Response to Make Lee Green’s ‘mythbuster’ (part 1)

Local group Make Lee Green have published a ‘mythbuster‘ and FAQ regarding the Lee Green Low Traffic Neighbourhood. Whilst some of their post is correct, there are number of issues we would like to point out.

“Looking at the overall road network those roads that are suitable for carrying non-local traffic (the A and B roads) are identified.”

In our area these so called main roads are not suitable. In many cases they’re no wider than the streets inside the low traffic neighbourhoods – the only difference being one is lined with parked cars. They are also heavily residential roads. In fact our analysis using data from Zoopla suggests there may be more homes on the roads surrounding the Lee Green LTN than on the roads inside which benefit.

See for yourself. One of these, the A205, is actually South London’s “ring road”!

This is not the case in other areas where LTNs have been successful. Compare the “ring roads” in particular. Now these are roads that are suitable for carrying non-local traffic. Ours are more suitable for the horses and carts they were designed for!

Why Lee Green? Lee Green was identified following consultation in 2018 for Lewisham Council’s Transport Strategy as an area where a significant number of residents had responded requesting measures to deal with through motor traffic on the back of another resident lead campaign.

This may have been the original reason for the scheme being kicked off here, but the scheme has not been brought in as per the consulted design – it has specifically been introduced using a temporary traffic order “for reasons related to Coronavirus”.

The Lewisham Council “traffic reduction programme (healthy neighbourhoods)” clearly states that the priority order, with “Lewisham and Lee Green” first, was decided on a number of factors, including:

  • personal injury collisions
  • air quality
  • levels of obesity and deprivation
  • the feedback from their borough-wide Commonplace consultation

More information on the criteria is included in their Transport strategy and local implementation plan (which predates Coronavirus). In this document they list the criteria as personal injury collisions, levels of obesity in an area, air quality levels, asthma levels in the community, levels of deprivation, School Travel Plan (STP) accreditation level, public transport accessibility (PTAL) and car/van availability, LIP public consultation feedback, and pre-existing local community support and action.

Having checked publicly available data we are unable to understand how the Lee Green LTN ‘zone’ could possibly score highly on most of these criteria compared to neighbouring zones. The above comment on the Lee Green blog seems to confirm suspicions that the “pre-existing local community support and action” trumped all other factors, leading some to wonder if the real criteria was which area had the ‘sharpest elbowed’ campaigners.

We have asked our Lee Green councillor to provide the scores for our area and others, but he said he was not privy to this information and referred us to the Highways team, who we have emailed. If we do not get a prompt response we will be forced to waste time and money with a freedom of information request.

“COVID-19 is being used as an excuse to put this in”

It is literally being used as an excuse to put it in, using a temporary traffic order “for reasons related to Coronavirus”. If it is not for reasons related to Coronavirus then its implementation is invalid. The fact there were previous plans is moot – that budget has been halted, and plans changed.

We fail to see how the LTN alone does anything to help with social distancing. As Lee Green themselves point out, the roads are not closed. They haven’t been pedestrianised, you cannot walk down the middle of them. Pavements remain narrow, especially on bin days. Main roads such as Lee High Road are particularly bad for narrow pavements. If anything, the LTN is a distraction from implementing effective Covid Secure measures in the area.

“What is more, less than half of Lewisham households have access to a car (as few as 30% in some wards in the north of the borough).”

This is very true. But it is far from true for the ward which has been selected first for a low traffic neighbourhood! As you can see from the map below, car ownership is high inside the LTN (red) and low outside (green). So the streets with high car ownership get to drive their cars whilst also enjoying quiet streets, whilst traffic builds up on surrounding lower-car owning neighbourhoods – especially to the west – and on to residential main roads.

“Are these schemes going to be made permanent? Although the Temporary Traffic Orders enable the Council to maintain the changes for up to 18 months, it is expected that regular reviews will be carried out by the Council and an initial decision as to the success of the scheme might be reached in around 6 months.” 

