Written evidence submitted by Agilysis (RSS0096)

 

About Agilysis

Agilysis are a dedicated Road Safety consultancy led by a team with extensive backgrounds in roads policing, highways engineering and running road safety partnerships. Working in the UK for DfT, National Highways, Tfl, Transport Scotland, Welsh Government, TfGM and WMCA as well as overseas with World Health Organization and World Bank, our expertise is in supporting organisations towards Safe System implementation, using extensive experience of applied research, data analytics, network risk, data visualisation, scheme evaluation, intervention design, and behaviour change.

In recent years Agilysis has been at the forefront of supporting regional partnerships in developing Safe System strategies and implementation plans, pioneering work on Safe System culture and practice and the quantitative analysis that is critical to a Safe System performance management framework. Our evidence is therefore based on learnings from developing strategies that are Safe System aligned and supporting organisations to implement them.

Summary

After 15 years of poor performance on road safety, characterised by weak national leadership, a lack of enabling legislation and poor coordination among delivery partners, the new national road safety strategy is warmly welcomed and many of the measures are critical for addressing longstanding gaps. The emphasis in the strategy in adopting a Safe System approach aligns well with international evidence and recognises that the historic paradigm of trying to change the road user, must be replaced with an understanding that the current levels of injury and death are created by a system that has been poorly designed to accommodate human frailty, acknowledge the limits of human performance and underplayed the responsibility of those who design and operate the system for its outcomes.

In answering many of the questions posed in the Committees call for evidence, this submission seeks to address issues through a Safe System lens, drawing on evidence from some of Agilysis own work and a wider corpus to highlight where systemic improvements could be made. The submission reflects experience of working on Safe System strategies across the UK and other territories, recognising that this move is not without challenge. Adopting the Safe System requires different thinking and innovative approaches to the orthodoxy of road safety practice that has dominated the last 60 years. It therefore seeks not only to examine the measures in the strategy and their contribution but also to highlight some of the challenges around culture, capabilities and capacity that have been experienced by others trying to make this shift. Failure to recognise this need will create a risk to delivery.

Ambitions and evidence

a. The strategy sets targets of a 65 per cent reduction in people killed or seriously injured (KSI), and a 70 per cent reduction in child KSIs, by 2035. Do these targets reflect the right level of ambition?

A Safe System strategy must recognise that road deaths and life-changing injuries are not the acceptable consequence of mobility. A system which is functionally safe, will provide sufficient layers of protection to ensure that users will not experience serious harm providing that they do not act recklessly or in deliberate defiance of the law. This means that a Safe System is aligned with the ambitions of Vision Zero and the eradication of road death and severe injury.

The new national road safety strategy does not make an explicit long-term commitment to zero, but the ambition is implicit. The specific targets, relative to the target date (2035), also express a high level of ambition commensurate with an intention to achieve vision zero within a generation, reflecting the level of determination being shown by a number of leading road administrations (Scotland, Greater Manchester) although Transport for London is aiming to move more quickly (2041).

At Agilysis, we have worked with many sub-national authorities on developing road safety strategy and delivery plans that are explicitly aiming to achieve reductions of around 50% in KSI over a ten-year period without having their hands on the national policy levers of legislation and regulation. In seeking to exhibit leadership, it is important that the government exceeds this level of ambition when it is a national administration, with the freedom to act across all parts of the policy landscape. These targets are providing assurance that well-intentioned regional road safety groups will finally have the support required to deliver sustained reductions in road trauma over the long term.

b. Are governance, delivery and resourcing arrangements across Government departments and key partners strong enough to achieve these targets?

Having worked on reviewing progress and setting strategy in other jurisdictions (Saudi Arabia, Qatar, Tunisia) and across the UK on partnership reviews and establishing governance arrangements, Agilysis have concerns that the governance arrangements and resourcing are insufficient to meet the demanding targets.

For example, in Scotland where Transport Scotland had already established a 3-tier national governance structure (Strategic Partnership Board chaired by the cabinet secretary for transport, Operational Partnership Group and Local Partnership Forums) embracing all 32 local authorities, police, fire and rescue, public health and the participation of key third-sector organisations there was a recognition that a proactive programme of capacity building would be required.

