An article in The Times today (24/10/2022) showed LTNs don’t work under the headline “London LTNs: Councils that closed rat runs now have even more cars on the road”. It said “Councils that implemented low-traffic neighbourhoods during the pandemic have seen bigger increases in car use than boroughs that did not, according to government driving statistics”.
The explanation is probably that when roads are closed off the displaced traffic simply takes longer routes and hence does more miles.
But the Council is fighting back with plans to divide the city into six districts from next August with strict rules on how often motorists can drive outside their neighbourhood. Everybody who owns a car would need a permit and if they drive into an adjacent district more than a few times per year they would get fined.
This must be one of the most extreme anti-car measures implemented anywhere. A YouGov poll suggests that most people support these measures. But like all such polls the questions posed are misleading. Most people, including car drivers, would like less traffic but they are opposed to closing roads, particularly the ones they use.
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It’s in the name of creating “Clean Air Neighbourhoods”, but it includes such nonsense as “It will repurpose street space to be used by the community for play streets, community theatre and resident-led events such as street parties”. Roads are for transporting people and goods, not for playing in.
The report claims that “Long term exposure to man-made air pollution in the UK has an estimated annual effect equivalent to 28,000-36,000 deaths”. This is simply a lie. In addition decisions are being delegated on this to council officers so there will be no democratic input on the details or prior consultation before they are imposed. The crucial words “traffic access restrictions” are buried in a list of measures under the totally misleading title of “Clean Air Neighbourhoods Programme”. It is gridlock by stealth and every ward is affected.
Lambeth Council will make an investment of over £16 million to encourage residents to give up their cars and make sustainable travel choices. This is part of an “Air Quality Action Plan” (see https://love.lambeth.gov.uk/draft-aqap-consultation/ ).
It includes a comment that “Each year in Lambeth air pollution kills more than 100 Lambeth residents and causes hundreds of hospital admissions”. How do they know? There is no link between deaths from respiratory diseases or hospital admissions and background air pollution from man-made sources or any others.
The plans include protected cycle lanes, more bike storage facilities, new walking routes, more electric vehicle charge points and implementation of Low Traffic Neighbourhoods (LTNs).
Make sure you respond to the above consultation and oppose LTNs.
Islington has already implemented similar policies to the anger of many locals. It is reported that someone who lives there and had a simple journey to take her elderly mother to regular medical treatment now takes an hour, when it used to take 10 minutes! After school activities are rendered impossible. Cab drivers won’t go there and established local businesses have been forced to close.
It’s worth pointing out that all these LTN schemes typically enable the local councils to generate cash from fines on infringements. They are mainly about profit generation and hence the incredible claims made about the impacts of air pollution.
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A Judicial Review is a legal process that enables you to challenge decisions by central or local Government bodies or where the law may have been applied incorrectly by tribunals or other courts. It has been widely used of late by environmental lobbyists to challenge planning decisions but it can also be helpful on motoring issues. For example applications for judicial reviews have been made over Low Traffic Neighbourhood (LTN) schemes claiming they are in breach of the Equality Act, breach other legislation or failed to apply the Regulations correctly. There can also be challenges over the failure to consult fairly when consultation is legally required on proposals before implementation. See this blog post written last year for some examples and possible legal grounds over LTNs: https://freedomfordrivers.blog/2021/01/27/legal-actions-against-ltns-escalating/
But they are not always easy cases to pursue because they are not judged on moral principles but simply on the legal technicalities. Cases can be thrown out before they are even heard by judges if they are not handled correctly and do not meet certain criteria. For example cases need to be raised as soon as possible after the issue comes to the attention of litigants or at least within 3 months.
A recent publication by the Courts and Judicial Tribunal entitled “Administrative Court Judicial Review Guide” is exceedingly helpful in explaining what is required and the process that must be followed – see link below. It even explains how “litigants in person” are supported if you do not wish to pay for professional legal representation yourself. And it covers the issue of costs which must be taken into account which litigants may need to pay (and the defendants costs if you lose the case).
Costs can vary wildly. For example this writer has been involved in two judicial reviews. The first was a challenge to the suspension of a hearing in a magistrate’s court on an alleged motoring offence when a key prosecution witness failed to turn up. This cost me less than £2,000 in court fees and my own solicitor’s fees. The case was referred back to the magistrate’s court when the witness again failed to appear so the case was abandoned.
