Air Quality in Lewisham

One of the big topical issues in London is air quality, particularly as there is an allegation that the Low Traffic Neighbourhoods (LTNs) that have been introduced have made air pollution worse.

One of the justifications for introducing LTNs including road closures in boroughs such as Lewisham was the need to improve air quality. However it is alleged that the diversion of traffic onto main roads has actually made matters worse in some locations.

Lewisham has now published a Draft Air Quality Action Plan which is now open to public consultation (see link below). It gives some more data on the air pollution issue and what the council plans to do on this subject in 2022-2027. It’s well worth reading and commenting on by Lewisham residents and is probably typical of many other London boroughs.

Some comments before you respond to the consultation: This report and the associated consultation contain a mass of data and a few recommendations, but the information is hardly presented in a clear way. It is hardly the kind of document that an uninformed general member of the public will find digestible. I will try to pick out some of the salient points.

Firstly is there an air quality problem in Lewisham that is affecting the health of the general population? That’s opposed to those such as Ella Kissi-Debrah who was the subject of a recent inquest (i.e. the particularly vulnerable or suffering from other medical conditions), or children.

The report says: “An assessment of air quality in Lewisham has shown a decreasing trend in the levels of two pollutants, nitrogen dioxide (NO²)) and particulate matter (PM) in recent years. However more needs to be done to meet the guidelines set out by the World Health Organisation”. The report repeatedly refers to WHO guidelines which are not the legal limits set by EU and UK regulations (see link below). The WHO limits are much lower and are not necessarily those justifiable by scientific data on health impacts.

The report emphasises the health effects of exposure to nitrous oxides (NO2) despite the fact that there is no clear consensus on the long-term impacts of NO2 – see the latest COMEAP report from the Government Committee on the Medical Effects of Air Pollution (see link below). However it does say that “On average, annual mean NO2 concentrations at both roadside and urban background monitoring locations have decreased between 2014 and 2020 by an average of 42% and 37% respectively”. You can see the trend in NO2 emissions in Lewisham in the chart above.

Particulates (PM2.5 and PM10, particularly the former) are probably more of concern although here again Lewisham is within UK legal limits where the air quality is measured. Similarly here also the trend has been falling. It is difficult to see from the report that air quality is a substantial problem in Lewisham so far as health impacts are concerned. The data is not there to show that.

The air quality has clearly been improving in the last few years, but this is not obviously down to any actions by the local council but from changes to the vehicle fleet, central government regulations, improved heating systems, etc.

However the Council has clearly taken up the public clamour by attempts to reduce car use, making walking and cycling the preferred choice of travel, reducing children’s exposure by such measures as School Streets, and of course the LTNs.

Page 3 of the council’s report attempts to provide further justification by mixing up air quality and the council’s response to the alleged “climate emergency” as if improving NO2 or PM will have any impact on climate, when the latter is allegedly more related to CO2 emissions. There is no such link.

The council is adopting targets to reduce PM2.5 despite the fact that much of those pollutants come from outside the borough – indeed outside of London, even outside of the UK altogether, over which the council has no control.

The council’s proposals for action include an expansion in monitoring activities (more diffusion tubes to monitor NO2 and new PM2.5 monitors) and raising public awareness by more social media activity. They also propose:

  1. Reducing pollution in and around schools and extending school audits to other schools in polluted areas.
  2. Enforcing the Non-Road Mobile Machinery (NRMM) Low Emission Zone.
  3. Promoting and enforcing Smoke Control Zones.
  4. Promoting and delivering energy efficiency retrofitting projects in workplaces and homes.
  5. Installing Ultra-Low Emission Vehicle (ULEV) infrastructure.  
  6. Improving walking and cycling infrastructure
  7. Regular Car Free days/temporary road closures in high footfall areas.
  8. Reducing emissions from Council fleets.

Some of these measures may be beneficial but how much so is unclear.

