Ambitions and evidence

a. The strategy sets targets of a 65 per cent reduction in people killed or seriously injured (KSI), and a 70 per cent reduction in child KSIs, by 2035.

Do these targets reflect the right level of ambition?

Ambition

These targets certainly reflect the right level of ambition. But we doubt whether they have a basis other than ambition.

Safe System

We note that in the words of the minister “Addressing road safety needs a systemic solution, which is why the Safe System lies at the heart of our strategy.” However, the Safe System approach is not well understood by the public, councillors, politicians, police and some traffic engineers. Even where it is understood, a background of “motonormativity” and “pluralistic ignorance” influences what individuals may support, plan and implement. The Safe System approach is just as much cultural as technical and ensuring that a Safe System culture exists in town and county halls, government offices and the public will be key to these targets being achievable.

Baseline for Wales/Scotland Targets

We note that Wales and Scotland have already adopted a Safe System Approach and for their urban/village and vulnerable road users a key intervention was the setting of 20mph limits as a norm. For those countries, consider an earlier baseline, to take account of the progress already made, particularly on 20/30mph roads, such as the 26% reduction in casualties in Wales.

b. Are governance, delivery and resourcing arrangements across Government departments and key partners strong enough to achieve these targets?

No. A Safe System approach needs buy-in and support from many government departments beyond DfT, including Home Office, Public Health, NHS and Treasury. This is not evident in the strategy.

In particular, there is insufficient integration with the Home Office (with respect to roads policing) and we doubt that the DfT has sufficient resources to deliver the strategy targets.

c. Are the measures set out in the Strategy collectively sufficient to deliver its targets? What further measures, if any, would strengthen its impact?

No. The strategy does not define individually how much of a reduction each measure will deliver. Therefore it is impossible to say whether they will collectively deliver the targets. Without such individual metrics, it is highly unlikely that the targets will be reached.

Furthermore, an analysis of the Strategy shows that the so-called “commitments” are not actually measures.  Across the 4 themes, are commitments to consult, consider, pilot, publish, explore, collaborate, research, prioritise, review and gather evidence, rather than implement.

Whilst “consultation” may well be a stage in the delivery of an intervention, surely the commitment should be to the intervention itself and its consequential reduction in casualties, rather than merely to a consultation.

Delays in progressing through consultation stages to actions will inevitably delay and defer implementation of life-saving initiatives and critically impact meeting the strategy targets. It will back-end any progress on saving lives and push consequential reductions beyond 2030.

A stronger strategy would have identified the possible contribution of each of the initiatives to reaching the target reductions. This would include a matrix of initiatives, their potential timescales/costs and the expected contribution to meeting the targets.  

Much of the low-hanging fruit have well established and evidenced data showing their effectiveness and costs. This is especially true for the adoption of 20mph as an urban/village default (either legislative as in Wales or de-facto as in Scotland).  

Some population-wide interventions will reduce casualties for all types of road users in providing protection and others will be sector specific.

There are equally no interim targets. Indeed, we would suggest that some interventions will still be in the process of being considered or consulted on by the halfway point in 2030. If the record of the DfT consideration of e-scooters provides an indication of the possible pace of progress when “considering or piloting” then this was commenced in July 2020 and the pilot is expected to end in May 2028. Meantime throughout Europe and elsewhere e-scooters are providing much needed micro-mobility in communities in place of motor traffic.

The strategy highlights its belief that :-

“Speed is one of the ‘Fatal Four’ and safe speeds are a vital pillar of the Safe System.”

And also says:-

“Speed limits are designed to reduce the likelihood and impact of collisions. Local authorities are responsible for setting appropriate speed limits in their areas and the government provides comprehensive guidance to these authorities on doing so.”

This is misleading. “National” speed limits for England are set by the UK Government and represent the value placed on setting such a maximum speed for motor vehicles based on the users and risks on the roads. Local authorities’ responsibility is limited to altering these where local conditions would require a different limit.

It is illogical for the Government to set a national 30mph limit for urban/village roads and then expect local authorities to change it to 20mph for most roads because 30mph is inappropriate.

Note the current guidance is not appropriate or aligned with a Safe System.

