Cheshire East has produced a draft Speed Management Strategy, which they are currently consulting residents about. The deadline for responses is 31st January 2022. More information about the consultation can be found here. Residents are encouraged to read the strategy and respond to this consultation.
Holmes Chapel Parish Council has submitted a response to this consultation, which can be viewed below and which we hope residents will find useful to read:
"Holmes Chapel Parish Council is pleased to have the opportunity to comment on the Draft Speed Management Strategy (October 2021) proposed by Cheshire East Council.
This Parish Council has made a considerable range of proposals to Cheshire East Highways over the last 4 years, many of which have been deferred by the Highways Team on the grounds that the impending Speed Management Strategy would need to be in place for them to be considered. We refer specifically to ‘Traffic and Transport Issues in Holmes Chapel’ and ‘A Pedestrian-Friendly Village Centre’, both of which were presented to Cheshire East Council representatives in 2019 and received a favourable reaction.
It is encouraging, therefore, that the Overview statement in the draft strategy puts emphasis on a number of key matters which are at the heart of this community’s needs for speed management in the parish.
1. A safer road environment and encouraging a more active travel attitude
2. That the Council listens to the concerns of residents and road users
3. That changing speed limits is not the default solution…. promote the most appropriate approach..…to ensure the right solution is delivered
Having a strategy which delivers those aims is to be welcomed.
The 3 E’s Approach
While this approach is recognised as a positive route to evaluation of actions in speed management it is disappointing that Engineering in the flow chart is a measure of last resort. There are clearly situations where education and enforcement have already been seen to be ineffective and that some form of engineering solution would provide reduction in speed within existing speed limits and where the introduction of a lower mandatory limit would be ineffective. The flow chart should better reflect this.
Evaluation
The Parish Council is pleased to note that data from Speed Indicator Devices (SIDs) is recognised as a valuable method of gathering data with regard to traffic speeds. Holmes Chapel Parish has been gathering such data over a considerable period of time using portable SIDs on a number of fixed posts throughout the village highway network. It is, however, of great concern that the section in the draft strategy seeks to modify and thus undermine the effectiveness of this approach and a review of the SIDs proposals is included as a separate section at the end of this response.
Reference to Speed Watch in the draft is only included in relation to Education. It is our view that a properly managed speed watch can also provide valuable data in evaluating speeding issues. It should therefore be included in the Evaluation section.
The Highway Environment
Holmes Chapel, in common with other towns and villages across Cheshire East, has highway infrastructure which dates back many years, in some cases centuries, with little scope for improvement due to the physical constraints of existing buildings. There has however been considerable growth in housing here and across the borough with a concomitant increase in traffic. Added to the local situation Holmes Chapel sits at the crossroads of two major routes which further exacerbates traffic problems. On those routes it is not only volume but speed of traffic that has become unacceptable and potentially dangerous.
It is right, as stated in the draft strategy that consideration must be given to these key routes which, without a bypass, must continue to support the economy. While it is not necessarily appropriate to alter the existing, generally 30mph limits, there is a case for introducing engineering measures to reduce speeds and make drivers aware of the local environment for the safety of pedestrians and non-motorised users.
This latter point is particularly relevant in Holmes Chapel where footpaths that are on key walking routes to schools are narrow and overgrown. This approach to the safety of pedestrians and the associated encouragement towards active travel should have greater prominence in the strategy.
Speed Limit Framework
In the section 7.8 on speed limit framework, it states that 20mph speed limits and zones can be considered in built up areas, such as we have in the centre of Holmes Chapel on the A50, where there is a concentration of shops and other facilities and a predominance of pedestrians and other vulnerable road users.
While the introduction of a 20mph limit over a relatively short length of highway may not be appropriate, or practically enforceable, there is a good case for introducing some of the measures described in the strategy such as table crossings, road markings and coloured surfacing. It was pleasing, albeit frustrating, to note that such measures are being proposed in the borough at Alderley Edge where there is also the benefit of a bypass. This example of good practice should be more clearly emphasised within the draft strategy.
Overall the strategy comes across as focussed largely on the potential for amendment of speed limits. It is our view that much more emphasis should be on making improvements within existing speed limits so that compliance becomes the norm.