In summary this report from Lewisham Council is a typical one. Policies are proposed with no clear cost/benefit justification and no obvious measures of success. Just as with the Lee Green LTN, there is no clear outcome that will indicate whether the scheme is a success and justify the expenditure on implementation.

Neither will it satisfy Lewisham residents who are being affected by worse air pollution because there are no specific actions proposed to tackle their complaints (for example air pollution near the South Circular).

Even the proposed actions are unspecific and the on-line consultation form asks wishy-washy questions rather than specific ones. Do Lewisham residents, or their visitors, actually support “car-free” days for example?

But residents should certainly respond to the consultation.

UK and EU Air Quality Limits: https://uk-air.defra.gov.uk/air-pollution/uk-eu-limits

COMEAP https://www.gov.uk/government/groups/committee-on-the-medical-effects-of-air-pollutants-comeap

Air Quality and Vehicles: FFDF Report: https://www.freedomfordrivers.org/Air-Quality-and-Vehicles-The-Truth.pdf

Lewisham Air Quality Consultation: https://lewisham.gov.uk/airqualityconsultation

Roger Lawson

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New TfL Consultation Hub

Transport for London (TfL) have launched a new “Consultation Hub” where you can give feedback on new projects in London – see https://haveyoursay.tfl.gov.uk/ . You can also register to receive notifications of new consultation events.

This is not just about consulting on future projects but also submitting comments on live ones – such as the trial of E-Scooters that is currently running.

The new consultation “hub” will replace the existing consultation web site (see https://consultations.tfl.gov.uk/ ) which contains consultations on Streetspace schemes, bus lanes and other matters at present.

Is this a big improvement or is there any reason for the change? It’s not obvious how this change will help and moving and renaming a web site is never a good idea.

Readers are advised to register with the new site so as to be sure of being informed on new consultations.

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Albemarle Road, Beckenham Public Consultation

One of the few road traffic schemes in the London Borough of Bromley prompted by the Covid-19 epidemic and financed by funding like other schemes to encourage cycling was that in Albemarle Road, Beckenham. This road is a major route between Beckenham Junction and Bromley Town Centre via Shortlands.  It worked perfectly well but the introduction of a one-way system, with a cycle lane and other changes has created more traffic congestion. For our previous comments on this scheme, see https://freedomfordrivers.blog/2020/11/23/covid-19-induced-madness-comes-to-bromley-in-albemarle-road/

A petition against the “temporary” scheme has collected almost 2,500 signatures on change.org and many residents of Albemarle Road and surrounding roads have objected.

Now Bromley Council have launched a public consultation on the scheme. They give a couple of options, one of which is to remove the scheme completely. But it might make sense to retain traffic lights on Westgate Road bridge to avoid vehicle conflicts.

But please give your own views by responding to the consultation here: https://www.bromley.gov.uk/info/545/traffic_management/1510/traffic_management_on_albemarle_road_and_westgate_road_bridge_-_consultation

They want answers by the 3rd of March which may be rather soon. Traffic has not returned to normal levels because of the lock-downs and recent poor weather. But it certainly does not appear to have encouraged more cycling on this route.   

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London Opposition to LTNs, Lewisham Council Meeting, Commonplace and Ealing Opposed to LTNs

There are now multiple campaigns all over London opposing Low Traffic Neighbourhoods (LTNs). See this web page for a list of some of them (if you know of more please let me know so we can add to the list): https://www.freedomfordrivers.org/london-road-closures.htm . They show how anger is growing against the road closures which have been counterproductive in so many ways.

Lewisham Council Meeting

There was a meeting of Lewisham Council’s Overview and Business Scrutiny Panel on the 24th November. They finally got around to discussing the Report on the “Temporary measures to support safer talking and cycling in response to the Covid 19 pandemic”, i.e. the report on the Low Traffic Neighbourhood (LTN) introduced in Lee Green and Lewisham. But it is of course a misnomer as this was a scheme planned well before the epidemic hit and it has nothing to do with the epidemic at all.

You can actually watch a recording of the meeting (see Ref. 1 below) but you would not find it particularly revealing (Item 4 is about 58 minutes in).

