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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Justice Denied, Twice in One Week

In October 2020 I made an “Ethics Complaint” about Councillor Octavia Holland in Lewisham after she issued a tweet which said I had organised for our contacts to “…bombard me with abusive emails….”. This was a false allegation which clearly damaged my reputation and the campaign I have been running against the road closures in Lewisham.

All that I did was to ask our contacts to give their views on the matter directly to her as she had alleged that she had received many emails backing her support for the LTN in Lee Green.

After numerous reminders the Council’s Monitoring Officer has finally issued a judgement on the matter. She has rejected my complaint on the basis that “It was not an unforeseen consequence of such encouragement…. that Councillor Holland should in fact receive emails where such objections are raised, including in vehement tones, given the apparently heated public views around the issue”.

It would seem that encouraging members of the public to give their views to their local Councillors on topical issues is not to be encouraged in case they express their views too forcibly and that Councillors can make false allegations without proper grounds.

Councillor Octavia Holland Departing

But on the same day I received the above judgement Councillor Holland issued this tweet:

“@OctaviaLewisham

My news to add to the pot: I have confirmed this week I will not be restanding in 2022. Being a Cllr is a privilege and I am very grateful for the chance & support I have had. But as a single, working parent with a child about to enter his teens I need to be around more. Over the next 4 years and despite many understanding colleagues I can’t get away from the fact I want to be here to make dinner, help with homework, be a listening ear. I’ll be working hard until April, & looking forward to supporting the many brill candidates coming through”.

At least we have got rid of an incompetent and dishonest Councillor. She is lucky I did not pursue a legal case for defamation. Next time I will. Let us hope that any new Councillors proposed by the Labour Party in Lee Green are less divisive and will actually listen to all their electorate, not just a minority of car haters.

Councillors Not Responding

I have seen numerous complaints about Lewisham Councillors not responding to comments received from their electorate, and not just about Councillor Holland. For example this was an email I received in the last few days: “FYI, I live in Lewisham’s Blackheath ward and can vouch for the fact that none of our 3 councillors – Bonavia, De Ryk and Campbell all Labour – will answer emails from any of their constituents on any subject and haven’t done so since pre-Covid days.  Between them they rake in £50K’s worth of allowances for attendance at meetings and their places on Mayor Egan’s cabinet.  What exactly are they for!!”

Many councillors in Lewisham do not seem to understand that they have a responsibility to listen to their electorate and represent their views. For example the Local Government Association says this in one of their publications about how to be an effective councillor: “Representing local voices – being a channel of communication between the communities you serve and the council, representing the views of others and speaking up for the unheard, e.g.younger, older or disabled people.…”. See https://tinyurl.com/6tdxarn3 for details.

How can they do that if they are unwilling to participate in any dialogue with members of the public? The role of councillors is onerous and requires many hours of work but they should not be taking on the role if they cannot handle it properly.

Hackney Judicial Review over LTN Rejected

A judgement in the High Court last week by Mr Justice Dove rejected a judicial review claim brought by Horrendous Hackney Road Closures (HHRC) against the Low Traffic Neighbourhoods (LTNs) brought in by Hackney Council.

There were several grounds for the claim including the failure to comply with the Traffic Management Act 2004, a failure to have regard to the impact of the road closures on air quality, a failure to comply with the public sector equality duty under the Equality Act 2010 and a failure to undertake proper public consultation. All the grounds were rejected.

Experimental Traffic Orders (ETOs) were used to introduce the measures and the judge said that the Covid-19 guidance to introduce such measures urgently by the Secretary of State for Transport (Grant Shapps) justified the ETOs and also justified the lack of consultation.

For the full details of this disappointing judgement see:   https://www.bailii.org/ew/cases/EWHC/Admin/2021/2440.html  

This is a disappointing judgement but it was always going to be a difficult case and it does not mean that other similar legal challenges to LTNs may not succeed.

The main promoter of the LTNs in Hackney was Councillor Jon Burke. In January he announced he was resigning with the intention to move to the North of England. There seem to be a number of councillors in London who have been stepping down after promoting LTNs. They seem to be following the old proverb “If you can’t stand the heat get out of the kitchen”. Perhaps if they took a more consensual approach to local politics they would not need to quit.

