Transport CommitteeWritten evidence from the RAC Foundation

1. Summary

1.1 The Strategic Framework for Road Safety has a long-term vision of ensuring that Britain remains a world leader in road safety. It commits the Government to ensuring that the existing downward casualty trend is maintained and that the high risk experienced by some groups such as cyclists and children in deprived areas is reduced more quickly. This vision for road safety is appropriate and one which the RAC Foundation can support, but the Foundation does not necessarily agree with the way in which the Government intends to realise this vision.

1.2 The RAC Foundation is a charity which explores the economic, mobility, safety and environmental issues relating to roads and responsible road users. Independent and authoritative research, carried out for the public benefit, is central to the Foundation’s activities.

1.3 The key issues of concern are:

Over 20 years the present road safety regime, with considered, clear and stretching targets has proved itself to be politically robust and successful in making Britain’s roads some of the safest in the world and so should not be discarded lightly.

Pressure on local government finance are such that, in the absence of clear incentives there is a real danger that road safety programmes will be run down and the considerable achievements of recent years reversed.

Whilst the Framework’s proposals are workable they suffer from a number of weaknesses—for example insufficient attention to making road infrastructure more “forgiving” when accidents occur—which means the full potential for reducing deaths and injuries is may not be exploited.

2. Road Safety Targets and the Outcomes Framework

2.1 There are no formal targets included in the Road Safety Framework as the Government states that it does not believe central persuasion is needed to deliver road safety improvements. It is their expectation that both central and local government will continue prioritising road safety in any case. The framework suggests that Central Government should be judged by actions committed in the road safety action plan (up until 2015) and the road safety outcomes framework, which provides a list of indicators which can be used at the local or national level. Some projections of potential improvements by 2020 and 2030 are included in the strategy, but it is explicitly stated that these are illustrative of what can be achieved rather than hard projections or targets.

2.2 It is important that the road safety strategy for the UK is set over a relevant period of time. Given the challenges and potential solutions which could help in this area, a vital one being vehicle technology, the RAC Foundation doesn’t believe the road safety framework as it stands, goes far enough. A longer term strategy is needed, with nearer sighted reviews and targets for the five and ten year horizon. This is missing within the existing framework.

2.3 Without any formal performance framework for road safety to operate within there is also a danger, especially given how well the UK has been doing with casualty reduction, that resources will not be prioritised to deliver further road safety improvements. Without a national target or imperative for road safety in particular, the level of improvement achieved over previous years may not be replicated in future. The approach developed in the field of road safety over the last two decades is well understood, uncontroversial and has been very effective. There are few other areas of transport policy where there has been such success and given that the framework represents a significant departure from previous thinking this does provide cause for concern.

2.4 To establish the role and importance of targets in any given situation it is necessary to look had how other countries and sectors are making use of targets to improve policy outcomes. In the UK heath sector there is some evidence that targets have created a set of unintended consequences—for example, distortion of priorities or neglect of other non-targeted activities (Kings Fund, 2010) although enforced targets do appear to have been successful in improving some aspects of NHS performance, particularly in relation to waiting times. The untended consequences created by some targets have understandably provided targets per se with a bad reputation and as a consequence they have largely fallen out of favour politically. Road safety as a sector has however benefited significantly over the years from a target led approach, which has been led by both Labour and Conservative Governments. The first road safety targets were set in the 1987 publication “Road Safety: the next steps” which sought to achieve a one-third reduction in casualties by 2000 based on the 1981–85 baseline. This target was supported by the profession and achieved, with a 40% reduction in road deaths and a 45% reduction in serious injuries experienced over this time. This was followed in 2000 by “Tomorrow’s Roads—Safer for everyone” where three targets were proposed against the 1994–1998 baseline (The level of reduction actually achieved in 2010 is detailed in brackets below—DfT, 2011):

To cut death and serious injury (KSI) by 40% by 2010 (49% reduction in KSI 2010).

To cut child KSI by 50% by 2010 (64% reduction by 2010).

To reduce slight injuries by 10% by 2010 (32% reduction by 2010).

2.5 In 2009, the previous Government consulted on a third round of casualty reduction targets in “A Safer Way: A Consultation on Making Britain’s Roads the Safest in the World” (DfT, 2009). The proposed targets were a further reduction of at least one third in KSI by 2020 and of 50% in child KSI over the same period. In all of the three target setting processes that have taken place over the past 25 years achieving professional “buy in” for the process alongside having the right scientific basis for setting targets has been crucial.

