Road Safety Framework

Written evidence from the Campaign to Protect Rural England (CPRE) (RSF 41)

Summary of Key P oints

· A lmost two-thirds of road dea ths occur on rural roads, while cycling is three times more danger ous on rural than urban roads. Yet the F ramework fails completely to mention rural problems, let alone propose anything to tackle them.

· Setting road safety targets is important to deliver continued improvements overall, even more so where the UK has been less successful, such as the safety of vulnerable r oad u sers , particularly in rural areas.

· International evidence shows that a nationwide ‘Safe Systems Approach’ , including the concept of ‘self-explaining roads’, is the only credible basis for ensuring improved road safety outcomes in the longer term. The UK lacks such an approach.

· Localism has a place so long as there is a clear framework to improve c onsistency and predictability of road s . While such policy exists on the continent, the Government’s Strategic F ramewor k for Road Safety falls well short of achieving this .

· There is a particular need to change practice – in terms of (de-)engineering, enforcement and education – for the lowest tier of roads, whether urban streets or rural lanes. Changing driver expectations and behaviour will be essential too .

· Although there has been welcome progress on 20 mph in built-up areas, s peed limits in rural areas h ave become more haphazard since 2000 and the proposed economic toolkit on speed limits goes further in the wrong direction.

· Significant changes in policy and delivery are now needed to reflect the Framework’s welcome acknowledgement that subjective perceptions of road safety should matter in addition to objective statistics of numbers of people killed or seriously i njured.


1. We welcome the opportunity to submit evidence to the Transport Committee on the Government’s Strategic Framework for Road Safety (‘the Framework’). As a leading environmental charity, the Campaign to Protect Rural England (CPRE) has worked to promote and protect the beauty, tranquillity and diversity of rural England since 1926. Our 2026 Vision for the Countryside, which sets out how we would like to see the countryside in our centenary year, calls for a significant rise in walking and cycling.

2. Thousand s of parish councils are members of CPRE and road safety issues are often at or near the top of their agenda. CPRE has therefore been a leading voice for safer rural roads for decades. Over half of the written responses to A Safer Way , the Department for Transport ( DfT ) 2009 consultation to develop its future road safety strategy, were based on CPRE’s campaign for safer rural roads . Since then we have played a key role in the DfT Traffic Signs Policy Review to reform speed limit and regulatory signage.

3. Road safety is a policy area where there is comprehensive research to draw on as well as strong feelings, such as the perception that some safety measures are part of a ‘war against the motorist’. CPRE is concerned that the Framework takes a short-term view rather than a strategic approach . While the 2009 DfT consultation cited Dutch principles for the Safe Systems A pproach, it did not incorporate them into UK policy. Instead it took a short-term approach of focus ing on the low-hanging fruit. The Framework is ev en more light touch in policy terms and limited in its vision , which is simply to keep up with other countries.

Inquiry Questions

Whether the Government is right not to set road safety targets and whether its outcomes framework is appropriate?

4. The outcomes framework is a good step forward but a few headline targets are still needed to set the level of ambition. Such targets should not be seen as ‘central persuasion’, as the Framework puts it, but providing national leadership to drive ambition . Similarly a broader vision is needed in the Framework than ‘keeping up with the neighbours’ (paragraph 1.28). As stated in our 2009 consultation response [1] , we would like the headline vision to focus specifically on where Britain has been least successful compared to other countries: making people feel and be the safest in the world when choosing active modes of travel.

5. We strongly support the proposed indicator to measure whether people walking and cycling feel safe, which was one of our main asks in our campaign in 2009. Our Rural Traffic Fear Survey in 1999 showed that two-thirds of people do not feel safe some or all of the time walking, cycling or riding on rural roads.

6. Although this indicator of perceptions will be somewhat subjective, it is not only crucial that its definition is developed quickly and that the new approach is integrated in other policy areas. While the draft National Planning Policy Framework, for example, covered ‘crime and fear of crime’ (paragraphs 116 and 125), in relation to road safety it only called for ‘safe and secure layouts’ (paragraph 89), thereby missing out perceptions. The DfT should work with the Home Office to develop guidance and best practice as to how the indicator could, if identified as a local priority, be best incorporated into the work of local Crime & Disorder Partnerships.

