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4.1       The Council’s SoC does not provide sound evidence for the trial to be made permanent.


a)     The trial has not met its objectives with regard to safety and pollution


b)     The trial has created multiple adverse impacts, which outweigh any positive impacts, and which the

         Council is largely not taking into account


c)     There are alternative plans for the area which could achieve the Council’s objectives without such

        adverse impacts, and these have not been fairly and adequately considered


d)    The Council’s Statement of Case supporting the trial being made permanent is based on many

        statements which are unsubstantiated, and statements for which the evidence is quite contrary to the

        assertions, and some incorrect information.


4.2        The trial removes a vital westbound route

The west-bound Torrington-Tavistock corridor which has been blocked was not a short cut; it was not even only a key west-bound vehicle route; it was in fact the only west-bound vehicular route between the Strand and Euston Road; once that is digested, one begins to understand the significant problems caused by its closure.


4.3        BRAG proposes that corridor should be reversed to its previous two  way traffic but with the modification

                 that, instead of one bidirectional cycle lane, there should be two unidirectional cycle lanes. 



Proofs of evidence will demonstrate:


  1. Traffic displaced from Tavistock Place

  2. The flawed nature of the consultation process

  3. The Freedom of Information request for data ignored by Council

  4. Stop-start traffic and consequent pollution in surrounding streets

  5. Cycling accident information

  6. Increased risk to cyclists in surrounding streets

  7. Routes designated for emergency vehicles

  8. Problems caused to hospital patients and staff

  9. Problems caused for people with impaired mobility 

  10. Problems caused for local businesses

  11. BRAG’s proposal to reverse the trial, but with modifications

  12. Commentary of the Council’s critique of BRAG’s proposal

  13. Commentary on the Council’s SoC

  14. Video evidence covering displaced traffic, risks to cyclists and the impeding of emergency vehicles

  15. Pedestrian accident information

Documents to be referred to:


a)      National standards re road widths etc as referred to by Council barrister in Pre-Inquiry

         Meeting, and which, it is understood, will be part of a common library of documents

b)     BRAG formal response to the consultation

c)     Camden Council Cabinet papers for January 2015

d)     Website document (not the hard copy leaflet) published by the Council at the beginning of the trial in

        November 2015

e)     BRAG’s Community Planning Day Report

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