----------------C. Cooke - Submission to Highways - STARTS ------------------
Attn Geoffrey Bevan
Route Performance Manager
TOD Midlands MAC 11
C5
5 Broadway
Broad Street
Birmingham B15 1BL
Your ref: HA 28/013/000002.1
Dear Mr Bevan
A5 Trunk Road (M42 Junction to Grendon, Warks) (40mph and 50 MPH speed limit)
Order 200
Dear Mr Bevan
Thank you for your letter of 9th November 2006 and your giving me a further chance to submit further written material - after our meeting at Optima's premises in Tamworth.
First I must apologise for taking this right up to your 11th December 2006 deadline. I've been trying for ages to get down to the additional material I have now received from Optima and to sort it out into some sort of rationality and to give a considered response. However I have been inundated with a great deal of other work recently and it has proved impossible. In fact I feel I am not doing it justice right now - even at this late stage - but at least I am putting in some sort of response.
In reference to your 9/11 letter I am sure it is right that this should not go to an inquiry. It would not be a proper use of the extra public funding it would involve. I also note that you have - in the heading - included the complete section of the A5 speed limit proposals - from the M42 junction to the M69 junction. However I have only objection to the Secretary of State Order HA 28/2/148 which was from the M42 junction through Dordon to Grendon - and that is all I have paperwork to support. If the order had covered the whole stretch to the M69 then I would have commented appropriately at the time - but I am less familiar with the Witherley - M69 section and that was covered by a separate consultation order HA 28/11/17. Which brings me to my first point.
1. The whole project should have been one Order. At our meeting at Optima's Office it was made clear to me by Ms Karen Friend, Optima's representative, that the A5 scheme was to be taken as a whole. This was not made at all clear beforehand. It was also made clear to me - when I tried to suggest a compromise - that the scheme could not be amended - it could only be adopted or rejected. This seems wholly unreasonable. I believe I - and Mr Biggs who accompanied me to the Optima offices - have shown at least parts of the schemes to be flawed. There should be some way a consultation can take this into account. I can only carry on continuing to object to M42 - Grendon Order - but if I was made aware from the start that the whole project was inseparable I would have taken a very different approach.
2. Updated Accident Comment. Now I can only comment on Order HA 28/2/148. We now have a more detailed analysis of accident statistics from our Optima meeting. What we were presented with were segmented balloons stuck on a map of the route marking each “injury”. On it were all sorts of “details” about it - supposedly details of weather conditions, road conditions, etc - but nothing which we could sensibly enumerate, analyse and make conclusions from. fact I couldn’t even read it as it was too small and faint. Ms Friend did spend quite some time trying to explain what the various parts of the balloon were and she apologised that it wasn’t in any form that we could actually make sense of. However it was at least clear from the balloons that the injury accidents were concentrated almost exclusively to the junctions around the two roundabouts and the Garage. We can postulate about how these accidents occurred, but at the roundabouts whatever speed the traffic is likely to be moving at those points it is impossible to believe that the speed limits were being exceeding. Indeed in the later accident analysis I later received from Ms Friend it is clear that by far the most common form of accident was the "shunt". Therefore it is most improbable that those accidents can relate to speed above the set limit. Indeed I now have a breakdown of the 55 accidents to show that 50 of them were considered "slight", four were "serious" and one was "fatal". That is not to be complacent for a "slight" accident could so easily turn "fatal" given a very small change in circumstance. But I cannot glean from these figures that there is anything relating to speed (above the set limit) that was a factor.
At the Garage it may be more probable that speed (at least inappropriate for the conditions) was a factor - but as the details of the accidents were not recorded it seems just as likely that the accidents were the result of cars trying to get back onto the carriage way and perhaps even shunting another car trying to do the same. These represent the more common sorts of collisions. Then again - although on balance I support the single carriage way on that stretch of the A5 - at that point it's disadvantage is that traffic from the garage finds it more difficult to access the single carriageway because traffic has no other lane to move into to give way. But again speed above the set limit is not the issue here - it is a judgment and awareness problem that needs to be addressed. If the traffic were made to move more slowly then that would reduce the space available for garage traffic to gain access to the A5. The likelihood here then is that traffic accidents may increase as opportunities to access the carriageway (spacing between traffic doing lower speeds) decreases. This is because it is human beings that drive cars - not robots - and human failings really must be taken into account when highways are re-engineered and new limits are set.
