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PostPosted: Wed Oct 27, 2004 13:53 
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Hi everyone,

This has been on my "to do" list since August. To my horror, I have just learned that this important consultation closes on Friday.

The DfT have published a consultation as follows:

Page: http://www.dft.gov.uk/stellent/groups/d ... 30771.hcsp

Document: http://www.dft.gov.uk/stellent/groups/d ... 030771.pdf

This concerns introducing a system of graduated penalties for speeding offences.

I am working on a "reply pack" right now that will include all the principle arguments that we would recommend.

Everyone has the right to reply to this consultation, and we need to organise as many replies as possible. Every single reply will count.

So can we discuss the matter urgently? I'll be working on the "reply pack" to be published to the web site later today.

You might also think it well worth reminding friends or folk on mailing lists or other forums about the consultation and the closing date.

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The Safe Speed campaign demands a return to intelligent road safety


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PostPosted: Wed Oct 27, 2004 18:15 
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Scrap the pounts totting up system completly.

They could just issue fines, if it is paid within a certain amount of time. Outside of a time period they get points as well.

Quick and easy, no need for the court or DVLA costs and the driver gets punished.

The Government will be happy as they have received the revenue, and the cost of the current systems.

Driver's will be happier, as their insurance will not be going through the roof, or will they be losing their jobs.

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 Post subject: Ban immediately
PostPosted: Wed Oct 27, 2004 22:31 
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No - if someone is so dangerous, despite never being in or caused an accident before, if they trangress the speed limit they should be banned for life immediately.

That will stop dangerous drivers.

:roll:

I know, not that useful, but it makes the point.

cheers

Paul


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PostPosted: Thu Oct 28, 2004 10:32 
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Please feel free to comment. I will email the DFT with this as it is unless convinced otherwise.

======
Question 1

Do you agree with the Government's view that there is a case for fixed penalties for speeding to be more graduated, with higher penalties for more serious categories of speeding, and lower penalties for less serious cases?


1. I agree that a graduated system of penalties is a fairer system than a 'one size fits all' system. However it must be practical and it must not be counter-productive for road safety.

Question 2

If you do not agree with a graduated system, do you support the present structure of penalties, or would you wish to see an alternative approach?


2. Although I agree with the proposal to have graduated penalties for speeding offenses I think that worthy alternatives could be considered such as introducing incentives for NOT speeding. For example a system whereby if a person is not caught speeding for a fixed period of several months (say 12) some or all of the points are removed.

Question 3

The table below illustrates a possible structure for graduated penalties. Ministers would welcome comments on it, without prejudice to statutory consultation on future proposals, and comments which you may wish to submit on that statutory consultation.


3. The proposal seems to apply zero tolerance in the lower penalty category! This is completely unacceptable as it would force the majority of drivers to divert much of their attention from the road to their speedometer. This could potentially result in an unintended negative consequence of more accidents and deaths rather than fewer. I think a carefull study of the side effects of such a measure is required.

Question 4

It has been suggested that fixed penalties should be higher for repeat speeding offences. Do you have views on this?


4. Perhaps for repeat speeding that falls into the Higher Penalty categories, if there is good evidence that this is an indication of systematic reckless driving practice and as such deserves harsher treatment. However before such harsher penalties are applied I would like the psychological effects of these to be studied - would they actually have a positive effect on road safety, or would they simply make people resentful and force them into a spiral of further law-breaking. A better alternative could be a compulsory driving course that focuses on the dangers of excessive and inappropriate speed.

Question 5

Should other factors be taken into account, such as the location where the speeding occurred, or other factors?


5. Yes, other factors such as road and weather condition at the time of offense, presence of pedestrians and/or school children at the time etc should be taken into account ideally.

Now to the important questions that are not covered by the Government/DFT consultation paper.

