NZTA Setting of Speed Limits Rule
Due in 16.6.17
Link to NZTA for consultation http://www.nzta.govt.nz/about-us/consultations/setting-of-speed-limits-rule/
To make a submission include NZTA Setting of Speed Limits Rule along with your:
Name, title ( if any), organisation (if any), postal and email address
Send to rules@nzta.govt.nz
Draft Submission from Spokes Canterbury
Spokes strongly supports NZTA in encouraging Road Controlling Authorities (RCA’s) to focus on speed management to yield safer transport.
Efficiency must be second to safety. Efficiency considerations must be comprehensive and include all road users. Priority setting and funding decisions must remain with RCA’s.
NZTA AND RCA’s
Formalizing NZTA as the central entity for assessing and identifying roads nationwide to allow for standardized speed limits is appealing. That RCA’s will continue to have the power to choose what roads receive their attention and funding is fundamental. Local knowledge and local needs can benefit from NZTA’s work, so long as the focus and response to meet local conditions and needs is paramount. In support of this NZTA should provide block funding rather than offering funding for NZTA favoured projects.
NZTA can perform a valuable service in helping RCA’s to prioritize the roads which will best benefit. Mandatory criteria should be limited to limiting the number of speed limit designations, 50, 80, 100 km/h in line with the goal to standardize speed limits nationally and the provision of maps indicating opportunities for speed adjustment. RCA’s must have the power to set lower speeds if they so wish.
Inclusive Participation Assured
Spokes supports NZTA’s role as an advisory agency for safe and appropriate speed for each type of road. With such a broad power NZTA will need to institutionalize inclusion of the needs and voices of all road users’: Pedestrians, The disabled, Cyclists, Motorcyclists, Car drivers’, Truckies’, etc. It will only be through working out issues together that a consensus on what is safe and efficient can be established.
It is noted that in developing the ‘Speed Management Guide’ business interests were consulted but road safety, walking and cycling groups appear to have been neglected. This oversight provides the impetus and opportunity to make permanent a Cycle Advisory Panel at NZTA. It will be vital for this panel to have the power to review and guide current and future policy and projects.
Road Policing
NZTA and RCA’s will need to receive cooperation from police if lower speeds are to be achieved. This may well require more funding for road policing. NZTA is encouraged to make this a strong component of this rule making and to advise government to fund accordingly.
110 km/h Limit
Spokes has strong reservations with the increase to 110 km/h. It is highly likely that safety will be compromised for very questionable efficiency outcomes. Spokes understands that the higher limit will apply only to roads with the ‘best’ infrastructure. The benefits of improved road and vehicle safety features are limited when an accident occurs at high speed. The minimal claims of efficiency do not warrant the increased risk.
Quoting from the frequently asked questions supplement, “For an individual driver, travelling faster doesn’t save much time. Other factors such as traffic lights, congestion, and intersections have a far greater influence than maximum travel speed. The roads that can support a 110km/h limit aren’t affected by these factors. They allow for smooth and consistent travel, which means an individual road user is estimated to save around 30 seconds on a 10km stretch of road travelling at 110km/h rather than 100km/h.”
This ignores congestion and the fact that the higher limit will get drivers to an intersection or junction to wait for traffic to clear or a light to change 30 seconds faster. Even if more roads will offer the higher limit for greater distances congestion and tail backs when lower speed roads are reached is not addressed. Encouraging increased preference for driving with the illusion of faster travel times has serious safety, economic and environmental impacts. The Kapiti Expressway is one example of the questionable benefits and high cost of this approach to transport ‘efficiency’.
It is claimed that pollution will be mitigated as the 110 km/h limit will only apply to some roads and people will be encouraged to cycle or use public transport. Without a major shift in transport spending to support public and active transport this is a spurious assertion. This is especially disingenuous as the benefits of the higher limit are promised to be enhanced by adding more additions to the high speed network. Funding is simply not available to accommodate all these projects.
Central median dividers decrease head on collisions, but where side barriers are also installed careening cars tend to result in increased property damage and injury as well as the inefficiency of roads closed due to accidents. The consultation document does not include information allowing an assessment of this risk. Has NZTA investigated and factored in the costs?
The proposed rule also fails to factor in the costs to the country from the increased resource use, ACC claims and infrastructure maintenance and capital costs required by the higher limit.
The appearance of higher speeds being offered as an election year inducement to voters is inescapable.
Measuring Efficiency
Spokes is concerned that increased speed not be equated with efficiency. Should this attitude carry over to urban streets the impact this proposal could have on people who cycle could easily be catastrophic both personally and for the country. Even if increasing speeds lead to ‘mere’ monetary damages to cyclists the psychological impact could easily be a deterrent to cycling. The resulting personal costs not limited to increased transportation expenses but to degraded personal health as well. Fatalities would compound this impact. The costs to the nation for increased demand for motorised transport and health costs are real, if difficult to quantify. Any efficiency gains are easily lost and congestion would lead to further declines.
Proposals
Spokes appreciates that proposal 1 makes clear that speed setting is to ‘achieve safe and appropriate travel speeds’. It is important that it be made clear that this is not to be undermined by misinterpretation of the following sections ‘It aims for higher speeds on higher classification, economically important routes…’ ‘…managing safety through low cost improvements or lowering the speed limit where necessary on lower classification routes.’ Safety should never be relegated to ‘low cost’ or ‘where necessary’.
If the emphasis is on safety and good practice it needs to be made very clear. Safer Journeys offered technology as a key driver for safety. Technology can offer benefits, often at very high cost. This is not always efficient, affordable or offering ‘value for money’. Humans are not always rational and lowering speed limits can be the most efficient, easily policed and cost effective approach to safety.
For consultation to be informed and effective Proposal 2, 110 km/h speed limit, needs information on the efficiency, safety, costs and alternatives. See specific concerns raised earlier in this submission. The information provided in the frequently asked questions document supplementing this process addresses some of the issues poorly and incompletely.
Proposal 5 covers the issues of road works and road degradation as factors which can be applied to temporary speed limits. It is not clear if RCA’s will be prevented from setting temporary limits at schools, for special events, etc. RCA’s will need this authority.
