15 January 2015

ACT Speed Cameras

Last year's Speed Cameras in the ACT Performance Audit Report by the ACT Auditor-General comments
The ACT is unlikely to have the right number of speed cameras in the right places. The effectiveness of speed cameras in the ACT has not been established. Speed camera reliability is poor.
After noting that those deficiencies have  no effect on the validity of infringements issued the report offers specific comments over some 110 pages
Siting of speed cameras conclusions (Chapter 2)
There is no strategic basis for making decisions for integrating the use of the ACT’s speed camera systems as the ACT Government does not have a speed camera strategy and its draft ACT road safety camera strategy (September 2013) is ‘not a strategy’. Over the last fourteen years, the use of speed cameras in the ACT has grown incrementally without a strategy that covers the whole road network, or the contribution each camera system makes towards long-term road safety goals.
Problems and uncertainties exist with each of the four speed camera systems in use in the ACT:
  • Mobile speed camera coverage is limited compared with that envisaged by the ACT Government in 2005, and mobile camera operations are overt which means it is unlikely that the ACT Government is achieving its desired ‘anytime, anywhere’ approach. 
  • Speed and red light cameras may not be located at the highest priority sites as their effectiveness and relative priority, compared with intersections with traffic lights where there are no cameras, has not recently been evaluated. The last evaluation occurred in 2003 and it was for three sites only. 
  • There are too few mid-block speed cameras to achieve the Government’s aim of having a general effect on speeding across the road network, and the siting of these cameras does not take account of crash data as is the practice in other Australian jurisdictions. Mid-block cameras are unlikely to be sited to achieve the best road safety results. 
  • The siting of point-to-point speed cameras in the ACT is experimental as there is little or no evidence from elsewhere to support their use in an urban environment, for such short sections of road, or for the purpose of reducing speeding beyond the sections of road between the pairs of cameras. There is no evaluation plan to determine the effectiveness of the ACT’s point-to-point speed cameras.
Effectiveness of speed cameras conclusions (Chapter 3)
There is a persistent speeding problem in the ACT, according to survey and infringement data, which calls into question the effectiveness of the ACT Government’s speed camera systems.
Evaluations of speed camera systems, particularly the mid-block speed cameras and the recently implemented point-to-point cameras have not been undertaken. Furthermore the value for money of the two point-to-point camera installations is questionable. It is likely there has been a three-fold increase in the cost per km of road treated from the initial design stage through to implementation.
While the speeding problem in the ACT is persistent, its extent is unknown. Residents report high levels of speeding, but this cannot be confirmed with any accuracy. The use of infringement data from camera sites is an unreliable indicator of speeding behaviour across the road network and speed surveys have not been designed to be representative. As a result there is limited information on whether the problem of speeding is increasing or diminishing on the road network.
Limitations in data used in the development of the ACT’s speed camera systems are not identified to decision makers. The planning and coordination of data collection is not effective. Information on camera effectiveness has not been routinely made public. The administration of requests for the disclosure of vehicle images is inadequate.
Speed camera reliability and operations administration conclusions (Chapter 4)
Reliability problems, particularly with mobile cameras, have led to escalating maintenance costs, limited camera availability, and a greater number of rejected infringements when checked by adjudicators prior to issuing. This compromises the effectiveness of the Government’s speed enforcement activities as fewer speeding motorists receive a Camera Infringement Notice, despite speeding occurring at camera sites. In 2013-14 the Government funded ($1.55 million) the replacement of most of its speed camera equipment that is more than ten years old.
The Government’s administration of Camera Infringement Notices with respect to the verification of infringements is robust thereby reducing the risk of issuing invalid infringements. However, the relatively high rejection rate of potential infringements indicates inefficiencies. The Traffic Camera Office is aware of the limitations of its adjudication system which will be the subject of an options evaluation in 2013-14.
All fixed speed cameras receive routine checks with planned maintenance currently meeting requirements. While this is the case, the current maintenance cycle for these cameras may be too frequent in some instances. This needs to be investigated as savings may be able to be realised if cameras are being over serviced.
