Written evidence submitted by RAC Motoring Services (RSM0099)
About the RAC
The RAC provides complete peace of mind to 12 million UK private and business drivers, whatever their motoring needs. We provide breakdown assistance, with a 1,600-strong branded patrol workforce attending more than two million breakdowns every year, fixing on average four out of five vehicles at the roadside.
Additional products include insurance, a used car buying website, vehicle inspections and checks, legal services or up-to-the-minute traffic and travel information.
The RAC also works to support the interests of its members and UK drivers on the most important motoring issues which it identifies via the annual RAC Report on Motoring and the RAC Opinion Panel. The Report on Motoring is the longest running analysis of driver opinion in the UK having been published every year since 1989. The 2020 RAC Report on Motoring can be found here. The RAC website can be found at www.rac.co.uk.
RAC Response: Introduction
Smart Motorways have become a contentious topic among policy-makers and the driving public. Our response to this inquiry looks at all the evidence available and research we have done on behalf of drivers to ensure that our representation is fair. The RAC has some serious concerns about the risk to drivers that suffer a breakdown on an all-lane running smart motorway especially. The 2019 RAC Report on Motoring asked a number of questions about drivers’ views of all-lane running smart motorways which we have used in our response where applicable alongside other evidence.
Our call for evidence – RAC response
• the benefits of smart motorways, for instance to reduce congestion on busy sections of motorway, and how necessary they are;
While there is increasing concern about some of the design aspects of smart motorways, it is worth remembering that there are several positive aspects of the schemes. These include:
- Variable speed limits: The ability to control traffic flow allows Highways England to manage congestion more effectively. This tends to allow to smoother running traffic rather than continuous stop-start traffic. This has environmental benefits as well as congestion and fuel-saving benefits for drivers. We have become more concerned, however, with Highways England’s shift towards using verge-mounted gantries which we believe are less visible than the previously more widely used overhead gantries.
- Variable message signs and information: The increasing prevalence of variable message signs to inform drivers of congestion, delays and incidents ahead are positive and are generally well received by drivers. According to research for the 2019 RAC Report on Motoring, more than half (54%) of drivers say they have confidence in the accuracy of variable (electronic) message signs warning of incidents ahead. These help to make drivers more alert and careful when driving and to anticipate potential incidents.
- Cost effectiveness on increasing capacity: The 2019 RAC Report on Motoring found the 52% of drivers agreed that smart motorways are a cost-effective way to increase capacity on congested motorways. The Government and Highways England has demonstrated that the smart motorway programme is a more cost-effective and time-saving way to increase capacity on the motorway network.
- Monitoring and the use of cameras: We welcome the use of closed-circuit TV camera equipment which is relayed to the control centres while the use of MIDAS technology is also an effective tool to change the speed limit and control traffic flow. Speed cameras can also be effective in enforcing speed limits, particularly where incidents and breakdowns have occurred.
• the safety of smart motorways, the adequacy of safety measures in place and how safety could be improved;
The Department for Transport’s evidence stocktake of early 2020 concluded that smart motorways overall are no less safe than a conventional motorway, however we remain concerned about the dangers to drivers and passengers of vehicles that suffer a breakdown on an all-lane running smart motorway for the following reasons:
- Heightened risk in a live lane: Highways England’s own impact assessment suggests a much bigger risk to stationary vehicles in a live lane. In a report in 2016: “A stationary live-lane obstruction creates a particular hazard during off-peak conditions (when flows are low and speeds are high) due to the increased severity associated with collisions involving large speed differentials. This is captured in the ALR generic hazard log as hazard H135: “vehicle stops in a running lane – off peak”. Compared to the D3M (3 lanes + hard shoulder) design used as the safety baseline, the assumption in the hazard log is that the H135 risk increases by 216%, making it the fourth highest scoring residual hazard.”
