Submission on National Speed Limit/Enforcement Policy
Departmental Speed Limit Review Group Submission August 2003
Summary
The Irish authorities have declined to institute the standard northern European hierarchy of speed limits, where urban speed limits of 30kph (20mph) or lower are in widespread use. In Ireland, there is an apparent problem of non-enforcement of the existing speed limits in urban areas. It is pointless to propose increasing walking, cycling or public transport use without confronting this issue. However, there is genuine concern that merely concentrating on base speeds represents an oversimplification of the problem. The greater concern is not speed per se, but the interaction between cyclists and motorists. Here, the emphasis is not on how fast motorists choose to drive, but on how they choose to react, or not react, to the presence of cyclists in the same road space.
Solutions
Solutions are considered under the headings of Enforcement, Education and Engineering.
The behaviour of motorists who choose to speed is a direct cause of unnecessary traffic congestion and a direct cause of ill health among the wider population. This point needs to hammered home repeatedly in any education campaigns.
Enforcement: Legislative Environment
The restoration of cyclist access to Irish towns and cities requires that the issue of roundabouts be confronted. There is an urgent need to impose lower speed limits eg: 20 kph (12mph), on and approaching, roundabouts used by mixed traffic. A similar argument applies to complex junctions and other locations. In particular, there is also urgent need to impose lower speed limits eg 20 kph (12mph), on and approaching, deliberately engineered pinch points. The current failure to adopt the standard 30kph (20mph) urban speed limit is inexplicable and must be remedied as a matter of urgency. The introduction of home zone legislation is advocated. The use of 100kph (60mph) on as a standard speed limit on rural roads (with many different widths and standards) is challenged.
Enforcement: Enforcement effort
The current Garda enforcement effort is reviewed. The provision of an effective police service is fundamental to the restoration of cyclist/pedestrian access to Irish towns and cities. If the Garda are unable to provide an effective speed-enforcement service, whether by reason of institutional, cultural or resourcing obstacles, then this service should be privatised and put on the same basis as the private clamping operations used to prevent illegal parking in urban areas.
Whether by default, or design, it has been long standing Irish road design practice to focus on attempting to create a state of "free flow" for private car users to the practical exclusion of all other considerations. Whether by default, or design, this was also a decision to promote a motorist driving style based on competition, acceleration and speed. This also represents a decision to exclude cyclists, pedestrians and public transport users from the state's primary transportation infrastructure. The massive traffic congestion that has resulted from these practices was entirely predictable and inevitable. The wider engineering issues involved are considered in attached appendices.
Main Submission
Statement of Problem: Speeds of traffic on Irish roads
The Irish authorities have declined to institute the standard northern European hierarchy of speed limits, where urban speed limits of 30kph (20mph) or lower are in widespread use. In Ireland, there is an apparent problem of non-enforcement of the existing speed limits in urban areas. According to the NRA, 68% of cars exceed the existing (inappropriately high) speed limits on residential roads. On main urban roads the average free speed of cars within 30mph zones is 45mph [1]. (See also Appendix 1: Speeds of Traffic on Irish Roads, page 7). An EU commissioned research report on promoting walking and cycling cites the following as the top two safety measures [2].
1. A comprehensive automatic camera speed control. National legislation must be changed (if not already done) so that speeding fines can be sent to the owner of the car, not to the driver. The surveillance must mainly be done with movable equipment at unexpected spots.
2. The maximum speed limit in central and residential streets - and in other streets where walkers and cyclists are present - should be 30kph (20mph).
In contrast to the 1500 speed/traffic light camera installations in the Netherlands, in Ireland there are only around 20 fixed speed camera installations, and three actual cameras. A recent report estimates that an Irish motorist stands less than a 1:1400 chance of getting caught speeding [3]. In Ireland, there must be an underlying assumption that in urban areas, both cyclists and law-abiding motorists will be using public roads without the type of support or routine protection provided by the Police forces of other European countries. This is readily demonstrated by the fact that in 1997 and 1998 Ireland achieved the highest child pedestrian death rates in Western Europe (See Appendix 2 Child Pedestrian Deaths). Speeding and aggressive behaviour by motorists is the single greatest obstacle to increasing bicycle use in Ireland. It is pointless to propose increasing walking, cycling or public transport use without confronting this issue. This fact must also inform any decisions made regarding road designs as road design can have strong role in influencing this aspect of motorist behaviour.
