— 30km/h limit should not be used on roads with “distributor function”, says legal advice
— “Not appropriate” to reduce speed limits on main roads at this time, says Council officials.
— Working group wants AA-inspired guidelines to be changed.
30km/h speed limits should not be applied to roads which have a distributor function according to legal advice given to Dublin City Council, however, a working group of councillors wants national guidelines to be altered to allow the change in limits.
The advice from officials is based on the current national speed limit guidelines, which were heavily influenced by the AA, a motoring insurance company and lobbying group. The AA was the only non-governmental organisation to have direct input to the 2013 national Speed Limits Review when led to the 2015 ‘Guidelines for Setting and Managing Speed Limits in Ireland’.
The way the guidelines are written hinders Irish councils from following those in the UK and elsewhere which have applied 30km/h to main roads and seen a safety effect related to such.
A recent report on transport in Ireland by the OECD also criticised Ireland’s system of road classification because it focused nearly solely on how traffic moves rather than other uses of roads and streets.
A report on speed limits by Dublin City Council, dated December 2021 and published on the council’s website ahead of the next transport committee meeting. The report stems from councillors, in 2021, blocking a plan from council management to apply 30km/h to most main roads in the city.
The report to councillors written by Bernard Rennick, a senior engineer, and John Flanagan, the assistant chief executive and city engineer, said: “Concerns were raised by a number of Councillors in relation to the general suitability and applicability of introducing a 30km/hr speed limits on arterial roads. The Executive agreed to seek legal advice, in respect of whether a 30km/hr special speed limit can be applied to arterial routes within the City, based on Regulations and the Guidance of the Minister of Transport. This section presents the conclusions of the legal opinion.”
The section of the report said: “The proposal to introduce a 30 km/h speed limit on arterial roads is not consistent with the Guidelines for Setting and Managing Speed Limits in Ireland (2015), under Road Traffic Act 2004. In particular it is not consistent with the various criteria which means that such limit should not apply to roads which have a distributor function. This is on the assumption that an arterial road by its various nature has a distributor function.”
The report said that it is “within the power of the local authority to introduce such 30km/h even if such speed limit is inconsistent with the Guidelines,” but in cases where a council were to consider doing so, it would have to have “appropriate and proper regard to such Guidelines”, and “must have bona fide reasons for not following such guidelines which should be expressly articulated and explained.”
Rennick and Flanagan said that based on the guidelines and their assessment “it is concluded that it would not be appropriate to reduce the speed limits of the roads under review to either 30 km/h or 40 km/hr at this time and without further assessment.”
Cllr Carolyn Moore (Green Party), chair of the Working Group on Speed Limits, is asking the transport committee to write to the Minister For Transport Eamon Ryan to change the guidelines.
In a separate report, the working group sets out a series of recommendations to the Department of Transport.
The report signed by Cllr Moore, as chairperson of the working group, said: “In order to improve road safety, encourage people to adopt forms of active mobility, reduce traffic congestion and pollution, the guidance on setting speed limits should now allow that the default speed limit in a city area may be set at 30 km/h, a change from the current situation where the default speed limit in a built up area is set at 50 kph.”
She said: “While at present a special speed limit may be set at 40kph or 30 kph, these are exceptions to the 50 kph limit and not the default. It must be stressed that this does not mean that every road will be at 30 kph but roads which have a different speed limit will have to be specifically listed and the rationale for not making them 30 clearly set out thus making it clearer that within built up urban areas that higher speeds are not endorsed.”
“There is no clear guidance on how vulnerable road users need to be considered when making a speed limit, there needs to be the ability to take into account their numbers and types with schoolchildren and the elderly having different requirements and considerations. There is need to be able to consider traffic segregation, the impact of higher road speed limits on visually and mobility impaired also and the impact of too great a speed differential on cyclists,” said the report.
The report said that there should also be clear guidance on the “type and nature of interventions which could be made on a road in order to meet its target speed”.
It said that at “present speed surveys play a part in the determination of the speed limit which applies on a particular road and so if the 85th percentile speed is used then setting of the speed limit in order to match means that in fact the use of the road is being dictated by the current speed
that traffic uses on the road rather than a target speed limit which takes consideration of
residents and use of the road by non-motorised traffic into account.”
Cllr Moore said: “I would ask that the Traffic and Transport SPC Members would consider and approve the recommendations above so that this can be conveyed to the Department of Transport and the Minister for Transport.”