Lewisham Council’s Consultation on the Lee Green LTN

Please make your views known to the Council before 8 August (see https://consultation.lewisham.gov.uk/highways-and-transport/low-traffic-neighbourhoods-ltn/). 

Although the Council is asking for people’s thoughts and experiences of the Lee Green LTN, the online and paper surveys are predominantly asking us to choose between the first and second versions of the LTN, and we are being nudged in that direction by the two maps, various misleading tables, and questions included in the survey. Anyone who thinks that the whole scheme should be completely rethought will need to send in a detailed response separately, or take full advantage of the ‘further comments’ sections.

Respondents’ feedback will be included in a report to the Mayor and Council, and a final decision on the LTN will be taken before the end of the year. Only then, if they decide to make the LTN permanent, will a health and safety study be carried out (see FOI - 6774405). The problem is that their decision will be based on incomplete statistics, as they have little information for the pre-pandemic situation and no statistics for the effect of the LTN post pandemic, when people will have returned to ‘normality’.  

The following questions might help you to make an informed response:

1. Does this particular LTN fulfil its expressed aims?

'to encourage people to walk and cycle more and to do so safely whilst maintaining social distancing; to improve air quality and public health, reduce air and noise pollution and make roads safer.'

While there has been some increase in walking and cycling in some parts of Lee Green, this is probably the result of lockdown, when most people were working from home. Once the pandemic is over, and time is at a premium again, car use may well increase as parents drive their children to various activities, and then the LTN will be properly tested. It has had a minimal effect on social distancing.

Nowhere do we have real evidence that the LTN has resulted in traffic ‘evaporating’ from the area, because Council statistics are mostly pandemic figures. If there’s been no overall reduction in traffic, then the only thing that the LTN has achieved is a displacement of traffic, with enforced longer journeys in slow moving traffic merely creating more pollution. While some roads have become cleaner and safer, much of the traffic and pollution has been moved to the less affluent parts of the borough. This is why clean air campaigner Rosamund Kissi-Debrah has been so critical of the Lee Green LTN.

2. How should we interpret the statistics?

As the Council admits, its traffic monitoring data are far from perfect, yet they nevertheless draw conclusions from them. They deal with averages, which mask fluctuating conditions during the day and do not reflect the real experience of residents, who have been particularly impacted by increased traffic during rush hour.

March 2019 measurements were taken before the LTN and before lockdown; by October 2020 many people were working from home and any reduction in vehicle numbers cannot with certainty be attributed to the LTN.  If fewer cars were due to the pandemic, then the figures will be reversed when we return to ‘normal’. The only reliable set of statistics are those which compare the two versions of the LTN, both broadly taken under similar circumstances.

There are winners and losers in any scheme. If one lives in a leafy street within the LTN (table 1), the statistics show that traffic decreased during the first LTN, but in some cases increased after the November modifications. This is because the first LTN displaced traffic onto the main roads, while the second version shared it out a little more fairly. So table 2 shows that many roads on the periphery of the LTN experienced huge increases in traffic, reduced somewhat by the November modifications. It is unfortunate that Brownhill Road / St Mildred’s Road / Westhorne Avenue (A205), Burnt Ash Road / Burnt Ash Hill and Lee High Road / Eltham Road (A20) are not included in this table and one wonders if residents of arterial roads have been invited to participate in the consultation. We know from experience that LTN1 forced us to make massive polluting detours to get to important locations like the hospital or supermarkets, while LTN2 enabled easier access to some of these venues, thus cutting down some journeys.

The monitoring of car journeys does not give the full picture. While Table 1 suggests that traffic in Manor Lane Terrace decreased under the LTNs, it does not reveal the number of vehicles which had to turn around because of the barrier - especially emergency vehicles, and often at night. This caused considerable noise and pollution to local residents.

Speeding statistics (p. 9) need to be considered road by road, but there is little evidence of cars exceeding the 20 mile an hour speed limit. While speed may have decreased in Ardgowan Road as a result of LTN1, this could also be because traffic was practically at a standstill during rush hour as a result of the surrounding modal filters.

Graph 1 (p.11) is incomplete, but does show that during the pandemic pollution fell, but was increased by the introduction of the LTN (pre-pandemic information is irrelevant here as it does not compare like with like).

3. Does the LTN improve safety?

Research reported in the Guardian (25.3.21), claiming that LTN’s result in fewer road accidents, does not properly take into account displaced traffic onto arterial roads around LTNs. Nor does it accept that there are likely to be fewer accidents when traffic is gridlocked (see the case of Ardgowan Road above). What the researchers did not mention was that slow moving traffic results in more long-term deaths from air pollution.