The Chairman and other speakers blamed the Government for the timescale imposed to implement the measures which meant there was no time for public consultation. But it is important to note that the Council did not have to take the money or implement the schemes as they have done! It was their choice to do so.

It is clear the Council hopes that the traffic will “evaporate” over time as people get used to the road closures but that is surely a vain hope (note that traffic congestion has certainly reduced in recent weeks but that is because of the lock-down restrictions recently in place with shopping, eating out and visiting friends severely restricted).

There were however some concerns expressed about the use of the Commonplace system as a consultation method, which I cover below in more detail.

Reference 1: Council Overview and Scrutiny Panel Meeting: https://councilmeetings.lewisham.gov.uk/ieListDocuments.aspx?CId=121&MId=6060&Ver=4

Commonplace System

The Commonplace system is used by a number of Councils and other organisations as a consultation mechanism, or a “community engagement platform” as they call it. It is a commercial operation which sells its services to councils (see https://www.commonplace.is/ ) and is funded by venture capital.

One of the first London Councils to use it was Waltham Forest and Lewisham have used it more recently to cover their Lee Green LTN scheme (see https://walthamforest.commonplace.is/ and https://lewishamcovidresidentialstreets.commonplace.is/ ).

The system is not an unbiased platform in that typically it is used to promote what a Council is planning to do – and more recently that means after decisions have already been made to implement schemes.

It also has the problem that unlike a conventional public consultation only people who are internet enabled, and are even aware of the platform, can respond. This excludes a large number of people such as the elderly who are not internet connected or don’t spend much time on it. So it tends to be dominated by young activists and those active in local politics, i.e. the comments on it are unrepresentative of the wider population.

How unrepresentative is it? It’s impossible to say because little information is collected on the profile of those who add comments and not even names are shown on the published comments, i.e. people can comment anonymously which is never a good idea.

But it is very clear if you look at the comments published on Lewisham’s LTN that many comments are repetitive and the same comments are made on multiple roads. There seems to be no attempt to stop duplicate comments so the system can be exploited by organised activist groups such as cyclists.

There is no way that Lewisham Council can get a balanced view of the comments received or any statistically useful information. They can pick comments out to justify any stance they wish to take.

Wildly inaccurate comments can also be made on the platform with no “rebuttal” possible – you can only “Agree” with comments, not “Disagree” with them and you cannot comment further in response. Clearly there are many people commenting who are not directly affected, and those that are affected just give very polarised comments. The comments are not helpful in determining a sensible compromise to meet the needs of the majority.

In summary, Commonplace is a system that can be used by Councils to claim they are “listening” to residents when in reality it is not a fair and honest way to collect the views of all residents. It is not an alternative to a proper public consultation and is more designed to promote the views of scheme promoters than collect unbiased information.

DO NOT ACCEPT COMMONPLACE AS AN ALTERNATIVE TO PROPER PUBLIC CONSULTATIONS!

Surveys Give the Truth – Ealing Opposes LTNs

Surveys of residents are more likely to give an unbiased and honest view of LTN schemes. Those undertaken by the LibDems and by us in Lewisham show a very large percentage opposed to road closures. The latest such survey is one done by the Conservative Party in Ealing – see https://www.ealingconservatives.org.uk/news/LTNSurveyResults . As their headline says: “95% of people living in Ealing’s LTN zones want them removed”. The Ealing Commonplace site just shows again how the platform just provides a way for extremists of all kinds to vent their anger rather than provide constructive criticism.

Funds for Legal Action

It is clear that Councils such as Ealing and Lewisham are going to persist with schemes that are opposed by the majority of local residents. As it will be two years before local councillors come up for re-election, and they are unlikely to change their minds in the meantime, the only short-term way to stop the proliferation of road closures under the name of “Low Traffic Neighbourhoods” is to mount a legal challenge.

