This submission was made by the Dublin Commuter Coalition on 4 April 2024, in response to the Department of Transport's Call for Submissions on the Review of Road Safety Authority.
Questions in bold italics were provided by the Department of Transport, with our responses following.
Views on Services Provided by the RSA
Q 1. The RSA currently provide a range of services and functions, including Driver Testing and Licencing, NCT and CVRT Vehicle Testing, road safety advice, road safety promotional and media campaigns, and road safety education programmes, as well as working with other stakeholders to enhance road safety enforcement and inputs to road safety legislation. What do you believe to be the most important of these services and functions? And are there any other services or functions which the RSA should be undertaking that they are not undertaking currently?
The primary function of the RSA, as listed on their own website is as follows: “Our mission is to make Irish roads safer for everyone.” Whilst functionally, that may have taken the form of licensing & regulating vehicles, the most important function of the Road Safety Authority is to ensure the roads are safe to travel on for all users. Unfortunately, this has not been happening.
By not providing any priority towards protecting vulnerable road users, the RSA is failing to implement its mission statement. Most campaigns from the RSA suggest it is the responsibility of the pedestrians and cyclists to be seen, and not the responsibility of the motorist to pay the correct level of attention while operating their vehicle. They target these campaigns even at very young children, placing the responsibility for not getting hit by a car on the child rather than the person driving the car.
Regarding additional Services, the remit of the RSA should be expanded to include a focus on identifying and responding to road design issues that impact on vulnerable road users to ensure that the safest design for vulnerable road users is implemented.
Furthermore we believe the RSA should undertake an in depth accident investigation process in a representative sample of road accidents with the goal of identifying all causative and contributing factors in accidents. This should follow a process broadly similar to that used in the UK for Road Accident In Depth Studies, and give the organisation a role similar to that proposed for the Road Safety Investigation Branch in the UK. This should result in the publishing of both summary reports of the factors most common to accidents, both causative and contributory. Further the RSA should engage with TII, an Garda Síochána, and local authorities in order to ensure an action plan is devised and put into effect to mitigate the factors that contributed to each investigated accident.
It might also be useful to bring other elements of road safety under the remit of the RSA and empower them to ensure the roads are truly safe. There is no reason why automated speed cameras’ couldn’t be installed on Irish Roads, other than lacking the political will to do so. The RSA could have the remit to monitor speeding through average speed camera zones, and issue fines & penalty points to drivers breaking the law. This would go a long way to freeing up Gardai resources and speed van hours, which are often reacting to speeding happening, or that has happened. Automated speed cameras actually create a disincentive for drivers to not speed in the first place, nowhere is this better seen than with the Port Tunnel, where cases of speeding are very low due to the cameras.
Moving on from this, they could also be responsible for installing and maintaining bus lane cameras, again using ANPR to ensure our bus lanes are prioritised for those who actually need it.
Q 2. Do you have any other views on the focus and balance of the Road Safety Authority’s functions, between the driver and vehicles testing and licensing services it delivers to the public, on the one hand, and the road safety policy, promotion, education, and research functions it undertakes, on the other? (See: Role of the RSA)
The RSA has a gap in its research and advocacy functions related to road and street design. The Road Safety Authority has been absent in pushing Local Authorities, the National Transport Authority and Engineering companies to deliver the safest possible design for vulnerable road users. This is a missed opportunity to push for new road and street designs to protect vulnerable road users through inherently safer design, and is a much stronger intervention than relying on awareness campaigns where the emphasis is put on the vulnerable road user to be visible rather than for segregation and protection for vulnerable road users’.
Furthermore, the RSA should ideally do semi-regular research into the prevalence of other dangerous traffic offenses such as running red lights, or using a mobile phone while driving, as is the case with the free speed survey. These should be used by An Garda Síochána as an input into their road policing plans, and to measure the effectiveness of roads policing actions.
One of the core responsibilities of the RSA is ‘Road safety and collision research’ and whilst it may be carrying out this research, it has recently been revealed that for the last eight years, the RSA have not been releasing that data to local Councils, citing GDPR as the reason they cannot do so. It is impossible for County Council engineers & town planners to make data driven decisions about road design, if the body tasked to collect that research is not empowered to release it.
