Government ignores pedestrians and cyclists in country road default speed limit probe
It’s as if pedestrians don’t exist
By Patrick Francis
Summary
The ‘Reducing default speed limits outside of built-up areas September 2025’ Consultation Regulatory Impact Statement (RIS) conducted by the Australian Transport Department** in October 2025 is an important step forward for rural road safety but has failed to identify all the human being cohorts likely to be involved in casualty and fatality collisions on roads outside built up areas which have a default 100km/h speed limit. It is critical to recognise all road user cohorts as the Safe System principles, philosophy and interventions are the basis on which the Australian Road Rules, the National Road Safety Strategy 2021 – 2030, the state and territory Road Safety Strategies and Speed Setting Technical Guidelines, the National Road Safety Action Plan 2023 – 25, and Vision Zero 2050, were developed.
The Safe System is clear about traffic speeds where pedestrians and cyclist share roads including the default 100km/h roads outside built-up areas. “Pedestrians and cyclists should not be exposed to vehicle travel speeds of over 30 km/h”.
This Consultation RIS has not accounted for unprotected pedestrians and cyclists who share default 100km/h roads, so its ‘Proposed options for sealed and unsealed roads’ speed limits are in excess of the Safe System Speed recommendation for this group of road users.
This submission recommends that for future versions of the Australian Road Rules, the National and State/Territory road safety strategies and speed setting technical guidelines and Vision Zero 2050 to comply with the Safe System principles and interventions on which they are based, an additional set of three speed limits 30km/h, 40km/h and 50km/h be included in the Consultation RIS proposed options for the sections of sealed and unsealed 100km/h default speed limit roads outside built up areas that are shared with unprotected road users such as pedestrians and cyclists. Patrick Francis
Figure 1: The default 100km/h speed limit for roads outside built-up areas ignores Safe System principles, the changing demographics in regional towns and the way residents share with vehicles access and connector sealed and unsealed roads as open space for exercise, and nature appreciation. Photos, Unprotected residents sharing a default 100km/h access road outside the Romsey (Vic) town boundary,
The federal Department of Transport* inquiry into reducing default speed limits outside of built-up areas is welcome and overdue as the default methodology adopted by state and territory governments for rural and regional roads is out of date and out of line with Safe System philosophy and principles.
The Safe System has moved road safety from a blame the driver approach to protecting the driver, vehicle occupants and other road users from injury and death by implementing a philosophy that “….acknowledges the physiological and psychological limitations of humans and places ultimate responsibility on managers of the system to accommodate human limitations”(Austroads 2019)
Furthermore Austroads 2019 states: “Effective speed management is fundamental and critical to reducing speed-related road trauma. Speed limit setting is at the core of speed management. Speed limits need to be set at a safe and appropriate level, considering the function, design and safety of the road”.
The default speed limit on roads adjacent to town boundaries highlight how out of date that methodology is for preventing pedestrian and cyclists casualties and fatalities. These roads were historically access and connector roads for use by adjacent farm land owners, staff and service providers. They were never intended to be shared roads between vehicles, pedestrians and cyclists. However, with increasing population growth and its shift to regional towns facilitated by conversion of farm land into housing estates, default speed limit roads have become part of many residents open space options, figure 1.
Austroads (2024) explains clearly why this situation has developed for default speed access and collector roads immediately outside town boundaries before new housing developments were built and town populations increased: “Speed limits were initially adopted with little understanding of safety in relation to crash incidence, vehicle occupant protection and vulnerable road users. A range of limits were historically fixed according to an adopted hierarchy and roads were generally designed to maintain these operating speeds with less consideration given to the benefits of adopting lower speed limits as a means of achieving lower operating speeds on the basis of safety or infrastructure cost. These practices have resulted in a legacy that is taking considerable effort to change, mainly because the population has been living with ‘high’ speed limits not aligned with injury reduction for many decades”.
The reluctance of Transport Departments to recognise this new shared road reality is demonstrated in Transport Victoria’s Speed Zoning Technical Guidelines 2021. Its reasoning for the 100km/h default speed outside built up areas is “… to minimise the need to sign the vast extent of short and/or minor roads that exist throughout the Victorian road network.” There is no acknowledgement that around many towns the default 100km/h roads outside the boundary are being shared with vulnerable road users. But the Guidelines go onto state “Under the Safe System, the setting of speed limits takes into account the risks to road users of sustaining fatal or serious injuries. For example, at locations where there is a significant level of pedestrian or cyclist activity, lower speed limits are appropriate”.
