Re-branding disguises fundamental flaw of the LTN scheme

The 8 March Decision to introduce 2+mile long LTN was stalled by 'Call In' proceedings brought by local councillors. Opposition Leader, Cllr Matt Hartley tabled a comprehensive notice based on 

• a widespread perception that the consultation process was flawed resulting in a lack of public confidence
• 'massive opposition' to the proposals was not taken sufficiently into account in the Decision
• failure to consult on all options 
• failure to take into account the impact on boundary roads and neighbouring areas
• the lack of details for monitoring the impact of the scheme on air pollution before and after implementation

At least four other local councillors requested the call in on the basis that the scheme would benefit from additional hard barriers. 

GGTF and other local groups appeared before the Scrutiny panel on 7 December 2023 to challenge the scheme during a review of the borough's transport strategy. That meeting was attended by Executive member Cllr Averil Lekau, responsible for Climate Change, Environment and Transport, as well as Officers. Scrutiny Committee is a statutory element of Council administration set up to put community concerns to the Council's Executive.
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With OneGreenwich, West Charlton Residents Association and other individuals and community representatives, GGTF questioned the compatibility of the proposals with the strategic goals of the council's transport strategy, and asked for evidence of impacts, including the claim that the scheme would reduce emissions. The Transport Strategy for London and the borough includes efficient public transport and efforts to reduce emissions, among other things. 

​ Cllr Lekau does not admit the overwhelmingly negative responses to the council's consultation on the East West Scheme. However, she appeared to accept that the Council had published a 'campaigning' leaflet in favour of the scheme within days of the closure of the consultation, and long before any Council scrutiny of the public response.  
 
The Officer’s report accompanying the 8 March Decision has published official figures of the full extent of opposition revealed by the August-September 2023 online consultation. But in recommendations for the Council’s decision to go ahead with the scheme, misleadingly states there is 'support' for the scheme without indicating that this is only based on minority consultation responses, and fails to give weight to majority views. 

The consultation was in two stages, the first of which did not discuss any scheme. The outcome of the first stage – indicating that the community wished to see speed control and conservative traffic control measures, such as raised tables – has been flatly rejected by the Council as ‘too expensive’.

The 8 March Officer’s report explains the introduction of the 2020 ‘Hills and Vales’ LTN as obeying Government requests to ‘make significant changes to … road layouts to give more space to cyclists and pedestrians’, § 4.9.  Neither that scheme, nor the present scheme provides any such additional space.  

A major plank of the challenge on 31 July is that the Council took the decision to bring in the scheme before consulting. This and other paragraphs in the 8 March Decision report indicates that the decision had already been made as long ago as 2022 in breach of Consultation rules.
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The Officers’ Report admits that the present decision had already been made in principle as part of the decision to remove the disastrous 2020 scheme: ‘The subsequent decision to approve the removal of the West Greenwich LTN … by allowing the ETO [Experimental Traffic Order] to expire also authorised Council Officers to “begin the process of developing an alternative LTN traffic scheme for West Greenwich”.’

The Council has never offered any evidence for the proposed changes in terms of traffic flow, pavement and roadspace for cycling and walking or objective information on emissions control – all of which have been offered as justifications for the scheme. 

Scope of the decision. Section 5 of the Officers’ Report to the 8 March Decision lists the ‘Available Options’ as:
1. ‘To trial and commence statutory consultation on Option A as an experimental traffic order [ETO] for West and East Greenwich as proposed in the Stage 2 Consultation.’ 
 
2. To amend the proposed trial scheme* and commence statutory consultation on Option A as an experimental traffic order [ETO] for West and East Greenwich areas. *(see 1 above)
The Amendments would be:

- replace hard closures with ANPR ‘wherever feasible’ 
- to allow ’exemption permits or unrestricted access’ to Blue Badge /organisational blue badge educational needs transporters, and exemptions, on application, on the grounds of ‘individual circumstances’.

- Unrestricted access for private hire vehicles

- Part time operation of the scheme.

3. To make a different set of amendments to the core proposal (Option 1) including all of the above exemptions plus a scheme to “allow residents of the scheme areas to purchase a permit exempting them from camera enforced restrictions” at a similar price to a residents parking permit.

4. Withdraw the proposals.

Of these options, Option 2 was ‘recommended’. The Council has decided that this will be carried out under an Experimental Traffic Order, allowing the new LTN scheme to be put in and consultation to be held later during the experimental period of (initially one year). 

In West Greenwich, the 2020 Scheme was introduced under an ETO, and removed in February 2022, with a Council decision NOT to convert the experimental scheme into a permanent TRO.  This means that a permanent traffic order was rejected by the Council. There is no legal provision to reintroduced a new scheme after such a decision. But the February decision included authorisation for officers 'to begin the process of developing an alternative LTN traffic scheme for West Greenwich'.  

Having discontinued the 2020 West Greenwich ETO in 2022, no objective evidence has been offered for creating another LTN. Statutory objections to the 2020 scheme were ignored and in its 2022 decision report, the Council failed to cite them. New Government Guidance reminds Councils that ETOs must adhere to the requirements of section 14 of the Road Traffic Regulation Act. Broadly, this means that traffic measures must be aimed at making the roads safer, and must not hold up bus routes.

Under Section 7 "Reasons for Recommendations" the Officers state that “From the results of the consultation exercises … there is support for the overarching vision of creating a more liveable environment with less through traffic, and better air quality.”  This support was numerically drawn from a small minority of consultees. In its analysis of the Consultation results, the Council emphasises minority views, failing to take account of cogent concerns.

GGTF says:

• There is ‘support’, but only among a minority of local residents.
• There is no evidence the scheme will produce ‘better air quality’, or who – if anyone – would be the beneficiaries.
• Five ‘significant concerns’ are listed under 7.2 – none of which are answered.

The report admits (§7.5) that “Allowing applications for free individual circumstance exemption permits … carries risks. It is likely to be more onerous to administer and could leave the Council open to challenge due to its subjectivity. It is hard to predict how many people would be eligible and how this may affect traffic reduction benefits arising from the scheme.”

This meeting is open to the public, and likely to be recorded via Council Youtube. Local residents' and other groups are likely to request the opportunity to put argument to the Council's Scrutiny Committee.

​Grounds for a Call In, and the outcomes available are limited. A Call In can result in:

• noting, and no further action being taken
• referring the decision back to Cllr Lekau for reconsideration
• referring the decision to Full Council if the decision 'is contrary to the Policy Framework or contrary to or not wholly in accordance with the Budget'.

 
All members of the public may attend the Scrutiny Committee, and could be permitted to speak by the Committee's Chair.  To find out more, navigate on the RBG web site to Meetings and Committees, and Scrutiny committee.
To find the Decision of 8 March 2024 and supporting documents, navigate the Royal Borough of Greenwich website to find 'Decisions' or 'Committee Meetings' and use the calendar to identify the Decision of 8 March 2024.