Earlier today (Fri 05 April 2024), Irish Cycling Campaign made a submission in response to the Department of Transport’s consultation on the Review of the Road Safety Authority. You can read a copy of it below.

We wish to thank all of our fabulous volunteers who contributed to this submission. We sincerely hope that it helps to reshape the institutional context which has a huge bearing on the real and perceived safety of those who travel on foot, by bike and indeed by any other mode of transport.

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Introduction

We in the Irish Cycling Campaign are a network of knowledgeable and passionate cycling advocates from across urban and rural Ireland. We are the member for Ireland of the European Cyclists’ Federation (https://ecf.com/) and also a member of the Irish Environmental Network (https://ien.ie/).  

We know that cycling is part of the solution to many of society’s problems, from health to the environment to the economy. We have a vision for Ireland where everyone has the opportunity to cycle safely to the shops, to school, to workplaces regardless of their age or ability. Our expertise in research, policy, transport planning, infrastructure design, event management and behaviour change means we are the trusted voice on everyday cycling in Ireland. 

The Department of Transport (‘the Department’) is currently undertaking a review of Ireland’s Road Safety Authority (RSA) via an independent third party, Indecon International Consultants. We set out our views below in the form of responses to the seven online questions posed by the Department on the downloadable public survey.

Executive Summary

We welcome the opportunity to make this submission. In short, we have serious concerns about the performance of the RSA:

1. Institutional and financial adherence to car dominance
2. Cultural blindness to the needs of vulnerable road users
3. Failure to advocate for better road designs and effective enforcement
4. Silence on the rapid growth of ever larger and more dangerous private motor vehicles (SUVs)

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Views on Services Provided by the RSA

Q 1.  The RSA currently provide a range of services and functions, including Driver Testing and Licencing, NCT and CVRT Vehicle Testing, road safety advice, road safety promotional and media campaigns, and road safety education programmes, as well as working with other stakeholders to enhance road safety enforcement and inputs to road safety legislation. What do you believe to be the most important of these services and functions? And are there any other services or functions which the RSA should be undertaking that they are not undertaking currently?

We believe that any authority concerned with road safety in Ireland must carry out all those functions. However, the current dominance by private car use (whether EV or ICE) leads to poorer safety outcomes, compared to a holistic approach to road use (and transport generally) that tackles car dominance and unrestrained driving. 

We see a crying need to shift Ireland’s road use and culture to one that is both safe and healthy, and one that prioritises vulnerable road users (as required by the Department’s own guidance and investment frameworks). Thus the education, promotional and legislative functions must take priority. We believe any effective road safety authority will also have an active role in enforcement of traffic legislation, and in advocacy for better roads, cycleways and walkways.

Implementing road safety measures can be unpopular and is often faced with local and political opposition, especially when it involves prioritising road users who are not driving. It should be a core function of the Road Safety Authority (RSA) to dispel misinformation and clearly educate the public in relation to the importance and benefits of reduced speed limits and the infrastructure that improves road safety.

Data:

High quality research and data is needed to lead road safety interventions. The RSA should be bringing together multidisciplinary research teams in universities to carry out comprehensive research and data analysis. Such teams would include behavioural scientists, experts in public health and epidemiology, statisticians and engineers. 

The absence of any road traffic collision data made publicly available for researchers and public engagement, is a major deficiency in one of the core roles of the RSA.

By contrast, such data is not only available in the UK in machine-readable format amenable for analysis, but is also collated and presented for better public information with dashboards and interactive maps. See for example the following: 

Road accidents and safety statistics – GOV.UK; 

THINK Map; 

Reported road casualty statistics in Great Britain: interactive dashboard, from 2018. 

Arguments about GDPR preventing the release of these data in Ireland do not appear to hold much water, since other European jurisdictions are subject to the same regulations.

We note that a road traffic collision map was previously available on the RSA website, covering collisions until 2016. Although limited in its function, it had a role in road safety audits and could be used for simple research, public information and advocacy purposes. This map was removed in late 2020, and on November 30th 2020, the following statement appeared on the RSA’s website:

“Access to road safety data”

We are in the process of reviewing our road traffic collision (RTC) data sharing policies and procedures. Record-level RTC data can’t be shared until this review is complete.”

(Source here)

After more than 3 years, there appears to have been no visible progress on this issue. This is an obvious concern for all stakeholders. The impression given (whether true or not) is that this is not a priority for the RSA, or that there is something to conceal in these data. We would strongly argue that the RSA follows the example from other states in making the data available and useable.

