How Many Objections in Lewisham to the LTN?

Back in November 2020 we submitted a request under the Freedom of Information Act (FOI) to obtain the number of objections received by the Council or Councillors to the Low Traffic Neighbourhood (LTN) schemes in Lewisham. Their response after a long delay was that they did not have that information.

We appealed to the Information Commissioner’s Office (ICO) and have just received a final decision. The ICO have concluded that the Council breached regulations 5(2) and 14(1) of the EIR by failing to respond within 20 working days and failing to advise that it was relying on regulation 12(4)(b). But they agreed that it was too burdensome a request.  

The FOI Act can be a useful piece of legislation but not when Councils deliberately frustrate or delay answering reasonable questions.

It’s taken so long (eighteen months) to get to this point that the information requested is now somewhat irrelevant so we won’t be pursuing a further appeal. But one item of data obtained as a result was that Louise McBride (Head of Highways and Transport at the Council) alone received 1,040 emails on the subject.

That contradicted a minute of a Council Meeting on the 25th January 2022 where it was stated that Cabinet Member Patrick Codd reported that the Council received approximately 150 emails about the experimental introduction of the LTNs. That was clearly inaccurate and Councillor Codd is arranging for the minute to be corrected.

These events show how Lewisham Council is incompetent in many ways. They failed to record objections in any useful way despite the Lee Green LTN being an “experimental” scheme. I have requested that they at least count the objections to the Permanent LTN properly.

If you have not yet sent in objections to the Lewisham and Lee Green LTN, please use this template email or letter below (simply copy and paste it but modify it as you see fit):

Send to: ParkingDesign@lewisham.gov.uk (or post to Lewisham Transport Policy & Development, 5th Floor Laurence House, 1 Catford Road, London SE6 4RU)

Objection Letter:

Re: Statement of Objections to Traffic Order 4030579

I am writing to object to the proposed Traffic Order 4030579 published on the 25th March 2022 made by the London borough of Lewisham (“Lewisham”) concerning the Lewisham and Lee Green Low Traffic Neighbourhood.

Grounds for Objection

I dispute whether the experimental scheme which is now proposed to be made permanent has actually reduced the volume of traffic (rather than just displaced it). There is no evidence that it has done so during the period of the experimental traffic orders other than within the LTN alone where roads were closed while traffic flows on boundary roads have increased. Neither has it had any impact on overall levels of air pollution as is clear from the evidence in the Monitoring Data Summary published by the council but residents have reported large increases on boundary roads.

One of the objectives was apparently to mitigate the impact of emissions on climate change but there is no way that actions in Lewisham will have any impact on climate change which is driven by major global factors. Any impact from actions in Lewisham will be trivial.    

The effect of the scheme has been highly detrimental for the local community as a whole but especially detrimental for people from protected groups defined in the Equality Act 2010. The proposed mitigation measures do not address the intrinsic flaws in the scheme, which have been readily apparent for the entire duration of the scheme.

In short, the scheme displaces traffic on to certain “strategic” and certain other roads without proper consideration of the consequences. Specifically, the impact on those who are car-dependent and those who are dependent upon visitors (e.g. those who receive social care) are disregarded. Moreover, the gridlock and traffic congestion the scheme has created has had indirect effects on many.

1. The Scheme

The scheme restricts traffic from using certain roads at certain times and prevents traffic using routes that have historically been available. This concentrates traffic onto other roads, increases congestion and acts as a barrier, making it much harder to traverse across the borough, and in particular north to south Lewisham and vice versa. The Blackheath, Lee and Hither Green community was previously a completely holistic one but has now been cut in half by the imposition of a physical barrier to all motorised traffic in the heart of the area.

2. The Public Consultation

The public consultation with local residents had numerous flaws and is therefore unlikely to represent the true extent of the local community’s aversion to the scheme.

The Report on the consultation ignores the views expressed in response to the public consultation, the objections received to the Temporary Traffic Orders and the 12,000 signature petition which was submitted to the Council (from Change.org).

Councillor Patrick Codd is reported as saying: “We believe the LTN is meeting its aims…..” while Mayor Damien Egan said “The world is facing a climate emergency and we urgently need to do more to improve air quality in London” but he seems to have ignored the evidence in the report that air quality is already massively improved and will continue to be so (NO2 concentrations at roadsides have fallen by 42% since 2014).