- Vehicles not reaching refuge (SOS) areas: Former Highways England chief executive Jim O’Sullivan told the House of Commons Transport Committee in November 2019 that 38% of all breakdowns on ALR stretches occur in live lanes (rather than a refuge area), indicating a substantial number of vehicles at a higher risk when a breakdown occurs.
- Detection of stranded vehicles: We are very concerned by the length of time it appears to take to detect a vehicle and close the lane to traffic. A report by Highways England suggested that CCTV operators took an average of 20 minutes to spot a stranded vehicle and close the lane for it to be recovered. In one case a vehicle was left for more than an hour before the lane was closed. We also remain concerned that the latest stopped vehicle detection (SVD) technology is not in use across the majority of the ALR smart motorway network. An FOI in 2019 showed that only 24 miles had been fitted with the technology. As of autumn 2019, SVD technology covers only 18% of stretches where the hard shoulder has been permanently removed. Much of the network instead uses a MIDAS loop which only picks up slowing traffic and adjusts speed limits accordingly before a lane is closed.
- Enforcement of red X: We are concerned that many drivers continue to disobey the red X (lane closed) signs. According to the M25 ALR year 3 evaluation report, 6% of vehicles on this stretch were non-compliant with red X signs, while research by the RAC found that more than a fifth of motorists have driven in a lane closed by the red X sign in the past year. As of February 2021, enforcement of the red X signs is taking place, but not along all stretches, with around half not functioning.
Therefore our conclusion is that while the overall safety of all-lane running appears to be in line with a conventional motorway, we are not satisfied that drivers who suffer a breakdown are safe as they should be, given the lack of appropriate detection technology, the large spacing between refuge areas and a lack of enforcement of the red X lane closed signs. We do not believe the safety measures in place are as rigorous as they should be. Our view is that should the Government persist with the roll-out of ALR, the minimum needed is:
- Stopped vehicle detection must be implemented across the entire smart motorway network, alongside current MIDAS technology and there should be sufficient numbers of staff in contact centres to monitor the network. While we are pleased that the date for completion has been brought forward to 2022 (rather than Highways England’s original deadline of 2023), we struggle to understand why these schemes were developed without the technology in the first place. We urge the Government to continue to look at any technology which can assist in quickly detecting stranded vehicles and closing lanes as soon as possible. Even stopped vehicle detection technology is not 100% fool-proof, with Autotrader reporting in March 2021 that SVD could miss up to 15% of stopped vehicles so it is important that other technology should be considered to work alongside SVD and MIDAS where needed.
- More traffic officer patrols: We welcome a commitment from Highways England to increase traffic officers on the smart motorway network, as outlined in the actions from the evidence stocktake. However, a Freedom of Information request by the RAC in March 2020 revealed that the number of full-time traffic HE traffic officers fell by 5% between 2013 and 2020.
- Nationally consistent spacing standards of SOS areas: The evidence stocktake makes clear the new spacing standards for SOS (emergency refuge) areas will be for future all-lane running schemes. We do not believe this is adequate and do not want to see a two-tier system of all-lane running smart motorways where certain sections are safer than others. If the Transport Secretary believes that the new design scheme is safer, then the Government should roll this standard out nationally across all schemes, retrofitting where required. Refuge areas should be spaced at no further than 0.75 miles apart unless there are other areas to pull off the motorway such as junctions.
- Variable Message Signs: We urge Highways England to make the overhead gantries the default design option, supported with verge-mounted gantries where neededWe feel more VMS signs would be helpful in quickly conveying to drivers that there is an obstruction ahead as these are typically spaced at every an average of 1km apart, meaning there could still be a high proportion of drivers that have already passed a sign which has just been switched on. We would believe there is also an opportunity for more design ingenuity to quickly highlight lane closures thereby ensuring fewer drivers miss them.
- Red X enforcement: We would encourage the full enforcement of red X ‘lane closed’ signage to be rolled out as quickly as possible. Recent evidence highlighted by The Times suggests that around half of cameras are not yet capable of enforcing the red X sign despite promises from Highways England for many years that enforcement would be a priority.
