Memorandum by the ACPO
Traffic Committee (IT 168)
THE INTEGRATED TRANSPORT WHITE PAPER
"A NEW DEAL FOR TRANSPORT: BETTER FOR
EVERYONE"
1. GENERAL
1.1 I am encouraged by the overall content of
the White Paper and pleased to note that due recognition is given
to the need for road policing to concentrate on all aspects of
public safety (3.82). "Travelling without fear", as
the White Paper puts it, is also a key element of my Association's
National Road Policing Strategy.
1.2 Coupled with the statutory partnerships
and safety audits that the Crime and Disorder Act introduces,
and the new DETR Strategy to 2010, to which my Committee has contributed
and will again be giving its support, the White Paper provides
the bedrock for effective inter-agency co-operation in policing
the roads into the new century.
1.3 We are particularly encouraged to note the
following specific areas, which support or complement the Committee's
National Road Policing Strategy of "Reducing death and injury,
damage or fear on the roads":
— New road safety strategy and targets,
together with localised road safety targets (3.219; 1.38 and 1.29)
plus the specific emphasis on education, vehicle safety, road
engineering and more enforcement (3.220)—see paragraph
1.2 above.
— Work with the European Union on education
and vehicle engineering (3.226)—these are key elements
of the ACPO National Road Policing strategy.
— Possible measures to improve drink
driving enforcement (3.223)—we support a reduction in
the limit from 80 to 50mg and seek a "general power"
to breath test all drivers.
— The commitment that the reduction
of crime and the fear of crime will be a major priority (3.82),
coupled with specific measures to address personal security (3.83
and 3.84)—a core policing function.
— Measures to reduce motor vehicle
crime (3.83)—this very much supports my Association's
work with the Home office and Crime Prevention Agency in the Vehicle
Crime Reduction Action Teams (VCRATs).
— The enhanced provision of roadside
equipment such as CCTV cameras for use by the police, should reassure
the motorist and improve police efficiency in responding to incidents
with added potential for enforcement (3.143)—this mirrors
the benefits already experienced with town centre CCTV schemes.
— Improved co-ordination of intelligence
between the various enforcement agencies is to be encouraged (4.192)—already
an acceptable principle in the fight against crime and of undoubted
benefit to road policing.
— Improve drivers hours legislation
(1.38 and 3.239)—reflects my Committee's desires to see
better regulation of LGV and PCV drivers and operators as recommended
in my submission to the House of Commons Transport Committee Enquiry
on the Adequacy and Enforcement of Regulations Governing Heavy
Goods Vehicles, Buses and Coaches.
— Proposals for Regional Traffic Control
Centres (RTCCs) have the potential to both assist the motorist
and remove an unwanted burden upon the police service (3.138-3.140)—supported
in principle in a recent consultation of all chief constables.
2. STRATEGIC CONCERNS
2.1 My Committee has not previously had the
opportunity to respond to the White Paper. The DETR is consulting
on various aspects and this process has already begun and we will
be responding in detail to each specific proposal. There are a
number of issues of a strategic nature in the White Paper that
are of concern to my Committee and I list these below.
2.2 Better Enforcement—(4.177-4.192)
2.2.1 The White Paper reminds us of the Home
Secretary's letter on Key Objectives and that, " . . . traffic
policing is a central port of the police's responsibilities for
maintaining law and order and preventing and deterring crime and
reducing death and injury on the road. I will therefore expect
traffic policing to play a full part in achieving my overall objectives
for the police service, particularly in relation to community
safety and crime reduction and in achieving a safer environment
on the roads". (4.187). I do not take issue with this statement.
However, in a developing and expanding police "best value"
and performance management culture, it is quite natural that in
the absence of a "road safety" or "Traffic"
objective, available resources will be focused in those areas
of policing upon which chief constables are currently measured.
2.2.2 To date, "road policing" which
encompasses the whole ambit of police proactivity on the road,
is not specifically mentioned in the current Home Secretary's
Key Policing Objectives. I am, however, encouraged that the new
Ministerial Priorities for 1999-2000 include the reduction of
crime and disorder which provides scope for road safety and road
policing issues to be included in the crime and disorder audits
under the new Crime and Disorder Act.
