Why Southwark’s decision on the Dulwich LTNs is unsafe

In the run-up to the local elections on 5 May 2022, Southwark continues to deliver expensive updates through our letterboxes defending its Streetspace schemes. (Quote from the March 2022 update: “In just under two years, we have introduced 10 transformational Streetspace schemes across the borough.”)

However, the decision to make the Dulwich LTNs permanent is clearly unsafe because it is based on a number of failings, including:

1. Poor data analysis

We have already reported on Southwark’s poor and unreliable data (see our News updates of 5 November 2021 and 19 December 2021). Raw data is still hard to access (none has been published for 2022), and is presented in such a chaotic way (sometimes weekly, sometimes monthly) that only people with unlimited time and resources can work out how much of it is missing. A reliance on ‘overall’ figures hides significant problems on individual roads like East Dulwich Grove.

There has been no attempt to bring together data from all available sources – ATC (Automatic Traffic Counting), Vivacity, WAZE, SCOOT, etc – in order to highlight anomalies, or to analyse the specific effects of the LTNs on the boundary roads. On Croxted Road, for example, an analysis of SCOOT data shows that weekday morning congestion – leading to increased pollution and delays to essential bus services – has increased by 100% at peak hours since the LTNs went in.

Is Southwark’s poor data provision and analysis the result of general incompetence, or an attempt to cloud the true picture of what’s going on?

2. No local support

As we all know, two-thirds of those who responded to the consultation rejected the road closures. But Southwark has gone ahead anyway. Legally, the Council can do this. It demonstrates, however, that Southwark has lost touch with the needs and views of local people and is no longer concerned about having a democratic mandate for its actions.

3. Insufficient analysis of socio-economic impact

Southwark’s Equality Framework summary makes a clear commitment to addressing socio-economic disadvantage. But in the December 2021 report, supporting the final decision to make the Dulwich LTNs permanent, socio-economic impacts are dismissed in just one paragraph (paragraph 49) with no evidence to back up officers’ assertions at all.

4. Insufficient analysis of impact on groups with protected characteristics

Similarly, in the same report (paragraph 47), the Council dismisses adverse effects on those with protected characteristics. These are some of the most vulnerable people in our community, including the elderly and disabled, whose needs should be central to Council decision-making.

5. Poor attention to detail

Council officers have misrepresented several aspects of the scheme in reports for the decision-maker Cllr Catherine Rose (standing for re-election in Dulwich Wood ward in May). For example, if you look at Appendix A of the November 2021 report summarising objections from the public to the revised Streetspace scheme, Council officers (see points 3 and 4) imply that the Dulwich Village/Court Lane/Calton Avenue junction will benefit from the amended exemptions policy (allowing through Southwark Blue Badge holders, SEND vehicles and rapid response health workers). But it doesn’t benefit from this at all. Dulwich Village junction remains closed to all traffic except for emergency vehicles – and currently the signage is so poor that even ambulances aren’t venturing through.

So why is Southwark Council pushing ahead with this flawed decision?

The possibilities are:

• Weak leadership

• Pressure from lobby groups (see our earlier News piece)

• Lack of resources – no one willing or able to carry out the necessary research/analysis

• Unwillingness to lose the income from fines (roughly £12m across Southwark in 2021)

• Desire for extra government money (via TfL) for active travel schemes, whether they work or not

• Inability/reluctance to grasp the difference between (1) local schemes that genuinely reduce traffic and emissions, change behaviour, and contribute to fighting the climate crisis, and (2) local schemes that amount to nothing more than ‘greenwashing’ i.e. paying lip service to green issues but having no environmental impact at all

Can we challenge this unsafe decision?

We now know (see the statement by the Dulwich Alliance) that the Council has ticked all the boxes required by law, so it is not possible to challenge the decision in the courts.

We can, however, challenge the culture of decision-making in the Council when we vote in the local elections on 5 May 2022.

To do this, we need to vote for local councillors who will:

• stand up to internal Council politics, special interest lobby groups and greenwashing;

• commit to representing the views of the whole community; and

• commit to ensuring that decision-making is based on sound reasoning and detailed analysis.

Please make your vote count on 5 May 2022.