Social justice for all on our local streets
Royal Borough of Greenwich announces 27 November launch for
'West and East' LTN
Greenwich Council is going ahead with the West and East traffic management scheme, presenting a misleading picture of community responses, disregarding government guidance, failing to publish baseline information on pollution and traffic flow, and promising 'concessions' that fail to meet the social care and other needs of vulnerable children and adults.
The scheme threatens to disrupt community and family care networks, damage the local economy and could lead to loss of key workers unable to access schools, nurseries and medical facilities. (Read below on the inadequacy of permits based on the Blue Badge scheme and individual circumstances.)
A letter from Greenwich Council's Transport Team to 'Residents' on 24 October announcing the 27 November installation of the West-East LTN states the community 'worked with' the Council to: 'improve air quality, reduce traffic and make it safer to walk and cycle in west and east Greenwich', claims for which no hard evidence has ever been provided.
In an online consultation on the scheme held in 2023, at least three quarters of consultees registered 'negative' or 'very negative' reaction to it. But the October letter states: 'local people were supportive...' (of the scheme). What the Council describes as 'concerns about elements' of the scheme, led to apparent concessions said to be a 'response ... to feedback' (see below on the Call-In process). Changes made as a result of the Call In challenge included reducing the hours of the scheme from 24/7 to seven 'peak' hours Monday to Friday, and relief from fixed penalties for Blue Badge holders, Special Educational Needs and 'professional' carer transport, and a poorly defined category to be eligible for discretionary relief by Greenwich on application.
During the 2023 'engagement' period, live events were dominated by unanswered requests for evidence supporting the proposals, as well as demands for justice for local businesses, people with disabilities, and others whose essential vehicle use will attract penalties. Concerns about the state of Trafalgar Road and Blackheath Hill, both accident and congestion black spots, have been ignored by Greenwich Council and funding provider Transport for London. No impact statements have been provided, despite existing high levels of pollution and congestion on boundary roads.
The decision to launch follows unfulfilled pledges to consult Charlton residents. And despite requests, Greenwich Council has not produced baseline pollution and traffic evidence to ensure accurate monitoring of the scheme. Greenwich has also failed to produce a lawful Equalities Act Assessment.
The scheme cuts across Council responsibilities for special needs education, social care provision and public health, as well as the economic needs of the wider area, where boundary residents are coping with a degraded environment, increasing dangers to pedestrians and a declining bus service.
The Council has also failed to acknowledge openly Ambulance Service complaints about potential delays to emergency calls resulting from crowded boundary roads. This means that once again, the community will be placed at risk.
The scheme threatens to disrupt community and family care networks, damage the local economy and could lead to loss of key workers unable to access schools, nurseries and medical facilities. (Read below on the inadequacy of permits based on the Blue Badge scheme and individual circumstances.)
A letter from Greenwich Council's Transport Team to 'Residents' on 24 October announcing the 27 November installation of the West-East LTN states the community 'worked with' the Council to: 'improve air quality, reduce traffic and make it safer to walk and cycle in west and east Greenwich', claims for which no hard evidence has ever been provided.
In an online consultation on the scheme held in 2023, at least three quarters of consultees registered 'negative' or 'very negative' reaction to it. But the October letter states: 'local people were supportive...' (of the scheme). What the Council describes as 'concerns about elements' of the scheme, led to apparent concessions said to be a 'response ... to feedback' (see below on the Call-In process). Changes made as a result of the Call In challenge included reducing the hours of the scheme from 24/7 to seven 'peak' hours Monday to Friday, and relief from fixed penalties for Blue Badge holders, Special Educational Needs and 'professional' carer transport, and a poorly defined category to be eligible for discretionary relief by Greenwich on application.
During the 2023 'engagement' period, live events were dominated by unanswered requests for evidence supporting the proposals, as well as demands for justice for local businesses, people with disabilities, and others whose essential vehicle use will attract penalties. Concerns about the state of Trafalgar Road and Blackheath Hill, both accident and congestion black spots, have been ignored by Greenwich Council and funding provider Transport for London. No impact statements have been provided, despite existing high levels of pollution and congestion on boundary roads.
The decision to launch follows unfulfilled pledges to consult Charlton residents. And despite requests, Greenwich Council has not produced baseline pollution and traffic evidence to ensure accurate monitoring of the scheme. Greenwich has also failed to produce a lawful Equalities Act Assessment.