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Q 2.  Do you have any other views on the focus and balance of the Road Safety Authority’s functions, between the driver and vehicles testing and licensing services it delivers to the public, on the one hand, and the road safety policy, promotion, education, and research functions it undertakes, on the other? (See: Role of the RSA)

Decoupling of Services:

We propose a re-evaluation of the RSA’s structure to potentially decouple those two roles. Whether intentional or not, the RSA’s approach to road safety is extremely motor-centric. We expand on this below.

Culture and norms around driving instruction and testing

Respect for people cycling and understanding of cyclist behaviour needs to be prioritised in the driver training curriculum. We are concerned that some Driving Instructors have difficulty observing rules that are there to protect people walking and cycling, such as parking in cycle lanes and footpaths, even when engaged in training novice drivers.

There seems to be no understanding, for example, of the role played by bike-boxes with their advanced stop-lines among the ADIs. Drivers regularly invade these safety features, so it is clear that their importance is not covered by instructors or testers.

The test must be reformed so that there is a vulnerable road user category added with mandatory questions posed in the on-line assessment; in addition, we would urge that a mandatory requirement be introduced into the training and testing of professional drivers that involves safe interaction with bike users, where the novice or a driver undergoing annual CPC assessment must ride a bicycle in traffic in an urban area to have experiential awareness of extreme vulnerability.

The medical fitness to drive assessment requires reform 

GPs need to carry out a thorough investigation beyond focusing on blood pressure and eyesight. The exam should include checking peripheral vision or ability to rotate the head in a horizontal plane. This latter function is of critical importance in keeping bike users safe on our roads – drivers are failing to turn their heads in order to look properly so it is our view that many may not actually do this due to age related cervical vertebra mobility issues.

Taxi drivers must be subject to mandatory CPC 

The exclusion of taxi drivers from mandatory CPC assessment is unacceptable. They drive as a profession and therefore must be treated as a professional driver. Sharing bus lanes with bike users carries additional responsibility and awareness. 

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Views on the approach to funding of the RSA

Q 3.  The RSA’s functions and operations are mostly self-funded, from the fees it charges for the provision of services, including driver licensing and testing, and passenger and commercial vehicle roadworthiness testing services (the NCT and Commercial Vehicle Roadworthiness Testing), with little direct Exchequer/public funding received. What are your views on this self-funding model rather than an exchequer funded model or a mixed funding model?

The Irish Cycling Campaign fundamentally opposes the current self-funding model of the RSA, which relies heavily on the growth of private car ownership and use. This model creates a conflict of interest, as the RSA’s financial well-being is directly tied to the proliferation of vehicles and increased vehicle-kilometres travelled (VKT) on our roads. We strongly advocate for an exchequer-funded model to ensure the RSA’s independence and ability to take necessary actions to enhance road safety for all users.

It is deeply inappropriate for the RSA to use motor industry sponsors in road safety campaigns.

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Views on the future of the RSA

Q 4.  Do you have any views on the future role of the Road Safety Authority?

We have set out our views on future funding models, and on the cultural norms of the Authority. We would submit that there are other changes that would potentially be useful and effective.

Different indicators of success

The current mission of the RSA is “to save lives and prevent injuries by reducing the number and severity of collisions on the road.”

The statistics on death and injury should not be the only indicator of how safe our roads are. Another important key performance indicator which should be applied is the number of people walking and cycling on our roads. The number of children walking and cycling to school has plummeted in the past 30 years as the number of car journeys has soared. Parents no longer feel safe letting their children commute by bike or even playing outside in many places.

Counting not just victims by mode of transport but the perpetrators of road violence: 

Since the primary hazardous exposure on roads and streets in Ireland is driving, reducing the total number of kilometres driven nationally by enabling more walking, cycling or public transport journeys will itself make roads safer.  

As an example of the dominance of RSA’s culture by car use, a simple search of one particular social media channel shows the @RSAIreland account only replying to queries and comments regarding driver licensing:
https://twitter.com/search?q=(from%3ARSAIreland)%20filter%3Areplies%20-(to%3Arsaireland)&src=typed_query&f=top 

This has the effect of signalling to the public that the RSA only engages or values input from such “paying users” of its services.

Future Board Make-up / Expertise

In the make-up of the RSA board, we see a need for much wider ranges of expertise than are currently represented.

Such expertise might include, for example, vulnerable road user requirements, public health, health effects of sedentary lifestyles, of climate change, or of air/ noise pollution, and hazard and risk assessment in road use. There also appears to be an absence of non-drivers on the board. It is essential that road safety is approached representing the experience of people who do not use a car.

We are unaware of specialist sub-committees of the board, who may have expertise in the various relevant fields (e.g. public health, air pollution, social change). We would urge consideration of the establishment of such sub-committees, which might provide useful input to Board decision-making.

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Q 5.  Do you think there are any functions currently undertaken by the RSA that would be better delivered by another body/agency or any functions completed by others that would be better undertaken by the RSA?

