Fact Checker

FOI request reveals more flawed traffic data from Southwark Council (11 October 2020)

Thanks to an FOI (Freedom of Information) request, One Dulwich has found a second serious problem with the figures presented during Southwark’s "Our Healthy Streets Dulwich" (OHSD) consultation.

This raises the possibility that the consultation was based on data so flawed that none of the results can be relied upon.

It also raises the possibility of a failure of process.

We support the Council’s objectives of reducing traffic and encouraging active travel. But changes to roads – even if the measures are temporary and experimental – must be based on accurate data to which the Council responds in a proportionate way.

1. The Background

At the OHSD consultation meetings, our Councillors repeatedly emphasised that the closure of Dulwich Village junction was a logical part of the holistic scheme because of the huge increase in traffic through Dulwich Village and along Calton Avenue. They published an “evidence pack” to support these claims.

One Dulwich queried these claims of massive traffic increases, but were assured by Councillors and Council officers they were correct.

However, this is not the case.

We have already shown that the claimed 47% increase in traffic through Dulwich Village is not valid since the base comparison was calculated at a time when the junction was undergoing roadworks, with major delays and temporary traffic lights. In reality, traffic had decreased slightly over the past few years.

We now find a similar situation with the claimed increase in traffic on Calton Avenue.

2. The Calton Avenue Traffic Counts

The detailed story is as follows. (If you’re not that interested in figures and graphs, please feel free to go straight to the summary in the third section, ‘Conclusion’.)

In the evidence pack (look beneath the map at the bottom of ‘Phase 3’), the graphs show a large increase in traffic on Calton Avenue between 2015 and 2018, particularly in the morning peak (around 8am). As an example, see Graph A below.

However, the 2015 lines in the graphs look strange: they show no peak in the morning. They are also not consistent with separate counts carried out by Transport for London (TfL). (But we will leave the 2015 TfL figures to one side here. When questioned on the discrepancy in June 2020, the Council replied that it could only comment on its own data.)

As the underlying Council data is not publicly available, a supporter of One Dulwich used a Freedom of Information (FOI) request to get detailed Southwark traffic counts for Calton Avenue. These show a very different picture.

The Southwark traffic counts for 2015 were carried out over 22 days between 25 September and 16 October and the Council has used an average, the "Virtual Day", in the graphs.

However, as shown in graph B below, 10 of these 22 days show daily counts of either zero or extremely low figures. Clearly the traffic sensors were either out of action or not working accurately during much of the counting period.

A very important point is that the Council’s own data sheets highlight these invalid days, presumably because they could not be relied upon. Despite this, the Council included them in their calculated averages. This, of course, brought the average right down – because the overall figure was divided by 22 days instead of 12 – and skewed the results.

A proper comparison should have excluded the invalid days. We have done this, and calculated a realistic average (using the last seven days only to remove weekday phasing).

We also asked for the Council’s 2018 figures under the FOI but none are available. The Council was unable to provide the detailed supporting data for 2018 due to computer error (which is in itself concerning). We have therefore estimated these from the evidence pack.

To make a direct comparison with graph A (above), graph C (below) shows the revised figures for the hourly counts for 2015 and 2018:

3. Conclusion

This raises several issues. We invite the Council to respond to these, especially if it considers our conclusions are incorrect:

~ Despite what we were told during the OHSD consultation, the traffic along Calton Avenue had not massively increased since 2015 as claimed. It actually decreased.

~ During the OHSD public meetings, Councillors placed huge emphasis on the alleged massive traffic increases to justify their proposal to close the junction. Since, based on our findings, these assertions are incorrect, we consider that this invalidates the results of the consultation exercise. It also throws into question the Council’s continued reference to the consultation as the justification for its interventions.

~ Council officers were queried on their figures but defended them as being on a comparable, like-for-like basis. However, the Council's own data sheets highlighted the invalid data. Despite this, these discrepancies were ignored in the published "evidence pack". This raises a serious question about how carefully figures used to support traffic measures are being checked and analysed.

~ The measures currently being imposed under Experimental Traffic Orders, including the 24/7 closure of Dulwich Village junction, would appear to be driven by inaccurate information.

Are permit systems always linked to Controlled Parking Zones? (17 September 2020)

On several occasions this year, our councillors have suggested that permits allowing vehicles access when roads are closed can only be considered if the area has a Controlled Parking Zone (CPZ).