In supporting Transport Scotland to develop a coherent approach of embedding Safe System practice across all partners, Agilysis has worked on a range of measures, built around the 4 C’s model (Commitment, Capability, Capacity, Culture)

Commitment recognises that successful strategic implementation will require that a wide range of delivery organisations align around these ambitions. This cannot be delivered by national leadership alone, but will require significant commitments of resource and leadership from mayors, councillors, police chiefs, fire chiefs etc.

Capability recognises that Safe System practice is not well understood within many delivery bodies and that there is a skills gap where organisations lack appropriate professional education. There is significant work to do to ensure that the concepts and implications of adopting Safe System are properly understood through training and guidance. We undertook training of over 500 professionals in Scotland to help address this gap and worked with international experts to create an online Safe System manual to guide practice.

Capacity recognises that few agencies have any dedicated specialist resource. In providing training and education for a wide range of engineers, network managers, educators, police officers and fire and rescue personnel, Scotland is seeking to address some of the capacity gap. Where a skills deficit exists in any sector, it must be recognised that it takes considerable time to build competence at scale and ultimately change practice.

Culture recognises that it requires a significant investment in building the shared beliefs, values and vocabulary that lead to transformational change. Agilysis have led pioneering work with both National Highways and Transport Scotland to diagnose levels of cultural maturity in organisations regarding their application of Safe System (Fosdick et al, 2022) and through a Cultural Maturity Playbook (Campsall et al, 2025) to provide support for organisations wanting to operationalise a more effective culture.

c. Are the measures set out in the Strategy collectively sufficient to deliver its targets? What further measures, if any, would strengthen its impact?

Our estimate is that the current measures are probably insufficient to meet the stated ambition. It is clear that some effects from vehicle safety technology will accrue over time. Measures such as improved seatbelt legislation, lower BAC, mandatory eyesight testing, and minimum learning periods will lead to some incremental changes, dependent on the enforcement regime that accompanies their introduction, all of which means the rate of reduction should exceed the recent trend (shown in the chart below). However, when compared to the measures and investment that was introduced in the early 2000’s with the national strategy ‘Tomorrow’s Roads, Safer for Everyone’ it doesn’t appear that this strategy will match the performance in this period (shown by the 2nd line in the chart below). In particular, the lack of focussed attention on Speed Management which is at the heart of a robust Safe System approach and the injury reduction achieved pre-2010. There is also a need to consider whether the ambition can be met without reducing demand for private motor vehicles. The 2020 data point, when COVID restrictions reduced motor traffic by 21.3% (DfT, 2021) indicates how safety could be significantly impacted by a changing transport mix.

Figure 1: Long Term Trend in KSI Casualties (GB) with Modelled Projections to 2035 (https://agilysis.co.uk/2026/03/05/65-by-30/)

d. Are the measures set out in the Strategy based on robust evidence?

Overall, it seems that the evidence is instructive but selective. Policy measures that are proposed are generally supported by a body of evidence, but the evidence selected is not necessarily comprehensive. For example, whilst evidence on the potential value of a minimum learning period is presented, it is not necessarily reflective of the broader body of evidence on how to improve young driver safety. Similarly, the rationale for a Road Safety Investigation Branch refers to a range of useful data generated by existing collision reporting systems but does not refer to the body of evidence indicating that investigatory powers will be transformative for learning from collisions.

e. The Government has said its Strategy is informed by Sweden’s Safe System approach. What other international or UK examples offer the most relevant lessons for reducing deaths and serious injuries?

Sweden’s approach, normally referred to as Vision Zero, is regularly heralded as an exemplar, but the world’s leading performer on reducing road fatalities per head of population is currently Norway. Work by the Institute of Transport Economics in Oslo (Elvik & Nævestad) on measuring Safe System Implementation is also highly relevant to the UK Government’s ambitions. Agilysis are currently working on a mid-term review of Scotland’s road safety framework to 2030, announced by Fiona Hyslop MSP in 2025, which is looking to develop qualitative and quantitative comparisons between Scotland’s current Safe System implementation and that which has been achieved in Norway. A similar approach examining the UK’s current state of development might prove informative at the outset of this strategy period to identify the level of effort required to succeed.

Some jurisdictions (Victoria, Australia) have also been adopting a backcasting approach. The ambition here is to start with understanding the desired end-state, then working back to see which policies and interventions will be needed to achieve the target and where the gaps (residual risk) will remain in the system.

National Highways’ Road to Zero Harm programme adopts a slightly different approach to modelling but critically seeks to assess the contribution that countermeasures (in isolation of cooperation) might make to reducing harm on the strategic road network. This modelling approach could be repurposed to help drive delivery for other road authorities.

