Notes on Guidance

NOTES ON THE SURVEY EVIDENCE IN THE LTN REVIEW 


The surveys were conducted by Ipsos in four areas – Wigan, York, Birmingham, and Camden. No explanation is given about why or how these areas were chosen, other than they represent the “diversity” of schemes. It is certainly true that these four schemes are very different, indeed, some of them do not really look like LTNs at all. But before we come to that, it’s worth examining the surveys in a little more detail because when you do, it soon becomes clear that the results are far from what they might appear. 


The first thing to note is that only residents living within the LTNs were questioned, which means people on the boundary or sacrificial roads were not asked their opinion. This is a major omission that could easily distort favourability towards the schemes. If you exclude the opinions of those who bear the cost of traffic relocation and only ask the opinion of those who benefit from it, then you cannot be hugely surprised if you get a result that shows more people are favourable than not. 


Another major problem with the surveys is the sample size. 

Overall, only 15 per cent of residents in the four areas responded. Within the Birmingham scheme, this amounted to only 320 residents. But even worse, only 25 per cent of these 320 people even knew that the LTN existed before being asked about it. Presumably the rest were responding to pick up the £5 incentive offered by Ipos to complete the survey. So, in total only 80 people in Birmingham actually knew anything about the LTN or how it worked before answering questions about it. 

One has to wonder about the merits of asking people to judge a scheme that they do not know even exists. To draw an analogy, you would not take seriously the responses of people surveyed about a film they had not watched or knew had been made. 


How can the residents who knew nothing about the LTNs possibly give reasonable or informed judgements about them? The only conceivable way they can come to any opinion at all is by basing their judgement on the scheme’s name when presented with it for the first time by the survey. And who would not say they support a “low traffic neighbourhood” in their area if they are unaware of its negative consequences? 


The review confirms that the survey respondents who actually knew about the LTNs tended to be less favourable about the schemes than those who did not. Yet for some unknown reason, the review does not publish these results. Why not? Surely these are the only people giving anything like an informed opinion? At the very least, their views deserve to be disentangled from those who are commenting with no knowledge or awareness of the schemes or their consequences. 


To remedy this problem, I have submitted a FOI request to the DfT to find out the results in each area based only on those who were aware the schemes existed. But from what the review states, we know these results will show – at the very least – a more even distribution of opinion. They might yet even show the majority of those who know about the schemes are opposed. This was certainly the case with the Camden scheme when the local council conducted a post-implementation consultation. It found an outright majority of respondents did not want the LTN made permanent – an opinion that was, of course, ignored. 


Looking at the details of the LTN surveys, the same pattern emerges in every area. In Wigan, only 27 per cent of respondents actually knew about the scheme, in York it was only 33 per cent while in London it was 50 per cent. 


One might consider the schemes to be a success or at least not a burden if such a large proportion of respondents are unaware of them. However, I would counter that by saying there seems to be a very good reason why most of the respondents did not know about the LTNs, particularly in Birmingham, Wigan and York – and that is because the schemes in these areas don’t really look very much like LTNs at all. 

The York scheme, for example, consists only of a single roadblock to a single road, accompanied by a new section of cycle lane on a short section of an adjourning road, at least from the documents I can find online. 


Elsewhere, the scheme in Wigan blocks only two roads and mainly involves investments in improving the area, such as new zebra crossings, traffic calming chicanes, footpath widening, extra street lighting, tree planting and improved road markings. The area in question is also sandwiched between two major A-roads, with one being a non-residential dual carriageway, which would be an ideal and non-controversial route to redirect traffic.


The Birmingham scheme also blocks only two roads and instead predominately introduces one-way systems with contraflow cycle lanes and traffic calming measures. 


The Arlington Road scheme in Camden is more similar to what most people might consider a LTN, in that it contains multiple roadblocks that prevent any through traffic in the area but even this scheme is pretty small by comparison to many others in London. 


I don’t know the Birmingham, York or Wigan schemes in detail so I cannot talk much about their merits or flaws but what I can say with confidence is that they appear very different to the LTN schemes that have raised the most concern from campaigners. 


One of the main objections raised about LTNs is that they redirect traffic from a large number of the already quietest roads to a small number of the already busiest roads, creating extra delays, congestion and pollution where people shop, go to school/nursery, take the bus and walk. Introducing zebra crossing and traffic calming measures, planting trees and widening pavements, with the odd road closure is a very different proposition. 


It is therefore not a huge surprise if the residents within these schemes are either broadly supportive or do not even know about them. 

And yet despite all this, the surveys still actually show that more people than not in these areas believe their local scheme has: 


– helped divide the community

– made it harder to access local facilities

– increased journey times to places visited frequently 

– increased congestion and queues on nearby roads


Of course, the same doubts need to be raised about these findings because most of these opinions are being expressed by people who did not even know the schemes existed before being asked about them. But if you were to take the surveys at face value, they are hardly the resounding endorsement of LTNs presented by their advocates. Indeed, the LTN review concludes that "in all cases, the most common answer [from the surveys] was that the scheme made no difference". 

All this grief and expense for very little then. 


Given all of the above, it is perplexing that LTN advocates are choosing to suggest that these surveys are definitive evidence that LTNs are popular. 

That is not to say I believe all LTNs are intrinsically unpopular or unwelcome. Well-planned schemes that address specific problems in certain areas or certain streets may well be justified and may well be popular. If these schemes have majority support, are designed and implemented well, and properly monitored with little adverse effect elsewhere then they are to be welcomed. 


