Consultation Submission submitted on behalf of the Living Streets Edinburgh Group (LSEG)

This submission is being made as a direct email rather than through your standard consultation form since the design of that form does not allow us to be able to adequately express our concerns for pedestrians. We trust that our views, as below, will nevertheless be considered seriously.

The LSEG very strongly supports the proposed lowering of the default national speed limit from 60 to 50 mph on single carriageway roads. Scotland has a very poor safety record on these roads, with a large proportion of all fatalities and serious injuries occurring on them, as evidenced in the Consultation Review report. The 60 mph limit is far too high for safe driving, other than where there are long stretches of strait road without intervening property entrances or side-road junctions. A 50mph limit will result in safer speeds on these roads and all the more so if the new limit is properly enforced. We note that an even lower, 60 kmph, national limit is now being introduced on rural roads in Ireland, many of which have similar characteristics to those in Scotland.

The benefits for pedestrians on such roads is unlikely to be great however, since traffic speeds at up to either 50 or 60 mph intimidate pedestrians, and without the protection of segregated paths, on what are mostly narrow rural roads, there is little pedestrian activity. Our principle concern therefore is that the introduction of the 50mph limit does not go nearly far enough to make conditions safe for pedestrians or to reduce the levels of suppressed pedestrian trips along these roads.

In many places there are extensive stretches of bends with the current 60mph limit but where the maximum safe speed around the bends is no more than 40, or 30, or even 20mph. All too often only ‘Slow’ markings on the carriageway are in evidence. For conditions to be considered at all safe for pedestrians, with their visibility restricted by bends, speed limits need to be set at the appropriate lower levels that match the road design / conditions, not simply set to 50mph. There are also still many places, in particular on the approaches to villages or other settlements, where the prevailing speed limit needs to be reduced from 60 to well below 50mph; and, as in the Scottish Borders, 20mph in the villages themselves  We therefore call for there to be a comprehensive review following on from the introduction of the 50mph limit, with the aim to have speed limits set to appropriate levels for safe driving throughout the network, and whether or not there have been casualties in a particular location. This is a fundamental necessity if more walking is to be encouraged, in line with government policy. 

Even with the setting of the most  appropriate speed limits conditions will still be challenging for pedestrians and potentially dangerous without the provision of segregated routes. There is also a clear need in many places for the provision of pavements or off-road paths alongside rural roads. This provision could encourage many more walking trips, for example between adjacent villages or from villages to the nearest town where distances are not too great. It is also the case that more recreational walking, by visitors as well as residents, would be encouraged by the provision of more off-road footpaths in rural areas throughout Scotland. It is notable that many of the islands are very suited by size for recreational walking (and cycling) trips, yet still with very little provision of safe, segregated routes. Provision of such routes could encourage the leaving of cars behind on the mainland perhaps, or even altogether. Promoting such active travel would help increased tourism to take place without a comparable increase in car use.

Finally much intensified efforts to enforce the improved speed limits are essential in order to eliminate excessive speeding. Funding for these efforts needs to be resourced by means that are protected, otherwise grant cuts are likely when, as now, overall national and local public sector resources are under pressure. Without this the Vision Zero aim to have no serious injuries or fatalities will remain just a vision. The current enforcement system is simply not fit for purpose and needs reform, as the LSEG has argued elsewhere:   https://www.livingstreetsedinburgh.org.uk/2021/11/17/slower-speeds-safer-streets-for-edinburgh-an-action-plan/

We need to have a more comprehensive approach, with policies for the road safety of walkers (and cyclists) integrated with those for tourism and wider economic development.