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

Twitter: https://twitter.com/Drivers_London

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TfL Misleads on Safer Speeds

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 – see https://tinyurl.com/rlz4pa5. But we have now discovered that 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 was apparently 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 learn 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 to enable us to work out what the correct figure is, but it is likely to be very much lower. We will advise in due course as it will take some time to analyse the data.

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 now been found to have been fiddling the figures to make spurious claims.

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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

Twitter: https://twitter.com/Drivers_London

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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

Twitter: https://twitter.com/Drivers_London

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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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