Should a Value Be Placed on a Life, re Croydon 20MPH?

The scheme to implement a wide area, signed-only 20 Mph speed limit in the London Borough of Croydon has been covered in past article. The scheme will cost over £1 million and there have been lots of objections from local residents. But Councillors have pushed it through regardless.

It is now the subject of a Judicial Review over the defective consultation process. In addition, I made a complaint to Croydon Council about that in June, and after an initial brush off have had a final response from Jo Negrini, their CEO. She ignored my arguments about the lack of proper cost/benefit justification and lack of provision of the likely benefits in the consultation documents. She simply argued that a value cannot be placed on a life.

This is an extract from my response: “you say (on page 3) that “the report emphasises several times that a value cannot be placed on a life and therefore the benefit of preventing, even a single fatality, cannot be said not to represent value for money to the public”. You use that statement to justify the fact that no proper cost/benefit analysis was done, or the benefit of the scheme put to councillors before they made a decision to proceed.

Such a statement just shows how ignorant you are on road safety matters and the decision-making process used on public schemes (or perhaps you are not so ignorant and are just using this as a poor excuse). A value is placed on a life everyday when evaluating public expenditure. That is for the simple reason that when comparing projects, or looking at where limited cash resources are spent (and as Theresa May recently said: “there is no magic money tree”), it is rational to choose the most cost-effective projects in which to invest. By so doing, the most lives are saved.

The problem with the Croydon 20 wide area scheme is that an enormous amount of money has been spent, that could have been better spent on other road safety projects. And hence saved more lives!

Valuing lives may be seen as somewhat hard-nosed for those who do not have any scientific background, or have not been schooled in how to make rational decisions, but it is how road safety schemes normally are, and should be evaluated.”

This unfortunately is a very good example of the poor quality of local authority decision making in not just London but the UK as a whole. Uneducated and ill-informed councillors make policy decisions that their executive staff are expected to justify and implement. But good council officers should tell the truth and stand up for what is right.

Similarly the Mayor of London has caught this bug. So he went ahead with the London “T-Charge” this week despite being advised that it would not show any significant benefit in terms of reduced air pollution. It has just imposed enormous costs on one of the poorest sections of the community (those who drive very old cars), but the Mayor thinks it makes for good headlines. Just line up some young schoolchildren for a photo-shoot (a very dubioius practice) and explain this is one step to fixing air pollution problems in London. It makes for great publicity, and helps the Mayor to raise more in taxes under the guise of public health! Great politics if you can fool the public for long enough.

Roger Lawson


Judicial Reviews invoked by Motoring Groups

T-Charge. The Sun has reported that FairFuelUK are planning to challenge the Mayor of London’s introduction of the “Toxicity Tax” (“T-Charge”) via a judicial review in the High Court. This is a tax of £10 on certain older vehicles that do not meet newer emission standards that is being imposed from October if they are driven into the central congestion charge area.

The challenge will be on the basis that it is unfair discrimination against a small minority of road users when other vehicles (e.g. TfL buses) and other sources (e.g. construction machinery and diggers) generate more pollution. In other words, it is an unreasonable attack on car users.

FairFuelUK may be looking for financial support to enable them to fight this case (judicial reviews are expensive), so anyone interested in this matter should keep an eye open for further news.

Croydon 20MPH. Another judicial review where the case has already been filed in court is that over the public consultation in Croydon on implementation of the blanket 20 MPH speed limit. We supported an active local campaign against the proposals and we have also complained to the Council about the defective consultation process. The process was changed from one area to another, apparently with the objective of obtaining the desired result, the information provided to residents was biased, the results ignored, and objections not considered properly. There are established legal principles about how public consultation should be run to ensure they are fair and unbiased, which is no doubt the basis of the challenge.

Both cases are in essence about illogical and unreasonable attacks on car and van drivers in the name of environmental improvement when there will allegedly be negligible advantage but significant costs imposed on drivers.

Roger Lawson

20MPH Zone Impact on Traffic Speeds? – Not Much

What’s the impact of putting up 20MPH speed limit signs? Minimal according to a report from the London Borough of Hammersmith & Fulham. A report on traffic speeds after the introduction of wide-area 20 mph speed limits comparing measured traffic speeds in 2015 and 2017 showed an average reduction of just 1.3%.

