THE TRAFFIC SIGNS REGULATIONS AND GENERAL DIRECTIONS 2015 Response by the Campaign to Protect Rural England to the consultation by the Department for Transport June 2015 Introduction 1. The Campaign to Protect Rural England (CPRE) welcomes the opportunity to respond to this consultation on the proposed changes to the Traffic Signs Regulations and General Directions (‘the Regulations’). CPRE fights for a better future for the English countryside. We work locally and nationally to protect, shape and enhance a beautiful, thriving countryside for everyone to value and enjoy. As a charity with about 60,000 members, a branch in every county, over 200 district groups and more than 2,000 parish council members, we have considerable local and national expertise in relation to a wide range of road and development proposals. 2. CPRE has for many decades been concerned about the impact of signs on the character of the countryside. In 1996 we published The Cluttered Countryside, which brought together the various threats to the countryside. We recognise however the need for some signs to manage traffic, for example to restrict lorries from unsuitable roads or reduce speed in villages. CPRE was involved in the Department’s Traffic Signs Policy Review between 2008 and 2011, in particular in relation to speed limit signage. 3. We welcome the interest shown by the Government, in particular the Secretary of State for Transport, who said when he gave CPRE’s annual lecture in 2012: ‘Too many country roads carry a reminder of how insensitive planners can be to aesthetics. Ugly and unnecessary signs clutter up the network. New signs seem to sprout like weeds, without any apparent consideration of what’s already there. Often what we’re left with is not just a blot on the landscape. It’s confusing and potentially dangerous too.’ 4. This response comes in three parts. First an overview, which includes some points that do not fit well into the consultation questions. Second, answers to the consultation questions. We have not answered questions that are not relevant but have answered some questions that, despite being addressed only to highway authorities or sign practitioners, are nonetheless of relevance to CPRE’s concerns. Finally, there is an annex that shows some examples of the signs and lines that need to be added or amended. Overview 5. We strongly welcome the progress that has been made in improving the signing regulations and giving local authorities greater flexibility. We recognise that due to the complexity of the current recognitions this has been a significant undertaking, particularly 1

at a time when the Department has faced unprecedented constraints on its resources. Nonetheless we have significant concerns that the proposals are insufficient as:  Clutter is likely to continue to increase in future, as indeed is assumed in the Impact Assessment;  While local authorities are given greater flexibility through the ‘building block’ approach, there is little national consistency for different road types;  Little is proposed to treat minor roads differently, in particular give non-motorised users priority on them;  While the reforms are the biggest in 50 years, they still leave the UK way behind the changes to the French Code de la Route of 2008, which itself was some years behind other continental countries;  The proposals to relax requirements for repeater signs, although welcome and bring us closer to the continent, are likely to make it difficult for drivers to be sure of the relevant restrictions in place, particularly with the lack of any road hierarchy in the UK. 6.     

We therefore make the following key recommendations to the Department that it: Differentiates road types by providing new signs and lines for major roads and making existing signs for shared spaces and quiet lanes regulatory; Reduce clutter requirements further, for example in relation to designated (e.g. bus and cycle) lanes, clearways, and camera signs; Requires local authorities to publish traffic orders and information about other regulatory signs and lines as open data, including for existing signs and lines as well as proposals to make any changes to restrictions; Updates the Traffic Signs Manual and Highway Code as soon as possible following the commencement of the new Regulations; Brings into force Part 6 of the Traffic Management Act 2004 in relation to decriminalisation of moving traffic offences, so that more regulatory signage can be effective, particularly in rural areas where police resources are stretched thinly.

7. We hope that there will be further opportunities for CPRE to feed in to the final changes being made to the Regulations, for example in relation to ‘cycle quietways’, which may lead to confusion with quiet lanes if rolled out nationally. Open data 8. Although outside the scope of the consultation, we believe that the new traffic signs system proposed by the consultation needs to confirm with Government policy on open data if it is to succeed in its objectives. This is as much in terms of it leading to a reduction in clutter, as it being workable in terms of road users understanding the restrictions in force. Traffic orders and other restrictions, including those proposed in the new Regulations, should be ‘open data by default’. 9. The economic benefits of on-line journey planners being able to integrate information about where and when parking or loading is allowed would be huge: the Benefit Cost Ratio is likely to be infinite. As important however is the need to be fair to drivers, both in terms of providing an opportunity for consultation for changes to restrictions as well as it being reasonably easy to know what restrictions are. The system operated by ELGIN, which includes the roadworks.org portal that feeds sites such as Google with road work information, already has options for Temporary Traffic Regulation Orders and could easily be expanded. Even for those without smartphones, the private sector could easily be encouraged to provide a service allowing the public to text a street name and number, then receive a text in return setting out the parking restrictions. 2

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This would require the following actions: The Department to set up a working group and then consult on and publish both guidance and a data schema for traffic restrictions; Cut-offs for enforcement of restrictions that were not published as open data, perhaps speed limits first, then banned turns and one-ways, finally parking and loading restrictions which are the most complex.

