Setting of Speed Limits 2024

Submission from Spokes Canterbury

Reference: https://consult.transport.govt.nz/policy/setting-of-speed-limits-2024-consultation/

Tēnā koutou katoa

Thank you for the opportunity to comment on the proposed Land Transport Rule – Setting of Speed Limits 2024.

Introduction

Spokes Canterbury (http://www.spokes.org.nz/) is a local Canterbury cycling advocacy group with approximately 1,200 followers. Spokes is affiliated with the national Cycling Action Network (CAN – https://can.org.nz/). Spokes is dedicated to including cycling as an everyday form of transport in the greater Christchurch and Canterbury areas. Spokes has a long history of advocacy in this space including writing submissions, presenting to councils, and working collaboratively with others in the active transport space. We focus on the need for safe cycling for those aged 8 to 80. Spokes also supports all forms of active transport, public transport, and has an interest in environmental matters.

Proposed Speed Management Changes

Spokes Canterbury strongly opposes the proposed changes to the setting of speed limits. We request that the Ministry of Transport recommend it does not proceed through further stages. The majority of people will cycle in places where they feel safe on the road. Both international and national research has clearly shown that the most effective way to encourage people to cycle and walk more is to reduce speeds.

Active transport comes with many co-benefits that have not been sufficiently taken into account. Economic and productivity benefit needs to take into account the health and wellbeing costs. Trying to increase perceived benefits in transport without taking into account cost and impact on health and families is counter-productive and a waste of taxpayer money.

Speed

New Zealand and international research show that reducing speeds is the single most effective, and often cheapest, way to reduce death and serious injuries on our roads. Spokes Canterbury supports slower speeds on all roads that do not have a separated cycleway, particularly around schools and in neighbourhoods, which can encourage more active travel choices as cyclists and pedestrians feel safer.

The research is clear that speed is a factor in death and serious injury crashes and the risk is significantly reduced by lowering speeds in neighbourhood streets. There is now growing evidence in Aotearoa, confirming international research, that reducing speeds has a significant impact on reducing deaths and serious injuries. (See fig 1)
There is a significant difference between being hit by a vehicle in a 50 km/h zone to a 30 km/h zone (see fig 2)
Reducing speeds on rural roads also makes a significant difference (see fig 1), including variable speeds at intersections.
Reducing speeds is much cheaper that building separated infrastructure for different modes of travel in urban settings.

Fig 1. Glen Koorey, 2023 Australasian Road Safety Conference, Cairns

Fig 2 Deaths and Serious Injuries at various speeds

Prof. Simon Kingham presentation, Sept 2022

Benefits of active transport and reduced Speed

There are strong economic arguments to reducing rather than increasing speeds

Reducing speed limits:

Encourages more people to walk, cycle and use other forms of active transport, which brings significant physical and mental health benefits. Active transport has been proven to decrease rates of diabetes, cardiovascular diseases and cancer, and improve mental health, which improves a person’s quality of life while dramatically reducing the burden on the health system.
Allows for the building of infrastructure that makes crossing of roads easier for active transport users, e.g. safe speed platforms or pedestrian crossings.
Reduces congestion by smoothing out travel speeds/acceleration/deceleration on the road and the need for maintenance (the number of potholes).
Reduces deaths and serious injuries on our roads. Traffic injuries made up about 33% of overall health loss due to all injuries in New Zealand and disproportionately impact on the vulnerable in our society.
Makes local communities nicer places to live, particularly as housing density grows.
Reduces rural deaths and injuries. People living outside main urban areas have a high mortality rate from road crashes, with 74% of road deaths happening on rural roads.
Reduces both the speed and volume of traffic and leads to less air pollution (e.g. NOx and particulate), noise pollution and climate emissions (e.g. CO2).

The productivity gain of faster speeds is small relative to the costs. Research indicates that in reality, little time is gained by faster speeds, as the most time is taken up waiting at intersections and by congestion rather than the period in a trip travelling at the faster speed.