Although the Government has provided funding in 2013-14 for existing equipment replacement and maintenance, there is no documented strategy to guide how best to program and integrate these activities.
The planning and review of the sites scheduled for mobile speed van operations is inadequate. This makes strategic forward planning difficult and presents the risk that these cameras are not being used effectively.
The Auditor-General's key findings are -  
Siting of speed cameras --  The development of speed camera systems in the ACT . Since speed cameras were introduced in 1999 the ACT Government has not developed a speed camera strategy that: supports its road safety strategies and road safety action plans; adopts a network-wide approach; identifies a target contribution from speed cameras to the overall reduction in fatalities and injuries; and integrates systems and actions.
Budget proposals have been the basis for expanding speed camera systems in the ACT. Many have had a focus on adopting a new technology. Budget proposals have been inadequate as there has been no explanation for the scale of funding requested, proposals do not state what the funding requested will achieve in terms of road safety results and what the relationship is between the level of funding sought and the long-term expansion of camera systems.
At no time in the fourteen years of the development of speed camera systems in the ACT has there been a Government commitment to, or policy position for, the extent of the camera coverage in a timescale beyond the budget round at the time. Expansion has been a stated aim but it has not been defined.
The ACT Government in 2011 recognised the need for an overarching speed camera strategy in its Road safety action plan 2011-2013 in stating that an ‘overall strategy and guidelines for gradual expansion will be prepared’. A draft ACT road safety camera strategy (September 2013) has been prepared.
Professor Max Cameron, the road safety subject matter expert engaged to assist in this audit, advised that
‘The ACT road safety camera strategy (draft) is not a strategy. No goal is stated and its specific objectives for achieving a reduction in road trauma in the ACT are not given. The four types of camera system represent the elements of the system, but it is unclear what principles for the deterrence of speeding are their basis. No estimates of the speeding and crash reductions likely to be achieved by the camera systems, alone and in aggregate, appear to have been made in developing the strategy. Hence the ACT Government will have no idea whether its road safety camera program will contribute substantially to achieving the ACT and National strategic goals of 30 per cent reduction in serious road casualties by 2020, or not at all’. 
The lack of an adequate speed camera strategy presents the risk that the ACT’s speed camera systems, collectively and individually, will not achieve desired road safety objectives, funding will not be targeted, and decisions to invest in specific speed camera systems will result in poor value for money.
The ACT Government has agreed to adopt the National road safety strategy 2011-2020 which seeks to have jurisdictions consider the issue of hypothecation by the end of 2013. According to an Austroads report (2013) there has been a partial or full hypothecation of revenue from speed enforcement activities directly back to road safety in Victoria, Queensland, Tasmania and Western Australia. The ACT Government’s position on this matter has not been stated. 
Mobile speed cameras -- Mobile speed camera sites were initially selected based on, amongst other things, data relating to speed-related crash history and speed surveys. In 2005, the Government committed to assessing all 649 arterial and collector roads in the ACT with a view to expanding the number of sites for its mobile speed camera operations, and achieving a greater compliance with speed limits across the whole ACT road network.
The expansion of mobile speed camera operations is taking considerable time to achieve as after nine years, mobile speed camera vans are only able to be used on 147 roads, which is 23 per cent of the ACT’s 649 arterial and collector roads. This is because not all of the 649 roads have been assessed and therefore cannot be added to Schedule 1 of the Road Transport (Safety and Traffic Management) Regulation 2000 to facilitate the use of mobile speed cameras. 
Furthermore, since 2005, at least 77 per cent of sites added to Schedule 1 were initially identified from public complaints. In most cases, during the site assessment process, there was limited consideration of other site selection criteria, such as accident history and traffic density. Therefore Schedule 1 may not reflect the most appropriate sites according to a balanced consideration of all site selection criteria.
