Tonight there’s a call-in of the council’s arbitrary approach to 20mph limits in the borough. The local branch of 20’s Plenty has put together this excellent paper, supporting their submission.
If you want to attend, it’s an open meeting – all the details are here.
We thank the London Borough of Richmond Call In sub-committee for allowing 20’s Plenty for Richmond to speak to and submit comments about the Borough’s approach to 20mph speed limits. Where appropriate we have referenced the relevant paragraphs of the 9th October 2014 report to Cabinet entitled “Review of the Borough’s approach to 20mph Speed Limits”.
- We are disappointed by the negative approach to 20mph speed limits being taken by those seeking to introduce the policy outlined in the report to Cabinet dated 9th October. We believe that by setting up a procedure that imposes almost insurmountable hurdles to the introduction of 20mph speed limits (Para 3.15 Cabinet report) LB Richmond is at odds with the direction of Government and Mayoral policy and fails to support all those in LB Richmond who are trying to promote walking and cycling.
- We believe that this is a public health issue and not just a road safety issue. Public health deals with avoidable deaths and injuries and slowing traffic by introducing 20mph speed limits has been shown to make a positive contribution. It seems that LB Richmond recognises this, but, by not consulting its own Public Health Department about this issue, has distanced itself from its public health responsibilities. In no other area of public health are 51% of residents required to endorse a policy. This procedure assumes that only people who live on a street use that street but streets are public spaces not private property and are used by many other people.
- It is widely acknowledged that 20mph speed limits can reduce road casualties and improve public health, including obesity levels, by increasing the numbers walking and cycling, especially those who are more vulnerable such as older people, children and those with disabilities. They can also improve social cohesion and wellbeing by encouraging more people to be active outside in their community and improve the local economy as more pedestrians walk to and shop at their local shops and high streets. They are not a silver bullet on their own but, over time, they are a means of creating a fairer balance between motor vehicles and people and encouraging greater activity levels.
- We would thus encourage LB Richmond to review the obstacles it is seeking to put in the way of the introduction of 20mph speed limits and be more open to their introduction because of the many benefits that they bring.
We would briefly like to outline a number of areas that aim to address the Cabinet paper’s stated concerns about 20mph speed limits:
- Their popularity and the demand for them;
- Their effectiveness and the increasing support for 20mph from the police; and
- The changes to the regulatory regime from the Department for Transport and in London the GLA and TfL and more recently the Equalities Act 2010; and
- To highlight some further benefits that could result from introducing area-wide 20mph zones in LB Richmond.
1) Demand for 20mph Speed Limits
There are high overall levels of support for 20mph speed limits across the UK. Research under the long running British Social Attitudes Survey has consistently found that around three-quarters of UK adults support 20mph speed limits for residential roads (73% support in 2011). More recent research by YouGov in 2013 found that:
- 65% support a 20mph speed limit in residential areas
- 72% support a 20mph speed limit in busy (eg shopping) streets.
Recent research by Edinburgh City Council confirmed previous studies that support for 20mph limits increases after their introduction. In its research into the South Central Edinburgh’s 20mph limit trial found that support for 20mph rose from 68% before they were introduced to 79% after they were implemented.
We remain perplexed at the conclusions that LB Richmond has drawn from the consultation that occurred into 20mph limits in Kew, Whitton and Hampton Hill.
We understand the clear desire of residents not to see the introduction of a borough-wide 20mph limit and the overall lack of majority support for a 20mph speed limit in Whitton. Given, however, the fact that the principle of identifying candidate areas for 20mph limits was established in this consultation and the proposal for a 20mph limit on Hampton Hill High Street is to be taken forward on the basis of the results, it is not clear why the proposal for Kew has been rejected when levels of support for a 20mph zone were higher in Kew (at 56%) than in Hampton Hill High St (51%).
In addition, it appears strange that Para 3.11 uses the results of the question concerning whether the 20mph limit should include residential and or main roads to reject the support identified in the “20mph in my area question”. As a total of 43% of Kew residents stated that the 20mph limit should apply on only residential roads and a further 26% that it should apply on both residential roads and main roads. Therefore a combined total of 69% appear to support a 20mph limit at least on residential roads. Given that this process of consultation has been used to endorse the adoption of a 20mph limit on Hampton Hill High Street, it appears illogical that in spite of these high levels of support for 20mph in Kew as an area and on all of its residential roads, the process is then rejected owing to the low level response namely “Furthermore approximately 73% of Kew residents did not respond to the survey at all”.
2) Effectiveness & Enforcement
a) Casualty Reduction. (Para 3.1) Whilst it is true that lower speeds reduce the severity of road casualties, it is also the case that they reduce the numbers too. Research by the London School of Hygiene & Tropical Medicine into the impact of 300+ 20mph schemes across London over a 20 year period found that when speeds were reduced to a maximum of 20mph (principally in these studies through traffic calming) casualty numbers fell by 42% (over and above the rate of the background decline in road casualty levels).