The scheme cuts across Council responsibilities for special needs education, social care provision and public health, as well as the economic needs of the wider area, where boundary residents are coping with a degraded environment, increasing dangers to pedestrians and a declining bus service.
The Council has also failed to acknowledge openly Ambulance Service complaints about potential delays to emergency calls resulting from crowded boundary roads. This means that once again, the community will be placed at risk.
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West Greenwich scheme is on the same pattern as the failed 2020 LTN.* The Council's modification of the scheme, creating mini areas, mostly enforced by financial penalties, may not be lawful or safe. Blocks on deliveries and vital journeys during working hours could have serious consequences. No account has been taken of the dangers of multiple turning at several points on Royal Hill and other narrow streets. James Wolfe School is not 'protected'. Children attending school, or transferring to the Randall Place campus will have to run the gauntlet of traffic movements in the immediate area.
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East Greenwich scheme is opposed by Westcombe Park and Charlton communitiesCharlton wil bear the brunt of traffic outflow from the new LTN. Access to all areas north of the railway line will be barred. This means large outflows of local traffic travelling to Trafalgar and Woolwich Roads - heavily polluted and over-used 'main' roads carrying numerous bus routes.
Greenwich Council ignores requests for vital baseline traffic and pollution monitoring. |
Black dots: existing and new hard barriers (modal filters).
July Call-In resulted in a 'reconsideration' but no fundamental change
A public Call-In meeting held by the Council's Scrutiny Panel on 31 July heard that a consultation held in August and September 2023 was 'flawed', and that evidence demonstrated that the decision maker, Councillor Averil Lekau, had already made the decision on the scheme before considering consultation results.
The Council has proposed concessions, that look set to fail to meet the acute transportation and social care needs of children and adults needing family care to prop up the council’s inadequate social care system. Changes include limiting the hours of operation of the Scheme, and proposing 'concessions' for Blue Badge holders, special educational needs (SEN) transport providers, 'professional' carer vehicles, and a new 'individual circumstances' discretionary exemption. A final decision post Call In was taken on 20 August 2024. (see Concessions ... below.)
Up to 75% of respondents objected to options for the new scheme - designed to 'encourage' walking, wheel-chair use and cycling on the area's dangerously steep gradients, and force local traffic to heavily polluted boundaries - mainly the A2 (Blackheath Hill and Shooters Hill Road) as well as Woolwich and Trafalgar Roads. The options selected from the original consultation are the most environmentally and economically damaging, and those most opposed by the community on consultation.
Consultants PJA warned of lack of safety for cyclists and pedestrians on the area's steep gradients, as well as serious accident levels on Trafalgar Road in 2023 baseline studies - warnings that have been consistently ignored, while Greenwich has failed to take account of the risks to protected minorities, particularly people with disabilities.
Outflows from the Westcombe area will flood Charlton, increasing danger, traffic movement and congestion on Woolwich Road.
Many more local businesses and residents are now in opposition to the scheme due to a continuing failure by the Council to acknowledge the depth of local feeling.
*LTN schemes in the area have been rejected at five public consultations since 2019. A public consultation December to January 2022 rejected a permanent scheme in West Greenwich at the end of an extended 'experiment' and the scheme, which put the community at risk from emergency services access, and damaged local businesses, was removed.
Concessions and the Equality Act
An 'Equality Act Assessment' appended to the Decision of 20 August does not identify risks to protected categories of people, in particular, failing to identify the risks to which the concessionary’ measures are directed.
Significantly, the Assessment has failed to disclose that the authors, traffic Consultants PJA, warned Greenwich in 2023 that the severe gradients throughout the area are ‘likely to be a key barrier for people to walk and cycle’ (ref: PJA, Greenwich east and west neighbourhood management project. Baseline analysis and traffic study (East) p.20). Disability organisations confirm that wheelchairs cannot safely be used on gradients in the area, and cycling organisations agree that gradients of this order can only be tackled by the fittest.
Council modifications fail to take into account these and other risks posed by the ANPR fixed penalty scheme. The Council's new penalty exemptions have been devised as follows:
-one car can be registered for penalty relief to each Blue Badge holder.
-individual circumstance exemption permits: “would be expected to include” a driver with a child “with a condition that means sitting in a car or a re-routed journey causes overwhelming psychological distress”; or with a child, “with a chronic health condition that makes sitting in a car very difficult.”
