London Assembly enquiry into cycling and cycling safety

If you are interested in making your submission to this, look here. Ours is below here:

INTRODUCTION

The Road Danger Reduction Forum (RDRF) welcomes the opportunity to comment on this subject to the Transport Committee.  Supporting more and safer cycling is a key element of creating a sustainable transport system with “safe roads for all”. The Road Danger Reduction Forum has had our Road Danger Reduction Charter signed in the past by LBs Camden, Ealing and Lambeth, with LB Lambeth boasting the UK’s first Road Danger Reduction Officer – we therefore have a special interest in London.

Furthermore, our Chair and another committee member work for a London borough, with another Committee member being Cllr. Nigel Haselden (LB Lambeth).

Our Chair, Dr. Robert Davis, has worked as a Transport Planner in local government in London for 24 years with a special  focus on promoting and supporting cycling. He assisted in setting up the working party on Cycling and HGVs run by the Department for Transport in the early1990s, the preparation of the London Cycle Network in the late 1990s, and has worked on the Cycle Safety Working Group (which carries out the work of the Mayor of London’s Cycle Safety Action Plan) as the representative of the London Boroughs Cycling Officers Group, including leading on its Infrastructure Sub-Group.

A separate submission will be sent to you about the failures of the Cycle Safety Working Group.
More about the Road Danger Reduction Forum can be found on www.rdrf.org.uk

EXECUTIVE SUMMARY OF RECOMMENDATIONS.

A. Increasing the amount of cycling in accordance with the Mayor’s Transport Strategy targets will lead to a reduction in the chances of cyclists being killed or injured. There should be a renewed push for increasing the amount of cycling, which at present is not increasing in line with the Mayor’s target.

B. Danger should be represented as:

(a) KSI figures for cyclist casualties should be presented as KSIs per journey or distance travelled by cyclists, generally known as “Rate-based” measurement.

(b) Objective indicators of danger such as CSNA grading.

(c) Indicators related to cyclists’ perception of certain locations.

(d) In terms of danger to other road users

(e) TfL’s draft Road Safety Action Plan should be amended accordingly to be based on proper “Rate – based” measurements.

C. A sum of approximately £100 million, or 2%of the TfL net annual budget, should be allocated out of the TfL/GLA budgets to support cycle specific projects each
year (apart from the Barclays Bike Hire scheme, Cycle Super Highways, Biking Boroughs  or “Cycle tracks in the sky”).

D. Reduction of motor vehicle capacity should be considered as a viable option in designing or re-designing junctions on borough as well as TLRN roads.

E. TfL/GLA should support campaigns by bodies such as RoadPeace to make those responsible for endangering others properly and fully accountable. Part of this process requires a very significant increase in policing which should be made available from the TfL cycle-specific budget.

F. Boroughs should  have to be assessed by an independent commissioner and cycling stakeholders to see to what extent they are genuinely in support of cycling, as a precondition for general funding with restrictions applied for those with inadequate programmes. This will include:

(i) Programmes like LB Ealing’s Direct Support for Cycling programme

(ii) Appropriate infrastructure throughout the Borough
(iii) Support for sustainable transport policy

(iv) Appropriate staffing throughout the Borough

(v) Safer drivers programmes

(vi) A cycling (including cycling safety) strategy

(vii)           Re-allocation of TfL LIP funding away from anti-cycling Boroughs

G. (i) Cycling should not be seen as more hazardous than it is.

(ii) Cycling should not be seen as “the problem” in discussions about cycling safety.

(iii) Safety interventions should have a firm evidence base.

(iv)Cycling should be seen as an integral part of transport policy.

H. The problem of cyclist’s collisions with lorries should be dealt with principally through:

(i) Seeing the problem as primarily one of danger from lorries towards cyclists and also pedestrians.

(ii) Requiring future and retro-designed features on lorries including black-box systems, automatic braking systems and ways of reducing the gap between lorry and the road surface as  a way of preventing cyclists and pedestrians from being crushed in this gap.

(iii) Prioritising training of drivers – along with other professional drivers – above that of cyclists.

(iv) Emphasising that this problem area, while implicated in half of the deaths of the cyclists killed on London’s roads, is only a small part of the problem of cyclists’
safety in London – the vast majority of the vehicles involved in collisions with cyclists leading to serious or slight injury are NOT lorries.

