The Scottish Government has published its Road Safety Framework to 2030 Draft for consultation.

We applaud the vision within this that "Our vision is for Scotland to have the best road safety performance in the world by 2030." 

Scotland's road fatalities per million population stands at 30 this is considerably greater than leaders such as Iceland at 17 and Sweden at 22. Whilst such a radical vision is laudable we are concerned that the plans are not radical enough to catch up and overtake other countries in terms of road safety.

Our response to the consultation points out that much more must be done if Scotland's performance is to match its' aspirations. It makes particular reference to speed management. 

The Road Safety Framework to 2030 is available for download.

Our response was :-

Submitted to Scotland's Road Safety Framework to 2030 Draft Public Consultation
Submitted on 2020-11-29 19:57:07

Questions

1 Is the vision set out for the next 10 years the right one? Yes

As a vision it is good. A "vision for Scotland to have the best road safety in the world by 2030" is excellent. In 2019 deaths per million population was 30. This is admirable and compared to 29 for the whole UK. Other countries such as Sweden (22), Ireland (29), Norway (20) and Iceland (17) did far better in 2019. 

If Scotland is going to exceed the performance of other countries then the vision and its execution will need to "set best practice" beyond that which is being deployed elsewhere. Unless there is a firm commitment to going beyond the measures set by the best performing countries then such a vision is merely wishful thinking. This will inevitably also require at least a match in funding.

We applaud the vision, but realism tells us that a vision that is not accompanied by a radical rethink and additional funding will only disappoint and lose credibility. A strategy that merely "aims" to put people at its centre and takes human vulnerability into account will not be sufficient. From day one the strategy "must" put people at its centre.

2 Are the outcomes of Safe Road Use, Safe Speeds, Safe Vehicles, Safe Roads & Roadsides and Post-Crash Response to deliver the vision the right ones? No

Not as presented. For example on Safe Roads and Roadsides it notes that where it is not possible to segregate different road users "a speed limit to protect the most vulnerable road users can be implemented". The word "can" is far too soft and conflicts with both the vision and the best practice being deployed elsewhere.

It also conflicts with the need to create conditions for active travel users that will encourage them change from motorised travel to active travel. 

On Safe Speeds we note that the "The setting of speed limits" does not recognise the need for perceptions of safety to be taken into account. How roads "feel" to vulnerable road users is a key determinator of mode switch away from motorised personal transport. We commend that that speed limits should not be set on the behaviour of road users if this implies that current motor vehicle speed will not be used to determine speed limits. This should be clarified.

3 Do you agree that the Safe System Approach is fundamental to the success of the Framework? Yes

Yes, but if Scotland is to have the best road safety performance in the world then it will also need to to have the best "Safe Systems Approach" in the world. The commitment to this in terms of action (if it exists) is not clear.

4 Are the 12 key challenges for road safety, from Climate Emergency, Health to Emerging technologies and Post-crash response, the correct ones? Yes

Yes. It is good to see the breadth of these challenges and the need to take them into account. However we would make these comments :-

Climate Emergency.
There are few initiatives to actually discourage unsustainable travel. Other countries are adopting wide-spread measures to discourage the use of cars within the community environment. Reduced car parking facilities, city road charging, pedestrian and cycle only areas, low traffic neighbourhoods, etc can all be used to discourage private car usage and make our communities safer and more healthy. There seems to be no commitment to the sort of radical action and interventions that will be required in order to achieve any comprehensive modal shift from unsustainable to sustainable travel.

As traffic density is a key factor in road danger, those countries adopting motor dependency reduction as well as road safety strategies will potentially achieve greater results than those with a softer approach to traffic reduction.

Active and Sustainable Travel
The percentage of KSIs incurred by pedestrians is higher in Scotland than the safest European countries. This shows that Scotland's roads are both unforgiving and dangerous for our most vulnerable road users. Too much reliance has been made on limited site specific interventions and not enough on population-wide interventions. At the heart of these is the maintenance of a 30mph default urban speed limit which endorses motor vehicles being driven in the killing zone above 20mph when they do collide with pedestrians. There should be recognition that such a 30mph default speed limit is not consistent with any real ability to reduce pedestrian KSIs and encourage active travel by either pedestrians or cyclists. There is an elephant in the room and it is that the "state endorsement of driving at 30mph in Scottish estates, streets and villages discourages active travel and results in deaths which otherwise could be avoided".

Health
Public Health Scotland supports the adoption of a default national urban/village speed limit of 20mph. However, the stated strategy instead still supports localised decisions on 20mph limits. This both endorses the current 30mph speeds on most roads and also complicates and increases the costs of localised limits.

