Many individuals and organisations have made submissions to the council. Here's my response to WC's draft policy:
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In general a more positive approach should be taken to the introduction of 20mph limits where supported by local communities. More emphasis should be given to the benefits. WC should also consider more carefully the economic benefits to be gained, not just to the council directly but also to the wider community.
Specific points:
para 4 states that a separate review and separate report is to be produced on 20mph limits outside schools. It would be more sensible to have a single policy document covering all aspects of 20mph limits and zones including outside schools. Roads near schools are not separate from the rest of the road network and this would make options for communities clearer.
para 7 says Public Health Implications are not applicable. The introduction of 20mph zones impacts on public health in a number of ways such as casualty reduction and an increase in walking or cycling. There may also be an impact on air pollution: the possibility of using 20 limits as part of Air Quality Management Schemes in designated areas should be considered. The council's public health department should be involved in developing the 20mph policy.
WC draft policy document is less positive re introduction of 20 limits than the DfT circular on which it should be based. Much prominence has been given to para 132 and less to other parts of the circular (eg paras quoted below) which allow a more flexible approach. The inclusion of the network hierarchy map within the policy is unnecessary and demonstrates an over-prescriptive approach. For example a village such as Holt, although on a category 3 road, would benefit from a 20 limit, would fit other criteria, and could demonstrate community support. It's not clear what's meant by reference in the circular to roads where the movement of motor vehicles is or is not the primary function. A more common-sense approach, with each stretch of road where residents support a 20 limit being considered on its own merits, would be preferable. The statement that only roads to category 4b can be considered does not fit with the guidance and is unduly negative and prescriptive.
Examples of points from DfT circular 01/2013 Setting Local Speed Limits which encourage a more flexible policy:
Introduction: Traffic authorities are asked to keep their speed limits under review with changing circumstances, and to consider the introduction of more 20 mph limits and zones, over time, in urban areas and built-up village streets that are primarily residential, to ensure greater safety for pedestrians and cyclists, using the criteria in Section 6.
Para 17: The key objectives of this guidance are … achieving local speed limits that better reflect the needs of all road users, not just motorised vehicles…
Para 23: Local residents may also express their concerns or desire for a lower speed limit and these comments should be considered.
Para 32: Speed management strategies should seek to protect local community life.
Para 34: … evidence suggests that when traffic is travelling at constant speeds, even at a lower level, it may result in shorter and more reliable overall journey times, and that journey time savings from higher speed are often overestimated (Stradling et al., 2008).