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://freedomfordrivers.blog/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

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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

Twitter: https://twitter.com/Drivers_London

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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 we have 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 we have 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 set 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. We believe 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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No Road Safety Benefit from 20 MPH Schemes

The Department for Transport (DfT) have released a report that shows there is no road safety benefit whatsoever from signed-only 20 mph schemes. In addition they have negligible impact on modal shift or on traffic speeds.

This is 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 such as road engineering or education. 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.

This disappointing result is very similar to the result of a study of driver education courses now being used by the police to generate funds. Both that and 20 mph schemes have been advocated by those who know little about road safety and have not studied the evidence. We have long called for “evidence-based” road safety policies. Let us hope this latest evidence will not be ignored.

There will no doubt be calls for more enforcement of 20 mph limits but that ignores the basic issue – namely that reducing traffic speeds simply has little impact on road casualty statistics because excessive speed is one of the lowest contributory factors to road accidents – in reality less than 5% according to police reported statistics.

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.”

“The majority of resident (about two-thirds) and non-resident drivers (just over half) have not noticed a reduction in the speed of vehicles, and do not perceive there to be fewer vehicles driving at excessive speeds for the area.”

Roger Lawson

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Lewisham 20 MPH Limit Failing

The London Borough of Lewisham introduced a borough-wide 20 mph speed limit in 2016 – apart from a few major roads. But not surprisingly it is failing to change drivers’ behaviour who continue to use their intelligence to drive at what they consider an appropriate and safe speed. As a Council report says “As the general look and feel of the roads has not changed many drivers continue to drive at the old 30 mph limit”.

The Council report also says that speed “reductions have been relatively small” which is similar to other signed-only schemes. So they now want to spend £1.2 million on a number of measures to enforce the 20 limits. That may include speed humps, chicanes, build-outs and speed cameras, although they have not firmed up exactly what measures would be used and on which roads. Roads likely to be targeted are Downham Way, Brockley Road and Southend Lane.

They intend to progress those proposals despite the fact that they only have preliminary figures for speed reduction and no data at all on the resulting impact on personal injury accidents. Nor are they bothering to wait for a Government commissioned study of the effectiveness of 20 mph speed limit zones.

Neither is there any cost/benefit justification for these proposals. Slowing traffic costs money in the wasted time of vehicle drivers/passengers. It also creates more air pollution because vehicles driven at slower speeds cause more.

Lewisham are clearly one of those boroughs dominated by anti-car policies and without any consideration of what is rational or sensible. You can read the Council’s report here: http://councilmeetings.lewisham.gov.uk/documents/s59363/Lewisham%20borough%20wide%2020mph%20speed%20limit%20update.pdf

Roger Lawson

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Blanket 20 MPH Speed Limit in Richmond

The London Borough of Richmond is proposing to introduce a speed limit of 20 mph on all roads in the borough with two exceptions. The only exceptions will be the A205 (South Circular) and A316 which are TfL controlled roads.

The claim is that this will reduce the number and severity of road accidents but that is contrary to the evidence that has been appearing on that issue – see https://freedomfordrivers.blog/2018/09/15/20-mph-zones-are-a-waste-of-money-or-worse/

This will be a “signed-only” scheme so it is very unlikely to have any significant impact on traffic speeds (typically 1 mph on other such schemes which nobody can notice) and even less impact on casualty figures.

A public consultation is now open where you can give your views on this proposal. See: https://www.richmond.gov.uk/council/news/press_office/older_news/september_2018/consultation_on_borough_wide_20mph_limit_launched

Please make sure you respond as soon as possible!

Roger Lawson

Twitter: https://twitter.com/Drivers_London

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20 Mph Zones Are a Waste of Money, or Worse

The Sun Newspaper has reported on the success, or rather failure, of 20-mph wide area speed limits, to reduce accidents. They have obtained figures from 20 local councils using the Freedom of Information Act where £11 million of taxpayers’ cash was spent on the lower limit. But in some cases, rates of serious accidents (Killed and Serious Injuries – KSIs) have actually gone up they reported.

AA President said that the schemes were a “waste of money”, effectively implying that if the money had been spent on other road safety measures, more lives and serious accidents would have been saved.

Examples the Sun gave were Bath where £804,000 was spent but a 2016 report revealed that the KSI’s went up in 7 out of the 13 zones where speeds were cut, and in Manchester £1.7 million was spent on a heavily criticised scheme while in Hampshire other schemes showed no benefit in terms of accident reduction.

We have of course reported similar problems before including in the City of London where a blanket 20 mph scheme has resulted in more minor injury reports.