1. The present system of self-financing Safety Camera Parterships (formerly Speed Camera Parterships) is deeply flawed and must be changed to remove the immense conflicts of interest that exist.The Parterships have a strong interest in advocating the use of speed cameras, deploying speed cameras in ways that maximise revenues rather than safety and in collecting and representing statistics in ways that favour the use of speed cameras. This is unacceptable and may well be extremely damaging to road safety. The fact that SCPs are 'not for profit' organisations is irrelevant here. Partership survival is dependent on the continution of speed camera enforcement policies. Poor public accountability allows the parterships to be run as commercial operations with performance targets that are based on numbers of speeding fines generated rather than actual casualty reductions in the area covered by the parterships. These are powerfull incentives that encourage parterships to ignore uncomfortable conclusions and misrepresent results in order to reinforce biased views on the effectiveness of the speed cameras.

2. In place of Camera Parterships I demand to see Road Safety Parterships that have in their arsenal of safety improvement measures much more than just the speed camera. I would like to see road layout improvements, electronic speed-activated warning signs that display specific warnings about the hazards ahead etc etc. The performance of these parterships should be evaluated in terms of year-on-year reductions in fatalities and injuries not in terms of meeting financial targets. These parterships must not be self-financing, instead they should be funded from the public purse and rewarded according to how good a job they do.

3. The collection and interpretation of statistics for measuring the performance of such partnerships must be done by independent bodies with no vested interests in the partnerships. The data and interpretation of the data must be available for open review.

4. A full and independent research programme must be commenced into the possible negative side-effects of automated speed enforcement. Diverting drivers' attention away from the road to their speedometer could turn out to have disastrous consequences for road safety. It must be proven that automated speed enforcement is not counter-productive.


Regards
ad

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PostPosted: Thu Oct 28, 2004 10:54 
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This is taking ages, and not least because I keep getting interrupted by journalists! Here's the work in progress:

http://www.safespeed.org.uk/consultation.html

There's still much more to do. I'm doing it.

I think the main flavour of the reply is really that graduated penalties are not a response to a problem with the law, but instead are a response to very serious problems with enforcement practice.

I also see graduated penalties as a further false emphasis on the importance of precise observation of speed limits. As such they are dangerous too. It's usually far more dangerous to go 29mph in a narrow busy village high street than it is to go at 125mph on a clear motorway.

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PostPosted: Fri Oct 29, 2004 04:50 
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I'm still working on this thing and have just sent the following email:

-------- Original Message --------
Subject: URGENT - Graduated speeding penalties consultation
Date: Fri, 29 Oct 2004 04:46:46 +0100
From: Paul Smith <psmith@safespeed.org.uk>
Organization: Safe Speed
To: mike.fishman@dft.gsi.gov.uk

Dear Sir,

I see that today is the closing date for the Graduated Speeding Penalties
Consultation.

How firm is the closing date? Would you accept submissions delivered by email before 9am on Monday 1st November?
===============================

I'd really like to see lots of replies going in to this consultation for "Safe Speed minded" folk. It'd be great if we could take the weekend to spread the word and encourage replies. My fingers are crossed.

There will be Safe Speed materials ready this morning, but more time would be nice.

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Our scrap speed cameras petition got over 28,000 sigs
The Safe Speed campaign demands a return to intelligent road safety


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PostPosted: Fri Oct 29, 2004 11:49 
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Hi All,

This just in:

===============================
-------- Original Message --------
Subject: Re: URGENT - Graduated speeding penalties consultation
Date: Fri, 29 Oct 2004 11:42:08 +0100
From: "Mike Fishman" <Mike.Fishman@dft.gsi.gov.uk>
To: <psmith@safespeed.org.uk>
CC: "David Patterson" <David.Patterson@dft.gsi.gov.uk>

Dear Mr Smith

A response on Monday will be fine.

Regards


Mike Fishman

Mike Fishman
Road Safety Division
Speed Policy Branch
2/13 Great Minster
0207 944 2028
================================

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PostPosted: Fri Oct 29, 2004 12:11 
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SafeSpeed wrote:
I think the main flavour of the reply is really that graduated penalties are not a response to a problem with the law, but instead are a response to very serious problems with enforcement practice.

