Safer Speeds – The Real Data

I have commented before on how Transport for London (TfL) have failed to justify their “Safer Speeds” proposals which includes imposing 20 mph speed limits on many roads. We have previously pointed out how TfL have been misinterpreting police accident data to support their claims that the measures are justified.

For example, they issued a Tweet that said “speed accounts for 37% of all death and serious injuries” in road accidents in London. That figure is simply wrong. The claim was allegedly based on the STATS19 data reported by the police (a form they fill out about every accident involving injuries).  That form allows for multiple factors to be recorded and after submitting a Freedom of Information Act request we learned that they counted all the accidents where factors 306, 307 and 602 were noted.

But factor 602 is described as “Driver/rider either behaved in a negligent or thoughtless manner or was in a hurry….”. Clearly the key word in that sentence is the second “or” when TfL have interpreted it to mean “and”.  There is no basis for claiming that all accidents where factor 602 is attached were rated by the police as ones where a driver was in a hurry. They might have simply been careless. Only where the other factors 306 or 307 were also noted could there be any claim that speed was a factor in the accident.

We now have the complete accident data and the data makes it plain that exceeding the speed limit (factor 306) is a very minor factor in KSIs (Killed and Serious Injuries) in London. It’s actually recorded as a contributory factor in only 5.9% of such accidents in the last five years. That’s actually less than the figure of 7.1% reported by the Department for Transport for the national figures in 2018 – see table below. Clearly tougher enforcement of speed limits is therefore unlikely to have much impact on the overall numbers. That of course is particularly so in London where average traffic speed is typically well below the speed limit.

Contributory Factors and Speed - ras50008

The largest contributory factor by far is “Failed to Look Properly” which accounted for 42% of KSIs in London or 35% nationally. But there are several other factors with higher ratings than “Exceeding the Speed Limit” such as “Poor Turn or Manoeuvre”, “Failed to Judge Other Persons Path…”, “Loss of Control” and “Careless, Reckless or in a Hurry”.

Even if you bundle factors 306 and 307 together only 12% of KSI incidents are included nationally so reducing speed limits is going to have only a small contribution at best to reducing such accidents. It’s reducing the other factors that is the key to substantially reducing road casualties. More driver education, improved roads and research into saccadic masking may be productive.

Note also that a lot of the reported factor 306 and 307 claims of excessive speed and speed above the speed limit might well involve illegal use of vehicles such as stolen vehicles so reducing speed limits will have negligible impact in reality.

There is simply no cost/benefit justification for the Safer Speeds proposals as pointed out in our previous article and TfL have clearly been abusing the data so as to make spurious claims.

Roger Lawson

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Westminster Proposes 20 MPH Limit Everywhere

The City of Westminster is proposing to implement a 20 MPH speed limit on all its roads. The only exception will be those roads they do not control which are TfL controlled roads and where TfL may impose such a limit anyway. This move is despite the fact that a report published by the Department of Transport shows there is no road safety benefit in signed-only 20 MPH limits and there is also no evidence of any other benefits.

Readers should oppose this move, which is in essence a waste of money that would be better spent on other measures, by responding to the public consultation here: https://www.westminster.gov.uk/20mph

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No Justification for 20 MPH Limits in Safer Speeds Proposals

I have written previously on the proposal to introduce a 20 MPH speed limit on major roads in central London, and probably in the rest of London later. I criticised the failure by Transport for London (TfL) to publish any cost/benefit justification and submitted an FOI Act request to obtain that information which TfL refused. See References below for the full story.

After appealing to the Information Commissioners Office (ICO) about the refusal by TfL to provide the requested information, which should have provided a justification for their proposals in advance of the public consultation, I have had my complaint upheld by the ICO and have now received the requested information. See Reference 5 below which contains the Business Case published very recently. This is very similar to a draft published in 2012 which was available well before the consultation was launched and hence should have been made available (See Reference 6). However, the numbers in the later version on which the cost/benefit is calculated were much different with the capital cost being reduced very substantially and the collision reduction benefit almost doubling. The outcome is of course a very clear positive benefit as a result.