Guidance on speed limit setting for urban/village environments where people share space with motor vehicles is still pre-occupied with the flawed and mistaken perception by drivers on what speed is acceptable or safe. This therefore prejudices the adoption of lower speed limits so preventing driver behaviour change and maintains higher vehicle speeds that reduce public health and prevent greater opportunities for modal shift to active travel.

Safe System
We are pleased to see this recognition of the benefits of all levels of society understanding what is meant by Safe Systems. However we would include the government, Transport Scotland and MSPs in requiring them to understand what it means and its implications for road safety.

Speed Management
We agree that there is a clear need for a National Speed Management Review. So often the setting of local speed limits is initiated because it becomes so clear that the nationally set speed limit is both wrong for road safety and will not deliver the outcomes that communities aspire to for active travel. In particular, the national blanket 30mph limit for lit streets is no longer "fit for purpose" when so many urban and village streets are required to be exceptions and set lower.

Reference has been made to the Stockholm Declaration and it being endorsed by the General Assembly of the UN. Within the Declaration the resolution on Speed Management was :-

“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”

It noted 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;”

To maintain a default national urban/village speed limit of 30mph which is 60% higher than the 30km/h (18.5mph) called for in the Declaration is inconsistent with any aspiration to either Vision Zero or a Safe System.

It also reverses the current expectation that 30mph is the norm and we "only slow down in some places" into one whereby " 20mph is the norm and we only go faster where pedestrians and cyclists are adequately protected".

Note that governments in Wales, Spain and Netherlands have made moves to adopt a national 30km/h limit for urban/village roads. It is extremely unlikely that Scotland will ever be able to surpass the road safety records of such countries without abandoning the 30mph national limit that was set in 1934.

Road Safety Delivery
It is incumbent upon the national government to take a holistic approach to delivery so that initiatives that are based on common values and benefits across the whole of Scotland can be implemented at national level to maximise effectiveness. In this respect the idea of multiple localised behaviour change programs around similar road safety themes is wasteful in cost and both the opportunity for a a co-ordinated and effective approach. Setting lower speeds where motor vehicles mix with vulnerable road users is such a typical example. If we really share values across Scotland in terms of the ability for individuals walking or cycling, especially as young or elderly, to feel safe on the roads, then why should there be a postcode lottery of implementations to create a safe environment.

This is another area where setting a national 20mph urban/village speed limit with localised exceptions makes sound sense economically and in terms of
effectiveness.

Driving/Riding for Work
We welcome the recognition that no-one should be killed whilst driving/riding for work. We also believe that no-one should be killed or injured by someone driving/riding for work. It is important to make the extension to not only protect the workers driving or riding, but also their responsibility to other members of the public that they share roads with.

Emerging Technologies
It is particularly pleasing to note the introduction of the "Third Mobility Package". This includes the adoption of mandatory speed limiters on all new car models from 2022 and all new cars from 2024. This provides a huge benefit in speed limit compliance. However such a benefit will be best gained if speed limits are set appropriately. Therefore we would urge the Scottish Government to seize the opportunity to set a revised national urban/village limit of 20mph. Complying with a speed limit will fall short of expectations if the default national urban limit of 30mph is retained.

We also note that data logging prior to any crash may well provide evidence for criminal prosecutions or civil liability claims. Evidence that a driver may have over-ridden any speed limiting device would be crucial to identifying and causation of a crash or not mitigating its consequences. We would therefore welcome the legal clarification of whether such evidence can be used in the courts to establish liability or fault.

Enforcement/Deterrence
There is a long established policy in the UK that :-

1. The government as representatives of the people create and set the rule of law.
2. A professional police force identifies non-compliance and presents evidence of law-breaking.
3. An independent judiciary sentences offenders.

The enforcement of speed limits using modern technology is perhaps one of the easiest and simplest of road offences to enforce. Yet police force seems to seek to both negatively influence the setting of appropriate lower speed limits and minimise their enforcement when they are set. There may be historical funding reasons why this has been the case. However, allowing non-compliance of speed limits will not be consistent with meeting Vision Zero goals. Lack of enforcement sends a strong signal out to drivers that non-compliance will be tolerated without penalty. So endorsing higher speeds and de-valuing the limits set.

Shifting this burden onto the public through Community Speedwatch or Operation Snap initiatives may well have some "marketing" benefits in communicating community support but unless they provide real "bite" in terms of their outcomes will only deliver "soft" support for speed limit compliance. Whilst this, together with other behaviour change programs, will have some benefits, for Scotland to achieve real improvements towards disciplined driving within existing laws then it must be abundantly clear that "road crime is real crime". This will only be achieved through effective police enforcement and prosecution.

