A Formal Objection to the SBLN

On grounds of serious legal, procedural and substantive failings

I try not to overload subscribers with too many posts, but this week may just be an exception. There are a lot of reality checks going on in BCC’s dystopian ‘liveable neighbourhood’ fantasy world at the moment.

The following is a guest post from Kelly, who lives in the proposed SBLN area and has written an open letter on the subject. ‘This is gold’, is how a fellow KBM campaigner describes it.

Please read.

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Southville resident voices concern over proposed transport changes, highlighting that her once-quiet road will see increased through traffic and her daily commute will lengthen. She emphasises that schemes must be inclusive and accessible, stating, “I don’t agree with ableist designs that fail to consider everyone’s needs.”

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Dear All,

I write in formal objection to the proposed South Bristol Liveable Neighbourhood (“SBLN”) scheme, on grounds of serious legal, procedural and substantive failings. Based on the evidence so far, the scheme is unnecessary, unsupported by robust data, likely to cause harmful unintended consequences, and poses a high risk of legal challenge.

1. Inadequate justification and absence of data

• The SBLN documentation presents a vision of safer, greener streets, yet offers no published local traffic modelling or quantified assessment of how many vehicles will be displaced, where they will be diverted, or what the journey-time impacts will be for residents.

• On parking, no detailed street-by-street analysis has been published showing the number of on-street bays to be removed, nor how the council proposes to accommodate the displaced vehicles or mitigate increased demand.

• The area already suffers from a high density of vehicles: adult children living at home due to unaffordable housing, rising cost of living, and high numbers of HMOs (approved by the Council) all contribute to increased parking demand. Yet the scheme appears blind to this context.

• The scheme’s conceptual basis seems derived from benchmarks or data from other cities (notably London) whose built environment and transport networks differ materially from Southville/Bedminster. Without local adaptation this is poor policy design.

Given these points, the scheme lacks the factual basis required before preparing an Equality Impact Assessment (“EqIA”) or making any decision. Implementation without such evidence risks being irrational and procedurally f lawed.

2. Procedural and consultation deficits

• The consultation materials contain maps which residents report to be inaccurate or misleading, giving a false impression of current traffic flows. This undermines the ability of consultees to provide meaningful responses. As an example, the maps at all in person consultation events had Morley Road as not having 2 access points onto Merrywood Road and only one, this at a critical point where it intersects with a school, it is false, misleading and fails legal principles.

• Language used in the survey and materials (e.g., “modal filters”) is opaque, and many residents report misunderstanding the nature and effect of the proposed changes. This is inconsistent with the Gunning/Moseley consultation principles requiring intelligible and accessible materials.

• The submission of more than 2,000 petition signatures (far higher than typical participation levels) suggests significant public interest. Yet there is no clear evidence that this level of representation has been meaningfully incorporated into decision-making. Are residents’ democratic rights being ignored?

• Documentation shows the EBLN trial (already implemented) has generated strong opposition, protest actions and feelings of division in the community. It appears the Council is repeating the same pattern in Southville without learning from those real-world outcomes.

Alternative, less intrusive options exist and should have been explored first. Notably, the Greater Manchester Combined Authority has trialled reduced zebra crossing infrastructure that is significantly cheaper to install than many engineered junction changes and does not remove parking or re-route traffic across neighbouring streets, notably at 95% less cost than some of the suggestions in this consultation. This type of proven, lower-cost pedestrian priority solution — and active engagement with GMCA and national government to enable broader deployment — would better deliver safety benefits without the heavy social, economic and equality costs of wholesale road closures. The Council should prioritise piloting such zebra crossing solutions and pursue regulatory change where necessary, rather than defaulting to closures and modal filters that remove parking and increase detours.

3. Social impact, crime and community cohesion concerns

• In the EBLN area residents report increased stress, anxiety, and community division — one article noted “even someone … is literally taking anti-depressants because of the road closures…”

• Moreover, crime and enforcement issues have been reported. For example, an EBLN rollout required a significant police presence and generated protest activity; these are real social costs that the Council appears prepared to replicate in Southville.

• The SBLN plan risks replicating these outcomes: by forcing certain streets to become through-routes and reducing parking near homes, the scheme may fuel neighbourhood tensions (“street vs street”), exacerbate fear of crime (especially for women walking further), and undermine community cohesion rather than improve it.

