TSRGD Consultation: Highways Agency Safe Road Design Team response.

Transcription

1 TSRGD Consultation: Highways Agency Safe Road Design Team response. 1. Summary While continuing to support the principles of revising the regulations the Agency notes the number of inconsistences in the draft, several omissions and referencing errors. We recommend that the department keeps major stakeholders informed of progress to enable them to check if identified signs were omitted by accident or are being removed from the Regulations and where text highlighted as being of concern is drafted as intended. We have highlighted four main issues which are of significant concern where we feel there is justification for significant changes in the proposed text and policy. 1. The changes to directional signs abandoning the Guilford rules and adopting a single stroke width (5sw) for all types of route for map type and other signs was not proposed before. No evidence has been provided that would show that either change is justified; the Agency s own evidence from research work would indicate that adopting a standard 5sw for signs would have a significant negative impact on driver comprehension and in a number of situation would be significant safety risk While the current design guidance on the use of correct patching (Guilford rules) causes uncertainty with less experienced designers, there is now a consistent sign format on the Agency network. While there may be benefits to some revision to the design rules we don t think that the proposed changes would lead to better sign being installed and would lead to inconsistent signing for the foreseeable future 2. The removal of all directions limiting what type of road signs and marking that can be placed is, based on existing experience, likely to encourage outside stakeholders from putting pressure on the Agency placing unsuitable signs on the network. The most obvious examples are tourist facility signs on Motorways and Motorway Service Area signs on all purpose roads. Even where authorities can restrict the number of unsuitable third party signs the time and effort needed to deal with these request will be significantly more than that currently the case. While there may be a case for removal of strict prohibition for primary and nonprimary signs on all-purpose roads. The revised TSRGD should retain restrictions relating to what signs can be placed on Motorways and where Motorways signs can be placed. 3. The flexibility introduced for matrix signs for lane control may lead to unacceptable aspects (which are currently prohibited) being used. While updated guidance, via the TSM, may identify what combinations should not be used we feel that it would be straight forward to implement these restrictions in the Regulations.

2 4. The terminology in respect of managed, controlled and smart motorways needs to be checked to ensure consistency and to permit the display of relevant aspects and legends on variable messages signs straddling the verge and running lane. 5. The effective application of the revised TSRGD will require a level of training and competence which current experience shows is far from universal. Adequate guidance, via an updated and expanded Traffic Signs Manual should be provided as a starting point. However, promoting and eventually requiring effective training and professional assessments of competence are needed to ensure that there are sufficient experienced signing practitioners to undertake the risk and design basements identified in the consultation documents.

3 2. Consultation Questions to be read in conjunction with main DfT document. Question Topic Answer Comments 1 If you are responding as a Traffic sign practitioner, 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? Strongly Disagree The proposed relaxations are a step too far in some areas, especially the potential impact of inappropriate signs being placed on motorways, such as signs to tourist facilities, which is a significant concern to the Agency Increased flexibility must be linked to comprehensive guidance contained within the relevant Traffic Sign Manuals. Where it is known that TSM guidance will not be provided for many years then flexibility afforded within the TSRGD will need to be reviewed to avoid national inconsistencies and possible exploitation by commercial companies. The removal of many TSRGD Directions which currently protect the SRN from either errors in design or commercial pressure is a step too far. Suggest the proposed removal of each Direction is carefully reviewed for impact on the SRN. 2A Lighting in 20 mph zone Neither 2B Do you agree that the requirement to light two-way traffic ahead signs is safetycritical and should remain or should be removed in line with Agree The signs are safety critical. If the requirement is removed any decision to remove lighting must be provide a robust risk assessment and evidential trail. other warning signs? 2C i Number of illuminates signs in 20 Zero mph zone 2C ii Number of signs on Unknown retroreflective bollards 2C iii Average cost of lighting a sign HA technology & Lighting team may be able to assist? 3A Any further action within TSRGD to tackle sign clutter Yes Retain the restriction for placing signs to tourist facilities on motorways and Motorway Service Area signs on all-purpose roads. The increased flexibility is likely to result in pressure to place additional tourist signs on the motorway network to tourist facilities. Therefore, retain Direction 13 and