Speeding: Partial dissent
Many experienced Irish cycle commuters have been dealing successfully, if uncomfortably, with high-speed motor traffic for many years. There is genuine concern that merely concentrating on base speeds represents an oversimplification of the problem. The greater concern is not speed per se, but the interaction between cyclists and motorists. Here, the emphasis is not on how fast motorists choose to drive, but on how they choose to react, or not react, to the presence of cyclists in the same road space. Unfavourable comparisons can be drawn with the US, where traffic speeds tend to be lower, but motorists may be openly intolerant towards cyclists in the same traffic stream. In contrast, favourable comparisons are drawn with French drivers, who are noted for an exuberant driving style, but who are also perceived as giving cyclists more room, and respect, on the road. However, under French law motorists have defined "risk-liability" regarding vulnerable road users, and French motorists overtaking cyclists are required to use a defined minimum passing distance. Nevertheless, these regulations may derive from, and be secondary to, a greater public awareness of, and tolerance towards, cyclists. There is little point trying to develop a cyclist/pedestrian friendly traffic environment and superimpose this on an underlying "roads culture" that is hostile to non-car users, this would be putting the cart very much before the horse.
The solutions
It is futile and self-defeating to consider speed limit policy merely in terms of legislation. Speed limit policy is merely one aspect of a range of measures needed to tackle speeding. The solution requires a set of interconnected and mutually supporting measures involving respectively Education, Enforcement and Engineering
Education: Setting the context
There is justified cynicism among the motoring public that current speed-limit enforcement efforts are primarily intended as "revenue and statistic" gathering exercises. If any increased enforcement effort is genuinely intended to improve road safety, then it must be accompanied by an information campaign to stress the wider context. The major problem with current road-safety education efforts is that the focus is almost exclusively on car crashes/collisions. For the individual motorist, these are not common events and the individual motorist might expect many thousands of miles of driving without any involvement in a serious accident. Therefore, the individual motorist reasonably weighs off the perceived personal benefit of speeding versus the low individual risk of serious accident.
Currently little attempt is made to sell the wider societal benefit of motorists complying with the law. Irish motorists are not being made aware of the connection between their decision to speed and the growing problem of traffic congestion. No attempt is made to point out to Irish motorists that racing from traffic jam to traffic jam merely increases the chance that junctions will overload and lock up. No attempt is made to point out to motorists that their own speeding is the reason why children, students and other adult commuters can no longer walk or cycle to school/work.
Ireland still has at least one generation of housewives who, until comparatively recently, used their bicycles to go to work and "do their messages". These women, many of whom are actually quite skilled cyclists, have been forced off the state roads network by the behaviour of Irish motorists.
Ireland has among the highest levels of obesity and heart disease in the EU and is also facing an epidemic of related conditions such as Type II diabetes. These conditions are intrinsically linked to a lack of safe opportunities for regular exercise, the principle source of danger in Irish public areas is the behaviour of Irish motorists. The point needs to hammered home repeatedly that the behaviour of motorists who choose to speed is a direct cause of unnecessary traffic congestion and a direct cause of ill health among the wider population.
Enforcement
Enforcement issues are considered under two headings- the legislative environment and the enforcement effort.
Legislative environment: Cyclist hostile infrastructure
Lower speed limits at Roundabouts
Despite the existence of serious reservations, the character and fabric of many Irish towns has been seriously degraded through the use of roundabouts of a design that is demonstrably hostile, dangerous and inappropriate. For pedestrians, cyclists, motorcyclists and many motorists, these junctions are the most loathed and feared locations on the roads network. On multilane roundabouts of the design specified by Irish road design guidance, cyclists have an injury accident rate that is 14-16 times that of motorists. Motorcycle/scooter users are only marginally better off at 10-13 times the injury rate. Some towns/cities, such as Galway, have effectively been sealed-off from their suburbs behind a ring of roundabouts (see Appendix 3a Anti Environmental Traffic Cells; Appendix 3; Extract from GCC submission on Galway City Development Plan 2003). There is a pressing need for remedial measures so as to restore some measure of cyclist access to such towns. Sixty eight per cent of motor vehicle/cyclist collisions at roundabouts involve motor-vehicles striking circulating cyclists, who have the legal right of way over entering and following traffic. There is general agreement that the only way for a cyclist/motorcyclist to negotiate such junctions is in exactly the same manner as a car. This is also the legally required manner in which to negotiate such roundabouts. This requires that the cyclist be able match the speeds of the traffic on the roundabout. This is only an option for fitter, adult cyclists, on fast bicycles. Therefore if these roundabouts are to be retained in Irish towns, and if the average cyclist cannot be made to go faster, then the motor traffic needs to be slowed down to a speed achievable by the average bicycle user. The introduction of a 12 mph (20kph) speed limit on, and approaching, all roundabouts with mixed traffic should be made a matter of urgency.