Current Speed Management Strategy (2016)
One of the provisions of the 2016 document is that of a stepped approach to speed limits so that there is never a reduction in one stage of more than two steps. That is 60mph to 30mph in 1 step is not acceptable and should be progressive as 60 to 40 to 30mph. There is no reference this in the current draft with the result that some current situations can remain unchanged. This 2016 requirement should be included in the current draft.
Speed Indicating Devices
Holmes Chapel Parish Council (HCPC) has considered, with some alarm, the proposed policies relating to SID deployment within the strategy. There appears to be a disproportionate amount of content related to SID usage within the overall Draft Speed Management Policy which leads us to feel there is a restrictive agenda being pursued for reasons that are not made clear.
Essentially, SIDs are intended to advise drivers of their speed and particularly to highlight when their speed exceeds the applicable limit. Whilst speed limits are set in accordance with the local conditions, conformance is often not high, creating an increased level of risk to other road users and especially to pedestrians and cyclists. In addition, getting speed limits reviewed and amended to take into account changing local conditions has proved almost impossible.
The challenge for Highway Authorities is how speed limit compliance can be achieved and various approaches are used, including signage, traffic calming, education and enforcement. The SID / VAS is one of those tools.
In Holmes Chapel there is a configuration of 12 solar panel equipped posts and six moveable SIDs. The posts were sited and provided by Cheshire East Council (CEC) in 2013, with the SIDs purchased, operated, and maintained by HCPC. Data is downloaded and shared with residents, CEC and the Police. Residents welcome the availability of this data.
Our observational evidence shows that the signs are effective in slowing traffic down. This is not necessarily reflected in the recorded data as it is based on the initial speed detected, but it can be seen that many drivers do reduce their speed. This is visible in a reducing speed display on the device, as the vehicle nears the sign.
The draft CEC SID policies refer to “evidence” that devices should be moved frequently to avoid a familiarity effect, such that drivers ignore them. This is based on a study undertaken in 2008 based in Kingston upon Thames, London. Conversely, a study was carried out by Dorset County Council on SIDs deployed in Weymouth during 2014-15. This later report concluded that whilst moving devices did not lead to traffic speeds increasing significantly, leaving them in-situ long term equally did not result in speeds increasing over time due to the familiarity argument. It can therefore be concluded that there is no argument for insisting that devices have to be moved on a frequent (2 – 3 week) basis.
Within Holmes Chapel the A50 which runs north/south, approaches to the village are 40 mph from the south and 50 mph from the north. The SIDs close to the 30mph limits provide a valuable reminder to drivers to reduce their speed as they enter the village and the lower speed limit. We would argue there is clear justification for these locations to be considered permanent, given the valuable role they perform. A re-classification as “Permanent Vehicle Activated Signs” could be appropriate for these locations.
The remaining four devices are moved around the remaining ten posts, but at a lower frequency that that proposed by the draft policy. This is a reflection of three factors: 1. Availability of volunteers to move devices on a short-term frequency. 2. The evidence that shows that frequent rotation between posts is not essential to maintain effectiveness. 3. Evidence that the devices do reduce the speed of approaching traffic irrespective of duration of deployment.
We consider that the proposed policies are unnecessarily restrictive, not to say threatening in tone and we find it disturbing that a Speed Management Strategy Policy should include so much negative content on this topic. We would cite the following as evidence of a restrictive and almost draconian approach to the use of these devices in the Speed Management Policy:
Section 5.4 It is recognized nationally that the effectiveness of SIDs reduces substantially after about two weeks and SIDs should be moved to maintain their effectiveness. There is other evidence that contradicts this assertion.
Section 5.7 Fixed installation SIDs We no longer install these on the network, nor allow others to do so, as they are not authorised for use on the highway by the DfT. We find no evidence for these assertions. Providing the devices comply with the relevant TSRGD regulations, they are permitted. This is also confirmed in Traffic Advisory Leaflet 1/03, as noted in Appendix B.
There is a possibility that the DfT request that such signs are removed from the highway in the future. This is a speculative statement that should not form part of a current policy.