Across 100 comparable roads, the 85th percentile reduced from 24.83 mph to 24.52 mph. Although some roads showed bigger reductions in speed, others actually showed substantial increases. But the data is difficult to interpret because those with the highest increases reported low speeds in 2015 while those with the biggest reductions reported high speeds in 2015. It’s possible these are statistical anomalies resulting from inadequate sample sizes.

Is there any data on accident impact? Too early to report apparently. But the Council is pushing ahead regardless with extending 20mph to all remaining side roads in the borough and on some sections of main roads.

You can read the H&F report here:

Comment: This surely demonstrates that the likely benefits of such schemes do not justify the cost. The money would be much better spent on other road safety measures.

Roger Lawson

Croydon 20 – Pushing Ahead Regardless of Objections

Croydon Council are pushing ahead with implementing wide-area, signed-only 20 MPH speed limits in the rest of the borough despite enormous numbers of objections.

The consultation process on Area 1 was clearly subject to fraud, and on Area 2 the vote in favour narrowed very substantially. So for areas 3, 4 and 5, which by their nature were more likely to oppose the proposal, they abandoned the previous consultation process and moved straight to a “statutory consultation”. That meant people had to take the trouble to write in with specific objections rather than simply respond to an on-line poll. The other advantage of that change is that objections to statutory consultations can be ignored so long as the council simply gives reasons to do so.

Was this process ethical? Absolutely not.

And what was the result of the formal statutory consultation on Areas 3, 4 and 5? They got 3,357 representations in total from 2,050 individuals, but only 103 of the representations were in support of the proposals. In detail there were a total of 18,862 objections of different kinds. These numbers are enormous for such a relatively small geographic area.

But are the Councillors and Council Officers going to reconsider? Absolutely not. A typical example of how dogma and policy decisions overrides the will of the people in some councils. The recommendation in a report to the Traffic Management Advisory Committee is to proceed regardless – see the report here which will be considered at a meeting on the 9th May – see Meeting-Agenda (Item 7 on the Agenda).

Residents of Croydon should go along to the meeting to show their concern about this anti-democratic approach, or make their feelings known to their local Councillors. And next time there is a vote for local Councillors, just bear in mind which Councillors and which political party (the Labour Party) have taken this stance in Croydon.

The last time I saw this ignoring of the electorate take place was in the London Borough of Richmond where the LibDems pushed through an emission based permit parking scheme against strong public opposition. They were subsequently removed from control of the Council by popular vote. And a very good thing that was too.

You can see more about the scheme in Croydon on our main web site. We did make written submissions on these schemes including on the latest 3 areas.

The report from Croydon Council does not adequately deal with all the objections, and in some regards is grossly misleading. For example, in Para 3.1.8 it says Manchester reported falls in cyclist and pedestrian casualties in 20 mph zones but due to the average speed reduction being only 0.7mph the further roll-out was being halted. In actual fact what Manchester City Council actually said (you can find their report on the web) was “Overall the results show that casualties in the phase 1 20mph area have not reduced as much as the casualty numbers citywide“. In other words, there was absolutely no benefit whatsoever in terms of casualties despite very high expenditure and if anything it made accident numbers worse.

Both ethics and democracy have clearly be thrown out of the window in Croydon.

Roger Lawson

Croydon Proceeds with 20 Mph Zones

The London Borough of Croydon are pushing ahead with imposing wide-area 20 mph speed limits on the whole of the borough. There are two regions already committed to implementation after public consultations, with three more to go.

On the public consultation on the last region, the North-East, they only got a narrow margin of support in response to the question “Do you support the proposal to lower the speed limit to 20 mph for residential roads shown in the plan”. There were 50.5% responses which said “Yes” versus 47.1% who said “No”. Only responses from residents within the region were accepted though so all visitors and other road users from other parts of the borough or outside the borough were ignored.

We put some effort into raising awareness of the public consultation which at least meant they got over 3,100 responses.

But for the remaining three areas, the Council have decided to do away with a wide public consultation despite previously having agreed that would be the process and will only perform a “Statutory Consultation” as required by law. In other words, they will advertise the proposal and await responses. They will then consider them and like all such consultations, they can they ignore the result if they don’t like what is submitted.

Now everyone who knows Croydon will be aware that the three remaining parts of the borough are more rural in character than the first two. So it was very likely that they would have voted the other way and opposed a wide area 20 mph limit.

It would therefore appear that after only narrowly winning the votes of residents in previous consultations (and in fact rigging the results in the first area as we previously reported), they have given up on proper public consultations because they feared losing the vote.