Road Safety Commissioner 

As outlined in Q.2 above, the two main functions of the RSA conflict with each other, and there is a strong argument for separating them. The appointment of a suitably empowered and resourced Road Safety Commissioner, working either in parallel or as an overarching authority above the RSA, should be considered. Such a Commissioner would take a broader view of road safety, particularly drawing out the implications of the existing Road Safety Strategy Safe System Priority Area Six, which 

‘…involves promoting these safer modes, such as public bus and train, and providing safer environments for healthier modes, such as walking and cycling.’

Strong advocacy for reduction in car use across society is the ultimate outcome of this Priority Area. Switching travel mode from private car to public and active travel is the ultimate road safety tactic, and should be a central task of any authority concerned with road safety. 

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Engagement with the RSA

Q6.  Please indicate any involvement you may have with the work of the organisation and your views on their road safety information campaigns, education work or other services.

The Irish Cycling Campaign meets regularly with RSA officials to advocate for safer cycling and measures to control poor driver behaviour. Under its former name, Cyclist.ie, and under sub-groups such as Dublin Cycling Campaign, the organisation has engaged with RSA since its inception.

Hierarchy of Controls

The Vision Zero approach refers to a hierarchy of controls. The Authority have noted in their own document “Guidelines for Improving Road Safety Around Your School” (2021), that personal protective equipment (hi-vis) is the last level of control (p15, Fig 3). 

The RSA should allocate funding to all levels in the hierarchy, with proportionally more to earlier levels – i.e. Elimination, Substitution. This is not to say that no funds should be allocated for hi-vis, but that funds for hi-vis should be lower than all other measures. Currently huge emphasis is placed on the wearing of hi-vis clothing. The emphasis on hi-vis has also meant that the message that it is a legal requirement to have bike lights in hours of darkness has been lost, with many people now cycling with hi-vis vests, but without lights.

Road Safety and Children

We urge the organisation to shift its focus away from victim-blaming campaigns centred on the wearing of high-visibility clothing. Is it an appropriate use of resources to be distributing 40,000 hi-vis vests to pre-school and school children annually, while there is little intervention to deal with driver behaviour around schools, sports grounds and playgrounds? It is an erroneous message to give children the impression that hi-vis will protect them. The responsibility for road safety lies with adults driving ever large motor vehicles recklessly and flouting road traffic laws – and not with small children.

Children lack the capacity to be responsible for road safety and must absolutely not be held accountable or held to blame. Children have the right to play, they have the right to be safe outside. Our car culture has negated this right. Driving is a privilege and it is viewed in Irish society as an entitlement. Driving has removed safe places for children to play outside. 

The RSA education programme to primary school students is actively disempowering in that it creates a sense of danger around walking and cycling outdoors. It perpetuates the removal of this freedom. The driver is 100% responsible for a child’s safety. These RSA primary school campaigns are public health campaigns around a group of people who do not drive. In short, the RSA is failing children.

Much of the “Guidelines for Improving Road Safety Around Your School” document is commendable, as it follows the Hierarchy of Controls, but it places the onus on already overburdened school management to create and implement a road safety plan. 

Most schools do not have the capacity to implement and sustain such a plan and certainly do not have the power or authority to enforce the main elements that would actually have an impact on road safety around schools. 

We need to see a move away from spending on PPE and hi-vis for small children and, instead, see a reprioritisation of the education message in primary schools from children to parents and other drivers.

We would recommend education nights by RSA educators and partners (AGS, etc) delivered to parents facilitated by school management and parents associations. 

Additionally the RSA need to measure modal shift to walking, wheeling and cycling as one of their metrics to measure a successful safe school environment. 

30kph Campaign

While we commend the RSA for its recent positive 30kph speed limit campaign (along with the campaign to urge drivers to allow sufficient space when overtaking people on bicycles), the Authority has failed to persuade An Garda Síochána to enforce 30kph limits. Furthermore, it is vital that traffic calming infrastructure is rolled-out quickly to ensure average traffic speeds are compliant with the posted speed limit. This involves engaging proactively with each of our 31 Local Authorities. 

Where traffic calming is ineffective or absent, there must be active enforcement. Without enforcement, people do not observe these limits as outlined in the RSA’s own Free Speed Survey 2018, which show that 98% of drivers speeding on urban national roads with 30kph limits, and 70% of drivers speeding in residential 30kph streets – (Appendix I, page 11, of FREE SPEED STUDY Survey Report 2018 | RSA

We also note that the Free Speed Survey in 2021 does not contain data on 30kph zones – Free Speed Survey 2021 | RSA.

