INITIAL RESPONSE

20-April-2022 @ 19:00

Cc: Cllr Mike Green (Transport Portfolio Holder), Cllr Drew Mellor (Council Leader), Cllr Mark Anderson (Ward), Cllr Cheryl Johnson (Ward), Dorset Police & Crime Commissioner

Dear Mr B,

Thank you for your email dated 14 April 2022 to Cllr Mike Greene and others, containing what I consider a very comprehensive report setting out your concerns about traffic speeds and the risk of accidents in Queens Park Avenue.

Your email has been passed to me as BCP Council Road Safety Team Leader for a response.

Road Safety Report Updates

I note that your pdf report makes reference to previous correspondence with my colleague Mr Richard Pearson which occurred between May 2014 and January 2020. As you state Mr Pearson has set out how casualty data is used to prioritise investment and inform strategy and how he has made reference to the BCP Council Road Safety Report.

For the sake of completeness here is a link to the latest version of that report.

https://www.bournemouth.gov.uk/travelandtransport/TransportDocs/Road-Safety-Report-Final-Published-2021.pdf

In addition to this we have recently published a guidance document which sets out how we address applications for minor transport schemes, which is effectively a process by which we categorise requests such as yours.

Here is a link to that document for information.

https://www.bcpcouncil.gov.uk/Roads-and-transport/Road-safety/Documents/Minor-Transport-Scheme-Request-Guidance.pdf

In terms of an overarching approach, BCP Council is lead member of a Strategic Partnership of all those involved in reducing road casualties across Dorset and we have signed up to the following Strategy Document.

https://www.bournemouth.gov.uk/travelandtransport/TransportDocs/Dorset-Strategic-Road-Safety-Partnership-Strategy-2021-2030.pdf

As you will see from this the Partnership has set a challenging target with a vision of zero Killed or Seriously Injured on Dorset’s roads by 2050 and we are actively pursuing that target.

I trust that the above information is of assistance and I will now endeavour to respond to the various issues raised in your report.

Accident Analysis

Firstly, in terms of road traffic injuries the Council looks at the most recent 5-year period for which Police records are available. Here is an accident plot of the area showing injury collisions over the period from 01/01/2017 to 31/12/2021.

As you will see from the far right hand column BCP has experienced over 4,000 road casualties over this 5-year period including 25 fatals and 637 serious injuries.

I note that your report incorporates crash map data showing accidents over the last 23 years but as I mention above we capture the most recent five-year data when prioritising investment in road safety.

We do this partly to make the analysis/number crunching more manageable and partly because over time trends will change as road layouts alter, traffic finds different routes or previous road improvements take effect.

I apologise if I am repeating what Mr Pearson may already have pointed out in previous correspondence but in terms of the way the Council determines which road safety schemes we carry out we do follow established national practice.

Put simply, at locations where risk is noticeably higher than the general level of risk on the local road network, there is a greater chance, for whatever reason that accidents will tend to cluster at these locations. This is why we treat individual cluster sites with engineering schemes.

The particular engineering treatment selected will depend on the specific pattern and causation factors at each location, which is determined from Police collision data. Any less than 5 years’ worth of data is not statistically significant to determine if there is a cluster effect and any greater periods means the long term effect of road layout changes will tend to be more influential.

Cluster sites are determined by the variables selected by the operator but whichever method is used it is evident, unfortunately, that this area is not a priority for our team, as there is only one slight injury accident recorded in this area during this period.

Vehicle speeds

In response to your comment on page one of your report about 30 mph repeater signs, local authorities are not permitted to erect repeater signs on roads with a system of streetlighting. The presence of lighting is deemed to indicate to drivers that there is a 30 mph limit in force and this is set out in the Highway Code.

I was interested to see the methods used in the report to capture traffic flows and speeds; it was not a technique I had come across before. As you might imagine the council uses many permanent Automatic Traffic Counters  (ATCs) which have been deployed at critical points across the highway network, as well as recording information obtained from manual traffic counts and mobile Speed Detection Radar (SDR) units erected on street furniture. All of the information thus obtained is kept on a central database and we do in fact hold historic data for this location.

