Ealing Cycling Campaign: Council Report Ignores Benefits of LTNs

A pile of dozens of children's bicycles in one of Ealing's Low Traffic Neighbourhoods with a sign saying "What about the Children?"

A pile of children's bicycles - a protest against Ealing Council's plans to allow through traffic on residential roads which will make the streets two to four times more dangerous for children.

Ealing Cycling Campaign has written to the Chief Executive of Ealing Council objecting to omissions in its officers' report to cabinet which recommends the removal of seven LTNs. The report ignores the widespread evidence that shows the benefits of low-traffic neighbourhoods. The council failed to carry out counts of walking and cycling in the borough, which means it can't quantify the shift from car use to active travel. Its report fails to mention data in an independent study that indicate people in the outer London LTNs installed last year spent 58 minutes more per week walking and cycling compared to people outside the LTNs, and 44 minutes less driving. The cabinet is due to vote on the report's recommendations tonight (22 September 2021). If the cabinet votes to remove the LTNs it will cause more people to be injured on Ealing's roads, reduce the amount of walking and cycling in the borough, and increase the amount of car use.

The text of our letter to the Chief Executive is below:

Re: Officers' report to cabinet: London Streetspace Plan (COVID Emergency Transport Measures) Update

Dear Mr. Najsarek,

We have serious concerns about this officers' report to the cabinet which recommends the removal of seven low-traffic neighbourhoods. The report contains serious omissions with the result that it fails to give an accurate picture of the benefits of the LTNs. It fails to make councillors aware of the new network management duty guidance, issued by the Secretary of State for Transport on 30 July 2021. It fails to make councillors aware that removing LTNs will result in a withdrawal of government funding for transport schemes in the borough. It makes recommendations which will negatively impact the council's three strategic priorities. And finally, it ignores the impact the removal of the LTNs will have on Ealing's Cycling Network. In short, it doesn't appear to have been based on evidence, but to have been written to justify a pre-determined decision.

1. Omissions

PEDESTRIAN AND CYCLE COUNTS

The council has not published any pedestrian and cycle counts for the 2020 low-traffic neighbourhoods. Given that the schemes were installed to increase the amount of walking and cycling, this is a serious omission. The report makes reference to the academic paper, The Impact of Low Traffic Neighbourhoods on Active Travel, Car Use, and Perceptions of Local Environment during the COVID-19 Pandemic, but fails to mention that the paper reports 58 minutes of extra active travel per person, per week in the outer London 2020 LTNs. This is a considerable benefit. There is also evidence from earlier LTNs in London that shows they increase the amount of walking and also, to a lesser extent, cycling.1 In the absence of data from Ealing this should be presented as a guide to the cabinet.

Ealing Cycling Campaign's own count, comparing cycle levels on Salisbury Road in LTN21 between September 2018 and September 2020 showed an 88% increase after the LTN was installed. Since the LTN was removed we have seen a 22% drop in cycling. This is likely to fall further if the nearby LTNs are removed.

REDUCTION IN CAR TRAVEL

Ealing hasn't published data on this. The report refers to the academic paper, The Impact of Low Traffic Neighbourhoods on Active Travel, Car Use, and Perceptions of Local Environment during the COVID-19 Pandemic2, but fails to mention that it found that minutes of car travel per person, per week in the Emergency LTNs was 44 minutes less, compared to control groups living outside the LTNs. This is a significant reduction and deserves further investigation.

HEALTH BENEFITS

One of the recognised benefits of LTNs is better health. For instance, the hospital charity, Guy's and St. Thomas' Charitable Trust contributed £250,000 to fund three low-traffic neighbourhoods in Southwark. Most of the benefits are due to increased walking, with predicted longer life expectancy.3 This information is absent from the report.

REDUCED ROAD TRAFFIC INJURIES

The report quotes an academic study that shows London's low-traffic neighbourhoods reduced road traffic injuries by half.4 An earlier study of pre-2020 LTNs indicated that walking, cycling, and driving all became approximately 3-4 times safer per trip inside LTNs with no change on the boundary roads.5 LTNs offer significant improvement in safety to vulnerable road users, and the report should give this greater prominence.

CRIME

The report notes that crime is slightly down in LTN areas, but states that there has not been enough time to draw any conclusions about their longer-term impact. An academic study, not included in the officers' report, found long-term benefits of LTNs.6 It reported that the introduction of LTNs "was associated with a 10% decrease in total street crime, and this effect increased with a longer duration since implementation (18% decrease after 3 years). An even larger reduction was observed for violence and sexual offences. The only subcategory of crime that increased significantly was bicycle theft. There was no indication of displacement of any crime subcategory into adjacent areas."

2. New statutory guidance

The legal section of the report fails to mention the new network management duty guidance, issued by the Secretary of State for Transport on 30 July 2021.7 This statutory guidance includes the following:

"we continue to expect local authorities to take measures to reallocate road space to people walking and cycling. The focus should now be on devising further schemes and assessing COVID-19 schemes with a view to making them permanent. The assumption should be that they will be retained unless there is substantial evidence to the contrary."

