Jennifer Bunyan and Marion Bunyan

Cambridgeshire
——_ © AAA county Council

Your ref:
Date: 7 October 2024
Contact: Chief Executive’s Office
Telephone: Cambridgeshire County Council
Email: New Shire Hall
Emery Crescent
Mr. David Heming Enterprise Campus
Senior Coroner Alconbury Weald
for Cambridgeshire and Peterborough Huntingdon
HM Coroner’s Office PE28 4YE

Dear Mr Heming,
Cambridgeshire County Council response to Regulation 28 report, Puddock Road

| write in response to the Regulation 28 Report to Prevent Future Deaths, dated 26 July
2024, which followed the Inquest into the deaths of Jennifer Bunyan, Marion Bunyan and
Erin Marion Chatten. In responding to you | first, and most importantly, wish to express
the County Council’s sincerest condolences to the family and friends of Jennifer, Marion
and Erin.

| also recognise that this response has taken longer to be produced that | would have
expected, or in accordance with the timescales you originally set. Please accept my
apologies for this delay, which was impacted by some organisational changes within the
County Council, which meant that this response involved a number of teams in transition
to new roles and reporting arrangements. However, | am pleased we are now in a
position to be able to formally respond to you.

Therefore, this letter details Cambridgeshire County Council’s response to the matters
you have raised as of concer as listed below.

A. Speed limit:
The designated speed for this section of road was 60 mph. The charity BRAKE have
Stated that the default speed limit on rural roads is 60 mph, a speed at which it is rarely
Safe to travel.

They stated the approach should be based on the design of roads. This road has an
uneven road surface and it was within local knowledge that the designated speed limit
was dangerous and could lead to a loss of control whilst driving in the upper speed
range.

The need for a reduction in the limit as a safety measure does not appear to have been
raised during inspections/debriefs following a series of fatalities that have led to a
number of drowning incidents along this section of road. It raises a concer that the
speed limit should be reduced significantly as a risk reduction measure — some areas
have adopted 20 mph on some sections of road.

B. Inspections of the road

 & Chief Executive cambridgeshire.gov.u

| have a concern that inspections of the road have not been sufficiently rigorous given a
recurring issue of highway degradation from ‘rutting’ at the carriageway edge which can
be a contributory factor causing loss of control of a vehicle.

It is unclear if the council have carried out audits to review the quality of inspections and
whether there have been examples of substandard inspections.

. Length of time to effect remedial action
These deaths occurred on the 7“ June 2020 and there had been previous fatalities along
this road which had led to fatalities caused by drowning when vehicles left the road.

A Barrier to prevent entry to the waterway would be one effective measure that has been
deployed in many other places to prevent a vehicle leaving the road and yet, |
understand no final solution is in place.

. Highway degradation

This has been an issue and | have a concern about prompt repairs being effected to the
road and also the weight of vehicles which is a factor in damage to the verge adjacent to
the road itself.

. Local safety group

The Fenland Road Safety Campaign (Charlotte's Way) have undertaken outstanding
work as a charity in raising awareness of the dangers of Fenland roads given the unique
environmental factors involved. It is not clear whether there has been prompt action
taken following representations from them on safety matters.

The County Council has carefully considered the issues that you have raised and offers
the following response to each of these areas:

Speed Limit

The speed limit on the single-track section of Puddock Road will be reduced to 30mph,
with 40mph buffer entry sections, from November 2024. A formal traffic regulation order
(TRO) has been approved for implementation of the new speed limit. The order will be
formally made following installation of the signage.

Inspections of the road

Puddock Road is subject to a formal inspection every three months and regular visits
from a Local Highway Officer. Where identified, necessary repairs are undertaken and
where possible, rutting is back filled. This is an interim solution to a complex issue
around soil erosion and climate factors. In July 2024 soil core sample were taken from
random sections of Puddock Road to assist engineers in understanding what lies
beneath the road and identify possible long term remedial solutions. The core samples
have revealed a peat layer between 300 and 500mm deep, on top of which is a layer of
silty clay.

