Traffic Orders

Synopsis

The Harrow (Bus Priority) Traffic Order 2016, which supposedly underlies PCNs on Camrose Avenue, does not, in fact, restrict traffic using the nearside lane to buses, cycles and taxis. Instead the restrictions which it defines apply in each direction between the traffic island and the central median strip. This is because the Council made a mistake in 1999 when consolidating bus restrictions into a single traffic order. It has repeated this mistake in traffic orders ever since.

Harrow were alerted to the mistake in 2024 but denied that there was one. Their explanation is set out below. They have not sought to amend the traffic order to avert further challenges, just as they have maintained since 2007 that the signage complies with TSRGD and no changes are needed.

How the Mistake Arose

The Harrow (Prescribed Routes) (No. 2) Traffic Order 1976 was the first definitive traffic order for Camrose Avenue. It defined both the width restriction and the then bus-only restriction. The latter applied (italics added here and subsequently to highlight compass-points of traffic islands):

on the south-eastern side of the north-easternmost island site [and] on the north-west side of the south-westernmost island site

In 1999 Harrow consolidated the various individual traffic orders into two traffic orders, one for width restrictions and one for bus-priority restrictions.

The Harrow (Prescribed Route) (Width Restriction) Traffic Order 1999 defined "prohibited lengths" between "the eastern island" and "the southern kerb-line" and between the "western island" and the "northern kerb-line". All traffic was banned here unless permitted under another traffic order.

The Harrow (Bus Priority) Traffic Order 1999 defined the areas of road to which bus-restrictions applied as:

Westbound: the carriageway to the south of the southern traffic island immediately to the west of its junction with Dale Avenue;

Eastbound: the carriageway to the north of the northern traffic island immediately to the west of its junction with Dale Avenue.

Thus the 1999 consolidated orders transformed the north-eastern traffic island into "the eastern traffic island" in the width-restriction order but "the southern traffic island" in the bus-priority order. Likewise, the orders transformed the south-western traffic island into "the western traffic island" in the width-restriction order but "the northern traffic island" in the bus-priority order. The mistakes in the bus-priority order have been repeated in subsequent traffic orders up to and including the current ones.

Inspection of a plan of the site shows that the entire south-western traffic island (which splits eastbound traffic and is ringed in red) lies to the south of the entire north-eastern traffic island (which splits westbound traffic and is ringed in yellow):

There is only one possible interpretation of "southern traffic island" and it is what the 1976 traffic order referred to as "the south-westernmost island site". 

Harrow's explanation

Harrow's explanation for these compass points is that "southern traffic island" and "northern traffic island" are to be understood by reference to their appearance to motorists approaching them in the specified direction. Thus to westbound motorists, the "southern traffic island" is the traffic island nearest to the westbound nearside kerb, while to eastbound motorists the "northern traffic island" is the traffic island nearest to the eastbound nearside kerb.

There are some obvious problems with this:

• it is based on the perception when approaching the restrictions that there are two traffic islands ahead. It is true that there are two kerbed structures with bollards and signs on posts. But if there really were two traffic islands in each direction, there would be four traffic islands in total. There are not. There are three kerbed structures: two traffic islands and the snake-like structure which is formally known (and referred to as such in the width-restriction TMO) as the central median strip;

• the other uses of compass points in the bus-priority traffic order make sense with their normal (geographic) meaning;

• the uses of compass points in the width-restriction traffic order written at the same time (1999) make sense with their normal meaning.

Traffic orders are formal legal documents written using a formal register. They define things precisely and use the correct legal terms. This is shown in the use by the contemporaneous width-restriction traffic order of the term "central median strip". If the words “northern“ and “southern” were being used with meanings other than the natural ones, this would be stated explicitly.

Consequences

It follows that the bus-priority traffic order does not specify the restriction which Harrow intended. That this should be so is consistent with other aspects of the scheme, such as the signage, which has been ineffective for 50 years in guiding vehicles away from the inside lane. Until 2006 this was merely a nuisance to residents; thereafter it made Camrose Avenue the most lucrative site in Harrow for PCNs. 

The traffic orders are local legislation. They define the restrictions which apply. The signage is placed to show the effect of the traffic orders. The presence of signage purportedly restricting the inside lanes between the traffic islands and the footway to buses, cycles and taxis does not create such a restriction. Nor does the placing of signage assist the courts in interpreting what the traffic order means. 

While courts adopt a purposive approach to the interpretation of legislation, the purpose of the traffic orders on Camrose Avenue is not to give priority to buses. As a council report in 2005 noted, it was to stop HGVs using Camrose Avenue. It was to achieve this by combining a width restriction with a short bypass for buses with a bus-operated gate. The scheme failed because the gates were not used. Far from being a bus-priority scheme, buses have to give way to traffic emerging from the width restriction.

Since 2015, neighboring Hillingdon has been using CCTV to enforce HGV restrictions without physical infrastructure. Buses would run more reliably on Camrose Avenue if they were not caught up in queues for the width restriction. 

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Written 28th October 2025; last updated 1st November 2025