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The submission from BRAG to the Public Inquiry seeks to show through local witness statements and other evidence, including photographs and video clips, that:

a)     The trial has not met its key objectives

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 multiple unsubstantiated statements and some incorrect information.





2.2.1     Air quality has not generally improved 


a)    The Torrington-Tavistock trial has caused massive displacement of traffic on to surrounding streets.  Prior to the trial, 4,500 vehicles per 12 hours travelled westbound on the trial route; those 4,500 vehicles were suddenly displaced on to the surrounding residential streets, creating long queues of stop-start traffic and a concomitant increase in pollution.

b)     The Council’s data on changes arising from the trial reflect people’s perceptions of greatly increased traffic; for instance, in Judd Street morning rush-hour traffic north-bound has increased by 58%, and in Southampton Row north of Fisher Street, morning rush-hour north-bound traffic has increased by 99%.


c)    This increase in volume on surrounding streets has led to unprecedented congestion. This congestion in turn results in idling, stop-start traffic, with diesel engines polluting densely residential streets for many hours per day. 

d)     Although the Council has been told by residents about this increased congestion and pollution in Judd Street and Hunter Street since November 2015, no monitoring of air quality was originally set up in those streets, or on other severely affected streets such as Southampton Row.  A monitor was set up belatedly in Judd Street, in February 2017, but as there will be no pre-trial comparative data, the usefulness of this is doubtful. Monitoring has taken place in three places including Tavistock Square, where air quality has improved, and this has been heralded as a success. The failure of the scheme in causing increased pollution on other streets is being ignored.  What the Council has done is in fact to create more congestion and pollution, in the surrounding area. Traffic in Tavistock Place and surrounding streets used to be mobile, albeit often slow; now that same traffic is squeezed on to fewer streets, it has become frequently stop-start, making the total sum pollution undoubtedly much higher, given that idling and stop-start engines cause more pollution. 

e)      On Judd Street, a journey of 140 metres which normally takes a car about 20 seconds often now takes 9 minutes. In such congested times, therefore, each car is spewing fumes for 27 times as long as before the trial; so, counting the number of cars is of no use at all in assessing pollution increase. But this common sense conclusion drawn from daily observation cannot be tested because the Council did not set up monitors on the streets which it was known would have to absorb the displaced traffic from Tavistock Place. 

f)     Proof of Evidence (4) demonstrates the stop-start traffic created by the one-way system, and the impact of the diesel smog which now some days permeates these densely packed residential streets (over 400 dwellings on Judd Street alone) with high buildings which prevent the emissions from escaping.


 2.2.2   The Torrington-Tavistock corridor is not safer for cyclists


a)  The Council has produced no evidence to show that cycling is safer on the Torrington-Tavistock corridor. Indeed, on the contrary, the Council SoC admits: ‘Early indications from draft collision data suggest an increase in accidents involving cyclists’ (SoC 7.8), thus stating that one of the main aims of the trial has not been met.


b)  BRAG also questions the Council’s November 2016 hard copy leaflet justifications for the trial, namely that ‘The previous cycle lane had become overcrowded, causing safety problems’ and ‘The route suffered from a high casualty record, particularly due to collisions between motor vehicles and cyclists, cyclists and cyclists’.  


c)  The Council’s statements after the consultation referred to cyclists ‘feeling safer’, as if this were proof of safety, which it clearly is not.  Now that 2016 data is available, it is clear that the trial has not reduced cycle casualties. Indeed, it may have increased the risk to cyclists by creating an environment where they feel safe to ride faster, as the Camden SoC acknowledges in paragraph 7.8  


d)  BRAG’s Proof of Evidence (5) sets out the evidence on cycle safety.   


e)  One of the original aims of the trial was to create wider cycle lanes to enable cyclists to ride faster and overtake. Now it appears that this has brought about increased risk to cyclist safety. (Council SoC 7.8).


f)     Although the Council reports that some of the 15,000 respondents (86% of whom were not from Camden) felt safer, many local cyclists who use the route regularly, do not.  This is set out in Proofs of Evidence (6).  Some cyclists feel safer; others do not.

2.2.3    Cycling is more dangerous on surrounding streets


a)     The Torrington-Tavistock trial has caused massive displacement of traffic on to surrounding streets.  Prior to the trial, 4,500 vehicles per 12 hours traveled westbound on the trial route; those 4,500 vehicles were suddenly displaced on to the surrounding residential streets, creating long queues of stop-start traffic and a concomitant increase in pollution.


b)     It has also caused a much more hazardous environment for cyclists. Cyclists are frequently observed having to weave in and out of the newly-created congested traffic, in a way which did not happen before November 2015. They also, when blocked by congested traffic, frequently overtake the vehicles and ride on the wrong side of the road in the face of oncoming traffic, obviously increasing the risk to their own safety, as well as that of others. Motor cyclists also often ride in the face of oncoming traffic, with obvious increased risk to general safety. Proofs of Evidence (6) demonstrate this.



