In response to emails from residents, Ealing council has issued a statement about the low-traffic neighbourhood around Loveday Road. The draft plan, that was circulated last month, will not be implemented. Many residents were concerned that the through route, via Waldemar Avenue, shown on the plans, would have funnelled traffic onto a single road. The statement says: “a through route is not part of our current plans”.
The following is the council’s statement in full:
Loveday Road Low Traffic Neighbourhood briefing statement
Officers and Councillors are aware of a significant amount of correspondence regarding the proposal to implement a Low Traffic Neighbourhood (LTN) in the Loveday Road area. Most of the e-mails raise similar points, and given the volume and our small team, we are unable to respond to them all individually. However, we hope that this general response covers the vast majority of the comments. Please feel free to share with your neighbours if you see fit.
It is unfortunate that the draft plan has been shared widely without explanation of what an LTN is, how they work or what the benefits are. It has led to understandable concern, but many of the comments are the result of a lack of understanding of how LTNs work and their efficacy.
The intention had always been to provide residents with information on LTNs prior to installation of this experimental one. Furthermore, and quite crucially, we had intended to explain how the consultation – for there will be one – will work. Unfortunately, the draft plans were prematurely circulated before the scheme had even received any funding, which invariably raised expectations.
This response contains much of the information and indeed further detail, that was going to be contained in the intended letters as we feel it is important that people make an informed decision on the LTN.
History of this Proposal
Reducing car use is a policy aim at a national, regional and local level, therefore, it transcends political parties who are generally in agreement about this. The reasons are that vehicular traffic is a major cause of air pollution and climate change, plus there are significant health benefits if people walk and cycle, particularly on short trips, rather than drive.
We are aware that not everyone is able to walk and cycle, but the proposals do not stop people from driving. Those that do continue to drive may have to take an alternative route, but otherwise the proposals will make the area quieter, safer and, therefore, easier to walk and cycle. This opens up active travel as a choice to those who would not normally feel able to due to roads being too busy.
There is significant concern that with the difficulty in maintaining social distance while on public transport, people will choose to drive instead. If this happens, then the road network will not cope. When congestion builds up, rat-running down residential roads increases, as people try to save time. It is for this reason that central Government and TfL both suggest LTNs as suitable interventions as part of the COVID emergency, because the very purpose of LTNs is to prevent rat running through residential neighbourhoods. Funding for the LTNs is through the COVID emergency TfL Streetspace Programme.
Why the Loveday Road Area?
Firstly, we have received multiple requests from residents to do something about rat-running in this area. We are also aware of the Community Speed Watch activities that took place in 2017 in response to the recognised speeding in the area.
Secondly, the proximity of the area to north-south routes such as Northfields Avenue, with connections to Uxbridge Road and the A4/M4, means this area has a high propensity to see increased rat running to avoid traffic on Northfields Avenue. We have had reports that some sat- navs already route vehicles through the area.
Whilst Loveday Road may be used as a north-south cut through, only addressing this one road would simply cause diversions through other streets instead, for example, Lavington Road. Therefore, we need to address the whole area to avoid displacing traffic onto a neighbouring residential road.
We have received requests for “data” to provide evidence/justification for the LTN. However, the purpose of the LTN is to prevent increased future rat running given the likely lack of public transport use. To predict this would require expensive and time-consuming traffic modelling to calculate, but there simply isn’t the time or money to do this. As the local authority, it is our duty of care to residents to ensure we prevent any foreseen negative consequences, which is our intention with these LTNs.
The Widely Circulated Draft Plan
The draft plan that many of you have seen is not the final plan, nor the scheme that will be implemented.
The draft proposal was put together for a bid to TfL for funding. The timeframe to submit bids to TfL was very short, but the bid needed to demonstrate how an LTN scheme could work as well as form the basis of the cost estimate. Given this tight turnaround, the draft was simply an indicative proposal, rather than a concrete plan. It was not intended for public viewing without any form of explanation, so it is unfortunate that this is the case.
Now that funding has been approved for the scheme, our officers are taking a detailed look at the designs and making the appropriate amendments. One controversial part of the proposal was the “through route” via Waldemar Avenue. There were good reasons for its initial inclusion, mainly related to access for refuse vehicles and emergency services, as well experience from other LTNs showing that through-routes do not gain significant volumes of traffic if designed well. However, we have found an alternative way of dealing with access for refuse vehicles and emergency services, so a through-route is not part of our current plans.
LTNs are not new; they have been implemented in many other locations in London, the rest of the country and indeed around the world. The impacts of LTNs are, therefore internationally recognised. The Council would not be proposing to implement LTNs if the impacts were usually negative. However, we have received multiple objections, probably because the impacts might seem counterintuitive. Experience, however, has shown that once implemented, the majority of objectors change their mind. An excellent case study is the “mini-Holland scheme” in Waltham Forest (which used a different name for their LTN, but the principles are very similar) where residents were initially opposed, but after seeing the effects, are now majority in support.
