Objections to the East Dulwich ETOs
The text below sets out (in detail) our formal objections to the Experimental Traffic Orders affecting East Dulwich.
29 January 2021
1. Objections to the East Dulwich Streetspace scheme TMO2021-EXP10_LSP E Dulwich (road closures on Derwent Grove, Elsie Road, Melbourne Grove and Tintagel Crescent); and
2. Objections to the impact on East Dulwich of the Dulwich Village Streetspace scheme that is, the impact of TMO2021-EXP02_LSP Dulwich and TMO2021-EXP16_LSP Dulwich 2 (road closures on Melbourne Grove South, Dulwich Village, Calton Avenue, Court Lane, Burbage Road, Turney Road and Townley Road) on East Dulwich roads, particularly Melbourne Grove South, Grove Vale, Lordship Lane and East Dulwich Grove.
We object to these experimental orders put in place on the grounds summarised below, which individually and collectively evidence the detrimental misuse by Southwark of the experimental order process – specifically to include the lack of evidence-based decision-making, the absence of any conscientious assessment of the risk and extent of adverse impacts on those in protected groups, and the flawed implementation of existing Southwark policy.
Summary of objections
1. Compromising the Emergency Services
2. Impacting trade and competitiveness for local businesses
3. Social injustice and discrimination
4. Worsening traffic and pollution on residential, business and school roads Grove Vale, Lordship Lane and East Dulwich Grove
5. Environmental damage in a climate emergency
6. Disregard for road and child safety
7. Failure to meet Southwark Council’s own Movement Plan Objectives and Equity Framework
8. Failure to follow Southwark Council’s own recommendations for implementing road schemes
Grounds for objections
1. Compromising the Emergency Services
In a meeting with Southwark Council Highways team on 16 July 2020, the London Ambulance Service, Met Police and London Fire Brigade said hard barriers such as planters ‘would cost lives’ and they did not support this type of barrier. Southwark proceeded anyway.
The Emergency Services are under enormous stress. Closing the shortest and most efficient routes to police, fire and ambulance services 24/7 may indeed cost lives.
2. Impacting trade and competitiveness for local businesses
Southwark did not communicate with or consult in any way the 60 businesses on Melbourne Grove North and Grove Vale who have been directly impacted by the way the closures have reduced access and parking, nor any of the 100 or so businesses on Lordship Lane who have also lost parking and experienced increased pollution and congestion due to displaced traffic from the measures.
Turnover for business on Melbourne Grove North was down 40% immediately after the barriers went in, and progressively got worse (80% down on some trading days). Customers of businesses on Melbourne Grove North and Lordship Lane talk about missing appointments due to traffic congestion, and opting to shop and eat elsewhere because of congestion and pollution. Late appointments while businesses try to stay Covid-compliant create huge levels of stress for managers and customers alike.
If high street businesses are able to open in April 2021, many will have been open for only 2.5 months out of the last 12. It is not reasonable for the Council to have put them at further competitive disadvantage by reducing access and parking at this crucial time. Road closures are also affecting how the businesses make and receive deliveries.
The road measures have divided the community. Some of those who support the road closures have publicly called for boycotts of any struggling businesses that state their opposition, leaving businesses afraid to speak out.
3. Social injustice and discrimination
The Equality Act of 2010 requires the Council to consider the needs of people with protected characteristics (for example, BAME, disabled, or elderly people). This applies equally to permanent and temporary traffic measures.
The road closures that were placed on Derwent, Elsie, Tintagel and Melbourne Grove North have mainly benefittedwhite, middle-class residents, many of whom have off-street parking and own more than one vehicle. These roads were leafleted by the Council in February 2020, and the residents’ opinions were sought in a survey about the implementation of the LTNs in July 2020.
None of the 70% social housing residents on Grove Vale; nor the 63% BAME residents, or 60% BAME businesses, on Grove Vale; nor the 60% BAME businesses on Melbourne Grove North; nor businesses or residents in East Dulwich Grove or Lordship Lane; were made aware of, or asked to participate in, any surveys or consultations, even though they would all be impacted by the closures.
The residents living on residential roads like Grove Vale, East Dulwich Grove and Lordship Lane are less likely to own cars than those on the roads that have been closed but are expected to take the increased traffic. People of BAME origin are 30% more likely to live on A-roads such us Grove Vale, East Dulwich Grove and Lordship Lane.
No disabled, elderly or other protected groups who rely on cars, nor tradespeople needing vehicles to carry out business, were consulted, although cycling lobby groups were.
The Council has requested feedback via Commonplace sites, putting those ‘not in the know’ or affected by digital poverty (without smartphone, computers or broadband) at a disadvantage and unable to give feedback, or make objections or suggestions.
4. Worsening traffic and pollution on Grove Vale, Lordship Lane and East Dulwich Grove, which are roads with residents, businesses, schools and health centres
Since the implementation of the Dulwich Village measures in June 2020, which included the closure of Melbourne Grove South, and the East Dulwich measures in September 2020, traffic and congestion have worsened on A-roads, affecting residents, businesses, schools and health centres.