Removal of Community Rights

Spokes is very concerned that the government is proposing to override local democratic decision making and override community voice. While some people within communities may not want safer speeds many communities do want them. In Opawa, Ōtautahi Christchurch, for example, the safer speeds consulted on and implemented in 2022 had 90% support from the 139 submissions, with many asking for more of its narrow streets to be slower. Why should any community have higher speeds forced on them with the consequential likely increase in crashes? Opawa would not qualify for an exemption to be 40 km/h as it does not have a high number of pedestrians on a short section of street, but there are many families with young children and older adults out for walks around the neighbourhood or biking to destinations. Other areas in Ōtautahi Christchurch are seeing the results and are now asking the council for similar treatments in their neighbourhoods.

This over-reach is further compounded by:

“10.3 Retention of information developed under the 2022 Rule (1) Despite clause 10.1, the details of a speed limit that is in force immediately before the commencement of this Rule (including any applicable speed management plan) that has been superseded by a new speed limit set in accordance with this Rule must be retained by the Agency (as RCA), a regional transport committee or a territorial authority (as the case may be) for a period of at least seven years from the date on which the new speed limit came into force.”

The consultation document does not mention it will take seven years before the speed limits they support in their neighbourhood can once again be reconsidered and restored. Young families are moving into and investing in these neighbourhoods because the slower speeds make them a safer and a more pleasant place to live.

Proposal One – require cost benefit analysis for speed limit changes

Spokes does not support the narrowing of impacts in the Cost Benefit Analysis. This leaves out important health, climate and societal impacts that have a significant impact on communities. The impact on all modes of transport should be considered in CBA, including active and public transport.

The draft Rule requires road controlling authorities (councils and NZTA) to undertake cost benefit analysis when consulting on proposed speed limit changes. In many cases the cost benefit is already clearly in favour of reduced speeds. The local community have often initiated the request for speed changes, particularly around schools. Local council RCAs should be able to set speed limits for individual or groups of streets (e.g. around a school or destination) with appropriate local consultation but without the added expense of a cost benefit analysis. Area-wide changes to a suburb or larger area should have a cost benefit analysis, unless there is an existing speed management plan which a council have already extensively consulted (and in some cases approved).

Christchurch City Council is using interactive maps of proposed areas to get a wide range of opinions on individual streets. This is used with a mixture of other forms of consultation to ensure wide community engagement.

Good guidelines and assistance for the business case analysis is important. The cost benefit analysis should take into account the indirect costs and benefits that will impact the local community and future generations.

The proposed rolling back of speed limit changes should also be subject to a full cost benefit analysis, particularly as if implemented it cannot be changed for seven years.

There is also no compulsory review of the changes after a certain period of time to see if the outcomes have been delivered. It can take some time to see a change in deaths and serious injuries however comparing an area with a similar area can show trends. Glen Korey has done a quick before/after crash analysis showing a 20.5% drop so far on the Akaroa highway (SH73/74) in expected crashes after the speed reductions, and another analysis over 5 years, using SH73 (West Melton – Bealey River) as a comparable “control site” relative to that route where the reduction in expected crashes so far was 13.3%. The changes are working to reduce deaths and serious injuries.

The following proposed rule has no particular objectives in terms providing safe infrastructure and an environment that reduces harm. Targeting enforcement is only part of the problem. Good drivers make mistakes even when driving to the rules. Slower speeds allow greater time to correct that mistake without serious life-changing consequences.

Clause 2.6(3)(a)(i) requires the Agency (NZTA) to have regard to the road safety objectives of the GPS on land transport. The safety strategic policy in the GPS encourages investment from third parties to make roads safer and targets enforcement of drink and drug driving rules, seatbelt rules and reducing the number of disqualified drivers on the road.
When a speed management plan is being prepared the third requirement of four is that a cost benefit analysis of speed limit changes must be performed.

Climate change and pollution should also be considered in the CBA.

Proposal Two – additional consultation requirements

The draft Rule proposes that all road controlling authorities follow the same consultation requirements, and expands on the consultation requirements already in the Local Government Act.