We believe there are good grounds for a legal challenge to these measures and have looked at the legal issues in some detail and have taken legal advice already. But we do need to raise substantial funds to launch a challenge (thanks to those who have already donated but we need many more people to do so).

PLEASE SUPPORT OUR CAMPAIGN AGAINST ROAD CLOSURES BY GOING HERE TO DONATE: https://www.freedomfordrivers.org/legal-fund.htm

Croydon Streetspace Consultation

The London Borough of Croydon has launched a public consultation on their “Streetspace” proposals. Namely the road closures that have hit residents in the Crystal Palace and South Norwood areas under the guise of a “Low Traffic Neighbourhood” when it has been anything but that. Traffic congestion has been horrendous and has even impacted roads in the adjacent borough of Bromley.

They are also consulting on Low Traffic Neighbourhood schemes in Broad Green and Albert Road with the former including a permit scheme for residents. There are also proposals for the Town Centre.

See https://new.croydon.gov.uk/croydon-streetspace for details – see bottom right for an open on-line consultation on the Crystal Palace and South Norwood scheme. This is the opportunity to have your say so please complete it!

These measures are claimed to be temporary but if the Council gets enough support they will undoubtedly make them permanent in due course. There is an active campaign against the closures under the name “Open Our Roads” who have already filed for a judicial review of the Council’s actions.

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More Road Closures in London

I mentioned in previous blog posts the road closures in Lewisham and Hackney using the Covid-19 epidemic as an excuse. There are also road closures being installed in:

Tower Hamlets. This borough proposes to close numerous roads. See this Traffic Order for details of some of them and where to send your objections: https://www.thegazette.co.uk/notice/3571436

Waltham Forest: This borough proposed a number of “Mini-Holland” schemes that involved road closures before the epidemic hit. Some have been delayed or cut back due to financial limitations, but there are still promoting walking and cycling via “low traffic streets” in the Coppermill and Hilltop areas. See https://enjoywalthamforest.co.uk/enjoy-waltham-forest/walking-and-cycling/ . As in Lewisham, they are using a CommonPlace web site as a consultation method but in this case there is no detailed information yet available. In this and many other London boroughs, there is minimal information on the plans that have been made public and decisions are effectively being taken in secret. Searching the Council’s web site for details of Committee Meetings and Decisions reveals no information. This is a good example of a “bad” borough in terms of democracy.

City of London: The City of London Corporation have issued a note that says the following:

What are the changes? On-street measures will include: Timed closures to motor vehicles, mostly 7am – 7pm, allowing limited access to premises for people with access needs, deliveries and servicing; Reallocation of carriageway to space for walking, queueing and cycling and priority for buses; Closing streets to through traffic or other changes in operation, e.g. switching to one-way.

Where will the changes be? Change is required across the Square Mile and will be delivered in phases. The following streets have been selected for Phase 1 based on pedestrian numbers, pavement widths, cycling demand and connections to destinations, retail and transport hubs: Cannon Street (between Queen Victoria Street and Monument junction); Cheapside and Poultry; Old Jewry and Coleman Street; Lombard Street; Leadenhall Street and St Mary Axe; Threadneedle Street and Old Broad Street.

There are a lot of pedestrians that cross Cannon Street from Cannon Street Station but closing the road when the Bank Junction is already closed is going to be very damaging to traffic flows.

All of these measures are claimed to be justified by the Covid-19 epidemic but they are unlikely to be temporary and are just a continuation of the City Corporation’s attack on all vehicle users. That includes the disabled or infirm to whom few concessions are made.

MAKE SURE YOU OBJECT AND STOP THE CLOSURES SPREADING!

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Lewisham Road Closure News

Scawen Road

What’s happening you may ask about the proposed road closures in Lewisham? These were originally proposed for Lee Green and other parts of the Borough under the Healthy Neighbourhood scheme, but are now being put forward as Covid-19 epidemic emergency responses. At least that seems to be the justification as it is proving impossible to obtain any information on them from the Council. I suspect this is a deliberate obstruction of local democracy but I am submitting a Freedom of Information Act request to obtain more information.

