RDRF submision to House of Commons Transport Committee

This has now been accepted as evidence:

House of Commons Transport Committee: Reply by Road Danger Reduction Forum to “Call for Evidence” into the Government’s “Strategic Framework for Road Safety”.

                                                     

 30th October 2011

 

SUMMARY OF MAIN POINTS:

  • While there are fundamental flaws in the Government’s approach to safety on the road, nevertheless we can say that:
  • The absence of traditional road safety targets being set is not necessarily a problem: however, there is a need for alternative targets to be set to reduce danger on the road, and they have not been.
  • The decentralisation programme of the current government will impede any efforts to reduce danger on the road.
  • The current legislative framework, combined with inadequate levels of traffic policing, is utterly insufficient to properly reduce danger ion the road, particularly towards cyclists and child pedestrians.
  • The action plan will not be able to achieve reduction in the chances of cyclists and child pedestrians being hurt or killed on the road.

 

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  1.  Introduction: The Road Danger Reduction Forum (RDRF)   

1.1     The RDRF was formed in December 1993 after the “Is it Safe?” Conference organised by Leeds City Council, itself prompted by the publication earlier in the year of “Death on the Streets: Cars and the mythology of road safety” by Dr. Robert Davis. The RDRF exists for professionals working in and for local government as highway and traffic engineers, road safety officers and others supporting road danger reduction (RDR) as part of the sustainable transport policy agenda. It has 20 local authorities as members that have signed the Road Danger Reduction Charter.

1.2      We also try to form partnerships with organisations that support the RDR, or “real road safety” agenda, such as the national cyclists’ organisation CTC, the Environmental Travel Association, London Cycling Campaign, the national road crash victim’s charity RoadPeace, Slower Speeds Initiative, etc.

1.3      Road Danger Reduction (RDR) – the “real road safety” agenda: We believe in “Safe Roads for All”, and that much of traditional “road safety” has been part of the problem of danger on our roads. We highlight these problems as they appear in the text of“A Safer Way: Making Britain’s Roads the Safest in the World”, as shown on our website www.rdrf.org.ukMore detailed explanations of road danger reduction and the steps required to achieve it are elsewhere on www.rdrf.org.uk The principal feature of RDR is the commitment to reduce danger at source – the inappropriate use of motor vehicles.

1.4      As such, we have fundamental problems with the Government’s strategic framework for road safety which we are asked to comment on. These are detailed at https://rdrf.org.uk/2011/05/a-bad-day-for-safety-on-the-roads/ and  https://rdrf.org.uk/2011/05/what-else-is-wrong-with-the-strategic-framework-for-road-safety/. Nevertheless, there are some comments we believe we should make:

 

  1. 2.   “Whether the Government is right not to set road safety targets and whether its outcomes framework is appropriate.”

2.1       There is substantial evidence, as evidenced in the Smeed curve, and discussed at length by us and authorities such as Professor John Adams, that road deaths per head of the population decline over time irrespective of the type of road safety intervention introduced by Government. We believe it likely that road deaths will decline with a likely decline in general levels of societal risk, which appears to be associated with a likely reduction or stagnation in economic activity.

2.2        It is also the case that many “road safety” interventions shift the burden of risk from the road users more dangerous to others (the motorised) on to the more vulnerable and benign modes (walking and cycling). It is therefore the case that reductions in overall road deaths can be at least partly due to a smaller share of the traffic mix by walking and particularly cycling.

2.3       As such, the absence of “road safety targets” by Government may not be a problem. Nevertheless, there are objectives which can be quantified which should be specified by Government as aims. These are:

2.4       (a)The targets referred to as “rate-based targets”, that is to say casualties (Killed and Serious Injuries – KSIs) expressed in relation to levels of exposure, e.g. casualties per journey or distance travelled. These should be the desired primary targets for reduction for cyclists, with more importance than the overall numbers of KSIs for cyclists nationally or in local areas. These can be used in areas where there are significant amounts of travel by bicycle and where there is therefore adequate data.

