CWIS (Cycling and Walking Investment Strategy) Safety Review response by CEoGB

This is our response to the Government's "Cycling And Walking Investment Strategy Safety Review" (see consultation here).

Question 1

Do you have any suggestions on the way in which the current approach to development and maintenance of road signs and infrastructure impacts the safety of cyclists and other vulnerable road users?

How could it be improved?

England needs a clear and consistent set of standards and rules applied to the entire road network, including roads controlled by local authorities. All roads and streets should be brought into line with those standards as part of a long-term plan, with local authorities penalised if they fail to comply. New roads should comply with these standards; existing roads and streets should be brought into line with them during the regular cycle of maintenance, roadworks and improvement.

This is the Dutch ‘Sustainable Safety’ approach, which should be adopted in England as a matter of urgency.

Overarching principles

Sustainable Safety is a preventive approach to road safety, ensuring that collisions do not occur in the first place, and mitigating their seriousness if they do occur. It takes account of human behaviour and fallibility. It has five central principles.

1) Monofunctionality

Roads and streets must have a single function - either an access road, a distributor road, or a through road. They must not have a mixed function.

Local authorities should be compelled to classify their road network according to these three road types, with long-term plans in place to shift - via design - roads and streets that currently have a mixed function into a single function.

Perhaps the most pressing examples are those streets that currently have large amounts of human-scale activity - shopping, leisure activities, work, day-to-day life - that also function as through-roads for motor traffic. That day-to-day activity should be separated from that motor traffic, primarily by removing through-traffic from these streets. Through-traffic should be confined to those roads and streets that are most appropriate for this function, and designed accordingly.

2) Homogeneity

The mass, speed and direction of road users should be equalised as much as is possible.

This means - in particular - that cycling should not be mixed with fast flowing motor traffic, or with large volumes of motor traffic, or with heavy vehicles.

In the Netherlands, cycling is not mixed with motor traffic travelling at above 40mph. Roads with speed limits above 40mph must have separate provision for cycling. 40mph should be the default speed limit for all unclassified roads in rural areas.

Likewise it should be unacceptable to mix cycling with high-mass vehicles, or dense flows of vehicles. Where this is unavoidable, the speed of these vehicles should be reduced as much as possible. 20mph limits should be the default speed limit in urban areas, with higher limits for distributor roads, where cycling should be physically separated from motor traffic.

3) Predictability

Road design should be instantly recognisable. The expected behaviour of users should flow naturally from the design of road.

This should minimise the need for enforcement. Road users should spontaneously follow the rules, rather than being compelled to behave in a way that seems unnatural. It should also mean that the number of signs and instructions given to road users can be minimised. Signs should not be used to fix behaviour. Too many signs, and sign clutter, are an indication of poor road design that does not result in expected or desired behaviour.

In particular speed limits should correspond to the design of the road. 20mph limits should be matched with design features that mean that 20mph is a natural speed at which to travel. Access roads (see ‘Monofunctionality’, Point 1) should have 20mph limits built into them by design.

Predictability also means that road design should be clear and consistent, with continuity.

4) - Forgivingness

Road design should accommodate those mistakes and errors that all human beings will make. Mistakes and errors should not lead to death or serious injury.

Human beings should be separated from fast-moving traffic, and large vehicles. Junction design should allow people to anticipate the behaviour of others and to react accordingly. Training and education should not be seen as a substitute for basic failures to design safe road environments.

Design standards

Supporting this overall approach to road design and network planning should be a clear and comprehensive set of design standards for cycling and walking, based on proven best practice from both in the UK and in continental Europe, particularly the Netherlands and Denmark.

The proposed update of LTN 2/08 ‘Cycling Infrastructure Design’ is welcome, as this document is now very dated. There is a growing (but patchy, and limited) amount of high-quality cycling infrastructure across the UK, examples of which should be drawn together in one comprehensive document, making it easy for all local authorities to draw upon.

Standard junction designs, in particular, should feature in such a document, using the best British examples. Where examples of good design for certain types of junction do not yet exist, this should be an opportunity for the Department for Transport to take the lead. Roundabouts in particular are an area where high-quality design standards are necessary. Clear design templates for roundabouts with perimeter, annular cycleways, drawing on best Dutch practice, are especially needed, as this is almost entirely absent from all existing British design guidance and standards.

Continuity of cycleways across side roads, with priority should also be clarified, again with clear design templates.

While good progress on the separation of movements at signalised junctions has been made in a variety of British cities, the best examples again need to be brought together in one clear and comprehensive standard.

This can be supported by rule changes which can increase the flexibility and potential efficiency of junctions, while ensuring the safety of people cycling. In particular, ‘conflicting greens’ between cycle movements should be explicitly permitted, allowing ‘simultaneous green’ junctions, involving cycle traffic flowing across a junction from all arms, at the same time. British Cycling’s ‘Turning the Corner’ proposals should also be considered, allowing straight ahead movements of cycle traffic to have priority over turning motor traffic, albeit with careful consideration to the design of junctions allowing this conflict, and the traffic context.

LCWIPs are welcome. However the current bidding process - with some local authorities gaining support, and others missing out - should be replaced with a comprehensive roll-out to all local authorities, with support from central government, as required.

