Re. Public consultation on government’s Road Safety Strategy 2021-2030

Madam/Sir,

Thank you for the opportunity to submit input to the forthcoming Road Safety Strategy 2021-2030. Fatalities on Irish roads decreased over the last decade, but at a much slower rate than previously. In addition, it appears that fatalities in this current three-year period will not show significant reductions.

International research suggests that evidence-based campaigns should be at the heart of any future strategy. The ‘Recommendations of the Academic Expert Group for the 3rd Global Ministerial Conference on Road Safety’* are a useful starting point in this regard. It advocates a Safe System approach. This involves accommodating human errors; limiting crash forces; and ensuring designers and maintainers share responsibility for safety with road users. It also requires the proactive improvement of roads and vehicles as part of a safe system, and a requirement that safety should not be compromised for the sake of other factors with zero deaths as a primary. Focus.

It recommends a modal shift to walking, bicycling and low speed powered two- or three-wheelers, and notes that the health benefits of increased physical activity far outweigh increases in safety and health risks associated with walking or bicycling.

Last February, I attended the Third Global High-Level Conference on Road Safety, where countries, including Ireland, came together to adopt The Stockholm Declaration**. The Declaration commits countries to the next stage of road safety guidelines that fall in line with the 2030 Sustainable Development Goals (SDGs) and is a useful reference in the formulation of a new Irish Strategy.

The Road Safety Authority should ensure the recommendations to national authorities made by the European Transport Safety Council in their 2020 report ”Ranking EU Progress on Road Safety: 14th Road Safety Performance Index Report’ are implemented in full.

In addition, I suggest the following proposals should inform the State’s next Road Safety Strategy.

Adopt a ‘Safe Systems’ approach

Sadly, many roads have been designed for speeds that are unsafe and take insufficient account of the needs of pedestrians and cyclists. The Road Safety Authority should work with all stakeholders to upgrade existing infrastructure to an adequate level of safety.

The review of design standards so that new roads are built according to Safe System principles is also essential and the Authority should work with Transport Infrastructure Ireland, the National Transportation Authority and other bodies to achieve this.

Lower safer speeds and more enforcement

The Road Safety Strategy must be explicit in calling for sufficient Garda resources to be directed towards road safety. The RSA’s own figures show that the majority of drivers break the speed limits, and the chances of being caught are low. The RSA must be explicit in calling for more Garda resources to be applied to speed enforcement. If it fails to achieve this objective, high numbers of people will continue to be killed every year on Irish roads.

The Authority should work more closely with An Garda Síochána to increase enforcement and produce statistics to show how much enforcement is carried out. I note that there is little evidence to date to show that enforcement is being given sufficient priority in 30 km/h zones.  

The RSA should work with the Department of Justice, the Department of Transport and other stakeholders to rapidly introduce red light running cameras as are commonly used in the UK to enforce speeding in urban areas.

The Strategy should seek the introduction of a 30 km/h speed limit in urban areas and should further promote Safe School Zones, and 20 km/h speed limits in areas close to where children congregate. It should also seek greater enforcement measures for drivers of vehicles that park on the footpath, in disabled parking places or in cycle lanes.

It should promote measures that encourage road users to upload camera footage of dangerous driving to An Garda Siochana for subsequent prosecution.

Sustainable mode shift

The ‘Recommendations of the Academic Expert Group’ highlight the need to encourage modal shift, and this should be at the heart of the RSA’s policies. Being overweight or obese is a far bigger risk than being injured on the roads and any future road safety Strategy that fails to encourage a modal shift to active mobility would be deficient. Encouraging ‘active travel’ modes can also reduce air pollution, another major health risk and cause of premature mortality. Walking and cycling produce low levels of greenhouse gas emissions, and therefore contribute to improving the safety of all in the years ahead. In addition, if more people walk or cycle, they will represent less of a threat to other road users as their speeds are low.

Promoting modal shift requires safe infrastructure. The RSA should actively encourage local authorities to provide safe segregated cycling infrastructure, and this should form part of the strategy. Simple road marking changes should be promoted, such as the common ‘2 minus 1’ – design used in Denmark ‘Cycling and Safety Measures in Danish Road Standards’ ***.  In addition, the RSA should advocate for a presumed liability for the drivers of motorised vehicles in urban areas as is common on mainland Europe. This appears to be a significant determinant in improving driver behaviour.

Improve statistics and evidence

The Strategy should seek more timely release and improvements in the statistical information relating to collisions. It is hard to plan when statistics aren’t published until many years have elapsed after collisions have occurred. The difficulty in accessing statistical breakdown for each of the Dublin Local Authorities is an impediment to taking action. Resources need to be applied to converting statistics for Garda regions to local authority areas. However local authority boundaries should not dominate the publication of statistics, particularly for smaller counties.

More in depth analysis by age group, speed limit areas, position on road, and speed of vehicle are required.

In addition, placing the evidence base for campaigns such as promoting the wearing of high visibility clothing should be seen as a prerequisite prior to proceedings with such initiatives.

Focus on Children

Rather than focusing on suggestions such as Professor Alf Nicholson’s presentation **** to the RSA urging ‘adequate supervision of children’ , or the promotion of high visibility clothing the RSA should focus on making the external environment safer for children by reducing traffic speeds and providing quality walking and cycling infrastructure. As the ‘Saving Lives’ report suggests: “If children cannot walk or bicycle to school without risking their lives, we limit their access to education, good health and freedom, and consequently our hope for the future.”

The RSA should ensure that all children are given cycling training in primary and secondary schools under the Cycle Right programme. It should also work more closely with the Green Schools Programme to prioritise improvements in physical infrastructure. Promoting the wearing of high-visibility clothing is no substitute for improvements in physical infrastructure and driver behaviour.

The RSA therefore should work to improve the physical environment and make it safer for, rather than limit the independent spatial mobility of children. It should also consult with children in the preparation of their strategy, perhaps through Comhairle na nÓg, the Green Schools Programme of An Taisce or similar bodies.

Many thanks in anticipation of your consideration of these suggestions.

Sincerely,

Ciarán Cuffe

MEP for Dublin

References

*SAVING LIVES BEYOND 2020: THE NEXT STEPS Recommendations of the Academic Expert Group for the 3rd Global Ministerial Conference on Road Safety

https://t.co/d4ZwGwAmzD?amp=1

**Stockholm Declaration. Third Global Ministerial Conference on Road Safety: Achieving Global Goals 2030. Stockholm, 19–20 February 2020

https://www.roadsafetysweden.com/contentassets/b37f0951c837443eb9661668d5be439e/stockholm-declaration-english.pdf

*** Cycling and Safety Measures in Danish Road Standards’. Anders G. Road Safety Expert. https://www.tii.ie/tii-library/conferences_and_seminars/nrc/nra-nrc-2016/6_2-Anders-Mollor-Gaardbo-2016-TII-Bicycle-Safety-DK.pdf

**** ‘Road Safety and Children, Where are we now’. Nicolson, A, 2015 https://rsa.ie/ga-IE/RSA/Sabhailteacht-ar-Bhoithre/Seimineair/Seimineair-Reatha/Children-and-Road-Safety/Presentations/