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Report to:
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Lead Member for
Transport and Environment
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Date of
meeting:
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26 June
2023
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By:
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Director of
Communities, Economy, and Transport
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Title:
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Notice of Motion to
review and update policy PS05/02 Local Speed Limits
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Purpose:
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To consider the Notice
of Motion requesting the County Council to review and update policy
PS05/02 and demonstrate that it is in line with Department for
Transport Circular 01/2013 to include a full audit of speed limit
assessments completed in the last two years.
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RECOMMENDATIONS:
The Lead Member is
recommended to recommend that the County Council rejects the
Motion.
1 Background
Information
1.1 The following
Notice of Motion has been submitted by Councillor Denis and
Councillor Georgia Taylor:
Policy
PS05/02 sets out the Council’s policy on local speed limits.
It claims to be in line with Government best practice guidance and
legislation on road safety. (Road Traffic Regulation Act, and more
recently the Department of Transport Circular Roads 01/2013.)
The
Policy sets out speed limits in section 5 of this policy with
average speed limits and it states that if average speeds are above
that level then, subject to “available resources”,
where injury or crashes at a site justify the necessary
expenditure, engineering measures will be implemented first and, if
this is not possible, then a lowering of the speed limit may be
introduced.
This
policy oversimplifies an approach to road safety and speed limits
that is not consistent with the guidance outlined in the Department
of Transport Circular Road 01/2013.
The above
Circular sets out that “Local traffic authorities are
responsible for determining speed limits on the local road
network”.
It
continues: “The underlying aim should be to achieve a
‘safe’ distribution of speeds. The key factors that
should be taken into account in any decisions on local speed limits
are:
·
history of collisions
·
road geometry and engineering
·
road function
·
composition of road users (including existing and potential
levels of vulnerable road users)
·
existing traffic speeds
·
road environment
While
these factors need to be considered for all road types, they may be
weighted differently in urban or rural areas. The impact on
community and environmental outcomes should also be
considered” [my emphasis].
The
following parts of the policy PS05/02 are not consistent with
national Circular 01/2013: specifically:
·
Paragraph 5. Speed limit table is an over simplifcation of a
complex assessment and as such is only one part of the overall
process. Using this table in this way means that the views and
experiences of residents are not being taken into account when
assessing speed limits as set out in the Circular. (ref 23 Circular
01/2013)
·
Paragraph 6. Refers to speed limits being investigated will be
subject to “available resources”. The Circular outlines
a cost benefit analysis that includes a wide range of non monetary
benefits that have to be considered including quality of life
factors and fear of speeds [my emphasis]. (ref: 31 Circular
01/2013)
·
Paragraph 7a: casualty reduction: The Circular further sets out
that the assessment is not simply about casualties on a road or
killed or seriously injured, but is a more complex process of
assessment that has to include the experience of other road users,
pedestrians, cyclists, horses and riders [my emphasis] (ref 32
Circular 01/2013)
·
Paragraph 7c: The self enforcing requirements of PS05/02 is not
a defacto requirement. It is a factor to consider and as such
the danger is that policy is used to uphold existing speed limits
rather than consider why compliance might be an issue and how to
address compliance. (ref 26 Circular 01/2013).
·
Appendix A outlines an approach to speed limit criteria that is
equally outwith of the national guidance, which requires local
traffic authorities to perform an assessment that includes
listening to local residents, and introduce 20mph speed limits in
towns AND villages, “particularly where the streets are being
used by people on foot and on bicycles, there is community support
and the characteristics of the street are suitable” (ref 84
Circular 01/2013).
Such
priorities are given further emphasis in the January 2022 revisions
to the Highway Code, in particular, the clear notation on the
‘Hierarchy of Road Users’, which “places those
road users most at risk in the event of a collision at the top of
the hierarchy. … [These are] pedestrians, cyclists, horse
riders and motorcyclists, with children, older adults and disabled
people being more at risk.”
