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.

the Original Traffic Orders

The restrictions on Camrose Avenue were created under The Harrow (Prescribed Routes) (No. 1) Experimental Traffic Order 1974. This was made by the Greater London Council on 3 December 1974. In the public notice its stated purpose was

to prohibit vehicles the overall width of which together with the load (if any) carried thereon exceeds 6 feet 6 inches from using Camrose Avenue as a through route. 

This was to be achieved by 

the construction of three island sites in Camrose Avenue immediately south-west of Dale Avenue. Vehicles less than 6 feet 6 inches in width will be permitted either side of the central island site. The nearside lane (on both sides of the road) will be reserved for buses and vehicles being used for fire brigade, ambulance or police purposes

The bus restrictions applied (italics added here and subsequently to highlight compass-points of the island sites):

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

The order was to come into force on 16 December 1974 and, under the legislation for Experimental Traffic Orders, would remain in force for 18 months. 

On 7 June 1976 the Greater London Council made The Harrow (Prescribed Routes) (No. 2) Traffic Order 1976. This continued in force indefinitely the provisions of the Experimental Traffic Order.

How the Mistake Arose

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 the public notice for the original traffic order stated, its purpose is

to prohibit vehicles the overall width of which together with the load (if any) carried thereon exceeds 6 feet 6 inches from using Camrose Avenue as a through route

With the technology available in 1974, that purpose was to be achieved by combining a physical width restriction of 6'6" 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, neighbouring Hillingdon has been using CCTV to enforce HGV restrictions without physical infrastructure. A width restriction can now be imposed by putting up a sign to that effect and using CCTV with ANPR and DVLA data to look up the vehicle's width and issue a PCN if it is too great. 

CCTV with ANPR and DVLA data are already used to issue PCNs on Camrose Avenue. A purposive approach to the traffic order could support the interpretation that it prohibits vehicles other than buses and the emergency services from using the road if they are more than 2.0m wide. It does not support the interpretation that vehicles less than 2.0m wide should be subject to penalties for using a nearside lane which the traffic order does not specify is prohibited to such vehicles.

Up Westbound Eastbound Dale Ave

Written 28th October 2025; last updated 15th February 2026