is the 20mph blanket speed ban working in tower hamlets?

Below is a copy of an email sent to Tower Hamlets Cabinet on Friday 2nd September before Cabinet on the 6th September, it refers to these cabinet reports found in section 5.3 on this link here read the report here first as it is the report I refer to below.

​Dear Cabinet members,

In advance of the cabinet meeting Tuesday I attach a submission on why on the surface the 20mph blanket speed ban is not working and should not be made permanent without more testing & analysis.

Summary
The evidence of collision data and residents surveys suggest that the blanket ban has not improved road safety and has only achieved an average reduction in speed of 1.4mph across Tower Hamlets and on some roads has resulted in higher speeds. The suggestion that the reduction of fatal & serious collisions at road junctions is entirely due to the reduction in speed is not backed up by evidence which should be readily available from public records but is not presented in the Cabinet report. My own analysis suggests otherwise. The number of collisions has though increased in total, on main roads and in residential areas according to the report.

However analysing the Cabinet report would suggest that there is not enough information on which to make a decision over making the 20mph blanket speed ban permanent and that the test should be extended into 2017 except for those roads it recommends should return to 30mph. In the mean-time the information gaps in the report outlined below should be rectified so that a better informed decision can be made in 2017.

This report should also be the start of a process to improve road safety not an isolated decision.

Detail
On the surface it appears as if the 20mph blanket speed ban has made the roads of Tower Hamlets less safe and many residents have told me what the surveys confirm, that the roads feel less safe than before not least because they see little reduction in speeds.
The table showing the increase in collisions on the road space between junctions (links in the report) is worth repeating as this the road space where vehicle speeds will be at their highest. The increase in fatal collision’s up 33%, slight collisions up 27% and those involving pedestrian up 51%. Serious and cycle collision’s no change. That would indicate that the 20mph has decreased road safety on the road space where vehicle speed is a factor.

The survey conducted by Tower Hamlets Council in May & June 2016 show that the majority of respondents do not agree that it makes the roads safer with 57% answering no they are not in favour of 20mph limits generally across London and 53% disagreed with the proposals to make the experimental 20mph limit on borough roads permanent. I have done my own survey using Surveymonkey (see attached) in August which reinforces this finding but with stronger results. I started it after I asked in the July Council meeting for a summary of survey results but was instead given information on collisions stats which are not replicated in the report. In my survey when I asked “Do you think Tower Hamlets roads are safer since the introduction of the 20 mph speed limit last April?” this is what I got from 446 responses;
 
Yes, much safer 4.72%
Yes, a little safer 6.97%
I have noticed no change 34.83%
No, a little more dangerous 19.55%
No, they are more dangerous 33.93% 

In the Cabinet paper its says this;
Para 3.2 Successful 20 mph zones and 20 mph speed limits should be self-enforcing, …. To achieve compliance there should be no expectation on the police to provide additional enforcement beyond their routine activity, unless this has been explicitly agreed.

How can a successful 20mph zone be self-enforcing if it does not have broad public support?
Especially if that 20mph speed test was never properly discussed or consulted upon before it started, being one of the last decisions made by Mayor Lutfur Rahman and with implementation taking place in-between his removal and the election of a new Mayor. You cannot change driving culture top down, without public engagement, without major physical changes and without police enforcement.

The data shows that in total collisions have increased by 15%, they have increased by 35% in residential streets and a 20% increase in the roads in-between junctions where you would expect road speeds to be at their highest. And although average speeds have reduced it is only by 1.4mph and on some roads speeds have actually increased.

But collisions at junctions have decreased by 13% which is attributed to the lower speed limit but this makes little sense. Generally, at junction’s vehicles are either stopping for a red light or slowing down to turn. Average vehicle speeds at junctions will therefore be lower than on the surrounding road spaces.

But since most fatal & serious collisions happen at junctions this is used to justify the claim that the lower speed limit has been a success because fatal accidents fell 20% and serious accidents fell 22% this is used to justify that the blanket speed ban is a success. Again this makes little sense, for example we know many cyclists are killed by HGV’s turning left at junctions, this is not a speed issue but a truck visibility and junction design issue.

And this is where we have the first problem with the lack of data which means the whole report is not providing us with enough information to make a decision. Mercifully the number of fatal and serious collisions is low (1.3 fatal & 33.3 serious in the post period) so it should be possible to analyse those accidents and work out whether speed was the main or contributory cause. But that information is missing from the report. I have attempted to use the www.crashmap.co.uk website to do my own analysis which suggests I am on the right lines in believing that accidents at junctions are not primarily speed related but that site only provides limited information. I have asked for the detail on accidents but have not received it. 

I believe that the report does not contain enough information on which to make a permanent decision in September 2016 and that you should extend the test period until you have it and can then make a permanent decision on a sound data.

The most important factor is that the report uses the 1st April 2015 to 31st December 2015 as the after period for analysis. There are several fundamental issues with this;

• 20mph introduced 13th April not 1st  April
• Most people were not aware of 20mph on 1st April as so poorly advertised, it was months before road signs were painted for 20mph. The end date of that road painting process should be used as the start of the analysis not 1st April which is probably around July 2015. How can people be expected to drive at 20mph before they are aware of the change?
• Not a full 12-month period therefore weather & clock changes cannot be factored in fully.

 
You need I believe a full 12 month set of road data to analyse post implementation results and 2015 is a mess due to the phased implementation and awareness of the 20mph test during the year. I think you need to wait until 2017 when we have a complete set of data for 2016 in order to do the analysis and then compare that data to 2014 and earlier years. You should probably repeat in March 2017 the road speed test as well.

