Lambeth council have issued a 1,136 word response to a petition signed by more than 1,000 people urgently calling for an immediate re-evaluation of the proposed West Dulwich Low Traffic Neighbourhood “due to critical concerns that no clear impact assessment has been carried out.”
In their response Lambeth council:
- admit Croxted Road – on the Lambeth / Southwark border where the number 3 bus route goes – is congested;
- admit removing cut-throughs carry the risk of displacing vehicles onto neighbouring roads, particularly within the first few months of the scheme; and
- now say ” behaviour change is key to traffic evaporation”
But it totally ignores many – if not all – of the other points the petition raises:
- That Transport for London (TfL) collision data indicates the LTN, contrary to its intended purpose of improving safety, will exacerbate existing issues;
- That, currently, 93 per cent of all accidents in the area occur on roads where traffic is expected to increase due to the LTN;
- That only three accidents have been recorded on the roads proposed for closure in the past five years, challenging the necessity of such measures;
- That there would be heightened health risks – higher pollution impact as greater volume of pedestrians on boundary roads;
- That worsening public transport delays won’t discourage car use, mirroring Streatham LTN’s issues; and
- That introducing traffic and dangerous intersections to a designated ‘healthy route’ undermines its purpose.
There is:
- NO Mention of collision data in the response;
- NO concern by Lambeth council about higher pollution impacts on pedestrians walking on boundary roads – only that: “It is anticipated that as journeys in private motor vehicles are switched to more sustainable modes of transport, and as it becomes less convenient for external traffic to cut through the neighbourhood, traffic volumes and associated air pollution will reduce on Rosendale Road and other streets in the area; and
- NO response to the comment that “worsening public transport delays won’t discourage car use” except “The impact on existing bus routes and TfL’s road network (A205) has been carefully assessed during the development of this proposal to ensure there is no detrimental impact” – without explaing what the result of any assessment/s is / are. And that “removing proposed modal filters on Idmiston Road was actioned to mitigate any risk of impact to the 322-bus route on Robson Road.”
- A request for immediate consultation is dismissed with this comment: “Please note that the street improvements, when launched, will trigger a six month statutory consultation under an Experimental Traffic Order (ETO) where representations can be made to the council.”
But they do say:
- TfL’s cycling quality standards and Lambeth’s Healthy Routes criteria require protected space for cycling on roads which have more than 200 mvpph (not explained what mvpph is in Lambeth’s response – Ed.)
Lambeth’s response in full (words placed in bold type by News From Crystal Palace):
The 2019 Lambeth Transport Strategy included an LTN Transport Strategy Implementation Plan (TSIP) which assessed the whole borough against a range of metrics such as levels of through traffic to help the borough prioritise LTNs for implementation. Cell ‘BR’ (the area in which the West Dulwich street improvements sits) from page 6 in the LTN TSIP plan scored highly (13) which indicated the need for mitigation, and development work began in 2022.
In addition, since 2015, Lambeth council have received numerous reports of high volumes of traffic using minor roads to travel between the Gipsy Hill area and the A205 and/or Herne Hill junction, as a means of avoiding various traffic light systems and congestion on main roads (such as Croxted Road). Data from traffic counts and modelled traffic flow data corroborates this, as detailed in the Baseline Traffic Data Report, published in 2022[1].
Traffic data shows more than 300 motor vehicles per peak hour (mvpph) counted on Dalmore Road at peak. The modal filter on Eastmearn Road is proposed to prevent this cut-through movement.
Modal filters on Tulsemere Road, Ardlui Road and Chatsworth Way are proposed to prevent cut-through traffic, which currently uses Eastmearn Rd /Dalmore Rd, from displacing onto these roads. Traffic data shows more than 850 motor vehicles counted on Rosendale Road at peak (south of Eastmearn Rd) – around a third of which uses the Eastmearn Rd /Dalmore Rd cut-through.
The volume of traffic on Rosendale Road is why protected cycle tracks are proposed. Rosendale Road was identified by TfL as a key strategic cycle route, providing a continuous cycle connection between Gipsy Hill and Brockwell Park. The route connects into Cycleway 17 in Southwark and Cycleway 48, which runs north to Clapham and Brixton via Railton Road, and southeast to Streatham.
TfL’s cycling quality standards and Lambeth’s Healthy Routes criteria require protected space for cycling on roads that have more than 200 mvpph. As part of exploring various options for the Healthy Route, engineers examined the possibility of closing Rosendale Road to motorised traffic but the risk of perpetuating congestion issues on Croxted Road makes this unfeasible.
Removing cut-through traffic and disincentivising short-distance journeys in private motor vehicles only goes so far.