Firstly, here is a summary infographic of the site location showing average traffic flows for this road. I’m not sure what happened to affect the readings in 2016 but it could have been down to roadworks or nearby road closures.

Secondly, here is a chart indicating recorded vehicle speeds for the road averaged over a 24-hour period.

As you will see from the smaller chart above, average speeds vary between 22.2 and 29.9 mph over time.

I am not sure why these readings stopped in 2018 but I would not expect them to have changed that much over the intervening period. As with all other residential roads there will be times when the speeds recorded are higher or lower than these so it would not be unusual if there are higher readings at 2.00am when there is much less traffic about.

As mentioned above I have not come across the method of collating vehicle speeds that you have used but they do not appear to be consistent with the data collected by our ATC’s; data which is supplied to the Department for Transport on a regular basis and which is used in compiling nationally published statistics. I am not saying there is no speeding taking place but I am just indicating that it is not really evidenced by our equipment.

Speed Enforcement

As you also highlight the road is already subject to police enforcement. Here is a table showing recent mobile camera enforcement activity undertaken by Dorset Police indicating the number of speeding offences detected during those visits (an average of 10 speeding vehicles detected on each visit).

Conclusion/Response to Report Outcomes

In terms of your expected outcomes, I would suggest that the above response constitutes a comprehensive study of the area that concerns you. We would usually only thoroughly investigate cluster sites which meet our criteria and we simply do not have the resource to be able to investigate every site of concern to residents in this sort of depth.

I can see that you are asking for constructive action and I am trying to end this reply on a more positive note.

I have already raised your concerns with Dorset Police and no doubt they will consider further enforcement in light of your report. I see that in the email below you have raised concerns about the new digital cameras and I will certainly pass on these comments.

In addition you may wish to consider setting up a Community Speed Watch group in this road; apologies if you have already explored this avenue. More information can be found here:

https://www.dorsetroadsafe.org.uk/enforcement-operations/community-speed-watch/

I understand that you are concerned about the potential for injury on the road and that potential exists in every road which is open to traffic – closing a road is the only way to be certain that the risk is minimised and that is clearly not an option in this case.

I would like to reassure you that we carry out an analysis of the whole road network on an annual basis and should the situation deteriorate here we will certainly draw up measures to investigate the problem.

I am sorry that this is probably not what you wanted to hear but I trust that it goes some way to addressing your latest concerns and hope that it is of interest.

FOLLOW-UP REMARKS

21-April-2022 @ 14:35

Cc: Cllr Mike Green (Transport Portfolio Holder), Cllr Drew Mellor (Council Leader), Cllr Mark Anderson (Ward), Cllr Cheryl Johnson (Ward), Dorset Police & Crime Commissioner

Dear Martin,

Thank you for your lengthy response. In my humble opinion it simply supports my previous criticism that road safety within BCP boundaries is treated as an academic exercise.

I am also very disappointed with facetious comments like "closing a road is the only way to be certain that the risk is minimised”, although I am not entirely surprised given Richard Pearson's condescending comments in 2017 around being unable to prioritise “where people are shouting the loudest”. However, I do expect more from a senior officers in the Road Safety team, because these attitudes indicate the seriousness in which the speeding issues in the conurbation are taken. I am sure you get lots of requests for engineering works that need to be given a straight bat from time-to-time, but that does not mean the requests are without merit, and considering I have highlighted a major problem (at my own expense) it does feel rather flippant.

When a person is eventually killed along Queens Park Avenue by a speeding driver, comments such as these would be very damaging for BCP if they were to appear in the press. Now that I have pointed that out, I am sure some of your politically-minded colleagues in Cc are now squirming at the thought that they may be associated with such a comment, especially if failing to wield their influence is de facto support for this point of view. Not a great look with the voting public, and given recent Cabinet meeting committments to safer walking and cycling routes, this is clearly a significant political issue from a Local Government perspective.