3. The 85th Percentile. - However speed data was also presented at the Optima meeting. it filled volumes!! We would have needed days - if not weeks - to pour over the information that had been recorded. again it was almost impossible to make out anything what we were really being shown. The when’s, where exactly’s, and why’s really were lost is the haze of figures.
What did stand out clearly was that the 85% percentile (the figure which we are supposed to work to) was at first too high for Highways to reduce the speed limits. So - just for the sake of reducing this 85th percentile - a whole raft of road engineering measures were used. Notice - NOT for reasons of safety - but for no reason other than to bring down a perfectly safe speed in order to meet guidelines to reduce the speed limit.
The point here of course is that since doing that a new road engineered environment had been created and it really needs 3 - if not 5 - years worth of statistics to see whether these had reduced (or increased?) accident figures. Without that information we really shouldn’t be reducing the limits at all. I also note that of the 55 accidents over the 5 year period not one of them has been shown to be due to speed over any set speed limit. I really do think that had they been serious or fatal accidents due to this reason we would have been made much more forcefully aware of them. As it stood accident figures for this stretch of road were amongst the least worrying in the Midlands!! Mr Biggs and myself pointed out that Government reports on the effect of artificially low speed limits show these can actually increase accidents. I am sure that will happen if these lower limits for this Order are implemented.
I must admit my surprise at the 85th percentile figures I saw while at the Optima meeting. Even after the speed reduction road engineering activity - the average 85th percentile was still 46mph - and even higher in the East Bound direction. In fact if we went by the graphs they had drawn we could see that the 85th percentile on some days was indeed above the 50mph. I had previously been led to believe they had brought the 85th percentile down below 40mph - and thought that was suspiciously low at the time. We were informed that Government guidelines allow to reductions in limits to 40mph even if the 85th percentile is as high as 47mph. Surely this cannot be right to reduce traffic speed to as low as 40mph when on some days speeds were even higher than the 47mph quoted as allowing a reduction? thought it was strange as since this all started I had often gone down that road and - driving very reasonably - I was still doing at least 45mph - and was wondering just how uncomfortable it would feel if the limit was reduced to 40 and how the figures had justified it. I understood! It didn’t have to get it below 40mph at all. In fact far from getting the limit to the reasonable 85th percentile it had more than likely reduced it to less than even an average speed along that road - seeing as the traffic travels at a reasonably even pace at most times clearly increases the dangers - whilst claiming to reduce danger. when the accident figures go up after the limits are reduced - the words “I told you so” may well seem in bad taste!
4. "Saved Accident" prediction. - But in the paperwork Ms Friend has now forwarded to me - in the Economics worksheet - I find that there is a "saved accident" prediction of 10% in the opening year. I see no basis nor logic for this figure. It appears to be simply plucked from the ether - as it were. In fact the figures even seem to conflict as the Statement of Reasons for the Order quotes 55 PIAs but the Economics worksheet seems to say it is really 63.8 (not sure how the Point 8 is arrived at?). Anyway the Economic Worksheet then goes on to say that this would mean a predicted saving of 6.4 accidents in the first year. That is nonsense. It must mean 6.4 accidents over the whole five year period. And if that is nonsense then so must be the predicted "savings" (ie - average cost of accidents to the State as a ratio of the total cost of the project). Please correct me if I am wrong but these figures do not make sense to me. But them I am not fully acquainted with the acronyms used in the report either (eg - AADT?) nor have I been given various appendices towards which some references were made. Therefore I am also very wary that the "average accident cost" may also not be being applied correctly - but I have no way of checking the methodology of this.
5. Warwickshire Police Comment. - Apart from the 55 accidents for the five year period the only other "reason" given in the "Statement of Reasons" (at least for the M42 - Grendon order) was that "Warwickshire Police support the proposals". This was not completely true. On reading the actual letter from the Warwickshire Police it seems that the proposals did give them concerns. They said if those concerns could be addressed then they could support the proposals. The proposals as presented to the Warwickshire Police have not changed at all. Therefore I do not believe the proposals address the concerns of the Warwickshire Police and therefore it cannot be said that Warwickshire Police support the proposals. In fact their letter more suggested that they were against, rather than for, the proposals and I would agree with them.