There are some other critical issues not fully raised in the report;

• Why the 17.5% fall in traffic year on year, this makes no sense, I can see why individual roads will have increases and decreases especially due to road works especially cycle super highway implementation but across the whole Borough? The report suggests this is due to an increase in cycling which I think is unlikely. I think we need to understand why such a material change by mapping locations & roadworks.
• The reason why I believe the roads have become more dangerous is because overtaking has increased. If I drive at exactly 20mph on A-roads, I will have a stack of vehicles behind me waiting to overtake me. When they do so, that increases the danger for all road users. I believe based on personal observation that the amount of overtaking has increased since the introduction of 20mph, this is backed up by other residents, 74% of who think overtaking has increased. But the report and data has no way of capturing this except for when collisions do occur which have increased in total.
• The other reason for why the roads have become less safe is that pre-change most vehicles on main or A-roads would have driven at similar speeds and those speeds would have been predictable. Now some drivers are driving at 20mph but many are not, there is now a wider gap between the fastest and slowest drivers creating less predictable driving conditions.
• Police vehicles not on call do not drive at 20mph, most do between 25 & 30mph, that does not encourage self-enforcement of 20mph for other residents. Other official vehicles i.e. buses and TH Council vehicles have also been seen ‘speeding’ 
• Tower Hamlets Police speed stops – very rare, on two stops I attended on Manchester Road they only stopped vehicles going over 30mph and only ticketed over 40mph (although on the last stop I attended no officers were trained to issue tickets, now rectified). Police stated they did not think they could issue tickets between 20mph & 30mph. Drivers do not live in fear of police speed stops.
• Only one portable speed laser gun in Tower Hamlets (as of early 2016) – owned by Tower Hamlets Council and stored in CCTV control room at Mulberry Place not by police – that shows how serious Tower Hamlets is about speeding enforcement
• A wider analysis of road safety across Tower Hamlets, we are looking at 20mph in isolation but most people killed are on TfL controlled roads. What is the best use of scarce resources? 

The following is missing from the report pack;

• Map of Tower Hamlets showing speeds on different routes & what is Council and what is TfL - would be useful
• Detail of all fatal and serious collisions to identify whether speed was a factor or what other lessons we need to learn i.e. do we need to spend more money on improving the layout of junctions or is speed the only issue?
• Map showing where fatal and serious collisions took place so that we could use our local knowledge to ascertain what the factors that might be (but see attachments).
• Analysis of speeds – for example some law abiding citizens are driving at 20mph now, many follow the vehicle in front even if over 20mph but I suspect speeds of fastest 10% of drivers has not changed much especially late at night when less traffic. Can we have this breakdown by speed and time of day?
• Dates and locations of March speed test locations so that we can ascertain using our local knowledge whether locations were the right ones to test speed
• Speed camera data not available i.e. how many tickets issues by speed cameras during the relevant periods at different speeds?
• Numbers of vehicles owned by TH residents, broken down by ward, parts of Tower Hamlets were originally designed for vehicles as no or minimal public transport present. In the 2011 census there were 43,589 vehicles owners in TH, 54% of households in St Katherine’s & Wapping have vehicles versus 32% in Spitalfields & Banglatown. Understanding this will affect survey results.
• Analysis of why people in Tower Hamlets use their vehicles, are they luxuries or essential? How many people rely on vehicles for work, elderly parents, mobility issues? This was the response to my question “If you are a car or van driver why do you use your vehicle; choose all that apply”

 
To travel to and from work 31.22%
For work, for example you use it to move between jobs or to carry tools 12.69%
To carry family members around like young children or elderly parents 39.34%
You or somebody in your family is disabled or are unable to walk long distances 11.68%
Shopping & running errands which you could not do on public transport 67.26%
Leisure use only 35.53%

What is also missing from the report is how the different surveys were advertised which affects the responses;

First Council survey in 2014 received only 171 responses of which 103 where from a cycling website versus 43,589 vehicle owners in TH, why was the response rate so poor? Perhaps because it was so poorly communicated, I only became aware of it after it closed and I was a Councillor!

Second survey in 2016 received a better response with 904 responses. But it received disproportionate response from the E14 postcode 58% of total. This was because the Council survey was heavily re-advertised within the E14 community via social media & by email. This does not appear to have happened in other parts of TH, why? Arguably that makes E14 responses more accurate as it has a higher % uptake but is also affected by inclusion of A-road (Preston’s, Westferry & Manchester) within the 20mph zone.

I have been talking to Adam Bunce at www.2020consultancy.co.uk who has made some interesting observations about how to make 20mph work. He makes the good point that one of the best ways of assessing whether a road is suitable or not is to drive it at exactly 20mph.
On a suitable road 20mph will feel comfortable whereas the unsuitable road will feel uncomfortably slow. He also emphasizes how important public engagement is which we have not done yet.

Finally, you might find interesting :) the responses to this survey question I asked; Who do you think should make the decision on whether to end, amend or make permanent the 20mph speed limit ban? Pick one choice
 
By Mayor John Biggs in a Cabinet meeting 7.99%
In a full Council meeting after a full debate with all Councillors voting 23.29%
Through a public referendum as happened in Wells, Croydon, York and Worthing 68.72%
  
Let me know if you have any questions,

The attachments below are screen shots from www.crashmap.co.uk showing the locations of different types of fatal and serious accidents on all roads including those controlled by TfL, not subject to 20mph, no 2016 data available. Also attached here is a summary of the survey I conducted. There were no fatal accidents involving children between 2011 & 2015 which is why not shown below.