This letter can be blocked, pasted and sent to the Chief Executive of Greenwich, with copies to local councillors, the Government and others that might be interested.
Ms Debbie Warren
The Chief Executive
Royal Borough of Greenwich
Woolwich Town Hall,
Wellington Street,
Woolwich SE18 6PW
[email protected]
date
Dear Ms Warren,
The proposed Westcombe Park and Maze Hill Area Low Traffic Neighbourhood
I am writing to make a formal complaint about the recently announced proposal for Westcombe Park and Maze Hill Area Low Traffic Neighbourhood.
1. Information on the Council’s website is wrong and misleading.
The suggestion, from a photo on your website and Facebook page, that the proposed LTN will allow children to play in the roadway (among other things) is irresponsible and wrong. The area will continue to be accessible to vehicles of all kinds, except that they may have to cover more mileage to reach their destinations, posing greater risks and causing more pollution. LTNs prevent, impede and displace traffic.
There will no change to the pavement area already available for walking and the use of wheelchairs. Traffic restrictions of this magnitude will not make the area any better for walking or cycling than less drastic measures.
There is no evidence that traffic has been “made worse by people driving during the pandemic”. The reverse is true. Traffic has declined significantly throughout inner London during 2020 in comparison with traffic levels in 2019. The Pandemic has reduced not increased traffic.
Traffic rose from 20 August 2020 on Maze Hill and other parts of East Greenwich because vehicles were displaced following the introduction of a similar scheme in West Greenwich. This displacement resulted in measurable increases in traffic in East Greenwich, extending to Trafalgar Road (A206), and Blackheath Hill (A2).
Your explanation suggests that all vehicles that would normally to cross the route of the new barrier are ‘rat runners’, an offensive term that does not apply to the great majority of road users.
There is no definition of the ‘car-led recovery’ your Authority refers to. There are indications that more people might work from home, and that some businesses will have a shorter working week, so that speculation might equally point to a further natural reduction in car traffic. Your information is speculative, tendentious and not evidence based.
There is no justification for the scheme to be based on the level of car ownership in the borough – people who do not own a car are likely to experience greater delays in obtaining cabs and deliveries as result of the scheme. People who do not own cars will not gain better access to public transport, because of the impact of displacement on bus routes.
There has been no mention of the risks and challenges of cycling or using wheelchairs in an area with steep gradients.
2 . The scheme could cause more harm than good and in law is likely to be judged as disproportionate
The scheme is divisive, unfair and could harm people with disabilities. There is cogent academic research on the social and health impact of displacing traffic from ‘residential areas’ to inadequate 'main' roads with similar numbers of residents who are denied the same advantages.
The Council has failed to provide objective information on what it believes the problems are, such as the source of traffic, or whether it has legitimate business in the area, such as house maintenance, caring work, GP visits, shopping deliveries (which are essential during the pandemic, particularly for vulnerable people), and journeys to work in the locality.
Many people are not able to walk or cycle for reasons of urgency and limitations on their time, their responsibilities for work and family, or because of disability. They may also choose to walk or cycle during their leisure time, and not for every journey.
The scheme is not a proportionate response in comparison with the mischief it seeks to prevent.
If this scheme goes ahead, traffic on the A2 and A206 will grow to unmanageable proportions, not only because of primary displacement out of the Westcombe Park area, but also because it will magnify existing displacement from the West Greenwich Traffic Management Scheme. Two adjacent areas would operate over a two-mile radius, increasing the distance and time taken to cover diversions caused by both Schemes. These will not be ‘slightly’ longer (as described) they will be ‘much’ longer for residents from both areas.
3. Guidance has not been followed
Although not binding, the Council’s failure to adhere to TfL Guidance detracts from the validity of the Council’s claims that the scheme is, in fact, an LTN. The Council is simply creating a barrier in the middle of the area, that will increase mileage and time wasted for local people.
Guidance states that an LTN ‘cell’ should be bounded by ‘robust’ major roads, that is, roads with the capacity for displaced traffic. This is not true of the A2 and A206 which are already congested. People living on the periphery will be at risk from more noise, pollution and traffic danger.