Road Infrastructure
It is unclear how investing in the unsustainable transport of private motor vehicle usage is consistent with the objectives of developing sustainable transport. We would also suggest that most road infrastructure projects that lower journey times or reduce congestion actually promote unsustainable transport.

Post-Crash Response
We agree that post-crash response is important. There is huge evidence that the impact speed with pedestrians is a key factor in survivability, especially for our most vulnerable children and elderly pedestrians. This is yet another reason why mitigating the consequences of road crashes is so important. This indicates the importance of national speed limits both in urban settings where pedestrians are at risk and also in more remote rural roads where drivers will be at risk. Population-wide initiatives to set and endorse correct speed limits will reduce post-crash consequences.

Road Users: Unsafe road use.
We agree that it is important to understand the challenges that novice and elderly drivers pose. But equally we need to inform road users that their behaviour should not only be conditioned by their propensity to crash. The cumulative effect of many driver actions can have an effect way beyond "not crashing". Road users do not generally understand such cumulative effects of speed, noise, infringement, illegal or inconsiderate parking, etc. The "I will only be 5 minutes" approach to illegal parking or the "Sorry mate I didn't see you" excuses need to be addressed through marketing and behaviour change.

We are concerned at the reliance on the "learning process and education in early years". There is strong evidence that children do not have the cognitive skills to reliably protect themselves in traffic environments where the speeds are above 20mph. Of course children can and should receive learning and knowledge on the way to use the streets that are as much for their use as adults. But it is the adults who need to understand that children cannot protect themselves. In doing so we need to set speed limits that will ensure that children neither die nor be injured purely because drivers were reliant on them having developed cognitive skills that it would not be possible for them to possess.

Motorcyclists
Motorcyclists pose particular problems for child and elderly pedestrians due to their narrowness and inability of pedestrians to detect approaching speed in the same manner as a wider vehicle. In urban environments, motorcyclists accelerating away from lights to be ahead of other traffic (and protect themselves) can do so at rates that many pedestrians could not react to. This is another reason for setting appropriate urban and village speed limits where pedestrians and cyclists do mix with motor vehicles including motorcycles.

Seatbelts, drink, drugs and mobile phones
We agree that this should be recognised and targeted. However in all of these cases the consequences of such actions will be affected by prevailing traffic speeds both in the likelihood of an incident developing, the ability of those involved to avoid a crash and the consequences of any crash.

Fatigue

Foreign Drivers
Foreign drivers may be far more accustomed to lower urban traffic speeds than the current 30mph in Scotland. Many other countries will have a 30km/h limit on most urban/village roads. A 30mph limit that is 60% higher is not conducive to a comfortable environment for foreign drivers.

We would also note that foreign pedestrians and cyclists have been omitted from consideration. With both having to contend with vehicles on the unnatural side of the road then the speeds in urban/village environments play a big part in their ability to take avoiding action if their first instinct regarding approaching vehicle direction is wrong.

5 Do you think the strategic actions will deliver the outcomes and address the identified challenges? No

Speed
It is clear that there are issues with the current national speed limits. It needs more than consideration.

Climate
The actions are far too weak. There needs to be much more than simply trying to smooth traffic flow. Traffic needs to be reduced and the dependency on motorised vehicles also reduced. Actions to discourage unsustainable travel should be pursued if this challenge is to be addressed.

Funding & Resourcing
Road safety and the impact of motors on climate change should be incorporated into an overall transport infrastructure fund. To be best in the world then road safety funding will need to be uncapped so it can take up as much of this as is required and automatically reduce spending on new roads.

If any Vision Zero aspiration is to be credible then there needs to be a radical shift in priorities. If current police prioritising is typified by police forces opposing appropriate speed limits due to their inability to allocate resources for enforcement is no basis for a successful Vision Zero policy.

If Scotland is to aim for competing with and exceeding the performance of other nations of road safety then it will need to be far more aware of global best practice and incorporate this into fully funded interventions in Scotland.

Changes in Attitudes and Behaviours
This must firstly happen at government level. There is far too great a tendency to view "road safety" through the lens of a driver by MSPs and officials. Other countries without the same dependency of motorised travel in urban areas, eg Netherlands, Sweden, Norway, and others currently do this far better than the Scottish administration.

It is rather "exceptionalist" to presume that Scotland can have the best road safety record in 10 years time without a radical change in thinking and attitude at government level.

Technology
This should be seen as an opportunity to implement technology for far greater compliant, diligent and disciplined driving. Rather than evaluating the impact of new technology, the government needs to be pre-emptive in the adoption of new technology to enhance road safety.

