Written Evidence submitted by Michael Hubbard (RSM0110)

INADEQUATE RISK ANALYSIS IN “SMART MOTORWAY SAFETY: EVIDENCE STOCKTAKE & ACTION PLAN”, DEPARTMENT FOR TRANSPORT 2020

I write as a user of motorways made anxious by removal of hard shoulders and erecting of ARMCO crash barriers along the left hand lane, knowing I can’t choose to break down near one of the new laybys, and therefore may have no escape from live lanes of high speed traffic.  The sad and mounting toll of deaths and serious injuries in live lanes of ‘smart motorways’ heightens the anxiety.

I am retired from University of Birmingham after a career which included much project planning.

My submission focuses on the inadequate analysis of risk in Highway England’s ‘Smart Motorway Safety: Evidence Stocktake & Action Plan’ 2020, and how this leads to an action plan which is doing little to allay public fears regarding ‘All Lanes Running’ (ALR) motorways:

1. The report does not specify safety objectives, the risks to achievement of which should be the focus of the risk analysis.  Since motorways are public investments, transparent safety standards set by public authority should have been specified, against which the risks are assessed.  Why are these standards absent from this policy document setting out the action plan, foreworded by the Secretary of State?

2. Risk of serious or fatal injury once stopped in a live lane is not analysed. Increased serious and fatal injuries as a result of stopping in a live lane of ALR motorways are noted but then set aside. This despite the evidence from Highways England’s earlier assessment that ALR will cause more than a three-fold increase (216% increase) in the frequency of vehicles stopping in a live lane, compared to traditional motorways[1].  Surely this should have led to a calculation of the likelihood of serious or fatal injury once you are stranded in a live ALR lane, compared to a traditional motorway?  But strangely the stocktake doesn’t address this risk which is uppermost in the minds of drivers on ALR motorways.  It confines itself to overall statistical likelihoods: “Although the risk of an accident involving a vehicle stopped in a live lane has grown, the level of risk compared to other hazards remains small” (para 4.5, page 46).

3. There is no analysis of consequences of perceived increased risk of death or serious injury if you are stranded in a live lane:   As a result of not seeing this elephant in the room, the stocktake also fails to analyse its consequences.  What is the change in anxiety levels among drivers using ALRs compared to traditional motorways?  Yes, people matter, not only traffic volumes and costs. Perceived risk changes behaviour. How many drivers stationary in an ALR live lane manage to reach one of the new laybys or other place of safety, compared to traditional motorways?  Drivers fear they will not break down conveniently near a layby. Is that right?  Have they been asked?  It seems not. How many drivers believe MIDAS and recovery services will provide them with as much safety as a continuous hard shoulder? Are they correct in their assumptions? Do ARMCO safety barriers along left lanes increase risks to stranded drivers? Are there consequences of evasive actions by drivers to reduce their risk of being stranded in a live lane? How many drivers avoid driving on the converted hard shoulder? How many drivers avoid ALRs altogether if they can?  Do these actions affect traffic flow? The stocktake’s headline observation that ALR reduces risks overall depends on increased traffic flow.  But there is no research or analysis of any of these questions. 

4. The action plan does little to allay fears:  Unsurprisingly, these major gaps in the risk analysis produce an action plan which seems not to have increased confidence among users.  Some promises, such as including ‘obstructed lane’ in overhead signalling and the promise to “investigate and take action where there have been clusters of incidents” are welcome. Are they being delivered?

Rollout of ALR is to continue apace, with dynamic hard shoulder running (DHS) to be replaced by ALR, despite ALR being the option with the highest rate of people killed or seriously injured.

More laybys are promised, better signposted, but still one mile apart (remember the original plan was 500 metres apart? How was that decided and why was it lengthened? How far are drivers of stranded vehicles able to walk to a layby and phone? What if they are disabled?).  Faster rollout of MIDAS is promised (but why was MIDAS rollout allowed to slip so far behind ALR rollout when it is so vital to driver safety?).

More rescue teams are promised, to reduce average waiting time for a stationary vehicle from 17 minutes to a target of 10 minutes (was that target researched? If so, why was it not considered important enough to include in the risk stocktake? If most or all collisions with stationary vehicles happen in less than 10 minutes this will have little impact).

The promised spending of an extra £5 million “to further increase awareness and understanding of smart motorways, how they work and how to use them more confidently”(para 1.20, page 66) assumes that public distrust of smart motorways is because the public is misinformed.  The stocktake made no attempt to assess whether the public is misinformed—so on what basis is it assumed that this information campaign is needed?   The Highways England advice on what to do in an emergency or breakdown has been included in the action plan.

It does not inspire confidence in this user regarding Highways England’s communication skills nor that the £5 million will be spent well.  The advice ranges from the obvious (eg. turn off the motorway if you able to, bring a charged phone and warm clothing) to the aspirational (“Use an emergency area if you can reach one safely”) and the amazing (move your vehicle “to the hard shoulder (where available)”---but surely not on ALRs where there is none and you are confronted by an ARMCO crash barrier when you try to do so?).   A useful piece of concrete information---the phone number on which Highways England can be contacted if you are in an emergency---is unfortunately an 0300 number for which you will be charged.

In conclusion, the stocktake and action plan reflect an approach which was common worldwide thirty years ago, when user safety was mainly left to the car maker and the driver.  This is despite Highways England formally adopting the Safe Systems approach in 2015, with a Towards Zero approach under which a ‘forgiving principle’ is central in road systems design to take account of people’s capabilities and limitations so that severe injuries and deaths don’t result from accidents.  The principle has not been incorporated into Highway England’s actions. The stocktake and action plan show that government and Highways England are determined to push ahead with rolling out ALR ---as they did in the face of the Select Committee’s call in 2016 for the rollout to be paused--- despite its higher risks of serious injury and deaths, and despite calls of motoring organisations, a coroner and public petitions for it to be halted. 

April 2021