In the meantime, Councillor Sophie McGeevor has issued the following Tweet: “As part of our emergency roll out of measures to support walking and cycling in Lewisham 6 modal filters (of an initial phase of 30) are being implemented next week!”

The roads involved are: Scawen Road (see photo above), George Lane, Kitto Road, Glenbow Rd, South Row, Bishopsthorpe Rd and Silverdale. These are spread around the borough so why they have been selected is not obvious.

You can see more information and add some comments here:  https://lewishamcovidresidentialstreets.commonplace.is/overview

PLEASE MAKE SURE YOU ADD SOME NEGATIVE COMMENTS AND “LIKE” THOSE WHO OPPOSE THESE CLOSURES!

You could also send comments to Sophie McGeevor who is responsible for these plans – her email address is CllrSophie.McGeevor@lewisham.gov.uk

If you don’t object, these closures are likely to be made permanent! The closures are likely to be implemented via Experimental Traffic Orders but these do not yet appear to have been published. It is important to oppose them when published. You should be able to find them in The Gazette (see https://www.thegazette.co.uk/  ) where all official notices appear. To search for notices from any London Borough use the search function to search for the boroughs name, e.g. “London Borough of Lewisham”).

We suggest that roads should not be closed without prior public consultations that include both local residents and road users. Such road closures do not help with social distancing so there is no justification for them as “emergency” measures. They create more traffic congestion and longer journey times. All roads should be shared by different users, not closed to vehicle traffic.

These roads are being closed using “Modal Filters” which is simply a euphemism and a deliberate misleading of the public. Only cyclists can easily get through such closures, and they will even obstruct emergency service vehicles.

MAKE SURE YOU OBJECT AND STOP THE CLOSURES SPREADING!

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More Taxes on Car Drivers, and Londoners in General

I covered the TfL bail-out deal that Sadiq Khan agreed with the Government in a previous blog post. As usual the Mayor blames the Government. So he says today: “The Government is, in effect, making ordinary Londoners pay the cost for doing the right thing on Covid-19”. He also said: “This deal is a sticking plaster. The old model for funding public transport in London simply does not work in this new reality – fares income will not cover the cost of running services while so few people can safely use public transport. Over the next few months we will have to negotiate a new funding model with Government – which will involve either permanent funding from Government or giving London more control over key taxes so we can pay for it ourselves – or a combination of both”. Yes it looks like the Mayor wants to take more from you in taxes!

See the link to the full announcement below.

To help raise more revenue, the Congestion Charge and ULEZ taxes are being immediately reinstated and the Congestion Charge is to go up a whopping 30% from the 22nd June and the times will be extended to between 07:00 and 22:00, seven days a week. It is suggested this might be a temporary change, but don’t bet on it!

In addition there will be road closures and Heidi Alexander has said “One of the world’s largest car free zones will be created in central London as part of our response to Covid-19”.

This is what Black-cab driver and general secretary of the London Taxi Drivers’ Association (LTDA) Steve McNamara said to the BBC: “ It’s an absolute disgrace –  no one had been consulted about plans to change the use of some roads. Usually you have to consult with the public and businesses – they are using a health emergency to get around the laws to consult people before you do these things. London will grind to a halt even with reduced people. It’s a land grab to exclude Londoners from their roads and to widen pavements for more cycling”.

We certainly agree with those comments and we have pointed out that the Covid-19 epidemic is being used to introduce an agenda that penalises private travel and reduces your freedom.

But it’s not just vehicle users who are going to be penalised. The BBC has said this about the Freedom Pass: “Under the new conditions, children will no longer have free travel across London and restrictions on travel passes for people with a disability or over the age of 60 will also be imposed during peak hours”, although no formal announcement has yet to be made. The Freedom Pass might have been overdue for reform but the Mayor will no doubt blame this on the Government also rather than his own financial mismanagement.

