An analysis of two surveys relating to the proposed North Dulwich CPZ by Mike Colvin

Introduction
As part of its third review of parking in North Dulwich, and the possible need for a CPZ, Southwark Council recently commissioned 2 surveys of:

1. Residents wishes in the 13 affected roads, which it carried out itself; and
2. Parking spaces and their usage in the 13 affected roads, which it retained consultants “Count on Us” to carry out.

It included the second survey at the back of its information pack but it appears to have been completely ignored by Southwark officers when writing their report: it is not referred to nor is the information provided therein used to inform its conclusions.
This is more that merely “unfortunate”  since if you read that report, and make use of the evidence so provided, you are inevitably drawn to conclusions which are almost diametrically opposed to those that have been drawn by Southwark Officers. It is thus difficult to avoid the conclusion that it has possibly been deliberately ignored for that reason.
This report draws upon both of the above mentioned survey reports for evidence and endeavours to produce a more complete report, and consequently more balanced findings and recommendations.
RECOMMENDATIONS
To the members of Dulwich Community Council, plus the strategic directors of environment and of housing:-

1. It is recommended that the existing Herne Hill CPZ is not extended to include Holmdene Avenue since there is minimal evidence of commuter parking (3%) which the existing HH CPZ is designed to solve. Moreover, the likely impact would be to displace such commuter parking to adjacent Elmwood Road which already has a much higher level (11%) of commuter parking than Holmdene has.

2. There is superficially a more arguable case to introduce controls into Ardbeg, Red Post Hill, and Half Moon Lane because it is clear from the evidence that they do indeed suffer from some commuter parking (8%, 10%, 3%) which a suitably designed CPZ could possibly relieve, and a majority of residents who actually voted have voted in favour of it in these three roads.

3. However a closer analysis reveals that despite this higher level of commuter parking, a minimum of 40% of unrestricted parking spaces are unused in the worst affected road (Red Post Hill) and so residents should have no difficulty finding a parking space somewhere in their road.

4. The voting in every road was less than 50% of its residents so such a vote can hardly be argued to have legitimacy when the introduction of a CPZ has financial implications for other residents in the road. More simply put, it is not equitable that a small number of residents who voted for the CPZ should impose their wish, and the corresponding financial burden, on the very much larger number of residents who voted against, it or did not vote at all, for whatever reason. The overall figure for these three roads is that each voting resident would be imposing a potential financial burden on 4 other residents.

5. For all these reasons it is recommended that a CPZ is not required in  any of the roads within the current consultation area.

6. It is recommended that you compliment the officers for commissioning “Count on Us” to provide some objective evidence on the need for a CPZ, but also reprimand them for then completely ignoring it, and in particular for consequently making recommendations which are the complete opposite of those which are informed by the evidence so provided.

BACKGROUND INFORMATION

1. This survey follows on from two previous surveys in 2002 & 2005 each of which massively rejected the idea of a CPZ in the north Dulwich area.

2. This further survey has come about as a result of a small group, we understand of predominantly Holmdene, residents persistent lobbying for a further re-assessment.

3. That Southwark report draws upon, but does not objectively represent, the detailed analysis even of its own consultation report (see background documents), and as has already been noted, it appears to have completely ignored the work carried out by consultants in assessing the number of parking bays and their usage.

4. The Parking Enforcement Plan (PEP) sets out the council’s policy in the management of parking on it’s public highway. The PEP acknowledges that few things polarise public opinion more than parking, and accordingly officers should appreciate the absolute imperative of objectively assessing the results of the survey and placing them in an appropriate context. Regrettably, IMHO, it has failed to do so.

5. In accordance with Part 3H of the council’s constitution, Dulwich Community Council approved the methods and boundary for the study on September 22 2009. Regrettably  the Southwark report has subsequently ignored that boundary and has included results from a street (Nairne Grove), which is clearly shown in the map produced at that time, to be outside the agreed boundary.

6. Moreover it has openly accepted, and decisively acted upon, petitions from undisclosed people outside the area without including such evidence as part of the report so that it can be evaluated, and where appropriate, challenged. It has clearly given these unidentified interests such undue weight that the democratic wishes of the residents of Red Post Hill, Ardbeg and Half Moon Lane, who each voted in favour of a CPZ, have been overturned.

7. During November and December 2009, the run up to Christmas when residents were least likely to respond to a survey, residents and businesses were consulted on parking in North Dulwich, primarily if they supported the introduction of a CPZ.

8. Several residents have since complained publicly about this unsuitable timing and how they were disenfranchised as a result.

KEY ISSUES FOR CONSIDERATION

1.  A total of 362 questionnaires were returned representing a 27% response rate. This is a better than average response rate for this type of consultation when compared with similar consultations in the borough and benchmarked against other London authorities.

2. That 27% splits as 8% in favour, 18% opposed, and 1% who failed to answer the key question of whether or not they wanted a CPZ in their road. In other words, there were 225% more votes against the CPZ proposal than there were in favour of it.

3. The council allegedly gives significant weighting to the consultation return when the response rate exceeds a threshold of 20%, except when it suits its purpose not to.