We have already acknowledged the importance of developing a Safe System culture at all levels of decision-making. There is a danger that unless an urgent engagement and education program is initiated with professionals, decision-makers and the public then progress will be thwarted. Motornormativity and pluralistic ignorance will create discord and contention over many of the life-saving initiatives being proposed. It is encouraging that the mismatch between what policy-makers “know” is correct and what the public “believe”, is referenced in the strategy with regard to the 2022 Highway Code update not being publicly recognised. It is vital that the lessons of “too little public engagement” are learned with regard to adopting a Safe System approach to road safety.

d. Are the measures set out in the Strategy based on robust evidence?

The evidence on many of the measures is sound and robust, coming from implementations in the UK and elsewhere. However the actual strategy seems to be selective in the evidence it references.

It fails to reference the 26% reduction in casualties in Wales from its default 20mph. Evidence of 20+% reductions in casualties exists from many previous implementations of area-wide 20mph in London, Edinburgh, and elsewhere.

e. The Government has said its Strategy is informed by Sweden’s Safe System approach. What other international or UK examples offer the most relevant lessons for reducing deaths and serious injuries?

Informed by? Yes, but there is little evidence that it is truly aligned. If it were then it would be looking far more closely at what is already proven to work within a Safe System.

Much of the Safe System approach was incorporated into the Stockholm Declaration announced at the 3rd Global Ministerial Conference in 2020. This was endorsed by the UK government and incorporated into the UN Decade of Action for Road Safety 2021-2030. The Strategy recognises the importance of Safe Speeds as one of the “Fatal Four” and a “vital pillar of the Safe System”, yet ignores completely Declaration 11:

“Focus on speed management, including the strengthening of law enforcement to prevent speeding and mandate a maximum road travel speed of 30 km/h in areas where vulnerable road users and vehicles mix in a frequent and planned manner, except where strong evidence exists that higher speeds are safe, noting that efforts to reduce speed in general will have a beneficial impact on air quality and climate change as well as being vital to reduce road traffic deaths and injuries;”

There is not a single mention of 20mph being the appropriate speed for where motor vehicles and vulnerable road users mix. In addition, the section of the strategy “Theme 2 - Ensuring infrastructure is safe” features an image of a clearly residential road with a Speed Indicator Device showing “thank you” to a driver and an indicated speed of 27mph. This shows a fundamental ignorance of what is a safe speed or what comprises a Safe System.

Urban/village 30km/h speed limits are recognised globally as being at the “heart” of a Safe System. Wales and Scotland have already acted on making 20mph the urban/village norm. Why has the strategy failed to even mention the initiative that is at the core of the Safe System in an urban/village and vulnerable road user context?

Theme 1: Supporting road users

There is a danger that the theme portrays the view that it is individual types of road user that that are responsible for the risks and hazards on the roads, both to themselves and others. It also risks blaming a particular group in society, when the key problem is that of motornormativity: societal acceptance of behaviour on the road that would not be acceptable in other circumstances.

f. What measures would be most effective in reducing deaths and serious injuries involving new and novice drivers? What are the likely impacts of introducing a minimum learning period for learner drivers?

20mph as a default urban/village speed limit would enable learner and novice drivers an environment that is for more forgiving of mistakes. It would also allow others, either in motor vehicles, on motorbikes, on pedals or on foot to have far more time and space to take avoiding action in such circumstances.

g. What is the right approach to safe driving later in life? What safeguards are required to protect both safety and independence of older drivers?

20mph as a default urban/village speed limit would enable older drivers an environment that is for more forgiving of mistakes. It would also allow others, either in motor vehicles on motorbikes, on pedals or on foot to have far more time and space to take avoiding action in such circumstances.

In addition, a 20mph environment is far more supportive of elderly mobility by walking or cycling. So helping to maintain cognitive skills and physical capabilities that prolong elderly well-being.

h. What should the proposed work-related road safety charter require of organisations that employ people to drive or ride for work?

Driving for work is currently outside the responsibilities of employers as legislated by Health and Safety Law. Compulsory ISA, black box tracking of driving standards and appropriate sanctions can all be used to minimise danger to employees.

i. To what extent does fear of traffic danger deter certain modes of travel, particularly walking and cycling, and what measures would be most effective in addressing this?

