Revision of Speed Limits: A257

Agenda Item No 7

To: Dover Joint Transportation Board, 9 June 2011

Main Portfolio Area: KCC – Environment, Highways and Waste

By: Head of Transport & Development, Kent Highway Services

Classification: Unrestricted

Ward: Little Stour and Ashtone, Little Stour Division : Sandwich

Summary: The report summarises the proposal of altering the current speed limit on the A257.

For Recommendation

1. Introduction

1.1 Members will recall that a report on this subject was tabled at the Dover JTB of 12 th April 2011. Unfortunately it was not possible to organise the advertising of the necessary Traffic Regulation Orders (TRO’s) prior to that JTB, as such it was decided to return to this JTB with any objections received.

1.2 The Traffic Regulation Order (TRO) to implement the proposed two new sections of 50mph and extension of the 30mph at the Western end of Wingham was advertised by Kent County Council (KCC) on the 8th May 2011 in the Kent on Sunday. Statutory and non statutory Consultees were also written to outlining the proposed TRO and the details were posted on the KCC website.

1.3 The closing date for comments was the 31 st May. Due to this final report being required prior to this closing date for comments, any additional comments received after this date will be reported to the JTB verbally. Comments that have been received can be seen in Appendix 1.

1.4 To date, two representations have been received from the Association of British Drivers and Kent Police. The former states that there is no crash data or speed check data to back up the proposal; the proposed limit is below the perceived safe speed limit of the road; and that drivers are capable of adjusting their speed to suit hazards in the road ahead without applying a blanket lower speed limit.

1.5 Kent Police have commented that the speed limit review recommended that the two stretches of national speed limit either side of Littlebourne should not be changed and they still support that stance. They state that divers will not view the road environment as a 50mph limit and the poor compliance will bring other 50mph limits into disrepute. The classification of the road prohibits any major engineering works that would assist in reducing speeds and therefore actual driven speeds will be unlikely to alter. There does not appear to be a pattern to the crash record and only one crash could possibly be attributed to excessive speed.

Kent Highway Services’ Comments 1.6 Although both objectors have raised valid points, observed speeds of the majority of vehicles are already sufficiently low to justify a 50mph speed limit, and therefore the proposed reduction in speed limit will not adversely affect the majority of drivers.

1.7 The extent of the proposal is shown on the two drawings in Appendix 2 and is being funded from the Member Highway Funds of Mr Ridings and Mr Northey

2. Recommendation

Subject to the views of this Board, it is recommended that the proposed speed limit alterations (The Kent County Council (A257 Canterbury, Littlebourne, Ickham and Well and Wingham) (50pmh Speed Limit) Order 2011) are progressed and implemented.

Due to part of the A257 falling within the Canterbury District, the approval of the Canterbury JTB will also be necessary for this scheme to be progressed (21 st June 2011).

Contact Officer:

Tony Jenson, Transportation Engineer – Dover and Shepway

Background Papers

Appendix 1: Copies of responses to TRO advertisement Appendix 2: Dover JTB Committee report Revision of Speed Limits: A257 12 April 2011

APPENDIX 1 – Copies of responses to TRO advertisement 1. Kent Police 2. Association of British Drivers

The Association of British Drivers. Kent Branch

8, Sussex Gardens Herne Bay Kent. CT6 8DU 18 th May 2011

The Transportation and Development Manager East Kent Area Kent Highway Services Javelin Way Ashford. TN24 8AD

Your ref:- (A257 Canterbury, Littlebourne, Ickham and Well and Wingham) (50MPH Speed limit) Order 2011

Dear Sir We wish to OBJECT to the above Traffic Regulation Order. We believe the current speed limit of 60mph should not be reduced.

We have listed several points which we would like you to consider:-

1 You have not listed any speed related accident figures to warrant lowering of the current limit. Kent Highway Services accident figures prove that most accidents occur within the already restricted areas, further speed reduction measures will not seem to serve any useful purpose, other than causing driver frustration and increasing the risk of prosecution whilst driving safely. Further inspection of accident figures seem to show that most accidents are within nationally recognised statistics, ie, rear end shunts, turning and failed to look properly categories and very few for speed per se.