-a professional carer whose ability to transport a care recipient in a car or directly assist them with their care needs is significantly impaired by an LTN.
-An organisation that solely transports people with access or disability needs.
For parents of special needs children, or adults with disabilities, who may not own a car, or who rely on more than one family member or friend for support, the blue badge ‘one car’ rule may not go far enough to compensate for additional traffic disruption on direct routes in the neighbourhood. Protected categories, such as pregnant women, would not benefit, and those with protected characteristics on the boundaries are ignored.
The structure of the scheme means that all residents use the boundaries, or will be forced to drive through Charlton and other areas forced to accept additional unnecessary traffic. If boundary congestion and pollution increase, many more local residents will be impacted.
The special circumstances scheme appears to be operated at the Council's discretion, and lacks independent oversight.
Government Guidance
Officers' Reports supporting council decisions on 8 March and 20 August to create the LTN rely on distorted emphasis on minority support and lack information on impacts over a wide area. The official Department for Transport Guidance could be breached in a number of ways.
Government Guidance states that schemes must be supported by a representative majority of the community as follows: 'a wide range of views should be sought but especially from those directly impacted or with particular requirements. Via its engagement and consultations an authority should be confident that a scheme is capable of carrying the support of a majority of the community before introducing it'. Further, schemes should not be introduced for penalty revenue.
A Government review found that revenue from fixed penalty notices averaged at roughly £2.3m per scheme each year. The 12 ANPR cameras of the West and East Traffic Management scheme, covering a wide area, could exceed this figure.
Officers' Reports supporting council decisions on 8 March and 20 August to create the LTN rely on distorted emphasis on minority support and lack information on impacts over a wide area. The official guidance could be breached in a number of ways.
A public Call-In meeting held by the Council's Scrutiny Panel on 31 July heard that a consultation held in August and September 2023 was 'flawed', and that evidence demonstrated that the decision maker, Councillor Averil Lekau, had already made the decision on the scheme before considering consultation results.
The Council has proposed concessions, that look set to fail to meet the acute transportation and social care needs of children and adults needing family care to prop up the council’s inadequate social care system. Changes include limiting the hours of operation of the Scheme, and proposing 'concessions' for Blue Badge holders, special educational needs (SEN) transport providers, 'professional' carer vehicles, and a new 'individual circumstances' discretionary exemption. A final decision post Call In was taken on 20 August 2024. (see Concessions ... below.)
Up to 75% of respondents objected to options for the new scheme - designed to 'encourage' walking, wheel-chair use and cycling on the area's dangerously steep gradients, and force local traffic to heavily polluted boundaries - mainly the A2 (Blackheath Hill and Shooters Hill Road) as well as Woolwich and Trafalgar Roads. The options selected from the original consultation are the most environmentally and economically damaging, and those most opposed by the community on consultation.
Consultants PJA warned of lack of safety for cyclists and pedestrians on the area's steep gradients, as well as serious accident levels on Trafalgar Road in 2023 baseline studies - warnings that have been consistently ignored, while Greenwich has failed to take account of the risks to protected minorities, particularly people with disabilities.
Outflows from the Westcombe area will flood Charlton, increasing danger, traffic movement and congestion on Woolwich Road.
Many more local businesses and residents are now in opposition to the scheme due to a continuing failure by the Council to acknowledge the depth of local feeling.
*LTN schemes in the area have been rejected at five public consultations since 2019. A public consultation December to January 2022 rejected a permanent scheme in West Greenwich at the end of an extended 'experiment' and the scheme, which put the community at risk from emergency services access, and damaged local businesses, was removed.
Concessions and the Equality Act
An 'Equality Act Assessment' appended to the Decision of 20 August does not identify risks to protected categories of people, in particular, failing to identify the risks to which the concessionary’ measures are directed.
Significantly, the Assessment has failed to disclose that the authors, traffic Consultants PJA, warned Greenwich in 2023 that the severe gradients throughout the area are ‘likely to be a key barrier for people to walk and cycle’ (ref: PJA, Greenwich east and west neighbourhood management project. Baseline analysis and traffic study (East) p.20). Disability organisations confirm that wheelchairs cannot safely be used on gradients in the area, and cycling organisations agree that gradients of this order can only be tackled by the fittest.
Council modifications fail to take into account these and other risks posed by the ANPR fixed penalty scheme. The Council's new penalty exemptions have been devised as follows:
-one car can be registered for penalty relief to each Blue Badge holder.