The ACT Government mobile camera operations are overt as the vans used in the ACT are white with a sign on the van roof stating ‘your speed has been checked’. This makes the vans identifiable to road users on their approach to the mobile speed cameras. While an overt approach is used, there is no evidence to suggest that a covert or a combined overt and covert approach, as happens in some other jurisdictions, was considered in the decision-making process.  Given the relatively limited number of sites where mobile camera vans may operate, and that operations are undertaken in an overt manner, the ACT Government is unlikely to achieve its desired ‘anytime, anywhere’ approach. 
Speed and red light cameras -- At the time of the introduction of speed and red light cameras in 2001, twenty intersections had been identified and prioritised from the analysis of crash data from the previous four years. The circumstances surrounding each crash at the twenty intersections were considered. As with mobile camera sites, each intersection was required to be added to Schedule 1 of the Regulation.
The ACT Government’s road safety strategy action plans (2003-04, 2005-06) identified the need for the ‘review of current intersection crash data to ensure most efficient allocation of red light cameras’. No such review has taken place since 2003, and the 2003 review related to the first three sites selected for speed and red light cameras.
Mid-block speed cameras -- Between the time at which the budget proposal was agreed in 2006 through to April 2008, there was a change in the Government’s stated purpose for the mid-block cameras: from one of achieving a local effect at ‘dangerous locations’ to that of achieving a general effect to improve speed compliance across the whole road network.
Professor Max Cameron advised that: … a signed, conspicuous fixed-spot speed camera system cannot achieve [a general deterrent or general effect], unless there is a high density of cameras e.g. at least 1 per 4 km.
There was no evidence that the ACT Government had planned a mid-block speed camera system with sufficient camera sites to potentially achieve a general effect across the whole arterial road network. The arterial network in the ACT extends to around 290 km on which there are only nine locations with thirteen mid-block speed cameras.
Furthermore, crash data was not included in the criteria for determining the siting of the mid-block cameras. The ACT is the only jurisdiction where crash data has not been used to prioritise mid-block camera sites.
Point-to-point speed cameras -- The ACT Government has implemented two point-to-point installations, one on Hindmarsh Drive and one on Athllon Drive. The Territory and Municipal Services Directorate has indicated that the purpose of the ACT Government’s point-to-point camera system is twofold: to have a general effect across the network, that is, an effect beyond the length of road between the pairs of speed cameras, and to have a local effect.
Professor Max Cameron advised that: ... there is no research to support the aspiration that the system will have an effect beyond the section covered by the pair of cameras, that is, a local effect over the treated length.....beyond that it is unclear and ambitious.
In relation to the use of point-to-point in an urban setting, Professor Max Cameron advised that it is: ... unprecedented outside the ACT ... [and that there are] doubts about its suitability in urban areas except for long lengths of urban freeway ...
The cost effectiveness of the installations on the two sections of road (Hindmarsh Drive, 2.8 km and Athllon Drive, 3.7 km) covered by the point-to-point cameras in the ACT is compromised since each section is shorter than: o the minimum length of sections in the two other jurisdictions (Victoria 7 km, and Queensland 14 km) that have installed point-to-point cameras for speed enforcement of all vehicles; o the minimum length initially proposed (5 km) by the ACT Government’s advisors in the Forward Design Study: Introduction of Point to Point Speed Cameras in the ACT (July 2010) in order to be the most cost effective option; and o the minimum length recommended by advisors (10 km) to two other jurisdictions considering the introduction of point-to-point systems.
While there are currently two point-to-point installations in the ACT, the initial forward design study (2010) identified ten or potentially more being implemented in a phased approach following a pilot. However, there is no evidence that advice has been sought or received as to the extent to which the current two installations or the initially proposed ten installations, as part of the phased approach, would provide a general effect across the network, or a local effect on the road lengths between the pairs of cameras.
The pilot of the point-to-point speed camera system in the ACT does not have a supporting evaluation plan that would ensure learnings from this experiment are maximised. Evaluating the pilot is important in order to determine if this type of system is providing value for money and should be further deployed in urban areas. 
