Your Ref: Economy, Environment and lnfrastructure Cargen Tower Our Ref: CSPD/TN11l AT Garroch Business Park 18 December 2018 DG2 BPN Mr David Gilbert Chairperson Any enquiries please contact Caerlaverock Comm u n ity Association Anthony Topping c/o Cedrum Direct Dial 01387 01387 271146 Kelton uk DUMFRIES E-mail: [email protected]. DG1 4UA

Dear Mr Gilbert INFRASTRUCTURE & TRANSPORTATION; ROADS SERVICE ,,TWENTY IS PLENTY" GLENCAPLE We acknowledge receipt of your letter (dated 28 SeptemberZ}18), Petition (20mph zones in Glencaple Village) and the 'Twenty is Plenty' Glencaple brochure. My team has now undertaken a desk study and a site visit was carried out on Monday 3 December 2018. Please accept my apologies for the delay in responding, we receive numerous road safety/ speed limit requests and enquiries and a considerable amount of time and effort was spent reviewing and addressing some of the specific issues raised in your brochure. Please find attached our considered response:

Background Glencaple is a small rural settlement situated on the banks of the River Nith, situated between Dumfries to the north and Caerlaverock Castle to the south. The 8725 runs through Glencaple in a north south direction and the C27n links Glencaple to the C12n Bankend Road to the east. Like many rural villages with a 30mph speed limit and street lighting, not all roads have dedicated footways, often due to lack of space and/or private ownership. lndeed, some villages object to the 'urbanisation' of their verges, instead preferring to see their roads as a shared space which encourages greater driver awareness and careful driving. The nature of the road geometry and alignment, in conjunction with parked vehicles/ lack of footways, means that vehicle speeds are generally compliant with the 30mph speed limit. The lack of footways and narrow verges mean that in certain locations the road is treated as a natural 'shared space' and the majority of road users are considerate, observant and courteous with regards to road safety. From the site visit it was observed that traffic flows were generally low and that vehicle speeds were not excessive and appropriate for the location and conditions. -2-

INFRASTRUCTURE & TRANSPORTATION; ROADS SERVIGE "TWENTY IS PLENTY" GLENCAPLE

Collision Data A check on the collision history of the extents of the speed limit at Glencaple was undertaken between the 1 January 2A13 to the 30 September 2018. There was one "Slight" collision on the 14 October 2016 involving a south-westbound vehicle (Van or Goods vehicle) and a north-eastbound vehicle (Bus/ coach). The causation is listed as "failed to judge other person's path or speed". Both vehicles were apportioned blame in this instance. This collision occurred near the Nith Hotel. There was also a "Damage only" collision on the 26 August 2013 involving a northbound vehicle (type of vehicle "unlisted"), no other vehicles were involved. The causation is listed as "Careless, reckless, or in a hurry/ exceeding speed limiU poor turn or manoeuvre". This collision occurred approximately 70 metres north of the Glencaple Road/ Church Street junction.

A further "Damage only" collision on the 27 May 2017 was reported involving a "parkedlparking" vehicle (Bus or coach) and a "parked/parking" vehicle (car). The causation was listed as "vehicle blind spot". This collision has been described as located near the Nith Hotel, Glencaple. It is important to note that none of the collisions Iisted involved pedestrians or children and were limited to the vicinity of the Nith Hoteland the Glencaple Road/ Church Street junction where vehicle turning movements occur the most. The Council operate a Committee approved Accident lnvestigation and Prevention (AlP) Programme. This is based on a trawl of all reported 'injury' accidents in , based on the following: 3 No. reported injury accidents in a 3-year period in the same location. If a location falls into this category, then it will be added to the Road Safety Programme for investigation and possible improvement works. There are no locations within the speed limit extents of Glencaple that have been identified either previously or currently as an AIP site.

