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Local authority consultation needs to follow legal guidelines known as the Gunning Principles described in detail at https://www.local.gov.uk/publications/new-conversations-20-lga-guide-engagement otherwise they may lay themselves open to judicial review proceedings. The Gunning Principles state: 1. Proposals must still be at a formative stage 2. There is sufficient information to give ‘intelligent consideration. The information provided must relate to the consultation and must be available, accessible, and easily interpretable for consultees to provide an informed response 3. There is adequate time for consideration and response 4. Conscientious consideration must be given to the consultation responses before a decision is made. Decision-makers should be able to provide evidence that they took consultation responses into account. The consultative basis for turning the whole borough into a CPZ seems pretty thin from what people are describing. Has any group been asked outright what they think of having the whole borough as a CPZ? It is also worrying there has been no integrated impact assessment of the policy which affects most people in the borough, driver or not and may hit vulnerable groups hard. The Gunning Principles.docx

We have the identical problem in Nunhead and Queens Road as we have been presented with the fait accompli of a blanket CPZ in Nunhead and Queens Road Ward and a section of Peckham Rye ward. Same forced choice of the parking controls we would 'like' to see which make no sense as there is not a parking problem to solve in much of the area. CPZs are intended to be useful tools to manage traffic flow, parking congestion and commuter parking which is an inconvenience to residents. There is no evidence that they lead to cleaner air - most of the cars are parked most of the time. It is wrong to impose them for areas relatively far from town centres, with poorer public transport access. This can only be understood as a greenwashed revenue raising venture. CPZs are meant to be self-financing and not profit making enterprises hence it is hard to understand where the money will come from for all the new street goodies being promised. The southern area of Southwark is mainly residential so all car owners (between 56% and 73% of households in the area) will be paying, for example, £225 p.a for a ULEZ compliant car. Less for electric, more for old diesel, plus of course the cost to visitors. Visit https://opposethecpz.org/ to see what is happening in the NQR area.

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