This
Council agrees:
a) To
request the Lead Member for Transport to demonstrate that PS05/02
and its operational implementation is fully in line with the
Circular 01/2013 with a full audit of speed limit assessments
completed in the last 2 years.
b) To
request that the Lead Member shares the results of this audit with
Full Council within two months.
c)
That PS05/02 be reviewed within the next two months and be
presented to Full Council to ensure it is fully in line with all
aspects of Circular 01/2013
d)
That community and resident experience, quality of life and fear
of speeds are included as explicit criteria in PS05/02 as clearly
indicated in Circular 01/2013.
1.2 In line with County
Council practice, the matter has been referred by the Chairman to
the Lead Member for Transport and Environment for consideration to
provide information and inform debate on the Motion. The Lead
Member’s recommendation on this Notice of Motion will be
reported to the Council at its meeting on 11 July 2023. A copy of
the Notice of Motion is included as Appendix 1 to this report.
2 Supporting
Information
3
2.1
Adopted Policy
PS05/02 Local Speed Limits (included as Appendix 2 to this
report) was approved by the Lead Member for Communities and Safety
on 16 March 2018. It is based on a range of national guidance issued by The Department for
Transport (including Circular 01/2013 that provides guidance to
local authorities for assessing and setting speed limits), best
practice, and is informed by the Council’s experience of
achieving effective speed limits. Circular 01/2013 is government
guidance and whilst it provides high level advice about what should
be considered when setting effective speed limits, it is not
definitive.
2.2 East
Sussex County Council ( ESCC) is committed to working with
all stakeholders to improve road safety across East Sussex,
including our partners on the Sussex Safer Roads
Partnership.
Setting effective
speed limits
2.3
The principal aim in determining appropriate speed limits is
to provide a consistent message between the speed limit and what
the road looks like, and for changes in the limit to be reflective
of changes in the road layout and characteristics.
2.4 The use
of average speeds to help define the level of a new speed limit
recognises that most road users drive at a speed that they consider
to be safe and appropriate for the road characteristics. A limit
should therefore seek to reinforce what an average driver sees as
the safest speed for the environment, thereby achieving the highest
level of compliance and a ‘safe distribution’ of
vehicle speeds.
2.5
The ‘Key points’ section to Circular 01/2013
includes that ‘speed limits should be evidence-led,
self-explaining and seek to reinforce people's assessment of what
is a safe speed to travel. They should encourage
self-compliance’.
2.6 It also
states that the guidance should also ‘be used as the basis
for assessments of local speed limits, for developing route
management strategies and for developing the speed management
strategies which can be included in Local Transport
Plans’.
2.7
National and international studies have indicated that reducing a
speed limit with traffic signs and road markings alone only reduces
the average speed of traffic by about one or two mph at most, and
only then when a driver can readily see the reason for the lower
limit. This replicates the Council’s own findings from before
and after studies when lower speed limits have been
introduced.
2.8 This is
reflected in the guidance which states ‘unless a speed limit
is set with support from the local community, the police and other
local services, with supporting education, and with consideration
of whether engineering measures are necessary to reduce speeds; or
if it is set unrealistically low for the particular road function
and condition, it may be ineffective and drivers may not comply
with the speed limit’. In addition, evidence indicates that
where signed only speed limits are introduced which do not match
the average speed of traffic, there can be increased overtaking and
conflict between drivers, which increases the likelihood of
collisions.
2.9 Sussex
Police have confirmed that they will not support any lower speed
limits that cannot demonstrate that they will be self-enforcing and
that they will not provide any additional enforcement over that
which would have been provided prior to the introduction of any
lower limit.
2.10 It is
therefore important that any consideration relating to a lower
speed limit must consider the prevailing conditions and existing
average speed of traffic, as this will demonstrate what is likely
to be an effective speed limit. If a lower speed limit is deemed
desirable but is not reflected in the road’s characteristics
or average speeds, then traffic management or engineering measures
will be required to ensure that the imposed limit is
effective.
