Written evidence submitted by the Automobile Association (AA) (RSM0111)

 

Overview

 

This enquiry is welcome as the AA has voicied concerns of our members, patrols and employees regarding smart motorways since 2012. The initial M42 trial appeared to  provide additional capacity in a relatively safe manner. However, the decision to extend the distances between Emergency Refuge Areas (ERAs) from approximately every 500m to 2,500m (1.5 miles) without consultation in 2012 has been consistently challenged by us and we believe was a dangerous and serious error based on cost savings rather than on grounds of road safety.

 

Throughout this time, we have raised our concerns with a dozen Secretaries of State and Roads Ministers who showed varying degrees of interest in the matter. We are grateful and acknowledge the efforts of the current Secretary of State, Grant Shapps, for his interest in the subject and his willingness to listen and engage. His Evidence Stocktake in March 2020 was a good start and we have expressed support for many of the actions outlined in this plan.

 

However, we believe that a fundamental flaw in ‘smart’ motorway design  lies in the distancing between ERAs. While the new standards outlined in March 2020 state that new schemes will have ERAs placed every 0.75 miles but no more than 1.0 miles apart, there seems to be a general contentedness to leave the existing network untouched with ERAs spaced at 1.5 miles apart

 

We believe that this anomaly needs to be addressed urgently. We cannot understand how a design which is deemed unacceptable for new schemes is still allowed to be operational and will continue to be so for several years while reviews are undertaken. We call on the committee to recommend the suspension of the RIS2 ‘smart’ motorway rollout and re-focus the efforts during this period to allow Highways England to retrofit ERAs to the new standards on the existing network.

 

Too many people have died unnecessarily on smart motorways. We believe some of these deaths would have been avoidable had a full safe systems approach to smart motorways been implemented before 2015. See  https://www.royalhaskoningdhv.com/united-kingdom/-/media/royalhaskoningdhvcorporate/files/independent-review-of-all-lane-running.pdf?la=en-gb

 

There is also a need to reassess the requirement for future increased motorway capacity with the move to hybrid or more flexible working patterns since the outbreak of Covid. It remains to be seen whether traditional  rush hours experienced pre-lockdown will reduce as working patterns change. We believe there is a need to put a halt to the future rollout of ‘smart’ motorways while a full assessment of traffic patterns is undertaken.

 

The welcome electrification of the vehicle parc also raises questions on future proofing our motorways. Some EVs are unable to be flat-towed or can only be towed very short distances and hence the need for more stopping places (ERAs or hard-shoulder).

See https://garagewire.co.uk/news/government-to-review-ev-dangers-as-transport-minister-astonished-by-sudden-ev-breakdowns/
 

• the benefits of smart motorways, for instance to reduce congestion on busy sections of motorway, and how necessary they are;

 

When considering the original reasoning behind the introduction of ‘smart’ motorways, we agree with the foundation principles of; increasing capacity, reducing congestion and providing sustainable journey times.

 

However, we feel the supposed benefits of ‘smart’ motorways have been significantly watered down with the changes in design without consultation in 2012. The increased spacing of ERAs and the focus on “value engineering” means that elements of safety were reduced in order to cut costs.

 

Looking to the future, consideration must be given to the wider need for  ‘smart’ motorways. The covid-19 pandemic has meant more people working from home and many employers are changing the work patterns for their staff. The most significant change being the formal introduction of hybrid working, where staff are only required into a physical place of work a few times a week or month. This change could have a monumental shift on commuting habits, traffic flow and types of road used.

 

In the short-term, we believe that as the UK unlocks there will be an increase in traffic, especially on motorways, as people take advantage of UK tourism and merely want to escape their local area having been under lockdown. Over time though, this traffic could dissipate and motorway volumes may reduce.

 

Therefore, we believe the necessity of more ‘smart’ motorways can be challenged and proposed  projects planned under RIS2 should be placed on hold while wider analysis is undertaken to understand the future of roads traffic after the pandemic.