Emergency services are not in favour of LTN’s and have reported some life-threatening incidents. They particularly recommend removing permanent barriers and key operated barriers, as not all crews carry keys. Blue badge holders and other exempted drivers cannot go through permanent barriers either, and all planters should at the very least be replaced by camera enforced filters if this LTN is made permanent.

The filter on Leahurst Road, at which only one of the three openings is in use, is particularly dangerous. This forces emergency vehicles and disabled drivers to travel in the opposite direction to the main traffic, all through the same opening.

Owing to the way LTN1 was structured, one major incident involving an Armed Police Response Vehicle at the intersection of Burnt Ash Hill and Westhorne Avenue (the South Circular A205) on 20 August 2020 at 10am caused major ‘gridlock’ and nearly resulted in residents being trapped in the LTN, as there were no alternative exits that did not give onto Burnt Ash Road. Although the restrictions on the Manor Park filter were lifted on that day, drivers were unaware of this.

4. What has been the effect of the LTNs on children, the disabled, elderly and frail, home carers, local businesses, public transport, our community?

Some roads within the LTN have become havens for children, while others have become a nightmare. There are potential dangers in encouraging children to play in the street when cars can still use these roads. There has obviously been an increase in the use of parks during the pandemic, yet how is this the result of LTNs, a link implied by questions in sections 7 and 8 of the survey?

Since not all elderly and frail people who cannot cycle or walk long distances are blue badge holders, this category of person has been discriminated against by the LTN. More people use vehicles than just car owners, and many elderly have reported that they were unable to get taxis and reluctant to ask relatives and friends for lifts when journeys which once took 10 minutes were now likely to take nearly an hour: important journeys to get to the hospital, doctor’s appointments, do shopping, etc. SEN transport has also been impacted, and the Council was slow to issue exemptions for blue badge holders.

For some local businesses the LTN has been catastrophic in that it has removed passing traffic, made the transport of goods very difficult, put taxi drivers out of work. Some of the negative impacts were alleviated by version 2.

People offering care in the home, whether professional carers or unpaid relatives and friends, have been prevented from making the usual number of home visits as a result of traffic jams produced by the LTN. Many of these people, along with music teachers, cannot use public transport because of the equipment they carry.

The bus journey times mentioned by the Council bear no resemblance to the lived experiences of individuals and it is not clear how the suspension of buses halfway along a route has affected average journey times. Moreover, supplying averages masks the massively longer journeys experienced by people using public transport during the rush hours, especially when children were attending school. Periods of lockdown/working from home would also have artificially reduced overall averages.

For our community the LTNs have been very divisive, separating Hither Green from Lee Green, pitting the young against the old, the able-bodied against the disabled.

5. Is this consultation fair?

It is clear that some people living within the LTN itself have benefited hugely from the scheme, while others living on the boundary roads have borne the brunt of extra traffic and pollution. Although the Council claims to have leafleted widely during this consultation, some residents within the LTN have not received leaflets, while leafleting on the periphery has been very patchy. This will undermine the validity of any quantitative analysis of survey responses.

6. What pre-existing problems in Lee Green was the LTN supposed to be addressing and what remedies could we suggest?

Prior to the introduction of the LTN, Lee Green was a pleasant place to live, and walking and cycling were safe most times of the day. However, in some streets there was too much through-traffic during rush hours/school drop offs, speeding limits were not properly enforced, there was a lack of pedestrian crossings, poor traffic light phasing, etc. The pollution levels, cases of speeding and number of road traffic accidents were not exceptionally high, but there were definite problems during the rush hour, when sat-nav users from outside the borough would cut through.

These deficiencies could have been rectified by introducing traditional school streets, one-way systems with more effective speed humps, restrictions on HGVs, more pedestrian crossings, better management of crossroads, without the need for a Draconian LTN. If residents decide to keep it, though, then at the very least all permanent barriers should be removed and serious consideration should be given to the use of ANPR to enable residents to move around the ward while dissuading nonresidents from entering the area during the rush hour. If the overall amount of traffic has not reduced as a result of these measures, then it is only right to share out the traffic more justly rather than concentrating it on a few unfortunate major roads.

Any future proposals would need to be assessed post-pandemic, taking account of the wider use of electric cars and the impact of the extended ULEZ, which the Council admits on p. 11 of its leaflet is expected to improve air quality further.

Please make your own views known to the Council before 8 August (see https://consultation.lewisham.gov.uk/highways-and-transport/low-traffic-neighbourhoods-ltn/)

Karen Pratt (Lee Green resident and LibDem campaigner)

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