LTN Guidance states that residents should have access to the entire LTN area. This will not be the case.
LTN Guidance states that ‘severance’ points should be made safe for cycling and walking. Journeys to school, work and the shops for most people in the area already involve travel to Trafalgar Road, Blackheath Standard, or farther afield. Nothing in the scheme improves safety for pedestrians, cyclists or wheelchair users (‘wheeling’) to these destinations.
TfL guidance on LTNs provides that local communities are involved in proposals at a formative stage. No such consultation has been held. The current questionnaire made available on the Council’s web site asks questions that are superficial, tendentious and unanswerable.
4. Consultation.
The questionnaire requests opinions about an idealised and non-specific imaginary LTN. It is not a grown up or appropriate consultation. A consultation should canvass all potential impacts of the actual scheme.
Questioning on the ‘affect’ [sic] of through traffic does not admit the possibility that noise, pollution, collisions, and additional traffic can be the result of legitimate local traffic. ‘Feeling unsafe’ is subjective and attributable to a number of causes. The poll begs the question of what a ‘local residential road’ is.
“Have you noticed an increase in rat-running through traffic levels over recent years” implies that respondents can distinguish between through traffic and local traffic, that they are resident in the area, and have made such observations over a long period.
A deadline of 8 March for responses does not comply with accepted consultation norms. An online survey does not guard against multiple or out-of-area responses or casual abuse. It is a poor substitute for empirical and value-free research into the views of people who live in the neighbourhood. There is no indication that the survey applies to the area in question.
The survey is not a consultation. There is no evidence that the survey responses will influence a decision about the introduction of the scheme, or changes to the proposals. The survey is not likely to provide cogent evidence on the impact of the scheme on local people.
No proper notice has been given to people living outside the area who are likely to be affected by traffic displacement.
5. The scheme is not an experiment
Your authority has announced that an Experimental Traffic Order will be made in respect of the scheme. An ETO must be a genuine experiment, and the Council is bound to make public the full terms of the Order and the administrative reasoning behind it.
Please explain why an ETO made under pandemic conditions can provide a valid experiment for a future permanent order.
Yours sincerely,
The Chief Executive
Royal Borough of Greenwich
Woolwich Town Hall,
Wellington Street,
Woolwich SE18 6PW
[email protected]
date
Dear Ms Warren,
The proposed Westcombe Park and Maze Hill Area Low Traffic Neighbourhood
I am writing to make a formal complaint about the recently announced proposal for Westcombe Park and Maze Hill Area Low Traffic Neighbourhood.
1. Information on the Council’s website is wrong and misleading.
The suggestion, from a photo on your website and Facebook page, that the proposed LTN will allow children to play in the roadway (among other things) is irresponsible and wrong. The area will continue to be accessible to vehicles of all kinds, except that they may have to cover more mileage to reach their destinations, posing greater risks and causing more pollution. LTNs prevent, impede and displace traffic.
There will no change to the pavement area already available for walking and the use of wheelchairs. Traffic restrictions of this magnitude will not make the area any better for walking or cycling than less drastic measures.
There is no evidence that traffic has been “made worse by people driving during the pandemic”. The reverse is true. Traffic has declined significantly throughout inner London during 2020 in comparison with traffic levels in 2019. The Pandemic has reduced not increased traffic.
Traffic rose from 20 August 2020 on Maze Hill and other parts of East Greenwich because vehicles were displaced following the introduction of a similar scheme in West Greenwich. This displacement resulted in measurable increases in traffic in East Greenwich, extending to Trafalgar Road (A206), and Blackheath Hill (A2).
Your explanation suggests that all vehicles that would normally to cross the route of the new barrier are ‘rat runners’, an offensive term that does not apply to the great majority of road users.
There is no definition of the ‘car-led recovery’ your Authority refers to. There are indications that more people might work from home, and that some businesses will have a shorter working week, so that speculation might equally point to a further natural reduction in car traffic. Your information is speculative, tendentious and not evidence based.
There is no justification for the scheme to be based on the level of car ownership in the borough – people who do not own a car are likely to experience greater delays in obtaining cabs and deliveries as result of the scheme. People who do not own cars will not gain better access to public transport, because of the impact of displacement on bus routes.