     (b) For pedestrians, where data on numbers of journeys is more difficult to secure, the target should be casualties per journey at specific sites.

     © Even where the “rate-based target” is used, this does not adequately refer to the danger to cyclists and pedestrians. It is possible to illustrate the rate-based targets by referring to the issue of legal fault: the long-term aim should be to reduce the rate of cyclist and pedestrian casualties where other road users are primarily legally at fault.

     (d) As a subsidiary target, it should be desirable to survey people as to whether levels of road danger are high enough to dissuade cycling and walking for them and their children.

2.5     Other targets which should be used are those relating to levels of dangerous behaviour, principally rule and law breaking behaviour by motorised road users, such as reductions in proportions of drivers and motorised riders who are:

(a)         Breaking speed limits.

(b)         Consuming alcohol or drugs (proprietary and prescribed psychotropic drugs as well as recreational).

(c)         Having inadequate eyesight.

(d)         Having medical conditions such as Alzheimer’s disease.

(e)         Engaging in inappropriate behaviour in the vicinity of cyclists such as breaking Highway Code recommendations with regard to overtaking distances, opening of car doors inattentively, etc.

2.6    Interventions to achieve the reductions which we refer to as desirable should be financed by central Government. Precise amounts can be related to savings in the normal manner, but should also include the costings in terms of health benefits of increased cycling and walking which can occur as a result of increased safety on the road.

 

  1. 3.   “How the decentralisation to local authorities of funding and the setting of priorities will work in practice and contribute towards fulfilling the Government’s vision.”

3.1     We think that the current decentralisation strategy will involve a reduced level of economic activity and – for the reason referred to above (2.1) – will, in that sense, be associated with a decline in overall reported road casualties. It will not, however, be associated with the desirable objective of achieving safety for all by reducing danger at source, and will not increase real road safety.

3.2      The decentralisation strategy will inevitably involve a reduction of spending on attempts to reduce danger on the road by local authorities. We notice that this is already happening with our supporters in various local authorities.

3.3      We are asked to “ensure that … the relatively high risk of accidents amongst some groups, such as cyclists and children from deprived areas, is quickly reduced. The Committee will examine whether the strategic framework will fulfil this vision.” This will not happen with the current decentralisation programme.

 

  1. 4.   “Whether the Government is right to argue that, for the most part, the right legislative framework for road safety is in place, and, in particular, whether the Road Safety Act 2006 has fulfilled its objectives (see Post-Legislative Assessment of the Road Safety Act 2006, Cm 8141, published by the DfT, July 2011)”

4.1      We do not think that the Road Safety Act 2006 can be said to have achieved its objectives.

4.2       We do not believe the correct legislative framework is in place, because:

4.3       The current and likely future decline in levels of policing mean that already inadequate levels of enforcement will be unable to give the required levels for legislation to have a proper effect.

4.4       In order for danger to be properly reduced for cyclists and pedestrians, it will be necessary to have collisions between drivers on the one hand, and pedestrians and cyclists on the other, defined as offences of strict liability for the driver. This should be the case under civil law, and as far as is possible under criminal law.

4.5       It will also be the case that in order for legislation to be effective, adequate forms of evidence gathering, such as with on-board “black-box” type collision recorders will have to be in place.

 

 

  1. 5.   “Whether the measures set out in the action plan are workable and sufficient”.

5.1      The measures set out in the action plan are in no way sufficient to: “ensure that …  the relatively high risk of accidents amongst some groups, such as cyclists and children from deprived areas, is quickly reduced.”

 

We are available to expand on any of the above issues to the Committee.

 

Dr. Robert Davis, Chair, Road Danger Reduction Forum www.rdrf.org.uk  

CONTACT ADDRESS: chairrdrf@aol.com  PO BOX 2944, LONDON NW10 2AX