- Those with disabilities: We are concerned that drivers and passengers that have disabilities are at a much greater disadvantage as they will not be able to leave the vehicle and jump over the barrier quickly as per the current advice. They will likely need to remain in their vehicle and dial 999. We believe it is vital that the Government ensures that all lane running smart motorways complies with equalities legislation and works closely with disability organisations.
• whether All Lane Running is the most suitable type of smart motorway to roll out or if there are better alternatives;
When the Government announced plans to scrap the dynamic hard shoulder (DHS) schemes, the RAC questioned whether the Government’s approach to scrapping these was correct. According to the evidence stocktake, dynamic hard shoulder schemes tend to have lower serious casualty and fatality rates:
- Fatal casualty rates on controlled (0.07 per hmvm), DHS (0.07 per hmvm) and ALR (0.11 per hmvm) are lower than conventional motorways (0.16 per hmvm).
- Serious casualty rates on controlled (1.2 per hmvm), DHS (1.2 per hmvm) and ALR (1.3 per hmvm) are slightly higher than conventional motorways (1.1 per hmvm).
- Slight casualty rates are higher on controlled (14 per hmvm) and DHS (15 per hmvm), compared to conventional motorways (10 per hmvm), while ALR rates are slightly higher (11 per hmvm)
While all-lane running overall has reasonably good levels of safety, it is not the safest type of motorway on any casualty severity level, while dynamic hard shoulder schemes have fewer fatal and serious casualties.
The physical presence of a solid white line could explain that when the hard shoulder needs closing, there may be better compliance, while other factors such as increased variable message and speed signage and closer refuge spacing may be other contributory factors. That said, from a breakdown operator’s perspective, it can be safer to attend a breakdown on an all-lane running because there is a requirement for the physical presence of either a traffic officer or the police before a patrol attends to a stranded vehicle, which is not the case where there is a hard shoulder, meaning that operators are at greater risk from moving vehicles.
In terms of reliability of all-lane running schemes, we also have some doubts about how robust they are in preventing congestion. Data from an FOI request made by the RAC in 2019 raises questions about performance reliability of ALR schemes when compared to conventional widening. The data below compares two stretches of the M25 – one is the four-lane plus hard shoulder ‘controlled/managed motorway’ between junctions 18-23, and the other is the four-lane all-lane running smart motorway with no hard shoulder between junctions 23-28:
Operation times: 1st August 2018 to 31st July 2019
M25 Junctions 23-28 (All-lane running smart motorway - four lanes with no hard shoulder)
M25 Junctions 18-23 (managed motorway four lanes + hard shoulder)
Live lane closures due to an incident
Percentage of time the live lane carriageway was reported as ‘clear’
How many incidents of delays of 30 minutes or more were reported in either direction as a result of an incident?
In an ideal world, we might use traditional widening (to four lanes with a hard shoulder) with the latest technology to make our motorways as safe as possible, but this would be more costly and would take longer to complete.
• public confidence in using smart motorways and how this could be improved;
The 2019 RAC Report on Motoring found the following in relation to public confidence of all-lane running smart motorways (note: DHS and controlled motorways were not researched)
- Removing hard shoulder: 68% of drivers in England think that removing the hard shoulder compromises safety in the event of a breakdown.
- Reaching SOS area: 72% of drivers are worried about not being able to reach an emergency SOS area if they break down.
- Gap between SOS areas: 59% think the distance between SOS refuge areas, at up to 1.6 miles (2.5km) apart, is too far, with only 13% disagreeing and 28% not expressing a view.
- Knowing what to do in a breakdown: Only half (51%) say they know what to do if they break down and are unable to reach a refuge area, meaning the remainder (49%) are unclear.
- Impact on congestion: 77% of motorists believe that a breakdown on a live lane leads to increased congestion.
- Cost-effective principle: 55% agree that smart motorways are a cost-effective way to increase capacity on congested motorways, with only 15% disagreeing (30% did not express a view).
