We the undersigned are opposed to the introduction of a blanket 20mph speed limit across restricted roads in Wales. We call on Welsh Government to pause, undertake a thorough review of the trials, including gaining feedback from residents in those areas, and consider alternative methods of road safety improvement. 

With the 20mph speed limit trials only underway for a short period, we are dismayed that the vote to make this law is being pushed through on the 12th July 2022 and completely ignores the consultation results, which found that 57% of respondents DO NOT want the speed limits to be changed.  That is not a democratic or evidence-based approach to law making. 

Our concerns are varied but include:

• Safety – it could cause more accidents
  • The very limited evidence that 20 mph limits will reduce accidents, on the contrary, we believe that it could cause more accidents, (See below.)
  • Traffic Accidents have reduced drastically over the past 10 years, despite an increase in car ownership (Police recorded road accidents: 2020 | GOV.WALES). However, UK Gov stats shows that 20mph roads are the only ones that show an increase in accident rates, (https://is.gd/mlhDbm)
  • Actual traffic speeds may only go down by as little as 1mph, however some of the most vulnerable road users are given a false indication of actual traffic speeds causing them to take less care when crossing.
  • The inclusion of main and higher standard roads will mean sat navs no longer see main roads as faster and direct traffic down ordinary residential streets, potentially causing more accidents
    
    
• Unfair enforcement
  • If the police are able to position their mobile camera units wherever they choose as the new law suggests, we will undoubtedly see an increase in fines and points against sensible drivers only driving a few mph above the limit
  • Enforcement is a key part of the policy. Be assured, this is about raising more money for the Welsh Government central fund
  • It is already possible to be prosecuted for dangerous or reckless driving should you cause an accident while driving too fast even if not speeding. 
    
    
• Environmental damage from longer car journeys
  • We do not agree with the environmental claims as cars will be on the roads for longer, lower gears, higher revs, more pollution and emissions
    
    
• Damage to our wellbein
  • It makes driving more stressful, you need to encourage alternative means of transport, not antagonise people out of cars.
  • As 20 mph is just too slow for some roads, those attempting to obey the law increase their accident risk by driving slower than the majority of traffic.

Please sign our petition and share your comments on why you think the law should not be passed.  

Also, please write to your elected representatives so that they represent your views in the Senedd during the debate. This will deeply affect our lives and should not be taken lightly and rushed through. www.writetothem.com

Notes on Road Safety
We agree that speed limits are an important tool for road safety and should be taken seriously by motorists.

However, the implementation of arbitrary, unrealistic, non-uniform and counter-intuitive speed limits across the city are helping to create a socially acceptable disregard towards speed limits. 

It’s intuitive to assume that by considerably dropping the speed limit, it will automatically make a road much safer; however, there are safety concerns to setting speed limits, either too high or too low. 

Many roads have had their speed limits dropped from 40 to 30 or 30 to 20 with little to no changes to their design, meaning that there is a gulf between the limit implied by the design of the road and the posted speed limit. [1]

What rarely if ever comes up in the debate over these schemes is what difference this makes to actual traffic speeds.  In Bath for example it was only 0.9mph, in most schemes it’s around 1mph, and they normally exempt higher standard roads.

However, it’s the fastest drivers who are least likely to slow down.  
This proposal does not help to do something about those drivers who genuinely treat out roads as a race track, on the contrary, it prohibits the behaviour of some of the most sensible drivers forces the police to target them to the detriment of limits being able to target those most likely to do harm. [2]

All the while the speed limit signs may help to give the most vulnerable road users, pedestrians and cyclists a false indication of actual traffic speeds.

20mph speed limits; may be helpful on ordinary narrow residential streets. 
However, limits should not be seen as traffic calming per se, they’re meant to be a legal tool there to single out the behaviour of the small number of drivers who seek to drive with little regard to the their own or other’s safety. 

For what difference they do make to actual traffic speeds they’re most effective when they match the engineering standard of the road, they’re on. 

The inclusion some very high standard and main roads, clearly not engineered for 20mph speed limits in the scheme could be dangerous [3] and may only serve to water down any effect the lower speed limit may have on ordinary residential streets. 

Speed limits should be set to assume ideal conditions, hence the need for other laws such as reckless, careless and dangerous driving. 

According to the guidelines “Speed limits should be evidence led, self-explaining, and seek to reinforce people’s assessment of what is a safe speed to travel. Speed limits should encourage self-compliance and not be seen by drivers as being a target speed at which to drive in all circumstances.” [4] These guidelines appear to have been ignored with the inclusion of higher standard roads. 

More emphasis should be on better driving standards, not drive-by-numbers.

Trying to get people who drive like maniacs to slow down is not a new idea, if just setting the speed limit very low was though to work that would have always been the way you set them.

Speed limits should especially not be set with the expectation that if you set them very low drivers who drive genuinely fast will only drive 5 or 10mph over the posted limit. They are meant to be a limit, not a target speed. 
More should be done to educate the public about the intricacies of setting appropriate speed limits.

Sources
1. Understanding the 85% Speed. youtu.be/NDYQaa3K_BA
2. Effects of Raising and Lowering Speed Limits - U.S. Department of Transportation, Federal Highway Administration (1992)
3. Crashes increase when speed limits dip far below engineering recommendation -Penn State (2018)
4. Setting Local Speed Limits in Wales.