2 You have not supplied any speed check data to warrant claims of excessive speeding. Has a traffic volume/speed census ever been done along this road to determine the accident rate in any three year period? If we assume that 15,000 vehicle movements a day is the norm, then that equates to about 16.5 million vehicle movements over a three year period. If as we suspect the rate is negligible, then lowering the speed limit will not reduce the number of casualties, as you claim it will do in your Statement of Reasons.

3 Lowering the speed limit by 10 mph, will only increase those ‘speeding’ and so increasing the conviction rate of perfectly safe drivers, driving over a downgraded limit, that is well below the generally perceived safe speed limit for this stretch of road. This simple fact is backed-up by similar views of Kent Police, who also stated that any downgrading of the current limit, would “bring other 50mph speed limits into disrepute”

7 4 On roads of this character drivers expect to encounter many types of hazards at various levels at certain periods of the day and you adjust your driving to suit. This simple fact is lost on those that think ‘driving by numbers’ is the panacea for preventing accidents.

No road has a ‘safe’ speed, it all depends on prevailing conditions.

While bearing in mind the above statement, the current 60mph is not a target speed and if you have done any speed checks, then you will have found that the vast majority of drivers think that this speed limit is perfectly safe for certain sections of the A257 especially on a rural road with limited housing density where a ‘blanket’ reduction would be un-acceptable.

5 May I quote from your own report by Mid Kent Transportation Manager dated 11 th July 2006. “It is our view that the introduction of an inappropriate limit is likely to breed contempt, lack of compliance and lack of respect for the law and place undue pressure upon the Police” It also says “ In setting any limit the Police and the County Council are seeking limits that foster compliance and as much self-enforcement as possible.” Similar views are set out in the DfT’s --- Setting Local Speed Limits 01/2006, and we repeat, that Kent Police have stated a similar view.

In Conclusion.

Your past experience will tell the average pedestrian/resident vastly over estimates traffic speeds, (your own traffic speed surveys will confirm this) and very often it is also traffic density that can be an underlying theme to demanding some sort of action. These schemes are so often generated by a few vocal residents and chased up by local councillors chasing a few votes come the next parish election. Do all these people, religiously follow speed limits when driving past somebody else’s house? The volume of so called ‘speeding drivers’ (which does not mean dangerous) tells us, they do not! As mentioned earlier, no traffic volumes, speed related accidents or speed survey tables have come with this TRO, so we assume it is more of a ‘rant’ from a few local people, which nowadays seems to be the driving force behind such measures. But in Setting Local Speed limits 01/2006 the opening line says ” Speed limits should be evidence- led” to pre-empt such ‘rants’ distorting statistical evidence. As in previous DfT Circulars, Setting Local Speed Limits 01/2006 says that “Speed limits should not be used to attempt to solve the problem of isolated hazards” , therefore, just lowering the speed limit is not the first option.

We must state here that we find it totally unacceptable that experienced Police advice and DfT guidelines are being totally ignored and that the personal views of a few councillors and two MP’s are being used to push this TRO through.

Thanking you for your time and we would like a written response to the points we have raised. We also wish to be given the opportunity of presenting our case at the meeting where these proposals will be decided.

Yours sincerely Terry Hudson Kent area co-ordinator

8 Tel:- 01227 374680 (evenings/weekends only) E-mail:- [email protected]

Brian Macdowall Secretary Tel:- 01227 369119 Mobile:- 07930 113232

Ian Taylor Assistant co-ordinator Tel:- 01304 203351 Mobile:- 07850 259499

Could you please acknowledge receipt of this e-mail.

Traffic Management Unit, Tactical Operations, London Road, Aylesford, Kent ME20 7SL Telephone: (01622) 798542 Fax: 01622 798549 Mrs. Lorna Day Kent Highway Services Invicta House Maidstone Kent ME14 1XX You Ref: LD/MJ Our Ref: 165/TRO/11826/11 Date 20 th May 2011

The Kent County Council (A257 Canterbury, Littlebourne, Ickham and Well and Wingham) (50mph Speed Limit) Order 2011. The Kent County Council (A257 Canterbury Road, Wingham) (30mph Speed Limit) Order 2011.

