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:
- Residents wishes in the 13 affected roads, which it carried out itself; and
- 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:-
- 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.
- 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.
- 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.
- 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.
- For all these reasons it is recommended that a CPZ is not required in any of the roads within the current consultation area.
- 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
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- Several residents have since complained publicly about this unsuitable timing and how they were disenfranchised as a result.
KEY ISSUES FOR CONSIDERATION
- 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.
- 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.
- 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.
- 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?
- 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.
- only 8% of all residents said YES to a CPZ in their road
- whilst 18% of all residents said NO to a CPZ
- in other words 237% times as many residents said NO as said YES
- only 25% of Holmdene residents are in favour of CPZ whilst 75% are happy with the current arrangements
- 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
- 71% of all roads said NO to a CPZ
- 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.
- 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.
- Red Post Hill and Half Moon Lane, who also had majorities in favour, have been rejected on the same grounds
- 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
- 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.
- 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.
- 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.
- 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.
- 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.
- Consequently it is recommended that a CPZ is not required for any of the roads within the current consultation area.
- 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:
- How many parking spaces are actually available per house/household in each street? and
- How often do they run out of unused unrestricted parking spaces?
At the back of the Southwark information pack
http://moderngov.
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 |
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
- parking by non residents; some non residents parking for days/weeks on end
- being unable to find a space and thus resorting to parking in nearby Elfindale or Beckwith
- being unable to find a space whilst neighbouring streets are allegedly empty
- safety issues for mothers with children from speeding cars
- 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.