Roger Lawson

Mayor’s Announcement: https://www.london.gov.uk/press-releases/mayoral/statement-from-the-mayor-of-london-regarding-tfl

You can see more details of the proposals from TfL to change London here:  https://tfl.gov.uk/travel-information/improvements-and-projects/streetspace-for-london

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Greenwich to Woolwich Road Degradation

Transport for London (TfL) have announced proposals for changes to the A206 between Greenwich and Woolwich that will lead to slower traffic, cause more traffic congestion and raise air pollution. The A206 is the main road between Woolwich and Greenwich. The proposals, which are open to public consultation include these proposals:

  • A new two-way Cycleway which will take up some of the existing road space and run along the south side of the road and remove one of two traffic lanes.
  • Six new pedestrian crossings.
  • Extending the existing bus lanes and new ones to effectively turn a two-lane road into one for all other traffic effective from 7.00 in the morning to 19.00 in the evening (7 to 7).
  • Widening the footway at a number of locations.
  • Closure of Charlton Lane.
  • Speed tables to slow traffic on the A206.
  • Changing the Angerstein Roundabout (the one under the A102 Blackwall Tunnel Approach) to improve safety – see photo below. That includes removing the central “roundabout” and banning turns onto the A102 so as “to reduce traffic volumes”. There have been two fatal accidents there in the last two years.

The ABD’s comments which we have submitted to the consultation are:

  1. There are certainly some parts of this road that could be improved for pedestrians and cyclists and the addition of a few pedestrian crossings may be justified. However, pedestrian crossings should be justified based on the number of pedestrians crossing the road at the given point, the difficulty of doing so and the volume of traffic.
  2. The Angerstein Roundabout is certainly a poor design at present as it is even difficult for vehicles to navigate if the driver is unfamiliar with the layout and HGVs are involved. Changing it to remove the roundabout and simply making it a signalised junction does make sense. However we object to the removal of turns onto the A102 as it is not clear what the alternative routes might be for larger vehicles and it might encourage the use of narrow side streets by other vehicles.
  3. We object to the use of speed tables, or any other form of speed humps, particularly on major roads such as the A206 and those used by buses. They generate severe discomfort for vehicle users and for bus passengers.
  4. We doubt the claim that these changes will not cause significant traffic delays, and particularly object to the prioritisation of the needs of cyclists (who only make up 5% of the road users according to TfL) over other road users.

You can read more details of the proposals and respond to an on-line consultation from this web page: https://consultations.tfl.gov.uk/cycling/greenwich-to-woolwich/

Make sure you object!

Note as usual with TfL consultations no information on the cost of the proposals is provided, nor any cost/benefit analysis. Please complain about that also.

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TfL Consultations and How to Influence Them

It has been apparent for some time that when Transport for London (TfL) undertake a public consultation they get many responses from cyclists and public transport users, but few from other road users. The result is that the ensuing consultation report shows a very biased picture of the views of the general public.

Why is this? It’s because TfL prompt responses by sending out emails. For example they sent out over 400,000 emails about the Hackney Cycleway proposals (described here: https://tinyurl.com/y6fxezmq ).

How did people get on their email contact list for this consultation? From an FOI Act request I can give you the answer. Some 81 people were bespoke to the consultation and were selected from “TfL’s Local Communities and Partnership” team. Another 4,875 came from statutory consultees (police, fire service, etc) and others who asked to be kept informed on TfL consultations. But the vast majority (473,210 to be exact) came from their Customer Database. That means everyone no doubt who has an Oyster Card or Freedom Pass or has opted to receive TfL travel information. So you can see why the result of the public consultations is biased towards public transport users.

How can private car users, taxi users, PHV users or LGV/HGV users influence the consultations? All you need to do is register to receive consultations by signing up on this web page: https://consultations.tfl.gov.uk/sign-up/0f3971fe/ . In addition you can sign up here for news updates: https://tfl.gov.uk/travel-information/social-media-and-email-updates/email-updates .

Adding your name to both those lists should ensure that you get information on new consultations and enable you to have your say. MAKE SURE YOU SIGN UP NOW!

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