The Report repeats the false allegation that traffic on local roads in London has increased by 60% since 2009 which is contradicted by the latest TfL report on Travel in London – see this blog post: https://freedomfordrivers.blog/2022/01/05/travel-in-london-report-mayors-objectives-not-met/   

The LTN was introduced urgently and without prior consultation as a measure to help social distancing during the pandemic. The Council’s report says “The primary aim was to encourage people to walk and cycle more, and to do so safely…..” (see para. 5.2). But did it? The evidence is not clear particularly as travel patterns changed as a result of the pandemic (see the TfL report above for evidence of how travel was reduced or changed in London). Closure of schools and businesses with more working from home were the main factors.

The Council received 7,065 responses to the public consultation on the LTN. Some 56% of respondents felt negatively about the revised LTN, as opposed to 44% who felt positively or neutral. That’s a clear majority against the current road closures which Councillors have ignored in an anti-democratic fashion. It is unfortunately the case that councillors and council officers once they have taken a dogmatic position, in this case that “deterring the use of vehicles is good for the planet”, they rarely want to change their minds despite the contrary evidence of the negative side effects.

In this case the road closures have increased journey times for many people, increased air pollution on boundary roads and obstructed emergency service vehicles. The conversion to ANPR enforcement will avoid the latter problem but has already resulted in many accidental fines so we do not consider that a sensible solution and it is clearly being motivated by the financial benefit obtained. That is unfair and unreasonable.

The Report comments on the Equalities Impact Assessment but simply ignores the negative consequences of the impact on disabled people who rely on motor vehicles. The Report also ignores the obligations of the Council under the Traffic Management Act 2004.

Although the latest LTN is an improvement on the original version it will still cause many problems. For example the closure of Upwood Road, Manor Lane, Manor Lane Terrace and Manor Park might deter through traffic but will also cause enormous inconvenience to local residents or their visitors who will have to take very circuitous routes. People badly affected by the closures are being ignored.

3. The impact of the scheme on main roads

There can be no doubt that the scheme has displaced substantial traffic onto roads which simply cannot bear the volume of traffic forced on them. This has had a severe impact on local residents and particularly the groups identified above.

4. The day-to-day impact of the scheme

The day-to day impacts to local residents have been overwhelming and are not limited to those outlined below;

5. Impact on certain groups

The Public Consultation confirms that the “overwhelming majority” of people from protected groups oppose the scheme. We strongly believe, and the evidence shows, that, despite this clear opposition, the needs of particular groups have not been adequately thought about and the scheme actually exacerbates challenges for these groups rather than removes them.

Car use is often essential for older and disabled people; and for those who are dependent upon their car it needs to be available at all times to ensure that they can visit urgent health appointments and live independently.

Many have attempted to eliminate their private car use, but the only potentially affordable alternative is taxis or minicabs (PHVs). However, as a result of the scheme, some residents are reporting that taxis and minicabs are struggling or refusing to access streets within the scheme.

The other alternative to private car use, buses, are slower and unreliable plus difficult to use for people with mobility problems meaning that older people do not feel that this is a viable alternative.

For many older people, cycling and walking extended distances are simply not viable.

Access to visitors who travel by car, such as community nurses, social care staff, pharmacists and GPs, is equally essential. Similarly, these health and social care professionals need to be available at all times to provide care and deliver prescriptions.

Cumulatively, older people describe the impact as severe; as well as the obvious health impacts caused by struggling to access services, they spoke of being kettled-in or cut-off from their friends and family.

Accessing school for disabled children has become exceptionally difficult with journeys that should take a maximum of 15 minutes now taking 45 minutes.

The consideration of those who are car-dependent has been wholly unsatisfactory.

Given that Lewisham is required to think about the impact of these schemes on protected groups and remove obstacles that prevent protected groups participating in society, Lewisham has failed to meet its duty since it has failed to make any effective mitigation for those who are largely or wholly car-dependent and whose mobility has been drastically reduced or removed by this scheme. Cumulatively, the scheme exacerbates obstacles for protected groups rather than removing them. These obvious disadvantages, explained in exacting detail in the Public Consultation, and Lewisham’s own Equality Impact Assessment, are completely discounted.

6. Add a statement about how you personally have been inconvenienced by this scheme:

7. Conclusion

For the reasons set out above, I object to Traffic Orders 4030579 in the strongest possible terms and ask that you reverse your decision to make the Lewisham and Lee Green Low Traffic Neighbourhood permanent given the impact on local residents, local businesses and, in particular, those in protected groups. I urge Lewisham to recognise that this experiment has thus far failed and to show its courage by not ploughing on with an obviously divisive, detrimental and unsuccessful scheme that fails to fulfil its aims.