2.6 The value and importance of setting targets to achieve casualty reduction is well known and advocated throughout Europe. A report from the OECD in 2002, Safety on the Road: What’s the Vision? recognised the value of setting targets to improve road safety performance and some subsequent research (Wong et al 2006, IN: OECD/ITF, 2008) suggests that countries with quantitative targets perform better than countries without targets. A meta-analysis indicated that overall, countries with targets had 17% lower fatalities than the countries without targets (OECD/ITF, 2008). The OECD’s most recent report on target setting in road safety finds that:

“Targets that are based on a comprehensive road safety vision communicate the importance of road safety, motivate stakeholders to act and help hold managers of the road transport system accountable for achieving defined results. Targets indicate that the government is committed to reducing the road toll and is likely to support proposed policy and legislative changes and allocate sufficient resources to safety programmes. Target setting is recommended as useful for all countries attempting to reduce the road toll” (OECD/ITF, 2008).

2.7 The European Commission’s recent policy for road safety advocates halving the overall number of road deaths in the European Union by 2020 (European Commission, 2010). Member states are being encouraged to contribute, through their national road safety strategies, to the achievement of this common objective and it is disappointing that the UK Government has not recognised the role of targets in improving road safety.

2.8 The outcomes framework provided in Annex B of the Strategic Framework provides a good overall basis for monitoring road safety performance. The RAC Foundation’s specific concern about each of the high level indicators is provided in Annex A of this submission. Given that the Government is committed to monitoring these indicators at both a national and local level, for all the reasons already stated it is a missed opportunity not to have targets associated with these indicators to help encourage progress.

3. The Role of Decentralisation

3.1 The strategic framework emphasises the importance of localism to the coalition Government as a whole and the road safety strategy in particular. In the Foreword the Secretary of State states that the framework aims to provide the freedom for local decisions to be made that best suit local communities and the document clearly provides the message that whilst central Government believes road safety to be an important issue, initiatives need to be set in the local context and delivered within resource constraints.

3.2 It is positive that National Government has reaffirmed their commitment to road safety and will endeavour to provide the tools needed at a local level, but the lack of financial resources and guiding framework for implementation of road safety at this level is a concern. The Strategic Framework essentially sets out National Government’s action plan and priorities for a non-specific period of time (latest deadline included is 2015). Whilst the document provides some general strategic pointers for local level decisions, such as emphasising the importance of targeting at risk groups through education and enforcement, there is no real basis upon which local authorities can build. There are also a number of gaps in the analysis, which does not provide local authorities with a full picture on areas of activity which would provide a useful focus. Safer vehicles and road infrastructure are two such issues which require Central Government focus, but have only received a small mention in the strategy itself.

3.3 The framework recognises the difference between high and low performing authorities and concludes that deaths could reduce by 57% to around 1,200 by 2030 if the performance of the worst local authorities catch up with the best. Providing information on comparative performance at the local level, as suggested within the framework, will play a useful part in helping local authorities achieve the highest possible standard, but it is also vital that the supporting tools and best practice resources are made available at the local level to help improve skills and performance, whilst reducing any duplication of effort.

3.4 The decision taken in the 2010 emergency budget to decentralise road safety funding has had a significant impact on road safety practice (See: RAC Foundation and PACTS 2010 and 2011 reports on “Tackling the Deficit”) and there have been difficulties with identifying other sources of funding at the local level with which to carry out road safety activities. Looking to the future it is still likely to be difficult for road safety initiatives to compete against other local authority resource needs, which further emphasises the need for tools which can help road safety officers make the business case for funding.

4. The Legislative Framework

4.1 The 1988 Road Traffic Act, Section 39, puts a Statutory Duty on local authorities to undertake studies into road accidents, and to take steps both to reduce and prevent accidents, so it will not be possible for local authorities to cease all activity in the road safety field. However the 1988 Act was cast in a clear context of a high national priority for road safety improvements expressed through clear targets. The combination of these two actions have provided the foundation for the substantial improvements in road safety subsequently. The removal of targets means that, in a time of severely restricted public expenditure, other incentives to restore and retain a high priority for local road safety programmes are needed. This could be by modifying the 1988 Act to give more specific duties to local authorities, or adapting the mechanism for funding local authorities to ensure that road safety gets the priority it deserves.