Tackling clutter 11. Again although outside the scope of the consultation, we would like to take the opportunity to make the following suggestions to help reduce clutter further:  Integration of an element into the formula for Integrated Transport Block funding of local authorities based on clutter reduction and publication of traffic restrictions as open data – this could operate temporarily, similar to the incentive to Bus Operators to fit their vehicles with GPS and smart ticket readers;  A right to request removal of a traffic sign, where a local authority would have to respond to a request within four weeks and publish data about how it responds. This could be backed up by an on-line service or app, making it easy to report errant and unnecessary signs and lines.  Engage parish and town councils or neighbourhood forums where there are none, such as in urban areas, to identify signs that could be removed;  A one up, two down rule to encourage authorities to keep looking for signs to take down. Consultation questions 1) From the draft you have seen in this consultation, do you believe the new structure and provisions of TSRGD will give you the flexibility to design and use the signs you need to help manage traffic? 12. Disagree. While the flexibility has been increased, the options for the lowest tier of roads, what the Dutch term access roads, remain far short what is available to practitioners in our European neighbours and indeed are inadequate to manage traffic on these types of road. 2A) We would like your views on extending deregulation of sign lighting. The proposal is that any signs within 20 mph limits and zones would no longer need to be lit. This is on the basis that at slower speeds there is more time available to drivers to read the signs. 13. Yes. We very much welcome this proposal, which should help reduce light pollution electricity and related costs for local authorities, not to mention carbon emissions, without having any noticeable impact on road safety. 3A) Is there anything more we can do within TSRGD to reduce sign clutter? 14. cases   

Yes. We make the following suggestions and have provided additional detail in most in our answer to question 13 below: Phase out Controlled Parking Zone signs; Phase out clearway signs; Phase out the route recommended for pedal cycles sign (diagram 967); 3

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Use pictograms for road users rather than words, which tend to require less space as well as be quicker to comprehend – there is no logic in the current system where for some signs or markings words are required, whereas for others it is pictograms; Simplify signage for designated lanes, for example reduce requirement to re-sign bus or cycle lanes after side roads; Remove requirements for zig-zags where speed limit is 20 mph; Other changes mentioned elsewhere in this consultation response, for example removing the need for camera signs.

15. While we support greater use of branding for cycle route direction signage, we are not persuaded by proposal to make the Cycle Superhighway branding trialled in London available nationally. Superhighways tried to show something was being done for cyclists, without actually reallocating space for cycling. Indeed in some cases they made cycling less safe while having a devastating impact on sensitive streetscapes. The Danish approach to blue cycle surfacing is that ‘less is more’ when it comes to improving safety, an approach the UK should learn from. 4) Do you support the proposals to allow changes to yellow line restrictions to be made without an associated Traffic Order (TO) process? 16. Yes and we also support the proposals to make it easier to introduce cycle lanes and exemptions to banned turns for cycles. Additional guidance is needed about consultation requirements. In particular, local authorities should publish open data for all such regulatory changes, not just when they are made but also when they are proposed. This will make it easier for people to be aware of the changes. In order to make the new system transparent, it would be helpful if statistics could be collated for each local authority about the number of people or businesses raising concerns about changes to restrictions. In line with the Government’s ‘digital by default’ policy, a simple on-line form should be provided to allow people to have their say. 6A) Do you agree that pelican crossings should not be included in TSRGD? 17. Yes. We agree with Living Streets (formerly the Pedestrians Association) that other new forms of crossing are better for pedestrians as well as other road users. The requirements for zig-zags around pelican crossings can impact negatively on the streetscape, which is another reason to favour their being phased out. 7) Questions on boundary signs 18. Although these questions are aimed only at local authorities, CPRE like other environmental, civic and heritage bodies, has legitimate interests in these signs and what they signify. We are concerned that the system of boundary signs should be easy to understand and not lead to excessive signing of different types of boundary. The current system of signing county boundaries manages this. We would support the proposal for photographic boundary signs, as this could help promote the special features that make up the character of a place or county. 19. The reforms propose allowing signing for any ‘designated geographical area’, which could cover a whole range of designations including Nature Improvement Areas, Local Enterprise Partnerships and Conservation Areas. We are concerned that this could rapidly lead to confusion as well as signage clutter. There are already some features at boundaries of nationally designated landscapes – national parks and Areas of Outstanding Natural Beauty – and heritage areas, which tend to use local materials and so do not fall within the definition of a traffic sign. We share the concerns of National Parks England 4

