Details
The council proposed four traffic routing options in August 2019 based on a small traffic experiment in 2018-19 in one area of the neighbourhood. However the proposals are now extensive and impact the whole of East Sheen. These proposals were introduced with no prior consultation with the whole of the East Sheen Neighbourhood. The proposals now include a Low Traffic Neighbourhood scheme. However the consultation process being followed by the council does not comply with the recommended process set out in “A Guide To Low Traffic Neighbourhoods” which is to help ensure policy makers develop optimal schemes for the borough with resident support and reduced controversy. The four options and the other measures proposed are seen as sub-optimal for the East Sheen Neighbourhood as they:
1. Potentially increase the risk of accidents and pollution for children at 2 schools: Sheen Mount on Christchurch Road and Tower House on Sheen Lane.
2. Incorporate some of the new experimental restrictions (Palmerston. Observatory and Coval Roads) which have been incorporated as full proposals before the council had first consulted East Sheen Residents across the whole neighbourhood.
3. Were not presented with research data and traffic modelling projections to support the 10 and 15% benefits claimed.
4. Already create new rat-runs as traffic avoids the experimental restrictions through other routes including north of the Upper Richmond Road. E.g. Burdenshott Ave, Warren Ave, Denehurst Gdns, Tangier Rd, Rothesay Ave and Clydesdale Gdns.
5. Direct traffic onto four Conservation Areas in the borough: Christchurch Road, Sheen Common Drive, Berwyn Road and Sheen Lane, in contravention of the Council’s 2018 guidelines.
6. Are for 365 days per year 24 hours a day, but the key issue is mainly peak hours and not when the park shuts 4pm – 7am during the winter.
7. Will increase the traffic volume and speed on Sheen Lane which is a residential road with a school and pedestrian/school crossing. It has housing close to the road and two dangerous pinch points. It is not an A road. It is a B road which is an historic designation when it was one of East Sheen’s principal streets and traffic was not a consideration. The designation does not imply any standard, make up or traffic capacity.
8. Do not contain proposals developed with The Royal Parks nor TFL which would have the biggest impact in reducing traffic while Hammersmith Bridge is shut for approximately 3 years.
9. Do not take into account the Ultra Low Emissions Zone (ULEZ) which has the Upper Richmond Road and the South Circular as boundaries.
10. In addition to the above, the Council’s on-line consultation survey form is poorly designed from a usability perspective and is confusing to users who may lose the opportunity to express their views.
11. You have to select “NO” to “do you support the idea of a low traffic neighbourhood” in order to access the box that contains the question “please tell us if you would like to see any restrictions retained/introduced in the area or the removal of the restrictions”.
12. No option 5 was presented in the online survey to return to the previous status quo although the proposals were originally presented as experimental
Started by: Tony Croxson (on behalf of East Sheen Streets)
This petition ran from 03/09/2019 to 03/12/2019.
Council response
The Council is nearing the end of a three-month public consultation process with regard to potential low traffic measures in East Sheen. Therefore, the current proposals will not be deferred at this stage as the Council is already actively engaging with over 8,000 residents and businesses in the East Sheen area and working on getting feedback to help inform next steps. With regard to the specific points raised:
1. As explained, the current proposals will not be deferred until at least the end of the current consultation exercise.
2. Both the consultation letter and the online consultation material provided a definition of a Low Traffic Neighbourhood as follows: ‘A low traffic neighbourhood is designed to keep through traffic on the most appropriate classified road network and discourage/prevent it using unclassified residential roads.’ This definition is in line with published and readily available information, such as the London Cycling Campaign and Living Streets guidance, which defines a LTN in the following way: ‘Low traffic neighbourhoods are groups of residential streets, bordered by main or “distributor” roads (the places where buses, lorries, non-local traffic should be), where “through” motor vehicle traffic is discouraged or removed. There’s lots of ways you can make a low traffic neighbourhood, but the main principle is that every resident can drive onto their street, get deliveries etc, but it’s harder or impossible to drive straight through from one main road to the next.‘ The question was designed to gauge residents’ views on the idea of a LTN overall, as well as support for the individual proposals, to help us understand people’s feedback and any concerns more fully.
