The Traffic Management Advisory Committee considered the objections received in response to the statutory (formal) consultation for the introduction of a maximum 20mph speed limit for the Croydon Areas 3, 4 & 5 which were detailed in the plans HWY-MPH-0000-005, 006 & 007 at Annex 1 of the report.
The Chair informed the Committee that he had used his discretion as the Chair to introduce a revised speaking procedure for this item only. The intention of the speaking procedure was to enable more people to address the Committee than would have ordinarily been allowed under the Part 5H of the Council's Constitution. The Chair further stated that given a small number of people had registered to address the meeting he would allow each speaking slot to be extended to five minutes.
Officers introduced the report outlining that the proposal was for the introduction of 20mph speed limits on roads across Areas 3, 4 and 5, not including main roads. A consultation had been undertaken with 1,500 public notices posted across the Areas and 90,000 leaflets delivered to the properties within the Areas. The consultation had been extended to be seven days longer than was statutorily required in light of the large area which had been consulted. Objections had been received in response to the Traffic Management Order (TMO) which had been reviewed and grouped within nine main headings which were outlined within the report. However, many of the comments received suggested roads that should be included or excluded from the scheme, as outlined within Annex 3 of the report, but officers recommended that the roads outlined within the TMO should be the ones where a 20mph speed restriction was introduced.
The Chair invited those who had registered to speak in regards to Area 3, with Mr Peter Morgan speaking in objection to the proposals. It was stated by Mr Morgan that the report contained a number of statements; many of which were not true.
Mr Morgan discussed Article 6 and the need for a fair hearing and suggested that a Public Inquiry should have been called for the TMO as the consultation process had not been acceptable. It was noted that for the extension of a Controlled Parking Zone there was a two stage process that members of the public understood and had been followed for the proposals for Areas 1 and 2, despite the low turnout of 6 - 8%. However, it was noted that a different procedure had been followed for Areas 3, 4 and 5 as it was stated that the Council felt that the two stage process was too complicated. Mr Morgan felt that the reason for the change in process was to enable the implementation of 20mph speed limits across the borough before the 2018 Local Elections and stressed that residents felt insulted by the change in process and perceived lack of interest in their views.
Mr Morgan stated that the process that had been followed by the Council was not a consultation, rather it was an opportunity to object, and under "the 1985 ruling" there was a requirement for local authorities to consult. Consultation, it was stated, should take place during the initial stages of the development of proposals. The second requirement outlined within the ruling was that sufficient opportunity should be provided for the public to understand and respond to the proposals. Mr Morgan stressed that 28 days was not enough time to consider the complexities of each of the roads within the three Areas.
Councillor Maggie Mansell addressed the Committee in support of the proposals noting that 20mph speed limits were first proposed six years before in Norbury and was supported by three of the resident associations. Councillor Mansell noted that 20mph speed limits in Area 2 had been popular and that the most frequent query she received from residents was why it was taking so long to implement in Area 3. While some people would continue to speed a lower speed limit was a deterrent and on many roads it was not possible to drive faster than 20mph due to the density of parking.
Councillor Mansell noted that it often took a period of time for behavioural change to take place, as had happened with the requirement to wear seatbelts, but a reduction in speed was welcomed by residents as it would reduce the damage to parked cars and accident levels. A programme of speed checks and work with the Police once the speed limits were implemented was requested.
Officers stressed that traffic speeds would be monitored by the council before and after implementation and discussions were being held with the Police regarding enforcement.
Mr Chris Hicks addressed the Committee in objection to the proposals for Area 4 noting that 103 people had responded in support of implementing speed limits, however the majority were against the proposals. It was suggested that if 20mph speed limits were imposed then it would be similar to "Big Brother" telling residents what was good for them; rather than what was necessary. Mr Hicks stated that his experience was that drivers did not take notice of the reduced speed limits and that it would be pertinent to evaluate Areas 1 and 2 before implementing across the rest of the borough.
The visual harm of additional signage was also raised as a concern as Areas 1 and 2 had excessive signage which had made the areas less attractive. Mr Hicks noted that inner London boroughs had not used as much signage and queried why Croydon had introduced so much. It was stressed that Mr Hicks was not opposed to 20mph speed limits in sensitive areas, such as outside schools and hospitals, however he opposed the proposed approach that all roads become 20mph.