In the case of 20mph speed limits (without calming), the reduction in average speeds alone may initially be no more than 1 or 2 mph but research has found that in an urban environment each reduction in average speeds of 1mph will deliver a 6% reduction in casualty levels. While there are examples of the creation of area-wide 20mph limits where the impact on casualties may not be clear cut, there are many examples of significant declines in casualty levels. Examples of this include:
- a 25% decline in casualties in a 140 road pilot in Warrington
- a 56% reduction in 8 areas each introducing 20mph limits in Newcastle
- a 46% fall in three 20mph pilot areas across Lancashire County Council
- most recently in Brighton & Hove where initial indications (in the year following implementation) show a 17% decline in all casualties and a 20% decline in the numbers killed and seriously injured in the year following the introduction of area-wide 20mph limits (compared to the 3 year average for 2010 to 2012).
In Islington, in the year following the introduction of the 20mph borough-wide speed limit (January 2013), there was a 42% reduction in the numbers of people killed and seriously injured on its roads. This compares to a 23% reduction across London for 2013. It is important to state, however, that percentage reductions in casualties in a number of other London boroughs were greater. In terms of casualties of all severities, there was a decline of 1% in Islington compared to a 6% fall across London.
In terms of vehicle speeds, the impact of the introduction of the 20mph limit in Islington was mixed with average speeds falling on 18 of the 29 main roads researched and rising on 10 of them. Overall it is estimated that average speeds across the borough fell by 1mph. It is important to note that this occurred without any significant enforcement support from the Metropolitan Police. Both in Islington and across London this picture of a lack of support for enforcement of 20mph limits is changing (see below).
b) Enforcement. While we agree that the environment for the enforcement of 20mph limits has not been strong in the recent past (Para 3.2) and that compliance with 20mph limits should not solely be about enforcement, the picture on enforcement is changing with the Metropolitan Police becoming far more willing to enforce 20mph limits.
The reasons for this are:
- Changes in ACPO Guidance. It is now the policy of the police to enforce 20mph limits following the change of guidance from ACPO in October 2013.
- Enforcement of 20mph limits is now occurring in London and FPNs are being issued to speeding drivers.
- The creation of the new Roads & Transport Policing Command. The Metropolitan Police has set up a 2,300 officer strong Road & Transport Policing Command which will become operational from 1st December 2014. At the Road Danger Reduction & Enforcement Conference of 1st November 2014, Sergeant Simon Castle confirmed Metropolitan Police support for enforcement of 20mph limits. A contributory factor to this change in approach has been the perceived success of Operation Safeway and the clear impact that enforcement had on dangerous behaviour on London’s roads.
- Local Enforcement. Ward panels have the capacity to set policing priorities and enforcement of speed limits can be set as a priority.
- Community Speed Watch. Members of the community can now play a role in encouraging compliance with speed limits through Community Speed Watch.
3) Regulatory Framework & 20mph Speed Limits
We are concerned that the statement in the Cabinet report (Para 3.2) “Guidance from the Department for Transport states that 20 mph speed limits should only be considered for streets where average speeds are already below 24mph” is an extremely skewed interpretation of Paragraph 95 of the DfT Setting Local Speed Limits Circular of 2013 and adds to the impression that the Cabinet report has not sought to be objective in relation to 20mph limits. We feel that stating this alone masks the support that the Department for Transport (DfT) and Transport for London (TfL) and the Greater London Authority (GLA) have sought to give to 20mph speed limits over the past 2 years.
Examples of policy support for 20mph limits in urban settings such as those which apply in Richmond are outlined below:
- DfT Setting Local Speed Limits Circular from 2013 (page 3 Key Points): “Traffic authorities are asked to keep their speed limits under review with changing circumstances, and to consider the introduction of more 20 mph limits and zones, over time, in urban areas and built-up village streets that are primarily residential, to ensure greater safety for pedestrians and cyclists”
- DfT Setting Local Speed Limits Circular 2013 Para 84: “Traffic authorities are able to use their power to introduce 20mph speed limits or zones on:
- Major streets where there are – or could be – significant numbers of journeys on foot, and/or where pedal cycle movements are an important consideration, and this outweighs the disadvantage of longer journey times for motorised traffic;
- Residential streets in cities, 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.
- The TfL/GLA Safer Streets for London Road Safety Action Plan (up to 2020) from June 2013 strongly supported the creation of more 20mph zones in London.
- The Mayor of London Vision from Cycling from March 2013 called for wider use of 20mph on the TLRN and the installation of 20mph zones and speed limits on borough roads owing to the “clear evidence that traffic travelling at speeds of 20mph improves the safety of both cyclists and pedestrians”.