It is clear that TfL deliberately concealed the earlier version because it provided marginal benefits. But both versions are seriously defective because they do not include all the costs in the analysis. For example, they do not include:

  • The economic costs of increased journey times. Although average speeds during a lot of the day are less than 20 mph on these roads, they are higher at other times and ignore the fact that between junctions and traffic lights/pedestrian crossings, the speeds are higher.
  • No costs are included for enforcement of the 20 MPH limits.
  • No costs imposed on drivers from paying fines for exceeding the limits are included, which will likely be quite substantial.
  • They discount the suggestion that lower speeds would increase emissions from vehicles and hence have not evaluated it which is contrary to readily available evidence on that issue.

In other words, TfL concealed the original “Business Case” on spurious grounds thus defeating a fair public consultation and then adjusted the numbers to give the required answer while not including all the associated costs. This demonstrates exactly why TfL are not to be trusted and should be reformed.

But one moral for readers is do not accept refusals to FOI Act requests. Such refusals are often unreasonable and are just a mechanism to delay answering and hence concealing information until it is too late to be useful. This is of course unprincipled in the extreme. TfL do this repeatedly and perhaps the ICO will deal properly with this issue if they get enough complaints.

In the meantime the Mayor of London, Sadiq Khan, who is a party to this dubious activity should ensure TfL act more responsibly. I will be sending him a complaint on this issue.

Reference 1: Consultations in Name Only and Safer Speeds: https://tinyurl.com/y3gqh5hh

Reference 2: Consultations in Name Only: https://tinyurl.com/y6lpuusp

Reference 3: 20 MPH Speed Limits in London on Major Roads: https://tinyurl.com/y5ntxu4a

Reference 4: 20 MPH Speed Limits Spreading in London: https://tinyurl.com/y3r9bddp

Reference 5: Business Case 2019: https://tinyurl.com/yxt9fy2d

Reference 6: Business Case 2012: https://tinyurl.com/y2zd7hko

Roger Lawson

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20 MPH Speed Limits in London on Major Roads

20 MPH SignTransport for London (TfL) are pushing ahead with their proposals for “Safer Speeds” in central London – which means 20 MPH speed limits enforced by cameras on many major roads in London. They have published the results of their fake public consultation on this subject which we have previously criticised as a consultation “in name only” including a refusal by TfL to provide key information on the proposals such as any cost/benefit analysis.

The public consultation used leading questions and was a complete distortion of how consultations should be performed – see https://tinyurl.com/y3gqh5hh for more information on how TfL ignores public opinion and does fake consultations.

You can read a report from TfL on the Safer Speeds consultation here: https://tinyurl.com/y3gqh5hh . On this very important topic to all road users, of which there are millions in London, they received less than 2,000 responses. Thirty nine percent of the responses came from cyclists which just shows how that pressure group dominates such consultations and are unrepresentative of the general public.

TfL propose to implement the 20 MPH limit on key roads in central London by 2020, and then in phase 2 they will extend lower speed limits to the inner ring road, and high-risk roads and town centre roads in the rest of London by 2024. In other words they will be coming to TfL controlled roads (i.e. main roads) even in outer London. Raised tables will be used at pedestrian crossings and elsewhere to slow traffic and all speed cameras will be recalibrated to the new lower speeds. Vehicle Activated Signs (VAS) will also be used to ensure drivers are aware of the new limits.

What is the likely impact on road casualties? From the experience of the City of London where a 20 MPH limit has been in use for some time, the impact will be negligible. But it will make life more difficult for drivers and result in many more speeding fines as the police will be stepping up enforcement measures. This is one more step in the Mayor’s Transport Strategy to deter people from using cars in London.

London is becoming a ghetto of anti-car fanatics. These proposals are being advocated in the name of road safety despite the fact that TfL refuse to give any estimates of the alleged benefits, probably because they know they will turn out to be false. The proposals are likely to be an enormous waste of money and contribute further to TfL’s budget deficit.

We are still pursuing a FOI Act request to obtain TfL’s internal reports justifying these proposals which in their usual anti-democratic approach they have refused to release. We suggest readers complain to their local MP and Greater London Assembly Member about this matter.

Roger Lawson

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Press Release: ABD Launches Campaign Against 20 MPH Speed Limits

20 MPH SignThe Alliance of British Drivers (ABD) has launched a campaign against blanket 20 MPH speed limits under the name “20s Senseless” – see www.20ssenseless.org

The reason for doing this is that there is much misinformation being spread by campaigners for such speed limits. What has been happening is that the anti-car activists encouraged by those campaigning for 20 MPH speed limits are now wasting millions of pounds nationwide when that money would have been better spent on other road safety measures – such as road engineering and education of younger drivers.