I was a good boy and sent a response in a couple of months ago :D

This is basically what I said - that the proposal puts too much emphasis on pure numerical speed and not on speed relative to the conditions, and the concerns it is addressing basically relate to enforcement practice, not the structure of the penalty system.

In principle, the current system is logical - there's a single, one size fits all fixed penalty offence, as a camera cannot judge the seriousness of an offence relative to the conditions. If, in the judgment of a police officer, the offence is sufficiently serious, then it can be referred to the courts who have a wider range of penalties available. The "problem" lies in the way the system is being abused to maximise the number of convictions, usually at very low tolerances and/or where it is least dangerous to exceed the speed limit.

By the way, I know we've discussed this before, but I didn't read in the document any clear implication that the ACPO guidelines would be abandoned and zero tolerance applied. They are after all only guidelines with no legal standing, and 31 in a 30 has always been strictly speaking illegal and open to prosecution if a police officer so decides.

If they do go for zero tolerance (which I don't believe they will) then there will be one hell of an outcry.

My view is that this proposal will be quietly dropped after the election, primarily because the anti-car lobby see it as diluting the seriousness of speeding offences.

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Any views expressed in this post are personal opinions and may not represent the views of Safe Speed


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PostPosted: Sat Oct 30, 2004 07:07 
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The Safe Speed submission is nearing completion. See:

http://www.safespeed.org.uk/consultation.html

I will also prepare three further documents from the web page.

1) Our submission
2) A "template" version of our submission that folk may like to edit, crib from, reword and send in as their own.
3) A letter of support for the Safe Speed submission.

The DfT have indicated that they will accept submissions that arrive on Monday morning. Please consider setting aside a little time before monday morning to send your own submission.

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Our scrap speed cameras petition got over 28,000 sigs
The Safe Speed campaign demands a return to intelligent road safety


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PostPosted: Sat Oct 30, 2004 15:58 
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Not sure of "competence" in your Q1 response, Paul. How about "significance" :idea:

Although I appreciate where you are coming from, I think your proposed response to Q3 is dichotometric to the basic message. Conditions, time of day etc must all play a part. The tables cannot show that. My reply - and I will make one - will basically not be as positive or as long as yours is in that area.

Excellent reasoning in your closing paragraphs. after Q5...

R


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PostPosted: Sat Oct 30, 2004 16:13 
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Roger wrote:
Not sure of "competence" in your Q1 response, Paul. How about "significance" :idea:


My choie of the word competence echos similar use in the normal expression of the "Peter Principle". I like it. :)


Roger wrote:
Although I appreciate where you are coming from, I think your proposed response to Q3 is dichotometric to the basic message. Conditions, time of day etc must all play a part. The tables cannot show that. My reply - and I will make one - will basically not be as positive or as long as yours is in that area.


The point here is that the review is about graduated speeding penalties. Although I strongly disagree with graduated speeding penalties, I recognise that the conclusion of the review is likely to accept them. Therefore I have proposed a scheme.

Roger wrote:
Excellent reasoning in your closing paragraphs. after Q5...


Thank you kind sir.

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Our scrap speed cameras petition got over 28,000 sigs
The Safe Speed campaign demands a return to intelligent road safety


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PostPosted: Sat Oct 30, 2004 16:18 
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I'd forgotten about Peter's principle :shock: Ok - I'll give you that one, but won't use it myself thanks to incompXXXX insignificance :wink:


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PostPosted: Sun Oct 31, 2004 05:59 
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Our template is ready.

See page: http://www.safespeed.org.uk/consultation.html

The template is here: http://www.safespeed.org.uk/template001.doc

You can download the template and, if you agree with our conclusions, add your details to the included template letter and send it in less than five minutes. I urge everyone to make a submission. Every single one will count.