There has been no mention of the risks and challenges of cycling or using wheelchairs in an area with steep gradients.
2 . The scheme could cause more harm than good and in law is likely to be judged as disproportionate
The scheme is divisive, unfair and could harm people with disabilities. There is cogent academic research on the social and health impact of displacing traffic from ‘residential areas’ to inadequate 'main' roads with similar numbers of residents who are denied the same advantages.
The Council has failed to provide objective information on what it believes the problems are, such as the source of traffic, or whether it has legitimate business in the area, such as house maintenance, caring work, GP visits, shopping deliveries (which are essential during the pandemic, particularly for vulnerable people), and journeys to work in the locality.
Many people are not able to walk or cycle for reasons of urgency and limitations on their time, their responsibilities for work and family, or because of disability. They may also choose to walk or cycle during their leisure time, and not for every journey.
The scheme is not a proportionate response in comparison with the mischief it seeks to prevent.
If this scheme goes ahead, traffic on the A2 and A206 will grow to unmanageable proportions, not only because of primary displacement out of the Westcombe Park area, but also because it will magnify existing displacement from the West Greenwich Traffic Management Scheme. Two adjacent areas would operate over a two-mile radius, increasing the distance and time taken to cover diversions caused by both Schemes. These will not be ‘slightly’ longer (as described) they will be ‘much’ longer for residents from both areas.
3. Guidance has not been followed
Although not binding, the Council’s failure to adhere to TfL Guidance detracts from the validity of the Council’s claims that the scheme is, in fact, an LTN. The Council is simply creating a barrier in the middle of the area, that will increase mileage and time wasted for local people.
Guidance states that an LTN ‘cell’ should be bounded by ‘robust’ major roads, that is, roads with the capacity for displaced traffic. This is not true of the A2 and A206 which are already congested. People living on the periphery will be at risk from more noise, pollution and traffic danger.
LTN Guidance states that residents should have access to the entire LTN area. This will not be the case.
LTN Guidance states that ‘severance’ points should be made safe for cycling and walking. Journeys to school, work and the shops for most people in the area already involve travel to Trafalgar Road, Blackheath Standard, or farther afield. Nothing in the scheme improves safety for pedestrians, cyclists or wheelchair users (‘wheeling’) to these destinations.
TfL guidance on LTNs provides that local communities are involved in proposals at a formative stage. No such consultation has been held. The current questionnaire made available on the Council’s web site asks questions that are superficial, tendentious and unanswerable.
4. Consultation.
The questionnaire requests opinions about an idealised and non-specific imaginary LTN. It is not a grown up or appropriate consultation. A consultation should canvass all potential impacts of the actual scheme.
Questioning on the ‘affect’ [sic] of through traffic does not admit the possibility that noise, pollution, collisions, and additional traffic can be the result of legitimate local traffic. ‘Feeling unsafe’ is subjective and attributable to a number of causes. The poll begs the question of what a ‘local residential road’ is.
“Have you noticed an increase in rat-running through traffic levels over recent years” implies that respondents can distinguish between through traffic and local traffic, that they are resident in the area, and have made such observations over a long period.
A deadline of 8 March for responses does not comply with accepted consultation norms. An online survey does not guard against multiple or out-of-area responses or casual abuse. It is a poor substitute for empirical and value-free research into the views of people who live in the neighbourhood. There is no indication that the survey applies to the area in question.
The survey is not a consultation. There is no evidence that the survey responses will influence a decision about the introduction of the scheme, or changes to the proposals. The survey is not likely to provide cogent evidence on the impact of the scheme on local people.
No proper notice has been given to people living outside the area who are likely to be affected by traffic displacement.
5. The scheme is not an experiment
Your authority has announced that an Experimental Traffic Order will be made in respect of the scheme. An ETO must be a genuine experiment, and the Council is bound to make public the full terms of the Order and the administrative reasoning behind it.
Please explain why an ETO made under pandemic conditions can provide a valid experiment for a future permanent order.
Yours sincerely,