Speed Limit Guidance National guidance on speed limits advises that: "speed limits should be evidence led, self-explaining and seek to reinforce people's assessment of what rs a safe speed to travel. They should encourage self-compliance and not be seen as a targef speed at which to drive in all circumstances" Studies have shown that 30mph speed limits set too far away from village or town residential boundaries do not reduce traffic speeds and further traffic calming measures and signage/ road markings are often required. Review of Speed Limits: A'Review of Speed Limits on LocalA and B Class Roads' across the region was carried out a number of years ago- This review included consideration by the four Area Committees and was reported to the 3 July 2012 and 12 March 2013 meetings of the Planning Housing and Environment Services (PHES) Committee. Review of Speed Limits on LocalA and B Class Roads 3 July 2412 Review of Speed Limits on LocalA and B Class Roads 12 March 2013 -3-

INFRASTRUGTU RE & TRANSPORTATION ; ROADS S E RVIC E ,,TI'VENTY IS PLENry" GLENCAPLE

At the 12 March 2A13 meeting, Members agreed "that unless fhere are material a,lterations to specific locations already reviewed there will be no need to re-consider resuests for speed limit alteratians at that location." This Report summarises 'that further reviews at communities on A and B Class roads are not required, unless there has been a naterial chanqe in circumstances.' The recommendations of that review were agreed with the then Chief Constable taking cognisance of national guidance that speed limits should be evidence led, self-explaining and that limits need to be consistent with what drivers would expect to find elsewhere in the region and in the country. A material chanqe would be a significant alteration to the road ctraracter, primarily relating to adjacent frontage development or major alterations to road geometry. lt should be the case that any such alterations, and therefore any potential need to alter speed limits or extents, should be identified through the Planning reviewl approval processes. Unless there is a material change to a town, village or local community i.e. new housing development, there is often limited justification to extend existing speed limits as there is a lack of evidence to drivers to suggest they should be driving at the reduced speed limit i.e. Iack of frontage properties, street lighting or footways. lf a speed limit was proposed to be extended, without good reason and substantiation, there would be little or no compliance from drivers. As with previous requests to extend speed limits, there would be no support from the Roads Authority or Police for the extension. The 8725 at Glencaple was not identified for inclusion in any of the Speed Limit Reviews in2Q12 and 2013. Current Transport Scotland guidance "Speed Limit Review: The Assessment Process" (2012) indicates 30 mph should be the standard speed limit in ruralvillages. This assessment is dependent upon a number of varying factors such as; . Single carriageway rural roads . Dual caniageway rural roads, and; o Villages and areas of significant residential commercial development Single carriageway rural roads: The assessment framework, originally developed by the Transport Research Laboratory (TRL) Limited, described in Setting Local Speed Limits is based on the presumption that when taking into account safety benefits, mobility costs plus environmental and accessibility factors, single carriageway roads should operate at speeds that help maximise operational efficiency. Villages and areas of significant residential commercial development: Transport Scotland has used the village definition given in 'Village Speed Limits' which identifies village criteria as 20 or more properties directly fronting the road and a minimum length of 600 metres. Where a section meets these criteria, a 30mph speed limit would usually be appropriate. -4-

INFRASTRUGTURE & TRANSPORTATION; ROADS SERvlcE *TWENry IS PLENTY" GLENCAPLE

Extension of 30mph Speed Limits Studies have shown that 30mph speed limits set too far away from village or town residential boundaries do not reduce traffic speeds and further traffic calming measures and signagel road markings are often required. The siting of the 30mph speed limit terminal signs is as per the guidance contained within Traffic Signs Manual (TSM) Chapter 3 'Regulatory Signs'which gives the minimum clear visibility distance for terminal signs on approach to a 30mph speed limit (in relation to the approach road speed limit of 60mph) as 115 metres. The geometry and vertical alignment of the 8725 and C27n public roads is such that the placement of the existing 30mph speed limit signs are compliant with this guidance. A blanket authorisation permitting the use of countdown marker signs on the approach to speed limit terminal signs, at the Traffic Authorities discretion, was issued in 1995. The Traffic Signs Regulations and General Directions (TSRGD) 2016 does not prescribe the use of these countdown markers. Based on the actual clear visibility distance on the approach to the 30mph speed limit signs, there is no road safetyl financial justification to install such signs. We do propose to extend the existing 30mph speed limit on the Dumfries approach to Glencaple on the 8725 to include the lnshore Rescue Boathouse. This will be to the northern boundary of the station at the existing 'Glencaple' village sign. The existing 30mph speed limit on the southern approach to Glencaple on the F725 will also be extended due to the development currently under initial site preparation works. This would result in the existing speed limit being moved further south to the southern boundary of "Gullsway'' (some 200 metres). The Traffic Regulation Order process for changing locations of speed limits will commence early 2019.

