Consultation on the Revision of the Department for Transport S Speed Limit Circular

Consultation on the revision of the Department for Transport’s speed limit circular Response by Brake, the road safety charity 1 October 2012

About Brake Brake is an independent charity working across the UK to make roads safer, prevent road death and injury, and care for road crash victims. Brake carries out research into road users’ attitudes on road safety, engages schools and communities to spread road safety education, disseminates research to professionals, and supports communities campaigning for road safety. It is also a national, government- funded provider of specialist support for people bereaved and seriously injured in road crashes, running a national helpline and providing information packs that are handed to bereaved families by police following every road death.

Summary There is a vital need to make roads safer for vulnerable road users, to prevent needless and devastating casualties, and the human suffering and economic costs these entail, and to enable more people to walk and cycle. Lowering and managing traffic speeds is fundamental to this.

Brake is desperately concerned about the increase in deaths and serious injuries among people on foot and bike in 20111. Each of these casualties causes profound pain and suffering – which Brake bears witness to through its support services – and each costs society dearly. Brake is also aware, through its own and others’ studies of public attitudes and behaviour, that the threat of injury from traffic – the danger itself – poses a major problem by preventing many children, families and adults from walking and cycling. In this way, fast traffic throws up a barrier in increasing levels of walking and cycling, which is a stated aim of the government and critical in improving public health and reducing congestion, pollution and oil dependency.

Lowering traffic speeds on any road is evidenced to reduce road casualties in frequency and severity2, and particularly to reduce the risks for people on foot and bicycle. Specifically, introducing 20mph limits in communities has been shown to result in fewer casualties, increased walking and cycling, and a positive response from residents3. For these reasons Brake strongly advocates lower speed limits. We believe 20mph is a more appropriate default for roads in built-up areas, and limits of 50mph and below are more appropriate on rural roads. However, while our default limits remain as they are, we believe local authorities should be given greater flexibility, support and leadership on the implementation of lower limits locally.

Brake therefore warmly welcomes this consultation, because circular 1/06 has long thrown up barriers in local authorities implementing lower speed limits, and we support the Department for Transport’s intention to make it easier for local authorities and communities to put in place lower limits through the revised guidance. However, Brake is concerned that the proposed guidance fails to satisfactorily achieve this aim. It continues to present barriers to authorities choosing to implement lower limits similar to those contained in circular 1/06 that have hindered local authority action in the past.

1 Reported road casualties Great Britain: main results 2011, Department for Transport, 2012

2 The effects of drivers’ speed on the frequency of road accidents, Transport Research Laboratory, 2000

3 20mph speed reduction initiative, Scottish Executive Central Research Unit , 2001; 20mph Speed Limit Pilots Evaluation Report, Warrington Borough Council, 2010

1 To achieve increased flexibility for local authorities to lower limits, the DfT should remove or reword qualifying statements and restrictive conditions contained in the guidance, such as specifying 20mph limits should be implemented only on roads where mean speeds are already at or below 24mph or where there are pre-existing high levels of walking and cycling. These conditions are not in keeping with the DfT’s aims of allowing local authorities to be responsive to local needs and act according to what will deliver maximum benefits for the community, since they place overarching, arbitrary and unhelpful restrictions on authorities’ actions. They also encourage stasis, rather than progress, in road safety, by encouraging local authorities to base their decisions on the status quo, rather than what can be achieved. Brake warns these elements of the redrafted guidance may also undermine and devalue the assessment tool the DfT is developing.

Brake recommends the guidance should take a more flexible and progressive stance, by asking local authorities to consider 20mph across all built-up roads and lower limits across all rural roads, as part of a wider approach to preventing casualties and encouraging sustainable travel and healthy living. Instead of giving criteria for roads suitable for 20mph limits, Brake suggests it would be more helpful to local authorities, and better for road safety, to give criteria for roads that may retain a higher limit as through routes. This approach would give local authorities the flexibility they need, and which the DfT wishes to provide, while still encouraging local authorities to consider how they will continue to enable through traffic while minimising risk to pedestrians and cyclists.

