Third time lucky with this anti-car agenda?

Dear Mr Gellard

Thank you for your email reply dated 2/12/09.

I read in this email that the "Council does support the implementation of CPZs". Since only the Council has the powers to propose and create new CPZs, the clear implication of this statement is that Council officers are actively searching for new areas where they can implement CPZ schemes.

Such an activist policy may explain why North Dulwich residents finds themselves once again being targeted for controlled parking. Council officers tried to impose a CPZ on North Dulwich residents in 2002 and 2005. On both occasions the local residents decided overwhelmingly to reject the CPZ proposals.

So why are you so determined to impose a CPZ on the area? Do the Council officers believe that in 2002 and 2005 the consulted residents failed to understand the "direct and indirect benefits to the community" of a CPZ? Does the Council think that it knows best?

I would suggest that the real motivation behind this determined, "third time lucky", approach to re-introducing the North Dulwich CPZ proposal is twofold:

Firstly, CPZs allow Southwark officials to raise more revenue, expand their influence and justify departments and jobs. On a basic level those Council officers currently engaged to "support the implementation of CPZs" must find suitable areas to implement CPZs in order to protect their own jobs.

Secondly, Southwark Council has adopted an anti-car agenda. The CPZ proposal is a devious means to increase the cost of car ownership and to reduce the total amount of parking capacity available in the Borough. Within any CPZ area a percentage of the roads will be painted with yellow lines. This serves to drastically reduce the number of parking spaces available for the majority of most days.

Whatever the true motivation, Southwark seems determined have a another go at getting the CPZ proposal past local residents. But this time round the Council seems to have decided to boost its chances of success by promoting its proposals, whilst limiting and restricting the consultation process. As a result, I believe the current consultation is so compromised and so flawed that one might consider the process "rigged".

This is not a suggestion that I make lightly. It is based upon the following criticisms of the current consultation process:

1. Lack of information. We are being asked to comment on a CPZ proposal without being given any details of the actual scheme. This is a deliberate attempt to try to get some kind of tacit approval for controlled parking in general without having to reveal any specifics. I suspect this is because, in the past consultations, when residents have been able to consider the actual details of how a CPZ would affected them and their families they have been put off and voted against.

2. Lack of time. The consultation process is clearly too short. There was less than three weeks from when I received the consultation notice on the 23th November 2009 until consultation closing date on the 11th December 2009. Such a short consultation period restricts the ability of residents to get fully informed or to consider and consult with their neighbours about this major proposal.

3. Lack of rationale. No real facts or evidence are provided to justify again resurrecting this previously rejected CPZ proposal. The Council asserts that CPZs imposed on neighbouring areas are causing / will cause parking to become scarcer in our area. This is pure conjecture. No evidence of this "displacement effect" is given. Furthermore, this alarmist rationale is completely self-serving. Southwark's twisted logic means that the more CPZs they create, the more additional CPZs will be required. Why instead can't the Council consider the real logical response which would be to look into scaling back or abolishing some of the existing neighbouring CPZs.

4. Overwhelming bias. The consultation document makes no attempt at impartiality. The disadvantages of CPZs are not mentioned (apart from the mandatory information that parking permits will have a cost and a box showing -current - permit prices). In contract, the document takes every opportunity to praise the "benefits" of CPZs. It even devotes a specially highlighted page to summarise in bullet points the "benefits of a CPZ for the community". How can a document that is so overtly pro-CPZ form the basis of a fair consultation process?

5. Misleading questionnaire. This error in question 6 means that anti-CPZ respondents are instructed to skip over a highly relevant question. This is likely to cause bias in the results. It is unacceptable to dismiss the errors on the questionnaire as merely "an oversight when proofing" and then to assert that these errors have caused "little or no misunderstanding". The questionnaire is only eight questions long! How can any proof reader fail to spot two nonsensical questions out of eight? And how can your partial department be trusted to judge the impact and significance of your own errors?

6. Little transparency. It is unclear on what basis the Council will derive conclusions from the consultation process. There is also no information about how the consultation result will be incorporated into the decision making process.

Based on this, I consider the current consultation process to be grossly unfair and biased. I ask you to consider these six criticisms and restart the consultation process on a more open, honest and impartial basis. If your department is not prepared to do this then I ask that our local Councilors intervene and protect the legal right of residents to be fully and fairly consulted again about this CPZ proposal.

If a full and fair consultation reveals strong popular support for the introduction of a CPZ, then so be it. However, until we have been properly consulted this proposal should not be allowed to progress.

Yours sincerely

Martin Bayntun
Elmwood Road