4 3B If you are responding as a traffic signs practitioner, will you take advantage of the greater flexibility within the new TSRGD to reduce sign clutter? A yes/no answer would be misleading 14 The decision to reduce sign clutter must be based on a sound engineering and risk based logicwhich will provide an evidential trail in the event of a decision being challenged in the courts at a later date 4 Do you support proposals to allow yellow lines to be laid without the need for a TRO? A yes/no answer would be misleading The extra flexibility will generate even greater pressure from stakeholders to install non-safety related signs (e.g. tourist and services) and therefore increase the problem of sign clutter.. Without a TRO there would need to be sufficient consultation and a clear indication of the proposed location of these marking to meet local needs, enforcement implications and the potential for contractor errors, which do occur from time to time. The time and effort needed for this means that there may be little benefit in time and cost in adopting this option. Also, it would mean that the basic need for these markings could be challenged. 5A 5B 5C 6A Number of cycle schemes introduced in last 10 years? Number of contraflow cycle lanes? One way traffic with contra-flow cycling Should pelican crossings be excluded from TSRGD? Unknown None None We are not aware that current experience with bus stop clearways or yellow box markings is sufficient to give sufficient confidence that this proposal would not cause significant problems There is insufficient evidence provided to make an informed decision as to the benefit (or not) of the prohibiting new pelican crossings by removal from the Regulations. 6B i Should they be allowed for multilane See above approaches? 6B ii Should they be allowed for any See above

5 7A site? Will you use the flexibility to put up signs for current county boundaries? Yes We do not intend to install signs of this type but we will consider third party request to fund these signs. 7B Will you use the flexibility to put up signs for historic county boundaries? No We cannot see what benefits there would be to road users of signing a historic county boundary. 7C Will you use the flexibility to put up signs for designated geographical area? Yes We do not intend to install signs of this type but we will consider third party request to fund these signs 7D Will you use the flexibility to put up photographic boundary signs? Yes We do not intend to install signs of this type but we will consider third party request to fund these signs 8 Do you support the proposed new tourist destination definition for England 9 Do you support the removal of the Guilford Rules from sign design? Yes No The proposal strengthens the definition of tourist destinations in England and will enable authorities to continue to sign genuine tourist destinations whilst eliminating more commercial establishments. It would be useful to understand the Department s rational for removing the Guildford rules (patching). Is there evidence to suggest it does not work? Has the Department considered the driver for introducing them originally? What has changed and what is the likely impact of having signs with and without the Guildford rules on the network for the foreseeable future. From the available evidence to us there may be a justification for looking to improve the current design rules but that there would be no net benefit in adopting the proposals. HA Research has shown that while few drivers articulate their preference for indicting priorities via arrow size, spacing and relative proportion for map type and associated signs in blind testing there is a statistically significant preference for representative priorities and layout to be shown (82%). Therefore, we do not agree at all with the adoption of single width arms (5sw) for these types of sign.

6 10 Do you support the proposal to expand the use of exceptions to no entry signs? No The continuing watering down of safety critical signs (i.e. No entry signs) should be avoided. Adding further exemptions will likely lead to drivers spending more time reading the exemptions than reacting to the symbol. The correct signs for these circumstances (953/ 953.2) are effective if the design of other aspects of the road provide a consistent message to road users. Deliberate miss-use should be tackled by driver education or enforcement. Also the degree of impact of the restrictions on local residents and subsequent violations should also be assessed. 11 Would a sub-plate on these signs (no pedestrians and no cyclists) be helpful in understanding these prohibitions? 12 Are the rules for signs indicating enforcement cameras necessary, or can they be dealt with via the planning system? No The meaning of these signs is generally understood. Violation of these signs is generally related to the acceptability/quality (or lack of) of the alternative NMU provision. No reply from JH as yet 13 Any further comments? Yes See below The provision of unique table numbers, from 1 to 76, across the different Schedules is very useful in navigating the document. Third parties have indicated that these are to be removed. We think that this is a mistake and the current numbering system be retained. The apparent decoupling of sign size and plate text size is not ideal and should be amended if possible. If not then design guidance must be provided when any revised regulation come into force.