Mr Peter Morgan, speaking in objection to the proposals for Area 4, informed the Committee that a consultation should include alternative options, as stated by the Supreme Court in 2014, which it was suggested had not been the case in the 20mph consultation. Mr Morgan stressed he felt that the process had been handled in an irresponsible way by the Council.
In addressing the Committee, Mr Morgan, raised that some evidence suggested that signage only led to a 1mph reduction in speed and that many motorists would travel at 24mph, but by lowering the speed limit to 20mph the Council would be knowingly leading people to break the law.
Mr Morgan further stated that there was an assumption by the council that there would be a similar affect as had been seen in Portsmouth, however it was noted that Croydon was not a homogenous borough and that the north was very different to the south. It was suggested that officers had refused to attend a site visit or take part in community engagement in regards to the proposals.
It was noted by Mr Morgan that in the eight years to 2015 there had been a big reduction in KSIs in the borough whereas in Islington, which had 20mph speed restriction in the same period, there had not been a significant decrease. As such, it was stated that it was not 20mph speed limits that caused better road safety; it was other factors that influenced fewer incidents.
Queries were raised by Mr Morgan as to why the consultation process was changed as the previous approach was considered reasonable. It was suggested the change was due to having small majorities in Areas 1 and 2 and the Council being concerned that there would not be sufficient support for 20mph speed limits in the remaining Areas. Mr Morgan stressed that the change was not fair and proper.
Officers thanked Mr Morgan for raising the reduction in KSIs that had been experienced in recent years, however noted that the reduction was often due to expensive measures and there were few remaining that could be implemented. It was stated that the only option to reduce KSIs further was through implementing extensive policies, such as 20mph speed limits, and that a 1mph reduction in speed would still create a casualty saving.
In response to concerns that 103 residents had responded in support, officers confirmed that 90,000 leaflets had been delivered and only 3,000 responses had been received, a number of which had been sent in by the same individuals. The TMO only requested objections and it was considered to be a positive response to receive support.
The concerns regarding the signage in Area 2 were addressed by officers who agreed that it had been excessive and would be reviewed. Assurances were provided that Areas 3, 4 and 5 would not suffer in the same way, however some signage would be required to notify drivers of the speed limit.
Mr Peter Morgan spoke to the Committee in objection to the proposals for Area 5 raising concerns that there were a mass of unstructured responses and objections which were hard to analyse, and that the Council was required to analyse all responses and to not to create objection categories. Furthermore, concerns were raised by Mr Morgan that a number of his submitted objections had been lost and queried how many submitted objections in total had been lost.
Mr Morgan went on to query why individual objections were not listed in the report as he had raised substantive objections which had not been addressed. It was further suggested that "false objections" had been included in the report which was disingenuous.
The background document to the report was discussed and Mr Morgan suggested that the comments should be provided within this spreadsheet; that suggestions from officers that comments were identifiable were incorrect. In addition, it was suggested that there had been 3355 objections and not the 3357 as stated in the report. Mr Morgan went on to say that there was no categorisation of those who wrote in to support the scheme and there was no rationale on why people had suggested roads for inclusion or exclusion.
Mr Morgan finally claimed that the Council had not followed government guidelines when carrying out the consultation. Furthermore, the authority did not know the current speed that vehicles travelled along the road and so were not aware of what the natural speed limit of the roads was.
Ms Helen Redfern addressed the Committee in objection to the proposals as it was felt that it would not improve road safety due to an anticipated lack of enforcement. Ms Redfern wanted to see children walk to school and friends' homes independently but felt that this would still not be possible due to reckless drivers who would continue to speed.
The statement from the Metropolitan Police Service was felt to not contain specific information, and Ms Redfern stated that she had spoken with the Borough Inspector, Jeff Boothe, who she claimed had indicated that the Police were not enforcing 30mph speed limits and so would not enforce 20mph. It was stated that it was important to know what had been agreed with the Metropolitan Police Service with regards to enforcement.