Under Safe System based road rules and road safety strategies pedestrians and cyclists sharing roads outside town boundaries should never be exposed to 100km/h or even 80km/h speed limits. Austroads 2019 and 2024 state:
* “An important cornerstone of the Safe System philosophy is that the care of human life and health is considered more important than anything else”.
* “Pedestrians and cyclists should not be exposed to vehicle travel speeds of over 30 km/h”.
* “The Safe System philosophy … does not require crashes to occur before acting to improve high risk locations on the road network”.
Austroads and many state Transport departments have published or recognised either the Safe System Speeds table or graphics which demonstrate the kinetic energy transfer impacts are much more survivable at speeds at or below 30km/h, figure 2.
Figure 2: The Safe System Speeds table and graphs which show vehicle impact survival rate declines exponentially as speed increases above 30km/h are widely recognised amongst state and territory transport departments but not implemented on local roads outside built-up areas shared with pedestrians and cyclists. Sources: Austroads 2014, Transport Victoria (VicRoads) 2017, Transport for NSW, photos Patrick Francis.
The Commonwealth government’s National Road Safety Strategy 2021 – 2030 and National Road Safety Action Plan 2023 – 25 also refer to pedestrians and cyclists sharing roads and “…making them more vulnerable in the event of a crash.” They also acknowledge the Safe System Speeds in figure 2 with the statement “There is an estimated 10 per cent probability of being killed if struck at 30 km/h, but this rises to over 90 per cent at 50 km/h, the default speed limit in built-up areas”.
The National Road Safety Strategy and the National Action Plan ignores any reference to pedestrians and cyclist sharing 100km/h default speed limit roads outside built up areas as shown in figure 1, so these documents assume such sharing does not happen. The Action Plan goes further stating ‘Vulnerable road users’ such as pedestrians and cyclists have “… unique road safety issues that need to be considered’. While the Safety Strategy states “The system needs to be designed and retrofitted to minimise the chances of unprotected road users coming into conflict with vehicles”. Yet there are no Australian Government or State and Territory governments Action statements in the Action Plan describing safety actions for pedestrians and cyclists sharing 100km/h default roads.
There is a suggestion in both the Action Plan and Safety Strategy’s around funding infrastructure and non-infrastructure programs to reduce risks to vulnerable road users but no reference to these users on 100km/h default speed limit roads. What’s more funding infrastructure along thousands of kilometres of these shared roads would face significant environmental damage issues as well as funding issues.
In practice these issues are avoided if Safe System Speeds are introduced for shared 100km/h default speed limit roads close to towns. As Austroads 2019 states for all roads “Speed management has the potential to deliver the highest injury reductions at the lowest cost when compared to other safety interventions; however, this can only be regarded as a primary treatment if reductions are achieved down to survivable levels”.
The imperative for action is clearly noted in the Safety Strategy where it states “Pedestrian fatalities over the last 10 years have shown little progress in downward trends”.
The reasoning behind adopting Safe System Speeds is clearly spelt out in Austroads 2019, it states “The Safe System philosophy … acknowledges the physiological and psychological limitations of humans and places ultimate responsibility on managers of the system to accommodate human limitations. Effective speed management is fundamental and critical to reducing speed-related road trauma. Speed limit setting is at the core of speed management. Speed limits need to be set at a safe and appropriate level, considering the function, design and safety of the road.
Austroads 2025 concludes “Research has consistently shown that reduced speeds lead to fewer crashes and less severe injuries when crashes do occur. This is primarily because lower speeds reduce the stopping distance required for a vehicle, provide drivers with more time to react to unexpected hazards (such as pedestrians) and decrease the kinetic energy involved in a collision”.
The Safe System principles and interventions being the basis for the National Road Safety Action Plan 2023 – 25, mean the Consultation RIS Table 1 proposed options for sealed and unsealed roads must include options for 100km/h default speed roads shared with pedestrians/cyclists so any revised Road Safety Action Plan will comply with the Safe System.
Table 1: The Consultation RIS proposed options for sealed and unsealed roads do not meet the Safe System Speed requirement for pedestrians and cyclists sharing default 100km/h roads.
The Consultation RIS options ignore the safety of pedestrians and cyclists sharing 100km/h default speed limit sealed and unsealed roads. Irrespective of road surface the critical factor that needs to be introduced as an option is whether or not a road is being shared. If it is then the options should extend to 50km/h, 40km/h or 30km/h.
Most if not all 100km/h default speed roads being shared with pedestrians outside of town boundaries are low traffic volume access and connector roads. They are the roads closest to new housing estates being built on rezoned farmland on the fringes of existing town boundaries, figure 3. Their appeal to residents is the relatively low traffic volume and the opportunity to access attractive native vegetation, landscapes and biodiversity across road verges and on adjacent farm land within short distance of their homes.
