Dulwich Review Response

Corporate response to the Dulwich Streetspace Review from the Dulwich Alliance

The Dulwich Alliance is an alliance of residents’ associations, societies, health centres, business groups, sports clubs, local businesses and campaign organisations, who support Southwark Council’s stated aims of reducing pollution and encouraging active travel, but in a way that is inclusive, fair and socially just. The ETOs that are the subject of the current Review Survey do not achieve any of the ‘Streets for people’ aims.

Since its inception, in December 2020, the Dulwich Alliance has regularly and repeatedly highlighted the many serious shortcomings and negative impacts the Dulwich LTNs have had on residents, health and social care workers, businesses, and other stakeholders in the Dulwich area. These are listed below. Several of them have had serious consequences on the health and wellbeing of vulnerable sections of our society, such as vehicle-dependent residents with disabilities, elderly residents, schoolchildren and nursery children on so-called ‘displacement routes’, and other vulnerable groups with protected characteristics.

Council officers and councillors responsible for transport, clean air, health and wellbeing, equalities and children all failed to anticipate or fully consider the consequences of the Experimental Traffic Orders they imposed, without consultation, on people living in Dulwich and the wider Dulwich area. Not to rectify the consequences of their actions, especially after being alerted to so many problems by so many residents, health and social care workers, shops and businesses, and others who have been so adversely affected, amounts to a dereliction of public duty, a denial of human rights and a failure to uphold the Seven Principles of Public Life.

We call on Southwark Council to accept its failings, set aside this unworkable and unpopular scheme, and work with all stakeholders, not just an unrepresentative few, to develop together an equitable and constructive solution to traffic and travel in the Dulwich area. We need a solution that leads to a reduction in traffic and an improvement in air quality, road safety and public transport, which encourages those who are able to do so to walk and/or cycle, and which also meets the needs of the wider community, particularly those more vulnerable members of our society who depend on the Council to represent their interests and leaves no one behind.

Below we set out the nine key reasons why the road closures and traffic restrictions have not been successful, do not meet the aims of ‘Streets for People’, and have created distrust and division in our community. They need to be removed as soon as possible and replaced with a solution co-created with the community that works for everyone. We set out 10 key principles that we believe would provide the basis for a better and fairer solution for traffic and travel in the Dulwich area.

Part 1: Key reasons the road schemes introduced in the Dulwich area are failing to meet their stated aims:

The road schemes do not improve road safety or make walking and cycling an enjoyable, safe and easy way of getting around, nor improve air quality, reduce pollution and noise levels for people living on Dulwich’s so-called ‘displacement routes’. This is because they push traffic and pollution from some roads on to neighbouring residential streets where thousands of children go to school, creating cleaner air and safer roads for a few roads inside the LTNs but dirtier air, increased traffic congestion and more dangerous travel for those on the outside.

Recent pollution monitoring shows that Calton Avenue, a key beneficiary road inside the Dulwich Village LTN, had Nitrogen Dioxide (NO2) levels in April of 19 micrograms per cubic metre, well below the WHO guideline of 40 mgms/m3, but that weekday NO2 levels on displacement routes have been around 60 mgms/m3 or higher. This is unacceptable. Thousands of children walk and cycle to schools on these roads. Children’s developing bodies are especially vulnerable, and dirty air contributes to increased asthma, obesity, mental disorders in children and, as evidenced by the case of Ella Kissi-Debrah, can lead to deaths.

The Council’s hoped-for traffic ’evaporation’ has not happened. Instead, it has created a scheme that dumps toxic waste from some streets where wealthier residents live on to other roads where people on lower incomes live. This increases inequalities in health and wellbeing instead of reducing them, which is morally unacceptable and in contravention of the Human Rights Act 1998. This must be stopped without delay.

The road schemes do not help tackle the climate emergency. On the contrary, longer journeys and more traffic congestion increase overall carbon emissions.

