Monday, May 6, 2013

Front Number Plates - again.

Firstly, we need to go back to 1980, when front number plates (FNPs) were removed because the research at that time indicated they posed a safety risk to pedestrians.  Their removal was actively encouraged by the states and territories of Australia.  Since then, nowhere in Australia have FNPs been required on motorcycles; indeed to my knowledge there is only one country in the world (Singapore) that mandates FNPs.  As such, 30+ years of motorcycle design have moved away from even catering for the placement of FNPs, adding logistical challenges to the unanswered safety concern about the consequences of adding them back onto motorcycles in Victoria.  As far as I know, there is no research to suggest that FNPs are now safer for pedestrians than they were in 1980; and given the dramatic increase in motorcycle ownership in Victoria over the last decade, I would be surprised to find that FNPs would pose less of a safety risk now than they did then, but the salient point is that the research that led to the removal of FNPs still stands, to the best of my knowledge and research.  (If you are privy to research that contradicts this I would be grateful to hear about it!).

So for the last 33 years, Victoria has had clear standards regarding the appropriate required identification for vehicles on Victoria's roads.  Vehicles with 4 (or more) wheels are required to display plates at front and rear; powered two- and three-wheeled vehicles are required to display rear plates only, and unpowered two wheelers (bicycles) are not required to display number plates at all.  All vehicles are allowed to operate on Victorian roads, all are subject to the same laws and the same enforcement, but each has its own requirements for number plate display as is appropriate for that vehicle class.  This doesn't represent a loop hole, so much as a recognition that the vehicle classes are different.

Every speed / red light enforcement camera that has been purchased and activated in the last 30 years has been done in the clear knowledge that these different standards are in place.  Regarding the issue of failure to identify motorcycles, I think the most pertinent (and unasked) question is this: given the increase in motorcycle ownership and participation in our traffic system has been clear since 2006, why has Victoria persisted in favouring forward facing enforcement cameras?  Every vehicle required to display a number plate displays one on the rear; surely the most effective enforcement camera strategy would be built on rear-facing cameras?

So that is the history of how we got to where we are: in the name of pedestrian safety we removed FNPs in 1980; in full knowledge of this, we bought predominantly front-facing cameras ever since.

Fast forward 33 years, and motorcycle safety is a pressing issue.  Though motorcyclist death and injury rates are consistently falling relative to the number of motorcyclists on the roads, riders are still over-represented in Victoria's road trauma stats.  Clearly the issue of enforcement is among the pertinent questions that must be asked, and put into the overall context of Victoria's road safety strategies and plans.  When it comes to these missing fines, however, it is challenging to get hold of source data.  Indeed the Victorian Motorcycle Council released a press release today stating that the report that the Safety Camera Commissioner based their recommendations on could not be found by either the Department of Justice nor the Office of the Safety Camera Commissioner when requested under FoI.  For the SCC to be making claims and recommendations based on a report that cannot be produced is a pretty alarming development and raises serious questions about the transparency and appropriateness of this whole process and the activities of the SCC in particular.  Regardless, let us press on with the evidence that we have at our disposal.

In 2001, there were 94,741 registered motorcycles, and 2,100 failed tickets, a ratio of 22.2 failed tickets per 1000 motorcycles.

In 2011 there were 160,634 registered motorcycles, and 4,500 failed tickets, a ratio of 28 failed tickets per 1000 motorcycles.  Today's herald sun article claims "almost 20,000" failed tickets in the last 3 years.  While it is hard to be specific with figures like that, it seems roughly consistent with the 2011 numbers that were available.

Our conclusion from the available figures is that the rate of failure for issuing enforcement tickets has risen by 0.6% relative to the motorcycling population between 2001 - 2011.  0.6% increase in detected non-compliance among motorcyclists does not strike me as the most pressing issue in motorcycling safety in this state, I would be interested in your views on that.

Today's Herald Sun quantified the financial impact of this in terms of revenue or deterrent foregone as $4m over the last 3 years.  Again this data is imprecise, but let us call it a $1.4m/annum problem, either as lost revenue, or as behavioural deterrent that wasn't issued, whichever one prefers.  This at least provides us some metric to evaluate the scale of the problem being discussed.

The proposed solution, the fitment of FNPs to motorcycles, was evaluated by Oxford Systematics in 2002.  Their report concluded that implementing such a scheme would cost $13.8m, with a recurring, ongoing cost of $0.94m a year thereafter.  These prices are in 2002 dollars, and prior to the almost doubling of motorcycle registrations that has taken place since the report was prepared.

So to summarise:
* in 1980, FNPs were removed due to research indicating a safety threat to pedestrians
* in response, appropriate vehicle identification for motorcycles was defined as rear facing only
* since then, Victoria has invested in largely forward facing cameras, in full knowledge of this limitation
* from 2001-2011, failure to identify motorcycles from these cameras has increased at a rate of 0.6% over that time.
* this represents foregone enforcement deterrents in the order of $1.4m / annum, 2013 dollars
* the suggested remedy was costed at $13.9m with an ongoing annual cost of $0.94m, 2002 dollars
* there remains no evidence that the safety fears that led to the removal of FNPs in the first place have been addressed.

Furthermore, the safety literature over the last decade has consistently indicated that improved road systems, rather than increased enforcement modifying road user behaviour, is the best way to reduce road trauma.  For example:

"safer roads - not changing driver behaviour - would have the biggest single impact on the road toll and could save more than 300 lives a year nationally."
Dr Kremmer argued that "changes in motorcyclist mortality rates are predominantly determined by the safety of the traffic system in which they operate rather than by the characteristics of the motorcycles or their riders" (Motorcycle and Scooter Safety Summit: The Road Ahead, 2008, p5)
"I'm going to say something I'll probably regret," says Ian Johnston, the director of Monash University's Accident Research Centre, which provided the research and arguments that underpin the Government's speed strategy. "It has been very convenient (for governments) to go along with the community belief that it's all about bad behaviour, because then you don't have to invest so much in infrastructure.

In conclusion, it appears that though we are forced to endure the degradation and decay of our entire road system which is putting all road users at increased risk, that there is a poorly constructed case to invest at least $14m in correcting an enforcement oversight that has been present for the last 30 years and has grown at a rate of 0.6% over the last 10 years.  This argument has found no basis in the report of the parliamentary inquiry into motorcycle safety, which itself contained many recommendations which are backed up by current research as offering real improvements in motorcycle safety and therefore improvements in the whole traffic system.  Lastly, this case around FNPs has been built upon and justified by a report that could not be found when requested under FoI.