That is what happens when dogmatic politicians take control of a Council and decide they know best, as is clearly the case in Croydon. Their idea of democracy is surely very different to most people’s. The Statutory Consultation will run from the 18 January 2017 till 15 February 2017. We will provide more information on it when known.

Roger Lawson

Scrutiny Committee of 20mph in Croydon

Last night Croydon Council held a Scrutiny Committee to review the councils decision to go ahead with a wide area, signed only, 20mph scheme in North Croydon. It had been requested by 14 Conservative councillors who were concerned about the cost. You can see a video recording of the event here:

I spoke to support the “call in” and in opposition to the proposal. To save you wading through the whole video, here is what I said:

Objections to a Wide Area 20 Mph Scheme for North Croydon – Scutiny Committee Speech

I understand the call-in has taken place because of concerns about the cost of the proposed 20 mph wide area scheme in North Croydon. At a cost of £300,000 it is certainly likely to be a waste of money.

The main arguments for 20 mph schemes have always relied on the benefits to road safety. In other words that accidents and injuries will be reduced. But this is a mirage and is not borne out by the evidence available to date. Claims for such benefits are wrong and that is why the Department of Transport has commissioned more research into this topic. The latest part of London to introduce a wide area 20 mph scheme was the City of London and the initial evidence there is that injury accidents rose afterwards.

The other claims such as “improving liveability” are basically just hot air with no substance in reality. Introducing a 20 mph speed limit does not encourage more people to walk or cycle – there is simply no evidence for this.

So in reality nothing much will change but you want to spend £300,000 of taxpayers money on just one part of Croydon to prove how pointless it will be. If you have £300,000 to spend on road safety it would be much better spent on other road safety initiatives, or point solutions.

It is most regrettable that these proposals have been put forward by those ignorant of the facts, and supported by a rigged public consultation exercise.

That is all I wish to say, but I hope Councillors will see sense on this matter and not pour £300,000s of taxpayers money down the drain.

Neither I nor local resident Peter Morgan who also spoke were given the opportunity to challenge many of the erroneous comments and “facts” presented by the supporters of this proposal, and none of members of the Scrutiny Committee apart from Conservative Councillors on the Committee (who spoke well incidentally in a reasoned and measured way, unlike some of their Labour opponents) took up any of the points I made or asked for more information. They prefer their own blinkered view of the wonders of such schemes rather than the facts – rather like adherents to a religion who will believe anything even though the facts undermine their beliefs.

One point not brought out though was that only residents within North Croydon were consulted (any responses from outside the area were ignored, so the views of those who drive through the area on the roads were sidelined).

As expected the motion to “call in” the proposal was rejected so the scheme will go ahead in North Croydon. Whether they will be able to push it through for other parts of Croydon, particularly if they see the results in the North Croydon first, remains to be seen.

Roger Lawson

Lambeth 20 Mph Scheme

Lambeth Council are pushing ahead with a borough wide 20 mph speed limit. See for the details.

Anyone who has any views on this should send them to Barbara Poulter at the Council (email address: ) . Here’s some comments this writer has already sent her (and the initial results from the 20mph speed limit in the City of London covered in another recent blog post show what a waste of money such schemes are and can actually increase accidents not reduce them):

Please note that we are not opposed to 20 mph speed limits in all locations – for example where the natural speed of traffic is near that speed. In many residential streets that is the case. However we are opposed to blanket wide area 20-mph limits because they are not a cost effective road safety measure, are not likely to be complied with and needlessly slow traffic.

  1. Let me first refer to your published document entitled “Lambeth Goes 20mph -Guide” which unfortunately contains a lot of inaccuracies.

For example, it states that “driving slower on residential roads has been proven to reduce traffic accidents,……”. Unfortunately there is no such evidence. Perhaps you could care to produce the evidence on that which is of course not supplied in the document concerned. Furthermore you say that “By reducing speeds to 20mph, it will reduce the number of casualties in the borough, improve pedestrian safety, encourage more confidence among cyclists and cut the number of incidents around schools”, but again there is no evidence for those claims.

  1. The facts are these:

a – In general the benefits of 20 mph signed area wide area schemes are grossly exaggerated. The average reduction in the speed of traffic is typically about 1 mph (assuming that there is no bias in the collection of data or other influences that might affect traffic speeds which is a dubious assumption).

