Plans for the Olympic Route Network remain unlawful and vulnerable to legal challenge through judicial review

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Mayor Johnson
Chairman
Transport for London
c/o TfL Olympic and Paralympic Route Network Engagement
Transport for London
5th Floor, Palestra
197 Blackfriars Road
London SE1 8NJ

By email and registered post:  [email protected]and [email protected]

12 September 2011

Dear Mayor Johnson

Local consultations on ‘Temporary road changes for the London 2012 Games’

Plans for the Olympic Route Network remain unlawful and vulnerable to legal challenge through judicial review

Proposals would: trap vehicles and pedestrians in local streets; force people down one lane or perhaps two alongside the ORN or PRN with all the buses and taxis; and rely on the ‘Big Scare’ tactic playing ‘mind-games’ successfully with Londoners to stop them driving or working in London (perhaps) to achieve a 30% reduction in ‘background’ or non-Games traffic

Everyone in London, except those using official Olympic vehicles, faces chaos for weeks on end in 2012 – even if the ‘Big Scare’ tactic is completely successful. The organisers should have planned many more events outside London.  In any event, having created this mess, the organisers now have a legal duty to mitigate in full the problems

Clean Air in London (CAL) welcomes the opportunity offered by Transport for London (TfL) to respond to its consultation on ‘Temporary road changes for the London 2012 Games’ (Phase 4 engagement) (the Consultation) which closes on 14 September 2011. See:

http://www.tfl.gov.uk/corporate/projectsandschemes/20550.aspx

This response is addressed also to the Mayor of London, as Chair of TfL, given that TfL assumed responsibility from the Olympic Delivery Authority (ODA) on 9 February 2011 for delivery of key 2012 Games transport programmes including the 2012 Games Travel Demand Management, Olympic and Paralympic Route Networks (ORN and PRN) and Road Freight Management (RFM) programmes in London. See:

http://www.tfl.gov.uk/corporate/media/newscentre/archive/18237.aspx

Please note that CAL has not been able to find the online feedback tool which was meant to be accessible at (link no longer available) and/or any telephone numbers or email address on TfL’s website for submitting responses to this consultation.   The only contact details were obtained by coincidence  through a local letter drop.  This seems a gross failure of governance and transparency by London government.

CAL is a not for profit organisation with a mission that includes campaigning to achieve urgently and sustainably at least World Health Organisation Standards (WHO) guidelines for air quality throughout London.

CAL is independent of any government funding, has cross-party support and many supporters, both individuals in London and organisations.   CAL provides a channel for both public concern and expert  opinion  on  air  pollution  in  London.     This  document  provides  both  general  and  expert comments in response to the consultation.

CAL has not repeated here points made to TfL and the ODA in its submission dated 8 April 2011 and elsewhere.

Summary

Traffic  is  a  major  cause  of  air  pollution  in  London  which  in  turn  contributes to  thousands of premature deaths per year and many thousands more illnesses, chronic illness and disability.  For this reason, traffic measures are also measures to deal with air quality.

It seems the plans for the ORN and PRN ‘boil down’ to:

  1. trap pedestrians and drivers in local residential streets;
  2. force drivers down one lane or perhaps two alongside the ORN and PRN with all the taxis and buses; and
  3. rely largely on the discredited ‘Big Scare’ tactic playing ‘mind-games’ with Londoners to stop them driving or working in London for weeks on end to achieve a 30% reduction in‘background’ or non-Games traffic…

…for 18 hours a day for long periods between July to September.  In some cases, restrictions will apply 24 hours a day and begin in June or early July 2012 and continue well into September e.g. North Carriage Drive, The Mall, Horse Guards Road and Marlborough Road.

The details of our response to TfL’s ‘informal’ Consultation on proposals for the ORN and PRN are set out below, but in brief:

  1. CAL does not think the consultation has been adequate because insufficient information was provided in the consultation documents;
  2. earlier modelling for the ODA suggested that the operation of the ORN and PRN would lead to an unlawful increase in air pollution, inconsistent with European Union (EU) law;
  3. it seems even more likely, having seen now the detail of TfL’s draconian proposals and feeble mitigation, that the ORN and the PRN would cause the aggravated breach of one or more limit values for dangerous airborne particles (PM10) and nitrogen dioxide (NO2) (e.g. the NO2  annual mean and NO2 hourly limit values in areas where they have been attained in 2011);
  4. it seems even more likely, having seen now the detail of TfL’s draconian proposals and feeble mitigation, that the ORN and the PRN would result in an increase in harmful concentrations in ambient air; and
  5. there has been no, or no adequate, consideration of the impact of the proposals on particularly vulnerable groups or minority ethnic groups.