7 3. Detailed Comments, corrections and proposed text Schedule 1 Warning signs TSRGD 2002 schedule 16 (17) stated the thickness of the route symbols other than the approach route symbol shall be varied to indicate the priority route through the road junction ahead" This is absent from the new TSRGD Table 5, Item 8 refers to illumination of a plate by the same means as the sign that it is used with. If the 'assumed default position for the illustrated sign is item 7 (the sign may be left unlit.) then where does it state this? For the avoidance of doubt suggest item 6 or 7 is stated, bearing in mind diagram used to be lit in accordance with Schedule 17(item1). This comment equally applies throughout Table Refers to item 3 only (VMS) what about illumination of plate (item 8) and sign (item 6 or 7)? Table 5 (item 6) wording differs from the wording currently specified in Schedule 17 Item 1 (2). The parts highlighted in red are missing. "Where the sign and any associated plate are erected on a road within 50 metres of any lamp lit by electricity which forms part of a system of street-lighting for that furnished by means of at least three such lamps placed not more than 183 metres in Scotland 185m) apart, it shall be illuminated by means of internal or external lighting either for so long as that system is illuminated, or throughout the hours of darkness, and may also be reflectorised." Table 5, Item 8 refers to illumination of a plate by the same means as the sign that it is used with. If the 'assumed default position for the illustrated sign is item 7 (the sign may be left unlit.) then where does it state this? For the avoidance of doubt suggest item 6 or 7 is stated, bearing in mind diagram used to be lit in accordance with Schedule 17(item1) , 8-12, 14, 27, 42, 45 Consider suffixes of a,b,c, where multiple variants are shown against a single diagram number. E.g a, b etc TSRGD 2002 contained brackets around 'x' heights greater than 62.5? TSRGD contained PV for HEAVY PLANT CROSSING when used with 504.1, 505.1, 506.1, 507.1, & 512.2? Table 1, item 19 refers to a gradient up a hill warning sign. Would you really need a Reduce Speed Now in this situation? Where is diagram 515.2? TSRGD 2002 Diagram 526 keep in low gear. Proposed wording states Keep in low gear now Why is an actual plate shown (530.1) when descriptions used elsewhere? X height bracket shown is TSRGD now removed? Why is an actual plate of shown when descriptions used elsewhere? Position of warning signs and dimensions removed from bridge height chord markings?

8 /4 Could worded Gate/Gates sign be combined? Missing traffic signals ahead warning sign diagram 543? Where is plate diagram Part-time signals & Peak hour signals? Order of diagram numbers not consistent in table 1 e.g. diagram 950 appears before 548, diagram 581 appears before diagram 558, diagram appears before diagram 552? Schedule 2 Regulatory signs E This marking seems to be missing This is not currently prescribed. Except for very limited situations diagrams and should be used instead These markings seems to be missing Does the wording permit the use of relevant diagram on an MS4 over both the verge and running lane? Does the wording permit the use of existing authorised versions of this diagram on a MS4 and AMI signals? 10 1 The statement where two panels are alongside each other, they shall be of the same height and of the same colour. Surely this statement would restrict diagram and other regulatory signs of this nature Schedule 3 Advisory Signs

9 41 77 Should this sign promote the use of a photographic image of a local landmark (as per the original DfT/DCMS pilot for county councils) and, wasn t there an intention to prescribe a brown background, especially where a photographic image is used? Alternatively, is the intention to retain the need for an Authorisation on behalf of the SoS for the use of a photograph and brown background? It is noted that this sign can now be used to sign a historic county boundary, what is the driver/benefit to the road user for this change? It is noted that previously, diagram 2401 could be used to sign the boundary of a district in England. This description is missing in the proposals. Should this sign promote the use of a photographic image of a local landmark (as per the original DfT/DCMS pilot for county councils) and, wasn t there an intention to prescribe a brown background, especially where a photographic image is used? Alternatively, is the intention to retain the need for an Authorisation on behalf of the SoS for the use of a photograph and brown background? It is noted that this sign can now be used to sign a historic county boundary, what is the driver/benefit to the road user for this change? Noted that a photograph of a local landmark may be added above the sign. It is noted that reference to the use of backing boards has been removed. How is this addressed? (Dir (42(6) & (7)) It is noted that this sign can no longer be used to sign a tunnel name. How are tunnel name signs to be prescribed. Previously, the letters did not have to have the proportions and form of those shown in Schedule 13 which effectively permitted any font to be used. This no longer appears to be permitted, is this intentional? (Reg 13(2), (4) & (7)) It is noted that reference to preventing the use of a backing board has been removed. How is this addressed? (Dir 42(8)) It is noted that this sign can now depict the boundary of a national park, area of outstanding natural beauty (England and Wales) and a National Scenic Area (Scotland)

10 Schedule 4 Directional Signs There is no limitation on having more than one copy of each corporate identifier 59 14&15 2 Should the wording be change to should be in contrasting colours rather than may? 59 various Is the intention that symbols on service signs can be placed in any order? 58 1 D15 9, 11, 14, 15 We would want the wording to mean that these signs/symbols can only lawfully be placed on a motorways Can these be placed on non- motorway approaches to MSA s Consider downward arrows in diagram 2909? Removing the ablity of designers to identify the priority and status on map type signs, could potentially lead to road user confusion, driver error and may increase the potential for accidents- see example below The new regulations state that for motorway service signs the size of the legend on the sign shall be in the range 75 millimetres to 400 millimetres. However in the existing TSRGD diagram it is within the range of 250mm to 400mm max? Check wording of items 1-4 does not conflict with current working drawings and NP drawings. E.g.