The Department for Transport (DfT) published the most authoritative study to date on the impact of wide-area signed-only 20 mph speed limits last year. It showed that there is no road safety benefit whatsoever from such schemes. In addition they have negligible impact on modal shift or on traffic speeds.

This was the long-awaited evidence that enormous amounts of money are being wasted on implementing 20 mph schemes which could have been spent instead on more effective road safety measures. In London alone, it is estimated that tens of millions of pounds have been spent on 20-mph signed-only schemes to no effect and nationwide it must run into hundreds of millions of pounds.

The Alliance of British Drivers (ABD) has long called for “evidence-based” road safety policies. The evidence on 20 MPH schemes should not be ignored.

The DfT report can be read here: https://www.gov.uk/government/publications/20-mph-speed-limits-on-roads . Key paragraphs from the report are:

“The evidence available to date shows no significant change in the short term in collisions and casualties, in the majority of the case studies (including the aggregated set of residential case studies).”

“Journey speed analysis shows that the median speed has fallen by 0.7mph in residential areas and 0.9mph in city centre areas.”

Note that the ABD is not opposed to the use of 20-mph speed limits where it might be of benefit or where compliance will be high but it is not the solution to all road safety problems and simply sticking up signs is a waste of money. The simplistic solutions proposed by advocates of wide area signed-only 20 MPH schemes do not work to reduce the Killed and Seriously Injured (KSIs) on our roads to any significant extent. Money is being wasted on them that could be better used to reduce KSIs in other ways.

20 MPH speed limits should be opposed by all road users. They are indeed SENSELESS.

For more information contact: Roger Lawson on 020-8295-0378
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Consultations in Name Only and “Safer Speeds”

I covered the issue of Transport for London (TfL) doing public consultations that do not provide enough information and are already decided in a previous note (see https://abdlondon.wordpress.com/2019/06/24/consultations-in-name-only/#comments ).

Subsequently I used the Freedom of Information Act to ask TfL for their consultation policy documents and guidelines, plus information on the costs and any cost/benefit analysis of the “Safer Speeds for London” proposals. That’s the proposal which will slow traffic to 20 mph on many major London roads and where there was a short (now closed) public consultation which did not contain evidence for justification.

TfL has supplied the information on their consultation policies and procedures and if anyone would like a copy, please let me know. In Principle 3 of the TfL Consultation Policy it says “We must provide consultees with enough information to understand what we are proposing so that they can respond on an informed basis”. That was certainly not done on the Safer Speeds proposal.

As regards my request for costs and cost/benefit data on the Safer Speeds proposal, TfL rejected my request on the basis that it is exempt information because the information requested “is intended for future publication” – see Section 22 of the FOI Act, and that it was not justified in the public interest. What is the point in publishing that information after the public consultation has ended? It looks like a simple attempt to avoid answering, or are they saying that they have not looked at the costs and costs/benefit before putting forward the Safer Speeds proposal? Either way, it is unreasonable so I am appealing.

This is of course the typical run around one gets with TfL when they don’t wish to disclose information. TfL are a secretive organisation that likes to develop proposals and present them as a fait-accompli with only public consultation on trivia. It has been that way ever since Ken Livingstone was in charge. It surely needs to change!

But according to a report in Local Transport Today (LTT) TfL is heading in the opposite direction. The report said that TfL is changing the way it engages and consults on active travel schemes. There will be “a greater emphasis on local engagement either in advance of, or potentially instead of, formal consultation”. It is suggested that to get the 73 safety critical road junctions in London improved they need to push through with projects and the public “has a limited ability to influence our proposals” – so there is no point in statutory consultations. But It also suggests road users will have less opportunity to comment, and of course a non-statutory consultation leaves little ability to mount a legal challenge.

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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Huge Increase in Speed Enforcement

Speed Camera 4The magazine Local Transport Today have run a story headlined “Met Police prepares for huge increase in speed enforcement”. They report that London police are planning a huge programme of speed limit enforcement with the aim of catching a million offenders a year. That’s up from 160,000 per annum at present.

That will be achieved by a large increase in speed camera activities including more mobile speed enforcement equipment. This is likely to mean aggressive enforcement of the 20 mph speed limits being brought in on many London roads.

The above information was disclosed at a meeting of London Councils, the representative body for London boroughs. That organisation is also looking at “decriminalisation” of speeding offences, which would effectively make it possible for local boroughs to enforce speed limits in the same way they do for parking offences at present.