The closures and restrictions make journeys longer for people living in Dulwich and for vehicles entering Dulwich and bypassing Dulwich. Journeys that used to take 10 minutes now take up to 40 minutes. London Travel Demand Surveys published in the Dulwich Area Traffic Management Study in 2018 show that before the pandemic, 68% of short journeys in Dulwich were being undertaken on foot or bicycle. While a further reduction in car use for short journeys should be encouraged, this is unlikely to happen unless Dulwich’s poor public transport is improved (the congestion on bus routes is currently achieving the exact opposite). Forcing cars on to displacement routes increases our collective carbon emissions and contribution to climate change. This does not meet the Streets for People aim of helping to tackle the climate emergency.

The road schemes cause delays to emergency vehicles, endangering people’s lives.

The closures in Dulwich Village and East Dulwich prevent emergency vehicles from getting through and the detours they have to take causes them to take longer to reach their destinations. Ambulance crews have reported delays in the Dulwich area of up to 10 minutes responding to life-threatening 999 calls. Average scene to hospital times have gone up by 2.5 minutes.

We are aware that the London Ambulance Service (LAS) has requested that Southwark replace the planters at the Dulwich Village junction with ANPR cameras. This is in line with LAS’s publicly stated position that it wants ANPR cameras to be used, instead of planters or bollards, as they result in “much lower levels of incident reporting”. The London Fire Brigade and Metropolitan Police have both highlighted the extent to which fixed road obstructions, such as planters, also hamper their ability to reach emergency situations.

Dulwich Alliance members have recorded many incidents of ambulances that have been delayed by the closure of Calton Avenue and we are aware of many residents who have had first-hand experience of delays caused by the closures and traffic congestion on the routes emergency vehicles have been forced to take. Several of these incidents have been communicated to Southwark Council, including to the leader of Southwark Council. However, despite the life-threatening nature of these delays, the Council has failed to install ANPR cameras at the Dulwich Village junction, continuing to put lives at risk. As a Metropolitan Police Officer attending a liaison meeting between Southwark Highways Department and the Emergency Services in July 2020 put it, ANPR cameras might be more expensive than planters but this is about saving lives.

The road schemes are increasing not reducing inequalities in health and wellbeing because they are preventing local community health and social care workers from reaching patients and clients in a timely manner, putting patients’ and elderly residents’ health and wellbeing at risk.

As Darren Farmer, former Assistant Director of Operations, South East Area, LAS NHS Trust, has pointed out to the Council on more than one occasion, the closures do not just impact blue light responders. A broad range of health workers is affected, including GPs, community first responders, community nurses, patient transport going to and from cancer appointments, and care services.

A local Health Centre has told the Council how its GPs are taking longer routes to visit their patients, and how their patients having to take longer routes to attend the Tessa Jowell Health Centre for blood tests and for their appointments at the surgery. Community nurses also struggle as these changes add to their journey times and make their days longer.

“The delays are so bad,” NHS midwives have told One Dulwich, a Dulwich Alliance member, “that I worry I won’t get to home births in time.” Many carers aren’t paid for travel time, so longer journeys caused by displaced traffic mean less client time and less for carers to live on. A local care provider, Home Instead, a member of the Dulwich Alliance, says the closures and restrictions mean carers no longer want to work in Dulwich.

The Dulwich Alliance and its members, including local GP surgeries, have been pointing out the difficulties these groups are experiencing to Southwark Council for some time but so far the Council has failed to acknowledge them, let alone attempt to find ways to mitigate them.

The road closures discriminate against residents with protected characteristics

The Council is failing in its Public Sector Equality Duty by discriminating against residents with protected characteristics as defined by the Equality Act 2010.

In particular, elderly residents who are mobility-impaired and who depend on vehicle transport to attend GP surgeries and hospital appointments are having their access to health and social services impaired. Fines and restrictions make elderly people anxious about going out, in case they can’t get back in time or failing memories mean they worry they will forget about the cameras. So they don’t go out, and this has caused many cases of increased isolation and loneliness.

Many residents with disabilities, young and old, who are mobility-impaired do not qualify for a Blue Badge. Even if they did, the closure of Dulwich Village junction has resulted in elderly people living east of the junction struggling to get to appointments at GP practices to the west of the junction and vice-versa.