The council has not stated what criteria will be used to determine if the trial is a success, despite councillors being asked. They are not measuring the impact on the surrounding main roads to see what the negative effects are. How will they reach a decision on the success of the scheme without proper measurement and clear objectives and key performance indicators?

Why not just deal with the problem roads and leave the rest open? Problem traffic is often concentrated on a few roads within a neighbourhood but simply blocking these just shifts the problem. As many as 80% of London drivers now use Satnavs so will immediately be rerouted around a single closure.”

We’re glad that Make Lee Green recognises that “traffic evaporation” is not absolute, especially in our world of sat navs. We agree that closing roads just shifts the problem. In our case it shifts the problem into other neighbourhoods such as Hither Green West and on to residential main roads.

Some have suggested that the solution is more LTNs, and that the scheme should be extended into Hither Green West. We are concerned that this will just shift the problem, creating even more problems for our residential main roads which were never designed to handle this amount of traffic. The residents of Hither Green also have to deal with the changes TFL are making to the A21 on one of their boundaries, which effectively creates a one-way system for them by making certain roads exit only and preventing certain turns on others. It seems unlikely that TFL would allow Hither Green Lane to be closed to through traffic as a result.

We support LTNs but only as part of a coordinated response to reduce traffic for all, not for a select few – see our mission for more information. We also ask for some modifications to the scheme to allow permitted vehicles such as local residents to use their own streets, via the ANPR as per a similar scheme in Fulham. This would enable the objective of reducing through traffic and ‘rat runs’ to be achieved, without adding even more additional traffic to the surrounding roads by adding unnecessary 2 kilometre detours which may actually encourage residents to shop further afield.

I live in the next neighbourhood – this is just going to make my area worse. It’s simply not possible to change the entire borough at once.”

We agree it is not possible to implement LTNs across the entire borough at once. That is why we are calling on the council to ensure that LTNs for each area are implemented alongside other measures for improving the alternatives. Or for them to consider options which are less of a ‘blunt instrument’ to achieve the goals – especially to enable social distancing.

It is only by improving alternatives which reduce car ownership that long term change can be achieved. For example, we would welcome the careful reduction of on-street parking if it allowed better cycle routes and pedestrian access, and the addition of cycle storage bays.

It’s just for the benefit of a few rich residents.

Here’s the area’s deprivation map (red is high deprivation). Look at the area getting quiet streets, and look where the traffic is being pushed to. Of course there are some pockets of social housing inside the scheme, but these are already on quiet cul de sacs. The main beneficiaries are in dark green.

It’s only going to benefit people who already cycle

We believe the benefit to cycling of closing these particular streets is low. Whilst some streets are quieter, others have always been quiet. There are still cars with local access, delivery vans, and motorbikes, there are still stretches with parked cars on both sides, and there is no cycling infrastructure to protect you. Also, other than a few specific routes, most routes in and out of the area involve having to cycle down one of the busy polluted main roads, even for a short length, which also have little or no cycling provision. It’s easy to see why many people would still not feel comfortable cycling, when we are hemmed in by these roads.

(We did note with interest that one of those specific cycleable routes would be the route through what is now the Lewisham Lee Gren LTN taken by a particularly prominent LTN campaigner who lives outside the immediate area. )

Cycling infrastructure on the main roads may change that. Cycling infrastructure inside the LTN would also help. Sadly due to the train line and River Quaggy any ‘quiet ways’ through back streets would be very indirect, which is a problem when you’re under your own steam, which is why the main roads are so critical in our area.

Emergency Services will be delayed

The College of Paramedics say they worry road closures could hamper 999 emergency response times. Whilst the Lee Green LTN may have involved emergency services consultation as it was an ‘off the shelf’ pre-existing plan, it’s clear some of these schemes are bypassing normal processes under cover of ‘covid emergency’. It’s impossible even for us to keep up with routes (especially given the council has failed to properly update Google Maps with road closures!), so when schemes start interacting – especially the TFL streetscape plans like the A21 – how will emergency services keep up?

