I've now worked out how this monstrous bus gate came to be created.
Enfield's Change of PlanOriginally, Enfield proposed a bus gate 20m south of where it is now. It was to be formed as a chicane using large planters. The southern planter is shown on
this plan. The northern planter isn't shown because its location has been covered by the revised bus gate. It would have been on the west side of the road, I surmise as far north as the southern area of block paving is.
After the original plan had been approved, Enfield appear to have realised or been told:
- it would cause mayhem because HGVs would no longer be able to access yards on the industrial estate as they had been doing. Instead, they would have to reverse large distances and round corners;
- Haringey wanted to have a new vehicular access into the Bull Lane playing fields which would be in the middle of the bus gate.
That led to revisions to the plan and a second round of consultations. The bus gate was moved north, to where it has been built. The planters were replaced with "carriageway build-outs" which were constructed of block-pavers with granite kerbs around them which were set "
flush with the carriageway". In other words, they weren't build-outs at all.
Why the "Build-outs Flush with the Carriageway"?This unusual (unprecedented?) form of "build-out" was necessitated by the requirement to allow HGVs to enter the yard at 22, Bull Lane (the southernmost commercial premises, which includes Demitris Motors). They do this by going beyond the entrance and then reversing in. In so doing, they make use of the full width of the carriageway. Any physical obstruction, such as build-outs, would prevent their entering the yard.
There wouldn't have been any problems for HGVs if the bus gate had been moved south and converted to build-outs on both sides of the road at the same point rather than a chicane. Such build-outs could have been put to the north of the existing vehicular cross-over and gates into the Bull Lane playing field. This vehicular access could have been widened to 6m without impinging on such a bus gate.
So the bus gate that is there now was an exercise in trying to say "yes" to Haringey's plans when they were a gleam in Haringey's eye. Enfield could have said "Sorry, it's just not possible. We've got to allow HGVs to use the yard at 22, Bull Lane. That means that any bus gate has to be at least 20m (preferably 25m) south of the entrance to the yard. We'll put the shortest bus gate we can south of that, which will leave you space to widen your existing vehicular access just north of the borough boundary from 3m to 6m."
But Enfield didn't. Instead, they built the bus gate we see today.
Approach to the Bus Gate from the NorthThe bus gate's defects are not just at the southern end of Bull Lane. They extend all the way from Bull Lane's junction with Wilbury Way/Bridport Road ¼ mile to the north. To the north of this, a segregated two-way cycle track has been created on the west side of Bull Lane. But to the south, there are no cycle lanes at all. Nor has the speed limit been reduced from 30 mph to 20 mph by creating a 20 mph zone. This would have enabled the council to install whatever traffic-calming measures it saw fit.
Instead, the council has used a single traffic order both to restrict the vehicles which can pass through the bus gate and to create the traffic-calming features around the bus gate. This means that the vehicle restrictions extend from the start of the traffic-calming features to their end. And from one edge of the highway to the other, i.e. across the footways as well as the carriageway.
Enfield appear not to have taken seriously the advice in the Traffic Signs Manual about the signage of bus gates or about how large signs need to be, especially those which contain words (e.g. map-type advance direction signs). There is a complete absence of signs warning of the bus gate ahead between the junction with Wilbury Way/Bridport Road and the bus gate, a distance of ¼ mile.
That is not normal. It offers scope to challenge PCNs by quoting
Coombes v DPP [2006] EWHC 3263 (Admin) and using the argument set out in paragraphs 4.22 - 4.31 of the
Chief Adjudicator's Review of TPT Decisions on John Dobson Street, Newcastle.
There's also the "hot potato" of the conduct of Enfield's second round of statutory consultation. This asserted that the revised bus gate had "carriageway build-outs" rather than planters. Any normal reader would interpret that as meaning that the chicane around the bus gate would now take the form of build-outs rather than planters. Yet these "build-outs" were actually areas of block paving flush with the carriageway. They did not narrow the carriageway or force vehicles to slow down. While this could be discovered by careful study of the drawing (which was available on the website), few, if any, of those consulted would have understood this.
The rest of this post presents this history. A further post will analyse the signage.
First Round of Statutory ConsultationOn 6 October 2021 Enfield went out to statutory consultation with
this letter. It followed an earlier
Community engagement letter which included a schematic map. This showed a bus gate at the southern end of Bull Lane but did not show the form which the bus gate took. It is not clear whether more detailed plans of the bus gate were sent to statutory consultees.
The schematic map also showed "modal filters" at the junctions between Bull Lane and Amersham Avenue and between Bull Lane and Shaftesbury Road. These restricted the vehicles which could pass through the filter to pedal cycles. Enfield stated that they would be signed using No Motor Vehicles rather than No Entry with "Except cycles" plates because the latter would prevent the emergency services from using them while No Motor Vehicles did not. Curiously, they don't seem to see any problem with the blue roundels which they have placed at the Bull Lane bus gate, which have exactly the same effect as No Entry signs with "Except buses and cycles" plates.
Second Round of Statutory ConsultationOn 9 November 2022 (i.e. more than one year later), Enfield went to a second round of statutory consultation.
This letter started by explaining that the project had been approved and that construction had started:
A statutory consultation on the draft traffic orders for this project was undertaken in late 2021, the project was granted approval in March 2022, and construction began in May 2022.
In other words, no significant changes had been required as a result of the first round of statutory consultation. Everything had been proceeding smoothly until something unspecified had forced a rethink. It continued:
We are now proposing changes to two aspects of the traffic orders which relate to:
- a modal filter at the junction of Shaftesbury Road with Bull Lane, and
- a bus gate at the southern end of Bull Lane.