Councillor Margaret Bird addressed the Committee in objection to the proposals stating that residents were concerned that there was a lack of enforcement at 30mph and that reckless drivers would not drive with greater care if the speed limit was 20mph. It was claimed that road rage would only get worse.
Coulsdon East was noted to be a hilly ward and that it would be difficult to drive at 20mph when going uphill and pollution levels would increase as a consequence. Furthermore, buses often travelled down the hills at 30mph due to momentum.
Councillor Bird raised concerns that residents would be unable to drive without constantly having to check their speed as some roads were more appropriate at 30mph. Following discussions with the Safer Neighbourhood Team it was clear that the Police required the assistance of the council to enforce speed restrictions, and Councillor Bird stressed that it was important that the authorities worked collaboratively.
In response to the points raised, officers stated that they understood the concerns raised regarding enforcement, however stressed that discussions had been held with the Police and confirmation had been received that the speed limit would be enforced. Discussions were ongoing with the Police as to how the Council could further assist, such as the introduction of new technology. It was felt that the workload of the Police would not be increased as there was only a need to recalibrate the speed guns.
In regards to the concerns raised around pollution, officers noted that there was different evidence on what caused higher levels of particulates, however it was their view that acceleration and deceleration caused more particulates and so higher levels of pollution would be caused by cars travelling at 30mph.
The Chair confirmed that on Rectory Park and Mitchely Hill, the council were working with the Police to consider both physical measures and enforcement to improve road safety. The Director of Streets went on to say that the council was reviewing accident hotspots and considering appropriate measures to reduce incidents.
In response to Member concerns, officers informed the Committee that for most consultations a limited number of responses were received which were included in reports, however given the number of objections provided it would not be possible for Members to read all of the individual objections. It had been considered appropriate to hone down on what the objections covered. Officers stated they were confident that all representations had been received, and that concerns raised by residents were in relation to it having sometimes taken officers a few days to confirm receipt.
Officers confirmed that the number of representations did not correlate to the number of individuals objecting as some people had submitted a number of representations and a number were also submitted anonymously. It was stressed that it was difficult to know how many people had participated in the consultation and so an estimate had been provided. The Chair further stated that he was confident that the Council had acted entirely properly and legally.
Councillor Avis commented that it was important to ensure the safety of children was kept in mind and that the map contained within the report was a convincing argument for introducing 20mph speed limits as a 1km radius from the schools covered the majority of the area under consideration. Councillor Avis went on to express concerns that there was an acceptance that children should not play on the streets and should be kept in cages as cars had priority. Some Members noted that the Police had stated the speed limit would be enforced and that the estimated inconvenience to drivers was around 20 seconds.
Councillor Canning further went on to comment that it was felt that the approach taken was an improvement on Areas 1 and 2 where there had been suggestions of disinformation having been circulated. It was suggested that public perception was that 20mph speed limits would be introduced unless there was a good reason to not implement restrictions in particular areas.
Councillor Bashford stated that the change in process from that followed in Areas 1 and 2 was due to the desire of the administration to implement the speed restriction by the 2018 Local Elections and expressed concerns that the public notices were inadequate, placed too high up lampposts or wrapped around, and so were difficult to read.
It was stated by Councillor Bashford that it was irresponsible of the Council to have proposed implementing further 20mph zones when the experiences of Manchester and Areas 1 and 2 had not been fully assessed. Concerns were also raised that the Council was imposing speed limits that would not be complied with as motorists were more likely to adhere to speed restrictions outside sensitive locations than on normal residential roads.
Councillor Bashford also expressed concerns that the statement from the Metropolitan Police at paragraph 3.5.2 suggested that there would not be any enforcement as it mentioned Roadwatch, a group which did not issue fines and could only give advice to those speeding. It was stated that the Police should concentrate on serious crime.
In response Councillor Pelling noted that people dying or being seriously injured was a serious matter that needed to be addressed by all, and that the Police should enforce speed limits as saving lives was important. It was further noted by Councillor Pelling that the map contained within the report did not include private schools which would cover even more of the borough.