The draft Rule proposes that all RCAs follow the same consultation requirements, that is, they must:

Use reasonable efforts to consult with persons that use the road for which a speed limit change is proposed, freight users, local communities, businesses and schools surrounding the impacted area, and local government (for example, neighbouring RCAs).
Publish the draft speed management plan and cost benefit analysis on a website and give at least four weeks for any interested party to make a submission.
Following consultation, publish a summary of submissions and include an explanation of how feedback was taken into account in the final speed limit changes.

Spokes agrees with these changes for the most part. Spokes notes that some RCAs, including the Christchurch City Council, already have good consultation processes in place, which are adapted for different communities, and the Council staff continue to evolve and learn from experience. Spokes prefers that all submissions are published as part of the process as well as a summary. It should be noted that businesses regularly over-estimate the importance of vehicle access and speeds on their business, so good consultation and discussions with businesses on the issues is important.

Spokes does not agree that the “proposed speed limit changes on each road must be presented separately in consultation to allow for consultation feedback on each road that is changing” if the intent of this change is to require RCAs to consult on every road separately rather than as a package. It does need to be clear during the consultation which roads are being proposed to change and that specific feedback is encouraged.

Spokes is pleased that NZTA would have the same requirements for consultation, including the requirement to consult and take into consideration local communities and council’s feedback.

Spokes is concerned about the impact of the consultation requirements on smaller RCAs who may not have the capacity to meet these consultation requirements, which will discourage changes which are likely to reduce deaths and serious injuries on our roads, particularly given 73% of road deaths are rural. NZTA should be tasked to support these RCAs where needed, for example by providing a consultation platform or analyst help.

Spokes does not support the removal of the requirement to provide processes to provide for Māori to contribute to the preparation of the plan. This is against principles of Te Tiriti o Waitangi, especially when Māori experience disproportionate rates of deaths and serious injuries on our roads.

Proposal Three – require variable speed limits outside school gates

Spokes does not support Proposal 3 under any circumstances.

Spokes strongly supports the previous rule that required speed limits of 30km/h around schools at all times, or 60km/h at all times in rural areas, depending on the location of the school. Ideally all schools would be 30 km/h.

We all agree on the importance of providing children with safe access to schools. This includes children walking, cycling and scooting from their home.

Variable speed limits for only 300m does not reflect how schools work. Children travel to and from school at different times of the day, including outside official school hours, for sport, music and other activities. Some schools have different hours every day of the week, or different hours for senior and junior classes. Schools and pre-schools are often close together but have different hours. Schools share resources or use Council resources for activities such as learning to swim, technical or IT training, or Library access.

An example of the complexity is Northcote Road in Ōtautahi Christchurch, where Casebrook Intermediate, Kidsfirst Kindergarten, Marian College, and St Bede’s College are all within 1.2km and all start and finish at different times of the day. Additionally, a large number of children use the same crossings to get to other schools close by including Papanui High School, Bishopdale School, and St Joseph’s Catholic Primary School. Another example is Waterloo Road and Hei Hei Road in Hornby, Christchurch, with Hornby High School, Hornby Primary School, BestStart Hei Hei, and St Bernadette’s School all in the same block, and with the Matatiki Sports Centre and Library (and Kyle Park) just across Waterloo Road. The proposed changes would result in an overlapping patchwork of 50 km/h and 30 km/h zones that would change during the day. Each day of the week may also be different.

Local schools and RCAs know best what will work for their particular circumstances. The most dangerous place for children may be on the way to school rather than outside a particular entrance, (e.g. Brougham St and Te Kura Taumatua / Addington Primary School) and that may require a special treatment rather than a blanket change.

On busy arterial roads, electronic variable speed signs that are regularly updated and crossings controlled by lights may be required and well worth the cost. On other streets, it makes more sense to have permanent 30km/h zones around the school and key routes to the school. Static signs for variable speeds for standardised school hours are not effective and should not be used on main roads. They may be appropriate on a quiet back street that has a single school present.

