Transport for London (TfL) have imposed 20 mph speed limits on a number of London’s main A roads. To quote from their press release: “20mph speed limits will be introduced across 28km of roads within the boroughs of Camden, Islington, Hackney, Haringey and Tower Hamlets from 31 March……TfL data shows 20mph speed limits are making London’s roads safer and have led to a 25 per cent reduction in deaths and serious injuries within the central London Congestion Charging Zone… Lower speed limits play a critical role in the Mayor’s Vision Zero plan to eliminate deaths and serious injury on the transport network”.
The data they provide to support these claims is both selective and inaccurate (see their press release below).
Their claims are grossly misleading about the benefit of 20 mph limits as other studies have shown no benefit. As we have pointed out before, Vision Zero is not working because it focuses too much on speed.
This is just another example of how the Mayor of London and certain boroughs plan to get rid of motorists altogether in London. The ULEZ expansion is also part of the plan. Cars are not being banned, just made unusable for many practical purposes. This is a typical diversionary tactic of politicians when banning something outright would be seen as totally unacceptable.
And just consider the plight of taxi/PHV drivers who could lose their licenses and jobs after being caught a few times for driving at 22 mph on TfL roads.
As evidence of how damaging the reign of Sadiq Khan has been to London’s road network, the table below gives the historic trends for average traffic speeds in London. It’s now less than 10 mph in central London!
Transport for London (TfL) have issued a press release claiming significant improvements in road safety since more 20 mph speed limits were introduced. The press release claims that collisions involving vulnerable road users have reduced by 36% and collisions involving death or serious injury have fallen by 25%.
The odd thing about this press release is that “collisions” are not recorded by the police, only road traffic accidents involving personal injury. In addition this claim is quite meaningless unless traffic volumes are measured at the same time and the impact of any other road safety measures such as road/junction improvements are taken into account.
TfL claim that it shows the Mayor’s Vision Zero plan is working but the last time we reported on this eighteen months ago we showed it was not. See https://tinyurl.com/3x3jvcr7
Regardless a report in the Daily Telegraph says that TfL is pushing ahead with lowering speed limits on many more roads in London. The majority of TfL controlled roads (red routes) will move from 30 mph to 20 mph limits.
Meanwhile the number of enforcement actions for speeding by the Metropolitan Police rose by 73% last year to 476,685, probably because 20 limits are not a natural speed to drive at on clear roads.
Comment: TfL claims contradict the authoritative study undertaken by the DfT which showed no statistically significant benefit from 20 mph speed limit zones. The TfL press release does not provide all the data and it is surely based on selective data and false analysis.
Vision Zero and reducing speed limits below what drivers consider as reasonable just seems to be an attack on driving in general with the aim of making life more difficult for those who need to drive. It’s unfair and is just another example of the anti-car mentality of TfL management.
It has now been reported that this approach has been blocked by the Department for Transport (DfT) who have indicated that obtaining driver details for that purpose is unlawful. The DfT have told the DVLA to stop sharing details of drivers caught speeding under the scheme.
Barrie Segal, an expert on motoring law who runs a web site called MyappealNow, has also said that he believes this scheme is illegal as only the police can enforce speed limits. He would be interested in hearing from anyone who is issued with a PCN by any council in such circumstances.
Comment: Motorists need to oppose this attempt to extend the law so that councils can generate money from minor infringements of speed limits.
I commented previously on the use of PCNs to enforce 20 mph speed limits on certain roads in the London Borough of Wandsworth – see links below. After exchanging numerous emails with the Council and looking into the relevant Acts of Parliament I have come to the conclusion that they have no proper legal grounds for issuing PCNs in these circumstances.
They claim to have taken two legal reviews which supports their stance. But why two? Did the first one not give the right answers?
After my last question to them they simply said “It would appear we are at an impasse, legal advice is privilege information and I have nothing further to add at this time”, i.e. they seem to be stumped for an answer.
Our advice to anyone who receives a PCN for exceeding a 20-mph speed limit in Wandsworth is to challenge it and take it to appeal to London Tribunals.
We are considering a wider legal challenge and if anyone would like to assist with that please contact me (tel: 020-8295-0378 during office hours).
The Council claims to be relying on the London Local Authorities and Transport for London Act 2003. (LLA &TfL Act 2003) and the Road Traffic Regulation Act 1984. (RTR Act 84). Specifically Section 4(5)(a) of the LLA&TfL Act 2003 that allows for Penalty Charge Notices to be issued for contravening a Prescribed Order. I pointed out that a prescribed order can only apply where there is a contravention of a traffic sign listed in Schedule 3 of the London Local Authorities and Transport for London Act 2003. There is no 20 mph sign limit listed in Schedule 3. And Section 4(6)(a) says: “No penalty charge shall be payable under subsection (5)(a) above where—(a) the person acting in contravention of the prescribed order also fails to comply with an indication given by a scheduled section 36 traffic sign; or….”. They also claimed support of Section 84 of the Road Traffic Regulation Act 1984 which specifically refers to “Speed limits on roads other than restricted roads” so only applies to non-restricted roads. The roads under discussion are almost certainly “restricted roads”.