2.2.4    No significant decline in pedestrian accidents


It appears that there were no pedestrian accidents on the corridor in the last year. However this is not statistically significant in this context and cannot be attributed to the trial, since this is part of a long term declining trend.  Proof of Evidence (15)



a)     In broad terms, Bloomsbury Residents’ Action Group argues that the Council has failed to demonstrate that the positive impacts outweigh the adverse impacts, and so, according to its own stated policy, the trial should not be made permanent


b)     On 21st January 2015, long before the imposition of the trial and the subsequent consultation, the Council had decided at a Cabinet meeting to approve a separate scheme called the West End Project (which radically changes the layout of major roads contingent to the area in question, and which the Cabinet knew would impact on the area in question) and, as part of that project, to approve a trial to reduce west-bound traffic on Tavistock Place and Torrington Place.

c)    In Appendix H to Item 16 of that Cabinet meeting, Camden Cabinet stated:


If the trial showed that positive impacts outweighed any adverse impacts, the changes could be made permanent. 


d)     In its submissions to the Public Inquiry, Bloomsbury Residents’ Action Group seeks to demonstrate that the Council has failed to show that positive impacts outweigh the adverse impacts, and that therefore the trial should not be made permanent.  Despite many meetings and the submission of evidence, the Council appears set on largely ignoring the adverse impacts.  When obliged by the facts to face up to some of these adverse impacts, the Council’s response has been, rather than to address the cause of the problem, to ignore them or to create more changes, in mitigation, which in turn seem very likely to create further traffic problems.

 2.3.1    The trial has created multiple adverse impacts: summary

a)  Made air quality, pedestrian and cyclist safety generally worse, as shown above

b)  Increased security risks with emergency vehicles being impeded

c)  Necessitated longer vehicle journeys thereby increasing the risk of accidents and pollution

d)  Delayed patient and health care staff journeys between hospital sites, which occur daily

e)  Made mobility and access more difficult and more expensive for a particular section of pedestrians -  frail, older and disabled people

f)  Threatened the sustainability of the community by making the practicalities of daily life for residents and local businesses more difficult and stressful.


2.3.2     Increased security risks with emergency vehicles being impeded


a)    Tavistock Place and Judd Street are both part of the network of key routes for emergency vehicles, which are now either blocked or impeded – and will be further impeded if the Council proceeds with road blocks at the junctions of Judd street and Euston Road, and Hunter Street and Lansdowne Terrace (one of the proposed potential ‘mitigations’ for the problems caused by the trial – a ‘mitigation’ which will in fact exacerbate the problems). Proof of Evidence (7) shows the emergency routes, as set out by Camden Council.


b)    Residents are aware that this is an area that has been a terrorist target (the bombings of 7/7); two bombs were in this precise area, one in Tavistock Square, and one on the Piccadilly Line directly below Judd Street. This is likely to continue to be a high risk area, given the proximity of three train stations, Eurostar, long distance rail passengers and a high density of tourists and commuters. There are also two major hospitals in the area, UCH, with its multiple sites including Queen’s Square, and Great Ormond Street. There are also several very large hotels and hostels. The security implications of the traffic changes and the consequent gridlock, or of the further plans to block emergency routes, have been brought to the Council’s attention on many occasions, but it seems that officers, who it is understood do not mostly live in the area, do not consider this important. It is considered to be extremely important by the people who live here.


c)     The safety of people in the area should be the primary concern of the council and the Tavistock trial is making the area less safe by causing congestion and blocking emergency routes and thereby increasing response time.


d)     Proof of Evidence (14 – video evidence) demonstrates the problems being experienced by emergency vehicles.