Please note that CAL’s response to this Consultation assumes that TfL will achieve some success – perhaps for many weeks in 2012 – through its cynical use of the ‘Big Scare’ tactic to dissuade ordinary people and businesses from driving or working in London during the Olympic Games and Paralympic Games.

Over the last six months or so, CAL has received written assurances from the ODA and the Mayor as Chair of TfL.  Crucially, these assurances related to the impacts of the Olympic Transport Plan, including the ORN and PRN, on air quality and the mitigation of adverse impacts.  The current consultation involves no more than the publication of maps showing restrictions for vehicles and pedestrians across much of London.  Instead you must make clear the environmental impacts of your proposals and the individual and cumulative impact of measures to achieve full mitigation of them. Please note also that your analysis needs to take account of the impact of the (prior) celebrations for the Queen’s Diamond Jubilee e.g. between 2 and 5 June 2012.

CAL has therefore responded as best it can to this Consultation despite the ongoing lack of information.

In CAL’s carefully considered view, TfL’s proposals for the ORN and PRN involve such draconian restrictions and feeble mitigation that they will result in chronic congestion and inconvenience for Londoners and breaches of air quality laws along the lines predicted by the Strategic Environmental Assessment (SEA) undertaken for the ODA or worse.  The proposals therefore remain unlawful and subject to legal challenge through judicial review.

Background and timeline

CAL sets out below background to this consultation and a timeline of events.

1.    The ODA’s promise

CAL notes the ODA’s promise in its letter to CAL dated 22 March 2011 that included:

“The ODA undertook the preliminary design for the Olympic Route Network (ORN) and for the Traffic Regulation Order (TRO)  process, however in  accordance with  our  strategy the  detailed design and operation have been handed over to Transport for London (TfL).  Funding has also been handed over to complete works associated with the build and operational phases.

“As detailed design of the routes, and therefore impacts, had not been finalised at the point of handover, the ODA will work collaboratively with TfL to ensure any statutory obligations are discharged in an appropriate and cost effective manner.” CAL emphasis.

2.      Response to SEA

Please see CAL’s response dated 8 April 2011 to the consultation on the Strategic Environmental Assessment (SEA) undertaken for the ODA:

https://cleanair.london/olympics/olympic-transport-plan-would-lead-to-breaches-of-air-pollution-laws/

Amongst other things, that response included details of the so-called ‘Big Scare’ tactic

3.    The Mayor’s promise

CAL notes the Mayor of London’s promise to it in a letter dated 3 May 2011 which said:

“Thank you for your letter of 8 April regarding the Strategic Environmental Assessment (SEA) of the Olympic Transport Plan, 2nd  Edition consultation draft.  I am aware of the issues raised in the SEA and Transport for London has responded to the consultation.

I will encourage the ODA to work with TfL on further modelling of the impacts of the Olympic Route Network on air quality in London, using the most up-to-date information. We will then consider what mitigation measures might be necessary.”  CAL emphasis

4.      Olympic Transport Plan

The Olympic Transport Plan published on 1 June 2011 stated in paragraphs 17.16 and 17.17 on page 226 in Part 7 (8 MB file size):

http://www.london2012.com/documents/oda-transport/final-transport-plan/transport-plan-part-7-ch-9- end-.pdf

http://www.london2012.com/making-it-happen/transport/transport-plan.php

“17.16  As part of the development of the Transport Plan, the ODA commissioned an independent Strategic Environmental Assessment (SEA). The purpose of the SEA was to ensure that environmental impacts were taken into consideration at the earliest opportunity.  In particular, it covered areas such as climate change, air quality, and noise related to the Transport Plan.

“17.17  The SEA Environmental Report concluded that: because the Plan specifies the use of existing public transport infrastructure and services due to the limited duration of the Games, the SEA has not identified any significant adverse environmental effect that will be likely to arise from the operation of the measures contained in the Transport Plan.   However as detailed operational plans mature the ODA  will  work  with  TfL,  the  GLA  and  delivery  partners  to  update  relevant  Environmental Assessments to ensure that this still remains the case and that mitigations are appropriate.”  CAL emphasis.

5.    Temporary road changes for the London 2012 Olympics: Phase 4 engagement

The current ‘informal’ Consultation was launched on 8 August 2011 and closes on 14 September 2011.