4. The table below details responses to the question “do you support the introduction of a CPZ in your street?” Note that unlike the misleading bar chart in the Southwark report, which shows the results only in terms of percentages of those who actually voted, this table shows those same votes expressed more appropriately in terms of percentages of households in the relevant street. The latter being obtained either by counting or from the postcode directory for this area.

Road	Houses	H'holds	number	% Road	Said	Said	% road	% road	Skipped	Forms	Number	Number	% not
	in road		returns	made a	YES	NO	= YES	=NO	question	% Not	forms NOT	Not YES	YES
		1.25		return						returned	returned
Ardbeg	28	35	17	49%	11	6	31%	17%	0	51	18	24	69%
Beckwith	93	116	37	32%	9	25	8%	22%	3	68	79	107	92%
Casino Avenue	130	162	33	20%	5	26	3%	16%	2	80	129	157	97%
Danecroft	79	99	38	38%	2	36	2%	36%	0	62	61	97	98%
Elfindale	96	120	48	40%	3	38	3%	32%	7	60	72	117	98%
Elmwood	80	100	26	26%	0	26	0%	26%	0	74	74	100	100%
Frankfurt	84	105	36	34%	5	29	5%	28%	2	66	69	100	95%
Half Moon Lane	69	86	9	10%	5	4	6%	5%	0	90	77	81	94%
Herne Hill	82	102	10	10%	3	6	3%	6%	1	90	92	99	97%
Holmdene Ave	107	134	48	36%	34	12	25%	9%	2	64	86	100	75%
Nairne Grove	24	30	2	7%	1	1	3%	3%	0	93	28	29	97%
Red Post Hill	106	132	25	19%	14	11	11%	8%	0	81	107	118	89%
Sunray Avenue	90	112	22	20%	8	11	7%	10%	3	80	90	104	93%
Wyneham	21	26	13	50%	2	11	8%	42%	0	50	13	24	92%
outside area			4
TOTAL	1089	1359	368		102	242	8%	18%	20		995	1257

What conclusions that can be drawn from these returns?

1. only 27% of all residents responded to the survey - this is the only one of the points made below that is made in the misleading Southwark report.
2. only 8% of all residents said YES to a CPZ in their road
3. whilst 18% of all residents said NO to a CPZ
4. in other words 237% times as many residents said NO as said YES
5. only 25% of Holmdene residents are in favour of CPZ  whilst 75% are happy with the current arrangements
6. only 8% of all residents in the proposed CPZ area are in favour of having a CPZ whilst 92% are happy with the current arrangements
7. 71% of all roads said NO to a CPZ
8. hence the small minority Holmdene residents who are in favour, amounting to only 2.5% of all residents, are effectively dictating the outcome not just for Holmdene, but for everyone else in the whole consultation area.
9. witness the fact that more residents, 31.4% in Ardbeg as opposed to only 25% in Holmdene, are in favour of a CPZ in their road, yet they have been refused a CPZ on what appear to be very spurious grounds, (details below) whilst Holmdene's minority wish has been granted.
10. Red Post Hill and Half Moon Lane, who also had majorities in favour, have been rejected on the same grounds
11. Given such illogicality, you can't help but wonder whether there is indeed an undeclared ulterior motive, as has long been suspected, for the whole push by Southwark to impose CPZs

And last, but by no means least, even if Holmdene were to get an extension to the existing CPZ zone, it is simply NOT going to solve Holmdene's problems (see below).
Resulting recommendations

1. It is not recommended that the existing Herne Hill CPZ is extended to include Holmdene Avenue since there is minimal evidence of commuter parking (3%), which the existing Herne Hill CPZ is designed to solve. Moreover, if extended, the likely impact would be to displace such commuter parking to adjacent Elmwood Road which already has a much higher level (11%) of commuter parking than Holmdene has.

2. There is a more arguable case to introduce controls into Ardbeg, Red Post Hill, and Half Moon Lane because it is clear from the evidence that they do indeed suffered from commuter parking (8%, 10%, 3%) which a suitably designed CPZ could possibly relieve, and a majority of residents who actually voted have voted in favour of it in these three roads.

3. However the Count on Us parking spaces survey shows that the maximum usage of unrestricted parking spaces (including commuter parking) in Red Post Hill was 84 out of an available 141 spaces, thus leaving a minimum 57 (40%) spaces free. So whilst acknowledging that some commuter parking does indeed take place it does not appear to be at such a level that residents cannot park in their own road although it may not be as close to their house as they would wish, given the length of Red Post Hill.

4. Voting in each of these three roads was less than 50% of residents, 30 (20%) out of 147 in total. Such a vote can hardly be argued to have legitimacy when the introduction of a CPZ has financial implications for other residents in the road. More simply put, it is not equitable that a small number of residents who voted for the CPZ should impose their wish, and the corresponding financial burden, on the very much larger number of residents who voted against it, or did not vote at all for whatever reason.

5. The highest percentage in favour (31% in Ardbeg) would thus be placing a financial burden on twice as many residents who had not voted in favour, whilst in the case of Holmdene it would be three times as many who had not voted in favour. The overall figure for these three roads is that each voting resident would be imposing a potential financial burden on 4 other residents.

