Memorandum by Green Speed (RTS 03)
These representations are made by GreenSpeed
which campaigns for lower speed limits; those compatible with
the objectives of reducing the adverse environmental and social
impacts of the private motor car. GreenSpeed stickers are available
to attach to the rear of the car as a signal to the driver following
that the car is being driven at responsible speeds;20 mph
in residential areas and55 mph out of town. These comments
concentrate on the need and justification for a 55 mph national
speed limit as the Committee are likely to receive many representations
on the imperative of lower speeds in urban areas on grounds of
1.1 The committee will be aware and will
no doubt be starting their enquiry from an examination or the
DETR publication (March 2000) New Directions in Speed ManagementA
Review of Policy. This report was the culmination of a wide
ranging review of speed policy and, as the Committee may regard
this as authoritative evidence based research, it maybe useful
to identify where the findings should not be regarded as reliable.
In particular, the comments made in these representations should
demonstrate that the review does not adequately justify retention
of the current speed limits.
1.2 It is fundamental to the Government's
(and most lobbyists') view of speed that it has been regarded
as an issue of safety with very little weight given to environmental
impacts. The Review was conducted for the Directorate of Road
Safety and the Environment but, the consideration given to the
issue of speed in the case of motorways and dual carriageways
is dealt with in a few paragraphs 161 to 165. The only analysis
of the effects of reducing the national speed limit to 55 mph
produces the diametrically opposed findings that:
lower speeds could have an adverse
economic effect through increased journey times,
but that lower speeds reduce journey
times through smoothing the flow in potentially congested conditions.
1.3 On this totally inadequate evidence,
the conclusion reached (paragraph 165) is that, in free-flowing
conditions, the current speed limits strike the right balance
between competing priorities.
1.4 The Review refers to the work of Hillman
and Plowden (Speed control and transport policy: PSI 1996).
This publication is the product of the most rigorous research
carried out on the various effects of speed, and concluded that
the national speed limit of 55 mph strikes the right balance.
This work should be compulsory reading for the Committee.
1.5 The Committee will also receive representations
from the Commission for Integrated Transport whose latest report
has found our motorways to be the most congested in Europe. Before
moving on to comment on other aspects of the 2001 DETR speed review,
the findings of the CIT raise the obvious question as to what
extent congestion is actually caused by speed. It is perverse
to say that in free flow conditions 70 mph is the appropriate
limit if that speed is a main contributor to the congestion, where
only very much lower speeds then become physically possible.
1.6 An investigation into the psychology
of car use (Guntram, U (1993) The McKinsey Quarterly No
2, pp 153-169) indicates that travelling has become an end in
itself and therefore, the accoutrements of this activity have
to make this a satisfying experience in itself. The in car environment
is far superior to most means of public transport. Cars could
be made to be ". . . very light, slow, short range, and capable
of being powered by one battery set (which) can be driven on regenerative
energy that need not be taken from a power plant". However,
the dispersion of car component manufacture across the globe means
that whole new cars (different to the model which has changed
so little in nearly 100 years) is very difficult to conceive.
If the committee recognise the obvious advantages of lower speed
limits they should not underestimate the resistance to such a
1.7 These representations will seek to explain
the ways in which the 70 mph limit (even assuming a reasonable
level of compliance) contributes to the unacceptable use and state
of the motorway and trunk road system while creating serious problems
for an integrated transport system making best use of bus, train,
walking and cycling.
2. THE DETR 2000
2.1 Under paragraph 36 the report says that
an individual driver is "much more likely to be involved
in an accident" going at 10-15 per cent above the average
speed around them. On trunk roads the speed limit for HGVs is
50 mph and if this is observed, greenspeeders would be safe when
going at 55 mph. However this is between 21 and 28 per cent slower
than the traffic observing the 70 mph speed limit. Although the
"average speed" is clearly somewhere between 50 and
70 mph it is clear that those travelling at 70 mph and more (as
unfortunately is very often the case) are endangering those who
have to (eg HGVs) or choose to (greenspeeders), travel at lower
speeds. By maintaining higher speed limits the Govenrment are
actually creating dangerous driving conditions for both those
choosing to drive at socially and environmentally responsible
speeds and those who continue to do the opposite. The fact that
those wishing to drive at socially and environmentally responsible
speeds cannot do so without causing danger to themselves and others,
and that there is a not altogether irrational pressure to drive
faster, is one compelling reason why official rather than voluntary
speed restraint is preferable so that the maximum and average
speeds are brought down.