that boundary signs should be in keeping with the landscape and suggest that these types of features should continue to be used rather than new traffic signs, so as to add to sense of place rather than detract from it. While we would not object to sensitively designed traffic signs being used at the boundary of nationally designated landscapes, we do not see a case for boundary signs to be used for other additional current or past geographical boundaries. In relation to historic county boundaries, historic features such as marker posts and locally distinctive features would be more suitable. 8) Do you support the proposal to include new definition of tourist destination for England within TSRGD? 20. Yes. We are concerned about the profusion of brown tourist signs and believe that this proposal may help tackle this problem. Tourist signs should only be provided where there is a particular need for directional signage for a significant tourist destination, rather than being viewed as a right for any tourist attraction. Brown tourist signs should only be provided where both Visit England and the local highway authority agree there is a clear need for them. 9) Do you support the proposal to remove the Guildford rules from sign design? 21. No. While we have no objection to the standardisation of the width of route arms, we are very concerned about the proposal to stop colour coding the route number and destination for lower status routes. The existing rules help differentiate minor roads of lower engineering standards from major roads. They enable drivers to see instantly whether a turning off the road they are on is onto another major road or a minor road of lower quality – rather than having to peer to see if there is an A or a B next to a road number. This system helps emphasise different road types and also can encourage through traffic to keep to major roads. The additional powers given to authorities to change road designations and the proposals in this consultation to make it easier to change speed limits could help make for a more hierarchical system. 10) Do you support the proposal to expand the use of exceptions to 'no entry' signs? 22. No. The new sign is larger yet harder to digest the meaning of quickly. Exempting buses and cycles from a no entry sign is not problematic: unlike taxis, these are visibly very different types of vehicles from general traffic. If the logic was followed through then ‘no entry except’ signs would replace many blue circular signs, which would lead to greater confusion. It would be better to design a bus, cycle and taxi only section of road (including an island to separate it from traffic proceeding in the other direction) and use the current sign, rather than add more exemptions. 11) In your view, would a sub-plate on these signs be helpful in understanding these prohibitions? 23. No. As the consultation notes, the meaning of these signs is obvious and adding a sub-plate would simply add to clutter. In some cases, compliance issues can be due to poorly designed streets that are designed around motor vehicles and that fail to give due regard to desire lines for people walking and cycling. Adding additional signs is likely to be a sticking plaster solution, when a more thorough rethink of street functions may be needed.