6. Highways Report - Supporting Information comments.
a. Journey Ambience. The PAR3.3 comment describes this as "beneficial". It says it will reduce fear of accidents and will reduce driver stress as speed limits "will be more appropriate to the environment". I fail to see how this conclusion has been reached. Is it because of Highways "prediction" of less accidents? And how can putting a speed limit well below an 85th percentile speed reduce driver stress? In my experience of 37 years of driving I have found that the most stressful driving was when driving at inappropriately low speeds. And these proposed speed limits will certainly appear inappropriately low to many drivers - including myself.
b. Safety. This comment says with definite prediction that the proposals "will reduce the number of speed related casualties". As there has been no indication as to which of the 55 accidents were indeed speed (in excess of a speed limit) related then this prediction seems impossibly optimistic and unsupported. I have predicted - with I think sensible reasoning - that the proposals will increase accidents (based on government guidance). What this is saying is that a reduction of roughly 1 accident a year is worth all this cost and bother. I would go further and say the proposals will make things worse. Time will of course tell who is right - but why don't we first find out what effect the road's newly engineered condition may have had on accidents? A period of stability and reflection is needed.
Also the report claims a reduction in speed differentials will be achieved. I sincerely doubt this. I expect many drivers will use any opportunity to overtake what they consider to be slow moving vehicles. Maybe not in this single carriageway section (although some drivers may well be tempted as plenty of side space exists!) but in later sections. It is at that stage of driver frustration where the dangers become greatest and driver speeds will increase dramatically ( notwithstanding any set speed limit) in overtaking manoeuvres that may well lack proper judgement. It is here that accidents will increase - and at that time when differential speeds will be at there greatest. These are the sort of rash decisions (failure to give way?) that may cause serious accidents and deaths. Shunts are an entirely different form of accident. Highways must take into account the human nature aspect - and not simply turn a blind eye and say "it would be alright if they obeyed the speed limits". The speed limits must include an allowance for human nature - that was the whole purpose of the 85th percentile in the first place.
c. Journey times. It is impossibly optimistic to claim - as this comment does - that mean speeds and journey time will remain "neutral". In fact in referring to mean speed their logic is clearly wrong. If the speed limit reflects the mean speed then the occasions when vehicles travel above the mean speed will be suppressed down by the new speed limits - limits which by definition must be the maximum speed. This must lower the mean speed. Indeed in the report in "Part 2 - Project Assessment" under the section "How are problems addressed" there is a claim that the speed of the traffic will be "relatively self enforcing as it changes speed limit to match what the average speed of the traffic is doing". Proving that this scheme is designed to reduce speeds to "average" rather than "85th percentile" limit setting. Of course such a speed limit will do nothing to "self enforce" traffic that could safely and easily drive above that "average". That enforcement will have to be done by police or camera - or not at all. If not at all then there is a serious danger of speed differentials increasing.
This comment even claims that "for a small proportion of the traffic the journey times will be reduced". How can that statement possible be true? It is ridiculous to claim that the lowering of speed limits to a level substantially below a reasonable maximum (the 85th percentile) will allow traffic to travel faster or will have no impact on journey times. It is a plainly absurd comment.
None of the above comments are supported by any evidence. They appear to me to come under the category of "wishful thinking" - and as such cannot be passed off as robust predictions.
6. Assessment Scores. - On part 2 of the Report (under Project Assessment) there are only two "beneficial" assessment scores - "Journey ambiance" and "accidents". Both of these are in serious doubt as I have already made clear. The rest of the "Assessment" is said to score "neutral". But under "journey times" it is clear that there must be an adverse impact (irrespective of the "qualitative comments" made in the report) on journey times. I see from the report that in the section marked "Journey Times" no measurements have been recorded. So no comparison can be made at a later date. Likewise there will have to be a wider economic cost to those slower journey times. Therefore it is wrong to claim a "neutral" effect on such things.
