Clause

Comment

3.2(6)(c)

We are concerned about the practical implications of requiring "safe and appropriate traffic engineering measures" to enforce speeds <50 km/h. Although often very desirable, this requirement may impede RCAs from actually implementing such zones or absolve them from using education and enforcement methods as well. We see no reason why the criteria that apply to setting other speed limits can't be sufficient, e.g. character of surrounding land-environment, function of road, road user activity, etc. We also have some concerns that many typical traffic engineering measures employed in the past have in fact been detrimental to the safety of cyclists, e.g. narrow chicanes without cycle bypasses.

We also have strong reservations about the requirement for mean operating speeds to be no greater than 5 km/h of the posted speed. Given that the available speed limits are in intervals of 10 km/h, this may be technically difficult to achieve every time for a start. The surveyed speeds are also likely to be highly variable depending on traffic volume, time of day, and location along the street. If the RCA and local community feel that the desired speed limit is appropriate for them, then other tools should be employed instead to achieve the desired mean operating speeds. For example, increasing enforcement, or local education & promotion. It is also difficult to see how the actual mean speed can always be accurately predicted, prior to the speed limit change.

3.2(8)(b)

It is not clear why specific parties need to be mentioned here, when the Rule states that any person "affected" by a speed limit can make a written request. The practical effect seems to be that some requests will be taken more seriously than others will. The fact that the only named road user groups are the Automobile Association and the Road Transport Forum continues the impression that these are the only road user groups significantly affected by speed limits. The specific mention of organisations and positions also opens this clause up for future redundancy, should the structure of these groups change (e.g. we believe that the RTF used to be the Road Transport Association). We suggest that an all-encompassing "road user group" clause be used instead, e.g.

(iv) a road user group such as the Automobile Association, Road Transport Forum, or Cycling Advocates Network

4.1(3)(a) (ii)

The term "traffic" is used by many to indicate motorised traffic, so this point should be explicit about referring to "motorised traffic, cyclist and pedestrian conditions".

This comment also applies to clauses 5.2(1)(a), 5.3(2)(b) and 6.2(1)(a).

7.1(2)

Again, as with 3.2(8)(b), we express our concern that the AA and RTF are the only road user groups that must be consulted. This continues the trend of marginalising the impacts on cyclists. It would also seem more practical and timely for the local branch of a road user group to be contacted rather than consulting the national executive first. We suggest that you remove clauses (e) and (f) and replace them with:

(e) all local road user groups that could be affected such as the Automobile Association, Road Transport Forum, or Cycling Advocates Network

8.4(2)

In our recent submission to Transit regarding the COPTTM, we highlighted the hazard to cyclists from leaving temporary sign stands in place on the road until their next use. While we concede that this is not relevant to the legality of the speed limit, it is an important safety concern that should be stated at all opportunities. Therefore we suggest that this clause be amended to read:

A person... must remove the sign and associated support materials (e.g. stands, sand-bags) immediately...

Table 8.2

Given the more hazardous road environment (e.g. road works) usually associated with temporary speed limits, and the difficulties often found in enforcing them, we suggest that the spacings for temporary speed limit repeater signs be halved, i.e. a repeater sign for every one minute of driving at the posted speed.

We note that the draft COPTTM specifies a constant 400m spacing, regardless of speed. This needs to be reconciled with what is put in the Rule.

Clause

Comment

We reiterate our concerns from 3.2(6)(c) and ask that similar changes be made here regarding 20/30/40 km/h speed limits.

We also refute the notion that an arterial or collector road could not successfully have a speed limit below 50 km/h, particularly if these streets are also major residential, shopping or business streets. It is precisely these types of streets where lower speed limits are needed, as high traffic volumes are combined with high pedestrian and cyclist numbers. Australian studies, quoted in a Bicycle Federation of Australia report ^[2] , support this and the practice is common in Europe.

2.5

If cyclists are expected to mix with motorists unprotected on arterial traffic routes, then RCAs should not be allowed to raise speed limits to 60 km/h. Therefore another example of a "necessary design feature" should be "the presence of adequate cycle facilities, such as cycle lanes."

2.7

The first bullet point suggests that a good reason to reduce a speed limit from 100 km/h to 80 km/h is "considerable cycle, school or pedestrian traffic". CAN would strongly suggest that such conditions often require a speed limit rather less than 80 km/h.

Narrow bridges are a common concern for cyclists. We suggest that for long narrow bridges in rural areas, 80 km/h speed limits on the bridge and approaches be recommended. What constitutes "long" or "narrow" varies from person to person, but even a 100m-long 7m-wide bridge with moderate traffic would be considered hazardous to most cyclists. In some cases, depending on the bridge dimensions, road user mix, and adjacent development, an even lower speed limit may be more prudent.

Many rural unsealed roads are also highly unsuitable for 100 km/h speeds, resulting in numerous crashes to both familiar and unfamiliar drivers alike. We suggest that SLNZ also considers the road surface of the proposed road and that 80 km/h be considered for unsealed rural roads (if not in fact made mandatory for all of them).

3.4

It is not clear what happens if the mean & 85th percentile speeds are more than those specified for a posted speed. A tacit response may be to "review" the speed limit upwards to comply, meaning that bad driving habits (i.e. greatly exceeding the speed limit) influence policy. However in many cases, we suspect that the community feels that the existing speed limit is appropriate for them, and other tools should be employed instead to achieve the desired mean & 85th percentile speeds. For example, increasing enforcement, local education & promotion, and engineering measures. CAN strongly recommends that these options be clearly spelt out here.

3.5

Crash rates are often misleading, as they are only derived from the people who choose to use the road. Many vulnerable road users may be discouraged from travelling along or crossing a certain road because of the existing motor vehicle speeds, resulting in a subsequently low level of crash problems recorded for them. Therefore we recommend that feedback should also be sought on whether the existing or proposed speed limit is discouraging pedestrians and cyclists from using the road.

3.6

We understand that Transfund are currently revising the Procedures for Road Safety Audit of Projects. Reference to the 1993 Transit procedures should therefore be updated.