2.2 The graphs show that the CO2 emissions
increase by about 20 per cent as a car slows from 30 mph to 20
mph and increase by about 20 per cent as speeds increase from
55 mph from 70 mph (consumption goes up by the square of the speed
so the faster the vehicle the worse the consumption and emissions).
The report seems to oblivious to the effect that current speed
limits have had on vehicle design (ignoring the quite irrational
capability of most cars to exceed 100 mph) and that these graphs
show the performance of the current generation of vehicles and
the graph would look different at both ends if cars were designed
to do a lower maximum speed.
2.3 Paragraph 54 says that speed may increase
choice. Clearly not everybody has the choice to travel at high
speeds and there are other ways of increasing choice (reducing
the car's competitive advantage over public transport) for more
people than allowing the privileged few to seek to satisfy their
desires over a wider area.
2.4 Publicity has recently been given to
clamping, auctioning and scrapping of cars found without a road
tax disc or insurance. The same should apply to the equally, if
not more serious offence of speeding. Initial clamping for say,
one hour, would rather extend the journey time which the speeder
was trying to save. A visit to the police station to interrupt
a journey could act as a very effective deterrent. Payment of
the fine could release the car. Depending on how fast the car
was going it could be clamped overnight, confiscated (as would
any lethal weapon) or sold. These would be more effective deterrents
than points on the licence.
2.5 The Report does not deal with the effect
of speed on motor car technology, eg the improvements to efficiency
and the competitiveness of alternative fuels (the Committee should
note that speed limits have also been omitted as a variable from
the current DTLR review on alternative fuels) which would be possible
with a lower maximum speed limit, ie 55 mph instead of 70 mph.
Although the reduction in the competitive advantage currently
enjoyed by the car over bike, bus and train is mentioned through
the description of the measures taken at Graz in Austria, there
is no follow-up to this impressive example. The Select Committee
is the ideal body to examine and understand the point that, the
speed and speed limits affecting the use of the private motor
car is absolutely crucial to the concept of an integrated transport
policy. A car designed for a top speed of 55 mph would, incidentally,
be less difficult to drive at both 30 and 20 mph in urban areas,
and would be less noisy and less polluting.
2.6 Lower speeds can reduce congestion which
can have the result of reducing rather than increasing journey
times (paragraph 113 suggests an increase in journey times while
paragraph 163 admits the opposite may be true). Even if the problems
of congestion were solved (by more road building?!) the reduced
time cost of road transport which could only then be possible
(see CIT report 2001), could reduce or delay the use of either
more environmentally friendly modes, or the move towards shorter
journeys to save the time currently lost to congestion.
2.7 Not only would urban traffic flow more
easily at lower speeds with less congestion and pollution but
there could be some modal shift to bike and bus with a consequent
reduction in pollutants. The suggestion in the report that 20
mph may be more polluting than 30 mph (paragraphs 47 and 118)
relies on the existence of "free flow", which is actually
more achievable at lower speeds, and overlooks the contribution
that higher speeds make towards congestion and the prevention
of free flow. Common sense and experience shows that it is easier
to enter roundabouts and main roads where that traffic is doing
a steady slow speed. Further, it is only the current generation
of vehicles which we know are designed for excessive speeds which
are more polluting at 20 mph than 30 mph.