It is important to allow children to develop an increasing degree of independence as they get older through the ability to safely walk, cycle, scoot or bus to school on their own or with limited supervision. Parents need to be comfortable it is safe to let their child do so. More than half (50.2% in the 2018 census) of students travel to education by car adding significantly to congestion and reducing safety for those using active means. Reducing speeds surrounding schools is key to changing this pattern.

Proposal Four – introduce a Ministerial speed objective

Spokes strongly opposes this change. Speed changes should be the responsibility of RCAs and NZTA working in collaboration, using sound principles based on international best practice, good data and local knowledge, and taking into account all modes of transport for the benefit of current and future generations.

The draft Rule introduces a ‘Ministerial speed objective’ which signals the pace, scale and focus of speed changes they expect road controlling authorities to work to. Ministerial objectives are subject to change over short periods of time. Decisions should be evidence-based rather than politically-based, particularly when it involves infrastructural investment lasting decades. Significant changes should be properly consulted on rather than set by a minister.

Proposal Five – schedule of speed limits classifications

Spokes does not support binding speed limits but there should be nationally suggested speed limits based on best practice and evidence. All roads should be able to have exceptions to reduce speeds to take into account the crash rate, geography, type of traffic, safety, and community views. RCAs should retain their current role in determining speeds.

Spokes supports the following suggested limits:

Urban streets should remain 30-40 km/h
Civic spaces – 10-20 km/h
Urban connectors – 40-50 km/h with the upper end only used rarely
Urban transit corridors – 50 km/h – where no separated cycleway alternative exists
Fully separated urban motorways with separated alternatives for cyclists – 80-100 km/h
Peri-urban roads – 50-80 km/h
Stopping places – 40-80 km/h
Rural roads – 60-80 km/h
Interregional connections – 60-100 km/h
Expressways – 100 km/h. This is safer, and has lower emissions and fuel costs.

Any urban road where cyclists are allowed and there is no separated infrastructure should be 50 km/hr or less (e.g. Blenheim Road which has businesses only accessible from that road).

Spokes mostly supports the exceptions. Urban streets with significant levels of pedestrian and cycling activity should be 30 km/h. Areas around schools should be listed as a 30 km/h exception.

There should be an exception for vulnerable infrastructure that would create significant problems if closed due to a crash. For example, aging bridges on open roads that are narrow or single lane should be 70-80 km/h (e.g. Rakaia River Bridge). There should also be a lower speed of 30 km/h when cyclists are on the bridge when there is no alternative option.

Proposal Six – update the Director’s criteria for assessing speed management plans for certification

Spokes does not support this update. It is too prescriptive and does not take properly into account local community requirements. The requirement to “regard any Ministerial Speed Objective” should be removed. The cost benefit analysis requirements should only apply to speed changes affecting large areas. Spokes also does not support the speed limit classifications which restrict councils’ ability to set safe speed limits of 30 km/h in urban areas.

Proposal Seven – reverse recent speed limit reductions

Spokes does not agree that speed limits reduced since 1 Jan 2020 should be reversed around schools, on arterial roads, on rural state highways or anywhere else (e.g. neighbourhoods). Christchurch City Council has properly consulted on these changes with the community. They have not been “blanket” changes. There should be a process to reconsider any decisions after a period of time but it should be evidence driven. Reversing the changes will be expensive at a time when council rates are at a record high and will lead to more deaths and serious injuries. The permanent speed reductions around schools are well supported.

Speed Management Committee

Spokes supports the retention of the independent Speed Management Committee.

Regional Speed Management Plans

Spokes believes that local decisions are best. However, there is some benefit in joint transport plans that look at the bigger picture rather than just speed management.

Higher Speed Limits on certain Roads

Spokes does not support speeds higher than 100 km/h from either a safety perspective or a climate perspective. Higher speeds also require more fuel and create more road damage. The costs to average New Zealanders outweigh the benefits.

I would like the opportunity to present on this submission and I am happy to discuss or clarify any issues that arise.

Anne Scott

Submissions Co-ordinator

Spokes Canterbury

submissions@spokes.org.nz