2.3.3   Longer vehicle journeys now necessitated, thereby increasing the risk of accidents, congestion and pollution


a)     On 10th March 2016, the Council held a hastily convened meeting at Pancras Square, to allow local people to find out what was happening. There were about 60 people present, almost all of whom expressed great anger at the changes which had been imposed on the neighbourhood without consultation or for many without warning. One of the facts to emerge was that the Council had not thought through how people would get around the area, with the closure of the major west-bound route.   Asked some specific questions about how people would travel between certain locations, officers, clearly thinking on their feet, looked at maps and suggested the roundabout routes which would now be necessary.  An exacerbating factor was that the closure of the north end of Judd Street was under consideration by the Council – and still is.  This would mean that a resident living near Tavistock Place, for instance on Thanet Street, who needs travel by taxi or car to hospital, would have to travel east to Gray’s Inn Road, in order to go west to University College Hospital. This journey would be more than twice as long, generating twice as much congestion, pollution, and risk of accidents; thus undermining the claim that the one-way system would improve safety and pollution. 


b)     It became clear at a public meeting on 19th September 2016 at the Lumen Centre, that the Council was accepting of the fact that the one-way system would result in longer vehicle journeys within the area – that is, more traffic -, with all that entails.  The Marchmont Association notes of the meeting read:


From a resident

'When managing the traffic the Council should realise that when roads are closed the traffic does not just go away, but just goes somewhere else.'


Response from the Council

'Some journeys will be longer.  It is thought that 11% of car journeys will be switched to another means.'


c)     It is not known what the evidence base is for the 11% drop. The Council talks about unnecessary vehicle journeys but has provided no evidence that many journeys are unnecessary; indeed, with the traffic conditions, congestion charge and parking restrictions, it seems unlikely that people would make frivolous car journeys in central London. However, taking this 11% drop as correct, that still leaves 89% of journeys still being made; and many of those journeys will be longer, sometimes significantly, with increased risk of road traffic accidents, and increased congestion, as cars are displaced, with associated increased pollution.


d)     So the Council’s aim to reduce traffic, whilst having obviously succeeded on the Torrington-Tavistock corridor where west-bound traffic is banned, appears to have back-fired, as the one-way system has caused longer journeys and increased traffic in the surrounding area, with increased pollution and risk to safety.    


e)     The Council’s SoC refers, in Appendix C to the loss of a  ‘westbound short cut through for motor traffic’.  The west-bound Torrington-Tavistock corridor 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 mayhem caused by its closure.  In using the term ‘short cut’ the Council seeks to belittle the corridor’s strategic importance as a vehicular route; and to sweep under the carpet the impact of its closure.

2.3.4     Delayed patient and health care staff journeys between hospital sites, which

occur daily

a)     The University College London Hospital Trust (UCLH)  regularly needs to move patients between Queen Square departments and the main campus on Tottenham Court Road, when tests or treatment needs are complex and go beyond what can be provided at Queen Square. There are also east-west patient journeys to the main campus from Throat Nose and Ear Hospital) but these are relatively infrequent and both hospitals will be relocated to Tottenham Court Road in due course.

b)     The west-east journey time is not an issue for UCLH because cars and ambulances can still approach Queen Square via Euston Road and Upper Woburn Place.

c)     UCLH’s main concern is therefore with east-west journeys between Queen Square (the National Hospital for Neurology and Neurosurgery and the Royal London Hospital for Integrated Medicine) and the main UCLH sites at the top of Tottenham Court Road.  The journeys involve not only patients but staff, especially senior staff with responsibilities covering all trust sites. Delays for patients put care at risk but delays for staff waste valuable work time and are a hidden cost for the NHS.

d)     Prior to the ETO no data on journey times was collected at UCLH. But the Trust’s transport managers estimate that a journey from Queen Square to the main campus would normally have taken 20 minutes or less, using the Tavistock-Torrington route.

e)     In January-April 2017, records for 147 non-emergency patient journeys between Queen Square and the main campus were analysed. The average east-west journey now takes about 50 minutes. The ETO has therefore added about 30 minutes to a journey which used to take 20 minutes.


f)     The Trust is not able to count the total number of east-west journeys, taking in additional emergency journeys, journeys by patients who make their own way from site to site, and staff journeys. Their data is based only on journeys by patients eligible to use the non-emergency transport service, who are a small minority of outpatients generally. But it is reasonable to say that the impact on journey times would not be different for different groups

g)     In providing this data, it should be understood that the Trust is not opposing the introduction of better cycle tracks. Many trust staff cycle to work and welcome the tracks. But patients must also be considered. 


h)     BRAG explained this adverse impact to hospital staff and patients in two meetings with the Council.

The Council is aware of this problem of delays to patients and hospital staff, with the concomitant waste of staff time and public money, alongside increased journey times and pollution, since it states in the Equality Impact Assessment (EIA) attached to its SoC:

‘University College Hospital London, Euston Road, NW1 2BU – staff who cycle to work support the proposal but hospital is concerned about increase in east-west journey times between sites; from Queen Square to UCH campus have increased from 10 minutes to 45 minutes and from Grays Inn Road to UCH campus from 15 minutes to 37 minutes. Would like traffic options explored that ease journey times from east to west. Wish to see good provision for cyclists but need a solution that does not cause delay and stress for patients. What guarantees can be given that emergency service vehicles and patient experience on reaching/departing the hospital are not compromised? 

