This is The Richmond Society’s response to the Council’s consultation about implementing a borough wide 20mph speed limit. The Society is a civic amenity group representing over 1,200 residents across an area of benefit extending from the Thames in the west to Chalker’s Corner in the east and including Richmond’s town centre and part of the A316.

The Society has promoted the Council’s consultation and associated press releases to its members throughout the process but will not take a position either for or against 20mph limits. We do, however, want to comment on the consultation itself.

General Observations

The relevant element of the consultation consists of only three questions (numbered 3 to 5). Questions 3 and 5 ask respondents for a personal and subjective view and, as such, are reasonable.

Question 4 asks respondents about the extent of their agreement or disagreement that the introduction of a 20mph borough-wide speed limit would:

i. Reduce the incidence and seriousness of road traffic accidents;
ii. Reduce car use by encouraging alternative forms of transport;
iii. Improve air quality.

Quite rightly the Council provides summary evidence to help residents who want to form an objective opinion on these issues. However, it is somewhat disappointing to find that, throughout virtually the entire three month consultation period, the Council only promoted information that tended to endorse 20mph limits. Most residents will be unaware of contradictory evidence, or that some of the Council’s extracts from research and data should have carried a qualification.

The choice of questions was very limited in scope and did not encourage residents to consider whether they might rate alternative solutions more highly to achieve equivalent aims. These could have included targeted interventions (e.g. 20mph outside schools, or by re-engineering accident black spots), or to gauge residents’ support for alternative ways of encouraging modal shift and reducing air pollution. The value of running an expensive consultation becomes questionable if the Council only wants to hold up a mirror that reflects a pre-determined position.

Caveats ought also to be attached to the consultation’s results due to the ability of anyone to submit an anonymous response online and without any apparent control to prevent multiple submissions.

The quality of the consultation results has also been affected by releasing different evidence and reference information during the time that it has been open and at “Community Conversations”. New material provided after the start of the consultation means that respondents had different information on which to base their opinion at different times within the consultation period. This might be unavoidable when important new information emerges but, in this case, it feels more like the consultation was started prematurely – or perhaps that, early responses were slow to arrive or not in line with the expected outcome, and more effort was needed.

In that regard, the report from Public Health dated November 28th was added more than two months after the consultation started and the DfT commissioned report on the effectiveness of 20mph limits (also published in November) was added about a week before the closing date. As possibly the most extensive study of 20mph limits across the country, the DfT report was long awaited and ought logically to be a key reference.

It is of some concern that the first consultation leaflet sent to residents did not specify the costs of the scheme stating only: “There will be no extra charges passed onto residents to pay for this.” Clearly there are costs with any proposal and, if there is to be no extra charge on residents, then funds must inevitably be diverted from other budgets. Later in the process the costs were announced at £0.7m – £1.5m but it remains unclear what other Highways projects must be scaled back (or stopped, or not progressed) to cover this expenditure. Residents’ views about these costs and alternative budget options were not sought. No estimate of the higher costs of maintaining repeater signage, or roundels painted on the road, has been provided.

The council measured speeds across a cross sections of roads to compute an average borough speed of 21.9mph but only released this information after the start of the consultation. We would request that, prior to completing the Cabinet report, the data underlying this computation (i.e. to include the survey dates, the individual roads tested and average speeds recorded) be published alongside other 20mph reference sources. This data can then be considered to represent a base case against which progress in reducing speed and accident rates could be measured in a few years.

Comments on the Component Elements of Section 4

i) Reduce the incidence and seriousness of road traffic accidents

The laws of physics dictate that, because slower speeds allow more reaction time, some accidents may be avoided and that, in the event of a collision, personal injuries and/or property damage are much reduced. It is therefore difficult for respondents to disagree that 20mph would not reduce the incidence and seriousness of accidents making the value of this question somewhat doubtful.

The Council’s initial leaflets, commentary and presentations have reiterated that improving safety is a key objective for introducing 20mph limits across the borough. However, the historical accident statistics used by the Council included TfL and Royal Parks routes although these are not part of the 20mph proposals.

This created a material mis-representation of the safety gains achievable given that, over the last three years, about 25% of KSI accidents and 37% of slight injuries occurred on TfL roads. The latest leaflet hand delivered to residents has compounded this mis-representation by stating that fatal and serious accidents (including TfL routes) have risen by 12% in the borough over the last three years. Although serious accidents on TfL roads are 88% higher in this period and a major contributor to the statistics, the leaflet rather misleadingly concludes that “You can stop this.”

The Atkins report commissioned by the DfT recognises the public’s concern about the lack of police enforcement and is inconclusive about the benefits of 20mph limits on reducing collision rates. It reports that there is tentative evidence to support concerns that lowering the speed limit may increase driver frustration and distraction as evidenced by a significant increase in the proportion of collisions that have been categorised as ‘careless / reckless / in a hurry’.

In this regard it is important to recognise that a borough wide 20mph limit may restrict opportunities to draw drivers’ attention to areas of vulnerability (particularly near schools) where a 20mph sign that currently helps to flag the need for care is removed. Ideally this loss would be offset by installing alternative signage.

If 20mph limits result in modal shift then it must be expected that, perversely, the number of incidents involving cyclists will increase. Headline accident rates may therefore not reduce as desired and with a risk that they include a greater number of vulnerable road users.

ii) Reduce car use by encouraging alternative forms of transport

Throughout essentially all of the consultation period the Council has only promoted a single viewpoint and most respondents do not have the wherewithal to look in detail at the evidence presented.

The Council’s first leaflet stated that “in Bristol, slowing speed limits from 30mph to 20mph contributed to increasing walking and cycling by over 20%.” This disregards the caveat in the UWE’s BRITE report that it is not possible to state with certainty that the 20% modal shift to cycling and walking was related to the introduction of 20 mph.

Anecdotal evidence in Richmond similarly seems to show significant increases in the numbers of people cycling locally since 2012. This has been achieved in the absence of 20mph limits although, because cyclists justifiably prefer lower vehicle speeds, it is impossible to know if uptake might have been higher.

The Atkins report for DfT suggests a net 1% of people cycling more as a consequence of 20mph limits, but that walking and cycling rates are essentially unchanged.

The Council has gone to some lengths to show that 20mph limits should not materially increase car journey times and so, by applying this logic, lower speeds should not of itself cause a driver to abandon their car. This question therefore seems to miss an opportunity to probe drivers about adopting alternative travel modes.

iii) Improve air quality

Most pundits agree that vehicle type and driving style have far more influence on reducing air pollution than lower speeds. Lower levels of braking and acceleration with 20mph limits should reduce particulate pollution, but the evidence linking 20mph to improved air quality remains fairly inconclusive.

Again the Council has presented information selectively. The first Council leaflet highlights the April 2013 research on behalf of Cross River Partnership which found lower emissions by diesels at 20mph. However, this statement has not been qualified by the fact that the same research also found emissions are 8% worse for petrol vehicles.

Conclusion

How this consultation presented its questions and the underlying evidence suggests a desire from the Council to drive responses that would show support for 20mph limits.

Given that 20mph limits has cross party political support locally this consultation seems to have missed a valuable opportunity for collecting feedback from residents that might have better helped the Council with its active travel planning.