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.

Friday, February 15, 2013

A letter to TAC's CEO

This is what I wrote to Janet Dore, CEO of the TAC, a week ago.  Ms Dore is a busy person with responsibilities that are far broader than micro-managing her road safety team, so I do not expect any form of reply soon.  Nevertheless, I hope that she will get personally involved in the road safety debacle that is currently unfolding...

Dear Ms Dore,

I'd like to take this opportunity to suggest that this year, the TAC takes a different approach to motorcycle safety, and to offer my assistance in making that happen.

This week we have seen the re-running of the 2009 TAC commercial "The Ride" on billboards, The Age online newspaper, and prime time TV.  I'm assuming that you were not across the decision to run this particular campaign at this time and I'd urge you to personally get involved in the motorcycle safety agenda for the TAC for this year.  I'm not sure how it looks from inside the TAC where I know you have to deal with the actual tragedy of road trauma on a daily basis, a reality that I'm sure puts a pretty down to earth spin on things.  From outside the TAC and speaking as a motorcyclist, however, this decision appears ill considered:

Recommendation 22 of the RSC's Inquiry into Motorcycle Safety report calls out that the TAC needs to "[redress] the attitude that responsibility for rider safety is solely attributable to the rider".  That the TAC's first entry into the arena of motorcycle safety since that report was handed down is built on the campaign that decried "Motorcyclists: it's up to you to reduce the risks" appears contemptuous not only towards motorcyclists, but towards the report of the parliamentary inquiry.  I'd encourage you to consider this, and I hope that this ad will be pulled immediately.  

The RSC was a remarkably positive process which saw a broad representation of the state's motorcyclists and motorcycling organisations engaging with the committee with the goal of improving motorcycling safety in Victoria.  There could hardly be a better time for the TAC to start working with motorcyclists and forming a holistic strategy for improving & promoting safe motorcycling.  Unfortunately there is a history of personalities both within the motorcycling lobby groups and also in the TAC that has hindered such cooperation in the past.  I am exerting what influence I can within the Motorcycling community to bring cooler heads to the table.  I'd like to bring a couple of observations about the TAC's role in this to your attention, in the hope that (should you agree with my conclusions) you can exert some influence there.

When the RSC heard supplementary presentations from both the TAC and the VMC in the second half of last year, a couple of public statements were made that I think highlight one of the problems that the TAC needs to overcome.  (I am quoting from memory rather than referring to the transcripts, so please forgive any minor inaccuracies   Gross inaccuracies you can of course point out as being in need of correction!)

* John Thompson observed that the vehemence of the reaction of motorcyclists to the 2012 Motorcycle Reconstruction campaign was a result of riders being "uncomfortable having the spotlight shone on them."

* Sam Cockfield stated that the TAC "understand the risks of motorcycling better than riders do."

I believe that these statements exemplify a failure of at least those two people (and owing to their seniority and responsibility I'm extrapolating this also to the Roads Safety area of the TAC, at least at that time) to understand the average motorcyclist in Victoria.  In light of the TAC's approach of creating behaviour-modification campaigns as documented by John Thompson and delivered (among other places no doubt) to the Asia Pacific summit, I believe that when it comes to motorcyclists, the TAC's failure to understand their target audience has undermined the efficacy of the campaigns.

I read a paper last year which observed that motorcyclists exhibited a lesser fear of death that non-motorcyclists in the study group surveyed.  This is not to say that riders have a death wish.  However I believe that most riders like myself (as I understand it the 'typical' Victorian getting their motorcycle Ls is a 30-something white collar professional) understand that there are certain risks associated with riding a motorcycle that are greater than the equivalent risks of driving a car.  The crucial point here is that riders understand the risks, and accept them, and (to greater or lesser degrees) attempt to mitigate and manage them.  

The TAC's history of taking a risk that people don't like to think about (eg drink driving) and graphically portraying the downside of that risk has been very successful in those areas where the audience are in denial about that risk, and try to tell themselves that "it won't happen to me."  Motorcyclists are a very different breed in my experience.  Every rider I know personally - every single one - knows someone who has been involved in a collision.  Most (myself included) know someone who has been killed while riding.  Yet we all still ride.  The attitude displayed by John and Sam at the RSC, and that comes through in each motorcycle-related ad that has been made in the last 5 years appears to me to amount to "if you knew what we know, you wouldn't ride, or ride like that."  And this approach is doomed to fail because not only do most riders know the risks associated with riding, we have been bombarded with negative messages of doom and disaster from friends and family when they first took up riding (and for some no doubt, ever since).  When the TAC creates campaigns that project that basic message, it is simply lost in the noise of every objection that the individual rider has already overcome in their decision to ride a motorcycle.

My suggestion to you and to the TAC therefore is that a new approach is needed.  I think it's fair to say that the parliamentary inquiry would endorse a change of tack also, based on the recommendations.

So here is my suggestion.  From 2007-11 motorcyclists accounted for roughly 20% of the TACs claims cost.  I expect that figure will remain about the same for 2012.  So take 20% of your road safety budget and dedicate it towards safe motorcycling.  Even if you just do it for the 13-14 financial year and see how it goes, it would be worth a shot in my view.  Use this allocation of resources to get people into your road safety group who understand and advocate motorcycling.  Create a Manager for Safe Motorcycling position, or fund a joint venture with the VMC... but come up with a new soundbyte for safe motorcycling other than the "we want riders to wear protective gear and stop speeding", a soundbyte that will actually resonate with the riders you are trying to influence, rather than alienate them.