 6.    Statutory consultation process: Traffic Orders

The current consultation dated 8 August 2011 states:

“The statutory consultation process, which is currently due to start in late October, will be the opportunity for you to make formal representation about the proposals and this will be advertised locally.”

TfL and the ODA are under a legal duty to ensure that air quality is not worsened by the planned ORN and PRN.  Further, the above statements by the ODA and the Mayor give CAL a ‘substantive legitimate expectation’ that offsetting measures will be introduced by the ODA and/or TfL to ensure that there is no worsening of air quality as a result of the ORN and/or PRN.

No information has been provided yet on where or when the breaches of EU limit values are likely to occur and there is none to quantify the individual and cumulative effect of measures needed to ensure the full mitigation of any adverse effects. So far, any measures are: vague or unspecified; and still unquantified.

Further details of CAL’s concerns are set out below.

Substantial information shortfall in air quality-related consultation

CAL  believes  that  the  information which  has  been  provided  to  the  public  in  this  Consultation document is still inadequate.

In the absence of the requisite information in the consultation papers themselves, CAL is prevented from responding fully to this Consultation including in relation to whether the proposals for the ORN and PRN are compatible with the UK’s obligation under air quality laws.  Please note that any such information needs to take full and cumulative account also of the impact on air quality of proposals for the Queen’s Diamond Jubilee not least because they will take place prior to the Olympic and Paralympic Games e.g. between 2 and 5 June 2012.

Please would you publish the following information as a matter of urgency and in any event no later than the start of any Statutory Consultation on the Traffic Orders for the ORN and PRN – if plans for them proceed – in a way that will readily bring it to the attention of the public:

1.   modelling or estimates of the likelihood of the PM10  daily limit value being breached in 2012 in London if the ORN and PRN were to be implemented.  In particular:

i.      the  modelling undertaken of the impact of the implementing the ORN and PRN (including  of  the  highest  mean  concentrations  of  annual  mean  PM10    withinconcentration contours’);

ii.      any modelling of the impact of mitigation measures;

iii.      any assumptions underpinning the above modelling; and

iv.      any  TfL  or  ODA  commissioned study  of  measures to  address concentrations at‘priority locations’.

2.   modelling or estimates of the likelihood of the NO2   annual mean and hourly limit values being breached in 2012 in London and the likelihood of maintaining annual mean concentrations of NO2 below 60 µg/m3   in each of those years, if the ORN and PRN were to be implemented. In particular:

i.            the modelling undertaken of the impact of implementing the ORN and PRN;

ii.            any modelling of the impact of mitigation measures;

iii.            any assumptions underpinning the above modelling;

iv.            any related  work  done   for   TfL   o r  t h e  ODA  equivalent to that undertaken for PM10.

3.   details of any measures that were considered for inclusion to mitigate the impact of the ORN and PRN,  but  ultimately rejected, and the reasons for such rejection.   In particular, the modelling undertaken of the likely impact of these measures on air quality.

As you will be aware, fair consultation must take place at a time when proposals are still at a formative stage; sufficient reasons must be given for proposals to enable consultees to give those proposals intelligent consideration and to provide an intelligent response; adequate time and opportunity  should  be  given  for  a  response;  and  the  product  of  the  consultation  must  be conscientiously taken into account by the authority when reaching its decision: R v Brent LBC ex p Gunning (1985) 84 LGR 168, approved in R v North and East Devon Health Authority ex p Coughlan [2001] 1 QB 213.

The  continuing failure  to  provide  the  information above  means  that  CAL  and  other  consultees are unable to give intelligent consideration or an informed response to the various options being consulted on.  It  is  difficult  to  think  of  information  which  could  be  more  relevant  to  a  public consultation on the possible implementation of the ORN and PRN than that which shows the extent to which the implementation of the ORN and PRN would result in air quality laws continuing to be breached.

If this information is not provided in good time, and at least 21 days prior to the end of any statutory consultation on plans for the ORN and/or PRN, we reserve the right to challenge it and any decision taken following such consultation or consultations, in particular on the basis that such consultation has been inadequate and has failed to meet accepted public law standards.

The failure to publish important information with the current air quality-related consultation points to serious failings by London government and a lack of fairness.

In the circumstances, CAL’s ability to respond to the current Consultation is compromised.

Response to the proposals, insofar as a response is possible

Notwithstanding and subject to its concerns about the consultation, CAL outlines below the response it is able to make to the proposal. This response is of necessity in general terms.