. . .
All of the changes proposed can be seen on the drawings accompanying the draft traffic orders, which can be found in the document library section on the right-hand side of the project page: http://letstalk.enfield.gov.uk/nmh-ati.
. . .
The main changes, which do not affect the purpose of the previous proposals, are summarised below:
Bull Lane
- Relocation of the bus gate approximately 20 metres further north
- Change from planters at the bus gate to carriageway buildouts
Reading between the lines, I surmise that businesses on Shaftesbury Road and Bull Lane had realised the implications of Enfield's plans: HGVs which accessed industrial premises on the affected roads had been in the habit of making short reversing manoeuvres on entry to or exit from the premises. Enfield's plans would require them to reverse all the way back to the preceding junction. This would cause mayhem and possible gridlock.
Plans of the Bus GateThe
drawings of the bus gate which are available now are Metis Drawing No: 20148-MET-0010-02-DR-001 Revision C dated 30 September 2022. The revision history shows that it was first issued on 16 May 2022, so was not part of the first round of consultations.
But it does show what looks remarkably like a large planter on the east side of Bull Lane 13m north of the boundary with Haringey. I surmise that it was part of the original plan for the bus gate and that there was a second large planter on the west side of the road roughly as far north as the southern area of block paving is now.
If that was the location of the northern planter, its northern end would have been about 8m south of the entrance to the yard at 22, Bull Lane.
Reasons to Move the Bus Gate SouthRigid HGVs are up to 12m long. The reversing manoeuvre to get through a gateway requires an HGV to leave a full vehicle's length clear between the further gatepost and the rear of the vehicle before it starts reversing. I have shown the swept path in the section about Bull Lane on
this web page.
Enfield's original plan was therefore not compatible with the well-established use by HGVs of the yard at 22, Bull Lane.
While a change to the bus gate was therefore required, the obvious solution would have been to move it
south and convert it from a chicane to build-outs which narrowed the road on both sides at the same point. Bull Lane isn't wide enough to have a cycle gap on even one side, but such a bus gate could have been installed north of the vehicular cross-overs on both sides of Bull Lane just north of the boundary with Haringey. This can be seen (in orange) on the same aerial view as the swept path.
Bus Gate Moved NorthThe bus gate was not moved south. It was moved north. The drawing shows the "Indicative potential location of future Selby Urban Village Development access". It is where the northern planter would have been. Enfield has evidently responded to a request from Haringey to change its plans for the bus gate to accommodate a future vehicular access to the Bull Lane playing fields. Unlike the planter in Enfield's original proposals, the solution which I outlined in the preceding section of moving the bus gate south would not have interfered with the use of the proposed vehicular access, but it would have put it on the other side of the bus gate from Haringey.
Enfield evidently sought to accommodate Haringey's wishes. They moved the bus gate 20m north. This brought the bus gate right to the entrance to the yard of 22, Bull Lane. An aerial view of it is shown to the right of the aerial view with the swept path. The purple rectangle shows the land defined in the traffic order as subject to its restrictions. The traffic order permits goods vehicle manoeuvring to enter the yard to make use of the land subject to the traffic order.
Failure to Create a 20 mph ZoneThe reason why the traffic order covers the full extent of the "carriageway build-outs" is presumably because highway authorities need a traffic order to implement traffic-calming measures. But, as already observed, this is a curious traffic-calming measure which doesn't actually impede traffic (except cyclists, who prefer their road surface smooth).
It's also because Enfield haven't done the obvious thing for a designated cycle route which lacks any cycle lane, whether on or off the carriageway: create a 20 mph zone and apply traffic-calming measures. If they had done that, the "carriageway build-outs could have been authorised under the traffic order imposing the 20 mph zone and the bus gate order could have applied only where Enfield actually propose to enforce the restriction.
As it is, almost every vehicle entering or leaving the yard at 22, Bull Lane or the future entrance to the Selby Centre is legally liable to the Moving traffic penalty and relies on Enfield's forbearance (if that isn't a contradiction in terms) not to issue them with one.
When is a Build-out not a Build-out?By 30 September 2022 (the date of the drawings of the bus gate which are available today), Enfield's consultants, Metis, had evidently worked out that the only way to allow HGVs to access the yard was to remove any obstructions from the carriageway. The drawings still showed build-outs with kerbs, but the kerbs were marked as "flushed with carriageway level" and the areas of the build-outs were formed of "Grey Block Paving Herringbone ... built to Traffic Loading Standard".
In other words, the "build-outs" weren't build-outs: they were part of the carriageway.
While the drawings do indeed show the nature of these very unusual "build-outs", the attention to detail required to work this out would be beyond most people. The text of the letter for the second round of statutory consultation asserted that the revised bus gate had "carriageway build-outs" rather than planters. This term is sometimes used by other highway authorities to mean a build-out. The usage may refer to the fact that most build-outs are now constructed in the carriageway with either a gutter or a cycle gap between them and the footway. This avoids problems with road drainage which arise when a build-out interrupts the gutter.
DfT's Local Transport Notes about Traffic Calming and Bus Priority Measures define build outs as being kerbed structures at the level of the adjacent footway, as does The Highways (Traffic Calming) Regulations 1999. Build-outs narrow the carriageway. That was not the case here.
Construction and Start of EnforcementResidents and business owners were sent a
letter dated 23 June 2023 informing them that work would begin on 31 July 2023 to construct the bus gate and that it was expected to take 3 - 4 weeks.
A further
letter dated 22 August 2023 informed them that camera enforcement would begin on 29 August 2023.