If the TAC wants to continue to operate in the public domain as an influencer of behaviour (rather than say an educator in the style of the NSW RTA's Safe Cornering campaign) then you need to rebuild the trust of your would-be audience, and reshape your message to one that they will not immediately switch off from.  I'm not sure if you appreciate this but many motorcyclists do not trust the TAC.  If one looks at the TAC's legacy in addressing general road vices such as speeding or drink driving, I don't think there's any public impression that the TAC is anti-driving.  Yet there is a strong sentiment that the TAC is anti-riding.  I attended a focus group in July last year at John Thompson's invitation and I came away feeling that the group facilitator or those who set the agenda for the session viewed recreational motorcycling as an aberrant behaviour, a road vice so to speak.  The impression is that the TAC wants to reduce motorcycle crashes rather than promote safe motorcycling.  The two should be one and the same, but only one ad in the last decade has presented motorcycling in anything but a negative light in the eyes of your would-be audience.

So those are my suggestions.  Fund safe motorcycling in proportion to the costs (both monetary and human) that we are trying to reduce.  Get motorcycling advocates on board with the responsibility and authority to shape the message and develop a coherent, holistic strategy for the TAC to pursue in improving safe motorcycling in Victoria.  Oh, and make a public response to the findings of the parliamentary inquiry, acknowledging that it was the most significant step that any victorian parliament has made to addressing this area of our road toll, and please get the TAC on board with its recommendations.  And if I can help with any of this, don't hesitate to ask!

Another year, another TAC failure

Dear TAC,

I can't do this dance anymore. You say that you're interested in safe motorcycling, but the fact is you just don't act like you are. You refuse to listen to criticism, you never admit when you're wrong or make a mistake, you lie, and when you're called on the lie, you lie some more. Trying to reason with you is like dealing with one of my 6 year old's tantrums, and I don't put up with this behaviour from her so I certainly won't put up with it from you.

Lies: Professor Stevenson from MUARC testified before the RSC that the 38 times figure is wrong. “Thirty-eight is inaccurate. I would put that on record” were his words. Yet you continue not only to run the TV ad which relies on that stat, you have it plastered on billboards around Melbourne.

You told MAG that you were 'considering' running the ad again, an announcement that was met with near universal concern and negativity as I hear it. Given the ad screened within 24 hours of that announcement it was clear that you weren't just considering it, you had decided to do it and had already booked it in. You intentionally attempted to mislead MAG. You lied.

You chose 'The Ride' in flagrant disregard for the explicit recommendation of the RSC that messages that place the responsibility for riders solely upon the rider were to be redressed, not encouraged. When called on this, you claimed that the ad 'targets drivers as well as riders.' TAC, that is another lie. If you honestly believe that, you're lying to yourself. Here's the voiceover:

"Motorcyclists have 38 times the risk of death or serious injury, regardless of whose fault it is. Not wearing protective clothing increases the risk. Speeding increases the risk. It's up to you to reduce the risks."

I do not accept that this voiceover targets drivers and encourages them to watch out for riders, and it further damages your credibility (if that is possible) for you to continue to assert that it does.

So enough with the lies. If you were my daughter, I would have already sent you to your room long ago. So here's the rub: I give up on you. You disregard all attempts to engage with you to improve your effectiveness on motorcycle safety. You disregard riders, you sideline and lie to MAG, and you ignore the report of the parliamentary inquiry. Your behaviour is in fact worse than my 6 year old's worst tantrum, because she is at least willing to examine the evidence and reason.

So I've had enough with you, you're a waste of time and tax payer money. If you ever decide to take your responsibility as a road safety body seriously and decide you want to come up with a motorcycle strategy that draws on more than your own data and the Neilsen Net Ratings (, you know where to find me. But in the mean time, go think about what you've done. But I suggest, just for a change, you take your own advice and put yourself in our shoes. In case you're wondering, it looks a bit like this:

"So far this year, 5 of our motorcycling brothers and sisters have been killed on the roads. This is a terrible start to the year and we are grieved by this loss, and our thoughts are with the families and loved ones.

"We're still hopeful because the report from the RSC inquiry into motorcycle safety had so many excellent and well researched and justified recommendations. Then we hear that the TAC is running an ad, and for a brief moment we dare to entertain the hope that the TAC has read the RSC report, taken it onboard, and has changed its approach on safe motorcycling.

"Instead, we find that they've rehashed The Ride, probably the most appalling and certainly the most reviled ad that the TAC has made on motorcycling, worse even than the Motorcycle Reconstruction debacle. We can't believe they chose that ad, after the stat was publicly debunked during the RSC hearings, and the tagline of 'its up to you to reduce the risk' spitting in the face of the RSC recommendations, but they did.

"So we tell them they've made a mistake. We tell them that they've screwed up royally and that they should pull the ad. Instead of coming clean, instead of even contemplating that they may have made a mistake, they lie more. They try to justify the ad, try to defend the stat, try to claim that somehow it encourages drivers to watch out for riders. They justify themselves with self-deceptions like "motorcyclists never like it when we point the spotlight on their behaviour" even though other states manage to achieve a 95% approval rate from riders for their motorcycle safety ads that tackle the same issues. They ignore our concerns, they ignore the evidence, they ignore the advisory groups and they thumb their nose at the parliamentary inquiry. They simply bury their heads in the sand and continue on their same, ineffective way."

TAC if you were merely an advertising agency, I'd say you should be pretty embarrassed with yourselves. Your target audience is telling you that you got it wrong, and you're ignoring them. But you're not an advertising agency, you're a supposed road safety body. You should be more than embarrassed with yourselves. You should be disgusted. Rest assured, we are disgusted with you. Five motorcyclists have died, and you carry on with the same old spin, the same ineffectual campaigns, the same stubborn arrogance, the same old lies. TAC, it's not the riders who aren't listening.

It's you.

Now go away, pull your head in, and have a good long look at yourselves, at what you've done, and what you've failed to do.