Review of relevant national
guidance
2.11
Following receipt of the Notice of Motion, a review was undertaken
of the relevant national guidance issued by The
Department for Transport (including Circular 01/2013 and the
January 2022 revisions
to the Highway Code) and this concluded that adopted Policy PS05/02
continues to reflect national guidance and best
practice.
Wider policy and
operational context
2.12 It is
important to clarify that the purpose of Local Speed Limit Policy
PS05/02 is to clearly set out the key criteria required to ensure
that speed limits are effective and should not be considered in
isolation when considering how ESCC assesses and prioritises road
safety concerns including requests for lower speed limits. It is
important to consider the wider policy and operational context,
including the County Council’s Local Transport Plan, and the
processes and criteria followed when setting the annual Capital
Programme for Local Transport Improvements, the Annual Road Safety,
Community Focused Road Safety and the Speed Management
Programmes.
Capital Programme
for Local Transport Improvements
2.13 Each year the
County Council develops and implements numerous local transport
improvements funded through its capital programme of local
transport improvements. In 2022/23 total funding of £11,776m
was allocated (a combination of funding from the County Council,
Local Growth Fund secured via the South East Enterprise Partnership
and development contributions) which delivered over 50 schemes and
studies across the county which include a number of road safety and
active travel improvements.
2.14 All
requested road safety and local transport improvements, including
requests to change the speed limits are assessed against the
established Local Transport Plan (LTP). The content of the capital
programme is considered by the Lead Member for Transport and
Environment on an annual basis. Key objectives against which
requests are assessed include the extent to which it
will:
·
Improve the
economy
·
Improve public safety
and health
·
Tackle climate
change
·
Improve accessibility
to employment, education, health facilities and other
services
·
Improve quality of
life
2.15
A review of ESCC’s Local Transport Plan commenced in
Summer 2022. The Government’s guidance on developing Local
Transport Plans is due imminently and it is expected to indicate
the need to focus on decarbonising transport as well as integrating
the Government Levelling Up, Bus Back Better and Gear Change
strategies into the Council’s transport strategy for the
county. A key element of the development of the new LTP has
been to engage with members, stakeholders, local communities and
businesses early and throughout the process to actively seek their
views and comments. This was initially through public and
stakeholder consultation on issues, opportunities and priorities in
autumn 2022 and at present via a series of workshops on the vision,
objectives, preferred strategy and potential interventions to
deliver the strategy. A LTP Reference Group comprising members of
the Place Scrutiny Committee and chaired by Councillor Redstone has
been established to provide Member input and challenge throughout
the LTP’s development.
2.16
Consultation on the draft LTP strategy, which will include an
updated scheme assessment process, will be undertaken in autumn
2023 with final adoption of the strategy programmed for early
2024.
Annual Road Safety
Programme
2.17 All road
safety concerns that are raised by Members and residents are
assessed by a member of the Road Safety Team and where appropriate
improvements introduced. In addition, annually the Road Safety Team
identifies sites that have the most personal injury crashes
(PIC’s) and put in place a programme of works to help reduce
the number of casualties on these roads. As part of this
year’s Road Safety Programme, 49 locations have been
identified where four or more PIC’s have occurred in the
three-year assessment period of 01/01/2020 to
31/12/2022.
Community Focused
Road Safety Schemes
2.18 The
Council receive many requests for small scale road safety
improvements to be made, including changes to speed limits, which
do not meet the requirements to be considered as part of the Annual
Road Safety Programme. To address these concerns £750,000 has
been allocated from the Community Match underspend to deliver
community focused road safety interventions. Selected schemes
address identified road safety concerns and are identified by
considering a range of issues and specific site characteristics,
weighted to define their relative priority. Current funding will
enable a three-year programme of works to be delivered. Approval
has also been given for any future underspends from the Community
Match allocation to be allocated to support further Community
Focused Schemes to be delivered.
Community Match
Initiative
2.19 Where
requests from Members or residents do not meet the criteria for
inclusion in the above Programmes, the Community Match Initiative
provides residents with the opportunity to take forward schemes to
lower the speed limit where appropriate when these are funded
locally. Where possible, the Council will support and assist local
communities and town/parish councils to implement such schemes, if
they are funded externally, or match funded through Community
Match.