20mph Speed Limit Policy (schools and urban locations) There is no legislation for 20mph speed limits or traffic calming at schools. Alt speed limits, other than those on restricted roads, are made by Order under Section 84 of the Road Traffic Regulation Act 1984. Any speed limits below 30 mph, other than 20 mph limits or 2O mph zones, require individual consent from the Secretary of State. Unless an Order has been made and the road is signed to the contrary, a 30 mph speed limit applies where there is a system of street lighting furnished by means of lamps placed not more than 200 yards apart. Note that there are no regulations regarding how to set a local speed limit. However, the Department for Transport does provide guidance (see below). Hence the Local Roads Authority must make a Traffic Regulation Order to set the speed limit at 20mph. This includes publishing and advertising the Order so that those affected may object if they wish. There is guidance for 20mph speed limits: . ETLLD Circular No. 1/2004 20mph Speed Limits around Schools on Roads with Speed Limits higher than 30mph . Department for Transport Circular 41i2413 Setting Local Speed Limits . 'Good Practice Guide on 20 mph Speed Restrictions', Transport Scotland (June 2016 Version 2) -5-

I N FRASTRUCTU RE & TRANSPORTATION ; ROADS SERVICE "TWENTY IS PLENTY' GLENGAPLE

A Council report in July 2012 '20mph Speed Limit Policyand Cycling Walking SaferStreets (CWSS) 2A12-13' agreed a prioritised listing for 20mph speed limit provision (see link below). http://eqenda.dumgal.sov.uUaksdumqal/gsers/puhlic/admin/kab12.pl?cmte=PHE&meet= 4&arg=71 (ltem 14)

For ease the list is as follows: i. urban locations with an injury accident record involving pedestrians or cyclists, ii" ' urban locations with an injury accident record, iii- conclude programme of provision at all schools in region (based on school pupil rolls to prioritise works at schools), iv. urban locations where provision would enable or encourage modalshift (e.g. whetre, for example, provision of a flat top hump or raised table at a junction would benefit pedestrian and/or cycle movements), v. urban locations adjacent to existing 20mph limits where existing speeds are sufficiently low that the limit could be extended with little or no additionalworks, vi. locations requested by the community, and where need and support can be demonstrated (minimum of five residents), vii. large housing areas without a 20mph limit; So, if the Community Council of a typical rural village requested a 20mph speed limit through their main street and there was no injury accident record or high incidences of speeding, it would be placed under priority 6. A primary school without a 20mph speed limit would be priority 3 and would be programmed with greater importance than a priority 6. The current 20mph Speed Limit at Schools programme still has 24 sites out of g8 schools outstanding. With regards to a proposed 20mph Speed Limit for Caerlaverock Primary School, the school has a roll of 24 pupils and is currently 19th on the list ot24 schools still to have a 20mph speed Iimit implemented. Therefore, the main priority of the Speed Limit and Traffic Calming Programme 2018t19 is to continue with the school's programme in conjunction with other speed limit and traffic calming schemes identified in the Programme.

School Road Safety Please the note the following: Extract from D&G Council 'SchoolTransport Policy 2015' Cl. 2.3 The first 2 miles of travel (pupil under 8) or 3 miles (if over 8) is the parents re,sponsibililv and they should ensure that their child reaches the designated pick-up point or the school safely. All routes are assessed on the assumption that the chlld is accompanied by a respons_ible person. Extract from 'School Crossing Patrol Guidelines': 1.5 Parental Responsibility - Even where a School Crossing patrol (SCP) is provided, parents remain responsible for ensuring their children's safety, just as they do when a zebra crossing or pelican crossing is provided. Some parents may believe the -6-

INFRASTRUCTURE & TRANSPORTATION; ROADS SERVICE "TWENW IS PLENTY" GLENCAPLE

Authority assumes responsibility for the safety of their children on their whole journey to and from schoolwhen it provides an SCP. This is a misconception that should be countered, perhaps by conducting local 'awareness-raising' campaigns to reinforce the message of parental responsibility every time a new SCP is appointed. The issue of parental responsibility also needs to be understood clearly by Elected Members, and officially enshrined in policy statements, road safety plans and guidelines. The responsibility for ensvfins the safety of chil4ren travellinq to and from school is, a,nd must remain. a parental qne.