Q1. Do you agree that this advice about introducing 20mph zones and limits provides useful guidance to traffic authorities considering speed management in urban areas? If not, please explain your reasons. Brake is concerned the advice is confusing and contradictory in places and continues to throw up barriers to authorities wishing to introduce widespread 20mph limits, which the DfT has stated it wishes to remove. While acknowledging the social benefits of 20mph limits and supporting their increased use, the revised circular includes restrictive conditions likely to limit both their implementation and benefits that can be derived from them, such as saying they should only be introduced where speeds are already low. It also jars with the work of increasing numbers of local authorities that have already implemented, or committed to, widespread 20mph limits, based on evidence that this a cost effective way to reduce casualties, particularly for vulnerable road users, as well achieve other health, environmental and social benefits, and that 20mph are widely supported by the public4. In this way, Brake argues this guidance is out of step with the needs of local authorities that have responsibility for making local streets safer. Brake also argues it does not provide an adequate response to the need to prioritise safety for vulnerable road users, or do enough to promote greater levels walking or cycling, in line with its stated aims.

Brake believes that ultimately our default urban limit should be lowered to 20mph, with only major through routes retaining 30mph limits where it can be shown it is appropriate and safe to do so. Until this happens, Brake urges the government to provide local authorities with the ability to easily implement widespread 20mph limits on roads around homes, shops and schools, through clear, helpful guidance that is enabling and encouraging around lower limits, and through specific funding for such measures.

This is on the basis there is a huge amount of evidence that slower traffic speeds reduce casualties5, particularly among people on foot and bike and among children in urban settings6. As well as reducing the human suffering caused by crashes and casualties, slower urban speeds enable a host of other benefits.

4 20mph speed reduction initiative, Scottish Executive Central Research Unit , 2001; 20mph Speed Limit Pilots Evaluation Report, Warrington Borough Council, 2010.

2 Brake surveys have shown that a major barrier to greater take up of walking and cycling is fear of fast traffic and more families would be encouraged to walk and cycle to get to work and education if there were 20mph limits where they live and on local routes7. Analysis of walking and cycling where widespread 20mph limits have been implemented has shown they result in more than 20% increases in walking and cycling8. Active travel is good for health, as well as for people’s everyday enjoyment of life and developing close community relationships. There are also environmental benefits to 20mph limits. Lower speeds mean lower emissions from individual journeys9, plus if modal shift to walking and cycling is achieved, more journeys become completely carbon emission-free.

While 20mph zones with traffic calming achieve greater average speed reductions and therefore greater casualty reductions where they are sited10, because of the expense of such zones their casualty reduction effect is usually limited to small areas. Similarly, zones cannot achieve the same modal shift to walking and cycling when they cover only limited areas and do not stretch to entire routes between homes and work or school. 20mph limits without widespread traffic calming are much less expensive so can be implemented over very large areas for the same cost as a small traffic-calmed zone. While 20mph limits do not reduce speeds by as much as zones, they do reduce speeds significantly enough to reduce casualties over a wider area, and to deliver other benefits, even without additional enforcement activity. Research has found that on average, in widespread 20mph limit schemes with signage only, speeds reduce by 1mph11, but crucially some streets, where the mean speeds were higher initially, experience much greater speed reductions and therefore a greater safety benefit12. The Transport Research Laboratory estimates there will be a 6% reduction in casualties for every 1mph reduction in speeds on urban roads with low average speeds, so it is clear there are large benefits to be gained by local authorities opting for 20mph limits across built-up areas13. Assessments of existing schemes have also found they deliver significant additional benefits to local communities. In Bristol’s widescale pilot of 20mph limits, walking increased by 23% and cycling by 21%14 and public attitude surveys on town and city-wide 20mph limits show they are widely supported15.

6 Effect of 20 mph traffic speed zones on road injuries in London, 1986-2006: controlled interrupted time series analysis, London School of Hygiene and Tropical Medicine, 2009

7 Brake and Bolt Burdon Kemp surveys of commuters and parents on cycling, 2012 and Brake and Churchill survey of parents on walking, 2012

8 Citywide Rollout of 20mph speed limits, Bristol City Council Cabinet, 2012

9 Environmental effects of 30 km/h in urban areas – with regard to exhaust emissions and noise, The Swedish National Road and Transport Research Institute, 1999

10 Urban speed management methods, Transport Research Laboratory, 1998

11 Citywide Rollout of 20mph speed limits, Bristol City Council Cabinet, 2012; 20mph Speed Limit Pilots Evaluation Report, Warrington Borough Council, 2010; Interim evaluation of the implementation of 20 mph speed limits in Portsmouth, Department for Transport, 2010

12 20mph speed reduction initiative, Scottish Executive Central Research Unit , 2001; Interim evaluation of the implementation of 20 mph speed limits in Portsmouth, Department for Transport, 2010

15 Citywide Rollout of 20mph speed limits, Bristol City Council Cabinet, 2012; 20mph Speed Limit Pilots Evaluation Report, Warrington Borough Council, 2010

3 Brake also supports widespread 20mph limits because they send out an appropriate message to drivers and all road users. 20mph limits tell drivers they have responsibility towards vulnerable road users and that the roads are shared spaces, where they can expect people on foot or bike to be. They tell everyone that people on foot or bike matter, and their needs and safety are a priority.