Effectiveness of speed cameras (Chapter 3)
Infringements -- Infringement rates for fixed speed cameras in the ACT are around 0.06 to 0.12 per cent over the long term, i.e. approximately one vehicle in one thousand is issued an infringement notice for speeding at camera sites. Infringement rates are of limited use in determining the extent of speeding. These rates are likely to grossly understate the level of speeding above the speed limits across the whole ACT road network as: o camera detected infringements are only issued for speeding offences that are significantly above the speed limit; and o the overt nature of fixed speed cameras and signs in the ACT provides road users with ample warning to slow down approaching camera sites.
The National road safety strategy action plan 2007-08 outlines measures for best practice including adopting ‘tight enforcement tolerances’. The ACT Government agreed to review the discretionary speed enforcement tolerance in the ACT in 2007-08. However, there is no a documented rationale for the ACT’s enforcement tolerance.
Community attitudes -- The National Survey of Community Satisfaction with Policing surveys shows that the ACT has a speeding problem as over 60 per cent of drivers surveyed each year from 2009-10 to 2011-12 stated that they had driven 10 km/h or more above the speed limit. This is higher than the Australian average and other jurisdictions in Australia, except for New South Wales in 2011-12 and Western Australia in 2010-11 where reported speeding was similar to that in the ACT.
Public perceptions of crime problems are also considered in the National Survey of Community Satisfaction with Policing surveys. Survey data suggests that ACT residents had the second highest level of concern for speeding as nuisance behaviour in residential neighbourhoods compared to residents in other Australian jurisdictions in 2011-12.
Attitudes of ACT residents, as identified in surveys, are difficult to reconcile. When compared to residents of other jurisdictions, ACT residents: o are more likely to see poor driving skills as a contributory factor in crashes; o are less likely to link speeding with the incidence of crashes; o have the strongest support for more speed enforcement activity; o feel they are less likely to get caught speeding; and o are more likely to agree with the speed limits. It is not clear in the draft ACT road safety camera strategy how community attitudes are influencing speed camera systems in the ACT. 
Speed surveys -- The ACT Government conducts and annually publishes the results of a large number of roadside speed surveys. In the last fourteen years there have been 3 644 surveys which show that free-flow traffic speed is greater than 5 km/h over the speed limit for approximately 50 per cent of the survey sites and ranges from 41 and 65 per cent.
While this identifies the extent of the speeding problem at specific locations this data does not provide an accurate indicator of speeding across the network. This is because the selection of survey sites is not a representative sample of road types and conditions of the ACT road network. Sites are generally identified for surveying as a result of perceived problems.
Speeding infringement rates, community surveys and roadside speed surveys indicate there is persistent speeding in the ACT. Since there is no network representative roadside speed survey or any other speed monitoring system, it is not possible to determine whether this problem is increasing or diminishing across the whole road network.
Evaluation -- Over the past fourteen years, the Government has planned but not undertaken evaluations for many aspects of its speed camera operations. Two camera systems (mobile, and speed and red light cameras) were evaluated but this was over ten years ago, and neither was conclusive. There is no overarching evaluation framework to gauge the effectiveness of speed camera activity across the whole ACT network despite the adoption and siting of camera systems in the ACT that is either contrary to prevailing research or where there is an absence of accepted practice.
The draft ACT road safety camera strategy recognises that formal evaluations of the effect of ACT road safety cameras have been limited and proposes options for the evaluation of effectiveness of the Government’s speed cameras. However, there is no commitment in the strategy to a forward program of evaluations. In November 2013 the Government committed to undertaking an evaluation of the ACT’s speed cameras in the first half of 2014.
No evaluation plan has been developed to guide the assessment of the pilot of the point-to-point system in the ACT. Such a plan is important to determine if this type of system is providing value for money and should be further deployed in urban areas.
The value for money of the point-to-point system pilot is likely to have been compromised by changes to the lengths of road covered by the two installations. The reduction in the length of the road between the pairs of point-to-point cameras, combined with the increase in actual costs (compared to the estimated cost) of installing this system, has led to a three-fold increase in the cost per km of road treated.