Roger Lawson

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Gear Change , But Downwards

Cover Photo from Gear Change

The Department for Transport (DfT) have recently published a document entitled “Gear Change: One Year On”. It’s a celebration of the radical changes implemented by Government policy in the last year, with more active travel. It also contains a forward by the Prime Minister containing such phrases as: “Hundreds of new schemes have created safe space for people to cycle and walk, supported pubs and restaurants that might otherwise have closed, and allowed us to get the exercise we need. For decades we mourned that children no longer played in the street. Now once again, in some places, they do”.

That’s a very distorted view of what has happened during the pandemic. More people have walked and cycled partly because they have been working from home and hence have more time to do so, but also because they have been avoiding public transport.

The PM also says: “I know many people think that cycling and walking schemes simply increase car traffic on other roads. But there is now increasing evidence that they do not. We sometimes think of traffic as like water: if you block a stream in one place, it will find the next easiest way. Of course some journeys by car are essential, but traffic is not a force of nature. It is a product of people’s choices. If you make it easier and safer to walk and cycle, more people choose to walk and cycle instead of driving, and the traffic falls overall”. The latter comments may be true but there is certainly evidence that closing roads which is a typical element of LTNs does increase traffic on other roads.

The Gear Change document is a panegyric to the wonders of walking and cycling, but it totally ignores the needs of major segments of the population such as the elderly or infirm, or those who rely on vehicles to transport goods, tools or multiple passengers. It also contains some very misleading data on such issues as the take-up of cycling. It also suggests there is widespread public support for LTNs when independent surveys suggest the majority are against them. It depends on who you ask, the questions posed and who runs the survey.

Gear Change promotes a negative, downward move to local transport that will be opposed by many. It’s basically a propaganda piece exhorting us to change our way of life rather than the Government tackling the underlying causes of traffic congestion.

A good example of the kind of opposition to LTNs is the formation of a new group in Dulwich called “Age Speaks”. They say “We are a group of older people within One Dulwich who have banded together to amplify our voice.  As individuals we are being ignored by Southwark Council and our views and needs are being drowned out by the lobby groups the Council is listening to.  Together our voices will be louder and so we are uniting to make sure that older people are heard.

We want to make sure that the Council understands the difficulties the experimental road schemes cause us and how the Council could change things to make sure that we are treated equally.  Age is a protected characteristic under the Equality Act 2010 and the Council has a duty to protect older people from unfair disadvantage.  This is particularly important now, as the Council will be making a decision on the road schemes in October, and so far has paid very little attention to the needs of older people”. They are particularly critical of an Equality Impact Assessment report from Southwark Council which is a typical example of such recent publications which tend to simply ignore many of the problems faced by the elderly.

Those who write such documents tend to be young and fit and simply have no understanding of how the elderly are impacted by attacks on the use of vehicles.

Gear Change report: https://tinyurl.com/yhc2fxkf

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Do LTNs Cut Accidents?

A study on Low Traffic Neighbourhoods (LTNs) by Anna Goodman et al, which has been widely reported by the Guardian and the Mayor of London, suggests that road casualties have fallen dramatically in London after LTNs were introduced. The fall is as much as 50% overall with large falls in pedestrian casualties.

One might say that if roads are closed and traffic reduced (the main objective of LTNs by their advocates although the Covid epidemic was used as the excuse to do so) then accidents are bound to fall. On the logic that the end justifies the means then to reduce the high road casualty toll, all roads should be closed. But that would not be very practical.

But if you look at the study, you will realise that it is hardly a scientifically accurate study of the impact of LTNs.

The key measure to look at when considering road accidents is the Killed and Seriously Injured (KSIs) where the data in this study seems to be very small, as minor injuries can suffer from under reporting. That is particularly so in the pandemic as people would be reluctant to visit police stations to report accidents.

