Lewisham council leaflet: the facts

Lewisham Council has dug into its PR budget for a charm offensive, presumably in the face of a huge amount of negative feedback and general disquiet from residents inside and outside of the Low Traffic Neighbourhood, and pushed the glossy leaflet above through local doors.

It’s not yet clear whether the leaflet has been distributed beyond the boundaries of the LTN, but given its intention appears to be to quell concerns about the impact on surrounding areas, you would presume that to be the case. (Update: somebody on Muirkirk Road has just received one, which suggests this is big leaflet drop!).

But how accurate is the leaflet? Is it useful communication or council propaganda to prop up a failing scheme?

The LTNs aim to reduce traffic on all roads, not just on the roads where measures are put in place.

There is no evidence that an LTN can reduce traffic on all roads, even if there is a net reduction overall. Other schemes have seen an 11% average increase on surrounding & main roads, but in schemes a third of the size with less traffic to displace.

How do they do that, exactly? In other schemes, such as the much cited Waltham Forest’s Walthamstowe Village LTN, whilst there is thought to be an overall net reduction in traffic in the area due to “traffic evaporation”, it is absolutely undisputed that main and surrounding roads have seen increased traffic as a result of displacement.

Some roads such as East Avenue saw increases as high as 40%! We suspect this is similar to what we are seeing on roads here such as Hither Green Lane.

From the Waltham Forest Council’s review in 2017:

We looked at the position of all the traffic counters used to analyse the before and after in Walthamstow Village. It is clear there are huge gaps in the monitoring, with several nearby surrounding roads which will clearly be alternative routes not being measured.

In addition to this, the wider main road network was never analysed to see if there was an increase in traffic bypassing the village or heading to alternative locations, despite the council’s promise to do this in 2015. This uncounted displacement will show up as ‘evaporation.

When sharing the results of the counts, Waltham Forest incorrectly totalled up all the small roads inside the ‘village’, and then compared them to the single counts on longer stretches of main roads. This results in significant double or even triple counting, and dramatically flattered the LTN scheme. This situation appears to have been replicated with the Lee Green scheme.

These false figures which claimed 10,000 cars a day were removed from inside the LTN have been quoted in conversations with our council.

By using a traffic analysis technique called “screenlining”, where you measure a single entry or exit point per route, we can eliminate the double counting. Using this technique, it seems the reduction in traffic inside the LTN was half that quoted by the Council – more like 5,000 cars per day.

But the surrounding roads saw an average increase of 11%.

This is likely to be an underestimate as an alternative route on the North side of the scheme, Church Hill, had no baseline traffic counts conducted. Overall this is a net reduction, not including any missing routes, of 2.5%.

Screenline analysis of Walthamstow’s LTN “before” and “after” traffic counts

It’s worth bearing in mind that the Walthamstow Village LTN is a third of the size of the Lewisham Lee Green LTN. This goes against Living Street’s guidance which suggests an area of one square kilometre (walkable in 15 minutes) works best.

The distance created between unfiltered through roads in Lee Green is twice as far as in Walthamstow. Our main roads also get 2-3x more traffic, and we previously had 2x more traffic on roads inside our scheme according to Lewisham Council counts – meaning more traffic is being displaced onto busier roads. It would take you 45 minutes to walk the length of our LTN.

Waltham Forest also has a purpose built six lane ring road nearby, whereas ours, The South Circular, is a two lane (one in each direction) residential road along our stretch, unsuitable for high volumes of traffic.

And remember that the Walthamstow Village scheme came with £30m of investment to encourage active travel, such as street lighting, cycle lanes, bike storage, seating, and pedestrian priority junctions and crossings – not just planters, bollards, cameras and road signs. We have had significantly less investment.

“By creating quieter streets, LTNs encourage walking and cycling, and discourage unnecessary car journeys”.

Simply closing side roads to through traffic does very little to encourage walking and cycling. Main roads are often far more in need of treatment.

Judging from feedback we’ve received from many residents, we’re not alone in wondering whether LTNs do in fact encourage walking and cycling. The pavements are no wider, you still cannot safely pass people at school run times. The roads are still lined on both sides by parked cars, so you cannot step out onto the road.

Nor would it be safe to step out on the road, for whilst there may be less traffic, the roads have not been pedestrianised – if anything, cars, vans, and motorbikes come whizzing down even faster, as they try and figure out their way out of the maze.

It was observed in lockdown that quieter roads meant more speeding.

The lack of enforcement of the 20mph zone featured heavily in the original 2019 ‘consultation’ – but residents were told there was no budget for cameras. We now have four for the LTN, of course. Where there’s a will, there’s a way.