2.8 The motorist lobby is winning the battle
of the speed cameras. As soon as all become painted yellow so
as to be unmissable to the motorist, it would seem to be inevitable
that speeds will increase elsewhere. We have all been in a decelerating
line of traffic which accelerates when past the camera. Sudden
braking at a camera could cause a danger but only to illegally
speeding traffic. Low (20 mph) speed limits need to be reinforced
by the smart bump that is now undergoing trials, which compresses
if a vehicle is obeying the speed limit, or with less conspicuous
cameras. The current system of bumps and inconspicuous cameras
causes stop-start driving which is inefficient and noisy and militates
against smooth and efficient driving.
2.9 The answer to the issue at paragraph
125; the pressing need for compliance with existing speed limits
in the absence of traffic calming, is the engineering of the car
and not the street. The car designed for no more than 55 mph does
not require the same level of calming as the 100 mph car, which
is the current norm.
2.10 It is implausible that the cost of
advertising the lowering of the national speed limit on single
carriageway roads is a relevant factor (paragraph 141) for this
once and for all change which would increase road safety and reduce
the number and severity of accidents. Apologists for the current
pattern of speed limits should see this as an acknowledgement
of the weakness of their case. Overtaking on straight stretches
of these roads can be as dangerous as on junctions and bends.
Overtaking is a result of wide differences of preferred speeds
and would be unnecessary if all traffic observed or was close
to a lower speed limit. Observance would be more likely in machines
designed without the ability/power to drive at twice the maximum
2.11 Again, the problems on rural roads
(paragraph 142) would be greatly helped through re-engineering
the capability of the car. Lowering the national speed limit would
provide the incentive to change the technology and make the car
more acceptable on rural roads and urban areas. Allowing local
authorities to lower speed limits overcomes none of the reservations
expressed in the report and looks like the abrogation of responsibility
by national government, not to mention the transfer of the costs
2.12 While the speed limit remains at 70
mph the technology will allow 100 mph (and more!) and the level
of non-compliance will continue. With a well-enforced limit of
55 mph, introduced say in 2006, the technology would change significantly.
There is no mention in the report that a decrease in speed would
provide a much needed reduction in emissions (the same argument
used in the report against lower speeds in urban areas). The journey
time argument cannot be made out in the medium and long term and
there could be a warning to the manufacturers and the car buying
public about the reduction of the national speed limit. Given
the known advantages of a reduced speed limit, it is entirely
unclear what the justification is for the statement in 165 that
there is a balance between priorities. The Plowden/Hillman research
is referred to as "Reference" as if it has been taken
into account, when its findings have been completely ignored.
2.13 The fuel price "crisis" of
2000 clearly showed that HMG had some difficulty in justifying
high prices at the pumps. It was very puzzling and disappointing
that the only argument deployed was the need to maintain income
to pay for public services. The imperative of reducing CO2 through
reduced use of the internal combustion engine would brook no argument
from the hauliers, farmers or motorists.
2.14 The report seems to be concerned about
the cost of changes to the regulations. There would be virtually
no cost involved in the introduction of a 55 mph maximum speed
limit as there are currently no signs showing 70 mph.
2.15 The point made at para 194 must be
right and the lenient position regarding speeding drivers is an
invitation to speed until caught three times. With cameras becoming
more easily seen, speeding could become more common.
2.16 The evidence in the report does not
support the conclusion at para 213 to maintain 70 mph as the national
speed limit. The report says that the benefits attributed to the
higher speed limits (both 30 mph and 70 mph) only accrue in conditions
of free-flow without realising that it is high speed which militates
against free-flow. The finding that lower speeds can improve free-flow
seems to have been forgotten as is rectifying the balance of the
competitive advantage enjoyed by the car. The economic effects
of a reduced national speed limit are extremely complex and extend
well beyond the desire of the current drivers and hauliers to
maintain their estimated current journey times. For a Government
report on a transport issue published in 2000 it is extraordinary
that there is no section or indeed reference to "sustainability".
Putting this into the balancing exercise could result in very
different conclusions which do not seem quite so attractive to
the road lobby.
