Dear Cllr Pascall,
Draft Third Local Implementation Plan – Response to Consultation
The Milner Street Area Residents’ Association (“MISARA”) hereby requests the removal of the “Sloane Street – Public Realm Improvements” scheme from RBK&C’s draft Third Local Implementation Plan (LIP) which was circulated by the Council for consultation on 22 November 2018. The main purpose of the LIP is to describe how RBK&C proposes to deliver the Mayor of London’s Transport Strategy, as well as contributing to its own transport objectives.
MISARA is the largest Residents’ Association in Chelsea, with more than 230 subscribing member households. Our eastern boundary, Clabon Mews, is a few minutes’ walk from the southern and central sections of Sloane Street.
MISARA’s Opposition to the Scheme
On 7 July 2016 we circulated the Council’s consultation paper on the Sloane Street scheme (described as a “newsletter”) to all our members and asked them for their views. We put the question in a neutral and unbiased manner, without seeking to lead them to any conclusion. The response from our members was strong and overwhelming opposition. Not a single member of MISARA expressed support for the scheme.
On 20 July 2016 we responded in detail to the Council. Our response can be read here:
And on 23 February 2017 we responded in detail to the Council’s second consultation:
Failure to support the Mayor’s Transport Strategy outcomes
The Council has grouped the Mayor’s desired Transport Strategy outcomes under three broad headings:
1. Healthy streets and healthy people, including traffic reduction strategies.
2. A good public transport experience.
3. New homes and jobs.
Taking the second heading first, one of the most remarkable aspects of the Council’s first consultation was that it did not seek to address what most people consider to be the main problem of Sloane Street, viz. the high level of congestion at the north end of the street. There are five main bus routes in the street, and it is bus passengers who are most badly (and unavoidably) affected by the congestion. Amazing to relate, the Council’s consultation paper did not even mention the word “bus”. The proposed narrowing of the carriageway can only make what is currently a bad public transport experience even worse.
As to the first heading, the increased level of congestion would result in increased pollution, particularly from buses struggling to get through – the opposite of a more “healthy street”.
As to the third heading, we do not see that the scheme will assist in creating any new homes or jobs.
In conclusion, therefore, the scheme does not support the desired outcomes of the Mayor’s Transport Strategy but runs counter to them.
Failure to support RBK&C’s own Transport Objectives
The Council has listed six “Borough Transport Objectives”:
1. Encourage more trips by walking, cycling, and public transport and fewer by private car.
2. Make our streets safer, secure and with fewer road collision casualties.
3. Make our streets cleaner and greener with less transport-related pollution.
4. Improve accessibility and journey time reliability on public transport.
5. Manage on-street parking and loading to make our streets more efficient.
6. Improve the appearance of our streets and ensure that they are well maintained.
The Sloane Street scheme would not improve bus services but would increase journey times and reduce reliability, contrary to objective (4). It would not encourage more trips by public transport but the opposite, contrary to objective (1). It would increase transport related pollution, contrary to objective (3) – and it should be recognised that the street could hardly be “greener” than it is already. Decluttering and repairing the fine York stone paving would certainly contribute to objective (6), though the construction of large flower beds with concrete seating (as depicted in the Council’s consultation materials) would crimp the space available to pedestrians and seriously detract from the dignified appearance of the street and the long straight green vistas we currently enjoy. We do not see that the scheme will significantly promote either objective (2) or objective (5).
In conclusion, the scheme does not support RBK&C’s own Transport Objectives but runs counter to them.
Widespread Opposition to the Scheme from Residents
In October 2016 the Council informed us that the comment cards sent in at the exhibition during the response to the first consultation showed that 65 individuals categorised as “businesses/workers” expressed support for the scheme, but only 13 “residents” did so. Given that the scheme was originated and has been heavily promoted by the Cadogan Estate, and that it was barely publicised amongst residents by the Council at this stage, the preponderance of support from business interests is perhaps not unexpected. It is significant that the two largest residents’ groups adjacent to Sloane Street – the Brompton Association and the Belgravia Residents’ Association – were not notified of the first consultation. The third largest group (MISARA) was only notified at a very late stage – eight days before the opening of the exhibition.
The report written by the Council in March 2017 explaining the results of the second consultation (“Sloane Street: Analysis of Stakeholder Consultation”) noted that individual respondents to the questionnaire had expressed the following main themes:
Against the proposals or widening of pavement/narrowing of road 137
Traffic congestion is a problem/will increase 134
In favour of scheme or one of the options 123
And in 31 emails and letters received from individuals and organisations (such as MISARA), the following were the main themes:
Against the proposals or widening of pavement/narrowing of road 16
Traffic congestion is a problem/will increase 13
Traffic control (road layout, traffic lights etc.)/pedestrian crossings 11
In favour of scheme or one of the options 8
These figures do not support the Council’s assertion that the scheme enjoys a level of support sufficient to warrant going ahead with its implementation (based on “maximum pavement widening”!) – if anything, the opposite. An interesting fact discovered by MISARA, but not mentioned in the Council’s report, is that the emails and letters (which we have read) showed opposition to the scheme by 19-7. The report claims that “these can be seen in full in appendix three”, but despite our requests this appendix has never been put on the Council’s website. Even today, after 22 months, if you go to the “Sloane Street Consultation Results” page on the website, you will find the Council’s report but not this highly revealing appendix.