5. Strategic Framework for Road Safety Action Plan

5.1 National Government’s stated role is to provide leadership in road safety, deliver better driving standards and testing, enforcement, education whilst managing the strategic road infrastructure. These roles are to be supported by research and research collation along with the provision of public information to support local delivery. This provides a clear mandate and a reasonably complete list for the areas of National Government responsibility. What is missing is a clearer directive on strategy at the local level, which may well hinder the delivery of road safety in the local authority setting. The measures set out in the road safety action plan are, given their practical and short term focus, workable by definition. The RAC Foundation however remains unconvinced that these measures will be sufficient to address the multitude of challenges faced by road safety in the longer term.

5.2 The Governments attention on enforcement in the Strategic Framework is welcome, although without adequate resources being devoted to this activity there is a risk that the benefits of the strategy will not be realised. As police resources are under significant pressure with numerous competing demands, it is not possible to know to what extent the aims of the strategy will be carried forward. Given that enforcement is one of two key planks of the National strategy this is cause for concern.

5.3 The focus on tackling “high end” offenders is a welcome approach which was started by the previous Government. It is wise, from a public perception perspective, that a wider focus on “anti-social” driving behaviour is taken, but it will still remain important for speed related issues to be addressed fully. It is also positive to see that the Government intends to undertake a speed review to provide advice and guidance to local authorities on how best to set limits in a consistent manner. Increasing penalty charge notices to bring them in line with other similar penalties is a development that the Foundation supports, whereas the benefits of introducing fixed penalty notices for careless driving is less clear cut. This move appears to have been well received by many sections of the road safety community, but there are unresolved issues surrounding how “careless driving” should be defined and appealed. Having the appropriate resources to enforce against this type of behaviour is also another consideration. Mobile phone use and seatbelt penalty charges are a case in point where it has been difficult for Police officers to enforce this activity with limited resources.

5.4 The action proposed against drink and drug drivers are positive developments, but the drink driving plans do not go far enough. For drink driving, closing the loop holes that exist and making it easier for police officers to convict at the scene will help, but the government’s decision not to reduce the BAC limit from 80mg/100ml to the common European level of 50mg/100ml is a missed opportunity. The intention of working towards making drug driving as socially unacceptable as drink driving and increasing the likelihood of detection is an important development and whilst focusing on and targeting high risk offenders is cost effective approach, but there are questions left unanswered about what effect this approach will have on the attitudes of the law abiding majority over time.

5.5 The Government’s approach to road safety education in the Framework represents a positive development. The coalition’s decision to go “with the grain of human behaviour” is a less confrontational approach than taken by previous administrations and may well help secure greater public support for the issues that need to be addressed. However a coherent approach to lifelong learning is currently missing, as based on the current programme of activity the only educational intervention drivers will experience will be a remedial education course they are sent on as a result of minor offences. Given the practical level of detection possible for these types of minor offences this will leave a significant number of people who would benefit from courses without access. Older drivers are only mentioned briefly in the strategy, with a commitment to work with voluntary groups to develop appropriate education programmes. This development might be helpful, but on its own it is unlikely to address the significant and growing older driver issue and the programmes delivered may not be robustly developed and effective.

5.6 Vehicle technology is are touched on within the framework, but the emerging challenges such as weight differentials, in-car distractions and older female drivers are only discussed in brief. The intention to work with vehicle manufacturers collaboratively on research is a positive, business orientated step, but there are many other organisation in both the public, private and third sector that Government should look to engage with on this issue.

5.7 The framework gives some space to the importance of road engineering improvements as it notes the relevance of combining a systems approach (recognising that people make mistakes and build systems to recognise this). The strategy also stresses the importance of taking a public health perspective (prevention, based on science and collaborative in nature) to road safety. The framework notes the high value for money returns which can be secured through road safety interventions on the strategic road network, but no indication is given of how safer roads can and should be developed at a local level and it is not clear whether the intention is for the Highways Agency to act as a “beacon” of good practice, or whether the toolkits due to be provided to local authorities will help appropriate local road improvements be developed. A recent report by the RAC Foundation and the Road Safety Foundation found that 6,000 lives could be saved on Britain’s roads over the next 10 years if just a fraction of the money currently spent on road maintenance was used more effectively for road safety engineering improvement (RAC Foundation and Road Safety Foundation, 2011). This is an important area that deserves greater attention.