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12) In your view, are revised signs indicating the presence of enforcement cameras necessary, or is the proposal to deal with this through the existing planning regime sufficient? 24. As the purpose of enforcement cameras is for the detection and prevention of crime, not all the principles in the Data Protection Act 1996 apply. In any event, the installation by highway authorities of cameras on the public highway for such purposes is so common that attempting to sign cameras is no longer practical or reasonable. Signs can become out of date and it is often not practical for drivers or indeed passengers to note down contact details when moving. 25. Instead there should be a dedicated page on GOV.UK providing information to the contact details for data protection requests for each authority, including a search function that would enable users to find out who the relevant authority is for a section of road. A regularly updated national dataset containing camera information should be made available; this would allow third parties, such as SatNav providers to integrate contact details of data controllers for cameras into their systems. This would be more userfriendly, cost effective as well as meaning less clutter. 13) Do you have any other comments on the draft Schedules? 26. Yes. We make suggestions below in relation to three broad areas: traffic zones; priority lanes and signing of major routes. Major roads in rural areas 27. The lack of a rural road hierarchy - differentiation of road types for roads outside built up areas - already leads to confusion about the applicable speed limit. While the proposal to relax repeater sign requirements is welcome, it is likely to make this problem worse as drivers will be unsure what the limit is. The National Speed Limits (NSL) apply sign used to mean no speed limit at all, until the introduction of the 60 mph 1970s, indeed still appear to signify this. With speed limits increasingly reduced on busy rural main roads to 50 mph, the sight of an NSL sign signifying a higher speed limit on a side road makes the system even more counter-intuitive. 28. Road safety policy emphasises the importance of self-explaining roads and differentiation of road types. The Dutch system of Essential Recognition Characteristics is the most advanced system of road markings in the world. While CPRE very much welcomes the inclusion of 40 mph zones in the Regulations, which we proposed based on the Dutch system, further changes are clearly needed. We suggest changing the default national speed limit for cars to 50 mph but allowing highway authorities to sign a higher speed limit of 60 mph by painting a coloured strip down between median markings. This would be much cheaper than requiring them to add many additional repeater signs, while being more comprehensible to drivers. We further recommend that we move over time to the Dutch system of only using solid edge markings on high speed roads. 29. Even though clearway signs would not need repeater signs, the requirement for such signs for drivers exiting or entering at side roads adds to clutter. Adding red route style markings to the road edge would, however, lead to safety concerns as the edge marking would not be so visible in poor light conditions. We suggest that a coloured median marking also signifies a stopping restriction. A few UK authorities already use coloured medians to highlight unsafe sections of road and this practice would need to end.

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Designated lanes 30. Bus, cycle and other designated lanes are an important means to manage traffic and secure the fullest possible use of sustainable travel, in accordance with the principles in the National Planning Policy Framework. Their signage can, however be confusing as well as lead to excessive clutter. 31. We welcome the proposed removal of the requirement for a Traffic Order to introduce cycle lanes. There is no justification given why this change should not apply to bus and other designated lanes: it would be confusing to have such a different process to create one type of lane and not the other. Bus lanes rarely continue to junctions where capacity is most constrained and have less of an impact on waiting and loading than cycle lanes. We recommend that Traffic Orders are not required for bus and other designated lanes but not where any type or all traffic is prohibited in travelling in one or more directions. 32. Other countries commonly combine the signs for with flow and contraflow bus or cycle lanes onto the same sign, in other words diagrams 959(.1) with 960(.1). Not only would this reduce clutter and cost, it is simpler to understand for all road users. Authorities already have the flexibility to change the number of lanes on a with flow or contra flow lane sign, there is no reason why they should be provided with the flexibility to include lanes in the opposite direction. 33. Plates beneath priority lanes stating that their hours of operation are ‘at any time’ or ‘Mon-Sun’ are superfluous, add to clutter and make a sign harder to read. They should not be permitted. We suggest that ways to reduce the need to sign bus and cycle lanes after minor junctions should be considered. Where a priority lane is continued past a side road with markings and coloured surfacing, there should not be a requirement to provide an upright sign. Where such a lane is only part-time, then a driver coming from a side road that is not familiar with the hours of operation would lose the opportunity to use the additional lane. But many drivers keep out of bus lanes even outside their hours of operation, so the loss would be negligible compared to the reduction in cost and clutter. 34. Bus lanes usually end before junctions to allow general traffic to turn left. Diagram 1050 is used to direct all traffic ‘EXCEPT BUS’ using the nearside lane to turn left. This is unhelpful for other motor traffic permitted to use the bus lane and can be dangerous for cycles. The cycle symbol should be used in such instances. Similarly flexibility for the sign for appropriate lanes at a junction ahead (diagram 877) should enable different vehicle types to be added after the word ‘Except’ as well as cycle lanes shown. 35. Diagram 1048 currently is the marking for ‘BUS ONLY’ but it is proposed to change this to ‘BUS GATE’. No rationale is provided for this changed wording, which has a less obvious meaning. This change should not be made but the requirement for the word AND or symbol & to be used should be removed. 36. In relation to cycling, we would recommend abolition of the recommended route for pedal cycles sign (diagram 967). This sign is not used in other countries and, with the introduction of new quietway and cycle street signage in addition to mandatory cycle lane and cycle track signs, it is not realistic to expect road users to understand the differences. We would recommend the diagram 1001.2A includes a variant of Advanced Stop Lines with an offside lead-in cycle lane, as this is useful where motor vehicles must turn left but cycles can proceed straight ahead, for example into pedestrian zones. It is unclear