What’s the real motivation behind these moves? It’s almost certainly about filling the coffers of the police by the offer of speed awareness courses, and also enabling local councils to fill their budget holes by also taking a cut of fees paid. Both organisations are under financial pressure and the Mayor of London, Sadiq Khan, is unwilling to help with the police budgets but would rather spend money on other things.

There is no evidence that lowering speed limits or more aggressive enforcement has any significant impact on road safety statistics. But politicians like gestures and many are only too pleased to kowtow to the anti-car fanatics. When it can be combined with excuses for revenue raising, it’s difficult to stop.

Just make sure you oppose it though.

Roger Lawson

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20 MPH Speed Limits Spreading in London

20 MPH Sign

Transport for London (TfL) have announced that 20 MPH speed limits are to be imposed on many central London roads. That will include many of the key arterial routes including:

Victoria Embankment, Upper/Lower Thames Street and Tower Hill, Albert Embankment, Millbank, Borough High Street, Blackfriars Road, Elephant and Castle roads and Aldgate “gyratory” even though that no longer exists.

These proposals are part of the “Vision Zero Action Plan” and Mayor Sadiq Khan’s Transport Strategy which the ABD has strongly opposed (see  https://www.freedomfordrivers.org/against-mts.htm for campaign details). It’s just another step in discouraging and impeding vehicle traffic which is adding to journey times and damaging London.

Will it have any impact on road casualties as claimed? Highly unlikely as the City of London wide-area 20-MPH scheme has demonstrated where there was no overall reduction in road accidents and minor casualties actually increased. The solution to road casualties is to look at where accidents occur and re-engineer the roads. Not more speed cameras and lower speed limits.

There is a public consultation and more details of the proposal you can access here: https://consultations.tfl.gov.uk/streets/20/ . PLEASE MAKE SURE YOU RESPOND TO THE PUBLIC CONSULTATION ASAP.

These are some of the comments the ABD has already submitted which you can copy:

“There proposals will not have any benefit for those walking and cycling but as it will slow bus journeys, the numbers travelling by bus will continue to fall as they have been lately, thus reducing TfL income.

As regards vehicle users, I think they will ignore the 20 limit as they do elsewhere if they consider the new speed limit inappropriate, as it undoubtedly will be in certain traffic conditions. It will just result in more speeding prosecutions which is already being used by the police to finance their operations by diversion to speed awareness courses – a totally unethical practice.

It will add delays to journeys. To minimise the impact, the solution would be to look at road engineering measures where too many accidents occur instead – and I don’t mean speed humps or tables which have a very negative impact on those with medical conditions. Indeed I would suggest that you are discriminating against the disabled by implementing raised tables.

A 20-mph speed limit will not reduce casualties as demonstrated by the statistics from the City of London’s 20 mph speed limit which actually resulted in minor accidents increasing and no overall benefit.

In summary we are opposed to these proposals in general, and there is no cost, or cost/benefit justification provided – this is yet another disgraceful example of a defective public consultation from TfL, with no simple question as to whether people support the proposals or not.”

Roger Lawson

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Richmond Ignores 20 Mph Vote, and Wandsworth’s Doubtful Claims

 

The London Borough of Richmond is set to ignore a public consultation where a majority of respondents opposed the introduction of a borough-wide 20 mph speed limit. The almost 10,000 respondents voted 47.9% in favour and 49.7% against. There was even less support for the notion that 20 mph speed limits will improve air quality and reduce car use.

However they have made some changes to the original proposals with more roads excluded from the scheme. See https://tinyurl.com/y2qcfz2m for more details.

Note that the LibDems won control of Richmond Council in 2018 when it had previously been Conservative controlled. They took over from LibDems in 2010 after the latter repeatedly ignored public opinion, e.g. over emission-based permit parking charges.

Comment: It looks like the LibDems are back to ignoring the results of public consultations, presumably because they think they know better. A very dubious decision which they will surely live to regret.

Wandsworth Claim 20 Mph Success, But Is It?

Meanwhile the neighbouring London Borough of Wandsworth have claimed a success for their borough-wide 20 Mph scheme which was implemented in 2017. Analysis of the first year post implementation data indicated a reduction of 9% in casualties although mean traffic speeds only fell by 0.6 mph. On that basis they have claimed it to be a success although casualties actually fell by 28% across all roads in the borough (which includes the Transport for London controlled main roads where the speed limit generally remained unchanged).