As recently as 26 August, in response to a question from a local GP who asked if there could be exemptions for Blue Badge holders and care workers, Councillor Newens said that “to be effective” a permit scheme had to go hand in hand with a CPZ. That same day, Clement Agyei-Frempong from Southwark’s Highways team said, “A permit system is not possible at this stage because you need a CPZ.”

But is that really the case? Does a CPZ really have to be a pre-condition of a permit scheme?

One Dulwich has found at least two other London boroughs where permit schemes operate independently of CPZs.

Firstly, in Hounslow there are a number of schemes based on Automatic Number Plate Recognition (ANPR) cameras. For the borough’s School Streets, a ‘whitelist’ is maintained for vehicles owned by residents who live within the zone, who are permitted access during the times the road is closed to other traffic. (This is similar to the way School Streets operate across the UK.) Some of the School Streets are in CPZs, but some aren’t: ANPR-controlled access is not dependent on whether or not a CPZ exists.

Hounslow is also trialling an innovative “access-only zone” for Strand on the Green, Thames Road and the adjoining side streets in Chiswick. This involves linked ANPR cameras that measure the journey time of vehicles across the zone. If the journey is completed in fewer than fifteen minutes, it is deemed to be a through journey, and the vehicle is fined accordingly. This avoids the need for residents in the zone to register at all, although registration is possible for vehicles providing local services.

In Hammersmith & Fulham, the Council has launched what they call a “pioneering traffic reduction scheme which uses the latest smart camera technology to halt rat-running by out-of-borough drivers”. The scheme went live on 20 July. Their website says, “To make the change as painless as possible for residents, we’re issuing borough access permits to all residents who are automatically eligible.” In other words, anyone who lives anywhere in the borough has a permit.

Residents in Hammersmith & Fulham who already have parking permits for CPZs don’t need to register – the Council automatically creates a free access permit on its system so residents can drive through the control points without penalty. For residents who don’t need a parking permit, “as long as your vehicle is registered with the DVLA at your address we’ll detect this the first time you drive through a camera and automatically create a free access permit for you on our system.”

These schemes in Hounslow and in Hammersmith & Fulham are just examples – as we’ve said before the issue of permits and exemptions is a matter for consultation with the local community.

But it would seem that Southwark’s position that you can’t have an access permit without a CPZ is not substantiated.

Can we expect a fair review of the “experimental measures” at the Dulwich Village junction? (30 June 2020)

We have become used to surveys from Southwark Council that are neither neutral nor balanced. Both the “Our Healthy Streets” surveys in Phase 2 and 3 included leading questions and a loaded choice of answers.

But Southwark’s latest online consultation – Streetspace Dulwich Village – takes this to a whole new level.

First, some background. On 19 June, Councillor Richard Livingstone wrote to residents explaining that “we are inviting residents to let us know about the impact on the streets they use – whether positive or negative – on the feedback map at https://dulwichvillagestreetspace.commonplace.is .”

This is all very lovely. We hear that Southwark will be closely monitoring the effects of the measures, and “we want to hear from you…Your comments will help inform any additional measures that we make.”

But it’s important to stress that only written objections to the Dulwich Village junction closure in the first six months after the traffic order has been put into place have legal weight. (You can email Southwark via via highways@southwark.gov.uk or, for those not online, the address is Southwark Council, PO Box 64529, London SE1P 5LX.) We are not certain, from what we’ve read so far, that objections registered on the Streetspace site will count.

So is it worth recording your views on the Streetspace site? Yes, definitely. We’re pretty sure that Southwark will be placing a lot of weight on the results. But be warned – it won’t be easy. You’ll have to negotiate your way past some very heavy bias.

Start by clicking on “Have your say”. The three questions contain a quite breathtaking level of both ‘framing bias’ (asking for feedback that is positive, rather than attempting to get balanced feedback, positive and negative) and ‘confirmation bias’ (implying the baseline for feedback is that the road closures stay in place – possibly with a few minor tweaks – rather than returning to the way things were before the experiment was forced through). Looking at them in turn:

Question 1 (‘What can we do to improve the experimental measures?’) has 12 pre-set answers, none of which includes anything along the lines of ‘Remove the new restrictions’ or ‘Have the restrictions during peak times only'.