Dear Mrs. Day,

Thank you for your letters dated 6th May 2011 regarding the above subject. The introduction of any new speed limit is an emotive subject, as is the antisocial behaviour of those motorists who exceed the present limits.

In order to ensure credibility of a new speed limit we would expect all aspects of DfT Circular 01/2006 to be adhered to.

Any speed limit introduced outside of this guidance will not only be ineffective but will leave the Police with the task of carrying out constant enforcement, where previously an issue of excess speed did not exist Kent Police would seek that the legislation and advice given in the Traffic Signs Manuel Chapters 3 and 5, and the Traffic Signs Regulations and General Directions 2002, is complied with.

Having studied these proposals and viewed the area, Kent Police have the following observations:

50mph Speed Limit.

As part of the consultation process, Kent Police would like to see 24-hour, 7-day speed data for these areas. We have previously requested this in a letter to Mr. Tony Jenson dated 9th March 2011, but to date no such data has been provided.

A speed limit review conducted by Jacobs on behalf of Kent Highway Services was commenced in 2007, and the A257 Canterbury to Sandwich was part of Area 2, this was reviewed in 2009.

The review team recommended that there should be no change to the current 60mph speed limit in site 8, which is located on the A257 between a point 85m west of the property entrance of ‘Little Acres, The Hill, Littlebourne and a point 80m east of the junction with Stodmarsh Road, Canterbury.

The review team also recommended that there should be no change to the current 60mph speed limit in site 6, which is located on the A257 between a point 325m west of the junction with Mill Road, Wingham Green and a point 40m west of the entrance to Lee Priory, Littlebourne.

Kent Police Traffic Management Unit personnel visited these sites and agreed with these recommendations.

The proposed new 50mph speed limit between the west of Littlebourne and the eastern outskirts of Canterbury appears to mirror site 8 of the speed limit review, which is 1.8 miles in length. The road geometry and environment does not appear to have changed since the review was conducted, and using the summary tables contained within DfT Circular 01/2006, this area would still fit the criteria for a rural 60mph speed limit.

10 During my visit, observed driven speeds were in the region of 50-65mph. Drivers will not view the road environment as a 50 mph limit and there will be poor compliance, this will bring other 50mph speed limits into disrepute . The proposed new 50mph speed limit between Wingham Green and the east of Littlebourne appears to mirror site 6 of the speed limit review, which is 1.4 miles in length.

The road geometry and environment does not appear to have changed since the review was conducted, and using the summary tables contained within DfT Circular 01/2006, this area would still fit the criteria for a rural 60mph speed limit.

During my visit, observed driven speeds were in the region of 50-60mph. Drivers will not view the road environment as a 50 mph limit and there will be poor compliance, this will bring other 50mph speed limits into disrepute .

The A257 is a major through route used by all types of vehicles, which prohibits any major engineering measures to assist in reducing vehicular speed. Without effective engineering changes to the road itself, the actual driven speeds will not be sufficiently reduced to obtain the necessary compliance to the proposed new 50mph speed limit.

Therefore Kent Police would view the proposed new 50mph speed limits as inappropriate and formally object to these proposals.

Having researched the available recorded crash data, there have been 6 injury crashes on the A257 between Littlebourne and Canterbury in the last 3 years, and 3 injury crashes on the A257 between Littlebourne and Wingham Green in the last 3 years.

Apart from loss of control in wet conditions, there does not appear to be any pattern to these crashes as the circumstances of the other collisions is different, and only one of these crashes indicates that excess speed may have been a factor. In our view the crash history for the last three years is not significant for an ‘A' class road considering the amount of traffic that uses it.

If any further information becomes available to be viewed in regard to this particular proposal Kent Police would be willing to look at this information and provide further comment.

30mph Speed Limit.