Data collection -- National road safety strategy action plans advise that the collection of speed data should be done independently of the data generated by enforcement activity at speed cameras sites. This is achieved in the ACT since the Traffic Data Unit in the Territory and Municipal Services Directorate provides such data to Legislation, Policy and Programs in the Justice and Community Safety Directorate, that is, the Directorate that leads on road safety policy and enforcement. However, the planning and coordination of activities between these sections is not fully effective.
The siting criteria for speed camera systems currently used in the ACT have relied on data which is primarily sourced from surveys of road speeds and traffic conditions, management information from camera operations such as infringement rates, and information on crashes. File records identify that many data sources used in the siting methodologies are imperfect as they are often incomplete or imprecise. There is a risk that decision makers are asked to make decisions on recommendations without knowing the robustness of the data.
Data utility is improving as the Territory and Municipal Services Directorate has been able to plot crash sites more accurately since 2011, using precise coordinates rather than attributing crashes to long sections of roads. Also a larger number of traffic light-controlled intersections can now be monitored for red light running, which can be a very useful predictor of potentially dangerous intersections.
Camera operations data -- The draft ACT road safety camera strategy identifies the need to improve the public availability of camera siting information, but the strategy does not identify a need to improve the availability of camera effectiveness information. Information on camera effectiveness has not been routinely made public. Other jurisdictions are considering publishing or have already published information on the effectiveness of camera operations.
Protecting and disclosing images of vehicles -- Disclosure of images from speed camera operations is permitted if it is ‘reasonably necessary for the enforcement of criminal law’. The point-to-point installation on Hindmarsh Drive takes images of an estimated 900 000 vehicle movements a month. ACT Policing has made 22 requests for images since January 2012. No other agencies have made requests.
The Traffic Camera Office’s administration of these requests is an area where procedures, practice and record keeping should be improved in order to provide assurance that camera image disclosure is ‘reasonably necessary’.
Speed camera reliability and operations administration (Chapter 4)
Speed camera reliability -- Annual reports show that the Government’s target level of fixed speed cameras being ‘in use’ for 95 per cent of the time has been achieved in six of the last seven years.
The Justice and Community Safety Directorate target of 43 shifts per week for mobile speed camera operations was not achieved in the last three years. Operational availability fell markedly in 2012-13 with fewer than 40 per cent of 43 shifts per week being possible in three of the four quarters of the year. This was due to equipment failure, which has resulted, at times, in only two of the five camera vans being available.
The number of reactive maintenance work requests has increased in the last three years by 109 per cent, from 114 in 2010-11, to 174 in 2011-12, and to 238 in 2012-13. An estimated two per cent of mobile camera detected potential infringements had to be rejected during adjudication due to camera errors in the two-year period to June 2012.
Maintenance of speed camera equipment -- The current and previous maintenance contracts covering the period August 2009 to date have a requirement for fortnightly planned maintenance for fixed speed cameras. This was not achieved in 2011 or 2012 but was met in 2013. While this is the case, it may not be problematic as in Victoria planned maintenance for fixed camera devices is specified to be undertaken on a monthly basis. It was not evident why fortnightly maintenance inspections are necessary in the ACT, rather than monthly. The estimated additional cost to the ACT of requiring fortnightly rather than monthly planned maintenance is $120 000 a year.
For the management of reactive maintenance, the Traffic Camera Office has improved its ability to track and confirm the responsiveness of its contractor. However, there remain areas for further improvement.
The Government agreed on 4 June 2013 to fund the replacement of six of its eight speed and red light cameras that are over ten years old and all its mobile cameras, costing $1.55 million. Once implemented, this will ensure all except two cameras in use on ACT roads are less than ten years old.
While the Government is funding the replacement of older speed cameras in 2013-14, there is no documented strategy that sets out the rationale and the program for speed camera maintenance and replacement.
Speed camera accuracy -- In considering the accuracy of speed measuring devices for the period 2010 to 2013, the Audit Office identified a lack of a master inventory of devices. In addition there is no readily accessible record system that identifies whether speed measuring devices are either in or out of use, or their location or certification dates.