Theme 1: Supporting road users

g. What is the right approach to safe driving later in life? What safeguards are required to protect both safety and independence of older drivers?

The international evidence is clear that the road related risk to older people is multifaceted, impacted by housing, environment, social cohesion, community activity, economy and transport provision. Working with the leading charity RoadSafe and a wide range of partners, Agilysis developed a suite of Safe System aligned reports on risks to an ageing population. (oldermobility.com). As demonstrated in the evidence that emerged from the COVID pandemic, many of the policies that improve road safety generally are disproportionately beneficial for older road users, including measures to reduce car dependence creating more amenable space for active journeys.

As a follow-on to Older Mobility, Agilysis and RoadSafe partnered on a project to look specifically at the viability of driver simulator screening tools used in a health context to identify early indications of declining performance (Ursachi et al, 2021). The study showed that there was an alignment between simulator scores and observations of experienced clinicians, suggesting that it could be a potential route to support a stretched healthcare system in identifying appropriate drivers for referral for older driver assessments.

i. To what extent does fear of traffic danger deter certain modes of travel, particularly walking and cycling, and what measures would be most effective in addressing this?

Other organisations will be well placed to describe the links between fear of traffic and deterrence of travel by active modes, with an emphasis on risks in urban areas. One area where evidence is less well documented and emerging more recently is on these effects in rural areas. Many rural roads are used for active, leisure-oriented travel (rambling, dog walking, cycling, horse riding etc.) but public perception is that prevailing speed limits and traffic speeds are often too high and pose a risk to these activities. In work with Surrey County Council and grant-funded by the Road Safety Trust, Agilysis has looked at the viability of implementing much lower speed limits on sections of the rural network commonly used for active journeys, where traffic speeds are already quite low and where fear of danger could be further reduced by aligning limits with current use.

This work aligns with the concepts of Movement and Place described below as well as Agilysis work on creating a rural road taxonomy. A functional hierarchy that establishes expectations around speed management (limits, engineering and enforcement) based on the function that the road serves (access, active travel, community, thoroughfare) would help to reduce fear of traffic danger in rural areas as well as urban environments.

j. What should reform of motorcycle training, testing and licensing look like in practice?

RideFree (www.safedrivingforlife.info/ridefree/), originally developed by Agilysis, used a randomised controlled trial to demonstrate that the current CBT could be enhanced with additional training elements, especially hazard perception training. Since being adopted by DVSA, it has been used to support thousands of young people at the very outset of their riding career. It is, however, voluntary in nature and some of the components should probably be mandated in order to address the high levels of injury suffered by young motorcycle riders.

Theme 2: Taking advantage of technology, data and innovation for safer vehicles and post collision care

k. How can Government maximise the safety benefits of Advanced Driver Assistance Systems (ADAS) and ensure they are used safely and appropriately?

One area for innovation that has been created by increasing deployment of ADAS systems is the value of data, which is now able to highlight a wide range of factors that are safety relevant (speed, compliance rates, asset condition) new metrics that have the potential to be transformative (harsh braking, friction demand, near miss) all of which can be generated from vehicle systems.

To make progress in the use of ADAS data, ensuring that it is used appropriately, Government will need to:

l. What is the right approach to strengthening vehicle safety standards? What measures should the Government prioritise in response to issues such as headlamp glare, increasing vehicle size and any broader issues not currently being considered by the Government’s consultation?

There are presently significant gaps in our understanding about the penetration and use of vehicle safety systems. A project currently underway (RAC Foundation and Agilysis) is seeking to understand some of the inequalities that might exist in access to and concomitant protection derived from vehicles of varying standards. By looking at the specific fitment of safety systems as well as vehicle characteristics (size, propulsion, MOT history etc.) this project aims to create a new methodology for analysing which users benefit from or suffer as a result of differential safety standards across the vehicle fleet.

Another area worthy of examination is the relatively recent introduction of subscription payments for safety equipment. Manufacturers offer safety features as benefits to purchasers, but the cost of subscriptions might become prohibitive over time or underutilised when vehicles move into the second-hand market. Considering that these manufacturers are selling products which introduce inherent risk into the public realm, is it reasonable that they then upsell safety by charging additional subscription payments which could deter use?