The speed limit review recommended that the eastern 30mph speed limit gateway of Wingham village should be moved 200 metres east as it is currently in a poor position, being located within a series of bends. This would appear to locate the gateway just east of the entrance to Fairview Nursery, and would be similar to your proposal.

Therefore Kent Police in principle would have no objections to this proposal Kent Police should point out that, as with all new Traffic Regulation Orders we would look for their introduction to be in the main self- enforcing. This fact needs to be taken into account when making new orders, and methods to ensure self- enforcement must be provided to maintain credibility of the order. The demands on Kent Police are such that deployment of resources must be prioritised and it is likely that enforcement of this regulation will receive a low priority.

I hope that these views are of assistance to you.

Yours Sincerely Geoff Bineham Police Constable 8635 Traffic Management Section

APPENDIX 2 – JTB Committee report Revision of Speed Limits: A257 12 April 2011

Revision of Speed Limits: A257

To: Dover Joint Transportation Board, 21 April 2011

Main Portfolio Area: KCC – Environment, Highways and Waste

By: Head of Transport & Development, Kent Highway Services

Classification: Unrestricted

Ward: Little Stour and Ashtone, Little Stour Division : Sandwich

Summary: The report summarises the proposal of altering the current speed limit on the A257.

For Recommendation

1. Introduction

1.8 On behalf of Kent County Council (KCC), Kent Highway Services (KHS) are proposing the alteration of the speed limit on two sections of the A257.

1.9 A working party was organised locally which included representatives from local Parish Council and residents groups; MP’s Laura Sandys and Julian Brazier; County Councillor Leyland Ridings and District Councillors and was formed to discuss the impact traffic had on the Villages located on the A257 and surrounding roads.

1.10 Among other issues, all were concerned with the speed of traffic on the A257 and had related concerns regarding road safety. As a result of this KHS were asked to investigate the potential of lowering the speed limit on the A257.

1.11 KHS carries out a yearly examination of crash clusters on the County’s Roads. This is based on personal injury crash information supplied by Kent Police. The 2010 investigation did not reveal any recurring crash cluster sites along the length of the A257 that required action.

1.12 As the year progressed two sites developed that had several ‘damage only’ crashes:

1.12.1 On the approach to Wingham from the west (Bridge Bend), additional signing and lining improvements were organised for this location.

1.12.2 The bend on the A257 at Shatterling suffered from a spate of crashes. Although the average traffic speeds were within the posted 50mph limit, there were a number of drivers maintaining excessive speed on the approach to the bend. As a result of this, County Councillor Leyland Ridings agreed to fund two bend warning interactive signs from his Member Highway Fund.

1.13 The A257 was assessed as part of the Kent-wide speed limit review carried out by KHS Road Safety Team and Kent Police in 2010 which examined all of the County’s A and B roads. This assessment was made in accordance with Department of Transport Circular 1/2006 "Setting Local Speed Limits" and primarily looks at the road environment rather than actual traffic speeds.

13 1.14 The only recommended alteration arising from the Speed Limit Review for the A257 was to extend the current 30mph entry on the western side of Wingham; to move this a further 200m to the west to locate the speed limit gateway prior to the series of bends as drivers approach the village from the west.

1.15 The characteristics defined within the Speed Limit Review for a 50mph road are as follows:

"Should be considered for lower quality A and B roads which may have a relatively high number of bends, junctions or accesses. Can also be considered where speeds are below 50mph, so lower limit does not interfere with traffic flow."

1.16 Following the request of the working party, KHS agreed to re-examine the existing 4 sections of 60mph speed limit on the A257. These are expanded upon below:

1.17 Stodmarsh Road to the west of Littlebourne Village. This section of the A257 incorporates several side roads, private accesses and a series of bends bordered closely by woodland. This may be appropriate for a 50mph limit (this section is within the Canterbury District).

1.18 East of Littlebourne Village to Wingham Green. This section also incorporates several side roads and private accesses (some with poor visibility); a length through a cutting where the road width narrows and a sharp bend (recently benefiting from Cllr Northy funding two interactive warning signs). This section may also be appropriate for a 50mph limit.