Concentrating traffic on to specific roads increases congestion, idling engines and pollution. TfL’s London Streetspace Plan – Interim Guidance to Boroughs, dated May 2020 shows several of the schools on Grove Vale and East Dulwich Grove already facing illegal levels of pollution in 2016. EDG Nursery, JAGS Pre-Prep, Charter East Dulwich, James Allen’s Girls’ School and Alleyn’s School (all on East Dulwich Grove); Goose Green Primary and Nursery School (Grove Vale) and Dog Kennel Hill School (Dog Kennel Hill); Judith Kerr primary school (Half Moon Lane), and Harris Primary (Lordship Lane) are all experiencing increased traffic past their playgrounds and at their school gates.
Southwark Council’s Air Quality Annual Status Report gives data from air pollution monitors outside Goose Green Primary School that show 50% of NO2 readings in 2019 were well above the WHO legal limit for pollution. The traffic here has now got worse. The increase in pollution on displacement routes is contrary to local and national air quality policy in an Air Quality Management Area. Air pollution is deemed a public health crisis and has recently been classed as a cause of death.
There has been very limited air pollution monitoring in the area. Mostly it is focused at Goose Green roundabout, a pollution hotspot. Despite the fact that TfL’s air quality monitoring shows that levels of pollution are consistently higher on the area’s A-roads, East Dulwich Grove has no ground level air pollution monitors at all.
5. Environmental damage in a climate emergency
Because the East Dulwich measures have closed four roads consecutively, residents’ cars are now routinely driving at least an extra 1km to get to the same point. The extra journey distances, coupled with congestion and idling traffic on neighbouring roads, mean the measures are increasing environmental damage. None of this is being monitored.
6. Disregard for road and child safety
CrashMap UK and TfL casualty data show that most accidents in the area occur on the A-roads – again Grove Vale, Lordship Lane and East Dulwich Grove. Increasing traffic on these roads will not reduce the number of accidents nor help fulfil the Mayor of London’s Vision Zero aim to reduce accidents to zero in London.
There are already more than 3,000 schoolchildren using East Dulwich Grove to walk, cycle and bus to school. From September 2021 Charter East Dulwich’s main entrance will be on East Dulwich Grove as the school expands in size with a sixth form and bulge Year 7. The road closures are funnelling all local traffic down Grove Vale, East Dulwich Grove and Lordship Lane, which are the main school routes.
A King’s College London Breathe London Wearables Study in October 2019 of primary school children’s routes to school showed children breathed in more air pollution on main road routes to schools than on other routes.
7. Failure to meet Southwark Council’s own Movement Plan Objectives and Equity Framework
Southwark’s Movement Plan 2019 – to which the experimental traffic orders should be compliant – is not being fulfilled. Particular note should be paid to:
Introduction ‘Our responsibilities’
Mission 6 – Support business to prosper
Mission 7 - All people to have a positive experience on our streets
Mission 8 - Manage change on our streets in a positive way for people
Mission 9 – Utilise information to deliver better services
As the document states under ‘Our responsibilities’, the Council has an obligation under the Traffic Management Act (TMA) 2004, ‘to ensure road networks are managed effectively to support our communities and their movement, improve safety, minimise congestion and disruption to all traffic, including pedestrians and vulnerable road users’. The Council is failing to fulfil this obligation. Similarly, the delivery objectives have not been fulfilled, particularly ‘We will put people at the heart of engagement through engagement that is built on trust, inclusive and collaborative.’ This has plainly not been the case. In addition, the Movement Plan is designed to benefit vulnerable groups identified as children, the elderly, the disabled, and the disadvantaged, which also includes those living on busy streets that are already polluted. LTNs that displace traffic on to those people and restrict movement further is not to their benefit.
The plan also states it puts fairness at its core, and that its equity framework will ensure that the needs of all people are being considered. Again, this is plainly not the case. The current road closures are discriminatory and do not benefit the majority of the community.
8. Failure to follow Southwark Council’s own recommendations for implementing road schemes
Recommendations in Southwark Council’s Environment Scrutiny Commission’s Air Quality Report July 2020 include: ‘Where traffic may be displaced on to main roads, the council must monitor the impact on air quality, and mitigate negative effects in advance of implementation, possibly by widening pavements and creating cycle lanes, managing traffic to reduce vehicle idling time and introducing green screening programmes.’
None of this has happened. Southwark Council was aware displacement was likely but this was not mitigated prior to implementation. Monitoring of traffic did not begin until after the road measures were introduced in September 2020, and even then only for a few weeks. Highways Officers admitted they did not have good baseline data in a meeting on September 22 2020. More traffic monitoring was installed in early January 2021, but this was during a national lockdown when schools were closed. Because of this, traffic levels will be low and unrepresentative.
Conclusion
For these reasons, the current scheme should be reversed or suspended, and the Council should ensure that future decision-making about road measures in East Dulwich and Dulwich Village is subject to appropriate procedures, including the application of the public sector equality duty, and the conscientious assessment of the risk and extent of any adverse impacts on those in protected groups.