6. Consequently it is recommended that a CPZ is not required for any of the roads within the current consultation area.

7. Interestingly, the Southwark report also rejects a CPZ for those three roads, but on what many would see as spurious grounds (details below), when it could more simply have done so on grounds of equity.

What grounds were used by Southwark for the rejection of CPZs in Ardbeg, Red Post Hill and Half Moon Lane?

• “It is not recommended to introduce controls into Red Post Hill due to the significant amount of correspondence received (against the CPZ) by email / letter beyond those charted in the questionnaire returns.
• In view of this and for the technical reasons provided in the consultation report it would be very difficult to provide a reasoned CPZ boundary for the two other supportive roads (Ardbeg Road and Half Moon Lane). Therefore these are not recommended for CPZ implementation.”

I can hardly believe I am reading that. Southwark spends thousands of pounds of rate payers money properly consulting the residents of North Dulwich, carefully agrees with the members of the DCC what the boundaries should be, then officers promptly ignore that agreement by including returns from Nairne Grove which were not in the originally agreed area. OK, this in itself is no big deal since it was only two returns and they cancel each other out, but it does not reflect at all well on the probity of the officers.
But now consider this. Residents have been consulted, then Red Post Hill, which has a majority voting in favour of a CPZ, is told by these same lacking in probity officers, that simply because an  unquantified number of unidentified outsiders, who were not part of the consultation, have raised objections, its expressed wish will not be granted. Moreover “in view of this” the expressed wish of residents in Ardbeg, who incidentally have a much higher proportion of their residents voting for a CPZ than do Holmdene, is also rejected, as is the majority wish of voters in Half Moon Lane. What sort of democracy is that?  
Note that despite being referred to as being elsewhere in the consultation report, the “technical reasons”, which are also referred to as grounds for rejection, are not to be found anywhere in the report. Unsurprisingly, one ends up suspecting that they simply do not exist.

Why, even if they were to get the CPZ extension, it is a CPZ not going to solve Holmdene's problems ?
First we need to understand what Holmdene's problems are, which is a lot easier said than done.
Although Southwark sensibly asked residents how difficult it was to park, sadly there has been no attempt by Southwark to ask Holmdene residents, or any other residents, why they believed it was difficult to park. I will come back later to their anecdotal statements that have appeared on the web, but first let us look at the basic facts which can be enumerated: 

1. How many parking spaces are actually available per house/household in each street? and
2. How often do they run out of unused unrestricted parking spaces?

At the back of the Southwark information pack 
http://moderngov.southwarksites.com/Published/C00000176/M00002978/$$ADocPackPublic.pdf, is a lot of seriously useful findings from the survey by “Count on Us” which was commissioned by Southwark, but which officers appear to have completely ignored when it comes to preparing their conclusions and writing their report. Nowhere in the report are they referred to, they are simply attached at the end as though they were of little consequence. 
However they are a mine of useful, and extremely relevant, information which should inform any assessment of the need for a CPZ. It is more than “unfortunate” that they have not done so as yet. So let me introduce some key findings.
There are numerous tables prepared by the consultants “Count on Us” from which I have abstracted the following.

Road	Houses	H'holds	Unrestricted parking bays	UPBs per h'hold
	in road
		1.28
Ardbeg	28	36	63	1.75
Beckwith	93	119	111	0.93
Casino Avenue	130	166	198	1.19
Danecroft	79	101	123	1.22
Elfindale	96	123	129	1.05
Elmwood	80	102	132	1.29
Frankfurt	84	107	111	1.04
Half Moon Lane	69	88	58	0.66
Herne Hill	82	105	0	0
Holmdene Ave	107	137	158	1.15
Red Post Hill	106	135	141	1.04
Sunray Avenue	90	115	232	2.02
Wyneham	21	27	45	1.67
TOTAL	1065	1361	1501	1.1

As you will see there are in total, according to the consultants' report, more parking spaces (1501) than there are houses or households (1361) with an average of 1.1 spaces per household. So in theory there should not be a problem if there was only one car per household. However the spaces are not evenly distributed, so we find that some roads, particularly roads with buses, like Herne Hill of Half Moon Lane, where parking spaces are restricted because of bus stops or yellow lines, are well below the average, whilst Sunray Avenue (surprisingly despite having a bus route) is well above the average with at theoretical 2 unrestricted parking spaces available per household.
Holmdene is above average with 158 bays which gives 1.15 per household, 1.48 per house.
The next question is “How intensely do they actually get used?” Despite all the vociferous complaints by Holmdene residents over the years about inadequate parking spaces, every time I have walked the length of Holmdene and counted the empty spaces there were always at least 10 available, at which point I gave up. I began to suspect that Holmdene residents were particularly lazy and perhaps not prepared to walk more than 10 yards. But maybe I was simply not counting at the right time, so it is refreshing to see that a systematic effort has finally been made to establish the true scale of the parking problem across the whole area.
“Count on Us” did 4 counts of the number of unrestricted parking spaces which were occupied on all 13 roads, at 4 times on each of two days (Thursday and Saturday), including two at 6 in the morning. The results for Holmdene were 127, 111, 124, 130, 131, 117, 105, 91 compared to the 158 available spaces. From that it is apparent that there were always at least 27 empty car parking spaces available, even overnight. 
So on the face of it, despite all the protests from Holmdene residents, there is no statistical   evidence from this survey to support their claims of lack of parking spaces. In fact quite the contrary, it appears that 17% of available spaces are permanently underused.
Anecdotal evidence
I mentioned earlier the anecdotal evidence of problems. There have been numerous postings on the http://cpzdulwich.net/ web site set up for that purpose. A number of the posts were from residents in favour of a CPZ, including several from Holmdene.
These posts can be summarised as expressing concern about

