THE ASSOCIATION OF BRITISH DRIVERS

IN SCOTLAND

 

Department for Transport
Mr Peter M Spinney, Chair
Association of British Drivers Scottish Members
c/o XXXXXXX XXX
Mugdock
Glasgow G62 XXX

 



MARK MAGEE
Driver Safety Division Department for Transport Zone 2/13
Great Minster House 76 Marsham Street
London SW1 P 4DR
Direct Line: 020 7944 8818 Fax: 020 7944 9618
mark. magee@dft.gsi.gov.uk
Web Site: www.dft.gov.uk
19 September 2006

 

Dear Mr Spinney,

DECISION LETTER FOLLOWING CONSULTATION SETTING LOCAL SPEED LIMITS

I refer to your letter of 19 August concerning the Department's decision letter following the public consultation exercise relating to DfT Circular 01/2006, the Department's new guidance to Traffic Authorities on setting local speed limits.

The Department refutes your allegations that the analysis of responses has not been undertaken in accordance with the Cabinet Office guidance on public consultation, and that the published guidance contains false and misleading statements regarding the use of mean speeds and should therefore be cancelled.
The Department's responses to your allegations (reproduced in italics below) are as follows.
The views of Traffic Authorities should not be given any special attention, and it is arguable that they should not be considered at all. A clear majority are against the move to mean speeds. No attempt appears to have been made to take proper account of the responses from the public.

Criterion 4 of The Cabinet Office Code of Practice on Written Consultations states the following in respect of the analysis of responses to consultations:

"Do not simply count votes when analysing responses. Particular attention may need to be given to representative bodies, such as business associations, trade unions, voluntary and consumer groups and other organisations representing groups especially affected. In order to ensure that responses are analysed correctly, it is important to understand whom different bodies represent, and the methodology used to gain members' input into the response. ".

As the Cabinet Office guidance makes clear a consultation exercise is not a referendum. With regards the move to mean speeds, as the decision letter shows, overall views were divided, with some 69 of the overall 139 who responded on this question against the move, 58 in favour, and 12 expressing mixed views. There were a further 70 respondents who did not comment on this aspect.

Of the 64 members of the public who responded to the consultation, 8 (13%) were in favour of the move to mean speeds, and 38 (59%) were opposed. Meanwhile of the 56 Traffic Authorities and authority associations who responded, 31 (55%) were in favour, and 11 (20%) were opposed. The position was therefore finely balanced.

In line with the Cabinet Office guidance, the Department has given due attention to the views expressed by Traffic Authorities and authority associations. This is only right and proper given their legal duty to promote and improve road safety in their local area, and that, as part of this, they will have the responsibility of implementing the guidance.

The speed limit on a road only affects vehicles capable of that speed and not other road users.

With the exception of motorways, our road network is equally accessible to non-motorised vehicles, and to pedestrians. It is therefore self evident that their needs should also be taken into consideration when assessing what is an appropriate speed limit.

Road users will form their own opinion as to whether the posted speed limit makes sense, quite irrespective of the method used. They simply have no need to know why or how the limit has been set.

To an extent, the mean vehicles speeds being driven on a road reflect road users adopting their own opinion as to what is an appropriate speed to travel on the road. One of the objectives of the new guidance is to improve respect for speed limits. Increasing the public understanding of why and how speed limits are set will help to achieve this. It will also importantly lead to greater self compliance, which should in turn reduce the need for enforcement of speed limits.

It beggars belief to claim that mean speeds ...are underpinned by extensive research....

Mean speeds are routinely used to evaluate the effectiveness of speed limits and other speed management measures.

There is a well proven correlation between speed and accident reductions, and this is recognised and supported by research both here in the UK and around the world. Much of that speed and accident relationship evidence is determined by and around mean vehicle speeds, notably TRL report 421, The effects of drivers' speed on the frequency of road accidents and TRL Report 511, The relationship between speed and accidents on rural singlecarriageway roads, which for example show the following:

In fact TRL51 1 found that no other measures of speed were found to influence accident frequency as strongly as mean speed.


Yours sincerely,

 

Mark Magee
Head of Speed Management Branch