Fear of traffic coupled with motornormativity that implies an acceptance of the danger from motor vehicles is a huge barrier to people walking and cycling. This is evidenced in multiple DfT National Travel Surveys.

Lowering the national speed limit for urban/village (restricted) roads to 20mph with local authorities able to except up where evidentially proven to be safe for vulnerable road users is a key intervention to protect pedestrians and cyclists.

Note that Wales has just legislated to allow Highway Authorities to create side road zebra crossings where a side road at 20mph meets a main road at 20mph. These allow black and white markings without the need for powered Belisha Beacons or zig-zags and endorses the 2022 Highway Code update regarding road user hierarchy.

j. What should reform of motorcycle training, testing and licensing look like in practice?

Theme 2: Taking advantage of technology, data and innovation for safer vehicles and post collision care

k. How can Government maximise the safety benefits of Advanced Driver Assistance Systems (ADAS) and ensure they are used safely and appropriately?

Many people with ADAS on their vehicles have never had any instruction on how they are used. Many will turn individual features off through fear and ignorance. Instruction could be made compulsory on the handover of any new car.

ISA would be far more effective if there were a national digitisation of speed limits and update to appropriate data providers.

l. What is the right approach to strengthening vehicle safety standards? What measures should the Government prioritise in response to issues such as headlamp glare, increasing vehicle size and any broader issues not currently being considered by the Government’s consultation?

The Government should align and adopt EU standards on vehicles.

Size of vehicle and driver sightlines should be a consideration in recognising the dangers of larger vehicles, especially for vulnerable road users.

There should be a national adoption of the HGV requirements in London regarding visibility.

Theme 3: Ensuring infrastructure is safe

m. How should evidence on the relationship between speed limits and safety influence new guidance? Does the Strategy strike the correct balance between a nationally-set direction and local decision-making regarding speed?

The evidence is absolutely clear about setting lower speed limits and that survivable speeds should be set nationally, with local authorities able to increase where appropriate.

This is a key aspect of the Safe System. We recommend the CIHT report on "Progressing the UK towards Safe System implementation" at:

https://www.ciht.org.uk/knowledge-resource-centre/resources/policy-technical/progressing-the-uk-towards-safe-system-implementation/

This calls for the UK Government to work with devolved governments and road authorities to ensure that speed limits, and guidance on setting speed limits, are better aligned with survivable speeds.

In the case of urban/village setting with roads shared with pedestrians and cyclists this is 20mph, with local authorities able to set higher limits where evidentially justified. This is the approach taken in Wales by national legislation and in Scotland by national guidance. It specifically gives criteria such as the presence of housing, schools, community buildings, and retail premises which determine whether the speed limit should be presumed to be set at 20mph or 30mph.

With clear evidence from Wales, Scotland and elsewhere of a 20-30% reduction in casualties when implementing 20mph as an urban/village norm we consider it would be negligent for the Government not to adopt this initiative for England. The Government has a clear responsibility for setting the default national speed limits and giving guidance on where local authorities can adjust it due to local characteristics of road use.  

The current guidance on Setting Local Speed Limits is neither "best practice" nor aligned with a Safe System. It is rooted in 1990s orthodoxy on speed limits and has been "tweaked" by successive governments in 2006, 2013 and 2024. It is contradictory in requiring highway authorities to take "full account of the needs of vulnerable road users", whilst at the same time basing limits on what motorists "think" is appropriate. Already 60 of the 154 English Highway Authorities in England, representing a population of 25 million out of 58 million people, have now rejected the guidance in setting 30mph as a norm for restricted roads. In order for the guidance to reflect a Safe System principle, its current form is not suited to further modification and a complete re-write is needed. In doing so, it could beneficially use the criteria for setting urban speed limits as used in Wales and Scotland which are both based on a Safe System approach.

In acknowledging that such a re-write will take time, the Government could issue an interim speed limit circular based on the Scottish criteria for 20mph within the context of a national 30mph limit. This states :-

The Road Assessment Criteria

From June 2022 Road authorities began assessing their 30mph road network to ascertain roads which are appropriate for a lower speed limit of 20mph. To apply a level of consistency when assessing their road network, the following road criteria was created and was used by all road authorities.