It is critical that the RSA continue to gather data on compliance in 30kph areas, call for enforcement in 30kph zones, and advocate the use of static speed cameras where AGS or Go Safe vans cannot provide enforcement.

A 2022 AECOM/ TII report pointed out the higher GHG emissions from ICE cars travelling at less than their optimally efficient speeds of 50 – 90 kpm. But it is important that, in urban and built-up areas, road safety is prioritised over minor possible savings in fuel efficiency. We would support the report’s recommendation for there to be a focus on the reduction of congestion in urban areas, and we maintain that this is best achieved through the allocation of road space to public transport and active travel. This would also improve road safety, if accompanied by measures to improve pedestrian and cycling infrastructure. 

The apparent absence of the RSA in policy discussions about speed limits on the national road network means that economic and GHG mitigation considerations have, in some cases, trumped the most obvious road safety benefits of reducing traffic speeds – and we are thinking here in particular of cases where schools are located right next to N-roads.

Call for effective and widespread enforcement in regard to conditions for people on foot / on bike

There needs to be an education and enforcement campaign with regard to motor vehicles parking on footpaths and cycle-lanes / cycle-tracks. This behaviour has become habitual, especially in residential areas. It creates hazards for vulnerable road users, especially those walking and cycling with children, elderly people and those with vision or mobility impairments.

Schools around the country have tried to educate and inform parents around illegal parking but to no avail. Safe Routes to school is progressing far too slowly to have the required impact on driver behaviour. In the interim, we need enforcement and RSA has not effectively advocated or demanded it.

Supporting implementation of road safety interventions: Advocate for infrastructure:

For many years the RSA have shown their support for investment in motorways and road upgrades to improve road safety outcomes. The RSA’s voice has been and is generally completely absent in educating the public on the positive road safety impacts arising from the reallocation of road space to modes other than private motor vehicles. This would include traffic calming measures such as junction redesign, road narrowing, and infrastructure to create a safe environment for people walking and cycling, segregated cycle paths, continuous raised footpaths across junctions and pedestrian and zebra crossings.

Providing public transport alternatives to driving also reduces the risk of people opting to drink/drug drive.

False equivalence 

The RSA must improve the language they use around people walking and cycling. The “Be Safe, Be seen” messaging is jarring, especially when so many collisions are due to drivers’ failing to observe. People cycling have a legal requirement to have front and rear lights in hours of darkness. People are clearly visible in daylight hours but they cannot make themselves seen by drivers who are distracted or failing to observe.

People cycling do not pose the same risk as people driving cars. The weight and speed of a motor vehicle means the driver bears far more responsibility when sharing the road with others. 

Sports Utility Vehicles / SUVs

The striking difference in the mass, momentum and kinetic energy of motor vehicles versus people on (10-20kg) bicycles, is accentuated further by the disturbing growth of ever larger Sports Utility Vehicles (SUVs) on our roads and streets. According to a recently published research paper: 

New cars in Europe are getting 1 cm wider every two years, on average. That’s according to research by Transport & Environment (T&E) which says the trend will continue due to the rising sales of SUVs – unless lawmakers take action. Around half of new cars sold are already too wide for the minimum on-street parking space in many countries. https://www.transportenvironment.org/discover/cars-are-getting-1-cm-wider-every-two-years-research/ 

The RSA has been silent on the frightening phenomenon whereby almost two out of every three cars sold in Ireland are of SUV body types (https://www.ft.com/content/fba7a808-e03e-40c6-9795-38c05abc844a). The trend towards wider vehicles is reducing the road space available for other vehicles and people on bikes (as shown in the image below), while parked cars are further encroaching on footpaths. The wider designs have also enabled the height of vehicles to be further raised, despite crash data showing that a 10 cm increase in the height of vehicle fronts carries a 30% higher risk of fatalities in collisions with pedestrians and cyclists. 

Figure from the Transport and Environment report, link above. 

From an emissions perspective, Prof Brian Caulfield, regarded as one of the leading authorities in transport emissions in Ireland, and someone who has conducted extensive research on decarbonising transport, said SUVs need phasing out (https://www.irishexaminer.com/news/spotlight/arid-41132380.html) – but from a road danger perspective, SUVs are contributing to a more hostile and hazardous road and street environment for everyone else in their vicinity. 

The RSA, or a replacement road safety organisation, needs to engage with the latest research on this topic, step up and advocate strongly on this topic.   

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Other Comments

Q7.  Finally, please provide any other comments which you feel may be of relevance to this review of the RSA.

In summary, we need an expedited, national motor traffic reduction plan and a paradigm shift in how we think about road danger. We need to stop diverting ourselves from the real issue – which is the physical presence, destructive and violent potential of ever larger forms of private individualised mobility.

We again thank the Department and Indecon for their attention to our submission.