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Sunday, 18 May 2025

Why Public Feedback Should Shape Transport Policy: Consultation and Decision-Making in Transport for London's Bus Service Changes

Route 205 leaflet from 2002 - © TfL

Transport for London’s (TfL) consultation report on the proposed changes to bus routes 30 and 205 included a reference to one of my tweets, which I appreciated. As some of my followers on X (formerly known as Twitter), Mastodon, and Bluesky may have seen, I’ve been sharing excerpts from the report.
The consultation, which included an Equality Impact Assessment (EqIA) to assess implications for protected groups, revealed strong public opposition. Concerns focused on the loss of direct bus connections and the increased need for interchanges. Additionally, the changes to Route 205, in particular, raised alarm for many as this route is a step-free accessible alternative to the Circle and Hammersmith & City Underground lines, providing a critical service to passengers who rely on step-free access. This is especially significant because many Underground stations do not have step-free access, creating challenges for disabled or older passengers who depend on accessible transport options. The loss of such a service could disproportionately affect vulnerable groups, reducing accessibility to key parts of the city.

Despite these objections from both the public and key stakeholders (including organisations, Assembly Members, and local councils), TfL has confirmed that it will proceed with the proposed changes, with implementation scheduled for June 2025. This decision, made despite clear opposition outlined in the May 2025 consultation report, underscores the tension between public consultation and the final decision-making powers vested in TfL. It is important to consider that while public feedback is part of the process, the final decision rests with TfL, often reflecting the broader strategic objectives of the Mayor’s transport policies.

When making changes to bus services, such as altering routes, adjusting frequencies, or withdrawing services, TfL must comply with legal obligations under the Greater London Authority (GLA) Act 1999. Section 183 of the Act requires TfL to consult with key stakeholders, including the police, London borough councils, and London TravelWatch (Officially known as the London Transport Users’ Committee), to ensure any proposed changes align with the Mayor’s transport strategy.

More specifically, Part IV, Chapter V of the GLA Act 1999 sets out the legal framework for regulating bus services in Greater London. It gives TfL responsibility for how bus services operate in the capital, including awarding service contracts, setting routes and fares, and ensuring services meet the needs of the travelling public. TfL must also aim to provide safe, integrated, and efficient transport services across London, under the strategic direction of the Mayor.

It is important to note that transport is officially recognised as part of the UK's Critical National Infrastructure (CNI), as defined by the National Protective Security Authority (NPSA). This designation highlights the essential role of transport in maintaining the country’s economic stability, public safety, and national resilience. Changes to transport services, therefore, must be approached with careful consideration of not just convenience and cost, but also wider impacts on accessibility, security, and social equity.

TfL is also subject to the public sector equality duty under the Equality Act 2010. This requires it to consider how service changes may affect individuals with protected characteristics, such as disabled or older passengers. All London buses are wheelchair accessible, and TfL provides staff training to promote equality and prevent discrimination. These legal duties are intended to ensure that transport policy is inclusive, transparent, and responsive to the needs of all Londoners.

The Greater London Authority, led by the Mayor of London, operates within a structured decision-making framework that defines who is responsible for different types of decisions. Some decisions are legally reserved for the Mayor, while others may be delegated to senior officers as a matter of policy. This framework was updated in June 2024, including changes to the financial thresholds requiring Mayoral approval and the review mechanisms for decision-making. The London Assembly plays a key role in scrutinising the Mayor’s decisions and holding them to account. Full details of the GLA’s governance arrangements are available on its website.

As a functional body of the GLA, TfL operates under the Mayor’s strategic direction and financial oversight. When proposing changes to services, such as in the recent consultation on routes 30 and 205, TfL carries out public consultations to gather feedback. While this input is considered, the final decision ultimately rests with TfL, acting within the framework of the Mayor’s wider transport strategy. In this case, despite the public opposition and concerns about the loss of step-free access on Route 205, TfL has opted to proceed.

Given that TfL is accountable to both the Mayor and the London Assembly, I believe decisions of this nature (including bus service changes) should be made at a more democratic level, involving both the Mayor and the Assembly directly.

Of course, the Mayor of London holds the statutory authority to make major decisions for the capital, as set out in the Greater London Authority Act 1999. This legislation gives the Mayor wide-ranging powers, including setting strategic direction across key policy areas such as transport, housing, and the environment, overseeing the GLA’s budget, and appointing key officials within the Authority and its functional bodies. While public consultation and stakeholder engagement are important, legal responsibility and final decision-making power rest with the Mayor, within the framework defined by the Act.
Walthamstow Bus Service Changes

TfL conducted a public consultation between 19 June and 30 July 2023 regarding proposed changes to bus routes W12, W13, W14 and 549 in the Walthamstow, Wanstead and Woodford areas. The consultation sought feedback on plans to restructure these routes, with the stated aim of improving connectivity (particularly to Whipps Cross Hospital) and simplifying the local bus network. Despite receiving 863 responses, TfL published a consultation report in January 2024 and decided to proceed with implementing the original proposals in September 2024.