‘National Hospital for Neurology and Neurosurgery – Hospital Transport Department, Queen Square, WC1N 3BG - Would like to return to pre-trial layout. Our patients travel to and from the main Hospital in Euston Road to Queen Square and their travel journey time has increased due to the road being made into a one way street, thus backing up traffic on the main Bloomsbury Road. Pre-trial layout worked best as it did not create traffic jams along Torrington Place and Bloomsbury. 

‘London Ambulance Service – Scheme causes delays in arriving at incidents.’ 


i)     The purpose of an organisation conducting an EIA is to identify situations where certain groups might be disadvantaged, and then to address that disadvantage.  If no mitigating action is taken, the EIA is a pointless paper exercise, undertaken to meet the letter of the law but not to address the needs of the people in question.  The Council has written an extensive EIA, in which it recognises it is disadvantaging hospital patients, but makes no proposal to ameliorate that disadvantage.  This point is taken up in 2.3.5 below, with regard to people with disabilities. 


j)     Proof of Evidence (8) demonstrates further the problems caused to hospital patients and staff by the one-way system.  


2.3.5  Mobility and access more difficult and more expensive for a particular section

           of pedestrians -  frail, older and disabled people


a)     The Camden transport policy hierarchy is: pedestrians – cyclists – public transport. However, in creating the ETO,  the Council has prioritised cycling at the expense of everything else. In particular they Council has shamefully neglected the needs of frail, older and disabled people. The trial has caused a great deal of distress and has worsened mobility for many frail, older and disabled people.


b)     The transport hierarchy ignores the fact that pedestrians – supposedly the highest priority – who cannot walk far, have to use public transport, which on the roads will be buses or taxis; and as there are no bus routes in this immediate area, the mode of transport has to be taxi or private car.   The Tavistock trial has disadvantaged frail, older and disabled people in numerous ways, arising from both the blocking of routes and new prohibitions or impediments to dropping people off. 


c)     Local taxi journeys can now take four times as long and cost four times as much; this additional cost is being imposed on a section of the community who are typically on lower than average incomes. Proof of evidence (9) demonstrates this point further.


d)     One very clear way in which disabled people have been disadvantaged is that wheelchair users wishing to enter the Tavistock Hotel have had their direct access removed.  The problem is that now taxis can travel only eastwards, it is the driver side which abuts the hotel entrance, but the ramp for wheelchairs is on the passenger side. At the public meeting held at the Lumen Centre on 19th September 2016, the following exchange is recorded in the notes:


From a taxi driver

Because the ramps in black cabs are on the nearside, it is not possible for the east-bound taxis (west-bound not being allowed in the trial) to ensure that people in wheelchairs can get out of the cab safely when going to the hotel. Moreover, the ramps cannot fit on the concrete divider in the road. It is not good enough for disabled people.  Is the Council aware of this problem for people in wheelchairs and what is being done?


Response from the Council

The Council is aware of the problem for people in wheelchairs and the options for people in wheelchairs wanting to get into the hotel are to be dropped off across the road or around the corner on Bedford Way.


e)     In fact, it was erroneous to say wheelchair user could be dropped off across the road, as taxis cannot park next to the pavement because of a concrete raised platform.  In the Council’s SoC, it states: 


‘The Council have incorporated a dedicated taxi rank along the route enabling taxi’s to arrive at the kerb side so disabled users can use the disabled loading facilities on this side of the vehicle.’ (7.17) 


f)     This is somewhat misleading since the loading bay does not enable wheelchair users to access the main entrance of the hotel directly.  Basically, wheelchair users would have to be dropped off in an adjoining street and propel themselves, or be pushed, some distance, around 50 metres. Pushing an adult in a wheelchair is a hard job, and any extra distance or impediment adds significantly to the difficulties that people with disabilities and their carers already have to deal with.


g)     The Council’s response implies they have solved the problem.  But it is the case that wheelchair users cannot access the main entrance, as they used to be able to, and so are disadvantaged by the scheme.   The Council’s SoC Equality Impact Assessment recognises that a ‘distance of 46m to travel from a drop-off or to a pick up point on the north side of the corridor would inconvenience some disabled people’, but considers ‘it is not an unreasonable distance to travel’.


h)     The point is that the one-way system makes access worse for wheelchair users.  The EIA is used to explain this, rather than to address it. It shows a lack of empathy and understanding for people with mobility problems and a tick-box approach to addressing inequality; the EIA is written and the Council feels that is sufficient.  


i)     Pedestrians are supposed to be the top priority, in Council policy.  And pedestrians with mobility problems should be given greatest attention within that priority group.  In this case the Council has prioritised cycling over pedestrians with mobility problems, and has not acted in accordance with its own policy.