It seems the plans for the ORN and PRN ‘boil down’ to:

  1. trap pedestrians and drivers in local residential streets;
  2. force drivers down one lane or perhaps two alongside the ORN and PRN with all the taxis and buses; and
  3. rely largely on the discredited ‘Big Scare’ tactic playing ‘mind-games’ with Londoners to stop them driving or working in London for weeks on end to achieve a 30% reduction in ‘background’ or non-Games traffic

…for 18 hours a day for long periods between July to September.  In some cases, restrictions will apply 24 hours a day and begin in June or early July and continue well into September e.g. North Carriage Drive, The Mall, Horse Guards Road and Marlborough Road.

Please tell Londoners what we can do not just what we can’t do during the Olympic Games and Paralympic Games.  The draconian and complex nature of the proposed restrictions make it virtually impossible for an ordinary person or business to understand how they will be able to access their property for many weeks in 2012.

CAL sets out below examples from the Phase 4 engagement consultation of the measures, areas and timescales involved. These proposals seem likely to cause widespread breaches of EU limit values.

Types of restrictions

  1. Games lanes
  2. Bus lanes suspended and/or relocated
  3. Taxi ranks suspended and/or relocated
  4. Parking/loading bays suspended and/or relocated
  5. Left and right turns banned
  6. Exits changed to ‘give way’
  7. Direction of traffic changes
  8. Nearside exit lanes closed to permit larger vehicle turning
  9. Pedestrian crossings suspended and/or signals changed
  10. Restricted access (exceptions apply)Changes to kerb side restrictions
  11. The introduction of weight restrictions for vehicles
  12. Barriers down the centre of the road to prevent ‘u-turns’ and pedestrian jay walking
  13. Restrictions in place from 6am to midnight and/or 24 hour restrictions in place

By way of further example, specific the arrangements proposed for the following areas include:

Examples of restrictions by area or road

Brompton Road and the A4

  •  Closure of Grosvenor Crescent at Hyde Park Corner
  • Closure of Lancelot Place at Brompton Road
  • No exit from Sloane Street into A4 Knightsbridge
  • No entry from Knightsbridge eastbound into Sloane Street
  • No exit from Thurloe Place into A4 Cromwell Gardens
  • Barriers to be installed to prevent ‘u-turns’
  • Suspension of eight pedestrian crossings between Earls Court and Hyde Park Corner
  • Reversal of traffic in Hans Road with banning of right turn onto A4 Brompton Road

It seems ordinary people would be trapped in local streets and/or forced down one lane or two at most with all the buses and taxis.

Parliament Square

  •  Games lane alongside Westminster Hall for 24 hours a day during the Olympics and from 6am to midnight during the Paralympics
  • Closure of Great George Street (except for official Games vehicles and cyclists) for 24 hours a day during the Olympics and from 6am to midnight during the Paralympics
  • No entry into Whitehall except official Games vehicles, TfL buses and cyclists
  • No access towards Millbank except official Games vehicles, local buses, cycles and local access from 7am to 7pm
  • Westminster Bridge eastbound TfL bus and cycle lane suspended
  • Official   Games   vehicles,   local   buses   and   cycles   only   permitted   westbound   across Westminster Bridge

It seems ordinary people (and Parliamentarians?) would only enter Parliament Square from Victoria Embankment, Victoria Street or Millbank and exit only to Victoria Street or Victoria Embankment alongside the ORN or PRN.

Trafalgar Square

  •  No entry to the Stand except official Games vehicles and TfL buses
  • No entry northbound into St Martin’s Place except TfL buses, taxis and cyclists. No entry southbound except for TfL buses
  • 6am to midnight access to Whitehall restricted to official Games vehicles, TfL buses and cyclists
  • Access to The Mall restricted 24 hours except for official Games vehicles
  • 6am to midnight. No entry onto Cockspur Street for general traffic except official Games vehicles.
  • Pedestrian crossings widened around Trafalgar Square roundabout
  • No access for general traffic to Trafalgar Square via Pall Mall east or Cockspur Street 6am to midnight.  TfL bus and taxi exemptions under consideration
  • 6am to midnight No entry into Cockspur Street for traffic except official Games vehicles and TfL buses
  • 6am to midnight NO entry for traffic except for access to Orange Street, St Martin’s Street, Suffolk Place, Suffolk Street, and Whitcomb Street.   Access to be managed by Traffic Marshalls

It is unclear how any ordinary people would access Trafalgar Square by vehicle other perhaps than from Northumberland Avenue.