Readers of the report would never imagine that opposition to some or all aspects of the scheme – in particular, the proposed widening of the pavements and narrowing of the carriageway – has been expressed not only by MISARA but also by the Brompton Association, the Belgravia Residents’ Association, the Knightsbridge Association and the Chelsea Society.
The consultation results cannot be relied upon
One of the most distressing aspects of the whole business, as we explained in detail in our letter of 23 February 2017, is that the Council’s consultation materials were so one sided, and the questions so loaded, that they could not possibly be used to derive an objective assessment of people’s views – they were clearly designed as a manipulative exercise to justify what the Council wanted in the first place. In fact it was a textbook example of a bogus consultation and nothing short of a disgrace.
The scheme has a bad smell to it, of manipulation and mendacity. It is based on a false claim – that the pavements in Sloane Street are “too narrow”. The cynicism of the claim is reinforced by the insertion of large municipal flower beds which would have the effect of reducing, not increasing, the amount of navigable pavement space available to pedestrians. The latest example of manipulation in an attempt to justify the scheme can be seen in the Council’s draft Hans Town Conservation Area Appraisal of October 2018, intended to replace the existing Hans Town Conservation Area Proposals Statement. This existing document states:
“Sloane Street branches off southwards from Knightsbridge in a long uninterrupted vista line towards Sloane Square. The most characteristic visual element of the street is the long expanse of the mature gardens of Cadogan Place on its east side. In addition, the sense of openness of the street is established by the generous pavement and road widths. Sympathetic tree planting is effective in nullifying the overpowering effect of the imposing buildings which line the thoroughfare and help minimise the disruptive effect of the incessant through traffic.”
In our response of 11 December 2018 to the consultation on this draft Appraisal, we wrote: “In the draft Appraisal we see to our surprise that the section on Sloane Street has been reduced to a handful of paragraphs, that all references to long green vistas and generous pavement widths have been removed…. We have to ask this question: has this tampering with the evidence base been made so as to facilitate approval of the Cadogan Estate’s unwelcome scheme to widen the pavements in the street, based on the ludicrous assertion that the pavements are not of “generous width” but “too narrow”? It is hard to avoid any other conclusion.”
Council officers seem to take satisfaction from the Cadogan Estate’s willingness to pay for the entire cost of the scheme – the draft LIP gives a figure of £18 million, about three times the total amount of Borough funding for all “LIP delivery” projects over the three year period (£6.1 million). But this should set alarm bells ringing. The Cadogan Estate is not a charity, its commercial objectives are not those of residents, and the fact that it is willing to pay for the scheme does not turn a bad project into a good one. We do not blame Cadogan for pursuing their own objectives - that is their job – but we do blame the Council, strongly, for having adopted Cadogan’s scheme and rebranding it as a scheme to “improve the public realm” whereas it would, in fact, disfigure it.
The process adopted by the Council to date bears a disturbing resemblance to its efforts to implement, ten years ago, an equally unwelcome scheme to turn Sloane Square into a crossroads. In that case, the effort started with the same claim that the square was “looking tired” (as with Sloane Street), ironically the result of the Council’s failure to maintain the paving in good order (as with Sloane Street); there were then two bogus consultations which purported to show that residents supported the scheme (as with Sloane Street); but the third and final consultation, conducted (for once) by an independent firm, showed opposition to the scheme by 72% to 28%. We believe that if the Sloane Street scheme were likewise to be made the subject of an independent consultation, it would show that residents do not support it.
There are a number of steps which could be taken to improve Sloane Street and which would command general support, as we have pointed out in our earlier letters. These include: decluttering; planting additional trees in the few spaces available where this could be done; repairing and reinstating the fine York stone paving where this has been neglected; and working with TfL to mitigate the congestion at the north end of the street. The Council can do all of these things independently without imposing the Cadogan Estate’s scheme. If Cadogan were still of a mind to be generous, we suggest that they be asked to contribute to the cost of restoring the York stone paving, as their shops and other properties in the street would clearly benefit from a restoration programme.
Councillors should not deceive themselves into thinking that Cadogan’s scheme enjoys the support of residents. We are impressed that our councillors, in the wake of the Grenfell tragedy, have been at pains to emphasise a new approach whereby, instead of assuming that they know what is good for us better than we do, they will listen to residents. Their response to our request will be a test case of their new resolve.
The opportunity is at hand. The Sloane Street scheme does not support the Mayor’s Transport Objectives or the Council’s own Borough Objectives. The scheme should be removed from the Local Implementation Plan and consigned to history.
Lord Grantley (8 Halsey Street, London SW3 2QH)
Chairman, Milner Street Area Residents’ Association