The legislation in this area is exceedingly complex and difficult to understand but I believe they have simply misinterpreted it in their enthusiasm to raise money from drivers who might not challenge PCNs.
20 Mph speed limits may be enforceable by the police but Councils have no authority to issue PCNs for breaches of 20 mph limits in our view.
I have asked the Council to provide information on what public consultation took place on this proposal and a copy of the Traffic Management Order (TMO) used to impose it (which was not published anywhere so far as I can see). They provided the latter but were very evasive about the former even though they claim they received 23 responses. I am pursuing it further.
But I have sent in an objection to the TMO as follows and I suggest readers do the same.
I refer to “The Wandsworth (Prescribed Routes) (20mph Speed Limit) Experimental Order 2021”
Please note our objections to this Order for the following reasons:
1. The 20-mph limit on the roads concerned is likely to have very little, if any, impact on road casualties. I quote from a recent article in the Daily Mail: “Researchers from Queen’s University Belfast, Edinburgh University and the University of Cambridge collected data on traffic collisions, casualties, driver speed and traffic volume before a 20mph limit was introduced, as well as one and three years afterwards.
Their study encompassed 76 streets in the city centre, and they compared data with that collected from nearby streets where the restrictions did not apply. Analysis showed that when compared with the sites that had retained their speed limits, a 20mph speed limit was associated with little change in short or long-termaccident statistics.
Small reductions in road traffic collisions of 3 per cent and 15 per cent, respectively, were observed one and three years after the policy took effect. But there was no statistically significant difference over time, the researchers said.
Similarly, casualty rates fell by 16 per cent and 22 per cent, respectively, one and three years after implementation – but these reductions also weren’t statistically significant”.
3. The roads on which you are enforcing the 20 limit are inappropriate for a 20 limit. For example Wimbledon Park Road is a straight and relatively wide road which drivers will not perceive as needing a 20 limit. Is there really a road safety problem in this road?
4. The ability of the Council to enforce such a limit via the issue of PCNs rather than have police pursue a prosecution suggests the motive for the scheme is to enable the Council to collect money from fines rather than to improve road safety.
5. We have studied the relevant Acts of Parliament referred to in the TMO and we cannot see that they enable enforcement of the 20 limit in this way by Wandsworth Council. London Councils certainly have powers to enforce parking restrictions, road closures and certain other traffic offences but we do not see that this extends to 20-mph speed limits. Please point out exactly which provisions in those Acts are being relied upon.
A petition on Change.org has been created by James Burdass which reads: “Stop every road in London having a 20mph Speed limit”.
More details say “Let’s face it, every driver knows that London is grinding to a halt under the Mayor’s transport policies. So why is it that we need more expensive to implement new anti-car 20mph speed limits?
The Mayor has said that all Red Routes within the Congestion charging zone will have 20mph limits. Yes, the main roads not the high street or residential roads. Just outside the zone, Park Lane goes from 40mph to 20mph. Progress?
For more than half a century 30mph has been the default urban speed limit in the UK. 20mph limits are expensive to implement, wasting scarce road related funding that could be better spent elsewhere, create more pollution on our streets, lead to more congestion and do not deliver the benefits in terms of casualty reduction that proponents expected.https://www.gov.uk/government/publications/20-mph-speed-limits-on-roads
20mph leads to slower speeds for everyone and that includes bus passengers and ambulances looking to get people to hospital. Rather than winning hearts and minds it is the backs and spines that are affected.
It is time that this was rolled back and London’s main roads restored to 30mph.
Transport for London (TfL) are proposing to reduce the speed limit on Battersea Park Road (the A3205) to 20 MPH along the whole length. In addition they are proposing a new segregated cycle lane and other minor changes to the road.
Why are they proposing these changes? To quote from the TfL document: “These changes seek to create a sustainable transport spine through the Nine Elms opportunity area, providing benefits to both the existing and future residents, and workers. The road layout along this stretch of Battersea Park Road is very constrained due to the railway arches and level of activity along the road. The proposals in this consultation would create an improved cycle link between CS8 to the west and CS5 to the east. They would improve connectivity and allow for increases in cycling demand that are anticipated to be generated by the new town centre emerging at Battersea Power Station, while providing safer separated sections of cycle track. The proposals would also provide more direct pedestrian crossings and more space to interchange between buses and trains at Battersea Park station. Overall, this will create a destination where people are encouraged to walk, cycle and use public transport. The proposals are fully funded through third party contributions from the regeneration along Battersea Park Road and Nine Elms Lane”.