Councillor Canning confirmed that it was essential that enforcement took place but compelled Members to not consider all motorists as speeders as the vast majority of drivers complied with speed limits. Furthermore, it was noted that many speed limits became self-enforcing as other motorists would also follow the lower speed limits driven by others on the road.
Councillor Avis reiterated the need for enforcement however noted that Members were able to purchase technology through the ward budgets, such as Councillor O'Connell who had purchased a speed visor which had been welcomed by residents. It was suggested by Councillor Avis that the 20mph speed limits would be enforced by the Council, the Police and local residents.
The Chair agreed with Members that the map within the report was very compelling as following the suggestion that speed restrictions should only be in place around sensitive locations would lead to the majority of the borough covered by 20mph speed limits as it was important to consider children's safety not just outside the school but also their journey to school. The Chair further noted that the map did not include schools that were just outside the borough boundary.
In response officers agreed that there would be ongoing enforcement issues, however stated that should not mean that the council should shy away from making a positive change. Behavioural change took time to take effect, as had happened with seatbelts, however road safety was important and should be a priority.
Officers confirmed that notices were placed on light columns in a similar manner as planning application notices were posted, and apologised if some were placed too high. It was confirmed that 1,500 notices were placed around the areas in places where it was felt people would notice them. While Manchester had chosen to remove the speed limits, many places had felt the restrictions had worked and officers had visited Portsmouth and inner London which had areas that were very similar to Croydon. As such, it was felt that 20mph speed limits would work in Croydon.
Councillor Bashford noted that 90,000 leaflets had been printed, however raised concerns that not all residents had received the leaflet and not all roads had had the leaflets redelivered. It was noted that while the consultation was an opportunity for residents to raise objections, Councillor King had recommended people submit positive responses also and only 103 representations in support had been received. Concerns were again raised regarding the change in process from Areas 1 and 2 and that residents had not had a fair chance to express their views.
Councillor Vidhi Mohan noted that the point of a consultation was to listen to what people had to say and modify plans, if necessary, which it was stated had not happened and that residents' concerns had been disregarded. It was suggested by Councillor Mohan that the policy was ideologically driven and not driven by need, and the consultation had been a box ticking exercise only as there was no intention to change the plans.
In response Councillor Canning suggested that Members should concentrate on the outcomes of the proposals and the reported drop in KSIs seen in other areas once a speed restriction had been implemented. Councillor Canning stressed that councillors should concentrate on improving road safety and supported resident's requests that Southbridge Road should be 20mph also.
Councillor Pelling further supported the request to make Southbridge Road 20mph as it was a heavily used road on which some drivers drove recklessly. It was noted that an added benefit of 20mph speed limits was the improved quality of life and the Waddon Estate was noted as an example for this benefit.
Councillor King recognised the difficulties of Southbridge Road, however noted that it was not possible to add additional roads that were not included within the TMO. It was suggested, however, that it may be pertinent in future to consult on implementing 20mph speed limits on this road. It was proposed that the recommendations should be agreed and additional roads should be reviewed in future.
The Director of Streets confirmed that the statutory process had been complied with and extended, as the statutory requirement had been for 21 days whereas the consultation had been over 28 days. Furthermore, the Committee were informed that there was no requirement for all residences to receive leaflets as had been done.
It was noted by the Committee that the decision to change the consultation process had been the subject of a decision of the Cabinet, at which meeting no objections were raised. The Chair further noted that Councillor Mohan had voted against proposals for Areas 1 and 2 when residents had voted in favour.
Councillor Mohan queried where the accident hotspots were in Croydon and suggested that the council should concentrate on these areas as blanket proposals did not target areas that required interventions, such as the main arteries, and was not a good use of public money. It was further suggested that an option to improve road safety would be to resurface the roads and fill the potholes, which would make the roads safer for cyclists.
All Members agreed that there was a need to ensure the safety of children and noted that there was a difference in the level of injury when a person was hit by a car at 20mph as opposed to 30mph, however Councillor Bashford stated that it was necessary that targeted schemes were implemented as opposed to blanket proposals. Councillor Canning suggested, however, that 20mph speed limits were one measure that could be taken to improve road safety along with filling in potholes and improving street lighting.