In addition it seems a lot of the reduction is to pedestrians who were probably much reduced, particularly on busy shopping streets where most casualties take place, because of the pandemic. Few people were going shopping other than via the internet during the pandemic (many shops were closed), and the elderly and young, who are most prone to road accidents were particularly avoiding going out (schools were closed for example). The data has not been adjusted to take account of these factors.

The other issue is that road safety professionals consider that a three-year before and three-year after comparison is best used when considering the impact of road changes. This is because if road layouts are changed there tends to be a significant but only short-term impact on road user behaviour.

This is very selective data over a short period of time and not likely to reflect longer term trends. It is a great pity that Sadiq Khan has promoted this report without thinking. There are many good reasons why LTNs are opposed by the majority of people and LTNs are not a good way to reduce road accidents. All such simplistic solutions will fail because the reasons for accidents are complex and scientific studies need to have proper “controls” in place before conclusions are drawn. In this study, why were pedestrian casualties much reduced while other types were not and what features of the LTNs may have reduced accidents? There are several ways to implement LTNs but the report tells us nothing about those issues.

Reference: https://findingspress.org/article/25633-impacts-of-2020-low-traffic-neighbourhoods-in-london-on-road-traffic-injuries 

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Residents Oppose Road Closures in Dulwich

Campaign group OneDulwich have published this note:

80% against 24/7 closure of Dulwich Village junction

Surveys of residents in ten roads close to Dulwich Village junction show that over 80% of more than 800 local households (representing a far greater number of individuals) do not support the 24/7 closure.

You can read their full report on their web site here: https://www.onedulwich.uk/ along with a lot of other useful information.

It might be time for Southwark Council to stop referring to those in opposition as a small vocal minority.

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Ealing LTN Consultations

From the OneEaling campaign:

Ealing Council consultation: the time is now!

Dear Supporter,

Ealing Council are holding a final consultation on the LTNs. PLEASE make sure you have your say. This has to be done by 23rd July!

After this consultation, the LTNs will either be scrapped if the majority want them removed or made permanent if the majority want them to stay in place.

This is your LAST CHANCE to have your say on ALL of these schemes, everyone is eligible and all can express their views on each scheme. Make sure you fill in the reason why you do not want each LTN, those living within/surrounding the LTNs will have more weighting but those who run businesses and work in the area will also be considered.

Below are the all links and the SurveyMonkey link is the actual voting part. It takes less than a minute to complete each survey.

Please share this amongst everyone you know locally, friends, neighbours, colleagues, etc.

LTN30: Loveday

https://www.surveymonkey.co.uk/r/lovedayroadltn

https://www.ealing.gov.uk/lovedayltn

LTN35: Mattock Lane

https://www.surveymonkey.co.uk/r/mattocklaneltn

https://www.ealing.gov.uk/mattockltn

LTN32: Junction Road

https://www.surveymonkey.co.uk/r/junctionroadltn

https://www.ealing.gov.uk/junctionltn

LTN20: West Ealing North (Waitrose)

https://www.surveymonkey.co.uk/r/westealingnorthltn

https://www.ealing.gov.uk/westealingnorthltn

LTN08: Olive Road (Popes Lane)

https://www.surveymonkey.co.uk/r/oliveroadltn

https://www.ealing.gov.uk/oliveltn

LTN48: Adrienne Ave (Greenford)

https://www.surveymonkey.co.uk/r/adrienneavenueltn

https://www.ealing.gov.uk/adrienneltn

LTN25 Acton Central

https://www.surveymonkey.co.uk/r/actoncentralltn

https://www.ealing.gov.uk/actoncentralltn

Deans Road/Montague Rd Consultation for LTN to be reinstated:

https://www.surveymonkey.co.uk/r/deanmontagueltn

https://www.ealing.gov.uk/info/201268/low_traffic_neighbourhoods/2821/deans_road_and_montague_avenue_low_traffic_neighbourhood/1

Thank you for your continued support.

