Act now to respond to the Council's consultation
https://greenersafergreenwich.commonplace.is/
The Commonplace Consultation
Commonplace is a commercial public relations organisation hired by local authorities. The text that supports consultation questions is designed to 'condition' (or unconsciously suggest) your responses. Phrases such as 'GreenerSaferGreenwich' are typical of suggestions intended to make you think the changes will make Greenwich 'greener' or 'safer' than it is now.
Commonplace and similar questionnaires were criticised in the recent High Court judgment given in the West Dulwich Action Group case, as not allowing 'for a response which challenged its fundamental premise'. That is: the consultation questions are based on the effects felt or expressed by consultees that are assumed to relate only to the operation of the scheme. Levels of pollution, or active travel for instance - are assumed to result from the scheme.
The Consultation does not allow consultees to say 'no' or disagree to the scheme: but only to give 'feedback'. In other words, there are reasons for believing there is less pollution, or for reducing or increasing 'active' travel, but they may have nothing to do with the scheme. Nevertheless, you can't say so.
To answer, use the text box to correct the false impressions your tick box answers might have given.
eg: 'I am walking more because I have a different job/the weather is warmer now, and not because of the scheme.'
Commonplace questionnaires confuse facts about the scheme with attitudes towards the scheme.
Tell the Council that the scheme cannot possibly be responsible for reductions in pollution that are all over London, due to ULEZ and the scrappage scheme, and cannot be attributed to one relatively small area, such as a part of north Greenwich.
Tell the Council about your personal experiences in the text box - be they to do with longer bus journeys due to boundary road congestion, delays to buses, missed medical appointments, or difficulties due to disability, such as lack of step free access across the railway line at Maze Hill and Westcombe Park, exacerbated by the scheme.
1. 'How do you feel about pollution/air quality'. Object to questions you cannot answer without expressing an unsupported opinion. This question assumes inexpert individuals are able to measure air pollution, and can pinpoint its whereabouts in relation to themselves, as well as attribute it to the West East Scheme.
Object also that there is no opportunity on the 'menu' of answers to say that you have provided an answer based on belief, guesswork, or the operation of ULEZ:
The London Assembly reports that:
"Cumulatively over a six-year period (2019 – 2024), air pollutant and carbon emissions across London are lower due to all phases of the ULEZ, compared to a scenario without the ULEZ. Specifically:
- NOX emissions are estimated to be 24 per cent lower.
- PM2.5 exhaust emissions are estimated to be 29 per cent lower.
- CO2 emissions are estimated to be two per cent lower.
- In 2024 alone, NOX emissions are estimated to be between 33 per cent and 39 per cent lower across all boroughs than they would have been without the ULEZ and its expansions."
2. Question 4 is limited to 'streets located within the grey marked area on the map as part of the neighbourhood management scheme'. This rules out comments on the boundary roads."For streets located within the grey marked area on the map as part of the neighbourhood management scheme, how do you feel about the following?" The 'Very positive' to 'Very negative' tick box does not allow the whole experience of living in the area. Many of us are likely to have a permanent feeling of positivity of our relatively pollution free road in the protected area (nothing has happened to change that for many), but experience of the boundaries may be 'very negative'. Why not ask us?
3. Question 5, on modes of transport, provides no opportunity to comment on the impact of the scheme on modes of transport used by active travellers as a result of added congestion on the boundary roads - particularly buses, which:
- are the cheapest and most accessible, particularly to those living in poverty or on the boundaries
- have been most affected by the scheme in terms of slower journey times and longer waits.
4. The consultation was launched late during the initial six month consultation phase, reducing access to information, and time available, to consider important questions interactively with Council representatives about the scheme. This limitation of access events is evidence of failure to consult appropriately at every stage, and ignored huge opposition in the 2023 Consultation.
In all, a majority of local people have rejected schemes in these two areas FIVE times since 2019.
5. The schemes are already threatening the viability of local businesses. But approaches to Councillors and consultation events suggest that action might not be taken in time.