As with other Fenland roads, Puddock Road is identified as one of the roads that has
been impacted by the behaviour of the soils on which the road has been built. Engineers
are now consulting on how best to deal with the rutting caused by the use of heavy

Adrgd Cambridgeshire
 & ACA County Council

agricultural machinery that overruns the paved road. Verge reinstatement trials will begin
in early 2025 where different sections of rutting will receive treatment to see which
performs best under varying conditions, and when it is anticipated the verges will be at
their softest and most susceptible to collapse or wash out. As part of a wide-ranging
change programme within our Place and Sustainability directorate, the County Council is
revising and tightening its assurance arrangements.

Length of time to effect remedial action

Following the fatalities, Puddock Road was identified as a priority for remedial action and
funding prioritised as part of the Road Safety Programme agreed by the Highways and
Transport Committee on 12 July 2022.

Due to the nature of this road the initial consideration was to review the use of a Vehicle
Restraint System (VRS, or Barriers). Having carefully considered this option with expert
technical advice, the project board made a recommendation to the Council’s Highways
and Transport Committee that alternative measures be implemented. The VRS was not
considered suitable due to the ground conditions, which may not be capable of
withstanding an impact and the barrier may simply collapse. A rafting barrier solution that
has been used by National Highways was also the considered, however the cost and
complexity of such a system was prohibitively expensive, not only to install but also to
maintain, and again with no guarantees of structural rigidity being retained over time.

The investigation of these options took some time and informed the resolution to pursue
the changes to speed limits noted above. The outcome of the investigations into various
options was reported to the Highways and Transport Committee of the County Council
on 5 March 2024, whereby members approved the recommendations for a series of
measures including the speed reduction, access restriction and works to improve the
edge of carriageway, as detailed further below.

Highway Degradation

The composition of Puddock Road presents the County Council with many challenges,
not least of which is the sub soil that the road is built on. Repairs that have been
completed do not last, and with the continued movement of the sub soil it is proving
difficult to find a long-lasting solution. This is why the Council instigated the enhanced
maintenance checks on Puddock Road. A weight restriction on the road was considered
but is not being progressed at this time due to the access requirements for farm vehicles.
The trial sections to treat rutting in the verge will be commencing in early 2025 will
hopefully give us some longer-term solutions to the soil erosion issues.

Local Safety Group

The Fenland Road Safety Campaign (Charlottes Way) have long been advocates of
safer roads and road environments in Fenland. The Council’s Road Safety Manager is in
regular contact with their chair EE on matters of concern to them.

Adrgd Cambridgeshire
 & ACA County Council

Puddock Road Project Board

The County Council's Puddock Road Project Board meets monthly to ensure that all
planned works remain on target, and that any issues that arise are addressed to avoid,
where possible, any unnecessary delays. The timeframes for the interventions noted
above are set out below:

Traffic regulation order for the 30mph stretch was advertised on 13 December 2023 and
ended on 15 January 2024 without objection.

Traffic regulation order for the 40mph buffer zone was advertised on 22 April 2024 and
ended on 16 May 2024 without objection.

Core samples along the carriageway and verge were taken in July 2024 and analysis is
now complete to establish next steps to deal with soil affected roadsides and roadway —
report received in September 2024.

Introduction of the 30mph speed limit (with 40mph buffers Zones) by the end of
November 2024 through signing and lining.

A traffic flow survey will be conducted in early November 2024.

Informal engagement will be undertaken on the closure or restricted access for Puddock
Road after the completion of the traffic flow survey. A formal application for a Traffic
Regulation Order will be made and subject to a statutory consultation.

Subject to approval of the TRO and following the implementation of the restricted
access, further monitoring will be put in place to check compliance with the traffic order.
Should action be necessary to enforce the order then the County Council will review the
options available.

Verge re-instatement trials will commence in early 2025.
Summary

The County Council has undertaken a considered and detailed review of potential
measures to be taken on Puddock Road and, by taking the above action, it will make
Puddock Road safer for all users, with appropriate systems in place to manage risk. The
County Council will continue to monitor the Puddock Road going forward.