The other was the challenge to the Government’s nationalisation of Northern Rock where legal costs of both sides were several million pounds. The court refused to overturn the decision in parliament by Labour MPs to force nil compensation to shareholders.
One can apply for a “cost cap” to stop the defendants running up enormous bills which Government bodies and Councils can otherwise easily do. And note that if a claim is over an environmental issue then the Arhaus Convention can be invoked to limit costs further. See the Guide in Section 25 for more details.
Although it is possible to pursue a judicial review without legal representation I would recommend that people contemplating a judicial review do take some advice from solicitors familiar with the process. It is particularly worth noting this statement in the Guide: “In judicial review proceedings, the Court’s function is to determine whether the decision or conduct challenged was a lawful exercise of a public function, not to assess the merits of the decision or conduct under challenge. It is therefore seldom necessary or appropriate to consider any evidence going beyond what was before the decision-maker and evidence about the process by which the decision was taken – let alone any expert evidence”.
In summary judicial reviews can be a useful tool for those challenging decisions of a public body but you need to adhere to the rules laid down by the courts including the timescales. The Guide is very helpful in that regard.
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Low Traffic Neighbourhoods (LTNs) have been justified on the basis that they reduce traffic and encourage more active travel (walking and cycling). The main evidence used to support this claim is a report prepared for and paid for by Transport for London. It was written by Dr. Rachel Aldred et al – see link below.
Dr (now Prof.) Aldred from the University of Westminster has written extensively on the benefits of active travel schemes, was actually a trustee of the London Cycling Campaign (LCC) when the report was commissioned and her work has been funded by TfL. The Mayor of London does of course have a policy to encourage more active travel and has been funding LTN schemes. In summary therefore both the commissioning organisation and the researchers were not independent but had an in-built conflict of interest in the outcome of the research.
The report is a “longitudinal” study of three London boroughs – Enfield, Kingston and Waltham Forest over the years 2016 to 2021. The results are based on survey respondents who lived in the area.
How were the survey respondents recruited? Initially by random household sampling but after a very low response rate they added people from TfL databases of Oyster users and cyclists. Hardly an unbiased sample!
Were there actual changes in travel behaviour during the phases of the study? There were reported reductions in minutes of car travel in the past week but also reductions in minutes of cycling and walking. But this was a period when the Covid epidemic was rampant and there was much more working from home, and avoidance of travel in general.
Were the changes in travel modes statistically significant anyway and were there adequate control groups? We do not know.
In summary this report is quite useless as a scientific study of the impact of LTNs.
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A report in the Daily Telegraph has covered the increasing delays to fire engines due to traffic calming measures. That includes the impact of LTNs. To quote from the report: “Analysis of the latest data published by the London Fire Brigade show firefighters experienced slowed response times 3,035 times, equivalent to 253 each month, due to “traffic calming” measures”.
Hackney and Lambeth boroughs were the most badly affected with increases of 66% and 92% in such incidents.
Such events are regularly reported to us and on social media so it is not surprising that the data now shows the problem, although the Fire Brigade say they are still meeting their response targets.
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Before Christmas Transport for London (TfL) published its 14th Report on Travel in London. It’s basically a collection of data on transport trends in the capital. At 263 pages I’ll only provide a brief summary of some of the key points here – see link below for the full report.
Pandemic Impact
The Report includes data showing the impact of the pandemic. By November 2021 the demand for public transport overall was down to around 70% from pre-pandemic levels. London Underground was 65% and bus demand was about 75%. But road traffic only reduced to about 95% as people chose to avoid using public transport by using private transport (i.e. cars or PHVs) or walking.
Walking actually increased substantially and cycling did increase but mainly for leisure cycling at weekends. Weekday peak commuter travel is not recovering rapidly as there is more working from home, and this is particularly noticeable in central London.
Mode Share
The mode share proportion since 2000 is shown in the above chart. You can see that despite the encouragement for cycling in recent years and particularly by the LTNs of late, cycling has remained a very small proportion and any increase during the pandemic was mainly for leisure.