Many residents move from cities to new housing estates on fringes of regional towns for economic as well as life style reasons with open spaces for exercise and communing with nature high priorities. For instance Macedon Ranges Shire Council states in its September 2025 Draft Open Spaces Strategy “The natural feel of open spaces is highly valued, and in particular landscape views and the preservation of biodiversity. Walking, cycling and running are the most common forms of physical activity”, figures 1 and 3A and 3B.
Figure 3A: The historic 100km/h default road approach is incompatible with the Safe System Speed principles around regional towns undergoing new housing developments to accommodate rising populations and resident expectations for using open spaces. In this example Romsey is a declared growth town for Macedon Ranges Shire. The first major housing estate Lomandra was completed by 2020 and has resulted in many residents using the attractive open space along a circuit of four roads three of which are unsealed 100km/h default speed roads, for exercise and to commune with nature. Two more housing estates adjacent to Lomandra are planned. Photo Google Earth and Patrick Francis
Figure 3B: Regional town housing estate residents are attracted to nearby open spaces along default 100km/h local access roads because of their adjacent landscapes and biodiversity. Photos Patrick Francis Moffats lane Romsey.
Despite the low traffic volume, the 100km/h default speed limit on narrow roads puts pedestrians and cyclists in great danger from vehicle collisions particular trucks as they have little room to move out of harms way such as on bridges and may even be injured attempting to avoid being hit by falling into drains, culverts and shrubs. There are also indirect impacts for pedestrians sharing gravel roads such as injury from gravel and rock throw and breathing complications from inhaling dust throw, figure 4.
Figure 4: Many default 100km/h roads are so narrow they present pedestrians and cyclists sharing them with danger from high speed collisions as well as unrecognised dangers including increased threat of being struck at narrow points like bridges and culverts and by stone throws and dust. Photos: Patrick Francis.
RIS cost benefit modelling incomplete without accommodating shared roads
The RIS modelling approach as described in chapter 4 is incomplete if its cost and benefits framework does not identify lower Safe Speed options for sealed and unsealed roads shared with pedestrians compared to those roads not shared. The detailed benefits and costs as described in Table 12 are incomparable for 100km/h default speed roads outside built-up which are shared, figure 3, and those not shared due to significant differences in variables involved including:
* Number of pedestrian and cyclist involved and subsequently the avoided fatalities, serious and minor injuries per kilometre.
* Number vehicle kilometres travelled in 2025 and projections for 2034
* Types and proportions of vehicles involved and cost of fuel
* Emissions benefits
* Intangible benefits such as reduced noise, reduced dust throw, improved town resident mental well being
* Reduced rate of wildlife vehicle collisions with cost and human health benefits given 1 in 41 collisions result in vehicle occupant casualty
* Private, business and logistics travel time
* Transport Authority and local government costs
* Social acceptance.
As well as these issues the Monash University Accident Research Centre’s updated Baseline Trauma Trends Model (BTTM) making informed FSI projections does not take injuries to unprotected users sharing 100km/h default roads outside built up areas as a specific cohort into account.
The FSI projection for the default roads model speeds is further clouded by variations in police crash report data which does not identify if a crash site was a default or signed speed zone.
This means the process for estimating FSI reduction on sealed and unsealed roads outside built-up areas using the stated default speed limit change scenarios will be meaningless for shared roads proportion of the total default speed roads.
Another significant modelling deficiency for the proposed default speed limit impacts on sealed and unsealed roads is the modelled travel speed reductions. For the sealed roads 90, 80 and 70km/h default speeds the travel speed reductions were 3km/h, 7km/h and 11km/h respectively. On the unsealed roads default speeds of 80 and 70km/h the travel speed reductions were 3km/h and 7km/h.
These modelled reduced speeds are far in excess of what the Safe System considers safe for unprotected pedestrians and cyclists sharing roads with vehicles. The modelled speeds demonstrate the futility of introducing the proposed default speed options without categorising roads as to whether or not they are shared or unshared. On unshared roads there will be likely reductions in FSIs as predicted in Table 37 but on shared roads FSI are likely to increase in line with predicted VKTs (Table 17) and projected increasing town populations and more people sharing roads. For instance Macedon Ranges Shire is predicting an 18.3% population increase between 2021 and 2031. Most of that increase to be accommodated in housing estate on edges of existing town boundaries and close to 100km/h default speed limit sealed and unsealed access roads, figure 3A.