1. parking by non residents; some non residents parking for days/weeks on end
2. being unable to find a space and thus resorting to parking in nearby Elfindale or Beckwith
3. being unable to find a space whilst neighbouring streets are allegedly empty
4. safety issues for mothers with children from speeding cars
5. safety issue or mothers with children because you cannot park in front of, or near, one's house

Checking these claims to the analysts carried out by “Count on Us”  and reported above, we find

• Issues 1-3 are simply not supported by the survey
• Issue 4, a CPZ in itself is not going to have any impact on speeding cars
• Issue 5, the 5 additional spaces that might conceivably be freed up by discouraging longer term “commuter” parking is not going to have much impact either on the 158 available spaces, or the 27 (minimum) unused spaces, and thus ensure that there is always an unused space near your house. Many other residents have wisely given up on such an aspiration many years ago.

Mike Colvin

Beckwith Road

URGENT: Dulwich Community Council Meeting TONIGHT...PLEASE ATTEND

This is just to let you know that the Herne Hill CPZ report is scheduled for the next DCC meeting on March 25 at the Herne Hill Baptist Church on Half Moon Lane.

The report is set for the second half of the meeting, after the Break at around 8.30pm.

CPZ needed in Holmdene

Yes Holmdene needs CPZ as we Have major problems in parking in the day time and evening  In day time there are serious health and safety issues for mothers taking young children in/out, 

In evening when many residents cannot park and are forced to go elsewhere. Women working late or out of London often have to walk back from their cars parked in other streets late at night alone.  Being the only through road in the triangle without parking restrictions We have seen displacement of cars to Holmdene. During the day and also for longer term  car owners use Holmdene for days/sometimes weeks of free parking; This is going to get worse: Lambeth is introducing CPZ just the other side Herne Hill – already installed by Ruskin Park

CPZ clearly works.   There are half-empty streets of Hollingbourne, Warmington etc at any time of day or night. (eg 18 free spaces in Hollingbourne at 10pm recently) . This shows that parking problem in Holmdene Avenue is not just London organic car growth. Diagonal parking is not the answer  It was considered in 2000 but dropped as too dangerous. Traffic picks up speed on the hill - it would put drivers at risk when reversing out  and would be very dangerous for any cyclist caught. And this would just attract in even more cars from  elsewhere - Holmdene does not want to become the free car park for the district.

Robert and Judy Foster,  Holmdene,

Holmdene... light on facts but heavy on emotion

Sally, David, Harriet, Holmdene anonymous, and everyone

There is a real need to think through the benefits (or otherwise) of a CPZ.

Sadly there appears to be a belief that it is a cure-all for parking problems when that simply is not the case. It seems to have delivered some improvement to the lives of residents in the existing CP zone near Herne Hill station because there's was a very specific problem of commuters parking there all day. Hence a balance was struck within the CPZ between the needs of shop keepers for shoppers to park, for the needs of residents for short term visitors or tradesmen to park without the hassle of having to buy a parking ticket, and the need to discourage commuters, by having the CPZ parking restriction apply only between the hours of noon and 2pm.

However, we seem to easily to forget that the inevitable corollary to such a limited hours restriction is that there is enforcement only between those same hours. Hence there is no enforcement in the evenings, or overnight, thus people can park where they like then, CPZ or no CPZ, with impunity.

Unsurprisingly therefore, that lack of enforcement will do nothing to solve another problem, namely too many overnight car parkers, a problem which is brought about by most streets not being big enough to accommodate even one car per house, let alone the two or three that occur when houses have been split into flats or there are multiple cars per household. This, as best I can understand it, from these postings, which seem to be light on facts but heavy on emotion, is the primary problem in Holmdene

So my suggestions to Sally and other residents in Holmdene are to first take the following actions
1.Do an audit of the real demand from Holmdene residents for parking in Holmdene. Amongst other things this could provide the registration numbers of residents cars and thus enable you to much more accurately determine how much parking is by residents, and how much is by non residents. You may be quite surprised to discover that what you thought was non resident parking was simply someone from further up the street
2.Carry out an audit of the parking at different times of day over a week and establish how many residents are parking, how many non residents are parking, and how many parking spaces are free. On the numerous occasions that I have tramped up and down Holmdene in the last few years counting available spaces, there have never been less than 10 free spaces.
3.Give up on the idea that you should always be able to park outside your own house. Most of us wised up to the fact that such a luxury was rarely going to happen many years ago.