Evidence also shows that there is huge differential risk between vehicles from different manufacturers (Tapp, Ursachi and Campsall), which indicates that they are being driven very differently. These are highly cultivated brands, that potentially market products based on factors that are likely to increase driver risk taking such as sensation, status, speed, independence and freedom. Recognising the commercial determinants of health, further work should consider the appropriate levels of regulation for brands that are associated with higher levels of risk. 

Theme 3: Ensuring infrastructure is safe

m. How should evidence on the relationship between speed limits and safety influence new guidance? Does the Strategy strike the correct balance between a nationally-set direction and local decision-making regarding speed?

The strategy makes no specific recommendation, but there is plentiful evidence of the potential to reduce serious harm by lower speed limits. We know that survivability deteriorates rapidly for unprotected road users at speeds above 20mph and we have strong evidence from Wales that this policy works.

There is a need to move to an approach that supports highway authorities in setting speed limits that are consistent, safe, credible and functional. We have worked with the Welsh Government on a project to help them produce guidance for setting local speed limits in Wales based on these principles.

Consistent – there needs to be consistency across roads that look and feel similar to drivers in different parts of the country so it is easy for them to identify and comply with the posted limit and supports positive behaviours. It is therefore important that there is a nationally-set framework, but that this allows sufficient flexibility to allow local decision-making on the detailed application. National guidance could identify a functional road hierarchy and suggest appropriate speeds for each road type based on the conflicts likely to occur on each type of road. Local decision-makers could then decide to address the conflict in another way (e.g. segregate vulnerable road users or replace at-grade junctions with grade-separated) or apply the recommended speed to mitigate the conflict outcomes.

Safe – there is a wealth of evidence now available around safe speeds for different types of conflict on the road. These speeds are often lower than expected and also assume limited other innovations in other safe system elements. It is important that the achievement of safe speeds across the network is the long term goal, aligned to achieving zero road deaths, but also to recognise this will require a societal journey over time. Work must also be undertaken to keep safe speeds under review against other innovations to mitigate conflicts.

Credible – Research has demonstrated that the credibility of speed limits plays a key role in understanding speed distributions and setting appropriate limits. Much of the existing literature has examined credibility using qualitative or experimental approaches, such as driver perception studies or simulator experiments. In practice, current guidance leads to the observed 85th %ile speed being used as an indication of credibility for a speed limit on a given road. However, this only serves to reinforce social norms which other interventions (e.g., enforcement, campaigns) are trying to change to improve safety. Understanding credibility in the context of lower / safe speeds will be important to their success.

Functional – we have developed a rural roads classification and a place and movement hierarchy for different types of road based on a range of characteristics, and aligned this with maximum posted speeds. This is shown in the figures below:

Source: Agilysis

n. What measures would be most effective in improving safety on rural roads, and is the Strategy’s proposed approach sufficient?

The term ‘rural roads’ describes a vastly diverse set of roads from motorways to remote, single-track roads. The Strategy refers to work undertaken by Agilysis in categorising rural roads and that “from early 2026, the government will explore whether the proposed rural roads categories are appropriate at a local level and assess their potential for national application.” This work is welcome as understanding the similarities and differences between categories of rural roads is the first step to developing system-based interventions. However, categorisation is not intervention and therefore, while it is an important and welcome first step, is not sufficient to deliver safety improvements on rural roads in its own right.

A key aspect of improving safety on rural roads is speed management, as discussed in our response to m. (above). There is evidence from Surrey (rural speed limit review), Scotland (speed management review) and Wales (setting local speed limits) on approaches that can be taken to this.

A key challenge on rural, high-speed roads (>40mph) is roadside hazards. These will range from natural hazards to objects placed adjacent to the highway (e.g. telegraph poles / sign posts / boundary fences). Current guidance (e.g. iRAP, RRRAP) focuses on clearing roadsides of these hazards or installing barriers but, while this may be the best approach on motorways or new infrastructure, is impossible to implement on the vast majority of rural roads. Better guidance and regulation on placement and type of boundary fences and telegraph poles would be beneficial, but there is also a considerable gap in understanding whether any particular species of natural roadside features (e.g. hedgerow) are more forgiving than others, or if there is potential to combine natural features with additional ‘man-made’ components to reduce the risks in run-off road collisions, while maintaining or improving biodiversity and habitat.