(v) Enforcing road traffic law where lorry drivers infringe regulations and the law.

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BASIC ISSUES

A. Safety in Numbers (SiN), otherwise known as “Critical Mass”.

The evidence shows that road users respond to changes around them and in perceived risk or hazard. For example, the number of cyclists killed in collisions with HGVs in London has stayed roughly the same over the last dozen years or so, despite a near threefold increase in the amount of cycling in the areas most affected (inner and inner north-east London) and a significant increase in road freight traffic.

We do not think that this can just be attributed mainly to awareness and training campaigns for HGV drivers and still less the far greater numbers of cyclists (although such initiatives can
be beneficial). The principal explanation is the increased presence of cyclists affecting the perception of lorry drivers.  We also think that this is a principal explanation for
the reduction in cyclist KSIs per journey made by bicycle since 2000.

This means that increasing the numbers of  cyclists is not just necessary for a variety of social, health and environmental reasons, but for the safety of existing and future cyclists. London is NOT on track to meet the Mayor’s target of an extra million daily cycling journeys per day by 2026, or some 80,000 extra cycling daily trips per year.

This does NOT mean that increasing the numbers of cyclists is enough for cyclists’ safety: far from it. There also need to be real commitment towards reducing anger from motorised road users to cyclists (and other road users), whether through engineering the highway or motor vehicles and enforcing the law with appropriate responses by Coroners, magistrates and Crown courts.

Safety in Numbers is most likely to work with a noticeable base level of cycling to start off with, and with reduced speeds.

Therefore:
Increasing the amount of cycling in accordance with the Mayor’s Transport Strategy targets will lead to a reduction in the chances of cyclists being killed or injured. There should be a renewed push for increasing the amount of cycling, which at present is not increasing in line with the Mayor’s target.

B. Measuring danger.

The only way that KSI figures for cyclist casualties should be presented is as KSIs per journey or distance travelled by cyclists, generally known as the “rate-based” measurement. In other words, if cycling numbers are doubled in accordance with  the MTS target, then even a desirable 50% cut in KSIs per distance travelled will involve more or less the same number of overall cyclist KSIs –we would see this as a significant step forward.

There are some locations, such as busy gyratory systems with multi-lane motor traffic which have to be traversed by cyclists which are excessively hazardous to cyclists irrespective of KSI rates.
These can be objectively identified in terms of features such as numbers of lanes to be traversed, and identified by programmes like the Cycle Skills Network Audit run by Transport Initiatives Ltd., which grades roads according to Bikeability level skills required at each location. In addition surveys considering how actual or potential cyclists see certain locations as barriers should be considered. These kinds of measure should also be used.

It is a matter of deep concern that TfL’s draft Road Safety Action Plan, currently out for consultation, does not include appropriate rate-based measures, such as KSIs per journey or
distance travelled by cyclists, generally known as the “rate-based” measurement.

Insofar as KSI figures are used, we believe there is a significant moral difference between those cases where cyclists have hurt themselves through their carelessness and where they are hurt or killed by careless, reckless, rule or law breaking behaviour by others. This is particularly relevant for the families of those hurt or killed and transport practitioners need to recognise this.

Therefore: Danger should be represented as:

(i) KSI figures for cyclist casualties should be presented as KSIs per journey or distance travelled by cyclists, generally known as “rate-based” measurement.

(ii) Objective indicators of danger such as CSNA grading.

(iii) Indicators related to cyclists’ perception of levels of danger at certain locations.

(iv) In terms of danger to other road users

(v) TfL’s draft Road Safety Action Plan should be amended accordingly to be based on proper “rate – based” measurements.

C. Discrimination against cycling.

We believe cycling as a mode of transport is treated inequitably with respect to other forms of transport, principally in terms of resources devoted to supporting it and the danger to which its users are presented. This is backed up a frequently abusive and victim-blaming culture which spreads through public services and needs to be combated. Specifically:

(a) Resources.
Comparison with funding to all the forms of public transport shows that cyclists do not receive funding for their mode of transport, with the exception of limited schemes such as the Cycle Hire and Cycle Super Highways. Without considering the massive external costs of motoring, public transport users are supported with subsidies for modes of transport which are more polluting and unhealthy. It is reasonable to expect that resources of approximately 1 – 2% of the TfL budget should be allocated to supporting cycling. This is both necessary for cycling numbers and safety to increase and in terms of basic fairness.