- Trust in detecting vehicles: 54% of drivers surveyed agree with the statement “I trust highways authorities’ abilities to detect a stationary vehicle in a running lane and respond accordingly” – a fifth (20%) disagreed while a concerning 26% did not have an opinion.
- Trust in Variable Message Signs: 53% agreed they had confidence in the accuracy of electronic variable messaging signs warning of incidents ahead (22% did not express an opinion).
- Speed limit compliance: 56% said the majority of drivers heeded the variable speed limits on smart motorways, but worryingly a quarter (25%) think the majority don’t. However, 65% claim to often see speed limits on smart motorways reduced for no apparent reason.
We accept that this data is now nearly two years old and more recent concerns and media coverage may now have made the driving public more sceptical of all-lane running smart motorways. We will continue to research drivers’ views on this configuration.
• the impact of smart motorways on the usage and safety of other roads in the strategic road network;
The RAC has no evidence to suggest that users are avoiding smart motorways and using alternative strategic roads, however this is something we are looking to explore in future research.
• the effectiveness of Highways England’s delivery of the smart motorways programme, the impact of construction works, and the costs of implementation.
Smart motorways have evolved since 2002 when controlled motorways were introduced. This was followed by more significant changes on the M42 in 2006 with the opening of the first dynamic hard shoulder scheme. Refuge areas on this stretch of motorway were every 500m to 800m apart with plentiful gantries and messaging signs; these distances, however, were increased in subsequent schemes. The first all-lane running stretch opened in 2014 on the M25 and through the DfT’s Road Investment Strategy, these schemes have been rolled out more widely since. We believe there has been a number of strategic errors on programme delivery:
- Lack of full consultation: The 2016 Transport Committee inquiry noted: “while there is a statutory requirement for a consultation when installing Variable Mandatory Speed Limits, there is no such requirement for consulting on All-Lane Running as a whole”. We feel the lack of engagement at the beginning of the process to change the default design from dynamic hard shoulder (DHS) to ALR, including increasing the spacing between refuge (SOS) areas, was a mistake on the part of the Highways Agency (as it was known then) and concerns that continue to be raised now could have been addressed when the ALR idea was conceived.
- No public awareness campaign: Highways England launched a public information campaign on 15th March 2021 which emphasised ‘go left’ on a motorway if you encounter any technical difficulties while driving. We broadly welcomed this but feel this is something that should have been done many years ago. Not communicating to drivers what to do in the event of a breakdown with such a radical design change to motorways is akin to introducing new emergency landing procedures without telling the pilots.
- Building motorways without full technology to detect stranded vehicles: Given that 38% of all breakdowns on all-lane running smart motorways occur on a live lane, we believe that these schemes should have always had the best technology possible to detect stranded vehicles.
- Lack of enforcement: A key issue to reduce red X non-compliance is enforcement. In May 2019, Highways England made announced their plans to enforce the lane-closed signs, however almost two years later, delays with type approval and equipment that isn’t engineered to detect red X offences means that around half of these cameras are not enforcing.
- Safety barriers – lane one: While we undoubtably understand the safety reasons for constructing safety barriers next to lane one, the impact of these barriers might mean a stranded vehicle cannot get off the carriageway. While it is not recommended practice to move the vehicle off the carriageway surface in the event of a breakdown, instinctively a driver will want to ensure their vehicle is as far away from harm as possible. Therefore, we would like to see the merits of either moving some of these barriers away from lane one to allow a vehicle to get off the carriageway, or if safe to do so, the complete removal of the barriers on many stretches. We understand there might be a safety trade-off here so would welcome Highways England looking closely at an impact assessment and any potential benefits.
- Near misses: A Freedom of Information (FoI) request by BBC Panorama to Highways England showed that on one section of the M25, the number of near misses had risen 20-fold since the hard shoulder was removed in April 2014. As part of the process, we feel it is important for Highways England to publish more openly the number of near misses and investigate more fully why they are occurring.