Clearly if the outcome of action 1 is that there is a greater indigenous demand for parking in Holmdene than Holmdene can currently itself satisfy, then the solution is largely in your own hands. You have to either promote a reduction in car ownership and a corresponding take up of car clubs, or park on your own forecourt where that is possible, or create more on street parking spaces. In the latter respect Holmdene is unique in this area in so far as it is such a wide road it, so it could have diagonal, as opposed to parallel parking, and increase the capacity by about 50%. OK, I know one of the officers stood up and said that was not safe, but that claim appears to be without foundation given that such parking already happens on a far busier road through Dulwich Village, and to the best of my knowledge there have never been any accidents there.

No Sally, it is not simply a case of “just because the 'no' vote streets don't want the acknowledged problem moving into theirs”, more a deeper recognition by many people who have thought long and hard about it, that a CPZ will not solve Holmdene's problems, or their own parking problems - and most streets have got a parking problem of some sort. As a result the numbers opposed to the idea of a CPZ are about 3 times those in favour.



 Mike Colvin, Beckwith Road

Yes in Holmdene Avenue

PLEASE PLEASE install cpz in holmdene avenue. Parking is a nightmare due to non residents using the street as a free car park as we are on the edge of the cpz boundary. We really want to have cpz, so many residents are campaigning for it. It's a serious issue for mothers with young children, of which there are many on this road. It's a safety issue at night for people trying to get home, and for everybody who lives here it's causing a real headache not to be able to park in front of or even near your own house. PLEASE listen and install cpz on this road. Thank you.

--
Kate Murrell

Controlled Parking Please in Holmdene

I am a resident of Holmdene Avenue. It is essential to have controlled parking here despite all its drawbacks we are now the first street away from Herne Hill without it and its a nightmare. I have had to park in Elfindale or Beckwith in order to avoid a parking fine in one of the controlled streets because everyone has crowded into Holmdene. A neighbour regularly blocks off the space outside her house so she can come back with her small children totally understandable but that means the rest of us have fewer options. THe only answer if controlled parking please for Holmdene. It would have been better not to have controlled any of the streets but now the others have been It's a nightmare. So I say a very strong yes to controlled parking


Helen Willcox
Holmdene Avenue

We absolutely need a CPZ for Holmdene Avenue

We absolutely need a CPZ for Holmdene Avenue. 

I agree this scheme should be assessed street by street and good luck to those residents who find themselves living next door to a CPZ street.

Holmdene Avenue suffers because the streets towards herne hill are all controlled As a result it is often impossible to park, whilst the neighbouring streets are empty.

Also, we do not need 4 loading bays at the bottom end of Holmdene Avenue. With available parking on the main road, there is no need for so many bays with such few shops.

David & Harriet

Holmdene Avenue

Do not rely on your councillors to support you

I previously lived in Wyneham Road and remember the 2005 consultation. Subsequently I moved to the other side of the hill where a CPZ has recently been introduced in the Herne Hill Road, Ferndene Road area. Based off these experiences I have the following observations and recommendations to make.

1) Mobilise! The council rely on residents inertia, weariness and fatalism to push these things through. Lobby loud and hard. In a large section of our roads - about a third of the now CPZ - a petition against the CPZ proposal attracted over 250 signatures as compared to the 73 people who subsequently voted in favour through the official consultation questionnaire. The Council dismissed the petition on the grounds it was not 'statistically comparable' to the official consultation. Setting aside the serious questions this raises about the demcratic process the important lesson to learn is this: of the 250 people who signed the petition only 72 made the effort to complete the official questionnaire. Inertia, of which I was guilty too, cost this area dearly.

2)Do not rely on your councillors to support you. Central government has a massive budget shortfall and consequently local governmenmt is and will feel the squeeze. You live in nice big expensive houses: no self respecting ambitious councillor will help you avoid the implementation of a lucrative annuity revenue stream. In our instance residents failed to observe that the ward councillor was also head of finance for Lambeth Council.

3) Think about who will get parking fines or have their cars towed away. It will not be the regular drive-train commuters - they will observe the change and simply park their cars elsewhere. Assuming the CPZ will operate between 12 and 2pm, those impacted by penalties will be YOU, directly or indirectly. They will catch i) visiting friends, family or workmen who either don't notice the signs, misunderstand the signs, or who simply loose track of time and overrun the meter or 12pm watershed; ii)residents who forget to renew their permits on time or who park two inches of their back wheels on the swathes of new (and largely purposeless) yellow lines that always accompany the introduction of any CPZ.

4)Where residents are opposed make sure that they respond to the official consultation. In our CPZ the percentage of residents (of the ultimate CPZ area) who voted in favour of the proposal was 16%, and against 8%. 74% did not respond. Based on those numbers the final consultation report concluded that "a strong majority" had voted in favour of the CPZ proposals. The report is in fact riddled with dishonest statements and misuse of statistics, but the lesson is this: we let the council do this to us. We failed to mobilise the vote and we did not properly scrutinise and challenge the consultation report at the right time.


Colin Harrison

So called "consultation"

Please take this email as our opposition to the above proposal. CPZ in our the above areas is unnecessary and will cause more financial strains.  As expected, lots of people like us were too busy prior to the festive season, and only have time to deal with this type of so called "consultation" now to express our opinion.

 

We wish the council, by now, should have been fully aware of the residents' opinion and should never make such a time-wasting proposal again.