Legislative environment: Cyclist Hostile Infrastructure:
Lower speed limits at other Junctions
Like roundabouts, there is also an argument that lower speed limits should be applied at any intersections where cyclists are required to weave across lanes of following traffic. Multilane one-systems are a case in point. If the standard Northern European urban 30kph limit is not to be generally applied on Irish urban roads then it is still arguable that lower speed limits should still applied at complex junctions. It is understood that the Netherlands exercises just such a policy of lower speed limits at junctions on rural roads. This, however, could be seen as equivalent to the Irish urban situation where "interurban arterial-road" type junction designs can be found i.e. high flow roundabouts, slip roads, long filter lanes, extensive one way systems etc. Such features are highly inappropriate on urban streets with mixed traffic. The automatic imposition of lower speed limits at, or approaching, signalised junctions might help tackle other offences such as red light running by motorists. The provision of a safer traffic environment might also help increase compliance by cyclists. (The wider issue of compliance by cyclists with traffic signals is outside the scope of this submission, suffice it to say that there is a strong argument that several generations of traffic engineers have been training several generations of cyclists to ignore traffic signals.)
Legislative environment: Cyclist Hostile Infrastructure:
Lower Speed Limits at Engineered Road narrowings/Pinch points
Road narrowings and pinch points are a source of concern to many cyclists. This is especially the case on roads with fast-moving and/or heavy traffic. At many locations, motorists will treat cyclists as an obstacle to be overtaken at all costs. This can result in either aggressive overtaking manoeuvres prior to the narrowing, or close proximity overtaking within the feature. Narrowings such as footway build-outs or central islands may be applied as part of "pedestrian refuge" installations. Alternatively, they may be applied as a speed-reducing feature in traffic calming schemes. There is a strong argument that in the latter application, the main speed-reducing factor is the presence of cyclists in the traffic stream. A Transport Research Laboratory report on such features has found that in effect "the cyclist is the principle speed reducing "feature"" [4]. Particular concerns have arisen over the use of pinch points at "gateway schemes" approaching Irish town and villages. This has resulted in an extremely hostile situation for transiting cyclists. Cyclists find themselves forced into sharing an extremely limited road space with vehicles, including HGV's, approaching at 60mph or more. It is known that Galway County Council shares these concerns and there may be similar concerns within other local authorities. The whole basis and advisability of many of these schemes must be questioned. If cyclist access to Irish towns/villages from their rural peripheries is to be restored then a national program is required to eliminate such gateway schemes (a properly enforced speed-limit regime will in any case eliminate the supposed rationale behind these schemes in the first place). However, if any of these features are to be retained either approaching, or within, Irish towns then the same considerations that arise with roundabouts will apply. e.g. If the average cyclist cannot be made to go faster, then the motor traffic needs to be slowed down to a speed achievable by the average bicycle user. The introduction of a 12 mph (20kph) speed limit on, and approaching, all engineered road narrowings should be made a matter of urgency. (see Appendix 5; Extract from GCC submission on Galway City Development Plan 2003)
Legislative environment: Urban roads with mixed traffic
Ireland may be unique among Northern European countries in not applying urban speed limits lower than 30mph (50kph). On local roads in Germany and Austria, "tempo 30" zones are used, in which an enforced speed limit of 30kph (20mph) is applied. In the Netherlands, the national road safety strategy is setting a target for 30kph (20mph) limits on up to 75% of the urban network. (Please see attached document Appendix 4 "20 mph as a Standard Speed limit Why Galway needs it). The ongoing failure of the Irish authorities to introduce 30kph as the standard urban speed limit is inexplicable.