Turning to your response below, these are the main points of contention:

• I am assuming the Automatic Traffic Counter (ATC) you refer to is the grey box within 50ft of the speed camera on the southern verge by the golf course’s 3rd tee. Of course it is going to capture low speeds, people are slowing down before they reach the speed trap.

• You have recognised your data is incorrect. The data is incomplete and inaccurate, so it is hard to see how this could in any way justify inaction. Assumptions around roadworks and the situation not changing are not enough.

• I have no issue with aiming to reduce injuries or deaths, and an approach must be taken. However, your approach uses lagging data. I am offering leading data that indicates a significant problem in a very specific area.

  • Lagging indicators are negative and are premised upon the understanding that safety is the absence of bad.

  • Safety being the absence of bad makes you hunt for bad. It makes you look for bad things. It makes you look for deficiencies. It makes you look for non-compliances.

  • A real-world example of why lagging indicators are bad and not too dissimilar to your approach: BP had a fantastic safety record at the time of the 2010 Gulf of Mexico oil spill, having just won a safety award weeks before. But the investigation report highlight that BP focused too narrowly instead of looking at big systemic hazards.

• You have recognised that “Cluster Analysis” is only as good as the operator. This means it is open to confirmation bias and could be manipulated to justify site selection by simply zooming out on a map until enough incidents are available in the surrounding area.

  • The different methods of clustering usually give very different results

  • With the exception of simple linkage, the results will be affected by the way in which the variables are ordered.

• With respect to not being familiar with the method used to obtain my data. I appreciate that the public sector tends to lag the private sector from an innovation perspective but this data is readily available and highly reliable. 

  • It is used in all modern sat nav and mobile devices to offer alternative routes when traffic flow along a chosen route is slowing or stopped. 

  • There is a wide array of peer reviewed academic literature that support the use of bounding box flow data.

  • This method is battle-tested in real world applications such as supply chain management.

I asked Cllr Greene the same question the other day, so perhaps it has yet to cross your desk. What I would like to know is why engineering works were undertaken on Braidley Road between the Wessex Way under bridge and Bourne Avenue roundabout? It would seem that these works cannot be justified using the method you have outlined in your response so an exception must have been given to prioritise a scheme on your office doorsteps ahead of high casualty sites.

https://www.bournemouth.gov.uk/travelandtransport/projectsconsultationslocaltransportplans/projectsconsultations/HighwayConsultations/Consultations/november-2016-braidley-road-bourne-avenue-avenue-road-improvement-scheme-residential-disabled-bays.aspx

The consultation information on the BCP website only appears to relate to excessive speeding in the area. Not dissimilar speeds to those recorded in Queens Park Avenue. According to Crash Maps, there has only been 1 slight incident in this location on 27/10/2011, and expanding further there was only 1 serious incident involving a motorcycle on 26/08/2012 on Bourne Avenue. These works are not justified on the basis you have outlined below as it would not have even registered as a cluster site.

Perhaps you could undertake the same analysis on the area of Queens Park Avenue I have highlighted as was done on Braidley Road?

Resources I have made available to you:

• A website that outlines these issues and has up-to-date statistics: HERE 

• You are also able to view the up-to-date metrics in a dashboard: HERE

Given the obvious flaws in your methodology and the precedent set at Braidley Road, I would hope you could consider undertaking an appropriate study of the area in question. I have provided all the necessary data for you to be able to make it an efficient exercise in terms of time and cost.

SUBSEQUENT RESPONSE

21-APRIL-2022 @ 19:00

Cc: Cllr Mike Green (Transport Portfolio Holder), Cllr Drew Mellor (Council Leader), Cllr Mark Anderson (Ward), Cllr Cheryl Johnson (Ward), Dorset Police & Crime Commissioner

Dear S,

Thank you for getting back to me so promptly. I am sorry that you appear dissatisfied with my response to you and have come back with further comments and questions. Please be aware that the road safety engineering team is small (three members of staff currently) and on average we receive over 600 individual requests each year from residents (and Ward Members) all calling for engineering interventions. The fact that we have to respond to each and every request in a fair and equal manner means we often have little time left over to carry out the detailed level of accident investigation, research and prevention that we would like to do and that the situation dictates.