Question 2 (‘Following the experimental road closures, what is working well at this location?’) is followed by 13 pre-set positive, feel-good answers. But the obvious balancing question (‘What issues are there with this experimental road closure at this location?’) is completely absent.

Question 3 (‘To what extent do you support the principle of re-purposing streetspace to prioritise public health, road safety, local business and active travel?) is a ridiculously loaded question. It suggests it is a universal truth that these worthy objectives, which no one could object to, are only achieved by re-purposing streetspace and, by implication, this specific road closure. And this is the answer used to colour-code the feedback pins on the map!

This sliding scale question is so generic as to be meaningless unless it is counterbalanced by another sliding scale question along the lines of ‘To what extent do you support this experimental road closure being made permanent in this location?’ Plus maybe a follow-up question such as ‘If you do not support this closure becoming permanent at this location, what amendments or alternative measures would you support?’

If this online forum is going to be the primary tool for feedback and decision-making on whether the ETO closure becomes permanent, gets modified or reverts back to the status quo, it is completely flawed. Statistics generated, such as ‘x% of survey respondents agreed with re-purposing streetspace’, will be meaningless.

We assume the Council does not wish deliberately to steamroll through a controversial policy without following due process. So why have they introduced such a flawed and biased process?

Updated 3 August 2020: At a meeting with representatives from residents' associations on 28 July, one of the Dulwich Village ward councillors confirmed that the purpose of the Streetspace map is to highlight problems. It is not a consultation tool. Anyone wishing to object must write to Southwark Council separately.

Is it reasonable to ask for timed restrictions? (28 June 2020)

In an email on 11 June 2020 to a local resident, talking about One Dulwich’s 27 April proposal for timed restrictions, one of our Village Ward Councillors said, “I am afraid that this proposal as it stands supports the creation of an exclusive gated community at the heart of Dulwich Village: if you live in the exclusive zone, you can drive as you wish, whilst imposing change on everyone else. As you will appreciate, Dulwich Village is already a rather privileged community. It would be very difficult to justify the council making it more so.”

So is it reasonable for residents to ask for timed restrictions rather than 24/7 closures?

Yes. Timed restrictions (preventing access to all or some motorised vehicles during certain time periods) are core to Schools Streets, restricted access zones in town and city centres, low-traffic neighbourhoods, and pedestrian and cycle zones (please see our earlier discussion document, dated 28 May 2020, in the Research section of this website).

Timed restrictions are part of the Healthy Streets toolkit, and approved by TfL’s Liveable Neighbourhoods. They are a pretty normal way of controlling traffic in residential neighbourhoods. As London’s Walking and Cycling Commissioner has said, “Filters allow people to access their homes, allow cab drop offs, allow emergency service access. But they stop rat running through residential areas, making it safer for everyone.”

So who should have access?

All schemes involving timed restrictions block motorised vehicles (including motorcycles) at certain hours. But most schemes make exemptions for some vehicles, including any of the following (in any combination):

• Blue Badge holders
• carers (family members or registered carers)
• residents (or permit-holders)
• local businesses
• emergency services
• taxis
• deliveries
• buses

This is based on the principle of reducing or removing through traffic (a central theme of the recent Our Healthy Streets consultation) while allowing in some or all local traffic.

Exemptions are usually a matter for local consultation. You can, of course, block all traffic at all times – which is what is happening with the ETO (Experimental Traffic Order) to close Dulwich Village junction.

Or you can look at what seems reasonable in response to local conditions.

In this context, as well as thinking about the needs of residents with mobility problems who cannot walk or cycle, you might want to consider that Dulwich Village Ward has:

• poor public transport – Dulwich has a low PTAL (Public Transport Accessibility Level) rating (PTAL ratings measure how easy it is to get to the nearest public transport stop, and the service frequency once you get there);
• no tube station (the nearest is Brixton);
• a street network with limited entry/exit points because of Dulwich Park and the green spaces belonging to the Dulwich Estate and its beneficiaries;
• few road links between East and West Dulwich (Calton Avenue-Turney Road is the most direct connecting route); and
• an unusually large number of schools and pre-schools, leading to high levels of traffic in term times.

The issue of access affects the whole area. An additional point to consider might be whether it is reasonable to push all of Dulwich Village’s local residential traffic at all times on to neighbouring roads like East Dulwich Grove and Lordship Lane, which already have their fair share of congestion and pollution.