The schemes in Wigan, Birmingham and York may well fit that description but I doubt that many of the huge LTNs causing major traffic displacement do. 


It is also perplexing that the DfT allowed these highly questionable survey results to be included in its review. It shows either statistical naivety or some prejudicious forethought in the design of the review or perhaps both. Either way, it certainly does not mean all LTNs are universally effective or popular. 








NOTES on Guidance


Generally speaking, the guidance to councils appears quite sensible and is clearly intended as a rebuke to local authorities that have chosen to implement LTNs without proper consultation or support from local residents. Yet, in recent days many LTN advocates have suggested that the guidance is some sort of vindication, saying it only reinforces what councils have been doing already. 


That is very far from the truth. For example, the guidance states that councils “should use objective methods, such as professional polling to British Polling Council standards, to establish a truly representative picture of local views”.
This is quite a stringent requirement and should, in theory, mean local authorities can no longer get away with consultations (designed by cycling lobby groups) that contain leading questions and can easily be gamed by activists on either side of the debate. 


The guidance also reminds councils that they
should consult bus operators in advance of implementing an LTN, something we know some authorities, such as Lambeth, have not been doing. They are also told to consult the emergency services – something you might not think they would need reminding about but the LTN review reports that 16 per cent of schemes were implemented without talking to the police, fire, or ambulance services. 


Another example from the guidance where councils are going to have to up their game comes in the section called “design principles for effective LTNs”. This states that schemes “
should have clear aims and objectives, with a rationale and evidence to support intervention and measurable metrics of success”.

This is going to present a challenge to many councils which, up to now, have chosen not to identify specific aims and objectives or defined metrics of success. Holding councils to this higher standard can only be welcome. 


However, the “
measurable metrics of success” are only as good as the data that the councils present and sadly the vehicle counting tubes that most authorities use can hugely under-report traffic levels, particularly on congested boundary roads. The data these tubes provide can also be gamed by where and when they are placed. It is therefore disappointing that the guidance does not also require councils to conduct some form of supplementary human counting of traffic on the most congested roads to validate the data provided by tubes. 


The guidance, rightly, also has plenty to say about what councils must do
to ensure schemes do not make life worse for the disabled. Sadly, we know this is necessary because the review states that more than one in ten LTNs were implemented without disabled groups even being consulted, which seems an abject failure of government. The guidance reminds councils that “accessibility requirements and the Public Sector Equality Duty apply to all measures”. It adds that councils “should always consider exemptions for Blue Badge holders”, which we know in many cases has not been happening and is something many LTN advocates object to for some unfathomable reason. 


The guidance also states that councils should consider giving local residents and those making deliveries permits to travel through restrictions
. Again, this seems like a sensible idea that would result in the schemes only hitting genuine “through traffic” and having much greater public support but is an anathema to most LTN advocates. However, because the guidance states only that councils should consider this then the chances of many actually doing it are slim to none. 


Another area where councils are going to have to up their game is on
planning and monitoring LTNs. The guidance says councils should collect “appropriate data” in advance and during monitoring to ensure there is “a robust evidence base on which to develop proposals and make decisions”. We know that in many LTNs this simply has not happened. My local LTN, for example, was introduced in 2020 despite the last traffic count on the main boundary having been conducted in 2014. 


The guidance goes on to list the data councils are expected to gather and this is going to make it much harder for councils to justify new LTNs and keep them once introduced
. It says the data should include “traffic counts, pedestrian and cyclist counts, traffic speed, journey times both within and around the perimeter, patterns of traffic flow, air quality data (particularly the possible air quality impacts of displaced traffic), public opinion surveys and consultation responses”.


The guidance to monitor journey times around the perimeter of LTNs before and after implementation is particularly welcome and I cannot think of a single case where this has been done so far
(although I am prepared to be corrected on that). There are also other parts of the guidance that, if adopted by councils, will significantly change the design of future schemes. For example, the guidance notes that physical barriers “are more likely to be appropriate for small schemes only”. This has not been the case up to now. 


The guidance also states that
warning notices should be issued for first-time contraventions for a period of 6 months after new schemes are implemented, or existing ones are made subject to camera enforcement for the first time”. This has not been happening at present. It adds that “traffic management schemes should be designed to work for local communities and never as a revenue raising tool”. Ha, Ha! 

All of this seems eminently sensible but is only as good as councils’ willingness to adhere to the guidance and the consequences for them should they choose to ignore it. Sadly, there is little substance in the guidance on how it will be enforced. It only really states that the transport secretary “reserves the right to take into account adherence to this guidance in relevant future transport funding allocations”. That is not a very big stick. There is also a commitment to consult on removing access to DVLA records for recalcitrant councils, but this looks fraught with difficulty and, realistically, will likely never happen. 


This is the main flaw in the guidance
– there is little that can be done if councils choose to ignore these protocols. There is not even a mechanism by which disgruntled residents or groups can submit evidence to the DfT of a council’s failure to adhere to the guidance. Basically, this guidance relies on the good will of councils and those in charge of local transport policy being sensible, moderate, and rational. Many who have engaged with councils over LTNs know this is all-too often not the case. And that is a shame because otherwise this guidance is generally good and would lead to better policy if it was adhered to. 


In many ways it is astonishing that councils should need reminding of so many simple principles of good governance but sadly too many LTNs have been implemented without consideration of the impacts beyond the area itself while residents who identified problems and shortcomings or suggest sensible mitigations have, in many cases, not just been ignored but cast as reactionaries or petrol heads. 


Let’s hope this guidance changes things but I am not hugely optimistic. 





 
 
 

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