20s Plenty founder Rod King called the articles “sloppy journalism” (one also appeared in the Daily Mail on the same subject). 20s Plenty has tried to debunk the reports of a number of local councils on their 20 mph schemes – for example they called the Bath report “biased, lacking in statistical rigour and not meeting several local authority duties on competency and equality”. But anyone who has surveyed all the evidence on such schemes will know that simply putting up signs typically reduces traffic speed by only 1 mph and that can have no significant impact on road casualties. In reality it seems to have the opposite effect in many cases as pedestrians no longer take so much care when crossing the road.

Rod King and 20s Plenty are like all fanatics – they ignore the negative impact of their policies and fail to see the truth. They are blinded in their zeal to reduce speed limits in the false presumption that reducing speeds are the answer to all road safety problems. But cutting road casualties is not as simple as that.

We still await a Government report on a more comprehensive study of 20 mph schemes.

In London, Transport for London (TfL) continue to finance such schemes in local boroughs and must have spent millions to date on them. Another example of unwise policies and reckless expenditure by TfL and Mayor Sadiq Khan, plus his predecessors. It is a great pity that money was not spent on road engineering to improve the safety of roads and junctions.

The Mayor actually wants to impose 20 mph speed limits on many major roads in London under his “Vision Zero” road safety plans. UKIP Transport Spokesperson Jill Seymour has challenged TfL to provide undisputed evidence of the justification for such proposals. She said “The authorities have strangled the main roads, and made them the most congested and slowest of any city in Europe. London is a mess when it comes to transport…..the London authorities, led by Sadiq Khan, appear to have a vendetta against personal transport and the car, and do everything they possibly can do to discriminate against it”. That’s definitely the truth of the matter.

Roger Lawson

Sun article here: https://www.thesun.co.uk/news/7253694/20-mph-zones-cause-more-deaths/

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20 Mph Speed Limit on Major London Roads

London Mayor Sadiq Khan has announced measures to improve road safety in London including a 20-mph speed limit on all major roads within the Congestion Charge zone. That will include such major arteries as the Embankment and Upper/Lower Thames Street. In addition he will be encouraging local London boroughs to introduce the same limit on TfL controlled roads in 32 town centres.

He is also proposing to improve 73 junctions which have been identified as those with the worse road safety record. These proposals are part of the Mayor’s “Vision Zero” policy which attempts to eliminate deaths and serious injuries on the roads.

Comment: Campaign Director Roger Lawson had these comments on the proposals:

The Mayor trots out those old misleading claims that reducing speed limits will remove almost all fatal and serious accidents. This is simply not borne out by the facts. For example, the City of London Corporation that covers the square mile introduced a blanket 20-mph speed limit in 2014. It had negligible impact on overall casualty figures, minor injuries actually increased and there were 2 fatalities in that area in 2016 – see references below. The results of signed-only 20 mph schemes have been very mixed and a Government report on the subject is still awaited.

Although the “Vision Zero” concept might make for good media coverage it does not necessarily help if ill-informed road safety policies are introduced. The reduction in speed limits will slow traffic causing additional costs in increased journey times and the police will no doubt be vigorously enforcing these new limits.

Many people will say that with average London traffic speed now nearer 10 mph than 20 mph, it may not make much difference. But that is not always the case. For example, outside rush hour times traffic moves much faster than 20 mph on many parts of the TfL road network (the “red routes”). This just looks like another attempt by the Mayor to remove all vehicles from the streets of London so as to achieve his vision of almost no private vehicle use (including cars, LGVs, taxis and PHVs) as spelled out in his Mayor’s Transport Strategy.

The only sensible part of his proposal is to improve junctions where there is a known poor accident record. Otherwise this latest move to slow traffic in London is another nail in the coffin of an efficient road transport network for our capital city. Sadiq Khan is surely the most incompetent London Mayor we have yet had.

Those who oppose this proposal should contact their Greater London Assembly Member (see: https://www.london.gov.uk/people/assembly ) or write to the Mayor himself: https://www.london.gov.uk/contact-us-form .

Roger Lawson

Notes:

The Mayor of London’s Press Release is given here: https://www.london.gov.uk/press-releases/mayoral/boldest-ever-plan-to-eliminate-deaths-on-the-roads

Report on the City of London 20-mph scheme: https://freedomfordrivers.blog/2015/10/09/city-of-london-20-mph-scheme-first-results/

TfL Road Casualties in 2016: http://content.tfl.gov.uk/casualties-in-greater-london-2016.pdf

The Mayor’s Transport Strategy and our comments on it: http://www.freedomfordrivers.org/against-mts.htm

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