ROAD DANGER REDUCTION FORUM
CONTENTS:
Page 2: About the Road Danger Reduction Forum
Page 3: The RDRF Response to the White Paper
General Comments
Some Basic Issues
Page 4: An example: The National Cycling Strategy
Page 5: Safety
Page 9: APPENDIX A: Indicators of Transport Safety
Page 11: APPENDIX B: Some Key Points
About The Road Danger Reduction Forum (RDRF):
The RDRF is a network of road safety professionals (road safety officers, traffic engineers, transport planners, public health doctors and others) who wish to develop a new approach to road safety, based on danger reduction at source. Since its inception in November 1993 some 40 local authorities have signed or supported the RDRF's Road Danger Reduction Charter. In 1996 the House of Commons Transport Committee published a report on 'Risk Reduction for Vulnerable Road Users' where the organisation whose submission obtained the largest number of favourable comments was the RDRF .
The approach of the RDRF, often referred to as the 'New Agenda', the "road danger reduction approach", or the "movement for real road safety", are now expressed by other organisations such as Transport 2000, RoadPeace, the Environmental Transport Association, and those bodies concerned with the rights and well being of people travelling outside cars, particularly cyclists and pedestrians. In October 1996 the Chairman of Edinburgh City Council's Transport Committee stated that the RDRF's 'Is It Safe: A guide to road danger reduction' "should be compulsory reading for everybody concerned with road transport".
The Vision of the RDRF
1. All road users being able to travel where they choose with a minimum of threat from other road users.
2. All road users taking full responsibility for the effects their transport choices have on others.
3. An environmentally sustainable transport system which provides equity and accessibility for all road users, permitting no disadvantage for those who choose not to own a car.
The RDRF Response to the White Paper
The RDRF has already made its views on sustainable transport and transport safety known to the Government in the consultation process preceding the publication of the White Paper. Below we confine ourselves to commenting on the principal elements of the white paper, and in particular on road safety.
General Comments
The White Paper marks a welcome and necessary change away from previous transport strategies in that it recognises the impossibility of supporting unlimited car use. It commends many of the necessary elements of a sustainable integrated transport strategy. Insofar as the detailed items of transport policy are not immediately apparent, it must be remembered that further elaboration is pending, for example through the road safety strategy due to be published this autumn.
Nevertheless, we are deeply concerned that the necessary mechanisms to achieve a sustainable integrated transport system are not present in the White Paper. In order to realise the vision of a civilised transport system it will be necessary to have far more robust elements available. It will also be necessary for all concerned to take full advantage of advocating progressive change in those items, such as the Traffic Reduction Act, which are not yet complete.
Some Basic Issues
1. Decision making at local and regional levels: We welcome the moves to have decisions on transport made at local and regional levels. This is a vital component of any sustainable transport policy. However, we are concerned that inadequate resources and expertise will be made to the local authorities charged with making these decisions. At present it appears that inadequate finance will be available, and that the tools for restraint will primarily be available to congested urban areas, and not the rural ones. It will furthermore be necessary for initiatives from central government, such as on fuel prices, to support these local initiatives. It is vital that the devolution of decision making is seen as empowering and enabling, rather than an avoidance of central government responsibility.
2. Land use planning: We welcome the understanding shown by government that land use planning is a central element of transport strategy. We are, however, concerned by the prospects of forms of development, such as greenfield housing, which could generate traffic and militate against the good moves stemming from other areas of the White paper. We are concerned about other problems which may arise from the loss of local amenities such as hospitals and the excessive dependence on car based retail outlets.
3. Integration between modes: We welcome the attempts to integrate different modes.
4. Fiscal proposals: It is a major step forward in government thinking to allow local authorities to spend income derived from the new transport charges on local transport. It is vital that legislation to implement this process has priority in order to deal with the transport crisis and not lose the momentum set up to do so. We believe that there is great benefit to be had from informing the motoring public that they have not paid for the disbenefits of motoring by the amounts of taxation they currently pay. It is of great importance to the road safety effort that the notion of motorists having "paid for the road" is dealt with, as it exacerbates the potential danger posed by motorists to other road users. This would involve making it clear that hypothecation - while a useful way of raising revenue - is flawed insofar as it backs up the idea that motorists are "paying their way".