2.3.6    Threat to the sustainability of the community, by making the practicalities of

             daily life for residents and local businesses more difficult and stressful


a)   Getting around the area by vehicle is, as has been shown above, very much more difficult now.  This makes ordinary life for people needing deliveries, or having luggage or children to transport more difficult and stressful.


b)   The one-way system has also impacted negatively on local businesses.  The area around Tavistock Place is largely a residential area, with over 22,000 voters in the three affected wards, with a proportionate number of local businesses which help to make the area sustainable and vibrant.  Local people rely on local businesses to keep the area a thriving community; and local businesses rely on being able to travel around the area. If local shops and other local businesses close, and if local people find that getting around - or the business of daily life - is just too difficult because of the road systems, there is a risk that flats will cease to be long term homes, but will increasingly become short-term lets, and the current healthy community will be undermined. 


c)   Proof of Evidence (10) explains this further.



2.4      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.


a)     Various groups have suggested alternative plans which would accommodate cycle lanes without causing the problems generated by the trial. Some, for instance, have suggested that a west-bound only route would be less damaging to the community, which BRAG agrees has some validity.


b)     BRAG has put forward a plan which would accommodate two unidirectional cycle lanes and two traffic lanes, meeting all national width standards. Proof of Evidence (11) sets this out in detail.


c)     A key aspect of this plan to take into account is that this corridor used to have two-way traffic and two separate cycle lanes.  Local cyclists say this worked well and could not understand why the Council changed it.  It is understood that there were local objections when the Council decide to replace the two unidirectional cycle lane with one bidirectional lane, but these objections were overruled.  


d)     BRAG’s proposed scheme is a reversal of the trial scheme to its previous two way traffic but with the modification that, instead of one bidirectional cycle lane, there should be two unidirectional cycle lanes.


e)      The Council has rejected this scheme but BRAG considers this rejection is not based on a fair assessment. Proof of Evidence (12) sets this out in detail.



2.5 The Council’s Statement of Case supporting the trial being made permanent is 

based on many statements which are either misleading or unsubstantiated, and statements for which the evidence is quite contrary to the assertions, and also some incorrect information.


Some examples are set out immediately below.


a)     (SoC 1.1) The SoC implies that the Council planned this reduction of west-bound traffic in November 2015. In fact, the decision to do this was taken at the Cabinet meeting in January 2015, when the West End Project was approved.


b)     (SoC 2.4) Tottenham Court Road is described as heavily congested; it is not; whereas Gower Street is sometimes congested, especially towards Oxford Street.  The decision to move traffic from Tottenham Court Road to Gower Street means that in Gower Street, already sometimes congested, the current two southbound + taxis which use the bus lane, will be squeezed into one southbound lane. Also pavements will be narrowed, which is not congruent with pedestrians having priority.


c)     (SoC 2.6) The area referred to as the Brunswick Square Project is already aesthetically pleasing, with much greenery, and is easy for pedestrians to negotiate. Before the beginning of the trial in November 2015, this was peaceful area. Now it is often congested with displaced traffic. The answer is not to cut off further streets and add to the traffic jams, but to undo the one-way system.


d)     (SoC 8.6) This paragraph is simply false. BRAG did not propose such a scheme.


e)     (SoC 2.2 and 8.7) The statement in 8.7 is also false.  According to the Council’s own data, ‘Prior to the trial, the corridor served approximately 250 motor vehicles per hour (vph) eastbound and 350 vph westbound in peak hours.’   If the eastbound traffic rather than the westbound were removed, there would be less displacement; i.e. there would be 250 vph reassigned to local roads, rather than 350 vph, as is now the case.  The Council opted for the route which would displace most traffic on to surrounding streets.  So it cannot not be true to say, as the Council, states in 8.7: 

‘A suggestion has also been made that the one-way vehicular traffic flow should be reversed so that it runs in a westbound direction. Broadly speaking this could achieve one objective of reducing motor traffic along the corridor, but a comparative modelling exercise indicated a greater level of reassignment to more local roads.’


Either the modelling or the data quoted in 2.2 must be erroneous.


f)     The above gives some examples of areas of weakness in the Council’s SoC; and this is the document in which they are relying to prove the trial should be made permanent.  More detailed commentary is provided in Proof of Evidence (13)

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