1 February 2021
Dear Muhammad
CRYSTAL PALACE AND SOUTH NORWOOD LTN
Residents and supporters of our campaign were dismayed to read your announcement that the current LTN measures will be taken out before the implementation of the planned new experimental layout, and, indeed, before there is any clarity about the timetable on which it will be implemented. I am sure you realise, but I must put on record, that a return to being a high traffic neighbourhood will have a devastating impact on well-being and quality of life for residents, particularly many with protected characteristics, and reverse the enormous progress which has been made in encouraging active travel.
We understand the need for you to reflect carefully on the implications of the recent Bishopsgate judgement, but other boroughs have decided, following guidance from TfL, to maintain their similar schemes pending an appeal. We beg you to reconsider, even at this late stage, whether you could not maintain the current measures until you are ready to put in place the new scheme. If that is not possible, it would be helpful to understand why you have concluded it is necessary to take such a retrograde and damaging step.
To give you a couple of examples, one parent has written as follows:
“Pre-lockdown, I had to get up at 6am to walk my child (13) to the bus stop (getting an early bus because the later ones were so packed she couldn’t guarantee making it to school on time). The walk to Norwood Junction is too dangerous for a child that age while speeding traffic is allowed on the residential roads which have to be crossed. On Lancaster Road, we have to brace ourselves to run across, as cars come hurtling round both bends at high speed. Do we now have to wait til someone is killed on that road before the danger is acknowledged and addressed?”
Another resident has written:
“I have a long term condition limiting my mobility and am only able to walk unsteadily and slowly. Despite that, I like to walk for exercise. During the period of the LTN, especially the lockdown phases, the quiet streets have been a safe and enjoyable space for me to walk. (Before anyone asks why I don’t walk in parks, I have to get to one, and as a vulnerable woman, I don’t always feel safe there!) Now the LTN is being removed, I am basically facing the loss of my independent mobility and ability to exercise, because the volume of traffic, and the dangerous and aggressive behaviour of many drivers, mean that I only feel safe if my partner accompanies me, which he is not always able to do because of work and other commitments. I am sure this will have a detrimental effect on my physical and mental health.”
Despite our dismay about the removal of the current scheme, we remain willing to work with you and officers in any way which will support progress on the new experimental layout. I am setting out a few points for your consideration; we would welcome an opportunity to discuss them with you and officers.
First, during the interval between the two schemes, would it be possible to implement some temporary additional safety measures on the streets which will again become heavily trafficked? The locations we have in mind in particular are:
- Lancaster Road and Southern Avenue. Like the parent quoted above, many residents’ experience of these streets before the LTN was that their poor sight lines and the reckless behaviour of drivers made them extremely unsafe.
- The junctions of Auckland Road and the ‘hill roads’: Sylvan, Stambourne and Fox. The Stambourne junction is particularly dangerous because of the wide splays, which encourage excessive speed by turning drivers and make the crossing on foot a greater distance than more perpendicular junctions. There is also almost permanent pooling on one side of that junction, which has been as issue for years and results in pedestrians being sprayed with water, especially when there is a lot of traffic.
Would you be able to ask your expert engineers whether there are any temporary measures which could be put in place to make these locations safer? If they would like to talk to residents to understand the issues in more detail, we will gladly arrange that.
I know you have no control over the police, but would you be able to use your good offices to encourage them to carry out speed and other traffic enforcement along Auckland Road, Lancaster Road, Southern Avenue and the ‘hill roads’?
Second, monitoring. (One of the few areas where we have something in common with scheme opponents!) Making a virtue of necessity, the reversion to a high traffic neighbourhood offers the opportunity to collect much fuller baseline data on traffic volumes and speed, and active travel, on the rat-run streets in the LTN, and the boundary roads, against to monitor the impact of the planned experimental scheme. We urge you to instruct officers to install monitoring equipment at as many locations as possible. As we have suggested before, we are also willing to organise which resident volunteers to assist with monitoring, for example of active travel. Some have obtained electronic devices which can be fitted on front windows to monitor all modes of travel. We would be willing to do this jointly with opponents to guarantee fair play, though they have rejected offers of this kind on our part before.
Third, equalities. We suggest it is vital to develop a balanced assessment of equalities impacts to counter partial and misleading analyses which overstate the negative impacts of LTN measures on people with protected characteristics, while almost completely disregarding other aspects of equalities where the impact of LTNs is positive. To take two examples:
- Age is a protected characteristic. As officers noted in the paper for TMAC, children and young people account for around a quarter of the population of the LTN, and many others walk or cycle through it on their way to school. The adverse impacts of traffic danger and poor air quality on children and young people are well understood – while, of course, they are not vehicle owners. Yet, because of the nature of the consultation process, their voice is hardly heard. We hope this point could be brought out more strongly in the next set of papers for TMAC.
- In terms of disability, it is vital that the analysis is balanced, reflecting the conclusions of the recent Transport for All report about disability and LTNs. The circumstances and choices of disabled people are very diverse. While many are more than typically dependent on motor vehicles, and may therefore experience adverse impacts from, for example, extended driving distances, many others do not even have access to a vehicle, and heavy traffic is a threat to their wellbeing, as the example above illustrates.
We hope that, in the run-up to the new scheme, and during the experimental period, the council will put in place specific consultation approaches which enable the voices of children and young people, and disabled people, to be heard directly and more prominently than up to now. Too often people outside these groups seek to speak for them, and, inadvertently or deliberately, misrepresent their needs and preferences.
Fourth, we understand, and welcome, that you will be consulting with Bromley Council over the next few weeks. However, we would urge you to ensure that discussions with them about the impact of Croydon LTN measures are evidence-based and balanced, and do not side-step Bromley Council’s own responsibility for traffic management and safety on their streets. In terms of impact, it is indisputable, but often glossed over, that the impact of the LTN on Hamlet Road and Waldegrave Road has been enormously beneficial, with the former not now experiencing the high traffic volumes and frequent east-bound queuing seen there previously. There has been some increase in traffic on the streets closer to Church Road, especially during the time Church Road was blocked by scaffolding. However, as the analysis carried out by our volunteers, and summarised in our consultation submission, shows, even during the scaffolding phase, it was of a completely different scale and nature from the volumes of through traffic which have plagued the Croydon streets further south, and, regrettably, look like returning now. Since the removal of the scaffolding, our members who frequently pass along those streets see only extremely light traffic. In our view, Bromley Council also need to stop shirking their responsibility to implement safer streets measures along the lines being strongly encouraged by the government and TfL. Such issues as there are on their side of the boundary could straightforwardly be addressed by measures complementing those in the Croydon LTN, and by reducing the speed limit to 20mph.
In this context, we would like to express our appreciation for the constructive and sympathetic stance of Bromley’s ward councillor for the area, Cllr Angela Wilkins.
Fifth, timetable and process. We understand there is to be another TMAC meeting on 15 February, but do not understand how the rest of the timetable works. If you could outline the current plan (which we appreciate is subject to change for reasons beyond your control), we could plan our activities in support of you and officers.
I look forward to your response and a suggested time for a discussion.
Kind regards
For Shape Better Streets campaign
cc
CPUN and South Norwood ward councillors
Cllr Angela Wilkins (Bromley)
Steve Reed MP
Ian Plowright
Shape Better Streets Croydon & Bromley 