5. Retail outlets: The Government should extend the potential for private non-residential (PNR) parking charges - a very useful and necessary form of revenue gathering and restriction on car use - to superstores and large car dependent retail outlets. Revenue gained can be directed into supporting home delivery schemes and local shopping projects.
6. Freight: The Sustainable Freight strategy awaits publication. We hope that there will be efforts to support appropriate restrictions on driver hours and other safety measures, as well as the creation of a lorry route network and restriction on access to non-trunk roads.
7. Car ownership: We feel that the aim of supporting the extension of car ownership is misconceived. We believe that this will inevitably conflict with the aim of slowing traffic growth, let alone of traffic reduction, unless far stronger restrictive measures are taken. We would like to see support for car-free housing and other developments, promotion of car clubs/street fleets as a practical alternative to private car ownership.
8. Traffic reduction: There is a vital need to reduce private motor vehicle traffic. This would have major benefits in terms of reducing danger on the road, noxious emissions, greenhouse gas emissions, noise and other forms of environmental destruction. It would make the alternative forms of travel and land-use more viable, and is indeed necessary for this to occur. The White Paper can be read to simply aim at making traffic growth occur less rapidly than it would do otherwise. We believe that this can be changed by Government making a commitment through the Traffic Reduction Act to a national traffic reduction target and a target for reduction in CO2 emissions from the transport sector.
9. Rural areas: the principal thrust on restricting car use is in congested urban areas where traffic growth is unlikely to increase much further simply because of the pressure of traffic. The principal problems as far as creating a society less dependent on cars, and in terms of reducing greenhouse gas emissions, are likely to occur in suburban and rural areas. Problems of safety in rural areas, and the difficulty of creating an inclusivist society for those who are unable or unwilling to own and use cars in rural areas have not been fully addressed in the White Paper.
An example: The National Cycling Strategy
Our view can be illustrated through just one example of policy in the White Paper: the case of the National Cycling Strategy (NCS). The White Paper clearly endorses the targets for modal share by cycling in the NCS. The RDRF warmly welcomes this endorsement as a vital component of an integrated sustainable transport policy. However, we must point out that unless there are significant additions and/or amendments to the White Paper, these targets are highly unlikely to be achieved.
In order to achieve the NCS targets of modal share, which are quite modest compared to the existing levels of cycle use in a number of European countries, it will be necessary to give far more support to cycling, and less support for private motoring. This can include:
· Allocating specific ringfenced funding of approximately £500 million over a five year period to cycle schemes throughout Britain. Also, clear incentives to pursue good practice can be made by ensuring that failure to progress towards implementing the necessary facilities will be considered in settlements awarded to Local Transport Plans.
· Increasing levels of law enforcement with deterrent sentencing for motorists endangering cyclists through careless or dangerous driving.
· Commitment to reduction in levels of private motor vehicle use through setting of traffic reduction targets with support for the appropriate fiscal and legal measures to make them realisable.
Traffic reduction is a necessary commitment as levels of motor traffic are a deterrence to cycling, and because support for cycling is not in itself likely to create sufficient new cyclists to achieve the targets.
The RDRF plays a role in the National Cycling Strategy's Cyclists and HGVs Working Party. This addresses the serious problems involved with collisions between cyclists and lorries, particularly in urban areas. These problems will be significantly affected by policies in the forthcoming Sustainable Freight Strategy if these are able to reduce the types of danger which HGVs can pose to cyclists, as well as the perceived intimidation from their presence which can act as a deterrent to cycling.
A number of positive features of the White Paper point in the right direction. The proposed review of speed limits could, if linked to reduced speeds, significantly reduce danger to cyclists as well as all road users, and create a less threatening environment for cyclists. A commitment to provide integration between different modes of transport could assist low cost but necessary measures required to, for example, assist cycling provision at rail stations and on trains. Such measures are typically low cost but useful.
In addition, the Government's decision to allow local authorities to spend income derived from new transport charges on local transport allows for the expenditure on much needed cycle schemes according to local needs. The emphasis on looking at transport strategy on a local and regional basis is a necessary element of any sustainable transport policy.
