Documents published by National Highways’ regulator show how the company tried to avoid being held to account during the new Road Investment Strategy (RIS 3) for its continued failure to meet casualty reduction targets and how little it is likely to do by way of dedicated safety work.
The Office of Rail and Road (ORR) efficiency review, or advice on National Highways’ draft strategic business plan, discloses what the company was proposing at the end of last year to do under the RIS that runs for five years from tomorrow.
If the proposed spending levels in the draft strategic business plan (SBP) have been carried through to the RIS itself, dedicated spending on safety over five years will be (significantly) less than the cost of one major enhancement scheme, such as the £600m A38 Derby Junctions scheme.
The ORR reported that National Highways’ draft SBP proposed a spend of £342m in its safety National Programme and £122m in its safety Designated Fund, totalling £464m.
The regulator has also published a document that informed its own review, Safety Advice to inform the RIS3 Efficiency Review by Thomas Fleming Transport Consulting.

This describes in quite scathing terms what the £464m looks like out of a budget totalling £25bn:
The commitment of less than 2% of the RIS3 Statement of Funds Available to specific safety activities is difficult to reconcile with safety being the number one priority for the organisation.
Comparison between the ORR’s account of the SBP and the RIS itself reveals that a proposal for the National Programme to deliver safety interventions on 18 priority corridors with current poor safety performance and a low International Road Assessment Programme (iRAP) star rating has been carried forward – suggesting that the funding levels will be very close to what was proposed.
In terms for casualty reduction, the Thomas Fleming analysis reveals that the National Programmes and Designated Funds combined were forecast to achieve a reduction of just 85 killed and seriously injured (KSI) casualties per year by the end of the RIS. It calculated that this would represent a cut of just 2.7% relative to the 2005-2009 baseline against which previous RIS targets were calculated.
It highlighted “significant disparities” between the scale of this reduction and the long-term trajectory required to achieve zero deaths and serious injuries on the strategic network by 2050 – a target date that National Highways has already put back by 10 years.
The ORR has repeatedly warned that National Highways is likely to miss its RIS 2 target that in 2025 KSIs will show a fall of 50% against a baseline of the average annual total for 2005-09, which works out at 1,550 KSIs or fewer.
Indeed, the latest data, shows that in 2024 there were 1,931 KSIs, which works out at a reduction of just 38% and is therefore higher (worse) than the RIS 1 target of a 40% cut in 2020, which the ORR has said was met because of lower traffic levels during the COVID pandemic.
But according to the ORR, National Highways’ response to this shocking failure has been to lobby for such network-wide targets to be removed from the RIS.
The ORR’s “efficiency” analysis that the company proposed “that the target for the number of people killed or seriously injured on the SRN be removed”. It wanted instead to be “held to account” for delivering a “flexible” five-year safety action plan with a forecast KSI reduction from delivering its National Programme and Designated Fund safety initiatives.
In its advice on the draft SBP, the ORR recommended “that a network-wide KSI target is retained and we have proposed a casualty reduction target based on the long-term trend in reductions in casualties on the SRN”.
On this point, the ORR prevailed but the target in the RIS is very weak. It only requires National Highways to “demonstrate it has done all it reasonably can” to achieve a 7.5% reduction in KSIs on by the end of 2031, based on the average for 2022-24. This is both lower in percentage terms than previous targets and, because the baseline is lower, a significantly lower target for casualty reduction.
With annual average KSIs for 2022-24 at 1,904, the required 7.5% cut provides a target of 1,761 during 2031 – more than 200 serious casualties over the 2025 target.
But given that National Highways only has to “demonstrate it has done all it reasonably can” and the ORR’s tendency to declare at the drop of a hat that it has done this, the target is almost an irrelevance.
By contrast, the Thomas Fleming assessment suggested an “ambitious” target of a 60% cut relative to the 2005-2009 baseline, which it said would put National Highways back on track eliminate KSIs by around 2050. This would mean 1,206 or fewer KSIs in the final year of the RIS. It said a “more pragmatic yet stretching target” would aim for a 10% reduction in KSIs relative to the 2005-2009 baseline beyond the reduction achieved in the interim year preceding RP3. That would be a cut of around 50% overall.
The 18 planned improvement schemes using the iRAP model are clearly what the ORR gave National Highways credit for developing to in its recent report on safety on the strategic network.
In its (earlier) review of the company’s draft SBP, the regulator commented that, from the evidence presented by National Highways, the corridor selection process, “appears to be robust”, but it criticised the company for “back ended expenditure profiles”, stating that “it is unclear, given the opportunity afforded by the interim period, why it has not proved possible to deliver more construction activity earlier in the period”.
This appears to have been based on comments in the Thomas Fleming report that that a “backloaded trajectory” for KSI reductions “suggests that much of the anticipated improvement is dependent on later stage activity, creating delivery risks due to resource availability, inflation and capacity challenges, and suggesting a lack of urgency to deliver KSI reductions earlier in the RIS3 period”.
The ORR also described the safety plans in the draft SBP as “narrowly focussed”, adding that “further work is needed to ensure planning translates into meaningful and measurable safety outcomes”.

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