3. The Council already follows best practice in consultation guidance, most notably the nationally recognised and accepted ‘HM Government Code of Practice on Consultation’. The document “A Guide to Low Traffic Neighbourhoods” sets out processes the Council is already following. We are also consulting in line with the Council’s Consultation Charter and the common law requirements of a fair public consultation. We understand the impact on local residents, which is why we are working so closely with them to find a consensus on a way forward. The public meetings are another element of the engagement taking place and we are keen to hear people’s views and concerns at these events and through responses to the consultation. With regards to transparency, the results of the consultation will be available to residents and published on the Council website, in addition to any other reports and decisions arising from it.
4. The challenges of an East Sheen Traffic Group is which roads/representatives are part this and the already known widely different views and perspectives of different roads, hence the focus initially is on two engagement events to initiate draw out all views. The potential for such a group will be considered after the current consultation.
5. The Council has already been actively engaging with various local groups, the Royal Parks and TfL and the initial proposals set out have been done so to ‘start a conversation’ with a view to then reviewing if these are supported or if revised proposals need to be developed as part of next stage of engagement. What is already very clear is that there are no proposals that are universally supported.
With regards to the justification set out, the Council would comment as follows:
- The current consultation on the four initial proposals is live. The ideas put forward are not directly based on nor informed by the previous experimental measures in place currently.
- In order for a low traffic neighbourhood to be fully effective, meeting the primary objective of substantially reducing through traffic in an area, it needs to eliminate or restrict the key through routes in the area. These are substantive in East Sheen hence the proposals have had to look at a number of interventions. However, the whole purpose of a consultation is to take views on these which could include looking at modified measures or complete withdrawal.
- The current measures were instigated by a petition that met the Council’s criteria for intervention as per its Traffic Management Policy. These were introduced under an Experimental Traffic Order that carries no formal or statutory consultation requirements but allows for representations to be made.
- As explained, the Council’s approach is consistent with the guide to low traffic neighbourhoods and we are presently looking to develop final measures that are optimal, well supported and have less controversy, hence the wide current engagement exercise to help inform this.
- The current four options have been developed by professional experts in the field. They achieve the objective of creating an effective low traffic neighbourhood but can be modified as part of the engagement feedback.
- The argument that the measures would potentially increase the risk of accidents and pollution for children at two schools (Sheen Mount on Christchurch Road and Tower House on Sheen Lane) is not shared as (a) the Council is introducing 20mph limits across the borough which will aid accident reduction and (b) low traffic neighbourhoods are stated as reducing overall traffic in the area by around 15% (as per the guide to low traffic neighbourhoods)
- Not all options set out incorporate the current restrictions on site. These cannot be ‘incorporated as full proposals’ as (a) they are only under experimental orders and (b) are subject to feedback from the current consultation
- There is no direct research or modelled data on the four options presented as these remain untested ideas. The 10% reduction in traffic was taken from counts prior to the closure of Hammersmith Bridge. The 15% reduction is widely quoted as typical of low traffic neighbourhoods and was the outcome of a recent low traffic neighbourhood recently trialled in West Hill.
- The proposals are unlikely to create new rat runs north of the Upper Richmond Road as there is no direct relationship between the proposed measures and current issues on these roads. Matters are more likely linked to the closure of Hammersmith Bridge.
- The proposals are seeking to reduce traffic levels in the area and are not in contravention of the Council’s 2018 guidelines around conservation.
- The opportunity to revise the hours of operation of any measures remains open
- Sheen Lane is the only classified area in the area (‘B’ road) and therefore deemed more appropriate for traffic than unclassified roads in the area
- There are no agreed proposals developed with the Royal Parks and the Council has already worked with TfL to seek to try to mitigate traffic impacts from the closure of Hammersmith Bridge which remains an ongoing discussion. Any measures on the TfL network are not appropriate to this consultation.
- ULEZ has been considered as part of this which is why for example a Controlled Parking Zone (CPZ) has been suggested.
- The Council is satisfied with the design and usability of its online form. Nonetheless, the opportunity to express views is also available through the 8,000 posted hard copies of the consultation plus the two drop in events set up.
- If you support the principle of a Low Traffic Neighbourhood, then some form of intervention is logically required. For removal of restrictions, or modification, this is clearly set out under the “NO” to the question of support of principle and/or will coded up as an option if people cover this under “any other comments”.
- As explained, the online consultation allows people to set out a preference for a return to the previous position. However, given there are known traffic level issues with certain roads in the area, removing all restrictions and doing nothing will not aid all people in the area and fail the very principles this petition quotes from the guide to low traffic neighbourhoods.
Signatures
1568 people have signed this petition. This includes a paper petition containing 719 signatures.