Recipients of funding should be assessed by a group of stakeholders rather than just TfL. Insofar as Boroughs are to receive funding, this can be achieved by allocating a status similar to that of “Biking Boroughs” to all London Boroughs that have a proven record of genuine commitment towards cycling – “New Biking Boroughs”. We believe LB Ealing requires an extra £2 million on average per annum over the next 15 years to achieve our objectives.

Any cycle-specific infrastructure schemes should not divert attention from features of the highway network that are hazardous to cycling. Much of any capital spend should be on removing gyratory systems, or providing good quality alternatives to them, or high quality cycle-specific features at them. Persisting with cycle-unfriendly infrastructure should disqualify potential “New Biking Boroughs” from such status. As dissuading or endangering cyclists conflicts with the objectives of MTS, TfL could penalise such Boroughs through reduced LIP funding.

Therefore:
A sum of approximately £100 million, or 2% of the TfL net annual budget, should be allocated out of the TfL/GLA budgets to support cycle specific projects each year (apart from the Barclays Bike Hire scheme, Cycle Super Highways,  the original “Biking boroughs” or “Cycle tracks in the sky”. )

(b)
Road space. It may be necessary in supporting cycling, particularly cycling safety, to have specific amounts of road space allocated towards cycling, and this may reduce motor vehicular capacity in the highway network. If this space is required it should be made available. At present conforming with Transport for London’s Network Assurance programme tends to impede this.

Therefore:
Reduction of motor vehicle capacity should be considered as a viable option in designing or re-designing junctions on borough as well as TLRN roads.

(c)
Policing and the law.
Locations where there are specific problems for cyclists as described in the list principal collision types listed in the Cycle Safety Action Plans should be the focus of traffic policing. A sum of £10 million per annum could be allocated to the Cycle Task Force to achieve a minimal level of policing which should concentrate on behaviour that endangers others.

In addition there should be general massive increases in the levels of traffic policing. The problems involved are described in documents such as “London’s Lawless Roads” by Jenny Jones MLA.  Regrettably it appears that schemes such as “Roadsafe” are at present inadequate – only 2% of complaints result in a prosecution being made – and may bring the law into disrepute.

Furthermore, there is substantial concern at the lenience of sentencing for those who kill, hurt or endanger others on the road, as well as inappropriate comments by Coroners. We note that the Mayor has agreed to write to the relevant authorities with regard to lenient sentencing.

Therefore:
TfL/GLA should support campaigns by bodies such as RoadPeace to make those responsible for endangering others properly and fully accountable. Part of this process requires a very significant increase in policing which should be made available from the TfL cycle-specific budget. Such measures are likely to act as disincentives to dangerous driving/increase compliance with the law.

ACTION WITHIN BOROUGHS

Based on the above principles there should be funding from TfL/GLA allocated to:

1. Direct Support for Cycling schemes.
Funding should be allocated to projects like LB  Ealing’s “Direct Support for Cycling” (DSC) programme this includes the following elements:

• Confidence training: High quality on-road training to National Standards can be supportive and empowering. Such training is not in “survival skills”, but based on enabling
  and encouraging a modal shifty to cycling. All schemes in London should be vetted with only those genuinely committed towards this should be funded by LIP funding. Many schemes are unfortunately not tuned in to this objective. This includes families, adults and can involve “Bike Buddy” commuter escorts.
• Dr. Bike cycle checks: As with the 100+ annual checks carried out in LB Ealing, these need to be done as empowering exercises which induct cyclists into other elements of the DSC
  programme.
• Safe and convenient home cycle parking: as carried out in LB Ealing on estates and private residences.
• Subsidy for accessories such as tyres, wet weather clothing etc. to cope with wet and cold weather. “The Keep Riding” scheme in LB Ealing offers vouchers for people doing cycle training in the winter.
• Assistance with buying low-cost bicycles. Support for bike recycling projects, such as that in LB Waltham Forest.

