Memorandum submitted Greenspeed
1. INTRODUCTION
1.01 Greenspeed has been campaigning for
over 10 years for regime change in the national speed limits from
70/30mph to 55/20mph. During that time traffic speed has been
the subject of a number of reviews but these have not covered
the full impact that our current speed limits on the economy,
society and the environment. Despite the preoccupation on road
"safety", the current speed regime continues to cause
a level of loss to life and limb that imposes serious costs on
the economy, the health services, emergency services, families
and communities.
1.02 On the recent/current DfT/Defra/DTI
consultation on climate change, the section on transport from
the Transport Secretary amounts to little more than an apology
for the failure of transport policy to deliver on reductions of
GHGs and assumes that the carbon burden will continue to increase
despite some technological innovation and fiscal measures making
marginal differences. This is presumably the basis of the concern
of the Environmental Audit Committee.
1.03 The problem for the transport sector
is illustrated by the reference to the DfT review in July 2004
that the objective is to achieve "better access and greater
mobility". The DfT is oblivious to the conflict between the
worthy objective of increasing "access" and damage caused
by increasing "mobility".
1.04 Greenspeed is not only familiar with
the reviews that have been carried out into speed, but has also
carried out extensive correspondence with the DfT (and The Commission
for Integrated Transport, IPPR, TRL, T2000 and others). Despite
not having spent any of its £40 million research budget on
the consequences of reducing the national speed limits, the DfT
continue to believe that 70/30 represents the "best balance".
1.05 A Division of the DfT is dedicated
to looking at the feasibility of road pricing to deal with congestion,
and believe that this could incidentally reduce GHGs. There is
no division in the DfT tasked with looking at the effects of lower
speed limits and the effect on GHGs. In fact the Secretary of
State for Transport effectively ruled out road pricing by giving
evidence to the Transport Select Committee in 2005 that it would
be unwise to rely on large computer systems, just the type of
system that would be required to monitor the movements of all
24-30 million cars wherever they happen to be on the road network.
However, since that evidence the Transport Secretary has made
a number of public statements suggesting that road pricing is
the answer to congestion, apparently oblivious to the research
carried out by Imperial College for the Energy Savings Trust that
this could have the effect of increasing GHG emissions.
1.06 Speed is not mentioned in the climate
change consultation paper as either a cause of GHGs and a potential
for GHG saving. Given the already well known advantages of lower
speeds in terms of both congestion and GHGs, the question must
be asked of Government (and the DfT) why this is not in the consultation
together with indications of the potential of speed reductions.
A Government cannot be taken seriously on climate change when
it ignores the measure with perhaps the greatest potential for
reducing GHGs, in the shortest timescale and at the least cost
(not to mention wide-ranging and cumulative benefits). This omission
means that Government will not benefit from comments on speed
management from those involved in the climate change consultation.
1.07 The most important research carried
out in 2005 and published in 19 January 2006 is the VIBAT study
by Bartlett and Halcrow. This shows that behavioural change (including
a 50 mph speed limit) is the key if the transport sector is to
contribute to the to the 60% reduction to GHGs that the Government
require. The point is also made that savings made now reduce the
severity of the changes that would be required later.
1.08 This evidence concentrates on two of
the issues raised by the EAC:
— the targets for CO2
reduction from the transport sector for 2010 and 2020 and,
— the specific steps that can
be taken over the next decade, with reference to low carbon vehicles
and demand management.
1.09 When looking at the transport sector
the Committee should have in mind that all impacts are a function
of volume, mix and speed. In order to effect any significant changes,
one of these fundamental elements must be targeted and there will
be knock-on effects on the remaining two. It is not hard to see
that speed is a factor that is already subject to regulation and
stands out from "volume" and "mix" as being
open to further modification.
2. LOWER SPEED
LIMITS
2.01 The transport system is very complex
and without extremely sophisticated modelling it would not be
sensible to attempt to quantify the level of the GHG reduction
that would result from a national regime change from 70/30 mph
to 55/20 mph. However, by their nature, systems contain and have
the potential for virtuous circles or vicious cycles. This means
that, if changes are introduced that "go with the grain",
they create synergetic (see ODPM paper on EU Directive on Strategic
Environmental Assessment and evidence of Chief Scientist to the
DfT to the Select Committee on road pricing) and cumulative effects.
If lower speeds can be shown to be part of, or even a trigger
for virtuous circles that include GHG reduction, then further
reductions can be achieved without further intervention. Measures
taken to trigger virtuous circles can be very cost effective indeed.
Those taken running against the grain will be wasteful of both
money and time.