11 noting that item 14 (Good Food) and item 15 Good Egg (black on yellow) states at top of the sign. On NP a red on white GOOD FOOD panel is located beneath the geographical services namewhich is not top of sign? These signs should be the diversion symbol (Table 50 Item 17) on a sign with the relevant background colour. The whole sign should not be yellow Diagram 2901 was previously protected by direction 14(1) the sign may only be placed on or near a motorway. Under the new regulations this has been removed? The New regulations only permit: 1. The motorway number shall be varied as appropriate and may be placed centrally above the motorway symbol 2. The motorway number may be shown in brackets 3. M may be varied to A, in which case (M) shall be added either to the right of, or centrally below, the motorway number So will M6 Toll diagram 2901 be non-prescribed? TSRGD Schedule 16 Item 20, also enabled a compass point to be added shown is brackets (PV2) and any superseded route numbers to be cancelled with a red bar (PV3), inclusion of emergency diversion symbols (PV6). Are these options still required? Previously in TSRGD 2002 use of Keep apart 2 Chevron signs (diagram 2933) were restricted to motorway use only via Direction 14(1). In addition, the use of the sign was linked to diagram 2934 (Check your distance) and diagram 1064 chevrons. There appears to be nothing stated on Table 41 to ensure this remains the case 45 5 Is the reference under column (2) to type B being placed only on a motorway sufficient to prevent its use in this manner as previously tourist signs were split into two schedules? The reference to incorporating destinations comprising the legends shown in Table 46 and symbols in Table 52 will permit the signing of tourist facilities on motorways. This is a significant concern for the Agency as signs to tourist facilities are not currently prescribed for use on motorways. Is it appropriate to prescribe symbols such as the

12 shop mobility and public telephone symbols for use on tourist signs? 50 Are all the symbols prescribed for use with Table 45 Item 5, appropriate? 52 As identified above, the proposals would appear to prescribe the placing of signs to tourist facilities, incorporating the relevant tourist facility symbol, on motorways. Currently T4, T5, T6, T7, T10, T11 and T12 cannot be used on a motorway. This is a significant concern for the Agency as signs to tourist facilities are not currently prescribed for use on motorways. Is there scope for symbols to leisure facilities to be removed from the list of tourist symbols and not be shown on tourist signs? 55 Title states Symbols indicating types of tourist and leisure facility destinations in England that Should table 55 relate to signs placed only in Scotland? 61 1 The sign description states where the same exit can be accessed from the centre lane. The sign depicts a 4 lane carriageway with the left hand lane not continuing through the junction. The left hand lane of the remaining three lanes can be used to exit the motorway The sign description states where the same exit can be accessed from the centre lane. The sign depicts a 4 lane carriageway with the left hand lane not continuing through the junction. The left hand lane of the remaining three lanes can be used to exit the motorway The proposals would appear to prescribe the placing of signs to tourist facilities, incorporating the relevant tourist facility symbol, on motorways. Currently T4, T5, T6, T7, T10, T11 and T12 cannot be used on a motorway. This is a significant concern for the Agency as signs to tourist facilities are not currently prescribed for use on motorways Removal of Direction 13(3) could result in this sign being placed on a motorway in advance of an MSA to 16 Removal of Direction 13(3) could result in this sign being placed on a motorway. Currently T4, T5, T6, T7, T10, T11 and T12 cannot be used on a motorway. This is a significant concern for the Agency as signs to tourist facilities are not currently prescribed for use on motorways. Schedule 5 Temporary Signs