2.2.3 There will also be scope, within the new
Overarching Aims and Objectives for the Police Service, agreed
between ACPO, the Association of Police Authorities and the Home
Office, for road safety concerns to be addressed under the specific
objective of "Contribute to improving road safety and the
reduction of casualties".
2.2.4 However, there is currently no strategic
fit for the White Paper's aims in relation to environmental and
traffic flow management (4.178) within the existing priorities
and objectives of the police service.
2.2.5 The key to "finding ways to promote
effective road policing" (4.187) is funding. Chief police
officers operate within finite budgets determined by a funding
formula. The Traffic element of the Formula is based upon the
number of officers ostensibly based upon traffic duties but only
represents a small proportion of the overall allocation. By far
the most significant elements revolve around crime, social needs
and disorder.
2.2.6 Any increase in policing activity on the
roads (4.178) would require either substantial additional funding
or be provided at the cost of some other important area of work,
leading to the possibility of a fall in performance against national
Ministerial Priorities. The current police funding situation is
not encouraging. The funding settlement for 1998-99 provided for
a total service spend of £6,606.8 million, an increase of
£194 million or 3 per cent over the comparable figure for
1997-98.
2.2.7 However, in the view of the Home Office
Services Expenditure Forecasting group (EFG), the increase was
more than absorbed by:
(1) an increase of £64 million in police
pension costs;
(2) the £30 million cost of police and
civilian staff salary increments; and
(3) pay and price rises of £195 million.
This is at a time of increasing demands upon
the service. The question of funding for extra police activity
in relation to innovations in traffic management and control,
need to be included in the planning of the Integrated Transport
Policy.
2.2.8 Indeed, no funding is currently provided
to forces for administering conditional offers of fixed penalty
in camera enforcement at today's levels, even though the cost
benefits of these cameras has been proved beyond doubt. A consistent
means of funding today's camera enforcement activity, let
alone for increased enforcement, needs to be identified and implemented
(4.180). Different systems for different schemes would be an undesirable
approach, creating considerable budgeting difficulties for the
police service.
2.2.9 That said, the means of gathering the
money must be right. The police service has consistently voiced
its objection to the use of hypothecation to fund camera enforcement,
since it could lead to suggestions of profiting from the imposition
of fines and using enforcement as a means of income generation.
Any system that reimburses police in this area of work must simply
return the cost of administration on a non-profit making basis,
rather than providing additional funding for conventional police
activities.
2.2.10 Whilst enforcement could be greatly enhanced
by an administrative charge for camera enforcement, operational
patrol, a key function in combating bad driving and anti-social
behaviour (4.186), is an important element of road safety. Such
patrolling cannot be increased without substantial additional
funding.
2.2.11 The issue of a funding formula for road
policing based, not upon traffic officer numbers as at present,
but upon death and serious injury on the road is another issue
that will need to be addressed if the police service is to do
justice to the road safety element of an integrated transport
policy.
2.2.12 Each road death can be costed at approximately
one million pounds and many believe this to be a very conservative
element. It certainly does not take account of the emotional cost
to those bereaved by road death. Nine deaths per day—3,300
per year—justify the spending of £3.5 billion per year
on road safety. Half of the current police budget. Yet the Government
consistently refuses to implement our requests for additional
funding. The cost benefits to the National Health Service in terms
of bed hours saved through the reduction of death and injury have
been identified in preparatory work conducted in Lancashire Constabulary's
proposed Victoria initiative is only one example of how the principal
of "spend to save" applied to road policing could benefit
society as a whole.
2.2.13 Strategic Partnerships to ensure multi-agency
involvement in making the roads safer are crucial (4.184). Working
across Government departments on issues relating to road policing
to ensure effective outcomes is not a simple process. Policing
matters are the responsibility of the Home Office, whilst roads
and road safety are the concern of the Department of Environment
Transport and the Regions (DETR) and its Agencies. Whilst the
liaison between the police service and the Home Office and DETR
have been good, the liaison between the latter two has not, at
times, been all that we might have hoped for. I have begun to
address this problem by establishing a tripartite meeting between
ACPO, the Home Office and the DETR at two levels. The first at
ministerial level and the second at senior official level. This
has already begun to show results by facilitating the movement
forward of discussions on the implementation of various aspects
of the Integrated Transport White Paper.
