BRAG’s Observations and Comments regarding consultation on Camden’s Draft Planning Guidance Documents (22 January 2019)
BRAG campaigns for interventions, developments and traffic management schemes that do not undermine the quality of life of residents in south Camden. We want decision-makers to understand, respect and respond to our stated aim: that ‘residents matter’.
Introduction: consultation process
Camden’s community engagement policy (Adopted 2015) states that “the Council is committed to effective engagement with its community and that Camden recognises that by engaging with the community, decision making is enhanced, services are more effectively delivered and that strategies and policies are likely to result in better outcomes for the community.”
However, despite being registered on Cindex since 2016, it took some time for BRAG to be alerted to the fact that the Council is reviewing and updating its Planning Guidance documents to support the delivery of the Camden Local Plan following its adoption in 2017. On 28 November 2018 we were sent formal notification by e-mail of the Camden Planning Guidance consultation. The deadline for comments was originally 11 January, and we note the consultation period coincides with the Christmas and New Year holiday season.
Community groups are composed of volunteers with busy lives, so it is difficult to respond to all consultations, and the necessary detail contained within these planning guidance documents adds to the workload.
We are aware that Camden has its own deadlines. But the Council also has to realise that REAL consultation takes time. Camden residents have many commitments, are busy working or dealing with families (young and old) which is why so few people respond or contribute, despite the Council’s request for comments. This is why consultation starts to feel like a tick box exercise, which undermines the process, and the results.
We requested additional time to respond and were provided with an extra 2 weeks. We have decided to focus on CPG: Air Quality and would like to respond with a few comments, and observations, with reference to the draft document text provided.
CPG: Air Quality
2.0 Air quality in Camden
Pollution caused by construction work
2.4 The text states “the main sources of air pollution in Camden are road transport and gas boilers.” This should be amended to include a reference to construction which is also a main source of air pollution. Much of the draft planning document discusses how air quality assessments are needed for planning applications and development, so the importance of this issue needs to be emphasized.
3.0 Assessing air quality impacts
Inaccuracy of data
BRAG took part in the 2017 Public Inquiry on the controversial Experimental Traffic Order for the Tavistock - Torrington Place corridor. Air quality was debated at length in front of the independent Inspector and his report reflected the fact that evidence on air quality produced by Camden was found to be erroneous or misleading. This leads residents to lose confidence in the data that is produced by Camden. How accurate is it?
4.0 Minimising emissions into the air
4.21 Traffic reduction
We accept that road transport is one of the main sources of air pollution in Camden, but it is still not recognised that shutting off a street does not stop pollution, simply creates congestion and moves it elsewhere.
Congestion means that vehicles are on the road for longer (often hours longer in London) than continuously flowing traffic. Stop-start traffic produces far higher emissions that continuously flowing traffic. To minimise emissions into the air we need fewer vehicles and those vehicles need to be able to move. The policy of shutting roads has resulted in longer journeys and traffic jams.
Camden's policy should concentrate first on vehicle reduction, then on ensuring that vehicles move. We refer to this paper that provides evidence that congestion increases pollution.
5.0 Conditions and legal agreements
5.4 Financial mitigation
This paragraph states that Council may seek a financial contribution after all possible mitigations are explored and integrated into the development. This may be where:
a development is likely to cause a deterioration in local air quality (once completed it will increase pollutant concentrations);
the demolition and/or construction phase of a development will impact on the local environment (through dust and exhaust emissions); and
a development introduces new receptors into an area of poor air quality (it will expose future occupiers to unacceptable pollutant concentrations/new exposure
It is important that this financial contribution should not just go into Camden’s general coffers but should be allocated to the specific area of Camden which will suffer from the negative impacts of the development (as in the bullet points above), and thus provide specific mitigation to the people who live and work in the vicinity of the increased pollution.
BRAG is aware that Camden’s transport policy has a hierarchy of movement modes, and we fully support the reduction of pollutants in central London.