20mph speed limits also help local authorities to meet the terms of the 2010 Equalities Act and its aim to protect people from “unfair treatment and to create a more equal society”. They can help ensure that access to services is more easily achieved for those with disabilities and those who are vulnerable, for example through their age, through a fairer balance between those on foot and those in motor vehicles.
We believe that these policies at a national and London governmental level give a strong foundation for the introduction of 20mph limits on residential roads and appropriate main roads in Richmond.
These policies envisage an area-wide approach and appear at odds with LB Richmond’s street-by-street approach. The Cabinet report admits that introducing 20mph on individual streets is more confusing and more costly than area wide limits, but then continues to recommend it.
4) Public Health and other benefits of introducing 20mph speed limits
In addition to the impact on casualty reduction we believe that there are further extensive benefits from 20mph speed limits which are supportive of other Council policies in relation to the health and wellbeing of residents and the success of local businesses but which were not considered in the Cabinet report. Examples include:
Obesity – promotion of walking and cycling is vital to address levels of obesity. Obesity, although lower than other parts of London, is remains high in LB Richmond and is a serious public health concern, according to the Council’s own Public Health reports. It is estimated that 14.3% of adults and 12% of 11 year old children in LB Richmond are obese, with levels of child obesity doubling between age 4 and age 11 and a further 14% of children considered to be overweight by age 11. No local figures are available for overweight adults but the national figure is a staggering 61.9%.
Public Health England has stated that “Creating an environment where people actively choose to walk and cycle as part of everyday life………. may be more cost effective than other initiatives that promote exercise, sport and leisure pursuits… Local Authority initiatives on road safety are key opportunities to create better conditions for walking and cycling. Moving to a default 20mph speed limit for streets where people live, work and shop may be the most cost effective approach available at present.”
The Edinburgh 20mph trial found that those considering cycling to be unsafe fell from 26% to 18%, the proportion of older primary age children cycling to school rose from 3% to 22%. Overall walking trips rose 7%, cycling trips rose 5% and car trips fell 3%.
Keeping Older and Disabled People Active – LB Richmond has an ageing population with 13.5% of people over 65 (2011 census) and a significant predicted increase in the 75+ age group over the next 5-10 years. Keeping these people active through providing an environment where they feel they can walk and cycle safely is also vital to keeping this group of residents healthy. Disabled people are more likely to be obese and are thus also in need of opportunities to walk and cycle safely.
Air Quality – remains a key local issue with pollution levels continuing to exceed the recommended standards. Driving at slower speeds generally decreases emissions.
Community cohesion – people spending more time outside. The Edinburgh 20mph trial found that the proportion of children allowed to play on the pavement or street rose from 31% to 66%.
20s Plenty for Richmond believes that LB Richmond should:
- undertake consultation on the introduction of 20mph zones on an area by area basis, prioritising communities which have demonstrated support for them e.g. in their Village plan;
- ensure that the consultation explains that the proposal covers the introduction of 20mph limits on main roads with a high “place” function (high streets or B roads) but not in those that have principally a “movement” function (eg arterial A roads);
- remove its insistence that only over 50% of residents of an area voting in favour demonstrates public support for 20mph speed limits;
- as well as the demand from local people, take into account the road safety, public health and community cohesion benefits as well as the boost that higher levels of pedestrian activity can give to local economies when considering introducing 20mph in zones and limits.
20’s Plenty for Richmond
. . . . . . . . . . . . . . . . . . . . . . . . . . http://www.tfl.gov.uk/cdn/static/cms/documents/town-centre-study-2011-report.pdf  http://www.edinburgh.gov.uk/meetings/meeting/3067/transport_and_environment_committee  http://sphr.lshtm.ac.uk/files/2013/12/improving-the-publics-health-kingsfund-dec13.pdf  http://www.acpo.presscentre.com/Press-Releases/ACPO-marks-refreshing-of-speed-enforcement-guidance-26e.aspx
http://www.islingtongazette.co.uk/news/drivers_breaking_islington_s_20mph_limit_to_be_fined_for_the_first_time_tomorrow_1_3796635 https://twitter.com/MPSCallySgt (Tweets – 23 September 2014)  http://www.communityspeedwatch.co.uk/  https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/63975/circular-01-2013.pdf (para 95)  https://www.tfl.gov.uk/cdn/static/cms/documents/safe-streets-for-london.pdf  http://www.london.gov.uk/sites/default/files/Cycling%20Vision%20GLA%20template%20FINAL.pdf  See www.richmond.gov.uk/jsna  https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/213720/dh_130487.pdf  http://www.20splentyforuk.org.uk/BriefingSheets/pollutionbriefing.pdf