Social justice for all on our local streets
Disastrous launch of 'West and East' LTN leaves pedestrians, cyclists and drivers vulnerable to dangerous turning
A launch of West and East Traffic Management Scheme went ahead on 27 November 2024 without mandatory signage in place, and lacking Department for Transport-approved safety measures. Greenwich Council admits signage blunders and dumping safety measures, but went ahead with the West-East scheme over a chaotic six-week-long catalogue of errors.
Greenwich signage: misleading blue badge symbol scrapped before the scheme started
A bungled last-minute signage roll-out on the 27 November commencement date meant that only a proportion of official notices about the LTN, signalling the existence of a barrier used at all ANPR controlled road blocks, were erected before the end of the day. They included the blue disability badge symbol. Badge holders were misled into believing they could pass through ANPR barriers without penalty. It is not lawful to commence an Experimental Traffic Order without all signage in place, (a regulation that the Courts are unlikely to enforce giving local councils the benefit of the doubt).
At the full Council Meeting on 4 December 2024, the Cllr Averil Lekau, Cabinet member for Climate Action, Sustainability and Transport, conceded to Cllr Matt Hartley during Member’s questions that use of the symbol lacked ‘clarity’ and was ambiguous. But Cllr Lekau nevertheless tried to explain it away stating the symbol "suggested" to drivers that they should make an application for personal exemption based on possession of a badge.
A wholesale coverup of all the symbols with adhesive white tape over the Christmas holiday, tacitly acknowledged the blue badge blunder. The last symbol disappeared on 8 January, six weeks after the actual 27 November commencement date.
An accident waiting to happen: new government safety measures to be put 'on hold' during the trial unless there is 'evidence of safety need'
Safety does not come first for Greenwich Council, according to Cllr Lekau's confused explanations for failures to implement mandatory safety measures, including a scrapping of Department of Transport safety measures and warnings.
Seventy separate withdrawals of resident parking places and increased ‘no waiting’ measures were the subject of additional Experimental Traffic Orders made on 20 November (none of which was advertised or consulted on in advance).
These measures were explained by Cllr Lekau at the 4 December Council Meeting as being “designed and installed to comply fully with national road safety regulations.” She also said that any modifications required to meet the specific need of this scheme had been authorised by the Department for Transport (DfT), to ensure the signs meet both national standards and the unique requirement of the scheme."
But answering further questions, Cllr Lekau - while affirming that the measures were to “ensure safe and efficient vehicle navigation in areas where traffic restrictions are being enforced” - contradicted this, and her previous statements, by saying that “the Council has decided to put these works on hold during the trial period” in order to monitor “traffic behaviour” and turning movements “under real-world conditions”. She then said the measures were “unnecessary disruptions to parking availability for residents and businesses”.
Both East and West Greenwich LTN schemes lack ‘advance’ signage warnings, which means that drivers reach ANPR barriers beyond the point of safe avoidance or diversion. Almost all filters and bus gates are ‘invisible’, causing unsafe three-point turns in narrow roads, and making vehicle encroachment on pavements inevitable. Correspondence from Greenwich traffic management officially claims that signage would: “be strategically positioned at all key entry points to the enforcement sites to ensure maximum visibility for drivers” (response to legal enquiries). This is not the case.
Earlier attempts to sign ‘dead end’ streets failed through incompetence – with the first two weeks in December seeing the erection of ‘no motor traffic at any time’ signage, closing several streets in the area permanently, 24/7, and then being taken down.
The Council’s confusion on safety was graphically in evidence at the 4 December Council Meeting – veering wildly between different versions of the Council's safety policy in the space of minutes.
As a result, no street is safe, while Council trials it without safeguards unless ‘evidence indicates’.
Just one example is the walking route of primary school children at James Wolfe School in Royal Hill at the Royal Place junction, where an invisible ANPR barrier marks a 360 degree three point turn for pink zone drivers and a compulsory right turn for approaching blue zone drivers. Governed by a single sign right on the junction, invisible on either approach, near-miss incidents area daily occurrence.
Greenwich signage: misleading blue badge symbol scrapped before the scheme started
A bungled last-minute signage roll-out on the 27 November commencement date meant that only a proportion of official notices about the LTN, signalling the existence of a barrier used at all ANPR controlled road blocks, were erected before the end of the day. They included the blue disability badge symbol. Badge holders were misled into believing they could pass through ANPR barriers without penalty. It is not lawful to commence an Experimental Traffic Order without all signage in place, (a regulation that the Courts are unlikely to enforce giving local councils the benefit of the doubt).
At the full Council Meeting on 4 December 2024, the Cllr Averil Lekau, Cabinet member for Climate Action, Sustainability and Transport, conceded to Cllr Matt Hartley during Member’s questions that use of the symbol lacked ‘clarity’ and was ambiguous. But Cllr Lekau nevertheless tried to explain it away stating the symbol "suggested" to drivers that they should make an application for personal exemption based on possession of a badge.
A wholesale coverup of all the symbols with adhesive white tape over the Christmas holiday, tacitly acknowledged the blue badge blunder. The last symbol disappeared on 8 January, six weeks after the actual 27 November commencement date.
An accident waiting to happen: new government safety measures to be put 'on hold' during the trial unless there is 'evidence of safety need'
Safety does not come first for Greenwich Council, according to Cllr Lekau's confused explanations for failures to implement mandatory safety measures, including a scrapping of Department of Transport safety measures and warnings.
Seventy separate withdrawals of resident parking places and increased ‘no waiting’ measures were the subject of additional Experimental Traffic Orders made on 20 November (none of which was advertised or consulted on in advance).
These measures were explained by Cllr Lekau at the 4 December Council Meeting as being “designed and installed to comply fully with national road safety regulations.” She also said that any modifications required to meet the specific need of this scheme had been authorised by the Department for Transport (DfT), to ensure the signs meet both national standards and the unique requirement of the scheme."
But answering further questions, Cllr Lekau - while affirming that the measures were to “ensure safe and efficient vehicle navigation in areas where traffic restrictions are being enforced” - contradicted this, and her previous statements, by saying that “the Council has decided to put these works on hold during the trial period” in order to monitor “traffic behaviour” and turning movements “under real-world conditions”. She then said the measures were “unnecessary disruptions to parking availability for residents and businesses”.
Both East and West Greenwich LTN schemes lack ‘advance’ signage warnings, which means that drivers reach ANPR barriers beyond the point of safe avoidance or diversion. Almost all filters and bus gates are ‘invisible’, causing unsafe three-point turns in narrow roads, and making vehicle encroachment on pavements inevitable. Correspondence from Greenwich traffic management officially claims that signage would: “be strategically positioned at all key entry points to the enforcement sites to ensure maximum visibility for drivers” (response to legal enquiries). This is not the case.
Earlier attempts to sign ‘dead end’ streets failed through incompetence – with the first two weeks in December seeing the erection of ‘no motor traffic at any time’ signage, closing several streets in the area permanently, 24/7, and then being taken down.
The Council’s confusion on safety was graphically in evidence at the 4 December Council Meeting – veering wildly between different versions of the Council's safety policy in the space of minutes.
As a result, no street is safe, while Council trials it without safeguards unless ‘evidence indicates’.
Just one example is the walking route of primary school children at James Wolfe School in Royal Hill at the Royal Place junction, where an invisible ANPR barrier marks a 360 degree three point turn for pink zone drivers and a compulsory right turn for approaching blue zone drivers. Governed by a single sign right on the junction, invisible on either approach, near-miss incidents area daily occurrence.
|
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.
|
|
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 ...
|
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
|
Sign Up For Updates