7. Consultation - Also under "Part 2 - Project Assessment" the first section, under "Other Options" claims there is no other option because of the "considerable pressure from locals and police". I may be confused from time to time whether the information I have been given applies to the traffic order I have objected to - or the whole A5 proposals. But at least as far as the Warwickshire section is concerned we now know that the police have NOT applied any pressure - and indeed they are concerned about the proposals. As for pressure from locals - I have neither been shown nor seen no evidence of any pressure whatsoever from any local people. What I have seen is some comments from a very few local parish councillors - who when approached by the Highways dept for consultation have said that they have "no objection". I question whether this was adequate consultation or whether it is sufficient to claim "considerable pressure". Or have I not been given all the information I asked for on the response to the Highways consultation? Therefore on both counts I see no evidence of any real pressure on the Highways to implement this scheme. Indeed if those who did have "no objections" were appraised of the full considerations - as I have attempted to be - I'm confident some would even withdraw there "no objection" statement - as indeed Mr Biggs and myself have been asked to withdraw our objections. Have these people also been given this information or been asked to withdraw their "no objection" statements? As an anecdote I remember once a road humps scheme being forced through in Tamworth. We were told there was "clear public support" for it. Yet the reality was that the vast majority had not taken any notice of the consultation. There were however 17 replies - of which 13 were against. But there were 4 who showed "clear public support"! I feel a similar exercise is being tried here.
8. A Consistent Approach. I object in principle to a scheme that attempts to relate its speed limits to various other limits along the same stretch of road ("a consistent approach" as the report says) but this appears to pay no regard to being "consistent" with the limits in the various areas through which it passes. It is obvious that traffic when travelling along a national trunk route will generally expect speeds to be higher than when they turn off into the local areas. Yet along this route on a number of occasions traffic turning off will go from 40mph to a real built-up area (and I have said before that this Dordon to Grendon stretch of road has very little in the way of being "built up" along it) where the limit will still be 40mph - yet the road conditions (winding, homes nearly fronting the roads, less well lit and maintained even) would suggest a different limit. It doesn't make sense. The report should have taken the limits in surrounding areas into account.
In closing I would say that there does seem something wrong when a speed limit is set to an average (mean) speed - notwithstanding new government guidelines that do not affect this Order. It's clear that this is the intention of these proposals - whatever lip-service may be paid to any 85th percentile. It will be an arbitrary and unsuitably low limit - certainly not conforming to the present guidance on the 85th percentile for at least some of week day periods.
If this means scrapping of the entire proposals instead of looking for some sensible compromises then that is an unfortunate consequence. But the status quo does seem to me to be the preferable option until such time as the matter can be re-assessed under new government guidelines. It has the added advantage of allowing time for a clearer picture of what present re-engineered road conditions may be. I'm sure that is sensible.
Yours sincerely
Cllr Chris Cooke
-------------------C. Cooke submission to Highways - ENDS-------------------------
ABD representative Paul Biggs was less fortunate than myself - for although being allowed to put in a further submission (below) - he received none of the paperwork we had asked for - so there was precious little more he could reasonably add.
----------Submission of Association Of British Drivers rep. Paul Biggs (web - www.abd.org.uk) ---------
3rd December 2006
Dear Mr Bevan,
Re; My objection to A5 speed limit reductions under order 200
Thank you for your letter dated 9th November.
Unsurprisingly, no evidence has been forthcoming from the HA that supports the claimed basis for the A5 speed limit reductions. Indeed, some road engineering has been undertaken without consultation in order to attempt to reduce 85th percentile speeds prior to the order 200 consultations. The 85th percentile speed remains at 47mph in a 50mph limit that the HA intends to reduce to 40mph. 47 mph is over the ACPO recommended enforcement threshold of 10% plus 2mph giving the potential for prosecuting drivers travelling at the scientifically safe 85th percentile speed.
Despite claims of police support for the proposals, it is clear from the 2-page written response by Warwickshire Police that they have reservations about the speed limit reductions. The one line response from Leicestershire police suggests that they did not give due consideration to the proposals.
DfT analysis of 147,000 injury accidents in 2005 shows that only 5% have ‘exceeding the speed limit’ as a contributory factor. ‘Excessive speed for the conditions,’ under the posted limit was a contributory factor in 10% of accidents analysed. Of course, the DfT has attempted to ‘spin’ the figures higher, but the focus on speed and speed limits as an accident reduction policy is fatally flawed.
Furthermore, TRL’s attempts to destroy the 85th percentile as the safest speed in free-flowing traffic conditions had to be statistically manipulated in order to obtain the desired result. See the enclosed destruction of TRL report 511.
NIMBYism by a minority of residents doesn’t aid road safety or essential road transport.
In conclusion, my objections to the HA proposals remain unchallenged.
Regards,
Paul Biggs