2.2.14 Similarly, discussions on the introduction
of the Highways Agency's "Toolkit" measures are being
brokered through the ACPO/HA Partnership Project. This innovative
approach to issues of joint concern enables mutually beneficial
projects to be developed and, in addition, has facilitated relationships
at operational, policy and strategic levels. This has enabled
both parties in the partnership to better understand the pressures,
constraints and priorities under which the other is operating.
It has the potential to lower barriers and ultimately deliver
a more holistic service to the joint customer base, thereby delivering
effective, efficient, and economic quality outcomes. This could
well be considered as a model for similar partnership arrangements
between other agencies of the DETR and ACPO, particularly the
Vehicle Inspectorate and the Driving Standards Agency and my Committee
is actively pursuing this possibility through the ACPO/DETR liaison
officer.
2.2.15 There is a real need for crime prevention
and traffic management to be considered together, since some traffic
management schemes can drastically impact upon levels of crime
and vice versa. For this reason, my Committee has recently revised
its Strategy in order to accommodate all types of vehicle related
crime. The importance of co-operation between road safety and
crime prevention specialists in the planning of new buildings
and their road infrastructure needs to be emphasised. Personal
security, safety and the fear of crime are relevant and important
issues wherever they occur and should be considered in any integrated
transport policy.
2.2.16 Partnerships in enforcement are another
key issue. The White Paper rightly recognises, at 4.184, that
traditionally the police service has been seen as the leading
enforcement agency for matters relating to road traffic. I note
with concern that at 4.186 there is a suggestion that less serious
offences "are suitable for streamlined procedures" and
wonder what is intended here. There is no consensus within the
police service for the enforcement and prosecution of offences
involving driver behaviour likely to cause death or injury such
as speeding, dangerous reckless or careless driving to be devolved
to other agencies or decriminalised.
2.2.17 Over recent years we have seen other
agencies adopting an increasing enforcement role. Whilst we accept
that offences involving parking, exhaust emission controls, certain
dedicated vehicle lanes and vehicle safety standards can quite
appropriately be processed by other agencies, the police service
jealously guards its prosecution role in relation to the more
serious traffic offences on the road and its sole possession of
the power to stop.
2.2.18 We are concerned that the lack of resources
for road policing may cause pressures for this core police enforcement
role to be devolved to other agencies and believe that there would
be a serious risk of inconsistency, and real public unease, if
the police service did not retain control of the enforcement of
such offences. Our efforts in this regard must not be diluted
by new work which is not safety related i.e., traffic flow management
and environmental and other social control issues, unless adequate
safeguards to ensure the continuation of our key role of preventing
death and injury, damage or fear on the roads, are also introduced,
based upon the provision of adequate funding.
2.2.19 It is our view that the power to stop
should only be held by sworn officers, or perhaps certain civilian
employees working under police management, such as vehicle examiners
or traffic wardens. The role of the latter has been considered
by chief constables and deemed suitable for development in order
to compliment the work of sworn officers. The Home Office is currently
considering the proposals of the police service in this regard
which have the potential to maintain police standards and accountability
whilst supporting the thrust of the White Paper and the work of
other agencies.
2.2.20 The police are very much aware of the
mutual benefits that can be achieved through close partnerships
with other agencies. The police service's agreement to assist
with stopping vehicles for emission testing by local authorities
is an example of how this can be achieved through inspired funding
arrangements which allow forces to continue their efforts in supporting
the strategic aim of road policing, whilst at the same time assisting
in a partnership with local authorities to improve the environment
for everyone. The potential for this type of approach to be applied
to other enforcement activities needs to be explored.