To quote from page 11 of the Report: “The overall active, efficient and sustainable mode share for travel in 2020 is estimated at 58.3 per cent, compared to 63.2 per cent in 2019”. That includes walking, cycling and public transport use, although why public transport should be considered “sustainable” is not clear. But clearly the effect of the pandemic has been to frustrate the Mayor’s objective to get us all out of our cars and increase “sustainable travel” modes to 80% by 2041. In fact, the active travel mode objective of 20 minutes per day (walking/cycling) for 70% of the population has instead fallen to 35% in the latest quarter probably due to less by those working from home.
Air Pollution
The Report contains some data on air pollution some of which comes from road and other transport of course. But it shows how air pollution has been substantially reducing in the last few years. One interesting comment in the Report is that “The Mayor’s Transport Strategy set a target for London to be a zero carbon city by 2050. However, the Mayor has recently called for this to be brought forward to 2030, recognising the importance of the climate change emergency we face”. That’s news to me. So a diesel/petrol car bought this year might be banned in eight years time if the Mayor has his way!
London’s Population
The good news is that limited data suggests the population of London has decreased with significant reductions in international inward migration. The pandemic has deterred international travel while Londoners have moved out to homes in the country and there may have been some “excess deaths” from the pandemic.
Low Traffic Neighbourhoods
The Report comments on the Low Traffic Neighbourhoods (LTNs) on page 123 but the data reported is very selective and biased. They conclude with this statement: “In summary, LTNs have a wide range of different and interconnected impacts but the evidence suggests that these are largely positive and that it is in the longer term where most of the benefits become apparent. Therefore, TfL shall continue to support and, where appropriate, conduct further research for a complete and thorough evaluation of LTN impacts”. It seems they have not yet accepted that the majority of residents do not support LTNs as is clear from recent surveys and public consultations in local boroughs, Lewisham being the latest one which we will comment on later.
Traffic Congestion
A section of the Report covers traffic congestion (pages 143 on). It reports that over the last decade “A slow but generally consistent trend of reducing traffic volumes in central and inner London…”; “Traffic volumes in outer London have, however, grown over this period; and “Generally lower car traffic, higher freight traffic, particularly LGVs, and dramatic changes to the numbers of private hire vehicles”. But this comment shows the impact of the Mayor’s policies: “Continued reductions to the effective capacity of London’s roads, generally reflecting other Mayoral priorities such as reducing road danger, requiring enhanced operational management of the road network”. Yes as we all know, London has become more congested in the last few years due to damaging policies.
There has been an allegation widely reported that traffic on minor roads in London has increased substantially in recent years but the Report contradicts that. It says: “Notably, the volume estimates for London’s major roads remained broadly unchanged, and there was no evidence of an (observed) increasing year-on-year trend in minor road traffic from available independent data over the preceding decade”. It seems the claimed increase might have been an aberration based on misleading statistical data.
How do you measure traffic congestion? One way is by traffic speed but that can be misleading. The best way is to look at “excess delay” which compares actual travel time versus that under “free-flow” conditions. The Report actually shows some data on this which is the first for some time to my knowledge. The chart below shows congestion worsening from 2010 and particularly in the period 2015-2019, but a big improvement thereafter as travel generally was reduced due to the pandemic. But it is still worse than ten years ago!
In conclusion, the Travel in London Report does contain some very interesting data, albeit distorted by the pandemic as travel patterns and volume changed. But it shows how defective has been the Mayor’s Transport Strategy as people have resisted change to modes while road capacity has been reduced.
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There was an interesting article in the Sunday Telegraph on 10/10/2021 over a complaint to the Local Government Ombudsman (LGO). This was a complaint on how two Low Traffic Neighbourhoods (LTNs) had been installed in Hounslow without proper consideration of the impact on older residents. The complainant who is aged in his 70s said he relied on his car to take shopping home and road closures obstructed the route.
The LGO upheld the complaint to the extent that the local Council had failed to produce evidence to show they considered the potential impact of the proposals and criticised some aspects of the decisions by the Council. But it appears that the only result might be an apology from the Council to the complainant although one of the road closures complained of was subsequently removed.
Comment: This is a typical example of the outcome of any complaint to the Local Government Ombudsman. I advise people not to waste their time on such complaints but to threaten legal action. From past experience the LGO seems to favour councils and rarely upholds complaints in full or gets action taken. The LGO is a very ineffective organisation probably because many of its staff are former local government officers.