7. Failing to have sufficient sub-groups in data can mask important factors and trends. As A Safer Way highlighted, almost two-thirds of road deaths occur on rural roads. Although minor collisions involving cyclists are more common in urban areas, half of all cycling deaths occur on rural roads because the risk of a fatal collision is three times higher than for cycling on urban roads [2] . In this context we would welcome a separation of all casualties by urban and rural roads. Furthermore although there is limited availability of precise cycling data, it would be better to change the cycling fatality rate indicator to be based on distance cycled to be consistent with the other indicators.

8. The data on collisions with excessive speed as a contributory factor comes from STATS19 reports from officers at the scene of incidents. Particularly on minor rural roads where the default National Speed Limit of 60 mph - higher than many drivers can manage - there may be a tendency for this factor to be under-recorded. More objective standards should be used.

9. There is a great need for more open data and transparency within road safety. D espite the high level of community concerns about road tr affic offences , such as speeding, this data has not been integrated within police crime maps. CPRE believes it should be, s imilarly STATS19 collision data should be improved and published in an ope n format on-line to improve transparency.

10. As part of the DfT Traffic Signs Policy Review, CPRE called for Traffic Regulation Orders, which cover matters such as speed limits and access restrictions, to be published in an open format on-line. We were disappointed that this suggestion was not accepted. Not only would it be of great benefit to drivers, as SatNavs could show speed limits and appropriate routes, but also it could make comparison of progress between highway authorities on the implementation of 20 mph in built-up areas and 40 mph on minor rural roads.

How the decentralisation to local authorities of funding and the setting of priorities will work in practice and contribute towards fulfilling the Government’s vision?

11. While CPRE supports the principle of localism, we are concerned that to avoid the wrong type of localism, where the centre abdicates responsibility for co-ordinating key policy and securing sufficient funding rather than providing the necessary conditions within which local communities can flourish.

12. Predictability and consistency are particularly important in relation to the types of road that make up the road network and speed limits. Clearly, as road users’ journeys do not fit neatly within local authority boundaries, there needs to be co-ordination between authorities. This is where the Framework is, however, at its weakest (paragraph 4) in that it does not propose the national co-ordination and engineering that are so needed.

13. Although the Netherlands has experienced significant decentralisation since the 1980s, the clear vision and set of principles in its Sustainable Safety policy [3] have supported local initiative within a clear national framework for road design and engineering. Although Dutch policy stresses the need for roads to be classed within different types [4] that have ‘Essential Recognisability Criteria’, this has resulted in more innovation and less clutter, particularly for the lowest tier of roads. The concept of shared space, for example, was first developed in the Dutch province of Friesland and has now spread widely.

14. CPRE has long campaigned for a rural road hierarchy along these lines and secured a change to the Transport Act 2000 to require a review of what changes would be needed to introduce one. Section 269 of that Act defines a rural road hierarchy as: 'a system under which rural roads are categorised by a local traffic authority (by reference to the ways in which they are used) for the purpose of subjecting different categories of rural roads to different speed limits.' Despite the review finding that ‘[t]he current speed limit system results in a great deal of confusion for motorists’, no further action was taken. We believe the time has come for renewed national action in this regard.

15. The lack of any mention of rural roads or rural road safety problems is a noticeable omission in the Framework, given the lack of safety on them [5] . The DfT has recently published research on four ru ral road demonstration projects it commissioned [6] . Although there were some interesting innovations, there is not the funding to repeat similar projects individually across the country and measures to tackle the unsuitability of the 60 mph National Speed Limit on minor rural roads could not be progressed. This is not a new problem: in New Directions in Speed Management (2001) the then Department for the Environment, Transport and the Regions stated that: 'The one aspect of the national speed limit system that comes in for most criticism is the notion that 60 mph is a reasonable maximum speed on country lanes.'

16. Clearly it will often be much more cost effective to have a single national campaign, rather than many local ones individually commissioned. It is not just about cost as local campaigns in rural authorities are unlikely to reach the drivers in urban areas that may make occasional use of rural roads. Similarly if we are to have ‘self-explaining roads’, which ensure drivers are better informed about the function of a roads and the driving style necessary for safe use of it, there needs to be national guidance and consistency rather than each local authority doing its own thing.

17. Previous research for the DfT highlighted how ‘many drivers’ perception and use of [minor rural] roads is inconsistent with their design and their usage by more vulnerable road users’. It called a fundamentally different approach to engineering for minor roads and extensive publicity, saying that ‘[c]hanges of this substance can only be made with strong national political support, with national investment and publicity programmes supporting implementation by local authorities’ [7] .