Such a speed reduction is not likely to have a significant or measurable impact on road traffic accidents and not have any impact on the general environment of the roads concerned. Neither is it likely to encourage cycling or walking or discourage driving so the general health benefits will be nil – indeed there is no good evidence yet available for any such positive benefits (cities such as Bristol have claimed such benefits but their evidence is statistically dubious in the extreme).

b – The suggestion that a reduction in traffic speed translates into a significant reduction in collisions is not borne out by the real world evidence but is based on a biased analysis of traffic speeds on different types of roads. There has been no proper “controlled” trial of the use of signed only speed limits. The results in Portsmouth (which are mentioned in your document who claim an 8% reduction in collisions) do not provide firm evidence that there is any real benefit. Indeed KSIs in Portsmouth actually rose. I wrote this article on the bias inherent in the claims by Portsmouth that gives more information:

You also refer to data from Nottingham which only covers one year and any road safety engineer will tell you that one year is too short a time to be significant, particularly as there tends to be a short-lived reduction in accidents if the road environment is changed. And as you are no doubt well aware, it is more normal to only consider 3 year before and after periods as showing any significant change.

c – There is no good evidence that 20 mph sign only schemes provide any real, statistically significant, and below trend accident reduction. It is also worth pointing out that the Department of Transport (DfT) have recently commissioned a three year study into the effectiveness of 20 mph schemes as they suggest that current evidence is “inconclusive”. It would be rash of Lambeth Council to spend large amounts of money on any 20 Mph, signed only, schemes before more evidence is available on their financial benefit and effectiveness.

  1. There is no cost/benefit justification provided for the large expenditure of £700,000 on these proposals, money that would be better spent on other road safety measures. The key question is whether the benefits of that expenditure outweigh the costs, i.e. that it is a superior cost/benefit ratio to spending that money on other things.
  2. More evidence. Historically there was a 20-mph speed limit across the whole of the UK before 1930 when accident figures were much higher. Accidents fell after it was removed.
  3. In general the evidence put forward by those who support 20 mph wide area speed limits as a road safety measure is dubious and I would welcome the opportunity to contradict any that you receive. They often rely on selection of the data while ignoring other factors that might affect the results. In practice, their understanding of statistical evidence and the scientific method is weak in the extreme.
  4. So the key question, is whether spending £700,000 on such a scheme is worthwhile, or whether it would not be better to spend it on other road safety measures! Regrettably a proposal to reduce traffic speeds looks both simple and attractive which is why politically it can appear to be sensible. But road safety is a much more complex matter that is not amenable to simplistic solutions. Smaller, focused road safety schemes would be likely to create much more benefit than putting up 20 mph signs everywhere (which will of course be ignored by many road users who will consider it an inappropriate speed for many roads in Lambeth). Imposing a speed limit that is lower than necessary will slow traffic of all kinds, and will not be adhered to unless there is massive expenditure on enforcement (which of course has to be taken into account in the cost/benefit calculations as has the cost of increased travel times).

Finally, let me say that these proposals are being put forward by those who have little understanding of road safety or how to reduce accidents. In reality it is “gesture politics” of the worst kind. It it likely to result in fewer reductions in road casualties, and hence possibly more deaths, by wasting money that would be better spent on other road safety measures.

Roger Lawson

City of London 20 Mph Scheme – First Results

The City of London has produced the first report on the wide area 20 mph scheme that was introduced in July 2014. It covers the whole City other than the A3211 (Lower/Upper Thames Street), but that has been slowed to a crawl anyway by the new Cycle Superhighway and associated road works.

Average speed has been reduced by 1.5mph which is higher than most such schemes (1 mph is more normal). But whether this was a result of the speed limit or more congestion generally is unclear. TfL have been complaining about more congestion from larger number of private hire vehicles in London and the Cycle Superhighway works and redevelopment of Aldgate have had wider impacts on congestion in the City also.

Provisional casualty data up to June 2015 suggest that there has been a continued increase in the number of slight injuries to people walking and cycling, according to the report. Increases in such accidents were one justification for the imposition of this scheme. The report argues that without the scheme, accidents might have increased even more, but that is a somewhat dubious statement is it not?

More data on accidents is not yet available (3 years before/after is the best measure of course although interpreting the data because of other changes in the City may not be easy).

The police have been quite vigorously enforcing the 20 mph limit and reported 370 traffic offences in the last 12 months which has resulted in 180 fixed penalty notices and 99 court summons.

The overall cost of this scheme was originally estimated at up to £150,000, and surely it has been a complete waste of money based on the evidence to date.