Any devices and posts owned and managed by third parties could be removed from the network where this [consent] is not obtained. This will be at the expense of the Town or Parish Council who requested their installation. This is an unnecessarily threatening position to take and hardly conducive to the relationship which should exist between the Council and its Towns & Parishes. CEC approved and installed the posts in Holmes Chapel and therefore we strongly argue that all our posts and devices have the required consent. CEC needs to include a statement in the SMS that already approved posts and SIDS are exempt from this point.
Regardless of the mechanism of original introduction the Council will not replace, or authorise replacement of, posts for fixed installation SIDs, nor will they approve the installation of new posts for such devices. What is the justification for this position and why does Cheshire East Highways oppose the use of SIDs by Town & Parish Councils? This takes no account of posts damaged in traffic accidents and ignores that fact that existing posts and devices have the approval of CEC.
Section 5.8 Site Approval A deployment at a site constitutes a maximum of three-week presence facing in one direction. Turning the unit to face the opposite direction is considered a separate deployment. Any device not moved within four weeks may be removed from the network by the Council and the associated costs passed to the Town or Parish Council responsible for the device. Once again, threatening phraseology, coupled with requirements that are not evidence based.
Content in this section appears to be a contradiction of proposals in 5.7
National regulations and guidance comments The devices deployed by HCPC were originally approved by CEC Highways and display only the vehicle speed and, where appropriate, a Slow Down message. The displays are yellow.
We believe our devices are fully compliant with DfT guidance.
SID Effectiveness
Research undertaken by the Transport Research Laboratory found that SIDs are most effective when moved regularly. It showed that the longer the SID stays in one place, the less drivers slow down when they see it. After about two weeks, the speed of traffic returns to what it was before the sign was erected, therefore, keeping signs up longer has no effect and may bring them into disrepute.
The research referred to, as noted previously, dates from 2008 and relates to trials in London. The above paragraph ignores other, later evidence which contradicts the assertions above. It is unreasonable to base policies on restricted evidence.
Conclusions
HCPC recognises that CEC, as the Highways Authority, has responsibility to ensure signs deployed on the highway conform to national regulations and also to ensure third parties operating such signs, work within safety and legal frameworks. This Parish Council is committed to complying with such requirements.
At the same time it is also reasonable to expect those requirements to be fair and equitable, recognizing the contribution the speed devices make to maintaining safe speeds within the village and the extent of experience gained in the deployment and operation of the devices. We would like to work in partnership with CEC to meet objectives, but without the arguably unreasonable conditions and threats of actions / penalties for non-compliance. This is not the sort of relationship that should exist between a senior Authority and its Town & Parish Councils.
We note that other Highway Authorities take a more pro-active stance in their relationships with their Town & Parish Councils, engaging positively with them in the deployment of speed indicating devices. North Yorkshire, Staffordshire, Dorset and Wirral Councils are notable examples.
We would urge Cheshire East Council to re-think this section of its Speed Management Policy to deliver a partnership-based approach that is less prescriptive and more collaborative.
Summary of response
While pleased to see the draft speed management strategy and to have the opportunity to comment, this Parish Council finds that proposals presented fall short of addressing the right approach to speed management within the varied settings within the borough.
As noted, the emphasis should be much more clearly focussed on the measures that can be used on existing highways and within existing speed limits and while the evaluation process might lead to such solutions, this is not made clearly apparent.
The one clear measure that is available, the use of Speed Indicating Devices, is described in such a manner as to negate the usefulness of these devices.
The conclusion to be drawn from this proposal is that it is designed to provide a hierarchy of evaluation which avoids expenditure on effective speed reduction measures until the very last resort.
It is our view that the document requires serious reconsideration in both content and emphasis, with greater stress on the need to listen to concerns and to work collaboratively with those who experience the issues of speeding and safety at first hand, namely the Town and Parish Councils of Cheshire East.
References
DfT Traffic Advisory Leaflet 1/03 – Vehicle Activated Signs - March 2003 (Archived)
DfT Traffic Advisory Leaflet 1/04 – Village speed limits (Archived)
DfT Traffic Advisory Leaflet 01/15 – Variable message Signs
DfT Traffic Signs Manual Chapters 1 – 7 + schedules & additional guidance leaflets
DfT Traffic Sign Regulations & General Directions (TSRGD) 2016
TRL Report PPR314 Study of SIDs usage in Kingston upon Thames 2008
Dorset CC Study into long-term deployment of SIDs in Weymouth 2015"