2.2.21 Additionally there is the potential to
lose a significant source of intelligence if these issues are
not handled carefully. The JEDI initiative mentioned at 4.192
of the White Paper is a good example of how all agencies involved
in the enforcement role can co-operate to mutual benefit, through
the exchange of intelligence, in order to increase the potential
for the targeting and detection of offenders. The police service
is also working with the insurance industry with a view to establishing
a national, insurance database, which we see as the forerunner
of a national database providing access to all driver and vehicle
data under one umbrella.
2.2.22 The enforcement burden is another key
issue. The police service must, of necessity, retain a robust
enforcement capability for those who fail to exercise self-discipline
and social responsibility. In order to police effectively it is
necessary to maintain a strong and highly visible police presence
on the roads and possess powers that enable the use of intelligence
led, targeted enforcement, thereby providing us with a realistic
chance of detecting and convicting those who pose a serious danger
to other road users. However, many motoring offences lend themselves
to efficient detection and subsequent processing by technological
means. The Controlled Motorways Experiment on the M25 is an example
of new technologies being applied through a partnership approach,
both for traffic management and road safety purposes.
2.2.23 To maximise the potential of all types
of traffic enforcement technologies for casualty reduction purposes,
police forces need to be in a position to avail themselves of
the infrastructural support necessary to bulk process offenders.
This can involve an expensive initial outlay and some form of
pump priming is necessary in order to encourage and capitalise
on the opportunities.
2.3 The review of speed policy—(3.227-3.230)
2.3.1 We welcome the review of speed policy
since we are concerned at the apparent growth in unrealistic speed
limits, imposed apparently in order to appease local pressure
groups rather than as a consequence of meaningful research into
what the appropriate safe limit ought to be. Such a plethora of
varying speed limits creates an unrealistic expectation in the
mind of the public that such limits will be rigorously enforced.
The opportunity to thoroughly review the criteria upon which speed
limits are applied should not be missed and this should lead to
a local review of all speed limits.
2.3.2 Our concerns are made deeper by the recent
government decision to allow local authorities to introduce 20-mph
limits without traffic calming measures. Funding restrictions
upon local authority budgets makes the introduction of such limits
without appropriate physical constraints an attractive proposition
yet the consequential enforcement burden upon the police service
is potentially substantial.
2.3.3 Traditionally, speed limits have been
imposed and enforced on the grounds of road safety and have, by
and large, been accepted by the public on that basis. The penalty
of driving licence endorsement, and ultimately disqualification,
has also traditionally only been applied to "unsafe"
practices on the road. The potential broadening of the reasons
for the imposition of speed limits to include environmental and
traffic management purposes e.g., tyre noise pollution, to support
cycling strategies, for environmental and social objectives needs
very careful consideration if acceptance by the public is to be
retained (3.228). Any introduction of environmentally based speed
limits will need to be preceded by considered debate on the possible
segregation of safety and environmentally related penalties and
processes.
2.4 Road charging—(4.92-4.99)
2.4.1 We note the proposals to reduce congestion
on the roads by the imposition of roads pricing and have two overarching
concerns. Firstly, that some revenue enforcement burden could
fall upon the police service and secondly that the displacement
of traffic to other roads might create added congestion and extra
enforcement demands. Additionally, we have the following specific
concerns in relation to "toll roads".
— Constructional safety implications
of revenue collection.
— Unrestricted access for emergency
service vehicles.
— Legal status of private toll roads.
— Ability to divert traffic onto, and
even close, toll roads in emergencies.
— Access to signalling systems and
integration with police tactical incident control.
3. OPERATIONAL ISSUES
3.1 There are a number of issues of an operational
nature in the White Paper that are of concern to my Committee
and I list these below.
3.2 The Use of Bus Lanes by Motorcycles—(3.47)
3.2.1 The proposal that local authorities conduct
pilot studies of the use of bus lanes by motorcycles causes my
Committee considerable concern. A recent consultation showed the
police service to be wholeheartedly opposed to the use of bus
lanes by motorcycles.
3.2.2 I would want to be convinced that there
would be a saving in death and serious injury to motorcyclists
before recommending that my Committee should support such a move.