 

There is also a fundamental question whether smart motorways are having the effect forecast on reducing congestion. The Transport Secretary said reversing this traffic measure would mean acquiring land the equivalent of 700 Wembley stadium-sized football pitches and destroying large areas of green belt. That may be the case if an additional lane is added as a hard shoulder (although at least one chartered engineer disputes this) but would not be the case if the current inside lane is reverted to a hard shoulder within the current land-take.

 

Our own research shows that approximately one third of drivers never use the inside lane on smart motorways as they are concerned there might be a broken-down vehicle ahead. This, coupled to general poor lane discipline, means that the claim of smart motorways adding one third extra capacity is over-stated. See https://www.theaa.com/about-us/newsroom/drivers-avoiding-lane-one-of-smart-motorways

 

• the safety of smart motorways, the adequacy of safety measures in place and how safety could be improved;

 

It is true to say that motorways of all types are the safest roads in England, but we should always aspire to design and build the safest roads possible. While some of the incidents which have occurred on ‘smart’ motorways would have happened on a conventional motorway (i.e. a vehicle leaving the carriageway), currently on smart motorways there is double the risk of stopping in a live lane and 38% of breakdowns are in live lanes.  No matter what technology is in place, these risks associated with live lane stops are far too high and should not be sanctioned. Of course, drivers should maintain their vehicles in good condition, have adequate fuel or electric charge etc, to minimise the chance of live-lane breakdowns. However, we believe it is the lack of hard-shoulder and inadequate number of ERAs mean the risk associated with current live lane stops is unacceptable and puts lives at risk.

 

ERAs

While schemes being designed and built from 2021 will aspire to have ERAs at every 0.75 mile, but no more than 1.0 mile, we have seen little evidence to suggest that the retrofitting of ERAs on existing schemes built to the older standards will take place.

 

While the stocktake and action plan stateretrofitting will be considered, we believe that this should be the paramount consideration, otherwise a two-tier system will become commonplace as new schemes are delivered to  different standards to those constructed between 2012 and 2020. We recommend that  planned construction under the RIS2 programme should be paused and all focus and emphasis be placed on upgrading the existing network to the new standard before constructing new ALR schemes.

 

CCTV

In the pre-inquest hearing into the fatality of Mrs Begum on the M1, the coroner was informed that between seven and eight staff within the regional control centre would watch over 450 CCTV cameras for the Yorkshire and North East region, of which 287 CCTV cameras specifically overlook the ‘smart’ motorway sections. This means that staff in the control centres are looking across more than 55 cameras each, of which 35 of those cameras form part of the ‘smart’ motorway network.

 

Highways England’s counsel also advised that there is “no policy for constant or routine monitoring the motorways”, meaning that staff are merely watching over the cameras and only react if they spot something or are asked to investigate an obstruction.

 

We feel serious consideration needs to be given to the ratio of cameras per control centre staff and that more cameras are needed. Expecting one person to look across more than 50 cameras at any one time is excessive and unmanageable. While Highways England can claim they have 100% coverage of the ‘smart’ motorway network, the cameras will only point in one direction and need to be turned in order to scan the whole carriageway.

 

Stationary Vehicle Detection (SVD)

While we are pleased that the retrofitting of SVD will be completed by 2022, there are still serious concerns regarding the accuracy of the technology. As outlined by an investigation by Highways Magazine and highway engineer, Alan Hames, based on an HE report, there are question marks surrounding the ability of the radar system to identify lower vehicles like the Mazda MX5, and questions whether  Highways England mis-attributed some of the cases in the initial trial to show the technology worked.

https://www.highwaysmagazine.co.uk/Exclusive-Errors-in-report-cast-doubt-on-smart-motorway-safety-system/8925

 

https://s3.eu-west-2.amazonaws.com/assets.highwaysengland.co.uk/Knowledge+Compendium/2016-17/Stationary+Vehicle+Detection+System+(SVD)+Monitoring.pdf

 

The HE report states “One of the lowest cars is the Mazda MX5 sports coupe which has a height of 1.225m. This is lower than a motorcycle with a rider so represents about the lowest vehicle that might be expected. The SVD radar tracks detected targets and identifies “stops”

 

as when a vehicle has dropped below a threshold speed. Therefore, it will detect motorcycle and rider combinations so the Mazda is still likely to be the more testing target.”
 