Additional data sources may also be necessary, and we are interested in the role connected vehicle data relating to wheel slippage (loss of traction) – currently available from NIRA Dynamics – could play in identifying higher risk locations regarding standing water and ice.

o. What scope is there for road design and maintenance to further improve safety?

Most current road design and maintenance approaches to safety are rooted in a reductionist, reactive approach. This is not well aligned to the Safe System which promotes proactivity and, as applied in Sweden and Victoria (Aus), a backcasting approach based on a desired Vision Zero end state. For example, new roads are being designed with the expectation that people will continue to be killed and seriously injured on them and these ‘costs’ factored into the cost-benefit analysis for the scheme appraisal. These roads are unlikely to see additional infrastructure investment beyond routine maintenance over the next half century, so these casualties are ‘baked-in’ to the design. A Safe System-aligned backcasting approach would instead set the vision for how safe roads, speeds, road use, vehicles and post-crash response should be expected to interact in the future (the end state). Designs should then focus on building roads to suit the future system end state – suitable for the desired vehicles and road use of the future.

Some authorities are using iRAP or similar assessment processes which, instead of focusing on where collisions are occurring, examine the inherent risk in the infrastructure and how road features affect the likelihood of fatal or serious collisions. The DfT has seen successful in applying this approach as part of the Safer Roads Fund programme, and upskilling Local Highway Authority staff in the methodology in the process. Continued focus on upskilling designers and road safety engineers in Safe System aligned methods, such as iRAP, through this type of programme would be welcome.

A key aspect of this is reviewing the design standards to better align with Safe System principles and a clearer future vision for safe roads and safe speeds within a wider Safe System. The commitment in the Strategy to update Manual for Streets is welcomed and could be approached in this way to provide considerable improvements in built-up areas. However, there will also need to be a similar focus on DMRB, and the application of design standards by Highway Authorities.

Maintenance is also an undervalued element within the Safe System. There is considerable focus on interventions, such as roadside barrier, but little discussion or emphasis on how safety performance changes over the course of their life. For example, iRAP considers the presence of a barrier, not whether it is still in a suitable condition to perform as designed when it was installed. Equally, road condition has been in a state of managed decline for more than a decade due to insufficient investment and the long-term implications of this for safety do not appear to be clearly understood. Also, the effect of more frequent or extreme weather events, particularly heavy rain, and the ability of road drainage systems to cope is a concern in this area, and new data sources such as wheel sensor data relating to loss of traction could be useful in supporting further developments.

Theme 4: Robust enforcement to protect all road users

p. What measures would most improve compliance and deterrence in relation to motoring offences? Which such offences have the biggest impacts on collision and casualty rates?

The motoring offences with the greatest impact on collision and casualty rates are the so-called “fatal four” driver behaviours: drink or drug driving, non-use of seatbelts, mobile phone use while driving, and speeding. Driver behaviour is a major contributory factor in road traffic crashes, and many fatal and serious collisions involve one or more of these behaviours. For example, in-depth fatal research in Scotland showed impairment by alcohol or drugs was a factor in 14% of fatal collisions in Scotland between 2015 and 2020, and 23% of car occupants killed in 2024 were not wearing a seatbelt, despite high overall compliance. Speeding remains one of the biggest contributors to serious crashes because higher speeds increase both the likelihood of a collision and the severity of injuries. Mobile phone use while driving also significantly increases crash risk due to visual and cognitive distraction. These behaviours often occur together (e.g. a driver who is impaired may also be speeding and not wearing a seatbelt), which further increases crash severity and reduces the chance of survival.

Measures most likely to improve compliance and deterrence focus on visible, consistent, and well-communicated enforcement. Evidence indicates that enforcement levels have declined in recent years, partly due to a reduction of over 20% in dedicated roads policing officers in England and Wales since 2010. As a result, only speeding is widely enforced, mainly through cameras, while enforcement of other fatal-four offences has decreased. This has weakened deterrence because many drivers believe they are unlikely to be caught.

Effective measures to improve compliance include:

Recent experience with AI-based enforcement technology illustrates the potential impact of these measures. Deployment of automated camera systems in Devon and Cornwall has been associated with a 50% reduction in seatbelt offences and a 33% reduction in mobile phone offences at monitored sites, alongside a sustained reduction in serious casualties between 2022 and 2024. This demonstrates that consistent, visible enforcement – supported by modern technology and clear communication – can significantly improve compliance and deter dangerous driving behaviours.

 

March 2026