13 The reference to BS873 should be replaced with one to BS EN The reference to BS873 should be replaced with one to BS EN The reference to BS873 should be replaced with one to BS EN It is assumed that guidance will have to be included in Chapter 8 Part 3 will link sign size with plate x height Dia 554 (Flood) This does not seem to have an option for For xx, only one to identify distance to the flood Dia 554 (no smoking) This does not seem to have an option for For xx, only one to identify distance to the flood Dia 562 Blasting is missing as an option for a temporary hazard when not part of road works. Also item 4(4) may read better as omit plate where Diagram 513.1A from Table 2 is used. The first two options don t identify the hazard and the third (escape lane should have its own sign); only the last option fits the requirement to identify the hazard Dia 7001 Plate option include For xx without a description and distance to with a description of the work. Why is there not a description with For xx? This is particularly important for mobile works b There does not seem to be any sign in tables which is covered by this point. There should be time limit to retain any works signs covered by this either 3 or 6 months There does not seem to be any sign in tables which is covered by this point. This should be related to dia Dia 7008 food should probably be good The top and bottom panels are show as 200 max is this the text height or panel depth? The text of the centre panel should be a single x height no larger than the telephone number Dia 7202 In 2011 amendment regs this was extended to one way streets is this reverting to DCs only? Should the arrow widths be set as max min rather than set sizes? 66 8 Dia Should the arrow widths be set as max min rather than set sizes? Dia 7210 Additional sign face needed to cover all options. The arrow width is set for 50 mph; it should be set as max min The reference to BS873 should be replaced. BS EN 12899, BS8408 etc.? Which signs does this apply to? 68 1 Are the references correct? 68 3 This has subpart 1 but no other. The wording, about statutory provision only applies if the sign includes a restriction symbol. Various Making all arms 5sw makes a number of standard TTM signs bigger than currently the case and make

14 comprehension harder in area of high driver workload (e.g works access) Missing diagram 63 plate options shown is TSRGD 2002: Ambulance, Blasting, Blind summit, Fire station, Hidden dip, Pedestrians in road? Missing plate warning of light signals as shown in diagram 3014 ahead 62 Where is diagram 574 Area infected by animal disease Schedule 6 Traffic Signals 69 Dia 543 This sign (signal warning sign) seems to be missing. Even if not required for permanent situations it may be needed for temporary works. Various Does the wording permit the use of relevant signals on MS4 over both the verge and running lane? Various How is Direction 56 (Approval of types of signs and signals by the Secretary of State) addressed in the proposals? to 39 If the default lighting position is the equivalent to the current Schedule 17(4), why is Table 71 Item 30 now being referred to? and 38 Under column 4, is the reference to chevron correct for this sign? and 7015 signs are intended to be covered by Regulation 53 Various Throughout document, permitted variants switches from listing the actual PVs, to listing the table and item ref, etc. Needs to be applied consistently Flashing beacons references temporary signs now covered by Reg The referenced temporary sign are intended to be covered by Regulation Various How have Directions 50, 51, 52 and 56 been addressed? 73 2 Check reference to Table 76 Item 2 current Direction 55A. How have Directions 50, 51 and 56 been addressed? 73 5 General comment appears to combine diagram 6006, , , 6008, 6009, , with a PV to vary the number of lanes open or closed As above, assumed for use on an MS Appears to combine , , and with a PV to vary the number of lanes. Table 74 item 4 permits the aspect to display the

15 number of lanes open or closed which effectively turns this into diagram Is there scope to combine into one diagram with a PV for the alternative legends? Are the dimensions appropriate for use on an MS4 with the appropriate Authorised aspects? Current TSRGD also prescribes for use with Table 73 Item 4, 8 and 9. Column 2 refers to Table 73 Item 14 however it is noted that Item 14 shows red lamps, rather than amber Column 2 refers to Table 73 Item 14 however it is noted that Item 14 shows red lamps, rather than amber. Should Item 8 fog also be included? Are the dimensions appropriate for use on an MS4 with the appropriate Authorised aspects? 74 7 Refers to Table 1 Item 8, is this correct as it is the PV for Table 73 Item 16? & 16 These have exactly the same meaning makes reference to applying to all indicated lanes and is therefore preferable. Dia (particularly when high mounted) can be difficult to tell apart from above lane one to traffic in the outside lanes. Therefore dia should only be used when placed on both offside and nearside verges Schedule 7 Fonts Schedule 8 Time and distance format Part varied with - -, number of hyphens 4c ex-pressed additional hyphen 4d 7012 and 7015 signs are intended to be covered by Regulation 53 Schedule 9 VMS legends

16 Various Does the wording permit the use of legends on MS4 over both the verge rand running lane? Schedule 10 Ulnladen vehicle None Spelling error in Schedule name.