The modelled avoided fatal and serious injuries 2026 – 2036 for the proposed speed reductions on sealed and unsealed roads, table 37 and table 41 are misleading for the proportion of roads shared between unprotected users and vehicles. On these sections of road the fatalities and serious injuries are likely to increase as the proposed speed reductions are far in excess of a human body’s biomechanical limit for kinetic energy transfer, figure 2. This RIA acknowledges the Safe System approach and states on page 27 “…when crashes inevitably occur, no one should be killed or seriously injured – that is, the road system needs to operate within the biomechanical limits of the road user”. Despite this the Safe System approaches example safe speed interventions in Table 8 fail to include implementing the Safe System speeds recommended for pedestrians and cyclists sharing roads with vehicles. The consequences for ignoring the safe speeds has been highlighted in Austroads October 2025 ‘Review of Speed Management Evidence and Guidance’, figure 5.
Figure 5: Austroads cannot be clearer about safe speeds for pedestrians sharing roads with vehicles. In this October 2025 infographic, driving at 65km/h has a 73% likelihood of pedestrian fatality or serious injury due to the driver’s speed, limited field of vision and stopping distance. The minimum speeds being considered for the consultation RIS are 70km/h on unsealed default roads and 80km/h on sealed default roads. Source: Austroads October 2025 ‘Review of Speed Management Evidence and Guidance’.
Operating within the biomechanical limits of all road users means the Net Present Value and Benefit Cost Ratio detailed in the page 67 table, tables 42 and 43 and figure 15 for each central estimate VKT-FSI assumption cannot be considered accurate or in the safety interests of unprotected road users. To be useful they should be calculated separately for sections of 100km/h default roads shared by unprotected road users and for the remainder of unshared roads.
The value of modelling as used in this Consultation RIS to achieve greater safety on existing 100km/h default speed roads has to be questioned when the data surrounding road fatalities and casualties across states is so incomplete. This is demonstrated in Transport Victoria’s ‘Road Trauma in Victoria 2024 Statistical Summary’ where the department states “DTP has data on motor vehicle travel on a limited selection of roads, but does not have travel data for the entire Victorian road network. It has therefore not been possible to report or compare total vehicle-kilometres of travel, nor rates of trauma per vehicle kilometre travelled, for particular road types, vehicle types or road user types”.
Conclusion
As the purpose of this Consultation RIS is to seek stakeholder feedback “… to inform a future review of default speed limits outside of built-up areas in the Australian Road Rules” then it should not confine feedback to its own preferred options that contradict the Safe System interventions for some road users. If the Safe System is to be considered a legitimate way of reversing Australia’s declining road safety performance with road fatalities per 100,000 population increasing from 4.3 in 2021 to 4.7 in 2024 and achieving Vision Zero 2050 then it must be adopted in its entirety and its principles and interventions applied with equity to all roads and road users. As Austroads 2024 states “With unprotected road users, safe speeds remain the most practical way for addressing safety”.
* Australian Government Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts.
** Background to the Consultation Regulatory Impact Statement (RIS):
In May 2021, the Australian Government and all state and territory governments agreed to the National Road Safety Strategy 2021-30 (the Strategy), which sets out the collective ambition of governments to improve road safety. Notably, this includes a reduction in road fatalities serious injuries by 50% and 30% (respectively) by 2030, with a long-term goal of zero by 2050.
To that end, the Infrastructure and Transport Ministers launched the National Road Safety Action Plan 2023-25 (the Action Plan) which detailed the actions each government would take to contribute to the 2030 goal. This included a commitment by the Australian Government, through the Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts (the Department) to: Co-ordinate a review of the Australian Road Rules and development of a Regulatory Impact Statement (RIS) on reducing the open road default speed limit in consultation with state and territory governments, including police, and local government. (Page 14, National Road Safety Action Plan 2023–25)
References:
Australian Government September 2025, ‘Consultation Regulatory Impact Analysis Reducing default speed limits outside of built-up areas’
Austroads 2019 Research Report ‘Road Risk Assessment, Case Studies and Engagement Guidance for Speed Management’
Austroads 2024 ‘Guide to Road Safety Part 3: Safe Speed’
Austroads May 2025 Research Report ‘Facilitating Speed Management Change: Example Case Studies from Australia and New Zealand’
Austroads October 2025 ‘Review of Speed Management Evidence and Guidance’.
Commonwealth of Australia 2023 ‘Infrastructure and Transport Ministers National Road Safety Action Plan 2023 – 2025’
Commonwealth of Australia 2021 ‘Infrastructure and Transport Ministers National Road Safety Strategy 2021 – 2030’
Transport Victoria (DTP) February 2025 ‘Road Trauma in Victoria 2024 Statistical Summary’
Transport Victoria December 2021 ‘Speed Zoning Technical Guidelines’
Macedon Ranges Shire Council September 2025 ‘Draft Open Spaces Strategy’