 

Thanks

Liu Family Sunray Avenue SE24 9PT

A disgusting money-making operation

I deeply disapprove of the plan to enforce CPZ on Sunray avenue and the streets of North Dulwich. It is a disgusting money-making operation which is of no benefit to residents or people who work in Dulwich at all! There is always plenty of parking on my street. I have no concerns about non-residents parking there freely. I need my car to come and go in the middle of the night as I am a junior doctor. Many others have similar reasons for needing their cars, not lease my house-mates. I live in a house of multiple occupancy where there are currently 5 tenants. How do you propose we all park with this ridiculous plan for Controlled parking! 

In anticipation of your action to halt this CPZ plan I thank you

Daisy Hamilton-Baillie

Sunray avenue

Have lived in other London boroughs where there are CPZs and they do not guarantee you a space

I live in Elfindale Road and also strongly oppose the CPZ plans. I
always find a parking space and the road has lots of spaces during the
day. I have lived in other London boroughs where there are CPZs and
they do not guarantee you a space in your own road!

Many thanks
Clare, Elfindale Rd 

Red Post Hill Resident's Committee...strongly object to CPZ

Further to our previous representation we are writing in response to the recent council consultation proposing CPZ in the ‘North Dulwich Triangle’.

We strongly object to the introduction of a CPZ zone on two major grounds as detailed below. The first is in terms of the detriment to both the nature and quality of life for residents and amenity users of our unique greener safer environment, and the second is on procedural grounds to request adequate consultation as once again, the council is in contravention of its own recommended practise and guidelines for consultation.

Ground 1

The proposed CPZ goes against both the wishes of local residents and amenity users of the area and is inconsistent with the current development s plans of the local authority (Green Safer Environments).

Previous representation and petitions have been made to the Council via committees, local councillor surgeries, scrutiny committee, public meetings, community council meetings, in writing, in response to written consultations and meetings demand by local residents and amenity users.

The council records and petitions show how over 90% of local residents and amenity users object to measures that increases traffic volume, speed and reduce safety (2007 - to date). These objections have included inappropriate and unnecessary proposals for yellow lines and CPZ zones.

Residents have previously justified and documented their objection and have been successful in convincing the council to halt their programme implementing measures that are significantly contrary to local needs. In addition, residents have campaigned and secured area improvements such as: safer crossings, traffic calming measures, 20 mph signage and funding from the councils own schemes to improve the local area and amenities.

These current proposals for the CPZ in the ‘North Dulwich Triangle’ are in total contradiction to what is already on the public record and has previously been agreed by both Council Committees and council officers.

The introduction of CPZ would cause:

• Significant reduction in the levels of safety to the large number of school children in the area both local primary (6) and secondary (4), the elderly  and those using the pavement with prams and mobility aids due to the increase of traffic, parking occlusions and traffic speed in the area
• Unnecessary increase cost and inconvenience to local residence and amenity users

Ground 2

Once again the following procedures have not been followed

i)                    Lack of detail in the consultation documentation

ii)                   No opportunity for open public  meeting consultation

iii)                 Inadequate time allowed for consultation

iv)                 Deliberately timed to reduce the response rate

v)                  Local groups have been inadequately consulted

vi)                 Previous strong objections to parking measures have not been presented as part of the consultation

vii)              The proposals are presented in isolation to other community development issues and concerns

Based on the information and grounds above we demand that the council hold a public meeting and allow adequate time for consultation and that the proposal together with the consultation process be referred to the scrutiny committee.

Yours Faithfully,

Marilyn Panayi

Vice Chair

Red Post Hill Resident's Committee

Charter School teachers using nearby roads ...should be taken up with school before taking such a draconian step

I am writing to inform you that I am opposed to the proposed CPZ for the North Dulwich Triangle (or any other location within the borough not already subject to a CPZ) for the following reasons:

1) I do not currently experience any parking problems. I own one car which I can park outside my home throughout the day.  The introduction of a CPZ covering my area is therefore unnecessary.  A CPZ also appear to be unnecessary for Sunray Avenue given that much of the housing on that road has off-street private parking.  In my experience there is never a shortage of space to park on Sunray Avenue.

2) This area does not generally suffer high demand for parking as there are few shops or other amenities (there are only small parades on Herne Hill and Half Moon Lane within the consultation area).  The area is otherwise low density residential where the supply of street parking spaces exceeds demand.

3) It has not been necessary for Lambeth to introduce CPZs close to Herne Hill Station other than for Poets Corner.  In particular the opposite side of Herne Hill to the consultation area is not within a CPZ.  This suggests that such measures are unnecessary.

4) In light of the above a CPZ appears to be a disproportionate response to any issues reported by residents in terms of (1) cost (2) balance between number of residents benefiting from the CPZ (few) and number of residents paying to implement the CPZ (many) and (3) the inevitable delays and difficulties  in issuing permits and enforcement, not to mention mistakes by residents and parking attendants as to where and when to park.  Ironically, this is likely to cause confusion and fines for residents and their visitors, the very people that the CPZ is intended to serve.

5) Are there no other alternatives to increasing the clutter (and parking attendants) on our streets?  It was certainly one of the attractions for me to live in this area that it is not within a CPZ.  In a CPZ the street scene is dominated by yellow lines, parking bays, zone entry and exit signs, parking meters and ticket machines, yellow and white parking signs, and patrolling wardens.  The imposition of parking rules in this way would make the area a much more stressful and unpleasant place to live as well as a more expensive place too.