There are approximately 800 miles of adopted public highway in the BCP district so we have to have some rational/equitable way of determining where the greatest risk lies and I am sorry if that appears to be taking an ‘academic’ viewpoint. For example, the annual risk of a pedestrian injury anywhere across all of BCP Council’s roads is low at around 2 per 10,000 population per year.

I am also sorry that you find some of my comments unacceptable. I am a professional Chartered road safety engineer with over 25 years’ experience in this role. I have visited the site of every fatal road traffic accident in Poole since 1997 so I feel qualified in determining what contributory factors can lead to road fatalities and how best to prevent them occurring within the budget allocated for this purpose.  There are a myriad of ways of physically calming traffic using engineering interventions but what these will do is reduce the frequency and severity of crashes; what I meant by my comment was that we cannot eliminate these incidents completely unless the road is closed to motor traffic.

I note your comments about BCP Council’s liability in the event of an accident. It may be of interest to you that while the Council has a common law duty to repair and maintain the public highway, in all other respects there is longstanding court authority/legal precedent that road users must take a highway as they find it, that the highway network is imperfect and drivers must take due care in using it and ultimately that they are ultimately responsible for any negligence as a result.

The Council can’t be held responsible for the poor driving behaviour of some individual motorists who blatantly ignore the rules under which they carry a license to drive on the highway. Ultimately all drivers who use our roads are responsible for their own actions and the way they drive; ignorance of the Highway Code is not a defence. Motorists are responsible for driving within the law and as circumstances dictate. Unsafe driving or manoeuvring is not something we are forcing drivers to do; it is a choice some are making (unfortunately). This is a wider societal issue and regrettably there remains a core of motorists who think they can get away with driving antisocially, speeding or taking other risks.

Furthermore we are not “waiting for a number of accidents to happen” before taking further action. Accidents are random and rare events, but what that does mean is that we are concentrating our limited resources at treating locations where they are more likely to occur (i.e. the cluster sites). As I have said previously this is not just a BCP way of responding to concerns like yours; the majority of all local authority road safety teams nationally carry out similar assessments and base their programmes on comparable assumptions.

In response to the new issues you have raised below I would respond as follows.

• I can see that you have put a lot of effort in producing your report but I have no reason to doubt the results from our traffic counters. We do not have the resources to carry out many ad hoc speed surveys across our road network each year but I will certainly ask the team responsible for collecting traffic data to arrange for another survey to be undertaken in due course.

• Yes, we do look at historic traffic accident data as that is really the only fully validated information we have to go on and it does enable us to carry out detailed statistical and cluster analyses. Conflict studies, which I believe are the sort of thing you are referring to, are by their very nature confined to one very small section of the network and are very time consuming and resource hungry. This approach does not allow us to take a strategic overview of how the whole network is performing and how we can address emerging issues. I will look again at the links you have provided and se if there is merit in further investigation.

• In terms of keeping up to date I do my best to ensure that my team has Continuing Professional Development as a central part of their personal development. We use companies like Agilysis for this training, one of the industry leaders in road safety research and analysis. Here is a flavour of some of their recent publications. https://agilysis.co.uk/publications/

• In terms of the Braidley Road measures I would have to admit that these were installed before I joined BCP Council from the Borough of Poole so I am personally not fully aware of the background. Having said that not every scheme BCP delivers is funded through the road safety team’s Travel Safety Measures budget. There are a number of other categories through which they can be delivered, such as the Local Transport Plan, Sustainable Transport, Highway maintenance etc. and, more recently through projects such as the Transforming Cities Fund which you may be aware of. Each project will have had its own justification for inclusion in the Capital Programme from whichever pot the scheme was deemed justified. From the link you have provided I would be content to assume that this was primarily funded from the Cycling and Walking budget but obviously it has road safety elements, as moist highway improvement schemes will do.

• Finally I see that you have provided further links etc. but in my opinion I personally think there is unlikely to be anything here that would indicate further interventions or investigations can be justified at present.