But BRAG was formed in 2016 to alert decision makers to the fact that the streets in south Camden have a large number of permanent residents whose needs and quality of life must be respected. It seems that residents in this part of London are being penalised so that people who live elsewhere are able to enjoy an easy means of commuting to central London by active modes.
It doesn’t take much research to recognise that the regeneration of Kings Cross railway lands has brought gentrification and high land values to a neighbourhood that was despised forty and more years ago. It is precisely these streets, south of the Euston Road, which are lived in by many Camden residents who have limited income, are now reaching an age when physical mobility is difficult, and some NEED access to motor vehicles in order to get around. The cutting off of roads is making taxi journeys more expensive for the very people who cannot afford it. The result is that we fear more and more elderly and frail residents will get trapped in their homes.
Comments on Air Quality from BRAG’s public meeting
In July 2018, BRAG held a public meeting at the Lumen Church, Tavistock Place London WC1, which was attended by over 70 local people. A report was published (which can be downloaded from ) and it might be pertinent to repeat what local people said on the issue of air quality and pollution:
“I live in the small streets off Kings Cross Road. We are gridlocked with displaced traffic from all
the changes which push more and more traffic on to the gyratory. Why is it OK for us to get all the pollution?”
“I work on Guilford Street and I’m very concerned. I understand that this overall macro plan is to clean up the small streets but there seems no understanding of what that means in practice. It will cause more pollution elsewhere.”
“We all want less pollution, less congestion but the plans don’t do this; it’s not possible; basically it’s difficult to reduce pollution and congestion.”
“All the displaced traffic has to go somewhere. You can’t just snap your fingers and it goes away.”
“It’s obvious - you just need to increase the Congestion Charge for people who don’t live here - it’s just not expensive enough to deter through traffic.”
“Camden must be made to conduct a proper study into the impact on the wider area if it is to have a realistic model of the traffic patterns & impact across our area…It is shocking that the independent report into Tavistock / Torrington noted that Camden simply didn’t have the data on the traffic displacement & negative impact on the wider area.”
Improving Air Quality and minimising emissions into the air
Number plate recognition / road closure
There are measures such as number plate recognition and closing roads at certain times of day that could be more effective at reducing pollution than complete road closure.
BRAG was surprised that council officers rejected these measures (in relation to the closure of Judd Street / Lansdowne Terrace), appearing not to even consider them. Number plate recognition was said to be too expensive for the Judd Street area, despite the cost of cameras being less than the cost of paving over Brunswick Square, and that number plate recognition can provide an income stream from traffic that ignores it.
Control of number of Uber vehicles
A Dept for Transport stats paper of October 2018 refers to a 1% increase in black cabs in London since 2005, compared with a 120% increase in PHVs.
We are aware that the London Mayor is seeking powers to limit the number of Uber drivers operating in the capital, blaming a surge in private hire drivers for the city’s increasing congestion and pollution, and would urge Camden to support his initiative.
Residents of South Camden want to live in a less congested city and breathe better air.
To quote from a participant at BRAG’s public meeting: “I’ve been a lecturer in epidemiology. We know that pollution is the greatest killer - we don’t have ten years, we need to do something NOW. We must do all we can to avoid stop-start traffic, to have traffic flowing properly.”
Planning Guidance documents are intended to support delivery of Camden’s Local Plan. We hope that the Council will use all reasonable and fair means to reduce pollutant emissions, while balancing these interventions with respect for residents who also need to maintain their daily quality of life.
 Quoting from an article from Guardian, August 15 2018. On Tuesday, New York City – Uber’s largest American market – signed into law a one-year moratorium on new licences for vehicles used for ride-hailing services, effectively capping the number of Uber drivers in the city, and also setting a minimum wage for app-based drivers. Sadiq Khan said a cap on new licences was an urgent and necessary step. But unlike New York, which announced a cap last week, he is unable to impose restrictions. Khan urged the government to grant him powers to limit the “unsustainable rise” in drivers to “enable Londoners, like New Yorkers, to breathe better air and live in a less congested city”.