#TfL Consultation report for #Walthamstow, #Wanstead, #Woodford – proposed changes to #London bus routes W12, W13, W14 and 549 haveyoursay.tfl.gov.uk/bus-routes-w...

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— CLondoner92 (@clondoner92.bsky.social) January 16, 2024 at 5:47 PM

The documentary by Riku Fryderyk highlights the impact of these changes on local residents, particularly vulnerable groups, and raises concerns about the adequacy of TfL’s consultation and engagement processes.

UK politicians often stress that consultations are not referendums. Rather, they are a means of gathering public views to inform decisions, without being binding.

I’m not an expert in law or legal affairs, but organisations, activists and affected individuals could potentially take legal action against TfL (or other transport authorities such as Transport for Greater Manchester (TfGM)) if they believe these bodies have breached the Equality Act 2010, including the public sector equality duty (PSED). Under the Act, public authorities must have “due regard” to eliminating discrimination, advancing equality of opportunity, and fostering good relations for people with protected characteristics when making decisions or setting policies, such as changes to bus services.

If TfL or similar bodies fail to properly consider these duties (often demonstrated through inadequate Equality Impact Assessments, or by ignoring evidence of disproportionate adverse effects), legal challenges can be brought to hold them accountable. Such claims typically focus on whether the public authority consciously considered its equality obligations and took reasonable steps to prevent discrimination or disadvantage.

The Campaign for Better Transport’s 2011 report highlights that local authorities across England must carry out EqIAs before deciding on bus service cuts, as required by the Equality Act 2010 and the public sector equality duty. For example, in the case of R (Meany) v Harlow District Council, the court ruled that the council acted unlawfully by failing to conduct a proper equalities impact assessment before making significant cuts to a welfare service, demonstrating the legal necessity of assessing impacts early in the decision-making process. Similarly, the Cambridgeshire case showed that cutting the entire bus subsidy budget without considering which routes or vulnerable groups would be affected was insufficient and unlawful, as the council did not properly assess or consult on the impacts before the decision.

The report stresses that consultations must occur at a formative stage, provide clear information about proposals, allow adequate time for responses, and genuinely consider consultation feedback. If bus cuts alter a Local Transport Plan, formal consultation is legally required; even if not, fair consultation is expected to enable affected communities to have their say. In Cambridgeshire, the council’s consultation after the decision to cut subsidies was deemed too late and ineffective, forcing them to restart the process. While unlawful decisions do not always prevent cuts, they require authorities to reconsider and follow proper legal procedures.

These principles apply broadly to transport authorities including TfL, TfGM, and others, ensuring that equality duties and fair consultation processes are upheld when making changes to bus services. Failure to comply can lead to legal challenges supported by campaign groups like the Campaign for Better Transport.

Expanding Beyond London: Local Authorities' Role in Bus Service Changes

My idea also extends to local authorities outside of London, where decisions on bus service changes, including those involving enhanced partnerships, franchising, and the operation of municipal bus companies (owned by local government authorities), should also consider equality and accessibility in their decision-making processes. For instance, municipalities with partially or wholly-owned bus operators, like Nottingham City Transport, where 18% of the company is owned by Transdev, should follow similar procedures to ensure that any changes to services meet the needs of local communities, especially vulnerable groups. The involvement of local authorities in bus operations, such as through joint ownership or municipal models, means that councils have a direct influence on how services are run, and therefore should be held accountable for ensuring that equality duties are met and that public consultations are carried out fairly.

Local authorities outside London, including those governed by Metro Mayors, must also consider these same principles in their service planning, ensuring that proposals for bus service changes, such as cuts or restructuring, involve meaningful consultation, take into account the equality impact, and promote accessibility. Metro Mayors, like the Mayor of Greater Manchester or the Mayor of the West Midlands, have significant powers over local transport networks, and it is essential they adhere to the same legal and ethical standards as TfL. If these processes are not followed properly, affected communities and stakeholders should have the right to challenge the decisions in the same way as with TfL, as part of a broader, nationwide approach to accountable and inclusive transport policy.

My ideas may require changes to legislation in Parliament.

I would like to extend an invite for you to follow me on X (formerly Twitter) for transport-related updates. You can find me by searching for @CLondoner92 or by clicking on the direct link to my X page here. I am also present on BlueSky and Mastodon. I look forward to connecting with you on these platforms. Thank you for your support.

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