Sp6ed Limit Reviews Previous reviews of speed limits on local roads, in consultation with the then Chief Constable, concluded that speed limits should be evidence led, self-explaining and that Iimits need to be consistent with what drivers would expect to find elsewhere in the region and in the country. lf the existing speed limit were to be reduced/or extended, without good reason and substantiation, there would be little or no compliance from drivers and as such there would be no support from the Roads Authority or . On lengths of road with high reported incidences of speeding and injury collision rates, consideration would be given to temporary traffic data surveys to measure mean speeds and then if required a speed limit review, road safety improvement measures and/ ortraffic calming measures. The roads within Glencaple do not have a history record of reported speeding incidences or of collisions. Although the speed limit is set to advise drivers of the maximum speed limit it should be noted that this is not a target speed and that exceeding the speed limit is breaking the law. Drivers are responsible for their actions and should drive according to the road layout, conditions and in relation to the environment that they are within even if it means driving at a lower speed than advised.

Summary ln relation to the width of the existing cariageway between the schoot and the eastern extents of the village and its capacity to cope with passing vehicles, it should be noted that this is within a 30mph speed limit. There are residential areas in towns throughout Dumfries and Galloway with smaller carriageway widths where vehicles need to judge whether there is sufficient room to pass. Generally, in such instances drivers will show consideration and will allow other vehicles passage at slower speeds where this is little room to manoeuvre. Provision of a footway over this length would be expensive and unjustified given there are no records of reported road safety incidents or issues. The majority of rural roads in Dumfries and Galloway are used by a variety of people for recreation, exercise, commuting and work. People make their own choices and carry out their own assessment of risks and hazards on the roads they choose to use. lncrease in traffic volume and size of traffic is predominant throughout Dumfries and Galloway, and is not limited to Glencaple. We sympathise with regards to this issue, however, due to the nature of some villages i.e. particular layout and geometry we are restricted in how we can assist or indeed if there is any scope to assist without implementing measures which would cause major impact to the character of the village and therefore be unwelcome by the majority of the people who live there. lN FRASTRUCTU RE & TRANSPORTATION ; ROADS SERV|C E "TWENTY IS PLENTY" GLENCAPLE

Dumfries and Galloway Council does take its community and road safety very seriously, both as a regulatory local authority and as an inclusive Council. However due to increasing budgetary constraints across all departments we do need to programme and prioritise both new infrastructure schemes and maintenance of existing assets to create efficiencies and target areas most at need. Areas of need are where there are identifiable safety issues highlighted by an accident history. ln this instance Glencaple is not an area with an accident history and therefore there is no justification for a speed limit review. Finally, a Bill has been published 'Restricted Roads (20mph Speed Limit) (Scofland) Biil' which, is going before committees for review and scrutiny. lf passed by Scottish Parliament, the Bill could become law by the end of 2019, please note a restricted road is a Class C or unclassified road with street lighting placed no more than 185m apart. Local Roads Authorities would obviously be involved in the identification of appropriate roads and the decision making process should the Bill be passed and implemented.

Way Forward Upon review of our detailed re$ponse, we hope you will have a better understanding of policies, procedures and guidelines which the Council need to adhere to when assessing, prioritising and designing road safety and speed limit schemes. I propose a site meeting with yourself in the new year to discuss the following: . Any further queries/ clarification with regards to our response, o Suitable locations for temporary traffic data surveys, and o Possible appropriate and justifiable road infrastructure improvement measures to enhance accessibility and contribute to road safety and traffic calming.

I look forward to hearing from you in January 2019, please contact myself at the above office if you require any further information.

Yours sincerely

Anthony Topping Team Leader Network Strategy and Road Safety