There is no substantial evidence in the officers' report to indicate that the Low-Traffic Neighbourhoods should be removed. Instead, it explicitly states: "there are no schemes where the overall impact in terms of traffic/congestion and air quality are significant either positively or negatively."

The new statutory guidance also contains the requirement that:

"Trial or experimental schemes should be left in place for the full duration of the temporary traffic regulation order (TTRO) or experimental traffic regulation order (ETRO), where appropriate, or where no traffic regulation order (TRO) is required, until at least 12 months’ traffic data is available and has been published."

We have yet to see 12 months' traffic data published for all these schemes. LTN 30 (Loveday Road) was installed in November 2020, so time is still needed to collect traffic data for this area.

The new guidance is also specific in the type of data the council should use as evidence to make its decision:

"In assessing how and in what form to make schemes permanent, authorities should collect appropriate data to build a robust evidence base on which to make decisions. This should include traffic counts, pedestrian and cyclist counts, traffic speed, air quality data, public opinion surveys and consultation responses."

The council has failed to publish data in four of these seven categories. The following are missing: pedestrian and cyclist counts, traffic speed, and public opinion surveys. (Note the new guidance states that, "Engagement, especially on schemes where there is public controversy, should use objective methods, such as professional polling to British Polling Council standards, to establish a truly representative picture of local views and to ensure that minority views do not dominate the discourse.")

Finally the new guidance makes it clear that: "Consultations are not referendums, however. Polling results should be one part of the suite of robust, empirical evidence on which decisions are made." We note that the recommendations to remove or keep LTNs made in the officers' report coincide with the results of the council's Survey Monkey poll. This suggests that the poll, and not an objective assessment of the benefits and disadvantages of the LTNs is the true basis for the recommendations in this report.

3. Financial Consequences

The government has made it clear that it will withdraw future funding to boroughs that remove active travel schemes.8 This includes funding for schemes other than active travel, and funding the council receives from TfL. By removing LTN21, Ealing has already lost funding from the DfT. To help the cabinet make a decision, this report should include details of the amount of funding the council will lose, or could lose. For instance, the amount of funding received from the DfT and TfL over the last three years, and the proportion it makes up of total transport funding.

4. Links to the 3 Key Priorities for the Borough

The report fails to include the impact its recommendations will have on the borough's core objectives. Ealing has three key priorities: creating good jobs, tackling the climate crisis and fighting inequality. If the Low Traffic Neighbourhoods are removed the DfT will cut funding to the borough. This will mean job losses. Removing the LTNs will reduce the amount people walk and cycle, and increase car use. This will increase the rate of global warming. Without the LTNs there will be between two and four times as many road traffic injuries on the former LTN roads. This will disproportionately affect those on lower incomes who are less likely to drive.

5. Effect on Ealing's Cycle Network

Some of the roads in the LTNs are part of Ealing's draft Cycle Network. Removing the LTNs will increase motor traffic on these routes to levels that break the guidelines in Local Transport Note 1/20: Cycle Infrastructure Design. Section 7.1.1 states: "Most people, especially with younger children, will not feel comfortable on-carriageways with more than 2,500 vehicles per day and speeds of more than 20 mph. These values should be regarded as desirable upper limits for inclusive cycling within the carriageway." Section 7.1.4 says: "At flows of above 5000 vehicles per day few people will be prepared to cycle on-street"

The following roads are part of Ealing's latest draft cycle network. The council's own traffic counts show they will have unacceptable levels of motor traffic for cycle routes if the relevant LTNs are removed:

Culmington Road (existing cycle route)

Before LTN = 496 vehicles per hour / 5952 vehicles over 12 hours

With LTN = 61 vehicles per hour = 732 vehicles per 12 hours

Loveday Road (proposed cycle route)

Before LTN = 266 vehicles per hour / 3192 vehicles per 12 hours

With LTN = 7 vehicles per hour / 84 vehicles per 12 hours

Mattock Lane east (existing cycle route)

Before LTN = 318 vehicles per hour = 3816 vehicles per 12 hours

With LTN = 157 vehicles per hour/ 1884 vehicles per 12 hours

Mattock Lane west (existing cycle route)

Before LTN = 327 vehicles per hour / 3924 vehicles per 12 hours

With LTN = 279 vehicles per hour / 3348 vehicles per 12 hours

Conclusion

The officers' report states: "the only clear benefits to be identified (namely the reduction in traffic with each LTN) is of a localised nature and it is therefore appropriate to give weight to the views of local residents when balancing the data and responses." If the council finds only one clear benefit, it is because it has failed to collect the necessary data to identify other recognised benefits. It has also chosen to ignore or play down academic research and data from other boroughs that provides an extensive evidence base for the wider benefits of low traffic neighbourhoods. A full and properly researched report could only come to one conclusion - a recommendation to keep the Low Traffic Neighbourhoods.

Yours sincerely,

Ealing Cycling Campaign