Transport CommitteeWritten evidence from Core Cities

1. Introduction

1.1 In 2009, following consultation on “A Safer Way” when concerns were expressed that the Road Safety Delivery Board was not receiving comprehensive input and advice from metropolitan areas in particular, the Core Cities Safer Roads Steering Group (CCSRSG) was reconvened. CCSRSG is an officer group of safer roads practitioners from the core cities linking with officers from the Department for Transport. Core cities have continued to offer valuable contributions about the issues as they are affected by, and as they affect urban areas and conurbations.

1.2 Core Cities were represented at one of the Stakeholder seminars in December 2010, organised by PACTS on behalf of DfT to inform the preparation and release of the Strategic Framework for Road Safety (SFRS). One of our concerns is that our input to the seminar was not accurately reflected in the conclusions issued by PACTS in March 2011, leading us to question whether the needs and aspirations of local authorities and their communities have been fully appreciated and addressed in SFRS.

1.3 This document responds to the Call for Evidence issued by the House of Commons Transport Select Committee on 13 September 2011 for their inquiry into the SFRS. It is a safer roads practitioner overview presented by the Acting Chair of Core Cities and should not be taken to be representative of the Steering Group or of the constituent bodies. Transport for London will be making an individual submission and has asked to be excluded from the views expressed in this document.

2. Detailed Response

2.1 In response to the issues as annotated in the Select Committee announcement.

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

2.2 The SFRS acknowledges the need to bring a more systems-based approach to road safety combining this with that which has been applied relatively successfully in the public health domain.

2.3 We strongly support this methodology but cannot see why this should not include and be improved by targets. The rationale given in paragraph 1.21 of SFRS is that:

(a)Further central persuasion should not be needed to highlight the importance of road safety.

(b)It is not easy to determine a decade or more in advance the levels of intervention needed to meet a target.

2.4 We are not persuaded by this. The SFRS sets clear aims and projections/forecasts with numbers attached to both 2020 and 2030 and we have extensive historical experience of assessing and implementing interventions that produce longer term future benefits. Indeed the absence of national targets could be interpreted as the Government wishing to distance itself from setting target reductions and accepting responsibility, in favour of holding local highway authorities to account.

2.5 We firmly believe that targets focus and prioritise investment and activity and are essential to help measure progress. They allow us to gain support from other agencies, representative bodies and individuals that benefit from safer communities. We generally set them within our Local Transport Plans and, in some metropolitan areas, the Police and Fire Service have targets based on Killed and Seriously Injured casualties within their own operational plans.

2.6 This belief is supported by evidence and history. The “Child KSI” target, set in 2000 in “Tomorrow’s Roads—Safer for Everyone”, was seen as challenging but, because it set a priority and focus, it enabled all to concentrate on activity aimed at achieving it, which was done without undue detriment elsewhere. The “further central persuasion…” argument was not needed then and is felt to be irrelevant now. Much remains to be done however and the absence, in particular, of a “Children and Young People’s” target in SFRS is a serious omission that is likely to impact on metropolitan areas.

2.7 The Outcomes Framework (OF) is useful in setting an agenda or menu and the approach is welcome. However we feel that the key issues have been overlooked because local conditions and circumstances that lead to road crashes and injury are not recognised. Our view is that the OF should be an indicator that measures progress and identifies areas (geographic or social or demographic) where Government and local authorities need to work more closely, to address together particular issues such as inequality, deprivation and safer communities. Given the focus on local accountability along with several references to the effects of deprivation, we feel that the Government should consider resident risk among the measure of “performance”.

2.8 This weakness in the OF is highlighted by statements in paragraph 1.27 “to reduce death and serious injury on our roads” and in B1 “decreasing the number of fatalities and seriously injured casualties”. It cannot be denied that reducing KSIs is very important but road safety and safer roads is much more than this. We should all be working to lower risk and danger, reducing all injuries and distress and making our communities safer. The SFRS undermines this by its over-emphasis on KSI.

2.9 The casualty forecasts in SFRS are based fundamentally on the continuing performance of local authorities. Indeed, information about “performance” is to be published to “help citizens challenge their local area on road safety” (see paragraph 3.6). Whilst we are not concerned or challenged by comparisons, we have consistently made the point that “performance” at a local level is a function of both Government and local authorities (and many other stakeholders and people in local communities). There are significant factors outside the control of local authorities. For example, many areas of deprivation have seen increases in the rates of unemployment in the last 12 months or so well above national or regional trends thus adding to inequality and road safety risk. Government needs to recognise the areas with the greatest challenges and to provide the necessary leadership and support. In the spirit of true partnership working it would be better if we could report, together, the progress we are making to achieve our joint aims.