However, the useful pointers will ultimately fail to assist the realisation of the necessary changes because there is insufficient support for a shift to cycling, and above all, inadequate restriction and restraint on the way the lorry and the private car are used. We regret that there are inadequate mechanisms to assist and support those local authorities willing to provide the required infrastructure and associated measures, or to require a commitment from those reluctant to pursue a sustainable transport strategy.
"We do not want to make roads safer (sic) by simply discouraging vulnerable groups from venturing on to roads" Paragraph 3.220
The numbers issue.
Where falling casualty figures have been achieved by migration of vulnerable road users, often precisely because of increased danger, it is quite wrong to suggest that the road environment has become safer. The Road Danger Reduction Forum has been the foremost body in Britain arguing this point, and we are glad to see that the White Paper accepts this argument. Nevertheless, it appears from Paragraph 3.220 that this point is still not fully understood, and results in a self-contradictory and meaningless statement.
The RDRF has consistently argued that aggregating reported personal injury statistics of various kinds is not a true measure of the level of danger on the roads, partly for the reason stated above. Throughout Britain local residents restrict their children or themselves from using the more benign forms of transport because of danger from motorised traffic, while reported casualty figures create a picture of a "good road safety record". The civilised response to this state of affairs is to seek and then use alternative measures of danger on the road, such as casualty rates for different types of road user per distance or journey travelled. Other measures are indicated in the enclosed Appendix A.
Yet the persistence of the DETR in assessing safety in terms of aggregated reported casualties means that lower totals are still seen as being equivalent with safety, as expressed in Paragraph 3.220. The implication is still that modes of transport which are less dangerous to others than car use such as cycling and walking tend to make roads less "safe". Those outside cars are seen as a problem group because of their vulnerability, despite their relative lack of threat to others, quite apart from their health and environmental benefits.
The numbers issue is of particular relevance as the new Road Safety Strategy is about to be published, and targets and numerical issues of safety are central to the discussion. Below we present a discussion of the issues in Appendix A.
The morality issue
The RDRF is insistent on pointing out the difference between endangering or hurting others on the one hand, and being endangered or hurt on the other. This issue - the who kills whom issue - is central to a correct understanding of road safety. It needs to be pursued in all sections of the road safety effort, whether education, road and vehicle engineering or law enforcement and sentencing.
Roads for all
The White Paper shows a welcome interest in supporting the right of children to walk or cycle to school. However, it must be understood that mobility for children can not be achieved solely by the provision of segregated routes: people of all ages will need to use the existing road network to walk and cycle. Concentrating on segregated routes can lead to marginalisation of important forms of transport, and is technically unfeasible in many cases.
Enforcement
"Previous governments have, we believe, done little to combat the idea that many road traffic offences - speeding in particular - do not really matter…we need to take a radical look at enforcement." Paragraph 4.178
We warmly welcome the above paragraph. Whatever the gains to be made through various types of road and vehicle engineering, it remains the case that while there is the ability to endanger others through rule and law breaking, law enforcement and deterrent sentencing will be vital for the road safety effort.
We are a little concerned at the emphasis that "Better enforcement does not necessarily require more resources" in Paragraph. 4.179. While it is undoubtedly true that advances in technology are creating new scope in levels of la enforcement, it should not be overlooked that technology always needs a human resource back up. Law enforcement should always be properly resourced.
There is a great deal of public concern at lenient sentencing for criminally negligent motorists who kill or injure others on the roads. We believe that it is now time to hold a full scale re-assessment of road traffic law and its enforcement in conjunction with the Home Office. Serious offences should be highlighted, as well as matters such as bus lane infringement (Paragraph 4.182).
Education and training
"Safety should be an additional incentive for action, not a reason for delaying priority measures for cyclists". Paragraph 3.11.
We strongly welcome this comment. We are, however, concerned that this sentiment may be difficult to realise while the problems outlined with regard to successful implementation of the National Cycling Strategy above remain. We believe that it should be possible to support the all too few schemes to educate and train cyclists, such as those carried out by our member City of York Council with additional central government funds.