Justice and Community Service Directorate officers acknowledge the desirability of such a system, and advised that the use of an electronic diary for annual certification reminders, introduced after the February 2010 audit, was a stand-in measure until a new adjudication system was introduced that would incorporate the means to monitor annual certification. This system has not been designed or implemented.
There is no verification process for when test certificates are received by the Traffic Camera Office to check that their key content is correct, such as device details, test and signatory dates. 
Mobile speed camera operations  -- Based on a walk-through of systems and procedures by an audit officer on 24 September 2013, the assessment of records and a review of other documentation, it is considered that operational practices are aligned with legislative requirements and internal standard operating procedures regarding initial mobile camera operator training, and associated operator approval.
Auditing mobile camera operators, once approved, is an area where the record keeping, and potentially practice, is not in accordance with the internal standard operating procedures. The internal standard operating procedure for this indicates this should comprise one, two and three-month audits, as well as a number of unannounced audits and the evaluation of traffic camera operator effectiveness. There was no documented evidence of this audit process occurring.
In planning the shift schedule for mobile camera operations, the Traffic Camera Office takes limited account of site by site infringement history, that is, whether previous camera van shifts at the same site identified a high number of infringements and therefore evidence of a continuing speeding problem.
There was no evidence that demonstrated that the Traffic Camera Office periodically assesses road accident statistics to ensure that sites that are statistically significant are allocated mobile speed camera coverage, as the ACT Traffic Camera Office Mobile camera unit site selection criteria states should happen. There is no routine analysis of the results of mobile speed camera operations. 
Infringement validity -- The ACT Traffic Camera Office has a relatively high rejection rate of potential infringements due to adjudication. Between 18 and 43 per cent of all potential infringements per year over the last fourteen years have been rejected during adjudication. Rejected infringements are deemed to have not met evidentiary requirements. Professor Max Cameron advised that other Australian states typically achieve a lower than 20 per cent rejection rate as a result of adjudication, with one state managing an improvement from 25 down to 10 per cent over a fifteen-year period. He further advised that the percentage that is rejected is something that can be reduced, given effective systems.
Officers in the Traffic Camera Office identified that the existing adjudication database introduced in 2000 has many monitoring and reporting limitations due to its age and design. This makes it difficult to systematically focus on process improvements that may lead to reducing the infringement rejection rate. For example, officers advised that it is not possible to identify trends in the reasons for rejecting cases, the identity of previous adjudicators or the reasons for changes.
As a result of a 2013-14 budget proposal from the Justice and Community Safety Directorate being supported by the Government, funding of $50 000 has been allocated to evaluate adjudication system replacement options. This is currently being undertaken.  In the 60 infringement cases reviewed by an audit officer, there was sufficient evidence to re-adjudicate the case and the same conclusion could be derived as that made in the original adjudication.  
An analysis of the supervisory control sheets showed that there was disagreement between the first adjudicator and the cross checker in 0.3 per cent of all cases adjudicated for the most recent twelve-month period. This indicates that adjudicators, for a very high percentage of infringements, are consistent in their decision making regarding an infringement’s validity.
Training and development is effective in enabling new staff members to develop the skills and knowledge necessary to undertake the adjudication role and to be approved as competent. However, there is no independent training provided to the adjudicators, and there is no documented procedure for the adjudication training process. The Office is heavily reliant on the corporate knowledge of a few key members of staff with learning occurring through the sharing of experience.
Infringement administration -- Thirty case studies were assessed by an audit officer with respect to the three matters of: extension of time to pay ‘out of time’ applications, withdrawal of Camera Infringement Notices, and unknown drivers. The assessment identified inadequacies in procedures and their implementation, and in record keeping, since: o internal standard operating procedures were not up to date; o while there were internal standard operating procedures, at least in part, for each of these three matters, these were not always followed; o there was insufficient evidence in rego.act of the actions taken to understand why some decisions were made; and o the identity of the administrator approved to take a particular action was not available in every case.