Removing cut-throughs carries the risk of displacing vehicles onto neighbouring roads, particularly within the first few months of the scheme. This is why behaviour change is key to traffic evaporation.
The overarching objectives of the Lambeth Transport Strategy[2] is net traffic reduction in line with the Mayor’s Transport Strategy[3]. The predominant reason for congestion, air pollution and road danger across the borough, is too many journeys in private motorised vehicles.
The Mayor’s Transport Strategy suggests that a 27 per cent reduction in motor vehicle kilometres is required to reach net zero by 2030. Lambeth policy makers understand that some journeys need to be made by private motor vehicle, but these can be significantly reduced. Overall traffic reduction would benefit air quality and public health, reduce carbon emissions, support people to switch to active journeys (when possible), and make it easier for people who rely on motorised transport, by reducing congestion.
Lambeth are aware that Rosendale Road has high volumes of vehicular traffic, which is why interventions which support behaviour change and sustainable transport modes are needed.
It is anticipated that as journeys in private motor vehicles are switched to more sustainable modes of transport, and as it becomes less convenient for external traffic to cut through the neighbourhood, traffic volumes and associated air pollution will reduce on Rosendale Road and other streets in the area.
The impact on existing bus routes and TfL’s road network (A205) has been carefully assessed during the development of this proposal to ensure there is no detrimental impact because we recognise the importance of bus networks as a part of the shift towards more travel by sustainable transport that is needed to support traffic reduction targets.
This is also a statutory responsibility for the council under the Traffic Management Act and we have engaged with TfL over the proposals and the potential impact. TfL are, of course, a key stakeholder in the project. Not least because one of the boundary roads (the A205) is a TfL road and because TfL are redesigning the Rosendale Rd/ A205 junction – a vital link in the Healthy Route.
The A205 stands to benefit from the traffic filters. By preventing traffic cutting through Eastmearn Rd and Dalmore Rd, fewer vehicles will be turning in and out of Dalmore Road (turns which are unsignalised and impact flows on the A205).
Instead, movements of vehicles joining the A205 (South Circular Road) from the south will be controlled by signals at the Rosendale Rd / A205 junction and the Croxted/A205 junction.
In addition, removing proposed modal filters on Idmiston Road was actioned to mitigate any risk of impact to the 322-bus route on Robson Road. Traffic volumes and bus journey times on all boundary roads will be monitored during the trial.
The Brockwell Park to Gipsy Hill Healthy Route is a key part of the Healthy Routes network and TfL cycleway network, connecting several neighbourhoods, schools, businesses, green spaces and public transport hubs.
The route has been divided into four phases:
• Phase 1: between Brockwell Park and Turney Road
• Phase 2: between Turney Road and A205 South Circular
• Phase 3: between A205 South Circular and Park Hall Road
• Phase 4: between Park Hall Road and Gipsy Hill Station
The proposed alignment of the whole route went through public informal consultations in 2016, 2017 and 2018 as part of the wider consultations relating to the Quietway 7 route.
Phase 1 of the Healthy Route was installed in January 2021 under a temporary traffic order (issued on 28th November 2020), which was made permanent in January 2023. Phase 1 consists of two-way mandatory cycle tracks (protected by traffic wands), a banned left turn at junction with Turney Road, floating parking and four zebra crossings.
Phase 2 was installed in November 2023, consisting of:
• Three-metre-wide two-way cycle tracks protected with traffic wands along the eastern side of Rosendale Road, between Turney Road and the A205 South Circular.
• A parallel zebra pedestrian and cycle crossing near the junction of Turney Road, connecting the existing cycle track delivered in Phase 1.
• The uncontrolled crossing on Turney Road, outside the entrance to Rosendale Primary School was upgraded to a zebra crossing.
• The mini-roundabout at the junction of Turney Road and Rosendale Road was replaced with priority T-junctions, including widening footways and installed dropped kerbs, tactile paving and road markings
• A parallel zebra pedestrian and cycle crossing near the junction of Lovelace Road.
• The uncontrolled crossing on Rosendale Road, adjacent to All Saints church, was be (sic) upgraded to a raised zebra crossing.
Phase 3 is planned between the A205 South Circular and Park Hall Road, as a continuation of the bidirectional protected cycle track (physically separated with splitter islands and traffic wands) is proposed.
Please note that the street improvements, when launched, will trigger a six month statutory consultation under an Experimental Traffic Order (ETO) where representations can be made to the council.
Editor’s note: News From Crystal Palace have amended a few words / symbols in the council’s full response: ‘Over’ has been changed to ‘more than’; the per centage seesaw symbol has been changed to per cent or pc, so anyone checking the figure of 1,136 will now find it slightly higher. Numbers in brackets in Lambeth’s response have no link to them published in response.
NEWS FROM CRYSTAL PALACE 