Dear Mr Gifford,

Your letter to Oliver Letwin MP

I see displayed on the Internet at http://www.pacts.org.uk/Letwin.htm a copy of a letter you sent to Oliver Letwin MP on May 7th. Your letter portrays an entirely false view of the facts about the relationship between speed limit enforcement and road safety.

You say:

Speed, whether excess (breaking the posted limit) or inappropriate (driving too fast for the conditions), is a contributory factor in one in three road deaths. That amounts to about 1,100 deaths per year. Many of these deaths would have been avoided if drivers had remained within the speed limit.

• It is certainly not proven that one in three road deaths have “speed” as a contributory factor. The majority of figures available place this at 15% or under.
• It is misleading (although I accept difficult to avoid) to lump together excessive and inappropriate speed. Best estimates suggest that two thirds of these accidents take place within the speed limit and are therefore out of reach of speed enforcement.
• Drivers who will always ignore any speed enforcement measures cause a significant proportion of these deaths. They might be drunk, driving stolen cars, criminals escaping from the scene of a crime, police drivers on emergency calls, or otherwise driving recklessly or dangerously. It is entirely false to imply that these groups might somehow be rendered safe by speed enforcement.
• The word “many” in the last sentence is intended to imply a large number, when the reality might well be a very small number.
• No amount of enforcement will produce 100% compliance with speed limits, so enforcement will always fall short of eliminating deaths contributed to by excessive speeds.

But wait a minute, since we started installing speed cameras in 1993 the long term downwards trend in the UK fatal accident rate has stalled completely and looks about set to rise when 2002 figures are announced shortly. Do you not find it remarkable that despite massive increases in speed enforcement over the last decade we've seen no improvement in fatal accident figures? 

Of course, there are good reasons that our flawed policy has failed to deliver reductions in road deaths: 

Firstly, exceeding a speed limit alone is an insignificant accident causation factor.  TRL 323 has excessive speed as a definite causation factor in just 4.5% of accident reports. In some of those reports there will have been obvious causes of both the speed and the accidents; recklessness, escaping criminals, drunks and so on. Two of the reports were suicide attempts, and although we are not told if they were also excess speed accidents, they probably were. You might recall that TRL323 lumps together excessive and inappropriate speeds, so of course any remaining percentage needs to be reduced by perhaps 67% to account for the proportion of accidents that take place within the speed limit.

Secondly, increases in speed enforcement have some negative effects on road safety. I'll quote to you five major effects that are inadequately researched. At lower speeds driver concentration may be reduced. Impacts on “drivers’ priorities” where at a critical instant they might be more concerned about compliance with a legal speed limit instead of an unseen dangerous situation developing ahead. Risk compensation: Where a driver at a lower speed may unknowingly preserve risk values by driving closer or more aggressively. Attitude effects: Where increasing the restrictions on a driver may make him care less about his driving in general. Traffic displacement: where an increase in speed enforcement on one route causes drivers to chose an alternative route which is more dangerous. I maintain a list of 17 factors that may cause danger to be increased when automated speed enforcement is deployed. All of them are inadequately researched.

Thirdly, the supposed science supporting the so-called speed accident relationship fails to establish a causal link between speed and accidents. This isn't surprising, because no such causal link exists, yet even the TRL fail to come clean about it, and persist in claiming that reducing speeds will reduce accidents with no adequate supporting evidence. You might be interested to read correspondence with the TRL's Chief Executive about it here: http://www.safespeed.org.uk/trl.html.

Fourthly, rigid speed enforcement played no part in establishing Britain's roads as the safest in the world. In fact over the last decade we have lost much ground to some other European countries where speed enforcement has not become an obsession.

Fifthly, most accidents take place in areas of danger. In fact it is hard to imagine an accident taking place in the absence of road hazards. Billions of times each day drivers slow to appropriate speeds and negotiate road hazards safely at speeds both above and below the speed limit. Yet speed enforcement in general has its greatest effects exactly where dangers are least: on open roads away from hazards. So the greatest effects of enforcement tend to take place where road dangers are least.

You also said:

Figures from the report evaluating the first two years of eight of the speed camera partnerships published in February 2003 concluded that deaths and serious injuries had fallen by 35% on roads where speed cameras had been in operation, equating to about 280 people.

It is highly remarkable that the document does not include any fatal accident figures, and prefers the much vaguer “killed and seriously injured”. One assumes that this is because the deaths figures did not support the case presented.

The document ignores the possibility of site level regression to the mean effects, save to include:

We could not obtain data for the before period for individual sites other than at camera sites. It was therefore not possible to check fully for regression to the mean at the site level.

Based on all the above, I expect you will be revising your stance in the interests of real road safety based on truth. I look forward to hearing from you.

Yours sincerely
 
 
 
 

Paul Smith

cc:
The Right Honourable Oliver Letwin MP
House of Commons
Westminster
London SW1A 0AA

Dear Mr Gifford,

I see displayed on the Internet at http://www.pacts.org.uk/Collins.htm, a letter you sent to Tim Collins MP on 2nd July 2003. I also note that you have not replied to my letter of 1st June.

Again you support your anti-car assertions with limited, incorrect and flawed research.

