Lewisham Council have at last issued a public consultation you can respond to on the Lewisham/Lee Green Low Traffic Neighbourhood (LTN). That’s after multiple road closures have been in place for a year with no prior public consultation.

Lewisham residents and anyone else affected by the closures should make sure they respond to the consultation here: https://lewisham.gov.uk/ltnconsultation

Here are some comments on the questions posed and the information provided in support:

• They repeat the false allegation that the measures were necessary to ensure social distancing during the Covid epidemic. The Lee Green LTN was planned long before the epidemic arose and forcing people to walk or cycle could not help.

• They allege they had to act quickly and without prior public consultation because of “timescales and expectations set by central government” but this is untrue. They used this excuse and the funding available to rush in measures without due consideration or public consent. In effect, they defeated democratic input.

• Because of the rushed implementation there were inadequate measurements of traffic flows and air pollution and there still is.

• They provide tables of traffic volumes on roads within the LTN before the original LTN scheme was put in, afterwards, and after subsequent changes in November 2020. Needless to say that traffic volumes on closed roads such as Upwood Road fell dramatically. Overall volumes within the LTN fell substantially as one might expect but a few roads showed increases, such as Courthill Road. But for some of the period when measurements were taken the country was in lock-down with traffic much reduced as many people worked from home and others avoided going out altogether. The Council does acknowledge the limitations of traffic counts in the circumstances.

• No measurements of traffic volume on the main roads which will have been used as alternative routes by drivers are supplied – such as on Burnt Ash Road, Lee High Road, Lee Road and the South Circular. But traffic counts are only viable when there is free-flowing traffic, not when it is stationary.

• Bus journey times which can give a good indication of traffic speeds seem to be affected both negatively and positively depending on the route.

• The report discounts the impact on emergency services despite the numerous negative reports we have received. The change from physical road closures to camera enforced closures may have alleviated the problems on roads such as Manor Park Road.

• They report on average traffic speeds as there is a claim that an LTN will improve road safety, but it is clear that traffic speeds within the LTN were low beforehand. Few roads exceed 20 mph and the reduction after the LTN was implemented is only 2 mph in the first table or 1.2 mph in the second table which nobody would have noticed. These changes will have no significant impact on road casualties and the small changes in average speed could be due to other causes.

• As regards air pollution, based on NO2 measurements they claim that “the schemes have had little to no impact on air quality in and around the area”. They have not provided data on particulates which are probably more significant in terms of health impacts. They have ignored the numerous reports we have received about increases of air pollution on the surrounding main roads impacted by diverting traffic, and where stationery queues of vehicles are now common.

• Note that we recently submitted a request under the Environmental Information Regulations to obtain more data on air pollution in Lewisham. The reports they have previously published are now out of date and a new report is being held up for review and approval by the GLA and DEFRA. The council does not seem to have taken steps to monitor air pollution on the roads affected by increased traffic other than on the South Circular and data even from that is not yet available.

• The Council claims they “have engaged with a wide range of groups….” but they have not engaged with us and Councillor McGeevor has rejected our suggestion for a meeting.

• As regards the questions the Council poses in the consultation, these are quite bland and fail to ask the simple question as to whether people support the LTN or not.  But I have seen more biased consultation documents in the past.

Please make sure you give the Council your comments by responding to the consultation here:  https://lewisham.gov.uk/ltnconsultation

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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