It is imperative that this GDPR issue is immediately rectified, there is no reason under GDPR why personal data cannot be redacted when sharing collision data with local authorities.
It is of great disappointment that it seems like the primary function of the RSA is to help drivers, rather than promote road safety and education services. One glance at the RSA website is all that’s needed to see this. In prime position on the website are links to apply for driving licenses or tests, it is only as you scroll down, close to the end of the website are you presented with safety information and Vision Zero.
It would be far better if people visiting the website were met with safety information or campaigns to ensure drivers pay attention on the roads or drive at appropriate speeds. If most people accessing the website are doing so in order to apply for licenses or schedule tests, then they are the prime audience to target for safety messaging.
Views on the approach to funding of the RSA
Q 3. The RSA’s functions and operations are mostly self-funded, from the fees it charges for the provision of services, including driver licensing and testing, and passenger and commercial vehicle roadworthiness testing services (the NCT and Commercial Vehicle Roadworthiness Testing), with little direct Exchequer/public funding received. What are your views on this self-funding model rather than an exchequer funded model or a mixed funding model?
There is a significant conflict of interest in an organisation whose remit is to improve the safety of Irish roads, but whose funding is almost completely reliant on maintaining or increasing the number of vehicles on Irish roads.
The vast majority of the operational funding for the RSA, is generated through fees paid for Driving License applications and NCT testing. This leaves the RSA with a fundamental reliance on private car use, in order to have their funding increased over time. That can lead to a serious imbalance in safety communication, response, and actions.
Worse still are the results the RSA are achieving with the monies they oversee. €3.8 Billion was invested towards Phase 1 of the 2021-2030 road strategy, which contains milestones that the RSA will completely fail to meet. The results are so poor that every single year since the strategy has been released, we have seen an increase in road deaths and serious injuries. That €3.8 billion investment, and ultimate failure to meet the organisational goals, has not resulted in a single public investigation, reprimand, or resignation from the very body tasked to keep our roads safe.
What needs to happen immediately, is a comprehensive investigation into how these vast sums have been invested across the 50 identified ‘High-Impact’ actions, and a report generated which outlines why they have failed to reduce road deaths and injuries. Furthemore, the funding model needs to be changed to a direct-exchequer funded model, with an appropriately laid out budget, alongside a rigorous oversight process.
Views on the future of the RSA
Q 4. Do you have any views on the future role of the Road Safety Authority?
The RSA should be one of the most important pillars of the transport industry in Ireland, but it needs massive reform to become effective. One of their most basic tasks should be in the gathering, processing, and presentation of road safety statistics for politicians, academics, and the wider community.
In the past, the RSA had an interactive map on their website which displayed the historic data of recorded road crashes. This was a vital tool for local Councils and Activists to become aware of crash sites so that they could make needed changes to road infrastructure. Without that tool, town planners cannot use data led design within our communities to make the roads safer for all users. In Dublin, that responsibility has now fallen to a journalistic organisation - the Dublin Inquirer - who have developed their own interactive map (www.collisiontracker.ie) to record cycle incidents, for the very purpose that was once served by the Road Safety Authority themselves.
As mentioned in earlier points, it is imperative that the RSA is empowered with the adequate functions and oversight to make our roads safer. They need to be refocused away from facilitating ever increasing car numbers and towards safer streets and roads. Whilst it may be necessary for the RSA to retain the functions of licensing & testing, it is essential that they prioritise the road safety element of their functions at all times.
Q 5. Do you think there are any functions currently undertaken by the RSA that would be better delivered by another body/agency or any functions completed by others that would be better undertaken by the RSA?
The RSA’s responsibility for vehicle testing does not include a function to ensure vehicles on the road are compliant - relying solely instead on limited garda resources to enforce vehicle compliance. This is not the case in all countries. By comparison, the Norwegian Public Roads Administration has the ultimate responsibility for supervision and inspection of vehicles in Norway and utilizes fixed and mobile camera based Automatic Number Plate Recognition (ANPR) and their own inspectors to ensure vehicle compliance with roadworthiness and insurance regulations. This would align competencies on road testing with an enforcement function which can prevent unsafe vehicles from operating on irish roads.
