Transport Insights

All five road safety schemes that National Highways actually delivered under its “enhanced safety plan” for the last year of the second roads period fell under an existing safety programme, with no evidence that they were “beyond its previously planned activities”, as required by the company’s regulator.

But the Office of Rail and Road (ORR), which demanded that the company produce the “enhanced plan” to address its poor casualty reduction record, failed to carry out any checks to ensure the actions were genuinely additional.

In fact, both the company and the regulator have insisted (without evidence) that the actions in the enhanced safety plan, which was given to the ORR in March 2024, were “additional” to National Highways’ 2024-25 Delivery Plan Update, which was not published until this March and does not list specific activities.

National Highways appears to have actually cut the funding available for safety improvements at the end of the whole 2020-25 roads period, including the year covered by the plan.

The disclosure casts further doubt on the competence of the ORR and its willingness to hold National Highways to account, as it claims to do, after it refused to publish the plan but praised the company for “doing everything it reasonably can” to address its failing safety record.

The regulator revealed in March that National Highways had so far only delivered only five of the 24 road safety schemes in the enhanced plan, adding only that the company “expects” to deliver more.

National Highways has now told me that all five schemes were funded by “designated funds”.  This is a reference to the company’s four “ringfenced” funding streams during the 2024-25 (second) Roads Period, including a “Safety and Congestion” fund that was originally worth £140m.

A National Highways spokesperson told me: “They are also all additional schemes as they were outside our 24-25 Delivery Plan commitments and our original Designated Funds allocation.”

It has not however provided any evidence for this assertion.

Similarly, the ORR told me that all of the actions that it had described as additional “are in addition to those activities stated in National Highways Delivery Plan update 2024-25” but has confirmed that it does not have sight of an advanced list of safety schemes under the Safety and Congestion fund, meaning that it has no baseline for comparison.

Not only did the Delivery Plan Update published in March not list the safety actions that National Highways would carry out during the year, but the company has never said how much of the “ringfenced” fund would be spent specifically on safety or how many safety schemes it planned to carry out each year.

However, its annual reports covering the four years from 2020-21 to 2023-24 show that it spent £105.8m from the Safety and Congestion fund, leaving £34.2m to be spent in 2024-25. But the 2024-25 plan, published as the financial year ended, states: “We will invest £27m across a range of schemes.”

If National Highways did promise (and fail) to deliver 24 additional safety schemes funded by designated funds during 2024-25 – by focusing the whole designated fund on safety – this would have meant more that trebling the annual rate of delivery. As I have previously revealed, the company told the ORR it delivered 76 designated funds safety schemes across five years, which would represent an annual rate of around 10 a year before the 24 schemes were added to the existing programme for the final year.

The ORR’s annual assessment of National Highways’ performance in 2023-24 notes that a number of designated funds were underspent that year, including Safety and Congestion (£2.7m), which National Highways said was “because of projects funded by designated funds slipping into the final year of the road period”.

This may have included at least one scheme cited in the report as “additional” under the “enhanced plan” – “A417 at Birdlip” – which appears to have been planned and put in train long before the company delivered the enhanced plan to its regulator

This reference is to works to improve road markings and solar road studs on the A417 carried out by contractors Clearview Intelligence and WJ in April 2024 – just a month after the “enhanced plan” was delivered.

Another of the five road safety schemes cited in the ORR report ­– “A19 at Limekiln” – was a longstanding commitment. It appears to be a reference to part of a package of safety improvements to gaps in the central reserve on the A19 between Knayton and Ellerbeck, in September 2024.

In April 2021 local MP Kevin Hollingrake told constituents that detailed designs the scheme would be submitted for funding approval in 2023-2024. In May 2024, he said funding had been announced and the work would take place in September.

It is not clear whether this scheme was funded from the 2023-24 designated fund budget as intended or whether National Highways found the money in 2024-25 but there is no evidence that it was additional to existing plans.

The ORR has refused to make any comment as to how it checked that “additional” measures in the enhanced plan were genuinely additional. A spokesperson told me: “The enhanced safety plan from NH is an updated plan on how it intends to achieve the KPI on which we hold it to account. We will publish our annual assessment in the summer of how the company has performed.”

I then asked the ORR to treat my question as how it knew that the 24 road safety schemes that National Highway promised under the enhanced plan were not schemes that it was planning to do anyway as a request under the Freedom of Information Act. It replied that it held “no information” on this subject, confirming that no formal analysis was carried out.

How a transparent plan became a secret plan

The context for the “enhanced safety plan” is National Highways’ expected failure to hit its KPI target for reducing serious casualties by the end of December 2025. In its December 2023 (second) annual safety report, the ORR noted that the company was developing an additional programme of targeted interventions that it could implement in time to support delivery of the KPI and told it to “transparently” include them in a “robust plan” by the end of March 2024

However, the plan was neither transparent nor robust. Both organisations refused to let the public see it and concerns that this would allow National Highways to backslide were heightened when it said the actions within it were “subject to relevant risks”, which it said it would manage “where possible”.

Both organisations have suggested that the “enhanced plan”, as the name suggests, included both schemes that were already planned for 2024-25 and additional ones. However, in its March 2025 report the ORR referred to 43 actions “in addition to its existing commitments to improve safety…within annual delivery plans”. These comprised 24 road safety schemes, eight communications campaigns, and 11 ‘working with others’ actions.

In fact, the ORR revealed that by the end of February 2025, National Highways had delivered only 22 interventions, including the five road safety schemes.

It has since refused to disclose how many interventions had been delivered by the end of March. Rather than holding the company to account, it appears determined to cover for it.