2.17 When looking into the "long term"
(paras 244 and 245) there is still no mention of "sustainability",
no mention of changes in technology or that, without fundamental
changes, traffic will continue to grow and defeat the Kyoto commitments.
If the long term extends to 15 years, and some people keep their
cars for that length of time and longer, the oil supply position
could become very different. When fuel economy (again, no mention
in the report) becomes a priority, the Government will again have
to review the issue of speed control as this is one of the main
ways in which step improvements are possible, and reducing the
national speed limit would be one of the obvious incentives.
2.18 Not everything in the report is bad
and there are references to work which needs to be done in some
of the less well researched areas. However, the review is typical
of research which excludes important and possibly inconvenient
variables, in this case the national speed limit and the maximum
designed vehicle speed.
2.19 There are models of car ownership and
use used by the DETR and it would be very interesting to see how
these would predict modal shift and changes to journey patterns/length
relating to the change to the national speed limit. It would be
very interesting to see what the models predict would be the result
of keeping the maximum speed for coaches and buses at 65 mph (having
the use of the fast lanes on dual carriageways). We trust that
it will not be too long before the result of this additional work
will be available for Government and public scrutiny. Given the
comprehensive work done by Hillman and Plowden which is referred
to in the References it is difficult to see the evidence which
has been relied on to support such different conclusions. The
Government's catchphrase has been "evidence-based research"
and it is all there in Hillman and Plowden, which contrasts starkly
with the political dimension evident and made quite explicit in
the Speed Review.
3.1 Prof Phil Goodwin has shown that the
Government's transport plan just will not meet its own objectives.
This is borne out by the recent report from the CIT. In fact in
many areas the position will become or be made worse. Until the
full effects of car speed are factored into the issue of integration,
and sustainability is brought up the agenda, the Government's
transport planning will be bound to fail.
3.2 The advantages of a lower national speed
limit are mostly logical and intuitive. The only, possibly, counter
intuitive benefit would be the improved average speeds and journey
times achievable by lower speeds due to the reduced congestion
and free-flow. This is not unlike the 20 per cent fuel saving
from completing a journey at 55 mph rather than 70 mph, even if
the journey time is increased by 20 per cent.
3.3 GreenSpeed is interested in the reduction
of the urban speed limit to 20 mph for both reasons of safety
and the competitive advantage weighing back towards the cyclist
and pedestrian. However, the improvement to the liveability of
urban and village streets and rural roads will be boosted from
the technological changes to the car when it is designed to travel
at no more than 55 mph (with similarly reduced acceleration).
3.4 In the debate about "carrot and
stick"; whether the public transport system must be improved
to attract drivers out of their cars or whether taxes/charges
and traffic/parking regulations should be relied on, it should
be understood that the first is impossible without a dose of the
latter. When looking at the possible "sticks", a lower
national speed limit (and 20 mph the norm in urban areas) comes
recommended for the following reasons:
At virtually no cost, convert the
vicious cycle of degradation into a virtuous circle of improvements.
At a stroke, the bus (could retain
a 65 mph limit and have use of bus lanes on dual carriageways)
and train, become more competitive and profitable (the bums on
seats/paying passengers answer to the problem of integrated transport).
The "car" forced to evolve
into a machine more suitable to low speeds, greater economy and
Walking and cycling is less dangerous,
more pleasant and not so much slower.
Advantages to health through more
cycling and walking and less death and injury on the roads with
associated cost to our overstretched health service.
Massive improvements to transport
without investment in infrastructure; no building of roads (three
lanes designed for 70 mph could be divided into four for 55 mph)
or railways. There may be a need for more rolling stock and buses,
paid for out of use.
Significant reduction in fuel consumption
(even or especially from current generation of cars), proportionately
lower emissions (including CO2) and in noise pollution.
3.5 Given that the experts and the public
can see little or no prospect of resolving our transport crises
the advantages of lowering the national speed limit should not
be rejected without far more rigorous examination than was shown
by the DETR in 2000.
9 December 2001