Active & Sustainable Travel
The biggest impediment to active and sustainable travel is not the absence of infrastructure, but the over-dependence and over-dominance of unsustainable motorised vehicles on the public road network in urban and village environments. Unless this is addressed active travel will only increase marginally.

Knowledge & Data Analysis
There is already evidence of the under-reporting of road crashes and casualties, especially at lower levels. Addressing this issue with cross-correlation with hospital data, etc would be useful. The use of floating car data would be very beneficial in terms of understanding vehicle speeds and use.

Enforcement
Most road crime goes undetected. UK has one of the most tolerant enforcement levels in Europe. A greater priority for enforcement will be required if the Vision Zero and "best in world" aspiration is to be credible.

Health
There are massive health implications for dependency on motorised transport in terms of sedentary lifestyles. Hence as well as crashes being reduced, there needs to be a reduction in such dependency and a switch to healthier travel.

Education
Given that until secondary school age children cannot be relied upon to judge the speed of motors or protect themselves in traffic above 20mph it is somewhat concerning to see this over-reliance on children protecting themselves from an early age.

It is the adults which need most education on how they use the roads. Children are far too often the "low hanging fruit" of road safety education. The harsh reality that mistakes by adults, either intentional or unintentional, are the cause of most child and adult injury must form the basis of road safety education.

We must also move road safety towards positive nudging of driver behaviour making our communities better places to be.

6 Are some of these actions more important than others? Yes

Yes. Unless attitude and behaviour in decision-making around road safety is addressed and radically changed then Scotland will never reach its goal of having the best road safety record in the world.

7 What are your views on the proposed 2030 Interim Targets? Not Answered

8 Do you think that the Intermediate Outcome Targets and Key Performance Indicators are appropriate to monitor the progress towards
the 2030 interim targets? No

Compliance with a speed limit is not a good measure unless it also incorporates in some way the appropriateness of a speed limit. Compliance is rather binary in that it does not distinguish between any degree of non-compliance. In fact by keeping higher speed limits it may well be easier to score higher on compliance levels than setting lower and more appropriate limits.

Current urban speed limits are not consistent. The adoption of the Stockholm Declaration maximum of a 20mph speed limit where vulnerable road users mix with motors in the form of a national 20mph urban default would go a long way to making the compliance useful. Increasing inclusion of speed limiters in cars will also improve this score.

As road safety and collisions is associated with dependency , volume and speed of motorised vehicles there should be a targeted reduction in motorised (unsustainable) transport. This is already evident in countries above Scotland in Road Safety performance.

9 Do you think that the proposed Governance Structure is appropriate? No

We note that the OPG has no involvement from Public Health, road victim associations (eg BRAKE, RoadPeace) or pedestrian representatives. Given the aim to increase active travel then this needs to be addressed. In view of the objective to be the "best in the world", then this maybe need a far more radical revision of the governance structure.

Consideration should be given to the formation of a separate government body or ministry responsible for road safety that is independent from transport?

10 Would road safety performance be improved across Scotland as a result of systematically sharing information and best practice
between local authorities and/or local/regional partnerships through Local Partnership Forums? Yes

But far more importantly we very much know what works in road safety.

• Reduce the volume of unsustainable transport.
• Reduce the speed of unsustainable transport.
• Reduce the illegality of unsustainable transport.

Any credible aspiration to be the "best in the world" must also look to see what is developing best practice in other countries and remove obstacles to its adoption and implementation in Scotland.

11 In your opinion what aspects of road safety work well at the moment?

12 What practical actions would you like to see taken to encourage and promote these aspects?

13 In your opinion what aspects of road safety do not work well in general and as a result of Covid-19?

Urban and village speed limits are far too high at 30mph which is 60% higher than the internationally recognised best practice of 30kmh as in the Stockholm Declaration. The current insistence on it being a local authority responsibility to correct the "not fit for purpose" national limit is perverse. It leads to a postcode patchwork of inconsistent limits which suppresses compliance and effectiveness.

Covid-19 interventions have supported the setting of 20mph limits. This should be recognised in a national default urban speed limit of 20mph.

14 What practical actions would you like taken to overcome these aspects?

20mph should become the default urban/limit for restricted (lit) roads and local traffic authorities could facilitate an exception to a higher limit where they could show evidence of a higher limit being safe for vulnerable road users.

This is an initiative already being undertaken in Spain, Wales and The Netherlands. It is expected to be followed by other countries. This will be complemented by increased compliance as new cars include mandatory speed limiters from 2022.

This should be accompanied by a program of public engagement based on Scottish community values and enhancement of communities. A model may be taken from the way this has been approached in Wales where it has been adopted with cross-party support in the Senedd.