Many cyclists have said they never had a problem cycling through what is now the LTN. However, they needed to cycle along other roads, which are now so busy they’re impassable to cyclists.

One cyclist recently commented “The irony is cycling is pretty much impossible, not to mention dangerous, on the roads surrounding the LTN as there’s just no space left on the road! I had to cycle in the middle on Horncastle and Burnt Ash. In that respect, the changes do not even benefit cyclists.

Several women have reported to us that the quiet streets of the LTN makes them feel less safe at night, especially as it starts to get dark earlier, and many drive for personal safety (which is why the improved street lighting in Walthamstow was so interesting).

We still need School Streets inside the LTN. We still need a cycle lane inside the LTN. We still need to widen pavements inside the LTN. We still need places to store our bikes at home and at our destinations.

And ultimately, anyone who has to catch a bus usually has to walk down or wait on a main road, which is now more polluted. In these Covid times, with limited capacity for social distancing and every other bus allocated to schools, it can be quite the wait too.

If you look at Walthamstow Village, the increase in cycling inside the LTN was hard to measure due to the random nature of bike trips, but it perhaps totalled a few hundred extra daily cyclists. Meanwhile over a thousand cycle on the neighbouring main road every week day. The other Mini Holland schemes in Enfield and Kingston-upon-Thames have until recently eschewed modal filters in favour of concentrating on cycling infrastructure.

As for whether they discourage unnecessary journeys – yes, they probably do. To an extent. But given how horrendous driving in London is, I fear we’ll be surprised by how much London drivers are willing to put up with. It may also back fire and make local journeys less appealing and thus make journeys to destinations further away relatively more appealing – unnecessary or not.

It’s worth noting that the council claimed 60% of through traffic came from outside the area. Now the 40% of traffic which was inside the LTN is also adding to traffic on surrounding roads, in addition to the displaced non-local traffic.

60% of journeys in London are less than 2.5 miles

Note this figure is for ALL journeys in London – it includes public transport, and walking and cycling!

TFL analysis shows that after you adjust for age and disability, heavy or bulky loads and time of day, 22% of car journeys in London could be walked. This is based on data from 2007. It also states that 38% of car journeys could be cycled once adjusted in the same way, but that figure includes the 22% that could be walked.

If you take into account that this is a Greater London figure and that car ownership is much lower in our borough, it is reasonable to suggest journeys here may already be more optimised here than for outer London, and our potential is somewhat below these figures.

It’s not an insignificant amount, but given the council claimed 60% of through traffic was from outside the area, that suggests a maximum of 15% of car journeys being displaced that could be walked or cycled.

That 15% reduction could easily be undone by the remaining journeys having to take a 1-2 mile detour in standing traffic. Or from people choosing destinations further away in the opposite direction because they’re now more convenient.

It would be ironic if the LTN were to reduce the number of journeys under 2.5 miles by turning them all into journeys 4 miles long.

We are listening carefully to the feedback and will make changes in response to this.

The only changes being considered are more closures and more enforcement.

As demonstrated in the examples given, Lewisham Council (and especially local councillors) appear to only listen if the concerns fit their agenda. If you want more enforcement, or more roads closed, then you have their ear. Those seem to be the only changes they will consider.

But if you have concerns about the impact on residential main roads and for example think they need to change the scheme to be timed closures and/or ANPR access to reduce the impact on main roads, you get fobbed off. Ultimately any conversation they don’t like ends with “it’s a trial so we have to wait until the end” or “it’ll bed in”.

We have baseline measurements on traffic volumes and air quality…

The council does not have baselines for traffic volumes outside the LTN on the impacted roads. And air quality baselines for outside the LTN on impacted roads are seriously limited.

The three continuous monitoring sites (Aeroqual AQY – Micro Air Quality Stations) are all inside the LTN on filtered roads. The map produced to show monitoring implies the Manor Lane station is monitoring the main road, St Mildred’s, but it is at least 20 metres from the main road, so will only really be monitoring the junction for cars turning down Manor Lane (for which it’s arguably on the wrong side of the road).

The traffic volumes taken on surrounding roads in “June/July 2020” for 7 days were apparently carried out week commencing 29th June. The planters and road signs were installed week commencing 29th June. This is therefore not a baseline.

It would therefore be useful if the map distinguished which automatic counters have counts from March 2019 and which are counts from June/July 2020, and which have both.