Legislative environment: Speeding on rural roads/Rural accidents
Rural roads account for only 13.5% of recorded Irish cyclist casualties but account for 50% of cyclist fatalities, which clearly indicates that cycling on rural roads carries a disproportionate risk of fatal collision [5]. Ireland has a highly dispersed pattern of rural settlement. Therefore it is inevitable that on most rural roads, cyclists and motorists will be sharing the same road space. Other than isolated recreational routes, or roads where the standard hard shoulder treatment is available, a separate system of segregated space for cyclists is unlikely even in the long term. The current use of 100kph (60mph) as the standard speed limit on all roads outside built up areas must be queried as a matter of urgency. There are numerous narrow rural roads where 100kph (60mph) is not a remotely suitable speed limit. There is a strong argument that on non-national roads, or any roads of limited width and geometry, a standard maximum speed limit of 70kph (44mph), or lower, should apply. It is understood that both the Netherlands and Denmark apply standard rural limits of 80kph. However, lower limits are applied at junctions. On unlit roads, there is also a question of whether there should be separate daytime and night-time speed limits.
Legislative environment: Home Zones or woonerfen
The Netherlands is particularly noted for the development of Home zones or woonerfen. A home zone is a residential area in which pedestrians and cyclists have priority over motorised traffic. A speed limit of 10mph or lower is applied, and car users are automatically responsible for any injuries they cause. Used in the Netherlands since the 1960s, there are now over 6,500 woonerfen schemes in place [6]. Denmark introduced the concept in 1978, followed by Germany and Austria in the early 1980s. The original concept made no distinction between space for cars or for people. The entire street was effectively a large footpath/plaza, dropping the usual distinction made between "pedestrian" space or "car" space. In latter practice, or when applied to existing streets, extensive use is made of physical traffic-calming measures. This may or may not include the formal declaration of the area to be a home zone. The effect is to create a residential area in which children can play outside without fear from road danger. Other vulnerable road groups such as the elderly or disabled also gain from increased mobility. This creates a situation in which not only can children play outside but there is increased supervision and personal security as more local adults make use of the public space. This system then builds to create a network of back street routes through traffic-calmed/speed-restricted areas. Vulnerable road users such as children or the elderly gain increased mobility through access to an alternative network of routes. This can be contrasted with the Irish practice of planning exclusively on the basis of arterial, "high flow", access by car to cul-de-sac type developments. This practice then forces all cyclists and pedestrians, including children and the elderly, to use those same arterial roads for all trips, regardless of purpose or destination (or in practical terms, forces everybody into cars for all trips).
Legislative Environment: Increased sanctions for urban speeding
Given that speeding on urban roads is such a socially disruptive and damaging activity there is a strong argument for augmented sanctions. One option might be to introduce mandatory confiscation of vehicles where the level of speeding exceeds a pre-set limit. E.g. where a person is caught doing 80kph in a 30 kph zone - automatic vehicle confiscation would occur.
Enforcement: the Enforcement effort
Apart from certain selected stretches of arterial roads, the Garda seem to be operating an apparent policy of non-enforcement of the current speed limit regime. The suggestion that this situation is driven by a lack of resources is not credible. Lack of resources might limit the quantity of speed traps being set up, but it cannot explain the curiously limited distribution of speed trap locations. It is not clear if this situation derives from the attitude of the current Garda leadership, or from an internal Garda culture that is tolerant of dangerous driving, or both. The national media have reported resistance within the Garda to the introduction of penalty points. Newspaper leaks have suggested that An Garda Siochana are unable to effectively operate the current penalty point system. This only serves to reinforce the impression, that the Garda Siochana, as an institution, are currently part of the national traffic congestion problem rather than part of the solution. These observations are made without prejudice to the efforts of individual members of An Garda Siochana to deal with the current situation. The Galway Cycling Campaign actually has a good relationship with the local Garda.