The setting of speed limits currently sits with the Department of Transport and Local Authorities, but this is a function that the RSA should be accountable for. The RSA have the responsibility to collect road safety data so should also have the responsibility to push for the interventions and improvements needed to deliver the safest roads and streets possible. The RSA are the contributor for Ireland to the European Transport Safety Council report and with speeding and speed limits a key area of focus, it is logical to combine this evidence gathering and speed limit setting functions to deliver a Safe System of road design.
Engagement with the RSA
Q6. Please indicate any involvement you may have with the work of the organisation and your views on their road safety information campaigns, education work or other services.
Naturally, the Dublin Commuter Coalition’s goals align with the stated objectives of the RSA - to make transportation safer. Unfortunately, the actions in which the RSA take are fundamentally flawed from the beginning.
It has been a constant frustration to our members that one of the RSA’s key actions is to misinform young children, that the activity of cycling is at its core, dangerous. Many parents have had their 4-5 year old children come home from school, carrying an RSA labeled hi-vis jacket, after receiving a talk, telling them of the dangers of cycling and the need to protect themselves when they are walking and cycling. That they must wear elbow pads, knee pads, helmets and hi-visibility clothing before getting on their bicycles to school. From early childhood, the Road Safety Authority is telling children cycling is unsafe, and then wonder why so few people are cycling in our communities into their teenage years.
Worse still is their social media profiles, which constantly victim blame active travel users. Suggesting it is their responsibility to be ‘seen’, in order to avoid an incident, instead of the trained & licensed operators of the vehicle that may hit them, to pay attention to the road. Often the RSA do not even recognise that cycling is a mode of transportation, but rather simply a ‘pastime’ that people may do recreationally. If our National Road Safety organisation cannot use the correct language to describe an important mode of transportation, how will we ever make progress towards our road safety and environmental goals?
What we really need the RSA to do, is to be far more active in campaigns such as ‘30k Town’, which actually advocates for interventions that will make the Roads safer for active and private transport users.
The RSA should be the leading force in Ireland behind campaigns calling for camera enforcement on our roads, ensuring that speeding simply cannot happen - rather than asking drivers not to break the law. They should be constantly calling for Garda Enforcement against illegal parking on footpaths, which forces pedestrians into roadways. They should be insisting on serious fines for commercial drivers who needlessly crash into bridges, endangering other road, and public transport infrastructure. They should be the leading voice behind mandatory CPD training for drivers, to ensure they keep updated on the latest changes to laws, and can demonstrate the safe operation and understanding of their vehicles, but sadly, they do not do any of these things, all they manage to do is simply ask people to drive safely, while perpetuating a fear of active transport within schools.
Other Comments
Q7. Finally, please provide any other comments which you feel may be of relevance to this review of the RSA.
The RSA regularly promotes that Irish roads are some of the safest in Europe, while this is true on a per capita basis, it is not reflected when road fatality statistics are exposure adjusted for the number of kilometres walked or cycled as presented in a discussion paper to the International Transport Forum in 2018. The RSA noted in their own 2018 report that more exposure data needed to be collected on pedestrian and cyclist exposure to be able to accurately compare fatality trends with increases in travel volumes but this has not been included in their 2022 pedestrian or cyclist reports.
The RSA needs fundamental reforms. It is not currently acting in accordance with its stated aims. The tragic increases in deaths on our roads is a result of the lack of meaningful action by the RSA. This trend is underlined by the European Transport Safety Council 2023 PIN report where from 2019-2022 road deaths have increased in Ireland by over 10% while there has been an average decrease of 9% across the EU.
Figure 1. Fatality rate vs. exposure for walking for countries with high and very high reliability data only as well as trend line (source)
Figure 2. Fatality rate vs. exposure for cycling for countries with high and very high reliability data only as well as trend line (source)