Victoria Embankment, Upper and Lower Thames Street

  • Games lanes take up one lane each way from 6am to midnight
  • 10 pedestrian crossings suspended
  • 10 bus stops suspended (not relocated)
  • No  right  turn  from  Queen  Street  Place  northbound  (i.e.  Southwark  Bridge)  into  Upper

Thames Street

  • Many other turns banned and/or access restricted
  • Proposed changes will operate 24 hours a day ‘unless otherwise indicated’
  • Barriers to be installed along central reservation

It seems all ‘background’ or non-Games traffic would be funnelled down a single lane each way along the length of Victoria Embankment, Upper and Lower Thames Street.

Timescale of restrictions

CAL understands from the Royal Parks’ excellent Communications Manager for London 2012 Games that:

  • North Carriage Drive will be closed between 1 June and mid-September in order to allow for the temporary Olympic and Paralympic venue to be constructed and removed
  • The Mall and Horse Guards Road will be closed to public traffic for the duration of the Olympic and Paralympic Games and for a significant period either side.  This is because of the Olympic events taking place there – including the Beach Volleyball competition and a number of road race events
  • Marlborough Road will not be accessible to traffic between July and September due to theOlympic and Paralympic events that will take place nearby on The Mall

The  Olympic  Games  run  from  27  July  to  12  August  and  Paralympic  Games  29  August  to  9 September.  You will be aware that the Queen’s Diamond Jubilee celebrations are due to take place between 2 and 5 June.

Photos of chaos during the London-Surrey Cycle Classic

Please see also photographs taken by CAL of the major disruption caused during the London-Surrey Cycle Classic on Sunday 14 August 2010:

(new link needed)

The combination of such extensive measures for such long periods in 2012 seem certain to cause so much congestion that breaches of air quality laws are inevitable without extensive mitigation action.

NO2 limit values have been breached in London since they entered into force in January 2010 and may only be breached in the period up to January 2015 if the UK obtains a time extension to comply with them and meets various conditions such as the need to ensure NO2 annual mean concentrations do not exceed 60 micrograms per cubic metre (μg/m3).  The UK must lodge such an application by 30 September 2011 and the European Commission would then have until 30 June 2012 to object to it (or not).  In other words the outcome is likely to be known only in the last few days or weeks before the start of the London 2012 Olympic Games.  If the UK does not apply for a time extension for London, there will be no dispensation from the NO2 limit values applying from 1 January 2010.

You will be aware the UK was ‘third time lucky’ in obtaining a time extension until 2011 for PM10. The PM10 limit values are now in full force and must not be exceeded in 2012 (or thereafter).

In CAL’s carefully considered view, TfL’s proposals for the ORN and PRN involve such draconian restrictions and feeble mitigation that they will result in chronic congestion and inconvenience for Londoners and breaches of air quality laws along the lines predicted by the SEA or worse.

Mitigation measures

The more one looks as the proposals, the clearer it becomes that: attempts to persuade people not to drive or work in London for weeks on end during 2012 are doomed to failure or limited success at best.    The  current  proposals  would  disadvantage  everyone  (except  those  using  official  Games vehicles).

With such major changes proposed for the Olympic and Paralympic Games, there is a duty on the organisers to mitigate in full the environmental and other impacts of such arrangements.  The current efforts to mitigate the impact of the ORN and PRN are feeble.  For example:

Businesses race to get 2012 travel plans in place (26 July)

http://www.tfl.gov.uk/corporate/media/newscentre/archive/20606.aspx

Businesses kept on track with free London 2012 support package (26 August)

http://www.tfl.gov.uk/corporate/media/newscentre/archive/20835.aspx

‘Plan for Paralympics too’ businesses urged (5 September)

http://www.tfl.gov.uk/corporate/media/newscentre/archive/20900.aspx

Mayor announces Olympic Park electric charging network, creating air quality legacy (8

September)

http://www.tfl.gov.uk/static/corporate/media/newscentre/archive/20956.html

It would be much fairer and consistent with the ‘polluter pays’ policy to ban the oldest diesel vehicles from the most polluted parts of inner London during the period of the Queen’s Diamond Jubilee, the Olympic Games and the Paralympic Games.  CAL does not mean Phases 3 and 4 of the London-wide low emission zone which form the base line for 2012.