In summary, there is a now a well-established, long-existing evidence base of design that works to ensure the safety of people cycling and walking. We know what works. It is the government’s responsibility to start delivering it, and to ensure that local authorities deliver it too.

Question 2

Please set out any areas where you consider the laws or rules relating to road safety and their enforcement, with particular reference to cyclists and pedestrians, could be used to support the Government’s aim of improving cycling and walking safety whilst promoting more active travel.

As mentioned in the response to Question 1, there should be much more flexibility in the way our signalised junctions operate, permitting some types of signal conflict that are currently forbidden - in particular,

  • ‘simultaneous green’ junctions for cycling,

  • ‘Turning the Corner’ proposals that give priority to cycle and foot traffic progressing ahead, over traffic turning left on green,

  • Left-turn exemptions from red, for cycle traffic.

There should also be clear, explicit rules on pavement parking, and parking in cycleways. Parking on footways should be universally illegal, with no ambiguity.

Cycle lanes should also have an explicit ‘no parking’ rule - mandatory lanes should not need double yellows for enforcement. Local authorities (rather than the police) would then be able to enforce parking in these lanes.

Objective standards for traffic offences

In particular, there need to be objective and clear standards on what constitutes ‘dangerous’ or ‘careless’ driving, rather than a reference to what a ‘competent and careful’ driver might do, which is open to subjective interpretation.

Magistrates also need to enforce the existing rules. There should be no excuse for driving with 12 points - the points system is itself a warning system, designed to allow drivers to improve their standard of driving, before they exceed 12 points. Allowing drivers to exceed this limit provides no motivation for improving their standard of driving.

Autonomous vehicles

If the government is serious about promoting active travel, it should ensure that the safety, comfort and convenience of people walking and cycling is of the utmost priority in relation to any potential ‘autonomous vehicle’ legislation.

Presumed liability

Much of Europe uses the concept of ‘presumed liability’, which applies to civil cases and insurance claims. The more powerful party in a collision is presumed to be liable for financial damage, unless they can prove the incident was the result of circumstances beyond their control. This applies to both motor vehicle/cycle collisions, and to cycle/pedestrian collisions.

From the perspective of road justice, this would be an important addition to our legal system, although it must be stressed that such a law change should be presented clearly and precisely for what it is - a way of ensuring fairness in post-collision insurance claims, not as a means of changing driver behaviour or punishing motorists unfairly.

In general, as with our answer to Question 1, we believe that road design should be self-enforcing (e.g. with regard to speed limits, and priority). Adding more signage, more rules and more street clutter does not in of itself improve compliance with the law, and we cannot expect the police to be everywhere. Road design itself should achieve the desired behaviour from users.

Question 3

Do you have any suggestions for improving the way road users are trained, with specific consideration to protecting cyclists and pedestrians?

It should firstly be emphasised that training and education are not, and should not be, a substitute, or compensatory mechanism, for unsafe road design, or environments that pose significant danger.

However, there is a role for education and training to normalise walking and cycling as modes of transport. Existing ‘Bikeability’ training could be formalised into the school curriculum, and combined with a general traffic exam, as is the standard in the Netherlands.

Another option would be for all versions of the driving test to specifically include interactions with walking and cycling. This might take the form of virtual reality simulators showing a typical road, but could also involve prospective drivers having to cycle somewhere as part of their test.

Professional drivers should also have road user training, ensuring that they are familiar with the perspective and vulnerability of people walking and cycling. There is a wide range of opportunities to improve road user training, and many of these opportunities are already being taken up by more far-sighted operators.
Question 4

Do you have any suggestions on how we can improve road user education to help support more and safer walking and cycling?

Road users need to understand the impact of inattention, and driving while using a mobile phone (for example) needs to be as socially acceptable as driving having been drinking.

More generally, however, as with our previous answers, more and safer walking and cycling should be enabled entirely through the creation of safe and attractive environments. Education should not be used to compensate for the failings inherent in unclear, ambiguous or dangerous roads and streets.

Question 5

Do you have any suggestions on how Government policy on vehicles and equipment could improve safety of cyclists and pedestrians, whilst continuing to promote more walking and cycling?

Within urban areas, direct vision lorries should be the standard, with a clear schedule for banning non-compliant HGVs from built-up areas.

Serious consideration should be given to the use of existing technology to limit motor vehicles to posted speed limits

Rules for lights could be better - for instance, Germany has clear rules about dazzling.

The Highway Code (and the Government) need to stop showing people cycling in hi-viz clothing, and protective equipment: this shouldn’t be the norm for cycling.

Question 6

What can Government do to support better understanding and awareness of different types of road user in relation to cycle use in particular?

The government, and the Department for Transport in particular, have a repeated problem of talking about motorised road users as both the default and the only expected users of the road. For example, press releases and announcements from the DfT often talk of motorists rather than road users in general. The language used must reflect the fact that ‘road users’ will encompass a wide range of transport modes, with differing needs and requirements.

When it comes to discussing cycling, care should always be taken not to just talk of bicycles - there is a wide range of practical and useful forms of cycle which help the widest range to be able to cycle including tricycles, cargo cycles and more. Similarly, efforts to promote and grow active travel should always be mindful that the full spectrum of society should be able to be active or use infrastructure made for active travel including disabled people, pregnant mothers, families and pensioners.