The revised guidance states “Traffic authorities are reminded that they can, over time, introduce 20mph zones or limits into: Major streets where business on foot is more important than slowing down road traffic and; Lesser residential roads in cities, towns and villages, particularly where this would be reasonable for the road environment, there is community support and streets are being used by pedestrians and cyclists”. While this recognition that 20mph limits may be applied to a wide range of roads is welcomed, within this statement and elsewhere in the guidance there are limitations placed on local authorities, and mixed messages, which go against the government’s wish to create flexibility and are highly likely to continue to throw up barriers to local authority action. The three main barriers and limitations contained in the guidance are outlined below:

1) It advises 20mph limits should be introduced only on roads with existing mean speeds of 24mph or lower. This is despite elsewhere in the guidance acknowledgement that greater speed reductions (and therefore greater safety gains) are achieved on roads where existing speeds are higher than this. The only rational given for this very significant and restrictive condition is that the DfT believes 20mph limits should be self-enforcing so as not to increase the burden on traffic police. It also insinuates, by referencing the need to ‘balance priorities’, that 20mph limits could negatively impact the economy, if they are placed on roads with higher initial speeds. Brake disputes the rationale behind these two points, and would recommend they are removed on the basis that they continue to pose barriers in implementing 20mph limits, and therefore undermine the Department’s stated aim of making “it clearer that highway authorities have flexibility in the use of 20mph zones and limits, and should apply the option best suited to the local circumstances and that brings most benefits in terms of casualty reductions and wider community benefits.”

Speed limits should be set on the basis of desired outcomes, such as safety and public health, rather than the mean speeds that drivers, who lack information and expertise, choose to travel. No other speed limits are expected to be self-enforcing, and speed limits on 30mph roads suffer from high levels of speeding;16 this shouldn’t be justification for limiting the use of 20mph limits, particularly when the potential benefits are so great. It is also the case, as acknowledged in the revised guidance, that average speed camera technology is now available to use as a cost effective enforcement method for 20mph limits. Brake would suggest the guidance could make this point more explicitly, recommending that this technology is utilised as widely as possible, with priority given to areas where current mean speeds are higher and therefore compliance could be more challenging.

2) It suggests the need for protecting people on foot and bike should be balanced with the need to keep traffic moving and economic considerations. Brake disputes this on two counts. Firstly, we believe that protecting people on foot and bicycle should be a top priority across all built up areas, and we point out that this is essential in achieving the government’s aim of increasing walking and cycling levels (as explained above). Secondly, the implication of this statement is that lower speed limits have a significant negative effect on journey times. Yet evidence shows 20mph limits do not normally result in longer journey times for drivers17. Some studies have found lower limits can improve journey times by creating more even traffic flow18. 20mph limits also deliver significant economic benefits by preventing casualties and enabling

16 Free flow vehicle speeds in Great Britain: 2011, Department for Transport, 2012

17 20mph Limits Save Time and Improve Traffic Flow, 20’s Plenty for Us, 2010

18 Improving traffic behaviour and safety through urban design, Proceedings of the ICE – civil engineering, 2005

4 healthier lifestyles19. It is therefore irrational to base policy decisions on an assumption 20mph limits will have a negative impact on drivers and the economy, and weigh this up against clearly evidenced safety, environmental and health benefits. It is misleading to encourage local authorities to balance the benefits of 20mph limits against the need to keep traffic moving, when 20mph limits are not shown to negatively impact on the latter.

By including this within the guidance, the DfT is prioritising drivers feeling they are making progress, which is not evidenced, over everyone’s right to use roads without unacceptable levels of risk of injury or death, and the take up of more sustainable forms of transport.

3) It recommends use of lower limits on roads where there are already ‘high’ levels20 of walking and cycling. One of the main benefits of 20mph limits is that they enable and increase walking and cycling, so this is an absurd stipulation and does not gel with the government’s commitments to increasing levels of walking and cycling.

