-our-information/publication-scheme/mayor-londons-diary and a similar format here

The harder any Mayor works, the worse the result can be because nobody lobbies for the obvious.

Mayors want to do something about obvious crowding problems like

• high rising housing costs as a proportion of earnings.
• long commutes,
• pollution,
• rough sleeping, sofa-surfing, lack of B&Bs or landlords who take housing benefit, silting-up of hostels, lack of social housing, etc
• retention of staff in social services or emergency services.

But the conventional wisdom of people who have meetings is to favor something. Arts, tourism, inward investment, higher education, sport, fashion (whatever that is), and particular institutions involved. The meetings are not blatantly to bribe or even to lobby, but they put the Mayor face-to-face with a bunch of people and under pressure to understand their concerns and the great benefit that trade / institution A B or C does for taxpayers and voters, often acknowledged in a speech and sometimes regretted in hindsight. Gordon Brown did this kind of thing for Lehman Brothers. I am sure that politicians have done it for the National Tennis Academy. So I have rather cynically called people "lobbyists" on this round of meetings that each Mayor attends.

Each lobby group wants to crowd more people into town. None puts a price on crowding or crowding-out. Instead they have slick-looking dossiers of figures to say that "Fashion contributes £26 billion to the UK economy", or "International students contribute £26 billion to the UK economy". These phrases find their way into Mayor's briefings.

Nobody invites the Mayor to a media event to talk about Housing Benefit, or Income Support, or the basic insurance-like services which are depleted with each extra piece of spending on Tennis or Dance.

Nobody invites the Mayor to a media event to talk about over-crowding, and how to lower the profile of London as a destination, reduce tourism, reduce international study, reduce inward investment, reduce un-necessary jobs, making way for housing or workshops or social care.

The harder a Mayor works to help these lobbyists, the more damage is done.

Suggestion: the GLA London Mayor should get more self-critical lobby dossiers, and consider them more critically. Here's how.

• hire critically-minded economists at GLA economics
• guarantee them independence to state their opinions direct to the public and tell the public how to check facts on any statements received by the Mayor; I don't know how. Something like the Monetary Policy Committee
• promise to put any economic lobby dossiers to them for comment, and put the documents to the public for comment at the same time
• ask the public to point out any sentences designed to deceive. Journalists might respond. Any phrase like "world class" would risk ridicule in the tabloids before a mayor had to read it, and so after a while the Mayor would get better documents.

With luck, the mayor could stay in bed and good self-critical ideas would be pushed under his or her door, without phrases like "world class" in them.

For example the Mayor's budget states that four of the world's top four universities are in London, such as London School of Economics (LSE), and I am sure that their web sites agree. But LSE students on their economics degree give it the worst student feedback of any economics degree at any of the 83 institutions offering economics degrees in the UK. Bottom, according to Unistats. It is a degree with two years of someone's choice of theory followed by one year of application, with the option to study Game Theory but no option to study how to fund the NHS for the next fifty years. I pick this example because I did an economics course years ago, but I am sure there are a lot of example of unpopular institutions presenting themselves to the mayor as popular institutions.

Any Mayor needs a way to avoid the tiring round of engagements with groups who lure-in to a conventional wisdom and say things like "top university" instead of "bottom university" or "popular" instead of "unpopular", or "world class" and "international student", whatever they mean. Any Mayor would do better to stay in bed and have better, more self-critical information provided by institutions and pushed under the door.

I have a link to Unistats data about London School of Economics somewhere here:
https://veg-buildlog.blogspot.com/2018/01/international-student-course.html

I think the same kinds of points could be made about any of the consultations that the Mayor does, so I will concentrate mainly on the Queen Elizabeth Park project.

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2. Response about Cultural & Education District, Queen Elizabeth Park
Suggestion: the Greater London Authority should scale it down and look for popular colleges to work with instead of the chosen ones - London College of Fashion and UCL

University College London, University of the Arts' London College of Fashion, and Saddlers Wells dance company are to share a very expensive new development near the Olympic site. I have not followed the story...
theguardian.com/uk-news/2014/dec/02/london-olympicopolis-culture-hub-stratford

Any 18 year-old who looks for higher education courses will know tables like this,  mainly the ones that compare by course title. This is from The Guardian University Guide, first table quoting all the combined courses at each college, sorted by "satisfied with course" worst first . Expand the image or search yourself on Guardian University Guide if you want a closer look.

(University College London is more middling, with 84.2% satisfied with the courses and 86.0% with teaching)


I suggest trying to attract the colleges with best student feedback and best chance of creating jobs, which are probably midlands colleges and probably have less staff time and money to bid, or discuss, or build. A more modest, low-risk idea like using some existing buildings would be much more likely to attract them, as would a promise to deal only with the colleges that students like, and to cap the cost of bidding and discussing.