Send your completed submission to: mike.fishman@dft.gsi.gov.uk

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Our scrap speed cameras petition got over 28,000 sigs
The Safe Speed campaign demands a return to intelligent road safety


Last edited by SafeSpeed on Sun Oct 31, 2004 06:11, edited 1 time in total.

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PostPosted: Sun Oct 31, 2004 06:09 
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Looks good - but I need an hour of shut-eye. I'll do it after breakfast :roll:

However, I'll lay a link in "unsigned" to make amends for my misplaced highball the other week :wink:


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PostPosted: Tue Nov 02, 2004 06:22 
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There's a very sad RoSPA response here:

http://www.rospa.com/roadsafety/consult ... duated.pdf

It's stuffed full of dogma and incorrect assumptions. Don't the RoADA people know far better than this? Don't they talk together?

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Our scrap speed cameras petition got over 28,000 sigs
The Safe Speed campaign demands a return to intelligent road safety


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PostPosted: Tue Nov 02, 2004 11:32 
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Thanks for the effort you put in Paul - I made a very few additions.
I would not have been able to make such a thorough submission by myself

Keep up the good work.


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PostPosted: Tue Nov 02, 2004 12:04 
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SafeSpeed wrote:
There's a very sad RoSPA response here:

http://www.rospa.com/roadsafety/consult ... duated.pdf

It's stuffed full of dogma and incorrect assumptions. Don't the RoADA people know far better than this? Don't they talk together?


Hello Paul,

ROSPA sum up their submission with the following:

ROSPA wrote:
But ultimately, the public as a whole needs to be persuaded that driving at speeds above the posted speed limit or above what is clearly safe for the conditions, is not a minor technical offence that everyone commits, but a serious, dangerous and anti-social activity in which the speeding driver places his/her own convenience above the safety and well-being of other people


What would be your 'in a nutshell' riposte to that assertion, the SafeSpeed equivalent if you like?


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PostPosted: Wed Nov 03, 2004 02:40 
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Rigpig wrote:
ROSPA sum up their submission with the following:

ROSPA wrote:
But ultimately, the public as a whole needs to be persuaded that driving at speeds above the posted speed limit or above what is clearly safe for the conditions, is not a minor technical offence that everyone commits, but a serious, dangerous and anti-social activity in which the speeding driver places his/her own convenience above the safety and well-being of other people


What would be your 'in a nutshell' riposte to that assertion, the SafeSpeed equivalent if you like?


Good question. Quick draft:

But ultimately the authorities need to be persuaded to concentrate accurately on the real causes of road crashes. Excessive emphasis on easy-to-measure parameters is turning out to be dangerous - it leads to distorted safety priorities, and many opportunities for genuine improvements being missed. Road safety results prove beyond doubt that typical speeding behaviour is not dangerous, therefore when we do target speeding behaviour, we should be certain that it is untypical.

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PostPosted: Wed Nov 03, 2004 10:16 
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Something had me wondering when reading the posted link (admittedly not fully :oops: )...

Quote:
These illustrative figures have been calculated on the basis that the lower penalty would apply (except
for 20 mph zones) at speeds below the speed limit, plus 12.5%, plus 6 mph (to allow for the technical
limitations of speedometers); and that the higher penalty would apply to speeds beyond the speed
limit, plus 25%, plus 6 mph.


Ok, so for the 12.5% and 25% speeding cases they add on 6mph for the 'technical limitations of speedometers'. Does this mean that for the 0% speeding cases - i.e. doing the limit, they must also add on a 6mph tolerance for the limitations of speedometers. To not do that would seem rather inconsistent to me.

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PostPosted: Fri Nov 05, 2004 17:00 
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bmwk12 wrote:
Scrap the pounts totting up system completly


That would be regressive. Rich toffs could speed as much as they liked, and pay a paltry (to them) 60 pound fine. The points are good, because no matter how much money you have, points still hurt.

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