In addition, the use of dedicated vehicle lanes by differing classes
of vehicle makes the introduction of efficient and effective technological
enforcement devices all the more difficult.
3.3 The role of motorcycling—(3.44-3.47)
3.3.1 Any increase in the use of mopeds and
motorcycles on our congested roads must be accompanied by measures
to ensure that the risks associated with these modes of transport
are reduced.
3.4 The Highways Agency "Toolkit"—(3.132)
3.4.1 Traffic Committee has a full time liaison
officer working with the Highways Agency providing a means of
sharing in the development of the Agency's strategies and their
affect upon police operations (see also 3.5.1 of this paper).
The Committee will seek to ensure that the "toolkit"
measures referred to do not increase the efficiency of the network
to the detriment of operational policing. I have listed below
the main concerns of the police service:
— Opposition to the use of hardshoulders
as running lanes.
— Potential for substantially increased
enforcement burden.
— Police enforcement activity should
major upon casualty reduction rather than traffic flow management
and environmental issues.
— Funding and the need to secure a
sustainable enforcement funding stream.
3.5 Hard shoulder running—(3.143)
3.5.1 I note with concern in the proposal that
recovery vehicles should be permitted to run on the hard shoulder
in congested traffic. This dangerous manoeuvre is currently allowed
only under police control and any change in regulations would
need to be subject to stringent safeguards.
3.6 Regional Traffic Control Centres (RTCCs)—(3.138-3.140)
3.6.1 Through our Highways Agency/Police Joint
Standing Committee we will carefully monitor the introduction
of RTCCs, a concept that the police service has agreed to support
in principle. The police service has also agreed in principle
to the proposal that the handling of calls from emergency roadside
telephones should be devolved to the Highways Agency as the vast
majority of such calls relate to routine service provision rather
than emergency situations. However the police service wishes to
be further consulted on both these issues once firm proposals
have been drawn up. The keys to overall success in this venture
are effective communication channels and agreed operating protocols
that do not place extra burdens upon the police.
3.7 An Integrated Approach to Safety—(3.259)
3.7.1 It is not at all clear whether the intention
to " . . . review the arrangements for transport safety,
including accident investigation" refers to road collisions.
The Home Office Review of Core and Ancillary Tasks in 1995 concluded
that "the investigation of accidents is a core policing function
. . . " and I would underline the importance of the police
service maintaining the responsibility for this function.
3.8 Detention of Commercial Vehicles—(4.192)
3.8.1 Whilst supporting the need in principle
to detain unlawfully operated commercial vehicles, we would wish
to reiterate our concerns as expressed in our detailed submission
to the House of Commons Transport Committee Enquiry that no enforcement
or administrative burden should fall upon the police service in
this regard.
3.9 Lorry movement restrictions—(3.171-3.175)
3.9.1 Whilst we support in principle the proposal
to restrict lorry movements from unsuitable roads and at inappropriate
times, we are anxious to ensure that there is not an unrealistic
expectation of the police service's ability to become involved
in the enforcement of such measures without additional funding.
3.10 Helping the Road User—(3.143)
3.10.1 We note that the Highways Agency wishes
to ensure a continuing improvement in the service provided by
the police in mobilising breakdown or recovery vehicles following
incidents on motorways. We are uncertain how this is to be achieved
unless it forms part of the proposed transfer of roadside emergency
telephone call handling within the RTCC proposals. If not, this
proposal may be inappropriate, given chief constables' autonomy
and accountability in providing this service.
3.11 Suitable Traffic for Suitable Roads—(3.173)
3.11.1 Whilst not specifically mentioned, the
movement of abnormal indivisible loads is a contributory factor
in congestion. The Home Office has recently undertaken a public
consultation exercise into proposals that the escorting of loads,
within certain dimensional constraints, should be the responsibility
of the haulier rather than the police. To facilitate the effective
management of such loads and avoid added congestion at peak times,
the adequate provision of lay-up points needs to be built in to
the core trunk road network at key nodal points.
Thank you for this opportunity to present the
views of my Committee on the Transport White Paper.
Paul Manning
Chairman of Traffic Committee
The Association of Chief Police Officers
November 1998
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