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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The LTN, Air Pollution and Climate Emergency in Lewisham

The justification for the Low Traffic Neighbourhood (LTN) scheme in Lewisham was spelled out by Mayor Damien Egan in his webinar on the 22ndOctober (see https://tinyurl.com/LTNResidentsMeeting to watch a recording).

He said that the reasons the LTN was proposed was to a) Improve Air Quality; b) Making streets safer by reducing car journeys; and c) Making it easier to walk and cycle. He also said “road traffic is the number one cause of toxic air and toxic air kills”. Unfortunately he is wrong in several respects.

Toxic air is usually judged to be based on the level of particulates (dust) in the air and the level of nitrous oxides (NOX), although there is some debate as to whether NOX (mainly NO2) is actually damaging to health. Particulates, namely PM 2.5, are the major concern and to quote from the report in Reference 1 below “Road transport accounts for around a quarter of PM2.5 in London, with a large proportion also coming from construction, wood burning and commercial cooking”.

We covered the issue of the contribution of vehicles to air quality in a report we published two years ago – see Reference 2. The Conclusion in that report said this:

“In conclusion, let it be clear that we are supportive of improving air quality in the UK, particularly in urban areas and on particular roads where transport is a major generator of emissions. But there is no public health crisis and measures to improve air quality should be both reasonable and moderate. According to a recent report from Defra, since 1970 NOx emissions have fallen by 72% and Particulates (PM2.5) by 79%. The hysteria about air pollution is wrongly being used to generate tax revenues to local government (e.g. the ULEZ in London and similar proposals for other UK cities) without any justification in terms of cost/benefits. The likely improvement in air quality that will result will be unlikely to be noticed by residents because it will simply be too small and it will have no significant long-term impact on health”.

Even if you consider NOX to be of concern as a lot of it does come from transport, in practice LTNs mainly affect car users while the majority of NOX comes from buses and commercial vehicles – only 33% comes from petrol or diesel cars – see Reference 3 for the data from 2013 and it’s probably considerably less now.

Does “toxic air” kill, as the Mayor said? In reality it is very unlikely that the level of air pollution in Lewisham kills anyone at all. If you live on one of the worst streets for air pollution such as on the “A” roads where there is heavy traffic (particularly HGVs and buses), it is possible that life expectancy might be shortened by a few days. But you are likely to experience more exposure to particulates from domestic cooking and heating than from road transport. The exposure of smokers is also many times worse. Your life expectancy is most dependent on your lifestyle, domestic and work environments, not on background air pollution.

The Mayor also suggested that the streets would be safer if car journeys were reduced but diverting the journeys to main roads as the LTN is doing is not going to help. The accidents will move also to roads where higher speeds may be present. There is no evidence that overall road casualties will reduce by such an approach. In practice LTNs do not reduce car journeys significantly if a wider area is considered – they just divert journeys to longer routes.

As regards the comment that the LTN will make it easier to walk and cycle, there is no obvious problem in using either of those modes in the LTN and reducing traffic will not assist.     

Another justification given in the webinar for the LTN was by CEO Kim Wright who said it supported the Climate Emergency Strategic Action Plan adopted by the Borough – see Reference 4. Many Lewisham Councillors clearly believe they are helping to save the world from global warming by cutting CO2 emissions. Without getting into a debate on the science of global warming, you can see how futile that is in terms of actions possible by the London Borough of Lewisham by considering this data:

Lewisham emitted 805,000 tonnes of CO2 in 2017/2018 which is 0.2% of UK emissions of 354 million tonnes in 2019. The UK proportion of world emissions is about 1%, so Lewisham’s contribution to world emissions is 0.2% of 1%, i.e. 0.002%. The UK is taking vigorous actions to reduce overall emissions while countries such as China (28% of world emissions) are still building hundreds of coal-fired power plants. Any actions by Lewisham will have negligible impact on emissions in the UK let alone the world, and actions to tackle excessive CO2 emissions should be taken at a national level where it can be most effective.

In fact LTNs are unlikely to have any impact on CO2 emissions for another reason. Over 50% of CO2 emissions arise in housing – mainly domestic heating, and only 14.7% arise from cars.

In summary the main reason for the introduction of LTNs in Lewisham given by the Mayor of Lewisham simply do not stand up to scrutiny. The dogma about the need to reduce vehicles on our roads is not only unjustifiable on any cost/benefit analysis, it is simply unjustifiable full stop.

This virtue signalling by Lewisham councillors is imposing enormous inconvenience and costs on Lewisham residents that cannot be justified. Journey times have increased enormously, while air pollution on roads that already had high levels has clearly worsened.

Low Traffic Neighbourhoods do not solve anything and are based on irrational opposition to the use of vehicles which the world has come to rely on.

Roger Lawson

Reference 1: Air Pollution Monitoring Data in London: https://tinyurl.com/y57nucz9

Reference 2: Air Quality and Vehicles: The Truth: https://tinyurl.com/yx9bk9kg

Reference 3: Lewisham Air Quality Action Plan (2016-2021): https://tinyurl.com/y2n684bz

Reference 4; Lewisham Climate Emergency Strategic Action Plan: https://tinyurl.com/y34bwcnj

Twitter: https://twitter.com/Drivers_London

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