A20 speed limit reduction by TfL - omission from public consultation, bypassing democratic process
Request ID: FOI-4683-2324 Date published: 17 April 2024
You asked
1. I refer to your response to FOI Request ID: FOI-2444-2324 here:
https://tfl.gov.uk/corporate/transparency/freedom-of-information/foi-request-detail?referenceId=FOI-2444-2324. Please provide the reports for each of the reported collisions shown in your table, including the precise location of each accident on the A20.
2. Please provide a copy of the statement by the BP filling station operator to substatiate your claim that "Owing to the flooding and water sheeting, this has caused numerous incidents in the slip lane leading into the BP forecourt, resulting in vehicles colliding into the petrol pumps. The operator of the BP forecourt has also reported the extreme safety risks posed on the A20 and within the forecourt. This applies to all passengers in all vehicles, either stationery or approaching the forecourt. There’s a significant risk for customers and staff being injured." This is quite an incredible claim given the BP forecourt is off the A20 and located uphill of the A20, unless TfL is claiming gravity works upside down, whereby water flows uphill and that cars don't naturally decelerate when going uphill.
3. What is the name of the director(s) who signed off on the emergency order to reduce the speed limit on the A20 to 40mph without public consultation? Please provide a copy of the emergency order.
4. The A20 was not included in the public consultation map titled "proposed 40mph speed limit map" linked here: https://tfl.gov.uk/corporate/safety-and-security/road-safety/safe-speeds. What was TfL's reason for bypassing the democratic process and omitting the A20 from the public consultation map?
5. Please describe in detail in what way "We [TfL] work with the [London Metropolian] police to increase their capacity to take enforcement action against drivers and riders who speed."?
https://tfl.gov.uk/corporate/safety-and-security/road-safety/safe-speeds
We answered
Our ref: FOI-4683-2324/GH
Thank you for your request received by Transport for London (TfL) on 18 March 2024 asking for information about the A20 Speed limit reduction.
Your request has been considered under the requirements of the Environmental Information Regulations and our information access policy. I can confirm that we do hold the information you require.
We have rerun the data from the previous request referred to, and the numbers have changed from 45 to 48 collisions, this may be because we have used provisional data. All 2023 records are currently provisional and subject to change.
We receive personal injury collision information from the police, or self-reported by members of the public online. This data is recorded using Department for Transport guidance and is generally referred to as STATS19 data. The DfT website has more details on how this data is recorded https://www.gov.uk/government/collections/road-accidents-and-safety-statistics Using DfT guidance TfL only receives details of collisions occurring on the public highway, we should not receive details of collisions occurring on the garage forecourt as mentioned in the original response.
Please see the attached information. The files show attendant, casualty and vehicle details. One collision may involve injury to more than one person or involve multiple vehicles. These files can be linked by the unique collision reference number. In accordance with our obligations under Data Protection legislation some personal data has been removed, as required by Regulation 13 of the Environmental Information Regulations. This is because disclosure of this personal data (such as names and addresses) would be a breach of the legislation, specifically the first principle of Article 5 of the UK General Data Protection Regulation which requires all processing of personal data to be fair and lawful. It would not be fair to disclose this personal information when the individuals have no expectation it would be disclosed and TfL has not satisfied one of the conditions which would make the processing ‘fair’.
2. Please provide a copy of the statement by the BP filling station operator to substatiate your claim that "Owing to the flooding and water sheeting, this has caused numerous incidents in the slip lane leading into the BP forecourt, resulting in vehicles colliding into the petrol pumps. The operator of the BP forecourt has also reported the extreme safety risks posed on the A20 and within the forecourt. This applies to all passengers in all vehicles, either stationery or approaching the forecourt. There’s a significant risk for customers and staff being injured." This is quite an incredible claim given the BP forecourt is off the A20 and located uphill of the A20, unless TfL is claiming gravity works upside down, whereby water flows uphill and that cars don't naturally decelerate when going uphill.
We have video footage of vehicles aquaplaning in flooding and colliding into the petrol station causing serious damage and risk of injury – as well as a list of incidents recorded by the petrol station. Please see the attached email from Rontec reporting these incidents to our Chief of Staff and the Commissioner. As explained above, personal information has been redacted.
3. What is the name of the director(s) who signed off on the emergency order to reduce the speed limit on the A20 to 40mph without public consultation? Please provide a copy of the emergency order. Carl Eddleston is the Director of TfL Network Management and Resilience who signed off the emergency code order to reduce the speed limit on the A20 to 40mph. Please find attached a copy of the emergency order.
4. The A20 was not included in the public consultation map titled "proposed 40mph speed limit map" linked here: https://tfl.gov.uk/corporate/safety-and-security/road-safety/safe-speeds. What was TfL's reason for bypassing the democratic process and omitting the A20 from the public consultation map? The A20 does not form part of the safe speeds programme. The 40mph speed limit on the A20 Sidcup Road has been introduced temporarily owing to ongoing surface water flooding and water sheeting which has caused a number of safety concerns. This presents a serious risk to road users and the reduced speed limit will stay in place until permanent drainage measures can be installed. The speed reduction has been implemented under an emergency order owing to the significant risk to the travelling public. No formal consultation was required and the borough was informed of our proposal.
TfL owns and maintains London’s extensive safety camera network, which includes spot speed, red light and average speed cameras. We are currently working closely with the police to achieve capacity to enforce up to one million speeding offences per year by 2024/25, which is achieved by activities such as increasing the number of staff processing speed offences and supporting implementation of more efficient working practices. This is delivered through a combination of TfL funding, as well as reinvestment of the proportion of speed awareness course income which comes back to TfL; this is used to help offset the costs of London’s extensive safety camera operation including police enforcement. TfL also part funds the MPS Roads Transport Policing Command (RTPC) which has circa 2,000 officers to ensure that there is a focus on all TfL priorities such as Vision Zero and transport crime. TfL provides a safe, secure, reliable and green service which the MPS helps support the delivery of. Recently TfL have purchased seven mobile laser cameras which can undertake speed enforcement activity using Police Community Support Officers of the MPS RTPC.
Please let me know if this is not the information you are looking for, or if you are unable to access it for some reason.
If you are not satisfied with this response please see the attached information sheet for details of your right to appeal.
Yours sincerely
Graham Hurt FOI Case Officer FOI Case Management Team General Counsel Transport for London