The ACT Government has issued around 60 000 Camera Infringement Notices a year in the past three years, and collected around $10 million a year in fines. At any time over this period there is around $2 million to $3 million in uncollected fines. The value of uncollected speeding fines has grown from $448 528 as at 1 July 2001 to $2 939 455 as at 1 July 2013.
In June 2013 the Government legislated and implemented arrangements to enable people in receipt of infringement notices, who are having difficulties, to seek an extension of time, and to pay off fines according to an agreed plan. Long-term or high-level debtors are being encouraged to use the new arrangements. A priority group of road users with $4.8 million in debt have been contacted. Plans have been agreed for over 1 700 road users which account for $2.5 million in debt.
Limited management information is routinely drawn from the rego.act system to provide assurance as to the effectiveness of the system, for example, in terms of the transparency, consistency and fairness of administration of Camera Infringement Notices.
The report notes that the Auditor-General made 16 recommendations
R1 -- The ACT Government should develop and implement a speed camera strategy that: a) includes a goal and measurable objectives for achieving a reduction in road trauma on ACT roads through the use of speed cameras and related speed management actions; b) takes a long-term perspective (to 2020 or beyond) and addresses speeding and speed related crashes across the whole of the ACT road network; c) establishes, using leading practice from elsewhere, options for the development and integration of speed camera systems that will collectively achieve the targeted reductions in road trauma; and d) includes a sensitivity analysis, to support future budget proposals, which shows how varying levels of investment and the phasing of implementation will affect short, medium and long-term road safety.
R2 -- The ACT Government should develop and implement a mobile speed camera plan which: a) specifies the extent of the ACT road network where mobile speed cameras may operate, and the time by which this is to occur; and b) identifies the effect of different levels of operational intensity (i.e. the number of vans and shifts, and siting priorities), and mode of operation (i.e. overt, covert) on road safety goals as coverage of the road network is expanded.
R3 -- The  Government should review the purpose and siting of its existing thirteen mid- block speed cameras to determine if they need to be removed, relocated or expanded.
R4 --  The  Government, for its two existing point-to-point speed camera installations, should: a) review and state the purpose of the system; b) develop and implement an evaluation plan to assess their effectiveness in reducing speeding and road trauma; and c) determine their value for money compared with other speed management treatments to inform future decisions.
R5 -- The  Government should develop and implement a ‘relatively large, network- representative, speed monitoring system’ in order to determine changes in the extent of speeding on ACT roads.
R6 -- The  Government should develop and implement an ACT speed camera evaluation and data collection plan.
R7 -- The  Government should routinely publish information on the effectiveness of all its speed camera systems according to the stated purpose of each system.
R8 -- The Justice and Community Safety Directorate should document its procedures, and maintain comprehensive records, for its administration of requests for the disclosure of camera images.
R9 -- The  Directorate should align its speed camera maintenance practices, internal standard operating procedures and contractual requirements.
R10 -- The ACT Government should develop and implement a speed camera maintenance and replacement strategy (This could be part of the speed camera strategy which is the subject of Recommendation 1).
R11 -- The Directorate should develop and maintain a master inventory of speed camera devices and use this to verify the key content of new certification against primary and / or secondary sources.
R12 -- The  Directorate should undertake and document audits of approved mobile speed camera operators in accordance with its internal standard operating procedures.
R13 -- The  Directorate should strategically plan its mobile speed camera operations by fully applying the principles in the Mobile camera unit site selection criteria guide and as set out on its speed camera web-pages.
R14 -- The  Directorate should improve its recording of adjudication information so that this can be used to target improvements for reducing the infringement rejection rate.
R15 -- The  Directorate, in its administration of infringements in the rego.act system, should: a) update its internal standard operating procedures; b) align practice with procedure; and c) maintain comprehensive records for all manual interventions.
R16 -- The  Directorate should monitor the transparency, consistency and fairness of the administration of Camera Infringement Notices in the rego.act system by conducting qualitative and / or quantitative reviews.