Amending the Traffic Signs Regulations and General Directions 2002 to Enable Improved

Amending the Traffic Signs Regulations and General Directions 2002 to Enable Improved

Department for Transport consultation on:

Amending the traffic signs regulations and general directions 2002 to enable improved signing of safety cameras

Response from Brake, the road safety charity, September 2007

Introduction

Brake, the national road safety charity, is dedicated to stopping deaths and injuries on roads and caring for people bereaved and affected by road crashes. Brake carries out research into road users’ attitudes on aspects of road safety, including their opinions on speed limits, traffic-calming measures and speed cameras. Brake also works with people bereaved and seriously injured in road crashes to campaign for changes in the law, which will benefit road safety and provide much needed support for road crash victims.

General comments

Brake is concerned that the Government’s policy of having highly visible safety cameras weakens the ability of speed cameras to reduce crashes and casualties.

The effect of making speed cameras highly visible is that drivers are able to break speed limits for a large proportion of their journey, safe in the knowledge that if they are observant, they will be able to spot speed cameras in advance and slow down, avoiding a ticket. They can then speed up again until they spot another camera.

Hidden speed cameras would prove more of a deterrent to breaking the speed limit, giving drivers an incentive to drive within the speed limit at all times, with the knowledge that they may be unexpectedly caught out if they did not.

Although this consultation does not ask for views on the policy of highly visible safety cameras, Brake urges the Government to change its policy to favour hidden cameras, which would encourage more drivers to slow down more of the time, helping to reduce unnecessary deaths and serious injuries.

Brake is also of the view that speed limit repeater signs should be placed on restricted roads. It is absolutely essential that drivers are in no doubt of the speed limit. This is particularly important in 30mph zones where there are likely to be pedestrians and cyclists, who are much more likely to die if hit by a driver travelling at more than 30mph.

Brake recommends that the Government allows speed limit repeater signs on all roads and ensures that there are plenty of them on any road where there is a problem with speeding drivers. There should also be several reminders following any change in the speed limit. While there would be extra costs in providing additional speed signs around the country, Brake believes there is potential to increase drivers’ compliance with speed limits and save lives. The issue of environmental clutter should not be prioritised over safety.

The Government’s main aim in amending the regulations should be to give drivers plenty of information to enable them to drive safely, rather than just providing them with the information they need to avoid being caught breaking the law.

Annex C

CONSULTATION ON AMENDING THE TRAFFIC SIGNS REGULATIONS AND GENERAL DIRECTIONS (2002) TO ENABLE IMPROVED SIGNING OF SAFETY CAMERAS

REPLY FORM

Title: Mr/Mrs/Miss/Ms/Other (please state): Ms

Name: Rachel Burr

Organisation (if applicable): Brake

Address: PO Box 548, Huddersfield

Postcode: HD1 2XZ

E-mail address:

Date: 17.09.07

Please note:
The Department will prepare and publish a summary of all the responses to this consultation letter. Copies of individual responses may also be made available to anyone that requests them.
I am * content for a copy of my response to be made available if requested. Please note that if you ask for your response to be kept confidential this will only be possible if it is consistent with our obligations under the Freedom of Information Act 2000

*please delete as appropriate

Q1. Do you agree with the proposed amendment to Direction 11 to allow, where they are permitted, an additional speed limit repeater sign (diagram 670/671) to be placed in the vicinity of a safety camera, notwithstanding that this might cause the repeater spacing to become irregular.
No, I do not agree
Please explain your reasons and add any additional comments you wish to make:
It is important to ensure that drivers are regularly informed of the speed limit and Brake is in favour of allowing extra repeater signs, particularly in 30mph areas where there are currently none. However, placing additional repeater signs only in the vicinity of speed cameras will merely help to flag up the exact locations of the cameras, exacerbating the problem of drivers slowing down for a few metres around the camera and speeding along the rest of the route.
By restricting additional speed limit repeater signs to the vicinity of safety cameras, the Government is missing a crucial opportunity to allow repeater signs on any road where there is a problem with speeding drivers.
Q2. Do you agree with the proposed amendment to Direction 32 to allow the use of up to two signs to diagram 880 on each approach to the area or route on restricted roads where camera enforcement is undertaken
Yes, I agree
Please explain your reasons and add any additional comments you wish to make:
Given the current policy of having safety cameras which are highly visible, Brake is in favour of using signs on the approach to an area or route on restricted roads where camera enforcement is undertaken, as this may encourage drivers to stick to speed limits along the whole route, rather than merely slowing down for the few metres around each camera.
Q3. Do you agree with the proposed amendment to Direction 18 to allow 30mph carriageway roundels to be placed on the road surface in conjunction with the informatory diagram 880 and camera enforcement on restricted roads
Yes, I agree
Please explain your reasons and add any additional comments you wish to make:
TRL report 201* found that 40mph roundels reduce speeds by an average of 3mph, so for this reason, they are to be encouraged. While the report found that 30mph roundels had no measurable effect, the trials were fairly small scale and did not find any evidence of a negative effect on compliance with the speed limit.
Common sense would suggest that the greater the number of reminders of the speed limit, the less able drivers are to argue that they do not know what the speed limit is. For this reason, Brake agrees that the Government should allow 30mph carriageway roundels to be placed on the road surface in conjunction with diagram 880, as well as in conjunction with specified upright speed signs, as currently used.

* Barker J and R D Helliar-Symons. Count-down signs and roundel markings trials. TRL Report 201 (1996)

Q4. Do you agree with the proposed amendment to incorporate Diagram 880.1, which combine the camera warning sign with the National Speed Limit sign (671), and is used on unlit roads subject to the national speed limit, within TSRGD.
Yes, I agree
Please explain your reasons and add any additional comments you wish to make:
Given the current policy of having safety cameras which are highly visible and signs to indicate that there are cameras on a particular route, Brake is in favour of putting a reminder of the speed limit on all camera signs.
Q5. Do you agree with the proposed amendment to Directions 8(1) and 10(2) which clarify that the sign to diagram 675, end of 20mph zone, also signifies the start of a new speed limit
Yes, I agree
No, I do not agree
Please explain your reasons and add any additional comments you wish to make:
Brake does not have a strong view on this question. However, it has reservations about the proposal. It must be clear to drivers what the new speed limit is at the end of any 20mph limit.
Q6. Do you have any comments on the partial Regulatory Impact Assessment? Please let us know if you foresee any additional costs and have any specific views on the possible environmental and rural impacts
The partial Regulatory Impact Assessment does not fully analyse the costs of Brake’s preferred option: requiring hidden cameras and greater numbers of repeater speed limit signs. Paragraph 35 of the consultation document dismisses this option, due to the enormous financial cost to Traffic Authorities. However this cost needs to be balanced against the huge costs to society of road deaths and injuries, estimated in DfT’s own economic assessment of the cost-benefit of preventing road crashes (Highways Economic Note no 1) at £17,850,000,000 per year.
Q7. Do you have any other comments on the issues raised in this consultation document?
Please see above (p1 of this consultation response).
Q8. Do you have any comments to make on the consultation process?
It would have been useful to have had all the relevant information for each question in one place: having to look up the relevant parts of the regulations in the draft regulations document was time-consuming. Not all of the signs referred to in the consultation paper were given in the consultation document or draft regulations, requiring further cross-referencing to the current regulations.

For more information, please contact Rachel Burr, campaigns officer, on 01484 530085.

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