Whether the Government is right to argue that, for the most part, the right legislative framework for road safety is in place, and, in particular, whether the Road Safety Act 2006 has fulfilled its objectives?

18. It is too early to judge conclusively the impact of the Road Safety Act 2006 (‘the Act’), as key changes to offences only came into force in 2008 and there has not yet been significant consideration of a range of cases relating to them in the appellate courts. The changes should be reviewed by 2013 to allow new legislation to come into force by the end of this Parliament.

19. We have serious concerns about the subjective nature of the tests for careless and dangerous driving. The current labelling of driving errors that are frequently lethal as ‘careless’ as opposed than ‘dangerous’ does not make sense and can be offensive to those affected. Rather than the current, quasi-subjective test based on falling below or far below the standard of a competent and careful driver - leading to the assessors of fact thinking 'there but for the grace of God I go' - we would rather see an objective negligence based test. This could distinguish between driving faults and serious or dangerous faults on the same basis as the driving test. Such an objective test would be fairer to vulnerable road users, particularly in rural areas where drivers often fail to anticipate their presence.

20. We strongly support the proposed Fixed Penalty Notice for Careless and Inconsiderate Driving, which could start to tackle some lower level bad driving, such as failing to pass vulnerable road users on country lanes with sufficient space. Given the financial pressures on the police and justice system, any delay to the timetable to bring this in during 2012 would be likely to lead to a near total absence of enforcement of these offences.

21. Civil law principles in England for compensation for personal injuries caused by road traffic incidents for vulnerable road users were untouched by the Act and comparative research has shown the approach is one of the least favourable to vulnerable road users in Europe [8] . The Government has recently indicated to the Committee that it does not favour any change, as any shift to the burden of proof has ‘the potential to force an innocent motorist to pay compensation (albeit through insurance) in a case where there is a lack of, or inconclusive, evidence’ [9] .

22. The law on the other side of the Channel has progressed, leaving English law even more unjust in comparison. Recent revisions [10] to the French Highway Code introduced ‘the principle of prudence by the best-protected user towards the most vulnerable user’ [11] and new types of traffic zones, including ‘zones de recontre’, literally meeting zones. These are broader in use than the UK’s Home Zones as they can be used in the centres of towns and villages not just residential streets. In France, as in the Netherlands, predictability and consistency are crucial: ‘[a]s each zone is identified in the same way across France, it is easier for users to adapt their behaviour’.

23. Besides having a coherent national framework of road types , the continental approach involves a more equitable legal and moral vision of the rights and responsibilities of differe nt road users in shared spaces. The Government’s reliance on the concept of innocence conceals a belief that streets are naturally drivers’ space and ignores the fundamental imbalance between road users that are protected in vehicles and those that are not. If the new indicator of perceptions of road safety is to show progress, we will need to address these issues in this country too . It is in shared spaces, whether settlement centres or country lanes, where people particularly want to feel safe walking and cycling and where driver behaviour needs to change in order to achieve this .

24. CPRE proposed research into how the UK could learn from continental best practice as part of the DfT’s Traffic Signs Policy Review. Although a specification for a research project was drawn up, it was not authorised and instead a new informatory sign [12] for shared space was created at the last minute. We continue to believe that significant changes to policy are needed.

Whether the measures set out in the action plan are workable and sufficient

25. As highlighted above the F ramework fails to provide the necessary policy framework for speed limits and road design. Instead it proposes a new economic toolkit for speed limit setting, which is currently being researched by consultants. CPRE believes such an approach to be fundamentally misguided.

26. Cost benefit analysis does have a part to play in developing a national system of speed limits and informing local decisions about prioritisation. There are, however, significant limits to monetising impacts , as was acknowledged in the DfT’s April 2011 refresh of its guidance on Transport Business Cases . This is not just because some impacts cannot be easily monetised, such as the impact on communities of severance by speeding traffic [13] or the value of protecting areas of tranquillity in the countryside. In addition there is something morally suspect about pretend ing that road users lives can be traded off against time savings for drivers as easily as figures can be inserted into a spreadsheet template .

27. The problems become even greater if, as seems to be suggested, that highway authorities should work out speed limits through a n economic toolkit. This could lead to widely varying speed limits along roads that are confusing to drivers and that clutter up the countryside. It would also make it harder to reduce speed limits to improve people’s perceptions of road safety, something that cannot be easily monetised.