I think the method of choosing UCL and London College of Fashion should be published, cancelled, and that a more rational method of choosing colleges should be found and consulted-on.

If there is no way to scale-down the project and exclude London College of Fashion, maybe it would agree to be taken-over by another college with a different management and no Nike connections as part of the scheme.

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London College of Fashion : the charge sheet.

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University of the Arts and UCL make a lot of money because they provide courses with bad student feedback, as you can see on the table above. When a big famous city-centre institution has an unpopular course, the places still fill because international students who don't check Unistats take the places, and those from outside the EU pay about double the fee, so the college makes a lot of money. That's why these two colleges can afford staff to lobby and to apply for grants and suggest grand development deals and provide PR to make themselves sound like the best colleges, when the table shows one of them as the worst college for student satisfaction and just a shade better for graduate employment.

To read "London College of Fashion" as part of a scheme to promote UK employment around East London is a bit like reading about grants to Kids Company or contracts to Carillion; they have form.

• London College of Fashion graduates have mediocre to bad employment prospects.
  
• London College of Fashion students give lowest marks to their college for satisfaction
  
• London College of Fashion's knowledge transfer partnership scheme is used to promote a course: "we don't do bespoke", the person told me; "I'll let you know".
• London College of Fashion provided office space and helped claim grants with a company called Creative Connexions, designed to introduce UK designers and manufacturers to Chinese or Indian rivals. It was borne of  political initiatives and received 80% of the Higher Education Funding Council's budget for special projects in the first year or two. So UK taxpayers had to pay to put themselves out of work, just as UK students had to watch their government funding be sent to China. Creative Connexions and other LCF offices like Own-IT and UAL Ventures did a seminar called "making it ethically in China" in Manchester, just up the road from JJ Blackledge wallet manufacturers who went bust that weekend for lack of support in the home market. So, if London College of Fashion had never existed, there might still be a wallet manufacturer with all its automation called JJ Blackledge providing good jobs in Manchester.
• London College of Fashion did another bit of government business a few years ago, with Department for International Development in some rather boundary-less cross-departmental scheme that will never be accountable, leading to a web site that still warns people not to buy British made products on ethical grounds, and, at its peak, got huge amounts of column inches for its idea of "ethical fashion", meaning whatever they wanted it to mean and not fashion made in the UK, at a time when I could list the particular UK clothing and footwear manufacturers that were closing. 
• There is a fishy relationship to Nike, who sponsor the department at LCF.
  One director at Ethical Fashion Forum happened to be Nike's freelance consultant who vets ethical compliance reports sent to Nike from their contractors in the far east. A "highly regarded independent consultant on ethical trading, fair trade and corporate social responsibility" , according to the PR that went-out in the name of Ethical Fashion Forum. She did this interview for example.
  

  Adam Vaughan, journalist:

  "If we can generally guess what the problems are, can we shop by country, picking good ones and bad ones? Usually you can see where a product was made."

  
  Clare Lissaman,
  Nike consultant with government funding to promote Ethical Fashion Forum

  "I don't think you can compare countries. You're just as likely to have a sweatshop down the road here in London in the east end as you are in China, India or Bangladesh. One of the best factories I've come across in the world was in China. One of the worst factories I've come across in the world was in China."

  
  I think this is odd, because sweatshop employees in London have access to benefits including a health service and a functioning legal system with an emphasis on individual rights, so it is clearly not true that a factory in China is the same as one in London, and consumers should know the difference; London College of Fashion has helped divert London taxpayers' money into a scheme for reducing London employment and promoting Chinese employment at Nike factories.
• Nike's sponsored department acts as "secretariat" to the All Party Group for Ethics and Sustainability in Fashion, set-up by another consultant who had been nominated for peerage by someone at the Greater London Authority. There was another all party group on clothing, but this new one is a rival. It's fishy isn't it?
  
  

I made separate suggestions  a few years ago for improving the way London Fashion Week might help. and can repeat them if asked - just email

John Robertson
2 Avenue Gds, London SW14 8BP
shop a t veganline d o t com
responding to a GLA request for comment on the Mayor's budget

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16/2/18
Just today I heard that the education secretary wants to tweak the maximums that colleges are allowed to charge for fees, maybe allowing more for engineering and dentistry and (not reported but possible) less for English Literature or Law which are much cheaper to teach at the usual staff ratios.  If this is unpopular, I don't see any choice but for her to follow-through, because there are so many more degree-awarding adult education colleges and so many of them can simply not teach engineering or dentistry or mechanical engineering, leaving the traditional courses short of cash.