It is reported that Highways England completed a new report into SVD in 2018, but they have not published the findings.

 

Due to these concerns, we would like an independent investigation into SVD and for Highways England to release their 2018 report into SVD.

 

Red X enforcement

We understand that many police forces are still unable to penalise drivers who infringe a Red X on motorways. This action needs to be accelerated as quickly as possible as the Red X plays a crucial role in protecting vulnerable road users who have broken down on the network, whilst also providing safety to those approaching the scene. 

 

Highway Code

The proposed changes to the Highway Code are sufficient, but we feel more must be done to improve access to incidents for emergency services. We believe the introduction of an “Emergency Corridor” would help emergency services attend as quickly as possible. We wrote to the Department about updating the Highway Code in 2017, however these requests were rejected. See  https://www.theaa.com/about-us/newsroom/slow-down-and-move-over

 

We believe that the current design of smart motorways and lack of an ‘emergency corridor’ means that emergency services are hindered in the golden hour of accessing the casualties from collisions. See https://www.dailymail.co.uk/news/article-9458507/Highways-England-files-no-hard-shoulder-smart-motorways-causes-chaos-emergency-services.html

 

• whether All Lane Running is the most suitable type of smart motorway to roll out or if there are better alternatives;

 

At present there is a two-tier level of ALR schemes. Schemes already constructed are not the most suitable type of smart motorway on the basis that the ERAs are spaced too far apart. However, should all existing and new schemes meet the specifications as outlined in the March 2020 stocktake then we believe this form of ALR could work as there are more opportunities for drivers to exit the live lane should they breakdown.

 

We would also want to see fundamental changes made to the management of the schemes which would include; more Highways England Traffic Officers on the network to speed up vulnerable vehicle detection, more camera operators that can pro-actively monitor CCTV, more cameras so 100% carriageway coverage is available 100% of the time and an improved SVD system.

 

• public confidence in using smart motorways and how this could be improved;

 

Public confidence in using smart motorways is at an all-time low. In our most recent survey, the thoughts of drivers were clear as more than half (56%) of drivers said the smart motorways project should be scrapped and the hard shoulder should be reinstated.

 

We have often asked about drivers’ perception of safety using smart motorways compared to a traditional motorway. The following table shows the changing pattern over several years;

 

Q. On a scale of 1 to 10 where 1 is extremely nervous/anxious and 10 is completely safe/relaxed, how safe do you feel driving in each of the following situations

NET 1-3 ANXIOUS SCORE

 

 

A motorway with a continuous hard shoulder

A motorway with no hard shoulder but with emergency refuge areas (lay-bys) about one and a half (1.5) miles apart

A motorway with no hard shoulder but with emergency refuge areas (lay-bys) about one (1.0) mile apart

A motorway with no hard shoulder but with emergency refuge areas (lay-bys) about three quarters (0.75) of a mile apart

A motorway where the hard shoulder can be 'switched on and off' so it can be used as a running lane at peak times

Jan-17

2%

14%

N/A Option wasn’t asked in this survey

11%

18%

Aug-19

2%

15%

N/A Option wasn’t asked in this survey

12%

16%

Jan-20

2%

20%

19%

18%

25%

Mar-21

1%

39%

35%

32%

39%

 

As the table shows, there is considerable fear amongst drivers when thinking about using ‘smart’ motorways. It is also clear that the closer ERAs are spaced, the more support the concept receives. This further validates our fundamental submission that closer spaced ERAs are the key element to public confidence in ALR schemes.

 

This is further enhanced when drivers consider the delivery of the Action Plan. When asked what drivers think the top three actions should be they said the following;

 

Q. In March 2020, the Transport Secretary unveiled an “evidence stocktake” into smart motorways and an 18-point action plan to help improve their safety.