The provision of an effective police service is fundamental to the restoration of cyclist/pedestrian access to Irish towns and cities. Clearly it would be preferable if An Garda Siochana were in a position to uphold the right of all road users to go about their lawful business without threat or hindrance by others. However, if the Garda are unable to provide an effective speed-enforcement service, whether by reason of institutional, cultural or resourcing obstacles, then perhaps this service should be put on the same basis as the private clamping operations used to prevent illegal parking in urban areas. Speed detection and recording equipment can be entirely automated. In other countries speed enforcement has been shown to be a net revenue earner and is self-funding which makes it an ideal candidate for privatisation. These means that there is no reason why private entities could not operate certified speed detection apparatus, process the tickets and derive income as a proportion of the fines collected. Such detection equipment or services could be made available to local communities who could then set up their own temporary speed traps. Local communities often feel that they are left to put up with what is perceived as speeding "free for all" on secondary and residential streets. Privatising speed detection services might offer a way around this situation. If the desire is to achieve societal benefit then such a policy must however be a focus on tackling speeding in urban areas, rather than more "shooting of fish in barrels" on selected arterial routes. If a privatised service is introduced then it should be restricted to urban areas and non-national roads with the Garda retaining their role on interurban routes.
Engineering
In other countries it is an accepted principle of traffic management, and traffic law enforcement, that roads should have "self explanatory speed-limits" i.e. a perceived design speed that matches the speed limit being applied. This submission has been critical of the role of An Garda Siochana. However, rank and file Garda are perfectly entitled to point out that current situation on the Irish roads network was actively created by Irish traffic and roads engineers and their civil service supervisors. Under successive roads acts, Irish roads authorities were explicitly required to consider the needs of all road users in carrying out their functions. Despite this, it would seem to have been long standing Irish road design practice to focus on attempting to create a state of "free flow" for private car users to the practical exclusion of all other considerations. The decision by the Irish authorities to promote the use in urban areas of interurban-type road geometries and such features as:
1. One-way streets
2. High capacity roundabouts
3. Large kerb radii
4. Excessive visibility envelopes
5. Banned right turns
6. Cycle tracks
7. Free left turns
8. Filter lanes
9. Slip roads
10. Car centred traffic control systems
was, whether by default, or by design, a decision to promote a motorist driving style based on competition, acceleration and speed. It also represents a decision to exclude cyclists, pedestrians and public transport users from the state's primary transportation infrastructure. (Most public transport users are by definition also pedestrians). Concerns over of the use of roundabouts and one-way streets were raised in Irish reports as far back as 1979 and have been ignored. In Ireland, even the provision of pedestrian crossings is based on a "warrant system" whose stated goal is to reduce the "delay" caused to motorists by people who choose to cross the road while exercising their right to go about their lawful daily business on foot.
There is reason to believe that similar motivations lie behind recent attempts to impose alien and dangerous "cycle track" structures in Irish towns and cities. As the Irish authorities have been made repeatedly aware, these devices have had appalling safety records when tried in other countries. Nevertheless, Irish cyclists continue to find themselves being endangered obstructed and impeded by such cycle track/cycle lane devices. The presumption must be that this is being done in order to facilitate "flow", or in effect speeding, for Irish motorists by attempting to provide motorists with (theoretically) "cyclist free" routes. The simultaneous endangerment and obstruction of cyclists, and the discouragement of cycling as a form of transport, are assumed to be secondary considerations.
The massive traffic congestion that has resulted from these practices was entirely predictable and inevitable. Irish traffic management practice frequently seems intended to make the current situation worse rather than better. The wider engineering issues involved are too complex for a submission such as this but are considered in the attached appendices (See attached policy documents of the Galway City Community Forum 1) On promoting, protecting and celebrating, walking as the most important form of transport in Galway city. Adopted 1/12/01 2) Towards the creation of a people friendly roads infrastructure for Galway. Adopted 1/12/01, and also Urban Cycle Tracks, an Information Sheet, Galway Cycling Campaign, October 2000)
References
1 RS 453 Free Speeds on Urban Roads, National Roads Authority, 2000.
2 How to enhance WALking and CYcliNG instead of shorter car trips and to make these modes safer, Deliverable D6 WALCYNG Contract No: UR-96-SC.099, Department of Traffic Planning and Engineering, University of Lund, Sweden 1999.
3 Review of Ireland's Road Safety Strategy, R-2002-27, Fred Wegman, SWOV Institute for Road Safety Research, Leidschendam, The Netherlands, 2002
4 Cyclists at Road Narrowings, D.G. Davies, T.J. Ryley, S.B. Taylor, and M.E. Halliday, TRL Report No. 241, Transport Research Laboratory, Crowethorne, 1997.
5 Road Accident Facts, National Roads Authority, 1999.
6 Home Zones briefing sheet, Robert Huxford, Proceedings, Institution of Civil Engineers, Transport, 135, 45-46, February, 1999.