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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.
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Our new Mayor of London, Sadiq Khan, has issued a tweet that spells out his priorities. This is what he said:
Okay—here’s the plan:
🔨 Create + protect jobs 💰 Help businesses grow 🌳 Tackle the climate crisis 🏠 Build new homes 🚓 Invest in policing 🎬 Create opportunities for young people 🏆 Celebrate diversity 💪🏽 Root out inequality ⚽ Deliver an amazing Euro2020
<END>
These are all fine words, but rather like the Government’s policies as outlined in the Queen’s Speech, rather short on detail. It also contains phrases like “celebrate diversity” that are not just meaningless, but do not lead to specific actions or budget allocations. Many people would argue that there is too much diversity in London and that leads to social incoherence, and why should the Mayor be spending time or money on celebrating it anyway? We all know that the population of London is now very diverse and we have all come to accept that. So what is there to celebrate?
One big issue is certainly the comment that he plans to “Tackle the Climate Crisis”. Is there one? If you look at many London boroughs who have introduced Low Traffic Neighbourhoods they have justified this on the basis of tackling climate change. They argue that it is important to cut emissions from vehicles when doing so will have minimal impact on the climate. Climate may be influenced by man-made emissions (although some dispute that) but cutting vehicle emissions in London will have a negligible influence. Emissions in London come from many different sources and directly relate to the population of London and their requirements for buildings, heating and transport. The Mayor’s policies imply more businesses, more buildings to accommodate them, more homes for the workers and more infrastructure to support them so this is all contradictory.
Only if the Mayor adopted a policy of reducing the population of London while providing more infrastructure – particularly in terms of transport – would the environment be improved.
New York, New York
It’s interesting to look at another major city which has similar transport problems – a heavily congested road network and a public transport system in deficit. Just like the impact of the Covid epidemic on the budgets of Transport for London, New York is facing a major problem. The Metropolitan Transportation Authority (MTA) budget (which covers the subway and some bus services and is equivalent to TfL in London) is projecting a deficit of $16 billion for the period 2020 to 2024, even after major cuts in services.
New York is planning to introduce congestion charging to cut traffic and of course generate some income for the MTA – as much as $15 billion by charging $10 to $15 dollars per day for those entering Manhattan. But the adjacent state of New Jersey, from which many people commute into New York City, is threatening retaliation. Senator Laguna and Assemblyman Tully are developing legislation that would impose tolls on non-residents driving between New Jersey and New York. Mr Tully said “We should not be used to fund the MTA”.
This is equivalent to Essex or Kent imposing a tax on Londoners who drive into their counties if Sadiq Khan imposed a toll on those who drive into London from outside the M25 – as he is proposing. This is surely a very good response to such a threat!
County Councils that border the M25 should surely be asking the Government for such legislation, or asking the Government to stop this taxation without representation.
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The London Borough of Harrow is to remove cycle lanes and Low Traffic Neighbourhoods (LTNs) after a formal review and public consultation.
LTNs in the Headstone South, Francis Road and Vaughan Road schemes were opposed by between 65% and 80% of respondents to public consultation. The Council also claimed they increased congestion, increased air pollution and delayed emergency services.
The decision to remove the schemes was taken at a Cabinet Meeting on the 29th April. This is what the Leader of Harrow Council Graham Henson said:
“It is clear from the statutory consultation undertaken over the past six months that there is little support for the cycle lanes and low traffic neighbourhoods implemented as part of the national initiative.
And so, the decision to remove these experimental schemes is the right one for Harrow – we will keep residents informed about when this will take place.
We have listened to and understand residents’ concerns about how the schemes were implemented. Going forward the council will do things differently – engaging with our residents to shape projects before they are implemented.
We have some difficult decisions ahead of us to make our streets safer for all road users and reach our Climate Emergency pledge to lower emissions in the borough and be carbon neutral by 2030 but we will approach this challenge together in partnership with our residents.”
The Council is still persisting with their plans for School Streets.
Comment: Harrow Council is Labour controlled but by a slim majority over the Conservatives. It is remarkable how quickly the above decision was taken and it seems clear that the public opposition to the schemes had a big impact on the views of Councillors. It is good that Councillors did pay attention to the views of their electorate unlike in other London boroughs where dogma has overridden common sense.
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