2. Appropriate on and off-highway infrastructure

There is substantial debate and discussion about the best highway (and off-road) layouts for cycle use. The aim should be an environment, including areas where appropriate speeds are enforced through use of speed cameras as well as specific highway infrastructure, which throughout Borough should not be hostile to cycling and in accordance with the design principles
of TfL’s London Cycle Design Standards. It must be emphasised that this should be a requirement on all Borough roads which cyclists need to use, and not just to specifically designated “cycle routes”.

3. Support for sustainable transport policy

Although lip service is paid to sustainability, Councils generally do not make commitments towards developments that discourage motor vehicle use. There are a variety of ways in which Councils can restrict private motor vehicle use (minimal parking standards at housing and retail developments).

4. Appropriate staffing levels in Boroughs.

Those Boroughs supporting cycling (as in “New Biking boroughs”) should have appropriately designated staff with responsibility for cycling who are in a position to influence policy and its implementation, which does not occur in many Boroughs.

5. Safer drivers programmes.

All drivers for Councils or within the Council “families” should have the equivalent of CPC cyclist awareness (including on-bike) training. However, in addition, the annual £100 million cycling fund can support installation of high level safety technology such as infra-red and automatic braking systems.

6. Cycling (including cycling safety) strategy.

In order to meet the Mayor’s target for cycling, each Borough should have a strategy to specify how it intends to meet these requirements. At present it is not necessary for a Borough to give a properly thought through strategy as to how this will be achieved. This will be a necessary requirement for assessment of each Borough (see 7. Below)

7. Re-allocation of TfL LIP funding away from anti-cycling Boroughs

Legislation does not allow TfL/GLA to dictate what Boroughs spend resources on. Nevertheless, LIP funding is allocated on the basis of support for the Mayor’s Transport Strategy which has a commitment towards a significant increase in the modal share of cycling. It is pointless to fund some projects which may give some support towards cycling while funding others which have a negative effect on cycling. It is quite feasible to only allocate funding to Boroughs which are committed towards cycling and sustainable transport as indicated in this section Action within Boroughs 1 – 5 above, or at least restrict the amount of funding from TfL /GLA to Boroughs which are not.

Therefore: Boroughs should  have to be assessed by an independent commissioner and cycling stakeholders to see to what extent they are genuinely in support of cycling, as a precondition for general funding with restrictions applied for those with inadequate programmes. This will include:

1. Programmes like LB Ealing’s Direct Support for Cycling programme.

2. Appropriate infrastructure throughout the Borough .

3. Support for sustainable transport policy.

4. Appropri ate staffing throughout the Borough .

5. Safer drivers programmes.

6. A cycling (including cycling safety) strategy .

7. Re-allocation of TfL LIP funding away from anti-cycling Boroughs.

CULTURAL SHIFT

Any list of measures to be taken is useless outside of a necessary cultural change. Essentially, cycling should be seen as a normal form of everyday transport. Luckily the significant spontaneous increase in cycling as everyday transport, carried out by normal people in normal clothes, has already taken off in places like LB Hackney. However, in order to be progressed that officers in the Boroughs reverse many of the attitudes and beliefs that have been held by transport practitioners in the past.

Therefore:

1.  Cycling should not be seen as more hazardous than it is. This does not necessarily, and should not, conflict with rigorous attempts to reduce danger to cyclists.

2. Cycling should not be seen as “the problem” in discussions about cycling safety. It should be remembered that cyclists have been legitimate road users prior to the advent of mass motor vehicle use.

3. Safety interventions should have a firm evidence base. Many current initiatives, such as on hi-viz or cycle helmet wearing lack this.

4. Cycling should be seen as an integral part of transport policy.

HOW TO ADDRESS DANGER TO CYCLISTS – THE CASE OF LORRIES

This focus in current discussion of cycle safety is of great relevance to RDRF following our role in assisting in the first major focus on HGVs and Cyclists in the early 1990s. We are therefore in
great sympathy with the impetus behind The Times campaign for cyclist safety, generated by the serious injury suffered by one of their staff in collision with an HGV. London Boroughs should aim to provide:

1. Cyclist awareness training for lorry drivers in the Council “family” as part of the CPC training required by lorry drivers. We encourage the on-bicycle training in the “Safe Urban Driving” (with on-bike training) CPC module Extensive on-road cycle training that will include awareness of the dangers posed by cycling in proximity to the nearside of lorries.
2. Guidance on good quality junction design, particularly regarding Advanced Stop Lines, both internally in the Council and to practitioners elsewhere. However, we must note that with regard to these initiatives:
3. Despite the legal requirements for CPC certification and efforts at recruiting drivers for training, boroughs are having limited success in this area. Even if they were to be successful with
   the best training possible, training is always limited in its effectiveness in thoroughly changing driver behaviour appropriately.
4. Even with a successful programme of effective training to national standards, only a proportion of cyclists can be reached. Even with this training, not all those who have achieved it can be relied upon to always follow the knowledge imparted – after all, most drivers do not always follow the requirements which they displayed when passing their driving test.
5. While I and another Borough officer have assisted in providing guidelines for practitioners through the Cycle Safety Working group (Infrastructure Sub-Group), there is no requirement for practitioners in boroughs to follow this advice. Furthermore, the most effective highway engineering is likely to require significant re-allocation of road space with capacity implications.

Therefore our efforts are extremely limited in terms of significant change of reducing the chances of these incidents occurring. We therefore suggest that:

1. As well as cyclists, a similar number of pedestrians are killed in incidents involving lorries. Any measures which reduce the potential for lorry drivers to not hit cyclists or pedestrians by targeting the lorry and its driver and operator will have greater potential than measures which target cyclists on the same level as lorry drivers.
2. There are far fewer lorry drivers than cyclists – about 50,000 likely to drive and 1 million to cycle, in London. On a given day there are some 30,000 lorries on the streets of London, and 300,000 cyclists. It makes much more sense to focus far more on the lorry drivers.
3. Both the above points apply apart from any consideration of the “danger to whom?” question – the importance of considering endangering others as more important than being endangered.
4. The normal approach of safety engineers is to engineer out the possibilities of danger: in this case the issue is vehicles introduced into the road environment where there is the possibility of crushing injuries involving a vehicle with excessive space between its body and the tarmac.
5. Such devices should be considered for engineering or re-engineering the lorry, as well as electronic devices for recognising pedestrians or cyclists. These in turn should be associated with “black box” type technology to monitor driver behaviour / vehicle movement for insurance and/or criminal law enforcement. They can also be considered in association with automatic braking systems activated by such devices – all the above have been discussed for some time and exist either in fact, prototype, or could be introduced shortly.
6. At present, the evidence is that most lorries are likely to fail at least some of the legal safety requirements their operators have. There is a very strong case for significant additional police enforcement of regulations governing their use.

All the above suggests that this “headline case” of cyclist safety – collisions involving the two largest category of goods vehicle – stretches way beyond the kinds of measures at present being
employed. Further measures as suggested should be implemented as soon as possible, both to stop potential cyclists being deterred by the threat of danger from lorries and to reduce this danger effectively.

However, it is absolutely crucial to mention that – although this is the central focus for deaths of cyclists in London – the vast majority of Killed and Seriously Injured cyclists, not to mention Slight Injuries of cyclists, or danger experienced by cyclists do NOT involve lorries. The most important vehicle user type to be considered is the ordinary private
motorist. The extent of the problems of cyclist safety and supporting cycling are illuminated by making us aware of how much more we have to achieve in this area, while simultaneously avoiding any possibility of it diverting attention away from the main cyclist safety issue, which involves motor traffic in general.

Therefore: The problem of cyclist’s collisions with lorries should be dealt with primarily through:

1. Seeing the problem as primarily one of danger from lorries towards cyclists and also pedestrians.

2. Requiring future and retro-designed features on lorries including black-box systems, automatic braking systems and ways of reducing the gap between lorry and the road surface as a way of preventing cyclists and pedestrians from being crushed in this gap.

3. Prioritising training of drivers – along with other professional drivers – above that of cyclists.

4. Emphasising that this problem area, while implicated in half of the deaths of the cyclists killed on London’s roads, is only a small part of the problem of cyclists’ safety in London – the vast majority of the vehicles involved in collisions with cyclists leading to serious or slight injury are NOT lorries.

5. Enforcing road traffic law where lorry drivers infringe regulations and the law.

Dr. Robert Davis 19^th August 2012