6. The absence of advance consultation with schools and local trades and businesses means that nothing was done during planning for the scheme to avoid adverse impacts, and the evidence from responses via in-person meetings is that the problems are being pushed to one side when urgent action is needed now.
7. The Council continues to ignore information provided to them in 2023 in a Baseline Study by their Consultants, PJA. The Study:
- drew graphic attention to the area's steep gradients that are unsafe for wheelchair users and cyclists.
- recorded a lack of accidents within the LTN areas, together with an extremely accident rate involving pedestrians and cyclists on Trafalgar Road and Blackheath Hill, both boundary roads and not part of consultation.
- failed to identify primary schools and nurseries in the area and the risks to child health and safety associated with the planned schemes.
- produced a pollution map of the entire area demonstrating significantly higher levels of pollution, exceeding the UK legal limit, only on the boundary roads. Areas within the boundaries have relatively little pollution.
No studies were made about residents' and businesses' transport needs.
8. Broken promises In May 2022 new Leader Cllr Anthony Okereke said he intended to "put residents at the heart of every decision". The Council had already made official Decisions to remove the 2020 LTN scheme; and to accept the rejection (in a public consultation) of a scheme in East Greenwich. After this, a promise was made within a formal Decision, to review traffic management on a much wider scale. Cllr Okereke and the Cabinet member for transport, Councillor Averil Lekau overrode those Decisions by commencing preparations for the current scheme and did so ahead of any public consultation.
Ask the Council for the the promised review of traffic management borough-wide through a transparent and inclusive process. Deputy Leader Cllr Averil Lekau is Cabinet member for Climate Change, Environment and Transport with direct leadership on transportation for the authority. Throughout the development of the scheme, Councillor Lekau has failed to meet and discuss the real concerns of the whole community, including vital boundary roads.
9. Personal amenity produces the most responses in favour of the scheme: but remember that
- the 'LTN' roads were quiet and peaceful for two years after the removal of the 2020 scheme. Amenity was not compromised by the removal of the scheme.
- more, not less, traffic circulates the area to reach destinations and return via convoluted routes imposed by the scheme.
- there is no measurable clean air gain from the LTN- most of the improvements in pollution have resulted from owning compliant vehicles, via the imposition of ULEZ throughout the London area, and not by preserving an unrealistic level of amenity in tiny sets of privileged streets.
- personal amenity includes access to trades, carers, shops and schools.
- the emergency services' response to the scheme was that clogged boundaries restrict their movement, making us all less safe.
- everyone's access to hospital appointments, family and neighbourly support and efficient public transport.
- Fining local residents arbitrarily, via the scheme, removes rights accorded to other borough residents, is unfair and undemocratic.
10. There are better ways to achieve the same result.
11. Royal Hill contains three ANPR cameras within a few hundred yards. Reopening Royal Hill, together with traffic calming measures and additional crossing points there and in Blissett Street, (measures similar to the existing chicane outside James Wolfe School) would reduce traffic danger from excessive turning, and allow access and deliveries to our vital shops. It would liberate the Circus Street and Royal Hill restricted zones and reduce vehicle movements.
Thank you for backing us up on past actions: they made a difference
Complaints about Council administration
The Local Government Ombudsman has power to step in to put things right and investigate what the local council has got up to. Before you can reach the Ombudsman, you have to start with a formal complaint to the Council.
1. Start with a letter to the Chief Executive, who passes it to the relevant department. (You can send copies of your letter to local councillors.) There’s an example of a West Greenwich Traffic Scheme Formal Complaint on this link.
2. If the complaint is rejected and you can go to a ‘second stage’ in which you ask for a review.
After a review, if you’re still not satisfied, you can then make a complaint to the Local Government Ombudsman. The Ombudsman can investigate the Council and, potentially, put things right.
3. The Ombudsman can take action, or the matter can be taken to Court.
Otherwise … contact us to get updates, to let us know what you think, or write to us to contribute to our blog at [email protected]