The other problem with this data is that using only a one-year post implementation period is known to distort the figures. A three-year before and after period is recommended by road safety engineers to avoid temporary reactions to perceived road changes.

But Wandsworth is claiming it as a success anyway and is looking to impose 20 mph limits on some major roads such as Putney High Street.

Roger Lawson

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Bromley LIP – Better But Not Good Enough

My previous article was on the draft Local Implementation Plan (LIP) for Transport published by the London Borough of Lambeth. I suggested their past policies have been a failure both to improve road safety and provide an efficient transport network. The adjacent Borough of Bromley has now published their LIP and opened a public consultation on it. This article explains in brief some of the key points.

You would expect that Bromley’s LIP would be more sympathetic to vehicle users, and so it is to some extent, but it’s far from perfect. Bromley is a large borough with very high car ownership levels and some parts of the borough, such as Biggin Hill, have relatively low public transport accessibility. Poor orbital connectivity of public transport is also a problem that encourages car use. It is also hilly in parts which mitigates against cycling. But the future transport policies are to a large extent by the Mayor of London, Sadiq Khan – indeed I suggest that this LIP kowtows too much to the Mayor’s desires.

But Bromley’s population is growing like most London boroughs so traffic congestion is getting worse. The Mayor would like 80% of trips in London to be taken but Bromley is proposing targets of 47% by 2021 (1% change) and 60% by 2041. These figures will be achieved by encouraging more walking and cycling and by public transport improvements. To encourage cycling it is proposed to develop the Strategic Cycle Network and expand Quietways.

As regards road safety, Bromley has a good record – reducing KSIs from 230 in 1999 to 50 in 2014. This has been done by concentrating efforts on accident hot spots and good education programmes. However there was an increase in the last couple of years even allowing for adjusting to the change in accident recording. As in Lambeth, there is a disproportionate casualty incidence for pedal cyclists. Yes cycling is dangerous. This was made clear by a recent press release by a road safety organisation which said that people on two wheels face a 63 times higher risk of being killed or seriously injured (KSI) per mile travelled than car drivers. But the Mayor still wants us to cycle which might be good for your health in other ways but is clearly risky.

As regards safe speeds, the borough suggests that removing entre line markings can have a significant impact on traffic speed. But does it make the roads safer? And this is what they have to say on 20 mph limits which is more sensible: “With regard to 20mph speed limits and zones, the Borough does not believe that a blanket approach is the most effective means of improving road safety. Too often such schemes do nothing to change the characteristics of the street and lead to only quite insignificant reductions in speed and the cost of a Borough wide approach would also mean that resources would be diverted from schemes that tackle actual hot spots and priority areas that require more significant engineering measures. There is also a concern that borough wide approach could lead to an element of driver fatigue with the result that the key areas for driver attention are no longer prominent. The Borough will therefore adopt a targeted approach to the introduction of 20mph speed limits or advisory limits…..”. An eminently reasonable approach and which accords with the evidence on 20-mph schemes just published by the Department for Transport (DfT).

Apart from relieving traffic congestion by “mode shift”, they propose to promote the use of car clubs and various approaches to reduce van deliveries such as central consolidation centres with local cargo bike provision.

Air quality is not a major problem in Bromley but there are some “hot spots” that need improving. These will be tackled by specific measures – details to follow in the Borough’s Air Quality Action Plan, but the measures look relatively harmless such as encouragement of electric vehicles and anti-idling measures.

There are many initiatives proposed to improve access to public transport such as to buses and train stations which are positive, but they also wish to improve bus journey times. One proposal to assist is to extend the hours on some bus lanes. The ABD believes bus lanes should be removed not extended. They create congestion for other vehicles and do not necessarily assist with improving total people movement.

Many of the proposals do of course depend on funding from Transport for London (TfL) as local boroughs have very little of their own funding for transport programmes. This is evident from page 91 of the LIP. That means, the Mayor is dictating where money is spent, with the result that there is too much on cycling and pedestrian encouragement and too little on improving the road network for other users.

Will the draft Bromley LIP get past TfL and the Mayor, who have to approve such documents? We will have to wait and see. In the meantime you should respond to the on-line consultation here: https://www.bromley.gov.uk/localimplementationplan where you can also download the full LIP document to read if you wish to do so.

DO TELL THEM WHAT YOU THINK!

Roger Lawson

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