2.02 In fact, it is well known that lower
speeds do save GHGs. Because air resistance increases by the square
of the speed, higher speeds can only be maintained with high levels
of both fuel consumption and emissions. (recent research that
shows that the most modern cars may not be significantly less
efficient at higher speeds would only be relevant if there were
no other substantial reasons to lower maximum speeds). It is also
well known that lower speeds reduce congestion and that free-flow
at moderate speeds reduces fuel consumption. Lower speeds also
increase the capacity of both roads and junctions. None of the
existing knowledge about slower speeds is rocket science and yet,
due to the omission from the climate change consultation paper,
Greenspeed may be alone in making the climate change case for
reducing the national speed limits. Similarly, there were very
few references to the role of speed management as an alternative
to road pricing in the 2005 Transport Select Committee proceedings.
2.03 Greenspeed began its campaign when
the Government perversely put a maximum speed limit on buses and
coaches lower than that for cars. Now, by reducing the maximum
speed for cars below that for public transport, the competitive
advantage could be transferred to the bus and train that will
become the preferred means of travel, thereby reducing GHGs still
further, and increasing their profitability without continuous
increase in subsidy. Buses are assisted by the reduced congestion
and car drivers may also design their lives around shorter car
journeys thereby using still less fuel.
2.04 Inappropriate traffic speeds are the
greatest deterrent to walking and cycling. Therefore, the virtuous
circle continues to gain pace with the increase in cycling and
walking when cars are limited to 20 mph in urban areas and GHGs
go down again. When cars are designed for a 55 mph speed limit
instead of a 150 mph (for the German autobahn!?) the weight goes
down and the efficiency at both 55 and 20 mph increases and GHGs
are reduced still further. The labelling system being proposed
for cars show the most efficient cars have the lowest maximum
speeds.
2.05 By reducing speed limits in and between
urban areas, road congestion and its annual cost of £20 billion
will be consigned to history and road pricing (estimated cost
of £20 billion) appropriately labelled as a policy of "roads
for the rich" will become unnecessary after the pointless
wait of 10 years for its introduction. The latest example of road
pricing is the M6 Toll which has proved attractive to drivers
who average 79 mph thereby consuming about 30% more fuel than
if limited to 55 mph. However, if a 55 mph limit had been placed
on the M6, all traffic could travel at that speed with little
of no congestion and no new road may have been required. This
is the intelligent response to the suggestion that the M6 "widening"
is to be extended.
2.06 There will be less noise from engines
and tyres both of which will last longer, so that energy is not
consumed on repairs and replacements.
2.07 The very significant savings to the
emergency services, to the national health service and to families
and communities, by reducing the trauma of road traffic accidents
may not directly reduce GHGs. However, these savings can be borne
in mind when considering the other economic ad political impacts
of lower speeds. It should also be obvious that lowering the national
speed limits could be implemented at negligible cost, as a few
road signs will need to be replaced.
2.08 So, if all this is known without eating
into the DfT research budget of £40 million, what can it
be that prevents the Secretary of State for Transport mentioning
speed reduction in the climate change consultation, and continuing
to present road pricing as the answer to congestion (regardless
of the extra GHG burden? Even with none of the additional benefits,
the immediate saving of GHGs arising from road traffic if national
speed limits were reduced to 55/20 could be in the region of 25%.
In a letter to Greenspeed, Defra's response can be summarised
as, "It's the economy stupid!". If that is the reason
then it would be very interesting to see the figures. Before a
55 mph speed limit could impose a burden on the economy it would
have to exceed the £20 billion wasted through congestion,
the subsidy to underused public transport and the savings to the
emergency and health services. Access, essential to the economy
and well-being, will be improved even if mobility may be reduced.
A reference to the Bartlett/Halcrow VIBAT study shows that lower
speeds (50mph) is essential to a sustainable transport system
and it is only a question of time when this will become inevitable
if CO2 targets are to be met. DfT should be concentrating
on how and not whether to lower the national speed limits.
2.09 The DtT are in denial in respect of
the magnitude of the current contribution of transport to environmental,
social and economic problems that can be attributed to Government
transport policy. This is particularly true of CO2
emissions and the growth in car use. The DfT have no answer to
these issues.
3. CONCLUSIONS
3.01 There should be an inquiry into why
speed management is not flagged in the recent climate change consultation
document as it can be seen to be the measure with the greatest
potential for GHG saving at least cost and in the shortest timescale.
These comments to the Environmental Audit Committee do no more
than set out what is already well known about the unsustainability
of the 70/30 mph regime. An integrated and sustainable transport
system can only evolve when based on 55/20 mph, where the level
of GHGs emitted by fewer, lighter and more efficient vehicles
and well used public transport, walking and cycling, would be
a small fraction of the levels emitted in the car dependent 1990s
and 2000s.
3.02 The EAC should find that the current
DfT policies are not meeting the existing 10 year plan and unless
the conclusions of the VIBAT study commissioned from Bartlett/Halcrow
are taken on board there is no prospect of the emissions targets
being met.
February 2006
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