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No Justification for 20 MPH Limits in Safer Speeds Proposals


I have written previously on the proposal to introduce a 20 MPH speed limit on major roads in central London, and probably in the rest of London later. I criticised the failure by Transport for London (TfL) to publish any cost/benefit justification and submitted an FOI Act request to obtain that information which TfL refused. See References below for the full story.


After appealing to the Information Commissioners Office (ICO) about the refusal by TfL to provide the requested information, which should have provided a justification for their proposals in advance of the public consultation, I have had my complaint upheld by the ICO and have now received the requested information. See Reference 5 below which contains the Business Case published very recently. This is very similar to a draft published in 2012 which was available well before the consultation was launched and hence should have been made available (See Reference 6). However, the numbers in the later version on which the cost/benefit is calculated were much different with the capital cost being reduced very substantially and the collision reduction benefit almost doubling. The outcome is of course a very clear positive benefit as a result.


It is clear that TfL deliberately concealed the earlier version because it provided marginal benefits. But both versions are seriously defective because they do not include all the costs in the analysis. For example, they do not include:


- The economic costs of increased journey times. Although average speeds during a lot of the day are less than 20 mph on these roads, they are higher at other times and ignore the fact that between junctions and traffic lights/pedestrian crossings, the speeds are higher.


- No costs are included for enforcement of the 20 MPH limits.


- No costs imposed on drivers from paying fines for exceeding the limits are included, which will likely be quite substantial.


- They discount the suggestion that lower speeds would increase emissions from vehicles and hence have not evaluated it which is contrary to readily available evidence on that issue.


In other words, TfL concealed the original "Business Case" on spurious grounds thus defeating a fair public consultation and then adjusted the numbers to give the required answer while not including all the associated costs. This demonstrates exactly why TfL are not to be trusted and should be reformed.


But one moral for readers is do not accept refusals to FOI Act requests. Such refusals are often unreasonable and are just a mechanism to delay answering and hence concealing information until it is too late to be useful. This is of course unprincipled in the extreme. TfL do this repeatedly and perhaps the ICO will deal properly with this issue if they get enough complaints.


In the meantime the Mayor of London, Sadiq Khan, who is a party to this dubious activity should ensure TfL act more responsibly. I will be sending him a complaint on this issue.


Reference 1: Consultations in Name Only and Safer Speeds: https://tinyurl.com/y3gqh5hh


Reference 2: Consultations in Name Only: https://tinyurl.com/y6lpuusp


Reference 3: 20 MPH Speed Limits in London on Major Roads: https://tinyurl.com/y5ntxu4a


Reference 4: 20 MPH Speed Limits Spreading in London: https://tinyurl.com/y3r9bddp


Reference 5: Business Case 2019: TfL-Business-Case-2019

 

Reference 6: Business Case 2012: TfL-Business-Case-2012


Roger Lawson

October 2019