Request for documentation relating to decisions made by LBE and/or Cycle Enfield officers and councillors concerning the Bury Street West/Church Street junction.

Response to this request is long overdue. By law, under all circumstances, Enfield Council should have responded by now (details). You can complain by requesting an internal review.

Dear Enfield Council,

These requests relate to the proposals for changes to the road layout shown in the consultation QUIETWAY 18 - SECTION A A105 TO SALMONS BROOK, GENERAL ARRANGEMENT
SHEET 1 OF 3 drawing no: Q18-2017-196-100-01(previously available online at the Cycle Enfield website).
After an FOI request to LBE the following facts emerged about this junction.

1 - A formal safety audit was not carried out regarding “safety critical” deliveries of LPG and the possibility of collisions on Church Street due to the altered geometry of the junction.
2 - No specific survey of delivery, waste collection or HGV movements was undertaken.
3 – However, swept path analysis was undertaken prior to the final design that was presented for consultation.
4- These swept path drawings released showed a range of large vehicles (LFB Pump, Refuse Vehicle and a Pantechnicon) using this junction.
5 - All left turns out of Bury Street West showed that these vehicles would track into the paths of vehicles traveling North on Church Street.
6 - The only left turn into Bury Street West was by an LFB Pump which had to track across two lanes of oncoming traffic, practically hitting the kerb opposite just to be able to enter the junction.
7 - Omitted from these swept path drawings were left turns into Bury Street West by Refuse Vehicles, Pantechnicons and articulated vehicles. My own research showed that a 50 foot articulated vehicle would have to cross two opposing lanes and mount the pavement opposite to achieve a left turn out of Bury Street West.

Will you please provide copies of all meeting notes, emails and/or other documentation relating to the decisions made by LBE and/or Cycle Enfield officers and councillors:

a) not to carry out a safety audit for the proposed redesigned junction;
b) not to carry out a survey of delivery, waste collection or HGV movements; and
c) not to use the evidence produced by their own swept path drawings but rather, instead, to produce designs that their analyses had demonstrated to be extremely dangerous.

If no documentation is available relating to this series of decisions will you please provide a narrative account of the meetings at which these decisions were taken along with a list of the parties present at those meetings and the persons responsible for these decisions.

Yours faithfully,

Richard Turner

complaintsandinformation, Enfield Council

Thank you for your email.

We will respond as soon as possible.

Regards,

Complaints and Access to Information Team,
Enfield Council.

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Stuart Miller, Enfield Council

Dear Mr Turner,

Thank you for your enquiry containing a Freedom of Information request on Quietway 18.

London Cycling Design Standards state that in the case of

'Tracking large vehicle movements
As part of the design process, swept path analysis should be used to track the paths of larger vehicles around corners (Manual for Streets, 6.3.13). It is usually acceptable for large vehicles to enter the opposing general traffic lane or adjacent with-flow lane in order to turn, provided there are no physical constraints to them doing so. There may need to be some local strengthening of the footway to allow for larger vehicles occasionally overrunning, although this is not generally desirable because of its impact on pedestrian safety and comfort. It is important not to design geometry solely based on occasional use by large vehicles, such as refuse or removal trucks. In all instances, the designer should take into account the individual site characteristics when choosing the appropriate corner radii. Provided drivers can make the turn within the overall road space available, it is rarely necessary to design so that they can do so while remaining entirely in a single nearside lane.
In most circumstances, the safety benefits to cyclists of tighter geometry and the slowing of motorised vehicle turning movements outweigh risks to cyclists that exist in relation to larger vehicles moving out to the centre of the carriageway or a different traffic lane to make a left turn.'

In this instance the guidance above was followed consequently we do not hold any of the documents you refer to below;

“all meeting notes, emails and/or other documentation relating to the decisions made by LBE and/or Cycle Enfield officers and councillors:

a) not to carry out a safety audit for the proposed redesigned junction;
b) not to carry out a survey of delivery, waste collection or HGV movements; and
c) not to use the evidence produced by their own swept path drawings but rather, instead, to produce designs that their analyses had demonstrated to be extremely dangerous.”

We also do not hold a documented narrative account as requested.

If you are dissatisfied with the handling of your request, you have the right to ask for an internal review. Internal review requests should be submitted within two months of the date of receipt of the response to your original letter and should be addressed to:

Complaints and Access to Information Team Email – [Enfield Council request email]

Please remember to quote the reference number above in any future communications.

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Yours sincerely,

Stuart Miller | Cycle Enfield Community Relations Officer | 020 8379 4758 | [email address]| Planning, Highways and Transportation | Environment Department | Enfield Council

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Dear Enfield Council,

Please pass this on to the person who conducts Freedom of Information reviews. (complaints and information)

I am writing to request an internal review of Enfield Council's handling of my FOI request 'Request for documentation relating to decisions made by LBE and/or Cycle Enfield officers and councillors concerning the Bury Street West/Church Street junction.'.

This complaint relates to Mr Miller’s response on 9th January 2018 to my FOI request made on 7th December 2017. In my request I asked for copies of the communications between officers and councillors that led to presentation of the drawing of the junction of Bury Street West and Church Street (Sheet 1 of 3 drawing no: Q18-2017-196-100-01 previously available online at the Cycle Enfield website) as part of the consultation QUIETWAY 18 - SECTION A A105 TO SALMONS BROOK.