6) The issue of Charter School teachers using nearby roads should surely be first taken up with the School before taking such a draconian step.  Perhaps they can be persuaded to increase their own parking facilities or to introduce other schemes to reduce their car usage.  Let us not willingly destroy a sense of community and understanding by opting for rules, regulations, fines and penalties the responsibility for which we subcontract to private parking enforcement companies who care only about their profits.

7) As for commuters leaving their cars outside North Dulwich Station, I think if this is a central argument in favour of the CPZ we should be provided with some figures to understand the scale of the problem and whether there are alternatives to a CPZ.  Only when we understand the nature of the problem will we know how best to solve it.

8) In times of economic crisis such as these, we should be reluctant to increase the cost of living.  If there is a funding shortfall for other public services, parking and streets is one of the non-essential areas that could bear a reduction in budget to support core services.

Yours faithfully

Lee Khvat
Crossthwaite Avenue

London SE5

CPZ does not make sense

The proposal would make sense if it were addresssing a parking/circulation issue in the area but it is not: my street, Casino Ave is both qiuiet and always easy to park in with plenty of space even at week-ends. It is quieter than for instance Dovercourt Rd. from where I moved recently, and where many families have two cars, and streets nearby are also heavily parked, and control could be an issue.

The proposal is unfair and obviously a wheeze for raising revenue in return for nothing.

 Dr. Julian Minton  

Casino Ave.

Against in Casino Avenue

The majority of the residents and I who live on Casino Avenue, SE24 are strongly AGAINST any proposal to introduce Controlled Parking Zones (CPZ) 

on this street and on the North Dulwich Triangle.

We have no congestion or parking issues to contend with in this area. Furthermore I believe it is wrong for us to be levied to park outside our houses on top

of the increased road tax we have to pay.  Considering also the current economic restraint we are forced to undergo.

I urge you to please cancel this proposal to impose CPZ in our area.

Alphy Shields

Lived on Frankfurt for 14 years and don't want CPZ

I live in Frankfurt Road.  I am opposed to the proposal for the CPZ. I have lived in this street for 14 years and see no justification for one. I have to say in my experience it is rare whenever anyone complains about lack of car parking space in the street.

I cannot complete a Council consultation form as it has not been posted on the web so it appears that the consultation exercise is flawed in this respect.

My neighbours and I on either side do not own cars although I owned a car for 12 years. My neighbours on both sides have never owned a car!  Has your survey revealed how many cars each car owning family has?  Perhaps it is the two car owning families who are complaining, if any. Also some people persist in buying very large vehicles which do not seem justified in relation to their usage.

My family and I have reduced our car usage from years ago. I occasionally use a car club car and consider I made very efficient use of the car in an area where we have very high public transport accessibility (2 railway stations and buses nearby). Most of my transport needs are met by my family and  I walking, using public transport and cycling.  Some of my visitors occasionally use a car to visit us.

I accept that there is a case for disabled parking which I am very happy to support. Special places could be set aside for electric cars to encourage a switch to more non polluting cars. Designating space for bicycles or motorbikes could also be a better priority.

I think cars clutter the street scene and degrade the appearance of the street in urban design terms. CPZs confer the concept of 'car ownership space' on the road as a 'benefit' at a cost that house owners can acquire.  They are not.  Cars are ugly and cause air pollution.   CPZs just reinforce the notion that the car can rule and can be prioritised over the environment.

The road is a shared space for all users and should not be carved up between house owners who want to run a car - the 'wants' of some car owners for designated car parking space is not a justifiable social 'need'.   Need and want should not be confused.

The Council would be better off spending its efforts on behaviour change methods.  Introducing a car club space in the North Dulwich Triangle would perhaps reduce car ownership in our area for example (it certainly does that for us and we have 3 cars 6 minute walk away).  If we had car club spaces in every street for example the car driving fraternity might get the message that car clubs offer masses of savings, are a more sustainable approach to the use of the car and reduce trip generation, and significantly save car drivers lots of money.  They also save drivers loads of hassle including the need to find a car parking space!

Shopping is regularly delivered in our street by a range of supermarket chains and big stores - that also cuts down on the car. Delivery people have never complained to me about the lack of space.

When I had a car and parked regularly I generally did not find it difficult to park the car close to my house.  I noticed Saturday evenings could be congested late at night but this is not an issue when the kids are in bed and walking around the corner is not a pressure at weekends. 

I suspect that house owners close to Herne Hill itself might be under more pressure for car parking space but that does not justify the whole of the road being subject to a scheme as draconian as this.

I am happy for this response to go up on the dedicated webpage about this issue and join the voices of the majority in rejecting this proposal.

Yours sincerely

Liz Loughran

I do not own a car. But I am strongly opposed to introduction of controls in any part of the consultation area.