1.19 Gobery Hill east of Wingham, to Shatterling. The A257 in this area is extremely straight and has an open street scene, as such this section should remain 60mph.

1.20 Shatterling to the A256 . This section, mainly consisting of the Ash by-pass, has a wide and open layout benefitting from excellent visibility and should also remain at 60mph.

1.21 A briefing based on the above findings was provided for Leyland Ridings which he fed back to the working group at their meeting on the 5 th March 2011.

1.22 Kent Police Traffic Management Unit were consulted regarding the potential to lower the speed limit to 50mph at the above two locations. They returned a response stating that they do not support the lowering of the speed limit. There are various reasons for this these are summarised below, and the full response can be found in Appendix 1.

1.22.1 Kent Police Traffic Management Unit revisited the sites as examined in the Speed Limit Review and maintain that the original recommendations (no reduction in 60mph speed limits) are correct.. 1.22.2 Observed driven speeds are in the region of 60mph and as such drivers would not comply with a 50mph. 1.22.3 The introduction of unsuitable 50mph limits would bring 50mph limits into disrepute and result in Kent Police having to carry out constant enforcement on a road which previously did not have a speeding problem. 1.22.4 Kent Police Traffic Management Unit have also requested a 24hour 7day speed survey carried out for the lengths being considered for change.

1.23 Unanimous feedback from the working group was that the lowering of the speed limit to 50mph on the two sections of the A257 as mentioned above was a positive step and should be progressed was soon as possible.

1.24 County Councillors Leyland Ridings and Michael Northy have indicated that they would be willing to fund the required Traffic Regulation Order alterations and additional signing from their Member Highway Fund allocations to enable this scheme to be implemented.

1.25 To gauge feeling from the wider community a Traffic Regulation Order was advertised on 17 th April taking into account the lowering of the speed limit top 50mph on the aforementioned two sections of the A257 and the extension of the 30mph limit into Wingham from the west as mentioned in section 1.7. Plans for this can be seen in Appendix 2. This process will not be complete until 16 th May, any objections be received prior to the JTB will be reported verbally.

3. Recommendation Subject to the views of this Board, it is recommended that, should no further objections being received to the Traffic Regulation Order, the scheme is progressed and implemented.

Should objections be received after the April JTB meeting, they will be reported to the next available JTB.

Due to part of the A257 falling within the Canterbury District, the approval of the Canterbury JTB will also be necessary for this scheme to be progressed.

Contact Officer:

David Barton, Local Transportation & Development Manager - Dover and Shepway KHS Transport & Development (08458 247800)

Tony Jenson, Transportation Engineer – Dover and Shepway Development KHS

Background Papers

Appendix 1: Correspondence from Kent Police Traffic Management Unit Appendix 2: Plans showing potential speed limit changes

Revision of Speed Limits – A257

APPENDIX 1 – Correspondence from Kent Police Traffic Management Unit

Traffic Management Unit, Tactical Operations, London Road, Aylesford, Kent ME20 7SL Telephone: (01622) 798542 Fax: 01622 798549

Mr. Tony Jenson Kent Highway Services Javelin Way Henwood Industrial Estate Ashford Kent TN24 8AD

You Ref: MHF/10/11/LR Our Ref: 165/SL/11645/11

Date 9th March 2011

A257 Speed Limits Canterbury to Wingham Green.

Dear Mr. Jenson,

Thank you for your e-mail dated 25 th February 2011 regarding the above subject.

The introduction of any new speed limit is an emotive subject, as is the antisocial behaviour of those motorists who exceed the present limits.

In order to ensure credibility of a new speed limit we would expect all aspects of DfT Circular 01/2006 to be adhered to.

Kent Police would seek that the legislation and advice given in the Traffic Signs Manuel Chapters 3 and 5, and the Traffic Signs Regulations and General Directions 2002, is complied with.

Having studied these proposals and viewed the area, Kent Police have the following observations:

As part of the consultation process, Kent Police would like to see 24-hour, 7-day speed data for these areas.