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

2.10 We welcome the principle of decentralisation of funding and recognise the constraints and challenges set out in the Comprehensive Spending Review 2010. However, loss of the capital elements of the Road Safety Grant and the sub-summation of the revenue element into the Local Government Formula Grant settlement via the department of Communities and Local Government has impacted severely on resources available in the road safety field, given the funding challenges faced by other services delivered by local authorities. As authorities are left to choose between core services, future funding streams cannot be guaranteed. There are also difficult decisions to be made where the strategic needs for transport have to be considered against local needs for safer roads and how we approach the provisions of the Localism Bill/Act.

2.11 Notwithstanding, the quantum of funding and other resources available has been much reduced and it is irresponsible to pretend that this will not impact on priorities or the Government’s vision for road safety. It is not clear how Britain will remain “a world leader on road safety” (see paragraph 15, Executive Summary) if adequate resources are not sustained in this field. We look to the Government to play its part in assisting delivery of this “Governmental priority” (See paragraph 1.2). Power can be decentralised but overall responsibility cannot be abdicated.

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 (see Post-Legislative Assessment of the Road Safety Act 2006, Cm 8141, published by the DfT, July 2011)

2.12 We support the provisions of the Road Safety Act 2006 and consider that the promotion of road safety should remain a statutory duty on local highway authorities. The provisions in Section 39 of the Road Traffic Act 1988 set out that local authorities must carry out accident studies and take measures to prevent such accidents, including the dissemination of information and advice, practical training to road users and “engineering” type activity. We believe this would be helped by strengthening links with legislation relating to duty of care and with public and community health. We also feel that the importance of road traffic law enforcement should be emphasised.

2.13 There are other areas of legislation that directly relate to road traffic behaviour and road safety that have yet to be fully enacted. The enforcement of moving traffic offences for local authorities outside of London as contained in the Traffic Management Act 2004, is considered to be very important to improve driver behaviour, reduce risk and danger and to encourage overall compliance with regulations that benefit society overall.

2.14 Funding inevitably is, and will remain, an issue. The SFRS champions the importance of delivery and performance at the local level. With both these in mind, it is our view that penalties from the majority of road traffic offences could be allocated to the local administration in order that local authorities, the Police and Safer Roads Partnerships can adequately identify and deal with the prevailing local problems of lawlessness.

2.15 We welcome the intention to improve initial training for learner drivers and riders, develop a new post-test vocational training course and include safety messages in the theory test. We are unsure however whether some or all of these will require changes in legislation. We particularly support the provisions for driver re-training courses as a positive way to engage with offenders.

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

2.16 We understand and appreciate the Government’s “hands off”, non-prescriptive approach but the SFRS Action Plan is scant when compared to previous national strategies. It does not acknowledge the scale of the efforts that will be needed to be made and coordinated nationally and locally to continue to reduce road crashes and injuries, which, in turn, will regenerate our communities. There is an opportunity to review the Action Plan in consultation with partners and stakeholders.

2.17 We would like to continue to emphasise the point we have made previously that the provision of local information via the website perpetuates a focus on “location” rather than “cause” of collisions which could be particularly misleading.

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

2.18 The European Commission (and indeed the World Health Organisation’s “Decade for Action on Road Safety”) has recommended a coherent and integrated approach to road safety that takes into account synergies with other policy goals.

2.19 Government consultation on road safety matters was relatively narrowly-based and did not have full regard to the wider policy objectives that sustain and improve communities and contribute to better future for all our citizens. We do not clearly see how SFRS is integrated nationally or at local levels.

2.20 It remains a DfT document with the DfT logo despite comments at the aforementioned seminar(s) that it could be “badged” as a Government strategy. The Home Office, Ministry of Justice, Department of Health, Department for Education, Department for Environment and Climate Change and Department for Communities and Local Government all have ties to road safety that enable common issues such as inequality and deprivation to be tackled collectively.

3. Summary

3.1 SFRS is a start but could be considerably improved to form the basis for partnership working and engagement involving national and local government, associated agencies and local communities. It tends to give the impression that it is transferring responsibility and accountability from Government to local authorities without acknowledging the necessary support for local authorities to meet those responsibilities. As such in its current form it could generate conflict rather than fostering partnerships that would give significant local and national benefits for road safety and society overall.

3.2 With its emphasis on KSIs, the location of casualties rather than the causes of crashes and “performance”, it misses an opportunity to support the need to change towards a systematic identification of the specific causes and high risks and to resource actions that are most likely to address these, thereby preventing injuries in the years ahead.

3.3 We feel the SFRS is in many ways a retrograde step particularly for local authorities who have made a very considerable contribution to the reductions in road deaths and injuries we have seen in the last 10 years.

October 2011

Prepared 18th July 2012