Notice of
Motion
2.20 The
Notice of Motion highlights extracts from Circular
01/2013. The Road Safety Team have regard
to and consider the guidance as a whole during their assessment of
sites for potential inclusion within the annual Road Safety
Programme, the Capital Programme for Local Transport Improvements,
the Community Focused Road Safety Programme and will do so when
considering schemes for the Speed Management Programme. Appendix 3
sets out the sections of guidance referred to in the Notice of
Motion and provides further clarification on when the Road Safety
team consider these.
2.21
In order to undertake the
assessment and analysis requested it would be necessary to divert
officer resource away from delivering our annual road safety
programmes as detailed above in this report.
Review of Speed
Limits
2.22
Following the release of updated national guidance by the
Department for Transport in 2006 the Road Safety Team completed a
review of rural speed limits. As a result of this review, and in
line with the guidance, several lower speed limits were introduced
on rural roads. The speed limits met the guidance in terms of
visual characteristics. The opportunity was taken to undertake some
‘before and after’ studies to help us understand the
effect that introducing lower speed limits had on driver behaviour.
The results of this study are included as Appendix 4 to this
report.
2.23 The
results demonstrate that producing lower vehicle speeds is more
complex than solely relying on the introduction of a new speed
limit and associated signing.
2.24 The
Council is aware that neighbouring authorities have, or are
considering, amendments to their adopted policies relating to the
introduction of local speed limits and will assess the
effectiveness and impact of these policy changes when outcomes are
known.
2.25
A £500,000 budget has been allocated
to undertake a new
Speed Management Programme with additional on-going funding
identified within future Capital Programmes.
2.26 As
part of the Speed Management Programme a review will identify
lengths of the main road network that would benefit from a reduced
speed limit. It will also check that existing speed limits are
effective and producing the desired reductions in vehicle speeds
using available speed data and new in-vehicle telematics. The
review will also identify sites of greatest need and local concern
where proven traffic management measures would have a positive
effect and enhance the effectiveness of the speed limit. Over the
next three years, more than 25 stretches of road will benefit from
speed limit reductions or measures that will increase the
effectiveness of existing speed limits.
3 Conclusion and Reasons for
Recommendations
4
3.1 ESCC is
committed to working with all stakeholders to improve road safety
across East Sussex, including our partners on the Sussex Safer
Roads Partnership.
3.2 Speed limit
policy PS05/02 is based on national guidance issued by the
Department for Transport, best practice, local experience, the
views of Sussex Police as the appropriate enforcement authority,
and is reflective of what is required to produce an effective speed
limit. The policy will continue to be reviewed regularly to ensure
that it complies with the latest national guidance available.
3.3 The policy is not
prescriptive and allows for lower speed limits to be considered for
those locations deemed appropriate if the necessary traffic
management or engineering measures are implemented to ensure
compliance.
3.4 The policy has
been found to be fit for purpose. It does not commit the Council to
fund speed limits that are not an identified priority or linked to
an approved scheme funded from alternative sources.
3.5 Following
receipt of the Notice of Motion, a review was undertaken of the
relevant national guidance issued by The Department for Transport
(including Circular 01/2013 and the January 2022 revisions to the
Highway Code) and this concluded that adopted Policy PS05/02
continues to reflect national guidance and best practice.
Therefore, it is not recommended that valuable resources are
diverted to undertake the review requested by this Notice of
Motion.
3.6
The new Speed Limit Programme will
assess the potential for lower speed limits across all A and B
class roads within the County and identify a programme for
improvements. Over the next three years, more than 25 stretches of
road will benefit from speed limit reductions or measures that will
increase the effectiveness of existing speed limits.
3.7
The Lead Member is recommended to recommend that the County Council
rejects the Motion.
Director of Communities, Economy,
and Transport
Contact Officer: Brian
Banks
Tel. No. 07769 164195
Email: brian.banks@eastsussex.gov.uk
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