28. Economic benefits from transport schemes that increase rates of physically active travel can lead to very high Benefit Cost Ratios due to the reduction in obesity . T o be effective in doing so, lowering speed limits on minor roads needs to be combined as part of a wider package of measures, such as promotion of cycling and creating new routes along and across busy roads. This makes it very hard to disaggregate the benefits of lowering speed limits into economic values.

29. The Framework refers to managing the strategic road infrastructure but proposes nothing to reduce conflict between non-moto rised users and motor vehicles. Other countries have invested significantly to provide routes along main roads, yet there are still many instances where footpaths cross dual carriageways at surface level or people are expected to cycle sharing a road where drivers are travelling at 70 mph and then cross slip roads. The Government should take the lead in the forthcoming National Networks National Policy Statement to plan for safe segregation of users on trunk roads and identify funding for this from existing Highways Agency budgets.

30. Research in 2006 [14] revealed that 22% of rural A and B class roads might warrant a 60mph limit and 78% a 50mph limit, while 33% of C and unclassified roads might warrant a 50mph limit and 67% a 40mph limit. The default speed limit for rural single carriageways – in other words the speed limit that does not need repeater signs – should be the most common one. It would therefore be cheaper and simpler to make 50 mph the National Speed Limit and give highway authorities discretion to sign their safest roads at 60 mph. More leadership is needed to introduce new rural 40 mph zones [15] .

The relationship between the Government’s strategy and EU road safety initiatives

31. We are very concerned about the introduction of Daytime Running Lights. Not only will this introduce greater risks to Vulnerable Road Us ers, who will be less conspicuous compared to motor vehicles, and increase carbon emissio n s , it will increase visual intrusion in the countryside.


· Ambitious headline targets are important for continued improvements in road safety and so should be re-adopted .

· Targets s hould be accompanied by a broader vision and more open data to improve local authority accountability and performance.

· T ackling poor perceptions of road safety should become the key road safety p riority for the next decade. It should be integrate d in other policy areas besides road safety , such as planning.

· The Government should develop new guidance to make road types and speed limits more predictable and consistent for all road users as part of a road hierarchy. Work on the economic toolkit on speed limits should be ended.

· Strategic action and funding is needed to provide safe routes for walking and cycling across and along main roads , particularly in rural areas .

· The National Speed Limit should be set at 50 mph for rural single carriageways with highway authorities permitted to sign their safest roads at 60 mph. The Government should show more leadership and provide new funding and guidance to help authorities introduce 40 mph zones on networks of minor rural roads.

· New research is needed to learn from continental best practice on lower tier roads, in particular in relation to signage and driver liability.

· A new national campaign to change driver perceptions and behaviour on minor rural roads should be launched.


October 2011

[1] Available at:

[2] Page 77 in DfT, Road Safety Strategy Beyond 2010: A Scoping Study - Road Safety Research Report (RSRR) 105 , 2009

[3] Paragraph in RSRR 105

[4] SWOV, Factsheet, Background of the Five Sustainable Safety Principles , 2010

[4] SWOV, Factsheet – Recognisable Road Design , 2010


[5] Similarly the Manual for Streets 2 (CIHT, 2011) did not cover rural roads in detail.

[6] DfT, Taking on the Rural Road Safety Challenge , 2011

[7] Pages 19-20 in D A Lynam, Rural Road Safety – policy options - PPR 200, TRL, 2007

[8] Groutel, The Compensation of 'Vulnerable' Road-accident Victims , Academy of European Law , Trier , 2001

[9] The cost of motor insurance: Government Response to the Committee's 4th Report of Session 2010-12

[10] Decree 2008-754 of 30 July 2008

[11] CERTU, The “code de la rue” (street use code) programme in France , 2008

[12] Unlike regulatory signs, informatory signs do not change the legal position of road users. For more information see CPRE’s Traffic Signs Policy Thinkpiece (2009) at

[13] The monetisation of severance was abandoned in the following report: DfT, Understanding Community Severance II: Monetisation of Severance Impacts , 2006

[14] Sections 4.2 to 4.5 in Lynam, Hill & Barker, Developing a speed management assessment for rural single carriageway roads , TRL Published Project Report PPR 025, 2004

[15] There is just a brief mention of these in p aragraph 7.31 in DfT, Signing the way , 2011

Prepared 28th November 2011