Select Committee on Environment, Transport and Regional Affairs Minutes of Evidence

Memorandum by the ACPO Traffic Committee (IT 168)




  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.


  2.1 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.


  3.1 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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