You talk about raised speed limits in the USA and reference 1990 research, but I’m quite sure you are aware that the American national speed limit of 65mph was repealed in 1995. Since then American road safety trends have been good – better than ours in the UK. Why are you attempting to mislead? Why are the unrestricted German Autobahns twice as safe as the Belgian speed limited motorways? Is it speed that makes the difference there? Why do you think that speed limits and speed enforcement are the crucial factor here?

You talk about Traffic Calming and state quite correctly: “Hit by a vehicle travelling at 35 miles/h a pedestrian is twice as likely to be killed than if they were hit by a vehicle travelling at 30 miles/h.” The same research puts the likelihood of death for a pedestrian in a 30mph impact at about 50%. But of course you neglect to mention that although the latest official speed survey reports 59% of car drivers exceeding 30mph at sample sites, under 2% of pedestrians hurt in accidents actually died in 2002. And that 2% applies to all roads and all speed limits. Why didn’t more than 50% die Mr Gifford? Could it be because impacts at free travelling speeds are rare? Impacts at free travelling speeds are rare because of correct driver responses. Tiny improvements in average driver responses will clearly make a significant difference – but excessive enforcement and restriction will reduce driver responses – you are planning to make the roads more dangerous with your flawed policies.

You talk about speed cameras and trot out again the patently absurd claim: “…deaths and serious injuries had fallen by 35% on roads where speed cameras had been in operation”. Do you really believe this tripe? Rest assured that I am taking the matter up with the authors of the report, but the lion’s share of the claimed reduction is quite clearly a “regression to the mean” benefit illusion.

You talk about sleep-related accidents, and rightly point out that sleep related accidents should be a matter of considerable concern. But I presume that you have never bothered to discuss the matter with skilled or experienced drivers because they virtually all report that lower speeds tend to promote drowsiness. I think it’s very clear that Loughborough Sleep Research Centre are no experts in driving or road safety. Raised speed limits at night on suitable roads will undoubtedly reduce sleep-related accidents, but I agree that proper research is required to verify the point. 

Finally you reference your own document about “the speeding problem”.  You clearly believe that reducing the average speed of traffic will make the roads safer, but the evidence in support of the idea is scant and flawed. To begin with, faster roads are quite clearly safer than slower roads, with the fastest of all being the safest of all. You will probably be reaching for your well-read copy of TRL421 at this point, but I recommend throwing it away because it isn’t even worth the paper that it is written on. See this web page as a clear illustration of how the TRL find themselves completely unable to defend the bizarre claims it makes: http://www.safespeed.org.uk/trl.html.

It is transparently obvious that you pay no attention to the factors that made the UK roads the safest in the world in the first place – you probably don’t even know what they are. You are encouraging a road safety policy that has already destroyed a very long-term beneficial trend in the UK roads fatality rate, and the effects on the serious injury rate are now becoming apparent.

I look forward to hearing from you.

Yours sincerely
 
 
 
 

Paul Smith

cc:
http://www.safespeed.org.uk/pacts.html [this page]
The Right Honourable Tim Collins MP
House of Commons
Westminster
London SW1A 0AA

Dear Mr Gifford,

Thank you for your letter dated 14th July. I note that you have not addressed any specific points raised in either of my letters.

I broadly agree with the content of your letter except for the last paragraph. You suggest “in the context of speed policy and I fear that there is little that we can find to agree or debate in a meaningful way”. I would like to challenge that statement with two important sample questions. I would very much appreciate direct answers in the hope that we can build a greater understanding in the interests of UK road safety. 

I have chosen my sample questions because I believe that they represent cornerstones of the “speed kills” myth. I agree that speed is deadly. The myth comes from trying to measure the danger in miles per hour without adequate regard for the circumstances. The circumstances are so very fundamental to the degree of danger that speed expressed in miles per hour is not usually a worthwhile measure. Now if we had policies that encouraged or enforced appropriate speeds we might well be able to make a real difference.

That is not to say that I would advocate the abolition of speed limits – far from it – speed limits are good and we need them. Rather I would prefer to see intelligent enforcement of the speed limits with due regard for the circumstances and the danger. But the worst thing about modern speed enforcement is that it is so frequently a replacement for real road safety policies. 

Pacts frequently quotes from TRL421. I have studied TRL421 and find a range of serious flaws. The most fundamental flaw is that nothing in the report establishes that the observed speed accident relationship is a causal one. I have conducted correspondence with Dr Susan Sharland, Chief Executive of the TRL in the hope of understanding how this serious scientific error arose. From her replies it seems clear to me that they have no defence to offer. The correspondence can be viewed on the Internet at http://www.safespeed.org.uk/trl.html

Will you either a) give me an undertaking to stop quoting headline conclusions from TRL421 or b) explain to me how the headline conclusions are supported by the research content of the report?

What approximate percentage of excessive speed accidents do you believe take place entirely within the speed limit?

I look forward to hearing from you.

Yours sincerely
 
 
 

Paul Smith

cc:
http://www.safespeed.org.uk/pacts.html [this page]
The Right Honourable Tim Collins MP
The Right Honourable Oliver Letwin MP