The Dulwich Alliance and its members are aware of dozens of elderly, mobility-impaired residents who have written to Southwark Council pointing out the negative health and wellbeing impacts the ETOs have had and are having on them. These concerns have not been addressed and, as a consequence, the Council is directly responsible for having caused, and continuing to cause, considerable hardship and distress to vulnerable sections of our community.

General practitioners, registered carers and other health and social care service providers have also written to the Council explaining how the closure of Dulwich Village junction and other restrictions have prevented home visits.

The Council has failed to conduct and publish an Equality Impact Assessment, even though it has had over a year to do this.

Announcements that the Council would publish an ‘updated’ EqIA have failed to materialise. The list of organisations the Council have indicated it will consult is totally inadequate. For example, it includes Wheels for Wellbeing – a branch of the London Cycling Campaign that supports people with disabilities who wish, and are able, to cycle – but does not include local GP surgeries or social care providers. The Council indicated that elderly and people with disabilities were key stakeholder groups and that it intended to hold meetings with these groups. This hasn’t happened.

The Dulwich LTNs Review is a flawed process and so biased and open to interpretation that its impartiality and validity is undermined. No data has been produced by the Council to enable people to respond to the survey informed by facts rather than opinions

Although the Council committed to publishing data showing pedestrian and cycle counts, traffic counts, bus performance data, traffic light data at junctions, air quality data, accident data, penalty charge notice data and school travel survey data, this information has not materialised. This data is needed for respondents to be able to judge the effects of the measures. Without this evidence it is impossible for respondents to the Dulwich LTNs Review Survey to know if the Council is meeting its objectives or give an informed opinion. No reason has been given for this failure to publish.

A technical evaluation of the Dulwich LTNs Review by an independent public research and audience measurement specialist, commissioned by the Dulwich Alliance, found that the Review process makes no “serious attempt to establish stakeholders’ views”, and “falls far short of the standard which should be expected from a serious public consultation exercise on issues which impact the lives of residents and businesses.”

The report, which was conducted by Roger Gane, an independent market and public sector research consultant and former managing director of Ipsos UK, now Ipsos Mori, concludes that “In my view, the Council will not be able to draw any valid conclusions from it”.

On the key question that asks people their preference for the future of the road schemes, the report points out that “those responding are faced with three options for retention against a single one for removal”, adding “this question is clearly of central importance, and its design and construction is not satisfactory.”

Among Mr Gane’s other findings were that there was:

No attempt to structure the consultation to define stakeholder groups or establish their importance
No serious attempt at systematic contact with stakeholders or ensure different groups are adequately represented
No meaningful questions on people’s behaviour or the effects of closures on such behaviour
No mention of any ‘trade-offs’ which may have to be made if the schemes are made permanent
Insufficient information on the projected effectiveness of the schemes to provide rational answers
No attempt to provide ‘balance’ in the questions, which are heavily weighted towards cycling and worded in such a way that ‘participants are likely to find it difficult to disagree’.
No mechanism for validating the sources of response

The report concludes that “It is clear that the Review will fail to provide a fair and proper analysis on the acceptability of the Streetspace schemes to those affected by them. Given this it is reasonable to press for the Review to be withdrawn or fundamentally modified.”

Mr Gane’s technical insights highlight the extent to which the Council is failing to provide people living in Dulwich with a fair and reasonable opportunity to say what they think of the traffic measures that were imposed on them without consultation a year ago. Every single aspect of how the Council is running this Review is badly done, poorly designed, and unacceptably biased. People living in Dulwich deserve better than this from their Council.

By introducing these controversial measures in 2020 without consultation, the Council knowingly created social division. As the negative health, wellbeing and social consequences of the road schemes have been made known to the Council, its officers and councillors have failed to address them or mitigate them.

Hundreds of emails and letters have been written to the Council highlighting the many problems that have been caused by the road schemes.

The Council and councillors have consistently and insensitively disregarded these difficulties, causing distress to large numbers of people, and in many cases failing to recognise that it is their responsibility to represent the community and work constructively with them to secure better social, economic and environmental outcomes.