Road closures should only be for rush hour and certain times of the day. Filters would need to be designed in an ‘open state’ and would require drivers to obey signs in not passing through them. Evidence shows that compliance with these types of modal filters is low and having camera enforcement on every single filter in this way is not financially viable. “

We were originally told this would not be possible as it would require ANPR cameras, but the scheme has actually been implemented with four ANPR cameras. The trial has been put in using the fewest number of filters possible, and should the trial be successful then we imagine streets would be filtered in different positions eg at each main road junction. That is a discussion for another day.

During the trial it would be acceptable to open only those filters with cameras either to permitted vehicles (as per Fulham) or certain times of day (as per many in Waltham Forest). This would reduce the impact on surrounding main road and gain more buy-in from residents, whilst preventing problematic through traffic.

If the trial is measured correctly and the impact on main roads is below problematic levels, and other objectives such as active travel are not as high as desired, then at a later day restrictions could be further imposed.

Below is a Waltham Forest filter. Note the widened pavements, better signage, and improved pedestrian crossing and road raising.

“Initial figures from the Walthamstow Village area show traffic levels on main roads have increased by between 3% and 11%, but the number of vehicles in filtered roads has decreased by 56%. ” 

The initial figures (better link with actual data) and subsequent updates have not been subject to any statistical rigour and are a classic case of a council marking their own homework.

  1. They note that this analysis “does not represent all roads in the area“. They promised subsequent more detailed analysis “including the impact on the main road network“. However, whilst the detailed analysis has happened, anything about the impact on main road analysis continues is conspicuous by its absence. We have been told by somebody who was given a guided tour by Mini Holland advocates that once the main road traffic is included the picture is more “mixed”.
  2. The before and after were measured over completely different time periods, which would see differing seasonal traffic, for which no adjustment has been made.
  3. There is no attempt to remove the effects of wider trends, eg by comparing against London wide traffic.
  4. They (like Lewisham plan to) have largely only measured roads inside the scheme, and only 12 of them. They measured three surrounding roads, but only in one place which allows for a number of journeys to go un-captured. They did not measure the bordering road to the North.
  5. They have added up counts on roads inside the scheme, which will clearly be counting the same cars twice. It’s hard to analyse routes without the raw data and with most streets missing data, but an example one route heading north-south from Copeland Road saw a reduction of 2556 cars.
  6. Some of comments in the detailed 2016 analysis, that data may have been skewed for a particular hour of the day by a car parked on the counting equipment, seem to suggest that traffic counts on the surrounding roads may have been conducted on a single day. This raises the question whether counts were taken on the same day of the week, and how robust measurement from such a short time period could be. It would leave it open to cherry picking.

Here’s an example of a local journey in Waltham Forest, compared with the roads they counted. As you can see it totally bypasses their three roads even though it seems likely the previous shortest route would have been through what is now the LTN. This which shows why counting traffic over a wider area is critical.

We have seen this in action in Lee Green, where Google Maps is routing traffic as far as Blackheath Village and the Clifton Roundabout to avoid now gridlocked junctions!

Here is a chart covering traffic (in vehicle kilometres) for the whole Waltham Forest borough, using data produced by the Department of Transport, compared against London wide trends. Next to it are the NO2 readings from the nearest continuous monitoring point at Crooked Billet roundabout (in red), overlaid with the average measurements across the whole of London (blue).

We’re not saying Waltham Forest Mini Holland hasn’t been a success and hasn’t massively benefited those inside the scheme. It does seem to have improved active travel, even if there’s no evidence of reduced car use for residents. But remember, this was a scheme which didn’t simply closed roads, there was significant investment in other improvements – and they also have surrounding non-residential main roads that are actually designed to take traffic.

Traffic isn’t just going to disappear – to reduce congestion we need more space for motor vehicles, not less

We completely agree that traffic evaporation is possible. But is it not a given, especially in the long term. According to research it can ultimately result in people moving homes or jobs. And reducing space for some but not for others creates a social justice problem. Note that traffic experts concur with us that improvements to alternatives are required to avoid traffic returning to previous or even higher levels.

That’s all we have time for right now, more will follow….

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