The existing air quality diffusion tubes noted as being installed January 2019 do not appear to be present. It might be they are in the lab for analysis. Their readings are available in the 2019 Diffusion Tube report. It’s not clear if they are still in place to have provided January 2020 results, or indeed January 2021.

Ironically most of the badly affected roads are greyed out on the monitoring map. It would be useful if Lewisham would expand this map to include all the areas which the 2019 TFL modelling identified as being problematic, particularly south of the scheme.

It looks like there is a diffusion tube on Brownhill Road, and on Baring Road. The 2019 report notes that the highest annual mean NO2 concentration in the borough was measured “at the L51 site at 290 Brownhill Road, South Circular (44.9 µg/m3). The second highest annual mean NO2 concentration was measured at LWS017 site at Baring Road (41.0 µg/m3)“. The EU limit is 40.0 µg/m3.

To quote Lewisham Council’s own literature, a baseline should ideally be established from data collected at least three months, but ideally twelve months prior to the trial commencing. Not three months after.

It is expected that it will take time for drivers to adjust their behaviour in response to these changes.

We’re now 12 weeks into what we were initially told was a 2 week ‘bedding in period’. It took four years to see statistically significant changes to car use in Waltham Forest.

Originally councillors talked about a ‘2 week bedding in period’. We’re in the 12th week now! How much time is needed? Six months? A year? 18 months? Four years? Is this based on any evidence? Or the word of some lobbyists?

Studies in Walthamstow Village only started to show evidence of car ownership changing in 2019, four years after the modal filters were added. Until then there was very little difference, with studies showing there were roughly the same number of people using their car more than there were using their car less.

How much damage will be done to people living, working, learning, walking, cycling and waiting for busses on main and surrounding roads now suffering increased pollution and danger in the meantime? How long do we wait until we say “maybe it isn’t bedding in, maybe it’s just not working”?

We are confident that the impact on surrounding roads will ease and we will take steps to ensure it does.

What is the basis for this? Other schemes saw an 11% increase after a settling in period! What steps will the council take?

Why the confidence? What evidence is this based on? Why did a Lee Green councillor confirm that whilst she understood Walthamstow saw a 2-10% increase on main roads (it was actually 2.6-11.1% increase on boundary main roads), that “there is no expected increase for this LTN”?

Why would Walthamstow see an 11% increase and we wouldn’t? Are they over confident that the main roads are at capacity and thus can’t get any worse? Because that didn’t work out well for Hither Green Lane.

Did they do any modelling? Do they actually understand how the traffic flows locally? Some of these issues seem to have come as a surprise to the council, but were obvious for many local residents. Or did they know, but ploughed ahead anyway?

What steps will be taken? In our discussions you seem to have ruled out any compromise to the LTN, despite the recommendations of the EU Commission’s guide to do so. We think trying timed closures and/or ANPR access for Lewisham residents would lessen the impact on the surrounding roads and reduce unnecessary local detours.

But councillors think this won’t make driving inconvenient enough to force ‘modal shift’ to other forms of transport, so they won’t even entertain the idea. The only idea being entertained is to roll out more closures, which will only make our residential main roads worse.

We will be exploring the roll out of similar traffic reduction measures across the borough this autumn, including areas adjacent to the Lewisham and Lee Green LTN.

Two wrongs do not make a right. Expanding the LTN does nothing to solve the problem of traffic displacement onto our very residential main roads, which were never designed for this kind of traffic, and will just push the traffic onto other unsuitable roads in even less affluent areas.

Adding another LTN without addressing the issues caused by the current one may fix a couple of roads, but will continue to push the problem further into even less wealthy areas of Lewisham. And the thousands of people living on residential main roads such as Brownhill Road, St Mildred’s Road and Lee High Road will continue to see worse and worse traffic.

If you think the main roads can’t get any worse, just remember that’s what one Lee Green councillor said about Hither Green Lane before the Lee Green LTN went in!

This is yet another hint that the council have latched on to the “Hither Green West Village” proposal to fix the problem on the other side of the tracks (caused by the Lewisham and Lee Green LTN) by expanding the LTN to include Hither Green Lane.

Whilst a petition to filter Hither Green Lane managed to receive 738 signatures over the last few months, a petition to prevent Hither Green Lane being closed has received (at time of writing) 1,848 signatures and growing at a rate of 100 per day. But Lewisham Central councillors are of course only paying attention to the campaign which fits their agenda – classic confirmation bias.

We are also launching the first phase of our borough wide School Streets.

We welcome School Streets for the benefits they have to child safety but there doesn’t seem to be any evidence they are a traffic reduction measure.