Should you require any further information in response to this matter, please do not
hesitate to contact me.

Yours sincerel

Chief Executive

Adrgd Cambridgeshire
 & ACA County Council

Mr David Heming 
Senior Coroner for Cambridgeshire and Peterborough 
Lawrence Court 
Princes Street 
Huntingdon 
PE29 3PA 

From the Parliamentary   
Under Secretary of State  

Great Minster House  
33 Horseferry Road  
London  
SW1P 4DR  

Tel: 
E-Mail: 

Website: www.gov.uk/dft  

19 September 2024 

Dear Senior Coroner David Heming,  

RESPONSE TO REGULATION 28 REPORT TO PREVENT FUTURE 
DEATHS 

Thank you for your report of 26 July 2024 made under Regulation 28 of the 
Coroners (Investigations) Regulations 2013, following the inquest you 
conducted into the deaths of Jennifer and Marion Bunyan and of Jennifer’s 
unborn daughter Erin Marion Chatten who sadly died in utero during the 
accident. I am replying as the Minister responsible for road safety. 

I would like to take this opportunity to express my sincere condolences to the 
family of Jennifer, Erin and Marion Bunyan and to acknowledge the tragic 
nature of this incident.  

I want to assure you that I am determined that we learn from tragedies like 
this and that we take action to reduce those killed and injured on our roads. 
Delivering enduring improvements in road and vehicle safety is a key priority, 
which is why we have already announced the development of a new Road 
Safety Strategy – the first in over a decade. 

The Government takes road safety with the utmost seriousness, and we are 
committed to maintaining our roads as some of the safest in the world. 
Despite that record there is always room for improvement, so I have carefully 
considered the factors highlighted in your report, which are listed below: 

 
 
 
 
  
  
  
  
  
  
  
  
  
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 A. CLUSTER SITES  

Councils have a number of roads that feature on a cluster site analysis. By 
their nature, these will carry an obvious and serious risk of death or significant 
injury. Funding pressures in recent years have delayed prompt action in risk 
reduction at these sites. The coroner’s report raises a question over whether 
there should be a central government fund as a special measure to release 
capital for such sites as this would lead to enhanced risk reduction repairs 
being deployed more quickly.  

B. GPS  

On the facts of this investigation, this road had seen a number of fatalities 
which would not be known to those unfamiliar with the area (as here). It 
raises a question of whether there could be collaboration with software  
companies to flag roads on satellite navigation programming for providing 
verbal/visual prompts that a particular road carries high risk as an accident 
site. 

The below response sets out DfT’s current position regarding these raised 
concerns. 

Cluster sites: 

The Department allocates highways maintenance capital funding to local 
highways authorities so they can most effectively invest in maintaining and 
improving their respective network, based upon their local knowledge, 
circumstances, and priorities.   

It is up to each highway authority to determine how best to spend this 
funding, in order to fulfil their statutory duty under Section 41 of the Highways 
Act 1980 to maintain the highways. 

DfT strongly advocates a risk-based whole lifecycle management approach to 
local authority highways maintenance programmes. This approach considers 
all parts of the highway network, such as bridges, cycleways, and lighting 
columns. 

DfT does not intend to take any action on enforcing the use of cluster site 
analysis or the establishment of a central fund, as that is a matter for the 
relevant local authority.  

 
 
 
 
 
 
 
 
 
 GPS: 

Neither the Department for Transport nor individual local authorities have any 
direct power over the routing guidance offered by satellite navigation devices. 

It is the responsibility of satellite navigation operators to ensure the 
information they provide on their platforms is accurate and up to date. 
Drivers, should they choose to, can usually provide feedback and suggested 
corrections via satellite navigation operators’ websites.  

Road signage should always take precedence, and drivers should regard 
information provided by satellite navigation as only being advisory. Drivers 
should be familiar with the rules of the Highway Code in order to keep their 
journeys as safe as possible for the route they choose.   

Thank you again for taking the time to raise these important points of concern 
with me and I hope that you find our explanations helpful. 

Best wishes,  

MINISTER FOR THE FUTURE OF ROADS