CAL proposes that the Mayor should adopt a Berlin-style low emission zone for inner London during the  100  days  in  2012  covered  by  the  Queen’s  Diamond  Jubilee,  the  Olympic  Games  and  the Paralympic Games.  This would ban from 7 May to 30 September 2012 all pre-Euro 4 diesel vehicles with the exception of licenced black taxis dropping off fare paying passengers (but not picking them up) and vulnerable groups.  The scheme would continue in Central London after these events.

Based on TfL estimates (provided to CAL in response to a Freedom of Information request) this might affect up to 30% of diesel cars; 55% of LGVs and minibuses; 45% of coaches; 40% of rigid HGVs; and 30% of articulated HGVs.  Surely a planned measure like this would be better than a last minute, chaotic odd and even number plate ban affecting all vehicles?  It would reduce congestion and air pollution.

Such an approach would for example:

i.            reduce the most harmful emissions in the most polluted areas;

ii.            reduce substantially congestion for ordinary people and business vehicles along the ORN and PRN and wishing to cross them e.g. for local access;

iii.            allow more time for pedestrians to cross the ORN and PRN;

iv.            shorten TfL bus journey times (e.g. along routes where bus lanes are suspended) and therefore allow taxis to be given access to streets currently reserved for official Olympic vehicles, TfL buses and cycles e.g. the Strand eastbound; and

v.            provide a margin of safety where TfL has failed to understand the complexity of local traffic movements e.g. rat-running through residential streets to and/or from the ORN and PRN.

The above proposal could also: achieve the desired 30% reduction in ‘background’ or non-Games traffic necessary to ensure the smooth operation of the ORN and PRN; contribute materially to the avoidance of chaos in London in 2012; support the image of the ‘greenest Games ever’; and deliver tangible public health benefits.

It would also showcase for 100 days or so in 2012 the London we would see in Central London from late 2012 and more significantly across the city in 2015 and thereafter.

Conclusion

On the basis of the information provided, incomplete though it is:

  1. CAL does not think the consultation has been adequate because insufficient information was provided in the consultation documents;
  2. earlier modelling for the ODA suggested that the operation of the ORN and PRN would lead to an unlawful increase in air pollution, inconsistent with European Union (EU) law;
  3. it seems even more likely, having seen now the detail of TfL’s draconian proposals and feeble mitigation, that the ORN and the PRN would cause the aggravated breach of one or more limit values for dangerous airborne particles (PM10) and nitrogen dioxide (NO2) (e.g. the NO2  annual mean and NO2 hourly limit values in areas where they have been attained in 2011);
  4. it seems even more likely, having seen now the detail of TfL’s draconian proposals and feeble mitigation, that the ORN and the PRN would result in an increase in harmful concentrations in ambient air; and
  5. there has been no, or no adequate, consideration of the impact of the proposals on particularly vulnerable groups or minority ethnic groups.

For the reasons outlined above this would be unlawful and vulnerable to legal challenge through judicial review.

CAL therefore concludes that the ODA, TfL and the Mayor of London should reject the proposals for the ORN and PRN.  There should be no further outcome without further information and modelling, all of which should be subject to further consultation.

Please contact me if you have any questions or would like more information on any of the points raised in this letter.   I  have  copied  this  response to  interested  parties  including  Count  Jacques Rogge and Shaun McCarthy.

With best wishes.
Yours sincerely

 

Simon Birkett
Founder and Director
Clean Air in London

 

Cc:

 

The Rt. Hon. David Cameron MP, The Prime Minister
Count Jacques Rogge, President of the International Olympic Committee
The Rt. Hon. Philip Hammond, Secretary of State for Transport
The Rt. Hon. Caroline Spelman, Secretary of State for Environment Food and Rural Affairs
Janez Potočnik, Commissioner for the Environment, European Commission
Huw Edwards, Olympic Delivery Authority
Shaun McCarthy, Chair, Commission for Sustainable London 2012
Peter Hendy, Transport for London
Tony West, Director of TfL and Chair, Health and Safety Committee
The Lord Berkeley, House of Lords
Mark Field MP Karen Buck MP All London MPs
Jenny Jones AM, Green Party candidate for Mayor of London
Ken Livingstone, Labour Party candidate for Mayor of London
Brian Paddick, Liberal Democrat party candidate for Mayor of London
James Cleverly AM, Conservative
Darren Johnson AM, Green, Chair, London Assembly Environment Committee
Murad Qureshi AM, Labour, Deputy Chair, London Assembly Environment Committee
Mike Tuffrey AM, Liberal Democrat
Adrian Young, Environment Agency