This has been compounded by the behaviour of local councillors who have not only refused to help their constituents, or insisted that severe difficulties amount only to “inconvenience”, but have made distressing situations worse by disparaging genuine attempts by individuals and groups of residents to find a solution that does not discriminate against vulnerable residents.

The Council owes it to these people and these groups to work hard to repair the damage it has caused to the social fabric of the Dulwich community, not just the physical structure of its streets, and to bring the community together again around a solution everyone can support.

The road closures do not “encourage people to shop local to help businesses”. Local shops, businesses, sports clubs and community groups are suffering substantial losses in trade resulting in business closures, and undermining the future of Dulwich Village, Melbourne Grove, Grove Vale and Lordship Lane as shopping centres

Hundreds of shops and businesses in Dulwich Village, East Dulwich and the wider Dulwich area have written to Southwark Council to protest at the lack of consultation with them about the impact of the Dulwich LTNs road closures and traffic restrictions on our businesses and livelihoods.

Many submitted formal objections within the statutory six-month period after the ETOs were introduced in June and September 2020 and have written on numerous occasions to councillors and council officers to highlight the devastating consequences these measures are having on their ability to trade.

The assumption is that all difficulties have been caused by Covid-19. In fact, the far bigger challenge to recovery has been the road closures, restrictions and parking measures. The Council’s High Street Recovery Fund asks for great ideas to transform Southwark’s high streets, but the idea that would make the biggest impact – removing the road closures and restrictions – is being ignored.

What makes it worse is that the Council keeps saying that restricting vehicles is good for business. The exact opposite is the case. When it comes to high streets, TfL’s studies show that car-users spend significantly more per visit than people walking or cycling and that cyclists are the lowest spenders of all, whether per visit or over time. While there are a few shops that can happily survive with just local shoppers who walk and cycle, many more are ‘destination shops’ that rely on visits from people who live much farther away and who depend – because public transport is poor – on using their cars. Shoppers like these are put off by closures, fines and increased congestion.

It seems that the Council is doing all it can to stop people shopping locally and to force them instead to shop online. This means further dependence on delivery vans, which are greater polluters overall than private cars.

Businesses other than shops are suffering. Customers can no longer reach sports clubs, exercise classes and dance classes on time, because journeys have become too onerous or unpredictable and because the risk of fines is too great. After-school activities and clubs before 6pm are being cancelled. All this is having a negative impact on health and wellbeing across the wider area and works directly against the Council’s policy of increasing physical activity and reducing levels of obesity.

At the beginning of the Dulwich Review consultation, the Council said that businesses were an important stakeholder group. It promised to hold meetings with them, as part of the Review, to discuss the impact of the traffic measures. Nothing has happened. Despite repeated and increasingly desperate emails asking to be heard, no meetings have been scheduled.

Part 2: key principles that would provide the basis for a better and fairer solution, co-created by the Council with the community, for traffic and travel in the Dulwich area.

An area-wide approach to reducing traffic and improving travel (including walking, cycling, car use and public transport) that treats all stakeholder groups equally and fairly, and is genuinely open to all options.
A set of concrete, measurable objectives that any traffic and travel scheme must meet.
Co-operation and compromise by all those involved. It’s unlikely that everyone will get everything they want.
Detailed analysis of the reasons for journeys and the obstacles that prevent drivers from choosing alternative modes of travel (for example, poor public transport) in order to find practical solutions.
Baseline data on traffic and air pollution over the wider area before any scheme is implemented, even as an experiment.
A comprehensive Equalities Impact Assessment before any scheme is implemented, with meaningful input from groups representing those with protected characteristics (such as the elderly, people with disabilities, pregnant women, and new mothers).
A commitment to making travel to school safer and healthier for all children across Dulwich and the surrounding area.
To help stakeholders identify what works best, a range of actions that enable people to use private motor vehicles less, and encourage them to choose public transport and active travel more, in addition to technically feasible road measures. Carrots are needed, not just sticks.
Separate discussions with individual stakeholder groups to discuss and agree a solution that works for Dulwich – which may well be different from solutions applied elsewhere.
Post-implementation monitoring of traffic and air pollution over the wider area in order to evaluate change, and regular checks with stakeholders to ensure the solution works for everybody.