I did not ask Mr Miller for his opinion on the design of this junction;
I did not ask for any justification of why this dangerous drawing was submitted for public approval.

Previous FOI requests had revealed that.
1. No safety Audit had been carried out on this junction.
2. No vehicle movement studies had been carried out.
3. The swept path analyses undertaken by LBE showed that a London Fire Brigade Pump and indeed any large vehicles turning left into Bury Street West from Church Street would have to track out into the two adjacent lanes of oncoming traffic. All other large vehicle tracking at some point traversed oncoming traffic.

In Mr Miller’s response on the 9th January 2018 Mr Miller failed to provide copies of the communications between officers and councillors that led to confirmation of the design taken out to consultation.

Instead, he sought to justify the dangers revealed by LBE’s swept path analysis through unsubstantiated assumptions.

Instead of providing the information requested Mr Miller cherry picked a few sentences from the London Cycling Design Standards document Chapter 5 which deals with junction design issues.(link below)
http://content.tfl.gov.uk/lcds-chapter5-...

To justify all the evidence that illustrates dangerous swept paths taken by large vehicles he quotes
“It is usually acceptable for large vehicles to enter the opposing general traffic lane or adjacent with-flow lane in order to turn, provided there are no physical constraints to them doing so.”
And
“It is important not to design geometry solely based on occasional use by large vehicles, such as refuse or removal trucks. In all instances, the designer should take into account the individual site characteristics when choosing the appropriate corner radii. Provided drivers can make the turn within the overall road space available, it is rarely necessary to design so that they can do so while remaining entirely in a single nearside lane.”

The standards from the London Cycling Design Standards document that Mr Miller clearly failed to recognise were;

“As with links, all user needs must be taken into account (see section 3.2), particularly the movement of emergency service vehicles and pedestrians.”

“It is important for any junction improvement to be based on a comprehensive understanding of the place and movement functions of the location. Sources of information on this include:
• Collision history, showing locations, severity of injury and details of the circumstances
• Area-wide analysis: relationship between the junction in question and cycling routes, location of public transport stops, information about bus routes, the strategic importance of the streets, kerbside activity, motor traffic speeds
• Traffic flow data (including cycling), broken down by time of day and by mode, and traffic modelling
• Pedestrian flows, including trip generators and variation by time of day – this should include where crossings currently exist and show pedestrian desire lines.”

Since no safety audits and traffic movement studies were carried out and in the absence of the requested record of any communications between officers and councillors there is no evidence of how LBE ascertained that the proposed changes to the junction were safe. It is therefore impossible for Mr Miller to substantiate his justification.

I therefore wish to make two complaints in regard to how my FOI request was treated:
1. Mr Miller failed to provide the requested information
2. Mr Miller made claims for the safety of the proposals that were not substantiated by any evidence.
3. Furthermore, that the statements that Mr Miller selected for use in his response were biased and did not include those sections of the guidance that should be taken into account at a busy junction.

My original questions to Mr Miller still stand and I would appreciate it if he could provide me with the information that I requested.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/r...

Yours faithfully,

Richard Turner

complaintsandinformation, Enfield Council

Classification: OFFICIAL
Dear Mr Turner

I apologise for the delay in responding to your Internal Review Request.

This response is in line with the requirements on the Freedom of Information Act 2000.

You have listed the three points below which you would like the review to focus on:

1. Mr Miller failed to provide the requested information
2. Mr Miller made claims for the safety of the proposals that were not substantiated by any evidence.
3. Furthermore, that the statements that Mr Miller selected for use in his response were biased and did not include those sections of the guidance that should be taken into account at a busy junction.

The Freedom of Information Act provides the legal framework for responding to requests for information that is recorded on council systems. It does not cover statements or opinions based on what is in someone's head. The purpose of this review is therefore to consider whether we responded to the questions that you asked regarding recorded information. As such, points 2 and 3 do not fall within this category. You may refer to the Information Commissioner's guidance via this link, especially the Dos and Don'ts when making requests: https://ico.org.uk/for-the-public/offici...

With regards to point 1 (Mr Miller failed to provide the requested information), please see below:

You originally made the following request:

"Will you please provide copies of all meeting notes, emails and/or other documentation relating to the decisions made by LBE and/or Cycle Enfield officers and councillors:

a) not to carry out a safety audit for the proposed redesigned junction;
b) not to carry out a survey of delivery, waste collection or HGV movements; and
c) not to use the evidence produced by their own swept path drawings but rather, instead, to produce designs that their analyses had demonstrated to be extremely dangerous."

Our updated response is below:

a) There are no meeting notes or correspondence regarding the decision not to carry out a safety audit. However, the council have subsequently made major changes to the design based on feedback from the consultation.

b) We did not carry out any of these surveys prior to the consultation. However, since receiving consultation feedback, we have carried out a turning movement survey at this junction (over 3 separate days) by an outside company.

c) This is based on your opinion i.e. extremely dangerous. The junction re-design was carried out to benefit pedestrians and cyclists firstly. Our swept path analysis showed that vehicles were able to navigate the junction and it was our aim to discourage large HGV vehicles from using this route.

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Regards

Complaints and Access to Information Manager
Complaints and Access to Information Team
Finance, Resources and Customer Services
Enfield Council
PO Box 50,
Civic Centre,
Silver Street, Enfield
EN1 3XA

Enfield Council is committed to serving the whole Borough fairly, delivering excellent services and building strong communities.

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