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whether the relaxation of the rules in relation to yellow boxes would enable cycle lanes to be marked through junctions, as is common in Ireland. We suggest this should be possible. Zonal restrictions and pedestrian priority 37. Zonal parking restrictions have become increasingly complex. Many local authorities are no longer using Controlled Parking Zone (CPZ) signage when they introduce new parking restrictions. CPZs add to clutter while their restrictions can be confusing for drivers where the zones are large or complex. While we very much support the inclusion of Restricted Parking Zones (RPZ) in the TSRGD, the difference between ‘restricted’ and ‘controlled’ is not logical and the sign itself is large. We recommend changing the RPZ sign so there is simply a no waiting roundel followed by ‘ZONE’, with any exceptions or other details such as ‘No loading’ beneath. Other zonal parking signs should be phased out. 38. We recommend adopting a continental approach to different traffic zones, for example as adopted in the reforms to the French Code de la Route in 2008, following changes in other countries in the generation before that. We do not agree with the proposed new wording for pedestrian zone signs, which would add the word ‘and cyclists’. The problem is the sign, which, rather than showing a pedestrian zone as is the norm on the continent, shows a no (motor) vehicles zone. A continental sign (see annex) should be used with the option of adding ‘Except cycles’ etc. This would help emphasise that there is not just a restriction on motor vehicles but that an area is prioritised for pedestrians, such that cycles and any other vehicles permitted should give due precedence to pedestrians. 39. It is not surprising that a shared space sign for non-residential areas has had to be introduced: many other European countries have similarly expanded home zone style signs from residential areas to wider contexts. No other country, however has two different signs and, as with parking zones, this few road users will understand the difference between signs for home zones (diagram 881) and the new share space sign (diagram 886). We recommend replacing both informatory signs with a regulatory sign based on that in France, Switzerland and Belgium. The name may be trickier to get right but ‘shared street’ is used hereafter. Quiet lane signs should become regulatory too. As on the continent, there should be no need to post an ‘end of’ sign where there is another zone, for example a pedestrian zone, shared space, 20 zone etc. The sign for traffic calmed area (diagram 883) should be abolished too as traffic calming is so common now and this sign is superfluous. 40. Pedestrian zones, shared streets and quiet lanes should be designated as pedestrian crossings within the scope of section 25 of the Road Traffic Act 1988. This provides wide powers to ‘make regulations with respect to the precedence of vehicles and pedestrians respectively, and generally with respect to the movement of traffic (including pedestrians), at and in the vicinity of crossings’. Regulations should then be made to give pedestrians priority on all these types of area and to give cyclists and, in rural areas, riders and livestock priority (i.e. on quiet lanes) as appropriate. 41. A speed limit of 12 mph should apply on shared streets (equivalent to the 20 km/h on the continent), such as by putting a 12 roundel in the sign, and parking should not be permitted in pedestrian zones or shared streets except where explicitly permitted. This would tackle the problem of otherwise needing to have additional signs and sub-plates that can make the overall signage so large it cannot easily fit in some places and clutters up others.

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42. The changes to the crossing regulations, which have yet to be inserted into the draft Regulations, should make sure that drivers are prohibited from stopping on any type of pedestrian, cycle or equestrian crossing and that the contravention is enforceable in the same way as for a yellow box junction. CPRE June 2014

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Annex – different traffic signs Dutch rural road hierarchy Representation of lining and signing

Essential recognition characteristics Through road: the green stripe and continuous line along the edge signifies a higher speed limit of 100km/h (62mph) on a rural single carriageway without the need for additional speed limit signage. The median white markings can be made continuous where overtaking is prohibited. Separate provision for non-motorised users and sometimes farm traffic.

Distributor road: rural road with national speed limit of 80km/h (50mph), characterised by median markings and broken edge markings. The median markings can be continuous where overtaking is prohibited.

Access road: minor road with posted speed limit of 60km/h (38mph), no median markings and broken edge markings at a distance from the edge, to provide prioritised space for non-motorised users.

The new markings for through and distributor roads are expected to be rolled out nationwide by 2015. More information is available in Predictability by recognizable road design (SWOV, 2012). Note that local speed limits may be imposed to vary the national speed limits above. Suggested changes for UK:  Through road: the coloured line would also signify no stopping  Access road: edge markings would not be needed, particularly on narrower roads or in nationally designated landscapes

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Priority zone signage Continental shared zone

Continental pedestrian zone

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