Brake is concerned the draft guidance is also not in tune with the public mood around lower limits and active lifestyles. It is estimated that around 8 million people in the UK already live in areas with widespread 20mph limits21, and of those who do not, 90% would support widespread 20mph limits in their community22. The 2010 British Social Attitudes survey reported 71% of all respondents were in favour of 20mph limits in residential streets23. As well as being popular, the public is clear that widespread 20mph limits around homes, shops and schools would enable them and their families to walk and cycle more because one of the major barriers to active lifestyles is road danger24. Many local authorities have already recognised this public mood, and the benefits of widespread 20mph limits, and made significant progress in implementing or committing to widespread lower limits. Local authorities including Bristol, Lancashire, Warrington, Portsmouth, Liverpool, York and Brighton have committed to implementing widespread 20mph limits, and momentum is building. If it maintains barriers to widespread 20mph limits in its guidance, the government will be out of step with the current public appetite for slower speeds in communities and fail to meet its own aim of providing local authorities with the flexibility required to respond to demands and needs of local people.

Q2. Do you agree that traffic authorities should be able to consider the implementation of 20mph limits over a number of roads where mean speeds at or below 24mph are already achieved? If not, please explain your reasons. Local authorities are already able to do this, but Brake believes the guidance should be far more enabling and flexible on this point. As explained above, Brake disagrees with the draft guidance’s stipulation that mean speeds should be at 24mph or below before this can be considered.

Speed limits should be determined with a set of positive outcomes in mind, instead of based on the existing speeds of drivers. The greatest priority in setting limits should be the duty to protect vulnerable road users

20 Table 1 of the revised guidance

21 20’s Plenty for Us, 2012

22 Safer roads needed to nurture future Olympic cyclists, Brake and Bolt Burdon Kemp, 2012

23 2010 British Social Attitudes survey: attitudes to transport, Department for Transport, 2011

24 Survey reveals parents’ fears from fast traffic, Brake and Churchill, 2012; Safer roads needed to nurture future Olympic cyclists, Brake and Bolt Burdon Kemp, 2012

5 from risk of death or serious injury (and therefore enabling more people to walk and cycle without facing unreasonable dangers) using evidence-based methods. Basing decisions on the current mean speeds of drivers encourages stasis rather than positive change and desirable outcomes. It is also nonsensical to suggest that drivers’ chosen speeds provide a suitable guide to what is the most appropriate upper speed limit on that road. It is well evidenced that drivers’ behaviour often does not even correspond with their own perceptions of what is safe and appropriate: most drivers know that driving fast is dangerous, but do it anyway25. Other drivers may not understand or fully appreciate the greater risks associated with higher speeds for vulnerable road users. Instead of maintaining the status quo by using existing mean speeds to determine whether a lower limit is appropriate, the government should be aiming to positively influence driver behaviour to achieve the positive outcomes associated with lower speeds.

Aside from it being inappropriate to set speed limits based on existing speeds, a level of 24mph or below is far too low as a guide, throwing up a major barrier in local authorities implementing 20mph limits on a widespread basis and maximising benefits of these schemes. As was the case in Portsmouth, it is on roads with higher mean speeds that the greatest reduction in speed can be achieved and therefore greatest casualty reductions26. Given the current urban default limit is significantly higher than 24mph, and not always widely enforced, it is highly likely a great many urban roads that have houses, schools and community facilities, and are used by many pedestrians and cyclists (or with the propensity for such), could benefit greatly from 20mph limits, but have current mean speeds of more than 24mph. Brake argues it is damaging and restrictive to stipulate that local authorities discount these roads from their consideration of 20mph limits.

Through this stipulation, the government is continuing to throw up barriers to local authorities and is failing to give them the flexibility it aims to. Brake recommends that instead of limiting local authorities to implement 20mph limits only in specific circumstances, it should ask local authorities to consider 20mph across all urban roads as part of a wider approach to preventing casualties and encouraging sustainable travel and healthy living. Instead of providing limiting criteria on which roads to consider for 20mph limits, it would be more helpful and progressive, and offer greater flexibility, to instead include guidance on which roads might retain higher 30mph limits as through routes. This would give local authorities the flexibility they need, and which the DfT wishes to provide, while still encouraging them to consider how they will continue to enable through traffic while minimising risks to pedestrians and cyclists.