We are pleased to see these School Street schemes starting to roll out. They solve the problem of making the streets around schools safer without causing displaced traffic on other roads 24 hours a day seven days a week. They help reduce the pollution where kids are congregating which is especially important with Covid (although we should also be demanding parents switch of their engines and not to idle in their cars!).

But whilst I imagine there would be a hope that they discourage parents making the school run in their car, it isn’t right to claim they are specifically a traffic reduction scheme.

TFL are due to implement a number of measures on the A21.

We welcome the improvements to cycling infrastructure on Lewisham High Street, and we are glad that the council apparently got TFL to agree not to include the bans on left turns from Ladywell and on right turns from Courthill Road, which would have either effectively cut Lewisham shopping centre off for a huge number of residents or would have required additional filtered roads to avoid causing cut through traffic. Either way it would have added a huge detour to local journeys, onto even more congestion roads, causing even more pollution.

We ask the council to share their plans for Burnt Ash Road / Hill, which we understand are subject to a secret bid to TFL for funding.

We also ask that the council lobby TFL for a radical rethink of both Lee High Road and Brownhill Road / St Mildred’s road. The junctions urgently need fixing as the additional displaced traffic is literally causing gridlock, and not just at rush hour. Whilst these roads are narrow, there is room for a segregated cycle lane if turning lanes are removed or reduced and some no left/right turns are considered at strategic points.

Some sections of Lee High Road desperately need the pavement widening, which may involve removing pedestrian refuges and changing the timing of lights accordingly. Parking and loading bays could be reduced at key pinch points, in favour of loading on side roads where appropriate.

Experts are clear that unless LTNs are implemented with complementary measures and an overall traffic reduction plan, they will be divisive…

Will these measures be permanent?

A resident of Hither Green Lane recently suggested to their local councillor that the quickest way to resolve the incredible amount of traffic on his road would be to suspend the scheme in Lee Green.

This was rebuffed on the grounds that whilst it would solve the problem at the southern end of Hither Green Lane, the northern end and Courthill Road is currently enjoying less traffic. The councillor feared it would “restore the thousands of vehicle movements up and down Ennersdale Road – and bringing back constant queues of traffic onto Eastdown Park adjacent to Gilmore Road”.

We don’t want to return to the status quo, but it has to be an option on the table in the event that the LTN is causing unacceptable harm and changes cannot be made. If councillors aren’t prepared to return to the status quo even in those circumstances, it’s not much of a trial. It doesn’t bode well for the end of the trial.

Those on the now filtered streets will fight tooth and nail to keep them like that. And some houses in the LTN are already being advertised for as being on “no through roads”!

As we have made clear on countless occasions, One Lewisham does not want to simply remove the filters and for everything to go back to normal. We want to move forward with compromise and dialogue.

We want a balanced traffic reduction programme – one which does not provide improvements for “leafy areas” at the expense of the residents of “main roads”. Capacity must be reallocated to the most needy, and the benefit should not solely go to the streets with some of the highest car ownership figures in the borough.

To do otherwise creates a huge social justice issue, and pushes an even greater divide between the haves and the have nots.

LTNs do not negate the need to improve alternatives. You can paint it orange as much as you like, but an LTN is a stick, not a carrot.

We are also still lacking any success criteria. How can it be a trial without measurable criteria defined up front? Listing the factors that may be considered is insufficient. Any room for a subjective decision needs to be removed. Criteria must be scored and weighted.

We were told there are too many factors involved for this to be decided up front, but this is precisely why it needs to be decided up front – otherwise it risks being fudged at the end.

We are deeply concerned that “commonplace” feedback may be included in the criteria for success, given this seems to be the factor that enabled Lee Green to be selected first despite appearing to score low on all other criteria.

Commonplace does not validate where people commenting and liking are based, so could easily be skewed by national campaigners.

We are also concerned that “stakeholder” feedback may be skewed towards the vocal and persistent campaigners who have been behind the roll out of these schemes across London and the UK, and who’s organisations receive hundreds of thousands of pounds from councils for consulting services on these very schemes.

And on the subject of Commonplace, it is not a suitable tool for reporting problems or concerns as it requires you to ‘suggest a scheme’ in specific location. You cannot raise an objection to the scheme simply being unjust or unfair – or frankly, ethically questionable given it turns residents into lab rats simply to prevent ‘rat running’.

As a closing note, we urge the council to agree that should (improved) monitoring show that pollution on main or surrounding roads has increased above safe levels, then the scheme must be suspended immediately pending urgent changes. How can they not agree to that…?

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