General transport and safety education
The White Paper heralds a reversal of traditional transport thinking based around the idea of the desirability of continuing motor traffic growth. This new climate of thinking, supporting an increase in the amount of cycling and walking, will require a new consciousness on the part of Britain's travellers, both present and future, if the transport system is to function safely and effectively.
The private car has always been associated with ideas of personal freedom. Despite the fact that there have always been laws and rules against careless or dangerous driving, the breaking of these laws and regulations has been widespread, with culpable motorists believing that they have the right to decide the manner of their driving, whether or not it is illegal. Similarly, the decision to drive on roads where such a choice can never belong to more than a minority (for example, on congested urban roads at peak hours) is frequently seen as "right".
We believe it is absolutely paramount for such ideas to be successfully challenged if the long term aims of the White Paper are to be achieved. It will otherwise be too difficult to get public consensus on necessary measures, whether they be congestion charging, road space re-allocation, or law enforcement. In particular, we believe that the idea that motorists have "paid a tax for the road" is deeply harmful. It can, amongst other things, lead to discriminatory and dangerous attitudes to cyclists and pedestrians, as can the idea that motorists have earned a special right to be on the road by passing a driving test or paying third party insurance.
It is vital that central government supports a widespread educational programme in order to raise awareness about transport issues. The magnitude of this "hearts and minds" task needs serious attention and investment. This will ensure that planned physical changes to the road environment and transport services meet with changes in travel behaviour rather than resistance.
Speed
"We will therefore set up a review to develop a speed policy that takes account of the contribution of reduced speeds to environmental and social objectives as well as to road safety". Paragraph 3.228
There is already substantial evidence about the great safety and environmental advantages of reducing speeds. We welcome any change in speed policy that leads to reduction in speed of motor vehicles. To succeed, any such policy will require the use of appropriate technologies, which themselves should be developed in order to control other kinds of motorist behaviour with the potential to endanger others. Telematics and 'smart' technologies should be investigated and promoted as means of controlling danger at source.
APPENDIX A: INDICATORS OF TRANSPORT SAFETY
A Cautionary Note: Targets, Indicators and Road Safety Strategy
Traditionally used statistics are not a good indicator of whether roads are safe, and may even be perverse indicators of safety. Of course, even if we get very high quality indicators, this does not necessarily mean that local or central government will feel the need to pursue attempts to secure change leading to such indicators painting a better picture: the strategy pursued, rather than concern with statistics, is what really counts.
Nevertheless, we will always be hampered by a culture which says that things are better than they actually are by using traditional methods of analysis. RDRF came into being largely to oppose this method of evaluating safety on the roads, and continues to do so. We continually emphasise that retrospective analyses of aggregated casualty statistics are a poor or even contradictory performance indicator for assessing safety for road users. Our other main point of emphasis is that the road safety strategy should be an integral part of the new sustainable integrated transport strategy, and that unless this is fully understood, serious errors - however unintentional - will be made.
A reminder: What's Wrong With the Current Target(s)
1. Current figures are aggregates of different kinds of phenomenon. There is no distinction between innocent people killed/hurt by others and people killing/hurting themselves. Even where benign road users are legally at fault, one can argue that being killed/hurt is different from hurting/killing others. (The "who kills whom" question).
2. Figures - particularly for less serious injuries - are unreliable, because of unknown amounts of under-reporting and mis-reporting.
3. In terms of personal experience the figures tell us little, even if we talk about figures for a particular group of road users. This is partly because of the morality of issues involved (see 1. above), but also because there is no indicator of exposure. Exposure means looking at casualty rates (casualties of one type or another per distance, time taken, or journey travelled).
4. In fact, even casualty rates as depicted fall far short of an accurate representation of our individual problems. Rates have to be split down not just to road user groups, but by age and more specifically by location. Sometimes there will be different stories for different kinds of rate: fatality rates are higher for cyclists in rural as opposed to urban areas, but less serious casualties have lower rates.
5. In fact, even very accurate casualty rate measurements are hampered by being retrospective analyses of what has happened: they do not relate directly to the danger posed to road users. Hence the interest in indicators of levels of danger.