As usual with TfL proposals of late there is no cost information provided or cost/benefit justification.
The road network in central London is being destroyed by the actions of Transport for London (TfL) and local boroughs. When roads are closed or congestion made worse by bus or cycle lanes, then the whole network grinds to a halt. Recent new examples are:
King Street/Chiswick High Road Cycle Lane Scheme. See photograph above of the congestion this has caused. The cycle lane impedes emergency vehicles, is dangerous for pedestrians and cyclists, increases congestion and hence pollution, ended the King Street bus lane, and reduces parking space which negatively affects local businesses. The congestion doesn’t just stop on King Street. Hammersmith Road, Hammersmith Gyratory, and Fulham Palace Road have all become completed jammed at peak hours which affects the entire Borough.
London Bridge and Borough High Street. In the east of London, TfL introduced an experimental scheme on London Bridge and in Borough High Street in Spring 2020 using the Covid epidemic as an excuse. They are now proposing to extend these schemes for another six months. It effectively closed London Bridge to all traffic except pedestrians, cyclists, motorcyclists, buses and taxis.
TfL are now proposing to extend both schemes for a further six months using an experimental traffic order with another consultation exercise. They claim it has reduced bus journey times but that is hardly surprising when traffic and people in central London have been much reduced by the Covid pandemic.
This scheme is totally unjustifiable as it removes one of the key London river crossings for most traffic and effectively closes that part of the City to vehicles. You can send comments on the latest decision to firstname.lastname@example.org
Aldwych Scheme. While I was writing this blog post I received a telephone call complaining about the revised road layout on Aldwych and Kingsway. This has substantially increased traffic congestion in the area and many taxi drivers are complaining about it. It’s yet another defective traffic scheme introduced by TfL for no clear benefit.
Slowing Traffic with 20 Limits. Apart from slowing traffic with more congestion caused by the above schemes, TfL is now proposing to impose lower speed limits on several major roads. Four 20mph speed limits will be introduced, including the A10 – A503 corridor in Haringey, the A13 Commercial Road in Tower Hamlets, the A23 London Road in Croydon and the A107 corridor in Hackney. In addition, a 30mph speed limit has been introduced on a section of the A10 Great Cambridge Road in Enfield and Haringey.
These reductions are aimed at cutting casualties as part of its Vision Zero commitment to reduce road danger and enable more walking and cycling in the capital. The central London Congestion zone had a 20-mph limit imposed in 2020 and the Metropolitan Police Service (MPS) will significantly increase speed enforcement by increasing MPS capacity to enforce up to one million offences by 2024/25, introducing new technology to improve effectiveness of enforcement and rolling out new powers to Police Community Support Officers so that they can stop speeding vehicles and take enforcement action against drivers.
Comment: This is of course an example of how the MPS under Cressida Dick has lost track of its priorities. Instead of cutting knife crime and keeping the roads open the MPS prefers instead to spend money on speed limit enforcement.
This is yet more harassment of drivers which will have little impact on road casualties. Vision Zero is failing to achieve its objectives in cutting accidents because reducing speed limits alone by just putting up signs does not have any impact as is clear from studies published by the DfT. To cut accidents roads need to be re-engineered and money spent on driver education.
Central London is becoming a “no go” area for private car drivers and making life very difficult for taxi/PHV and delivery vehicle drivers. This is simply encouraging businesses and retailers to move out and will impoverish London in due course.
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You thought traffic in London was slow enough? Well Transport for London (TfL) have now published their report on the “consultation” into the permanent reduction of the speed limit on the Westway to 30mph, Park Lane (Northbound) to 20mph, and 13km of other routes in Westminster to 20mph. That includes on the Marylebone Road, Vauxhall Bridge Road and Edgware Road between the A40 and St. John’s Wood Road – see map below.
Needless to say, they’re planning on going ahead with it. But did you even know about this consultation? This writer certainly did not and the number of responses from the public was only 224 which surely suggests it was not widely known.
Comment: These are some of the main roads in central London and are vital to maintenance of an efficient road network. It is inconceivable that users of these roads would support such a change. It’s yet another example of TfL attempting to halt all use of motor vehicles and deter people from driving in London by making it inconvenient and frustrating.
It’s also a great example of how TfL does fake consultations with no publicity and done in mid-summer when many people are on holiday.
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.
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.