One Dulwich is still waiting to discuss all these issues with our councillors.

We would like to suggest a practical examination of timed restrictions in Dulwich Village in the context of data, modelling, comparable schemes and empirical evidence.

Did 55% of respondents/residents agree with the proposal to close Dulwich Village junction? (25 June 2020)

The short answer is that no one knows. Southwark Council hasn’t yet completed its analysis of the results of the Our Healthy Streets survey.

Despite this, the figure of 55% is now doing the rounds as if it’s undisputed fact.

On 10 June, Village Ward Councillor Margy Newens said of the OHSD Phase 3 consultation:

“We can now confirm that the vast majority of responses received were from within or immediately adjacent to the consultation area and that 55% of respondents agreed with the proposal to close the Dulwich Village/Calton Avenue/Court Lane junction to motor traffic, versus 37% who disagreed with this proposal.”

One Dulwich tried unsuccessfully to find out what was meant by “vast majority”; how the “consultation area” was defined; and what “immediately adjacent” meant (it was also described as people “living in the vicinity” of the junction). We were then told that there were 2,007 responses, that not all responses had been analysed and that it was not possible to break down the numbers by Areas A, B or C. We also gathered that there had been no de-duplication, so the 2,007 figure could include people who had responded several times. (The question of whether the responses of adults and children would be given equal weight wasn’t mentioned.)

Then, on 16 June, we were told that the Council didn't have any final results because there were a lot of emails and letters that hadn't been analysed and were therefore not included on the Council's consultation hub.

On 22 June, Village Ward Councillor Margy Newens gave us a further breakdown. She tweeted to say that there were about 1,267 responses from within Areas A, B and C, not including boundary roads like Dulwich Village, East Dulwich Grove and Half Moon Lane. She said (referring to the phrase “the vast majority”), “'vast’ was a poor choice – let’s say ‘large’.”

Based on these figures, responses from Areas A, B and C (excluding boundary roads) account for 63% of the total.

The Council’s original claim was that 55% of respondents agreed with the proposal to close Dulwich Village junction. Now that the Council had revealed the number of responses from the consultation area, we asked what percentage of respondents from Areas A, B and C had agreed (in the context of the whole package of interlinking proposals) that Dulwich Village junction should be closed?

On 22 June, Councillor Richard Livingstone (who had taken the decision to close Dulwich Village junction based on advice that there was majority support for it) tweeted that “there was 55% support for the Court-Calton closure both overall and from residents living within the consultation zone”. This seemed a truly remarkable coincidence – 55% overall AND 55% from Areas A, B and C?

But by now an incomplete analysis of draft figures – dribbled out over several days with misleading descriptions like “vast majority” – had become the de facto result.

The OHSD Phase 3 proposal stated that “you told us you favoured radical action at the Calton Avenue/Court Lane junction, including a permeable road closure that stops motor traffic”, even though this was based on a Phase 2 survey in which just 122 people (out of the 217 who responded) approved of permeable closure. Despite asking our councillors many times, we have never been given any information about who these Phase 2 respondents were (where did they live, for example?). Is it any wonder there is such a high level of doubt about the way in which the Council analyses and presents the results of consultation surveys?

Updated 6 August 2020 Councillor Livingstone emailed us on 30 June to say that 56% of respondents supported the junction closure - again, both overall and from within Areas A, B and C. We have written back four times to ask for further clarification, including whether the final figures include the emails, letters and paper questionnaires mentioned on 16 June, whether responses from adults and children have been given equal weight, and exactly which roads have been excluded.

Updated 27 November 2020 We have still had no answers to any of the questions above, and the results of the consultation have never been published.

Has traffic through Dulwich Village junction increased or decreased “in recent years”? (24 June 2020)

During the consultation period, Southwark Council claimed that traffic "through the junction" had increased by 47% “in recent years”. This claim featured prominently in several of the public meetings and was used as a justification for the urgent need to support the Council’s proposals.

One Dulwich fully supports the need to reduce traffic volumes in Dulwich. But we believe that any proposals the Council puts forward must be built on facts that can be openly shared with the public.

So has there been a sudden, unexplained and alarming increase in traffic through Dulwich Village? No, traffic through Dulwich Village has remained remarkably stable since 2010, as shown in these interactive slides.