The OneEaling Team

Lewisham Issues Public Consultation on LTN

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

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Croydon Decides on ANPR to Close LTN

The Cabinet of Croydon Council has approved Councillor Muhammad Ali’s decision to implement ANPR cameras in the Crystal Palace and South Norwood area to enforce a Low Traffic Neighbourhood. This is despite all the evidence, opposition from local residents and a public consultation. This decision also affects residents in the adjacent borough of Bromley who may yet have some say in the matter (they previously threatened legal action).

The previous closure created horrendous traffic congestion and no doubt it will now come back. This is a completely undemocratic decision and the only option remaining is probably a legal challenge for which we believe there are good grounds.

Although there may be some exceptions made to the enforcement, these are public roads which should be available to everyone.

You can obtain the 450 page report to the Scrutiny and Overview Committee on the 23rd March on which the decision by Mr Ali was presumably based from here: https://tinyurl.com/a4j9ysn5

Roger Lawson

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Telegraph Summarises Surveys Against LTNs, and John Redwood’s Blog Article

The Daily Telegraph has published an analysis of the 10 consultations on Low Traffic Neighbourhoods (LTNs) that local councils have reported to date. Three quarters of the people consulted over LTNs and cycle lanes opposed them.

The councils reporting their survey results include Harrow (82% opposed) and Windsor + Maidenhead (89% opposed). One exception was Bromley though with 64% supporting but their schemes are very limited in scope.

The newspaper also reported that one in three councils have axed, modified or reduced their active travel schemes. They also quote Tony Devenish, Conservative London Assembly Members as saying: “My Government is at fault to some extent, because they gave councils the power not to publicly consult for up to 18 months. You can’t just do these things to people. There has been absolute outcry from the Great British public – and that’s why so many councils have had to U-turn”.

But some Councils such as Lewisham have avoided doing public consultations despite promising to do them, or they keep moving the goalposts by changing the nature of the road closures (for example by changing them to “School Streets” or by reissuing Traffic Orders to avoid legal challenges).

Comment: Such public surveys show that the general public (even those who don’t own a car but rely on public transport such as buses), are opposed to the obstruction of our roads. Roads are essential for the movement of people and goods.

In Praise of the Car

John Redwood, M.P., has spelled out the advantages of cars in a good article on his blog (see Reference 2 below). He says: “Acquiring your first vehicle is a major advance in your personal freedom. Yet today government, Councils and better off greens from the security of their homes in major cities lecture the rest of us on the wickedness of the car. The better off Green city dweller can rely more on the tube or mass transit and has the money for taxis when needed. The aim is to get people out of car ownership or to reduce their use of the car, and in the meantime to cow people into keeping quiet about their reliance on this flexible and most popular form of transport”.

He explains at length why cars are more practical and economic for most of the journeys which he takes. A number of good comments have been added. I hope Grant Shapps reads the article.

Reference 1: Telegraph Article: https://tinyurl.com/2d44vbcn

Reference 2: Redwood Article: https://tinyurl.com/cchhcurc

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Millions Collected in Fines from LTNs

The Times have reported that drivers have racked up £14 million in fines in London in just a few months by driving into Low Traffic Neighbourhoods (LTNs). Cameras were introduced to stop people driving through “bus gates” or into these zones instead of using physical barriers as the latter prevent emergency vehicles from accessing the roads.

The penalty for driving through the cameras is £130 and many people have collected PCNs because they have not noticed the signs. An extreme example given by the Times is that of Ivan Izikowitz who collected 58 fines totalling £7,500 after temporarily leaving home to help his wife in Lewisham.

But there are many other examples reported to us of people collecting fines about which they are very angry. Roads which were previously opened and regularly used catch people out, particularly as satnav systems have often not been updated to take account of the closure.

The £14 million total was collected in just 10 London boroughs and Lewisham obtained more than any other borough. Lewisham and other boroughs are of course keen to extract more money from motorists to help with their budget problems, but there is no justification for this behaviour.

The road closures should be removed as the Covid pandemic does not justify them and they have many other negative consequences.

Times article: https://tinyurl.com/b8u2hyzb

London road closures: https://www.freedomfordrivers.org/london-road-closures.htm

Lewisham campaign against closures: https://www.freedomfordrivers.org/lewisham.htm

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