Yours faithfully

(Name)

(Address)

<END>

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Grant Shapps Changes Stance

I have been spending a lot of time on our campaign against road closures in Lewisham and other London boroughs over the last few months. It has just achieved some success as Lewisham Council announced a reopening of some roads on Friday. But not enough to appease the complainants, and not enough I think to stop the traffic congestion on many roads.

Part of the problem has been the encouragement by Central Government for road closures and cycle lanes, and funding to assist, as promulgated by Grant Shapps, Transport Secretary.

A Parliamentary e-petition on the subject has already collected near 20,000 signatures in a few days. See https://petition.parliament.uk/petitions/552306 . Please sign it and get your friends and relations to do so. And write to your member of Parliament on the Subject.

But it seems the worm is turning as the Daily Telegraph reported the following: “A letter, sent on Friday to local authority transport bosses and local highways authorities and seen by The Telegraph, warns how a ‘notable number of councils used their funding poorly and were simply out of step with the needs of the local communities’. Mr Shapps also said: ‘I saw or heard from the public and parliamentary colleagues about far too many instances where temporary cycles lanes were unused due to their location and design, while their creation left motor traffic backed up alongside them; of wide pavements causing unnecessary congestion in town centres; and other issues that many have, rightly, reacted angrily to.’

He explains how he had ordered his staff to “engage” with those councils where he had ‘concerns’, because badly thought out road closures and cycle lanes had been introduced.

‘Since then, numerous schemes have been scaled back and revised,’ he wrote. ‘I am pleased with this, but the work will continue where local residents continue to have concerns.’

He warns the second round of funding in the scheme could see some town halls receiving ‘considerably less’ money if they fail to ‘embrace good design’ or ‘consult their local communities’.”

Let us hope there is real change but I suspect Lewisham and some other dogma driven London Councils will continue to pursue irrational policies so the fight for sensible measures with democratic input will have to continue.

Photo above is of the demonstration on Saturday against the road closures in Lewisham – no doubt more would have attended if it had not been an illegal event. Video present here: https://youtu.be/cqW2hBfK7k0

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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Lewisham Backtracking on Road Closures

Lewisham Council have made an announcement concerning their Low Traffic Neighbourhood in Lee Green which has caused so much anger among residents. They have not conceded defeat but instead come up with a half-baked compromise that will only pacify a few people. Some roads are re-opened or made one-way but roads such as Upwood Road will remain closed. It also mentions plans for more “School Streets” (i.e. timed road closures) and longer-term changes for the Hither Green and Catford areas in 2021. The exclusion of HGVs from some of the roads may undoubtedly be welcomed by many people however.

You can read the details here: https://lewishamcovidresidentialstreets.commonplace.is/news/2020/10/16/changes-to-lewisham-and-lee-green-low-traffic-neighbourhood-announced? See Map below also.

It’s actually very difficult to understand the logic behind these changes as some local residents will find their journey’s improved while others will not. It is also not at all clear that it will substantially relieve the extra traffic loads on the main roads such as the South Circular.

They claim these changes are the result of “what the local community has told us” but as there has been no formal consultation process or surveys performed they are likely to have only listened to a very selective audience.

These changes are due to be implemented in the week commencing the 9th November when there will no doubt be another bout of confusion on which routes are permitted.

The group of local residents who oppose the road closures, which is supported by us and which now has support from over 10,000 people, will wait to hear your comments before commenting further. Please let us have them.

Note that there is a webinar meeting hosted by Mayor Damien Egan for local residents on the 22ndOctober at 7.00 pm which you can register for here: https://consultation.lewisham.gov.uk/highways-and-transport/lewisham-and-lee-green-ltn/

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Low Traffic Neighbourhoods and Disabled People

The population of the UK contains a high proportion of “disabled” people. According to Government statistics they actually represent 22% of the population (that’s 13.9 million people). In London a borough such as Lewisham reports that 15% of the population consider themselves disabled.

Disabled people face numerous problems such as access to health services and access to employment. They often rely on “carers” for assistance with many activities such as shopping.

How do Low Traffic Neighbourhoods such as the Healthy Neighbourhood plans (and associated road closures) in Lewisham and other boroughs affect them? We certainly know from the numbers responding to our campaign against the road closures that a very large number of them object to the road closures.

The problem is that many disabled people rely on motor vehicles for transport as they have difficulty using public transport and suggestions that they should cycle are treated with derision. They also often cannot walk far. They don’t just own cars and use them, they use taxi services or get transported by carers in vehicles. In addition, they often have support from social service workers who use vehicles to get around.