So what kinds of indicators?
A. Casualty rates, where rate is referring to the journey made.
This could be casualties per average trip, or casualties per kilometre, for each road user group.
B. Insurance claims.
There is a set of published figures from the Association of British Insurers (ABI) in RAGB. This almost doubled in the 1980's alone, and could be said to be an indication of danger as it relates to the much larger number of vehicle crashes rather than he casualties which occur in only 5% -20% of them.
C. Likelihood of killing others indicator.
It is possible to get a picture of the chances of being involved in a crash where someone else dies, and translating this into a likelihood of killing others indicator, with a comparison between different kinds of road user, rather than the more usual comparison in terms of being killed or hurt. This would not, however, be a useful target type of statistic, merely an indication of comparative danger to others.
D. Percentages of children (at different ages) allowed to walk or cycle to school.
E. Modal split or traffic reduction target.
There are a number of targets which are indicative of the aims of a sustainable transport policy, such as proportions of journeys by more benign modes, reduction in motor vehicle traffic overall etc.
F. Speed targets.
We should consider proportions of motorists breaking speed limits if we have a specific speed target, which is published already.
G. Total or average motorist 'blunder' numbers.
This was best described in the Autoglass survey, where self-report (Note: motorists tend to under-report their mistakes or bad driving) studies by motorists indicated an average of 50 'blunders' per week. These 'blunder's are types of behaviour designated as 'accident-causing' by TRL criteria. A target would be trying to get 50 - 100 billion blunders a year down by a few billion.
H. General attitudes.
Questionnaires or quicker repertory grid techniques can be used to assess residents attitudes to particular schemes, and amplify issues like allowing children independent mobility.
NOTE: Severity of casualties. Apart from the fact that these are affected by levels of medical care and methods of data collection (i.e. under new STATS 19 rules whiplash alone counts as 'Slight Injury'), Slight Injuries have increased by about 50% since the early 50's and contradict the picture painted by DETR figures.
Finally, RDRF has consistently emphasised two points:-
1. The moral issue which highlights the difference - if not conflict - between looking after yourself and endangering other people (community rather than just personal safety), and
2. The importance of the overall strategy, rather than specific targets.
APPENDIX B: A SUMMARY OF KEY POINTS
The RDRF welcomes:
· The change away from previous transport strategies by recognising the unsustainability of increasing car use, and the desirability of less dependence on the private car.
· The encouragement for local authorities to pursue their own strategies based on local needs.
· The importance accorded to land use planning.
· The focus on different types of integration in transport strategy.
· The potential for local authorities to spend money derived from forms of taxation on car use.
· The endorsement of the National Cycling Strategy.
· The review of policy on speed.
· The intention of not achieving a reduction in casualties by having fewer vulnerable road users in the road environment.
· The commitment to take enforcement of at least some parts of road traffic law seriously.
· The consideration of children's ability to walk or cycle to school.
· The consideration of re-allocation of road space from cars to pedestrians.
We are, however, concerned that the vision of integrated sustainable transport which is in many places apparent in the White Paper will not be fulfilled because:-
· There are insufficient instruments, whether through law enforcement, fiscal measures or land-use planning to ensure that the goal of a sustainable integrated transport system is achieved.
· This is further exacerbated by the apparent lack of urgency in passing necessary legislation.
· There is no commitment to traffic reduction, merely to reduction in it's growth.
· There is a lack of understanding that increasing car ownership tends to lead to increasing traffic.
· Excess motor traffic is seen as primarily an urban problem, rather than a problem which also has severe implications for rural areas.
· Without clearer controls and assistance local authorities will be unable to control the problems of excessive car use, and will see themselves as being the recipients of problems which could have been addressed more thoroughly at the level of central government.
· The Government continues to see safety as being analogous to absence of casualties from road crashes, despite an awareness that lack of casualties is not only different from, but can coincide with danger rather than safety.
· There may be insufficient controls on the extent and nature of road freight use.
· There has not been consideration of large retail outlets for inclusion in potential car taxation schemes.
There has not been adequate recognition of the magnitude of the hearts and minds element of awareness raising about transport issues with the associated investment required.