Q3. Do you agree that the recommendation to use the technical assessment tool should be withdrawn? If not, please explain your reasons. Brake agrees the recommendation to use the technical assessment tool should be withdrawn. This tool is highly limited in that it does not take account of the range of benefits of slower speeds, including the social, environmental and health benefits. It overestimates the economic benefits of higher speeds and does not adequately take into account the needs of vulnerable road users.

Brake welcomes the government’s recommendation for local authorities to consider lower limits on rural roads with a higher number of bends, junctions or accesses or with considerable number of vulnerable road users. However, Brake urges the government to impose fewer restrictions on lowering limits, giving local authorities greater flexibility to determine appropriate limits. Brake recommends the government ask local authorities to consider lower limits across all rural roads as part of a wider approach to reducing casualties, encouraging sustainable travel and healthy living, while specifying that priority should be given to roads

25 Want to comply with the speed limits; can comply with the speed limits: Effectiveness of behavioural planning for increasing drivers’ compliance with speed limits, Dr Mark Elliott at Brake’s Third International Congress on Speed, 13 May 2010

26 20mph speed reduction initiative, Scottish Executive Central Research Unit, 2001

6 with particular risks. In this way the Department for Transport would be guiding and supporting, rather than limiting, the work of the local authorities in making roads safer.

Brake welcomes the invitation for applications for 40mph zones in rural areas, particularly around national parks or areas of natural beauty, which are likely to attract higher numbers of tourists walking or cycling. However, Brake urges the Department for Transport to broaden this to invite applications for 30mph and 20mph limits too, to give local authorities the ability make decisions appropriate to local needs.

Q4. Do you agree that compliance with air quality limits could be a factor in the choice of speed made by local traffic authorities? If not, please explain your reasons. Emissions should be a factor in the choice of speed made by local authorities. However, emissions calculations should take account of traffic flow at different speeds and modal shift to more sustainable forms of transport as a result of lower speeds. Research shows 20mph limits increase walking and cycling27, so will help to reduce emissions.

Q5. Do you have other comments about the drafting of the revised circular? A major contradiction within this revised guidance is the suggestion that 30mph should be the norm, despite saying it is appropriate to consider 20mph limits and zones for the majority of roads in built up areas. Brake recommends this statement is simply taken out, as it constitutes another potential barrier (and is confusing) for local authorities wishing to lower urban limits to 20mph. In section six, Table 1, it is summarised that 20mph limits and zones should be considered “in streets that are primarily residential and in other town or city streets where pedestrian and cyclist movements are high, such as around schools, shops, markets, playgrounds and other areas, where vehicle movement is not the primary function.” While 30mph (the default) is appropriate “in other built-up areas (where vehicle movement is deemed more important), with development on both sides of the road.” This leads to questions over whether 30 should be the default speed at all, as the majority of urban roads would fit better into the first, rather than the second category. Brake considers that 20mph is a more appropriate default speed for these roads (see above), with 30mph limits only on major through routes. By insisting on keeping the default higher and mandating signing for lower speed roads, the government is ensuring a huge amount of local authority financial wastage on signage for widespread 20mph limits, which are increasingly becoming the norm around homes, schools and shops.

Brake is also concerned that the key points boxes and tables are unhelpful in many places throughout the document, as they often misrepresent what is contained in the rest of the section, and can throw up confusing contradictions. For example, in section one, the key points box fails to mention the crucial guidance contained in point 12, which asks local authorities to consider introducing more 20mph limits in urban areas. It even, arguably, undermines this point by implying that lower limits should only be considered where there are particular needs and conditions to warrant special attention, and that they should be based on drivers’ assessments of what’s a safe speed to travel (both of which are limiting conditions, as explained above, that we recommend are removed). Brake recommends removing, integrating or significantly overhauling the key points boxes, as they frequently conflict with the main body of the guidance.

Finally, and crucially, Brake is very concerned that in consulting upon this guidance it has not been given access to full information. It is extremely difficult to assess this guidance without having had the opportunity to review and consider the assessment tool referred to throughout and without understanding of the criteria it will use. Brake can only therefore provide an initial assessment of the guidance, which is subject to change, should the assessment tool prove to be inadequate in helping local authorities to gauge the full

7 range of health, social, economic and environmental benefits of lower limits. Brake would urge the DfT to give key experts and stakeholders such as Brake opportunity to consult on this tool before it is finalised.

For more information contact Ellen Booth, senior campaigns officer, on [email protected]