ROAD POLICING UNIT TRAFFIC MANAGEMENT OPERATIONS COMMAND Your Ref: CMS-1023-MM Our Ref: TMW/060/15/IWJ Date: 26th March 2015 Contact Name: Ian Jeffrey Email: [email protected] Mobile: 07979 245516 Dear Mr Moore, West Sussex County Council (Ansty and Staplefield and Cuckfield) (Brook Street (B2036)) (30mph Speed Limit) Order 2015 - Statutory Consultation I refer to your letter of formal consultation, dated the 19 th March 2015, in respect of the above matter. The police position remains unchanged since it was outlined in our informal response to the Authority in an email dated the 19th December 2013. Whilst Sussex Police acknowledge the aspirations of the local community, the fact remains that decision making in respect of speed limit setting must remain objective and based upon established engineering principles and the Department for Transport guidance as published in their document Circular Roads 1/2013. Whilst it is noted the Member’s easement to the WSCC Speed Management Policy granted in 2010 avoids the requirement for the proposed speed limit to meet the speed and route assessment criteria, the fact remains it does not reflect the underlying principles as outlined in paragraph 27 of Circular Roads and therefore cannot be supported by the police. The reason the Police are consulted upon any new traffic regulation order is for them to make a professional assessment and comment upon possible compliance levels and potential Crime and Disorder Act issues which could be generated following its introduction. /cont… Mr M Moore, Legal Officer, Joint TRO Team, Ground Floor, Northleigh, County Hall, Chichester, West Sussex, PO19 1QT Police Station, Ham Road, Shoreham By Sea, West Sussex BN43 6DB Website: http://www.sussex police.uk To assess how appropriate a new speed limit is likely to be, it is necessary to establish the mean speed of traffic using the road. In West Sussex mean speeds below 33mph are considered appropriate for a 30mph speed limit. In this case, the speed data available to us indicates the most appropriate speed limit for this section of road is 40mph; it enjoys a reasonable level of compliance confirming the limit is self enforcing and therefore fits the WSCC strategic philosophy in relation to speed limit setting. Contrary to popular belief, just introducing a lower limit and solely relying upon signing is not in itself a guarantee that it will work effectively. Experience has shown where this is the case speeds reduce by only 2mph. Many such examples can readily be found within the Mid Sussex area. Research and experience confirms that the implementation of an unrealistic or inappropriate speed limit is most likely not to be adhered to by the motoring public. As a consequence, the unrealised expectations of local residents will generate complaints to the police for enforcement action. This is already happening in relation to the existing limit; therefore the likelihood is there will be an increase in such requests to us. This is clearly a Crime and Disorder Act issue. Since 1998, Sussex Police has been a strong participant in the promotion of the West Sussex rural village speed limit programme. We have supported the introduction of at least 90 village speed limits. Regrettably, we cannot support this proposal and formally object for the following reasons: • The WSCC policy easement avoids the use and application of national guidance and best practice; • If national guidance and best practice were to be applied the proposal would not meet the implementation criteria; • The differential between the mean speed and the existing speed assessment criterion is too great and compliance levels are likely to be low; • Pedestrians and other vulnerable road users will have the expectation that traffic will be travelling at 30mph or slower, so may unwittingly endanger themselves when using the road as a result of the subsequent speed differential; • The introduction of a lower limit will raise public expectation and if unrealised will generate complaints to the police for blanket enforcement activity, as already exampled elsewhere within the Mid Sussex area; • We anticipate Crime and Disorder Act issues will be generated where there were none or few previously; /cont… • There are no additional gravity factors identified within the proposal that would justify the lowering of the limit. It is our view that in every case there must be a proven need for the lower speed limit, it must be clear and the motorist must have the ability to comply. The Service has limited capacity and resilience and will assume that if correctly placed, speed limits will be self enforcing and that the Highway Authority will be responsible for ensuring it meets those aims. In conclusion, speed limits should be set following proper assessment, based upon a set of appropriate and consistently applied criteria that resonate with the expectations of both the driver and the public alike, to do otherwise undermines the essential legitimacy of speed limit setting and the rule of law itself. Yours sincerely, Ian Jeffrey Traffic Management Officer (West) Road Policing Unit Operations Command .