 

Some of the points from the action plan are listed below. In your opinion, which of the following items should be implemented the fastest? Select up to three

 

  1. Retrofitting more Emergency Zones so that the maximum distance between them is 0.75 miles – 47%
     
  2. Retrofitting a Stopped Vehicle Detection radar system to help identify vehicles stopped in a live lane – 36%
     
  3. A public awareness and safety campaign – 28%

 

This clearly shows that more ERAs is the top consideration for drivers to help make ALR schemes safer.

 

Whilst many drivers would prefer to retain a permanent hard shoulder, we understand and acknowledge that the hard shoulder is not a safe place. Many hard shoulder stops are illegal and, as a separate issue, we would recommend further monitoring, management and prosecution of drivers abusing the hard shoulder. However, it is still preferable and safer to be able to stop on a hard-shoulder rather than in a live lane where, no matter what technology, your life is in greater risk.

 

Perhaps the poor public perception is unsurprising when HE reports show it can take a terrifying 37 minutes for the occupants of stopped vehicle in a live lane to be spotted and rescued.

 

 

If drivers can pull over to the inside lane or ‘go left’ the advice from Highways England is to leave the vehicle by the passenger door and stand behind the safety barriers (if there is one).  This is difficult or impossible for many disabled or indeed elderly drivers.

 

• the effectiveness of Highways England’s delivery of the smart motorways programme, the impact of construction works, and the costs of implementation.

 

While we have no comments on the impact of construction works, it should be noted that Highways England were working under the provision of “value engineering”, reflecting the period of austerity at the time of conception and delivery. It is clear that decisions were taken with economic constraints at the heart of the decision-making process. For example, documents written and published by Highways Agency infer that ERAs were only provided on ALR schemes to protect the reputation of the Agency. Likewise, other documents show a decision to include additional ERAs on the M1 J32 – 35a section of ALR to the cost of £2m were ruled out.

 

In terms of the delivery, we feel more action should have been taken at the very beginning of the project to make the public aware of the changes to motorways and how such schemes should be used.

 

A recent independent review of ALR by Sarah Simpson questions the fundamental safety of smart motorways. See https://www.royalhaskoningdhv.com/united-kingdom/-/media/royalhaskoningdhvcorporate/files/independent-review-of-all-lane-running.pdf?la=en-gb

 

The author states: “I am in no doubt that the ALR smart motorway has the lowest level of intrinsic safety of any form of motorway. It is my view that this is due to best practice in road safety, known as the Safe Systems approach, having not been adopted or fully implemented by Highways England (formerly the Highways Agency) in considering the implementation of smart motorways.

 

The Safe Systems approach focuses on eliminating and reducing the most deadly of hazards, with the specific aim of reducing the numbers of people who are killed or sustain life-changing, serious injuries on the road system. Unlike the traditional approach to road safety, Safe Systems accept that people are fallible with physical vulnerabilities, and that human error occurs. As well as the safety of ‘compliant’ road users, it therefore aims to ensure that people using the road transport system do not die or are seriously injured as a consequence of an unwise decision.

 

Despite the Transport Select Committee identifying Safe Systems as warranting proper exploration for adoption as long ago as 2008, this approach was adopted by Highways England only in 2015.

 

More recently, in 2020 a report for the Office of Rail and Road found significant shortfalls in the way that Highways England have implemented Safe Systems. This latter report also found that improvement schemes are consistently identified on the basis of capacity and not on the basis of improving safety. This characteristic aligns with the ‘value engineering’ approach used to compromise safety in order to secure cost savings in developing the ALR motorway format. As a result, ALR presents a controlled environment by design, which can give people the impression that they are safe, even when they are not.”

 

This analysis, coupled with the extensive research and campaigning by the AA over the last decade, shows the importance of this Select Committee enquiry and why urgent action is needed to save lives.

 

 

April 2021