Identifying any of the following place criteria on a road with a speed limit of 30mph will give an indication that the road is appropriate for a reduced speed limit of 20mph. Several factors should be considered when making the assessment which include - but are not restricted to the following:

1) Is the road within 100 m walk of any educational setting e.g. Early years, primary, secondary, further & higher education.

2) Does the number of residential and/or retail premises fronting the road (on one or both sides) exceed 20 over a continuous road length of between 400 – 600 m.

 3) Other key buildings which attract members of the public should also be considered.

4) Is the road within 100 m walk of an area of public interest such as a community centre, place of worship, sports facility (including playparks), hospital, GP, or health centre.

5) Does the composition of road users imply a lower speed of 20mph which will improve the conditions and facilities for vulnerable road users and other mode shift. (build capacity by reflecting on future delivery plans such as active and sustainable travel, consider existing and future levels of vulnerable road users)

6) Will the road, surrounding environment and the community be improved by a lower speed limit of 20mph e.g. quality of life, social cohesiveness, severance, noise, or air quality, active travel)

Points to Note - The presumption is that all 30mph roads are appropriate for a lower speed limit of 20 mph. However, there will be some anomalies, where roads meet the criteria but are not appropriate and others which do not meet the place criteria but are appropriate for a 20mph speed limit. This is where local knowledge and community feedback is key to setting the most appropriate speed limit for the environment.

In general, a road suitable to remain at 30mph will typically be on A and B Class roads with little frontage activity and where people walking, wheeling, and cycling do not need to share space with motor traffic.

A minimum road length for the speed limit is suggested between 400-600 m. The length adopted will depend on the conditions at or beyond the end points.

Note that there is a precedent for this. In December 2009 the DfT issued a Call for Comments on changes to guidance and stated:

"We would ask you to use the advice contained in his letter to continue with your speed management activity until the final new guidance is in place."

Based on results and evidence from Wales, Scotland and other places we estimate that changing most 30mph roads in England to 20mph deliver one tenth of the Government's 65% target for KSI reductions. For child KSIs the contribution would be even greater. This cannot be ignored. Given all the potential for "consultation" and "piloting" actions in the strategy to defer and delay actual interventions it is essential that such "low-hanging", evidentially-proven and cost effective measures be adopted in the early years of the strategy. 20mph as an urban/village norm is just such an initiative and should be progressed without delay bringing the same benefits to England and its vulnerable road users as in Scotland and Wales.

We also note that the Safety Performance Indicator 11 on speed relates to “Proportion of traffic volume with drivers travelling within the speed limit on 20mph/30mph/national speed limit roads.” Besides being a very coarse binary indicator of speed compliance, DfT has just 8 20mph sites where it monitors such compliance. It also states in annual reports that these are “free-flowing” and atypical of most 20mph roads. Hence are of limited benefit or relevance to compliance levels.

n. What measures would be most effective in improving safety on rural roads, and is the Strategy’s proposed approach sufficient?

Defining the purpose of a road and setting appropriate speed limits accordingly.

o. What scope is there for road design and maintenance to further improve safety?

Theme 4: Robust enforcement to protect all road users

p. What measures would most improve compliance and deterrence in relation to motoring offences?

Which such offences have the biggest impacts on collision and casualty rates?

Home office type approval is holding back use of newer technology. It is very slow to adopt new technologies and insistence on double verification of speed is making speed detection devices far more expensive than is needed.

Chief Constables already have (but do not use) the power to delegate enforcement to other organisations such as councils.

Police can use ASBOs which don’t need type approved speed detectors, just the officer’s judgement that a nuisance has been observed and could be assisted by non-type approved devices.

Police have targets only on KSI reduction which is not aligned with the many targets by LAs on public realm and road. Eg public health, active travel, emissions, etc. That mismatch limits collaboration between police and LAs

Police generally have little knowledge or training in the Safe System approach, and hence actually oppose many implementations such as lower speed limits that are beneficial.

Police should widen their focus from site-specific speed enforcement to network-wide compliance.

q. What role do the type and severity of sanctions play in deterring dangerous driving, and which sanctioning approaches are most effective at changing driver behaviour?

Probably limited, but the excuse of ‘hardship’ being used to avoid sanction should be abolished

Consideration should be given to fines based on income as well as severity of the crime. This applies in other countries.