-individual circumstance exemption permits: “would be expected to include” a driver with a child “with a condition that means sitting in a car or a re-routed journey causes overwhelming psychological distress”; or with a child, “with a chronic health condition that makes sitting in a car very difficult.”
-a professional carer whose ability to transport a care recipient in a car or directly assist them with their care needs is significantly impaired by an LTN.
-An organisation that solely transports people with access or disability needs.
For parents of special needs children, or adults with disabilities, who may not own a car, or who rely on more than one family member or friend for support, the blue badge ‘one car’ rule may not go far enough to compensate for additional traffic disruption on direct routes in the neighbourhood. Protected categories, such as pregnant women, would not benefit, and those with protected characteristics on the boundaries are ignored.
The structure of the scheme means that all residents use the boundaries, or will be forced to drive through Charlton and other areas forced to accept additional unnecessary traffic. If boundary congestion and pollution increase, many more local residents will be impacted.
The special circumstances scheme appears to be operated at the Council's discretion, and lacks independent oversight.
Government Guidance
Officers' Reports supporting council decisions on 8 March and 20 August to create the LTN rely on distorted emphasis on minority support and lack information on impacts over a wide area. The official Department for Transport Guidance could be breached in a number of ways.
Government Guidance states that schemes must be supported by a representative majority of the community as follows: 'a wide range of views should be sought but especially from those directly impacted or with particular requirements. Via its engagement and consultations an authority should be confident that a scheme is capable of carrying the support of a majority of the community before introducing it'. Further, schemes should not be introduced for penalty revenue.
A Government review found that revenue from fixed penalty notices averaged at roughly £2.3m per scheme each year. The 12 ANPR cameras of the West and East Traffic Management scheme, covering a wide area, could exceed this figure.
Officers' Reports supporting council decisions on 8 March and 20 August to create the LTN rely on distorted emphasis on minority support and lack information on impacts over a wide area. The official guidance could be breached in a number of ways.
Government compensation to pollution victim's family could mean justice for boundary road residents (to follow)
In the October release, Cllr Lekau also refers to high levels of hospitalised babies in the borough with respiratory tract infections and 'one of the highest levels of childhood obesity' in London. No connection of these claims with the scheme has ever been explained. The boundary roads population has a much higher deprivation classification, according to the 2021 Census, as well as higher child counts and greater levels of disability.
Read more...
In the October release, Cllr Lekau also refers to high levels of hospitalised babies in the borough with respiratory tract infections and 'one of the highest levels of childhood obesity' in London. No connection of these claims with the scheme has ever been explained. The boundary roads population has a much higher deprivation classification, according to the 2021 Census, as well as higher child counts and greater levels of disability.
Read more...
Last year's online consultation gave decisive thumbs down to the LTN plan
Last year's plans threatened closures 24/7, while traffic calming to enforce the 20mph speed limit and introduced calming measure were rejected out of hand by Greenwich. Here's how the community reacted to the August 2023 consultation ... Read more...
Last year's plans threatened closures 24/7, while traffic calming to enforce the 20mph speed limit and introduced calming measure were rejected out of hand by Greenwich. Here's how the community reacted to the August 2023 consultation ... Read more...
Lessons of the failed West Greenwich 2020 scheme have been ignored
The Council fought privately to suppress cross borough objections to LTN boundary road displacement, as well as emergency service complaints about delays caused by the barriers. A specialist transport report did not support the Council's analysis of traffic movement, and detailed broader trends that should inform decisions, such as big box retailing on the Peninsula, and London wide emissions actions
Read more ...
The Council fought privately to suppress cross borough objections to LTN boundary road displacement, as well as emergency service complaints about delays caused by the barriers. A specialist transport report did not support the Council's analysis of traffic movement, and detailed broader trends that should inform decisions, such as big box retailing on the Peninsula, and London wide emissions actions
Read more ...
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Boundary road system increases deprivation
Greenwich claims traffic diversion "will be on to the main roads and not into neighbouring residential areas". But the 'main' roads are residential, as are large areas of Charlton where traffic will have to access the Westcombe Park LTN. Forcing ALL vehicles around the boundary has toxic and unfair consequences for those living there. Experts say the worst pollution in the borough is on the boundaries to the scheme. Read more... New government guidance could test the lawfulness of the Council's 8 March decision
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