• An alternative model exists: large ‘event-parking’ schemes (such as those operated around Twickenham stadium), which activate only during major events and do not impose daily burdens on residents. This proves that targeted, conditional traffic management is viable and far less disruptive.

4. Equality and protected group impacts

The Equality Impact Assessment (EqIA) produced by the Council is superficial and fails to meet the statutory requirements under section 149 of the Equality Act 2010. The Council must show due regard to how this scheme will affect those with protected characteristics — including age, disability, gender, pregnancy, and socio economic status. The assessment fails to do so in both scope and depth.

• Women’s safety has not been properly considered. The removal of on-street parking spaces, increased walking distances from vehicles to homes, and poorer night-time visibility directly increase vulnerability to street harassment, assault, and violence — particularly in South Bristol, where recorded incidents of violence against women and girls have risen sharply in recent years. The Council’s own policy commitments to the Bristol Women’s Safety Charter are contradicted by a scheme that makes women walk further, often in low-lit or isolated conditions, to access their own homes. The EqIA fails to acknowledge or mitigate this.

• Disabled residents are significantly disadvantaged. Reduced parking capacity means blue badge holders and those with mobility issues will struggle to park near their homes or support networks. The proposals do not include enough designated accessible bays, nor any commitment to prioritise these before the scheme’s rollout. Expecting residents to take circuitous detours or park hundreds of metres away breaches the Council’s duties under both the Equality Act and the Human Rights Act (right to dignity and safe access).

• Older people face exclusion and isolation. Many rely on visitors, carers, and family members arriving by car. The removal of parking, coupled with extended restrictions, will make it harder for carers to attend and for older residents to maintain social contact — an established factor in mental and physical wellbeing.

• Low-income households and those in socio-economically deprived groups are disproportionately affected. The increasing cost of residents’ parking permits, Clean Air Zone compliance, and general cost of-living pressures compound one another. This is particularly acute in multi-adult households where adult children remain at home due to the housing crisis, often with multiple working residents sharing a single vehicle. Penalising these households with additional charges or reduced parking provision is inherently regressive.

• Ethnic minority residents and those for whom English is not a first language are also disadvantaged by the consultation process itself. The survey materials use complex, technical language (“modal filters”, “connector roads”, “greening”) that are not easily interpretable. This restricts meaningful participation and fails to satisfy the PSED requirement to advance equality of opportunity by ensuring information is clear and accessible.

The EqIA provided makes no reference to these nuanced or intersectional impacts. It contains no quantitative or qualitative data, no mitigation plan, and no monitoring or evaluation mechanism. It amounts to a procedural tick box exercise rather than a live, evidence-led equality assessment.

This omission is not a mere oversight — it is a legal failing. Under the Equality Act, the Council’s duty is ongoing, active, and must be demonstrable through recorded reasoning before decisions are made. The absence of meaningful analysis or mitigation means the decision, if taken, would be unlawful and open to judicial review.

5. Scheme disproportionate, divisive and risk-laden

• The segmentation design means that residents may need to drive long detours (sometimes over a mile) just to check for parking on adjacent streets. This is inequitable, increases fuel and time costs, and is inconsistent with air-quality, accessibility and convenience objectives.

• The scheme is creating division within the community: competing street-level interests (“my street vs your street”) rather than shared neighbourhood benefit. Councils should foster community, yet this plan risks polarising it.

• Without robust baseline data (e.g., air-quality monitors on Coronation Road), the measures cannot claim to improve environmental outcomes and may in practice worsen them via increased journey times and congestion.

6. Legal risk

There is a real risk of judicial review on grounds of:

• Failure to have proper evidence (irrationality)

• Failure to comply with the Public Sector Equality Duty

• Unlawful consultation (Gunning/Moseley)

• Breach of the Network Management Duty (Traffic Management Act 2004) if traffic displacement is significant and unmitigated

Accordingly I request that Bristol City Council immediately pause progression of the SBLN scheme, publish all relevant data (traffic modelling, parking bay impact table, petition results, raw consultation data) and commission a full independent review of the scheme’s design, equalities impacts and community acceptance.

Conclusion

The SBLN scheme in its current form is not needed, lacks evidential support, is procedurally flawed and risks harming the very community it claims to serve. It demands major review, not incremental implementation. I trust the Council will recognise the scale of the concerns and act accordingly to avoid significant social, legal and reputational damage.