A speed limit review conducted by Jacobs on behalf of Kent Highway Services was commenced in 2007, and the A257 Canterbury to Sandwich was part of Area 2, this was reviewed in 2009.

The review team recommended that there should be no change to the current 60mph speed limit in site 6, which is located on the A257 between a point 325m west of the junction with Mill Road, Wingham Green and a point 40m west of the entrance to Lee Priory, Littlebourne. The review team also recommended that there should be no change to the current 60mph speed limit in site 8, which is located on the A257 between a point 85m west of the property entrance of ‘Little Acres, The Hill, Littlebourne and a point 80m east of the junction with Stodmarsh Road, Canterbury.

17 Kent Police Traffic Management Unit personnel visited these sites and agreed with these recommendations.

Section 1

The proposed new 50mph speed limit between the west of Littlebourne and the eastern outskirts of Canterbury appears to be similar to site 8 of the speed limit review. The road geometry and environment does not appear to have changed since the review was conducted Using the summary tables contained within DfT Circular 01/2006, this area would still fit the criteria for a rural 60mph speed limit.

During my visit, observed driven speeds were in the region of 60mph. Drivers will not view the road environment as a 50 mph limit and there will be poor compliance, this will bring other 50mph speed limits into disrepute .

Section 2

The proposed new 50mph speed limit between Wingham Green and the east of Littlebourne appears to be similar to site 6 of the speed limit review. The road geometry and environment does not appear to have changed since the review was conducted Using the summary tables contained within DfT Circular 01/2006, this area would still fit the criteria for a rural 60mph speed limit.

Therefore Kent Police would view the proposed new 50mph speed limits as inappropriate and would not support these proposals.

Having researched the available recorded crash data, there have been 6 injury crashes on the A257 within section 1 in the last 3 years:

• There was a loss of control collision in wet conditions/daylight in August 2008. There was no evidence of speeding but there was a patch of mud on the road. • The next crash occurred at night in dry conditions in January 2009, where a vehicle was speeding, overtook another vehicle then lost control and overturned • The third crash occurred in May 2009 during the day in wet weather, where two vehicles slowed, but a following vehicle failed to react and collided with the rear of the vehicle in front. • The fourth crash occurred during the day in October 2009 in dry conditions, where a vehicle lost control for unknown reasons and left the road to the nearside • The Fifth crash occurred in May 2010 during the day in dry weather, a driver was alighting from her vehicle, closed the drivers door and another vehicle collided with her one of her legs and failed to stop.

18 • The sixth crash occurred during the day in dry weather in August 2008, where a vehicle lost control on a bend and collided with a vehicle travelling in the opposite direction. The driver of the vehicle that lost control failed a breath test.

Having researched the available recorded crash data, there have been 4 injury crashes on the A257 within section 2 in the last 3 years: • There was a head-on collision caused by inappropriate overtaking in wet conditions/daylight in January 2008. • The next crash occurred in March 2009 during the day in dry weather, where a vehicle slowed to carry out a turning manoeuvre, and a following vehicle failed to react and collided with the rear of the vehicle in front. • The third crash occurred in daylight in November 2009, where a vehicle braked hard in wet conditions and lost control, colliding with oncoming traffic. • The fourth crash occurred during the day in December 2009 also in wet conditions, where a vehicle overshot a junction from a side road colliding with a vehicle on the A257, and the offending vehicle failed to stop.

Apart from loss of control, there does not appear to be any pattern to these crashes as the circumstances of each crash is different, and in our view the crash history for the last three years is not significant for an ‘A' class road.

Kent Police should point out that, as with all new Traffic Regulation Orders we would look for their introduction to be in the main self-enforcing. This fact needs to be taken into account when making new orders, and methods to ensure self-enforcement must be provided to maintain credibility of the order. The demands on Kent Police are such that deployment of resources must be prioritised and it is likely that enforcement of this regulation will receive a low priority.

I hope that these views are of assistance to you.

Yours Sincerely

Geoff Bineham Police Constable 8635 Traffic Management Section

Revision of Speed Limits – A257

APPENDIX 2 – Plans showing potential speed limit changes