Submission on Draft Rule 54001

Land Transport Safety

(Setting of Speed Limits)

Cycle Aware Wellington

Cycle Aware Wellington is an advocacy group working for improved conditions for cycling in the Wellington region. CAW liaises with local, regional and national authorities, and undertakes educational, safety, promotional and recreational projects.

General Comments

Estimates of the prevalence of cycling in NZ suggest that between two and five percent of journeys are undertaken by cycle. The disparity in cycling rates between NZ cities suggests there is potential for a considerable increase in the use of cycles.

Although there is an urgent need for more and more accurate data on cycle usage (and cycle crashes), cyclists are nonetheless an important �minority group� of road users, whose needs must be taken into account in transport planning and engineering.

Speed limits rarely have the intention or effect of altering cyclists� speed, but they are nonetheless of real concern to them. Motor vehicles generally travel faster than cyclists and come off best when both are involved in a crash. An increase in speed of motor vehicles tends to be associated with an increase in perceived and actual risk to cyclists and pedestrians. There is much international research on the effect of speed on injury and mortality rates in cycle crashes involving motor vehicles.

Use of 85th Percentile

The use of the 85th percentile in speed limit setting is oriented towards motorists. We believe it is inappropriate to use it as measure for setting speed limits in areas where there are many pedestrians and cyclists (or indeed where it is desirable to enourage more people to walk or cycle - most roads, in fact).

The 85th percentile reflects motorists� actual behaviour - their perception of the comfort and safety of a road is an important influence on their speed. Their perceptions may not be shared by pedestrians or cyclists, however.

Community Input

We wish to see Rule 54001 and Speed Limits NZ changed to enhance community and road user consultation in the process of setting speed limits.� RTS 17, the 1995 Guidelines to Changing Speed Limits, suggests cyclists need only be consulted if many cyclists use the road concerned.

CAW believes that cycle use should be encouraged as a means to improving the nation�s health and reducing the environmental impact of the transport system. If cyclists are reluctant to use a particular road, we would wish to see conditions altered, where practical, in order to encourage cyclists. This may include the setting of lower speed limits.

We believe there is a trend in NZ towards� removing cyclists (or pedestrians) from situations that are deemed hazardous to them, rather than taking steps to make the existing roads more cycle-friendly. Without an opportunity for input on issues such as the setting of a speed limit, this trend can only continue. This will do nothing to encourage cycle use - it is likely to have quite the opposite effect.

CAW wishes to see consultation with the community and road user groups in the setting of all speed limits, not just in the setting of a speed limit that is different from the calculated speed limit. (2.4, p.17) However, we do not believe it is sufficient to consult with list of organisations described in 2.4(2)(a).

Cyclists, pedestrians and bus operators are three groups of road users with a strong interest in the issue. We are concerned that if the proposed consultation process remains unchanged, the Director will not have these people�s views when making a decision as described in 2.4(2)(c)(II).

30 km/h Speed Limits

CAW strongly supports the introduction of a 30 km/h limit. (p.10) 30 km/h (or 20 mph) zones have been successful overseas in substantially reducing speeds and crashes in areas where they have been applied.

In a 1996 study of 20 mph zones in the UK ^[1] �found that the average annual accident frequency fell by about 60 percent. Child cyclist accidents fell by 48 percent after the schemes were installed. The reduction in accidents for all cyclists was 29 percent. Pedestrian accidents (child pedestrians in particular) showed an even more marked fall.

Vehicle speeds fell by an average of 9.3 mph overall, with the average speed �at a calming measure� being 13.2 mph and �between calming measures� at 17.8 mph.

A study of child pedestrian injuries in Auckland ^[2] found that vehicle speed over 40 km/h was associated with a threefold increase in the risk of injury. The average vehicle speed was in excess of the 50 km/h limit at 42% of the pedestrian injury sites in the study.

We do not believe it is necessary to trial the limits in NZ prior to their introduction. There is a wealth of research data from overseas on 30 km/h (or 20 mph) limits and practical information on their implementation. Appendix 1 to this draft Rule contains the basis of advice to NZ local authorities on setting 30 km/h zones and could be combined with overseas experience and included in Speed Limits NZ.

If it is decided to proceed with trials, we would wish to see a change to 4.8 in Appendix 1 (p.10). We believe that if �after� speed surveys show that the mean and 85th percentile speeds are not below 30 km/h and 40 km/h respectively, the LTSA should consider requesting additional or more appropriate active or passive enforcement of the 30 km/h limit.

We strongly support the suggestion (Appendix 1, 4.3) that the introduction of a 30 km/h speed limit should be considered as a part of a local area traffic management scheme or urban safety strategy, rather than in isolation.

We believe, however, that arterial, distributor and collector roads should not be deemed unsuitable for 30 km/h speed limits 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 ^[3] , support this.

The Auckland child pedestrian injury study (quoted above) found that there was a steady increase in the risk of injury as traffic volume increased. The risk of injury for children living in neighbourhoods with the highest traffic volumes was 13 times that of children living in the least busy neighbourhoods.

Maximum Speed Limit of 100 km/h

We support no increase in maximum speed limit. (p.12)

Minimum Speed Limits

Minimum speed limits might pose difficulties for cyclists! (p.22)

Robert Ibell

Co-Secretary

Cycle Aware Wellington (Inc.)

26 February 1998