Councillor Bashford queried the evidence that suggested that congestion would not get worse on the main roads and queried the need to spend £1.5million if people were already travelling at 20mph. It was suggested that this sum could be used on other targeted measures to improve road safety. In addition, Councillor Bashford queried the level of enforcement and the number of speeding fines issued, as stated at paragraph 5.5.2 of the report.
In response officers confirmed the figures at 5.5.2 of the report covered Police speed offences and did not include speed cameras, however it was anticipated that officers would gain more of an understanding as further discussions were held with the Police. It was further noted that implementing speed restrictions in smaller areas cost more money as an increased volume of signage was required to notify drivers when entering and exiting different speed zones, and thus the proposal was considered to be the most cost effective means of introducing speed restrictions. The Chair reiterated the need for consistency when implementing speed restrictions as it would enable drivers to know the speed limit of the roads they were driving on and would not require constant changing of speed to adhere to the speed limit.
Officers stated that the majority of drivers travelled on the main road network, which would remain at 30mph, and so would only be travelling at 20mph while driving on the local roads en route to the main roads. It was not anticipated that congestion would be significant on the main road network.
The differing views on what caused a higher level of particulates was discussed by the Committee, however officers reiterated their view that a greater volume of particulates was created from harsh accelerating and braking, and so higher speeds would cause more pollution.
While it was noted by the Committee that there was no assessment of Areas 1 and 2, due to wanting to allow a reasonable length of time to pass to enable the change to be embedded, it was felt by some Members that this should not stop the implementation of speed restrictions in Areas 3, 4 and 5. It was stated by Councillor Canning that residents' safety should be put first.
In response to Member queries officers informed the Committee that Annex 3 outlined the roads that respondents had suggested remain at 30mph or roads that should be 20mph. Officers had reviewed all the suggestions however felt that the rationale of local roads being 20mph and the main road network retaining a 30mph speed limit remained sound, and so did not recommend any changes to the initial proposal. The areas and roads outlined in Annex 3 were listed as resident's had written them and so did not always relate to specific roads.
The Chair concluded that it was not possible to please everyone with the proposals, however stressed that the evidence showed that 20mph speed limits did reduce road accidents and KSIs. With over 40% of roads in London having a 20mph speed restriction it was felt that this figure would only rise given that Department for Transport guidelines suggested that local authorities should consider 20mph zones in urban and built up areas.
The Chair noted the concerns regarding enforcement, however confirmed that following discussions with the Borough Commander there was a clear commitment to work together. Finally, the Chair noted there had been over 3,500 submissions to the TMO, however given the population in this part of the borough was around 150,000 adults this equated to around 2% of the population of Areas 3, 4 and 5, which it was suggested did not show a high level of dissatisfaction to the proposals.
The Committee voted on the recommendations contained within the report and voted:
In support (4): Councillors Stuart King, Jane Avis, Robert Canning and Andrew Pelling.
Against (2): Councillors Sara Bashford and Vidhi Mohan.
The Traffic Management Advisory Committee RESOLVED to recommend to the Cabinet Member for Transport and Environment that they:
1. Consider the objections received in response to the statutory (formal) consultation and the officer comments in response to the objections within this report and agree, that the Highway Improvements Manager, Streets Division, be authorised to make the necessary Traffic Management Orders under the Road Traffic Regulation Act 1984 (as amended) so as to
1. Implement the maximum 20mph speed limit for North-West Croydon Area 3 as identified on plan HWY-MPH-0000-005.
2. Implement the maximum 20mph speed limit for South-East Croydon Area 4 as identified on plan HWY-MPH-0000-006.
3. Implement the maximum 20mph speed limit for South-West Croydon Area 5 as identified on plan HWY-MPH-0000-007.
2. Consider the representations received concerning other roads to be included or excluded from the 20mph speed limits in Areas 3, 4 & 5 and authorise the Highway Improvements Manager, Streets Division, to issue any notice required and make any necessary Traffic Management Orders under the Road Traffic Regulation Act 1984 (as amended) after determination of any objections received.
3. Inform the objectors and those who responded in support of the decision