According to UK charity Living Streets, LTNs reduce total traffic by an average of 15% across the target area. This is before any increase that is likely to be experienced as normality resumes post lockdown, given the expected reductions in public transport use.
Through-traffic is less likely to obey speed restrictions, given the intention to save time by cutting through a residential area. By reducing this through-traffic, the area therefore becomes much more pleasant for walking and cycling. This benefit applies to people of all ages, because staying active is important to everybody, no matter your age, according to NHS advice on keeping healthy.
Access for Emergency Services, deliveries, etc
Emergency services and refuse vehicles will still be able to access the entire area. The intention is now to include a “drop down bollard”, which is unlocked using a standard key which the drivers carry routinely. Emergency services have been consulted on this arrangement and have raised no significant objections.
Delivery vehicles will still have access to all streets, just as residents will. As with other transport schemes, we aim to update the key mapping companies such as Waze and Google Maps, which are used by delivery services, minicabs, Uber and so on.
Reduced traffic also means less air pollution, traffic noise and improved road safety. For example, air quality monitoring found that similar interventions in Waltham Forest led to a 90% reduction in household exposure to Nitrogen Dioxide.
Reducing traffic will also decrease the contribution to climate change through lower levels of CO2 emissions. Please see the reports at the end of the document for further information.
Implementing the Scheme and Consultation
The scheme will be implemented using temporary materials and an Experimental Traffic Order (ETO). It will therefore not be a permanent scheme, although has the potential to become one in the future should residents want it.
The road closures themselves will be a combination of planters and the aforementioned drop-down bollards. The initial plan was to use concrete blocks, in line with Government and TfL guidance, but this combination is more attractive and improves emergency and refuse vehicle access. There would also need to be some double yellow lines added in the vicinity of the road closure to allow room for vehicles to turn.
An ETO is a requirement of the funding and follows Government guidance on implementing COVID related LTN schemes. An ETO is a legal document which imposes traffic and parking restrictions, but as the name suggests, allows the scheme to be tested to see if it works, as well as allowing changes to be made. There are two main advantages of an ETO; one is that it allows a council to move fast, which in this case, is criteria for the funding, and secondly, it lets people actually see how a scheme works before a permanent decision is made, rather than base their feedback on an abstract plan.
The COVID funding available to us requires that measures be delivered by September, otherwise the allocation will be retrieved by TfL. Therefore, were we to conduct traditional forms of consultation we would be unable to implement any measures to mitigate the predicted oncoming congestion.
An ETO can stay in force for a maximum of 18 months while the effects are monitored and assessed, of which the first six months become the consultation period. There is a statutory minimum one- week notification/advertising period prior to the ETO coming into force so those affected (including the emergency services) are aware of the start date of the scheme.
Changes can be made during the first six months if necessary, before any decision whether or not to make the scheme permanent. The decision to make a scheme permanent will follow the Council’s formal decision-making process.
It is not possible to lodge a formal objection to an ETO until it is in force. Once in force, any objections must be made strictly within the six-month period. If, due to feedback or an objection, changes are made, then the objection period resets, allowing a further six months. It is highly likely we will carry out a more structured engagement towards the end of the 6 months to ensure we capture all viewpoints. The details of this are, at the time of writing, still to be fully developed, but you will be kept informed of how to contribute.
Although there will be advanced warning signs, it is common for there to be traffic disruption for the first few days or weeks after the LTN is implemented. This resolves itself once drivers have become accustomed to the new road layout and adjusted their journeys accordingly. We would, therefore, urge you to wait to see the final impacts rather than making a comment on the first few days.
Timetable for Implementation
The scheme is still going through the detailed design stage so there isn’t a specific date to implement this scheme yet, although as per funding criteria, all COVID schemes must be implemented by September 2020. You will, however, receive the notification of the ETO and its start date delivered to your door one week in advance.
• What is the objective of the scheme?
To reduce or remove rat running traffic from this residential neighbourhood in light of the anticipated increase in traffic likely to arise from much lower use of public transport
• What are the timelines for the scheme?
To be implemented by September 2020, but the exact date is subject to confirmation
• What is the consultation period for the scheme?
The consultation period will be for 6 months from the date of the Experimental Traffic Order
• Why use temporary materials?
Because they are easily moved or removed should there be significant negative impacts. If the scheme gets made permanent, then more permanent materials can be used at this point.
• What are the success criteria?
It will be a combination of observed traffic reduction, increased walking and cycling, few negative impacts (e.g. on emergency services) and feedback from residents. Your local Ward Members will be involved in the decision.
We hope that these explanations show the rationale behind the schemes and reassure those with concerns.
Below are some useful links which provide more detail about Low Traffic Neighbourhoods and how Emergency Traffic Orders work.