For example, this is one comment just received “I strongly disagree with these closures, I work for the Borough of Lewisham and respond to vulnerable clients in the Borough. These road closures have delayed us responding to our clients, and one day the outcome will result in more serious consequences. Sitting in traffic, unable to access roads, this is not solving anything. If anything the situation is causing more pollution,  congestion and more aggressive drivers. The fact that we as residents of the borough were not consulted is not acceptable”.

Life has become much more difficult for disabled people since the road closures were introduced in Lewisham with much extended journey times as a result. Simply accessing Lewisham hospital is a common complaint.

Has Lewisham Council considered the impact of the road closures on disabled people? In other words, have they done an “Equality Impact Assessment” as required by the Equalities Act 2010?  So far as we are aware they have not done so. Paul Howarth submitted a Freedom of Information Act request on this subject back in February but does not appear to have received an answer – see https://www.whatdotheyknow.com/request/the_so_called_healthy_neighborho

Just like the lack of public consultation, it seems the Covid-19 epidemic is being used to bypass and abandon the normal requirements for new road schemes.

An interesting recent publication from Lewisham Council was from the Stronger Communities Select Committee (see https://councilmeetings.lewisham.gov.uk/ieListDocuments.aspx?MId=6323&x=1 ). The Council is reviewing its obligations under the Equalities Act and have produced a draft report. But perhaps surprisingly they don’t cover this issue. Note that Lee Green Ward Councillors James Rathbone and Jim Mallory actually sit on this Committee so they should surely take a great interest in the impact of the road closures on the disabled community but not obviously so to date.

Lewisham has also created a “Disabled Peoples’ Commission” chaired by Jamie Hale – see https://labourlist.org/2020/02/our-disabled-peoples-commission-can-identify-barriers-and-deliver-change/ . I suggest disabled people who have been affected by the road closures in Lewisham ask the Commission to represent their interests.

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Lewisham MPs Hear Complaints About Road Closures

Last night (on 25/8/2020), Janet Daby and Vicky Foxcroft, two M.P.s who represent Lewisham constituencies, hosted a Zoom conference to hear people’s views about the road closures in the borough. There were as many as 100 attendees when more wanted to join but apparently could not do so. I will only summarise some of the proceedings and the key comments.

It was clear by the end of the event that there were only very few people supportive of Lewisham Council’s plan for a “Healthy Neighbourhood” (or Low Traffic Neighbourhood as others call these schemes involving road closures). Most of the speakers opposed the current road closures and I’ll give some of the comments below. The supporters of the scheme talked about saving the planet, cutting air pollution and road traffic accidents and getting everyone out of cars.

But it was very obvious how many were reliant on vehicles. For example one of the first speakers, Dr Petula Peters who has to take her sister to hospital said it was now an absolute nightmare with the new road arrangements. Her GP was also having difficulties getting to see patients.

Several people complained about the impact on the South Circular as traffic is now forced to use that more. Others spoke about the impact on the elderly and disabled and the lack of an equality impact assessment. It’s all terribly divisive one person said.

The lack of consultation was also mentioned by many people and one good point made was that there was no traffic modelling undertaken before the roads were closed. That would have predicted the current problems.

Many minor roads that were previously quiet were seeing much more traffic as vehicles divert around the closed roads – this prompted some people to ask for the scheme to be extended over a much wider area.

Viv Hammond summarised the views of many in these words: “It has totally changed our lives”. She is very concerned about the air pollution created and it is “making life very difficult”. As Vicky said “the whole idea that cars will go away is just ridiculous. They have cut Lewisham in half. Everyone can’t walk or cycle. A badly thought out scheme that has not worked. What are M.P.s going to do about it?”, She was clapped at this point.

In the concluding remarks from Janet Daby she mentioned that the Council planned a public meeting and consultation in September. She summarised the objections and concerns and will talk to the Council but note that M.P.s have no direct influence over local Councillors.

Perhaps the mood of the audience was summarised by one person who interjected just before the meeting was closed and the audio turned off. He said “A load or rubbish – they’ll do nothing”. It indicated the frustration of residents and the view that Councillors are simply not listening to complaints and acting on them.

But it’s worth pointing out that Lewisham Council’s policies are partly being driven by central Government edicts, as one speaker in the meeting indicated, over which even Labour M.P.s might have some influence. I suggest voters ask them to make representations on the issue.

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