Summary of response

1. I do not own a car.  But I am strongly opposed to introduction of controls in any part of the consultation area.   Introduction of controls simply creates a problem in streets where there is currently none.  The supposed problems perceived by residents of some streets are not so pressing as to justify the inevitable harm that controls would cause to neighbouring streets.  Instead the Council should attempt other measures to reduce car dependency throughout the locality.  Those include provision of additional car club spaces.  That would be preferable in policy terms to parking measures aimed at private cars.

Policy framework

2. Local Implementation Plan (2006): the ten overarching transport objectives include – as Lip 2 – “promote more sustainable modes of travel”.  The fact box on p. 2 defines “sustainable transport” as including “modes of transport that minimal [sic] impact on the environment, this includes walking, cycling and public transport and in some circumstances car clubs…” [emphasis added].  The Executive Summary shows “encourage use of… car clubs” in priority to “implement the parking and enforcement plan” (see below).  The Council’s transport hierarchy gives the lowest priority to private cars.  By implication, a higher priority is given to car clubs in satisfying travel demand.  
3. Parking and Enforcement Plan:

• The parking hierarchy prioritises “care share and car club bays” over resident and other parking.  That means measures to provide car club bays should take policy priority over measures that either provide or regulate parking of private vehicles. 
• Section 3.2 (“taking stock”) notes mixed reactions to recent consultations – “some of the reactions may reflect growing resistance by the public to CPZs” whereas “in some areas there remain localised conflicts between residents’ needs and parking by all day commuters…”.  “Analysis of supply and demand within existing CPZs indicates that pressures on available parking space vary significantly suggesting that a one size fits all approach to the CPZ regime may not be appropriate…”   [emphasis added]. 
• The “new strategic principles for parking control” (p. 8) begin with “The purpose of each CPZ and other parking controls should be defined in relation to local circumstances in the context of the council’s wider development and transport plans”.

4. Car clubs: The Council has recently adopted Borough-wide policy in favour of promoting provision of car club spaces.  That is also consistent with TfL policy of spreading availability of car club spaces.

The situation in North Dulwich

5. Frankfurt Road is typical of many of the streets in the area.  Parking congestion is at its greatest in the evenings and weekends when residents are at home.  There is no discernible commuter parking problem. Laying out a CPZ here would exacerbate congestion by reducing the parking capacity of the street for residents.   Some residents already park in neighbouring streets at the busiest times.  Introducing controls in streets like this would increase that pressure.
6. Introducing controls in a neighbouring street would, in the same way, displace resident parking to this street.  It also follows that if there is a commuter parking problem in a neighbouring street, introducing controls would also displace that problem here too.  So it would bring about pressure for a CPZ as “least worst option” to control commuter parking at the expense of creating additional problems for resident parking.  It is precisely because of this problem of “CPZ creep” that residents a large majority of residents opposed CPZ controls in the whole area at the last round of consultation.  The very fact that some residents of a street adjacent to the existing CPZ boundary are complaining of a commuter parking problem shows that we were right to anticipate this effect.  The problem is not the absence of controls but the controls themselves.

What the Council should do

7. The Council needs to get serious about reducing overall car use in the area.  Car club bays are an effective way of doing this.  I have not owned a car for over two years. I have been able to sustain this because I am a  member of a car club (Streetcar) which has a number of vehicles in bays in the immediate and wider area.   I know from dealing with planning applications around the Borough that there is powerful evidence that each new car club bay replaces several private cars.  The effect is particularly pronounced with second cars – a ratio of up to 1:20.  Households who get rid of a second car will be neither parking it nor commuting in it.   So the result of each new car club bay is to reduce overall car use and levels of ownership as habits change.  That reduces parking pressure from both residents and commuters.
8. But locally the scheme is becoming a victim of its own success.  There is now considerable pressure on the cars nearest Frankfurt Road (which are in Half Moon Lane and Kestrel Avenue).  The next nearest cars are more than a 10 minute walk away.  A 10-min walk is the outer limit in TfL policy.   So other local residents will be deterred from giving up their cars unless provision is increased.   So we need to increase provision sharply and see what happens.  If anything I would expect it to become possible to reduce rather than extend the existing CPZ.
9. The policy framework clearly prioritises car club measures over measures relating to private car parking.  Given that introduction of new CPZ controls in even one or two local streets would exacerbate parking problems in other streets, it makes sense to try providing a number of new car club bays first and monitor the effects.  There is no case for extending controls to any local street until this has been tried first.
10. A car club bay can be provided in streets without existing controls. 

Process

11. Under Southwark’s Constitution Part 3H para. 16 decisions on non-strategic parking restrictions are reserved to Community Councils, not to officers.  Given the small area involved, a decision on how to proceed in the light of this consultation cannot be considered strategic.  A binding decision should be taken by members of Dulwich CC. 
12. I would urge members to decline to introduce any new controls in any part of the area.  Instead Community Council should invite officers to return with proposals for an additional number of car club bays in the consultation area, with priority given to those streets where the consultation response reports the greatest pressure on parking.  The results should then be monitored for 6 to 12 months before any new proposals for CPZ controls are considered.
13. I could not find a link on the Southwark website to an electronic version of the consultation response form accompanying the proposals.  That is a matter of some concern.  I have e-mailed this document to parkingreview@southwark.gov.uk with a copy to the Village ward councillors.   I hope my views will be taken into account.

Gordon Nardell