5.8 There are also a number of problems recognised by the framework where specific plans of action are not forthcoming. For instance younger drivers are described as an at risk group, but beyond formal driving education improvements there was no specific plan mentioned to address this concern. The higher rates of accidents of motorcycles and bicycles are also mentioned, but again there is nothing contained in the document about how to address this issue, beyond a commitment to working on improving the situation. There is a commitment to carry on the THINK! campaigns targeted specifically at young drivers, motorcyclists and child pedestrians, which is a positive development, but unlikely to be enough on its own do address the road safety issues experienced by these groups.

5.9 The framework document lists past trends and the factors that have contributed to the considerable reduction in deaths, including safer vehicles, road engineering and reductions in speeding. Despite these past successes, these a subjects are only mentioned in passing as actions to be taken forward, and we would suggest that the Government revisit what part these interventions play.

6. EU Road Safety Initiatives and their Relationship With Government Strategy

6.1 The Framework mentions in passing the strategic framework’s linkages with activity in Europe, but the Foundation believes that this could be made stronger. The strategy recognises the importance of negotiating and agreeing International standards at a national level and the continuing role of programmes such as EuroNCAP. There is an apparent willingness to be involved in the International Programmes such as the UN Decade of Action for Road Safety 2011–2020, but the strategic framework clearly takes a different approach to the target setting and safe systems approach advocated in many other European countries. Great Britain has a significant amount to learn from other top performing countries in Europe and the Foundation would like to see the Government engage more readily in this area.

References

Baster, N. (2011) Tackling the Deficit: Where next for road safety?

Beasley, E. (2010) Tackling the Deficit: At what cost to road safety?

DfT (2009) A Safer Way: A Consultation on Making Britain’s Roads the Safest in the World.

DfT (2011) Reported Road Casualties in Great Britain: 2010 Annual Report
http://www.dft.gov.uk/statistics/releases/road-accidents-and-safety-annual-report-2010

European Commission (2010) Towards a European road safety area: policy orientations on road safety 2011–2020
www.ec.europa.eu/transport/road_safety/pdf/com_20072010_en.pdf

Kings Fund (2010) Have targets improved NHS performance? A factsheet for the 2010 election
http://www.kingsfund.org.uk/current_projects/general_election_2010/key_election_questions/have_targets.html

OECD (2002) Safety on Roads. What’s the Vision?

OECD/ITF (2008) Towards zero: Ambitious road safety targets and the safe system approach
www.internationaltransportforum.org/jtrc/safety/targets/targets.html

RAC Foundation and Road Safety Foundation (2011) Saving Lives, Saving Money: the costs and benefits of achieving safe roads http://www.racfoundation.org/research/safety/saving-lives-saving-money.

Annex A

RAC FOUNDATION COMMENTS ON KEY OUTCOME FRAMEWORK INDICATORS

Indicator

Comment

Number of road deaths (and rate per billion vehicle miles)

Historically km have been used as the unit of measurement for indicators of this type, and Government should consider keeping this unit of measurement to allow for easy trend analysis. For all the measures it might be more appropriate to have a measure of “per 100 million x km” than using the larger “unit of per billion”.

Rate of motorcyclist deaths per billion vehicle miles

This measure should be per billion motorcycle user-km otherwise the KSI will be affected by changes in average vehicle occupancy in all vehicles.

Rate of car occupant deaths per billion vehicle miles

As above this should be changed to per billion car user-km otherwise the death rate will be affected by changes in average vehicle occupancy and this could be important if sustainability policies lead to higher occupancies.

Rate of pedal cyclist deaths per billion vehicle miles

There could be a problem with this indicator due to limited distance covered by pedal cyclists in comparison to motorized transport. It might be better to quantify this indicator by using hours of exposure rather than distance travelled.

Rate of pedestrian deaths per billion miles walked

Same point as above for pedal cyclists.

Number of deaths resulting from collisions involving drivers under 25

This measure should be per 100,000 population under 25 and should either be for the population aged 17–24 or, car-licensed drivers under 25.

Authors own: Responses extracted from RAC Foundation consultation response to DfT (2009) “A Safer Way: A Consultation on Making Britain’s Roads the Safest in the World”.

October 2011

Prepared 18th July 2012