London's draft Cycle Safety Plan and Design Guide: pretty darn good - by UK standards!
Although CTC has highlighted some important weaknesses, we have given both documents an overall thumbs-up, recognising that the draft LCDS in particular already represents a huge step forward for cycle planning in the UK.
London Cycling Design Standards
The LCDS document is a vast tome - over 350 pages - and has clearly been a labour of love for its lead authors, Brian Deegan and Paul Lavelle. However, if the prospect scares you, rest assured that it starts with concise statement of 20 guiding principles or 'Requirements', which every councillor, traffic planner and engineer in the country should read (even though we've suggested tweaks and additions to some of them!)
LCDS: the good news
The first of the guiding principles sets the tone in a really positive way:
There are some really important details which the draft LCDS gets absolutely right. One is its unequivocal rejection of the much-despised 'Cyclists Dismount' sign:
"The ‘Cyclists dismount’ sign is the infallible mark of a faulty cycle route ... If a route cannot be done without these signs, it should not be done at all." (p11)
... and ...
"A cycling route should never disappear abruptly. ‘End’ signing and ‘Cyclists Dismount’ signs are unacceptable because they show that consideration for cyclists has simply ended." (p250).
If only the Department for Transport's woolly "Cycle infrastructure design" guidance (Local Transport Note LTN 2/08) was as uncompromising!
The document is also very good on the importance of providing cyclists with physical protection from other traffic on roads with higher traffic volumes and/or speeds, whilst strenuously avoiding conflict between pedestrians and cyclists:
Another positive feature is the requirement that "All designers must experience the roads on a bicycle". I suspect that a lot of London's traffic planners and engineers will be attending cycle training courses in the coming months. I also hope it spreads rapidly throughout the UK!
The authors have also thought carefully about how to increase cyclists' priority and safety at junctions. At several points though, they have to acknowledge that some continental best-practise solutions haven't yet been fully legalised in the UK. CTC has therefore urged that paper versions of the document should be issued in ring-binder form, so that it can be easily updated in the light of future regulatory changes, and the resulting experience and evidence from putting these ideas into practice in the UK context.
Level of service assessment
Perhaps the most important breakthrough is the proposed 'Cycling Level of Service' (CLoS) process. This allows the cycle-friendliness of existing roads and/or proposed improvements to be assessed in terms of the five Dutch cycle planning criteria of Safety, Directness, Comfort, Coherence and Attractiveness - plus a sixth one added by the authors: Adaptability.
It remains to be seen how CLoS will work in practice, alongside similar processes for assessing junctions and the accessibility and density of local cycle networks. The Welsh Government's Design Guidance, also subject to recent consultation following the passing of the Active Travel (Wales) Act, contains a simplified version, which may work better for non-London authorities with fewer resources.
Either way though, the CLoS process could be a really useful tool for helping councils and campaigners alike to distinguish between marginal improvements and the transformatory 'Space for Cycling' schemes that we really need if Britain is to become a place where people of all ages and abilities can feel safe and confident about getting around by cycle for everyday journeys.
LCDS: the weaknesses
CTC's LCDS consultation response identifies a number of areas where we think the document could be improved. However, there are three that I'd particularly highlight:
1. LCDS identifies different types of cycling provision that might be appropriate on different types of streets, depending on their importance both for 'movement' (for traffic to pass through) and as 'places' (for people to live, shop, play etc.). What it doesn't say is that it is undesirable to have High Streets etc. where these two functions are acutely in conflict, particularly where there is limited space. Separate cycle provision is fine on busy main roads where the movement function dominates. However, where there are also homes, shops and people - particularly where space is limited - it is better to plan for lower traffic volumes and speeds.
2. Specifically, LCDS needs to be much more proactive about urging that 20 mph should be the norm for the majority of the road network, with 30 mph or higher limits applying only on the relatively limited network of major through routes.
3. LCDS is weak on road maintenance. As well as defining criteria for inspection frequencies, standards for reactive maintenance, sweeping and winter maintenance, the document should also look to maximise the opportunities to improve the cycle-friendliness of roads and junctions whenever planned resurfacing is undertaken. New York's Department of Transport has introduced some really effective segregated cycle schemes at marginal extra cost, simply by linking them to planned maintenance works. We urge TfL to do likewise.
Cycle safety plan
CTC's response to CSAP2 is also largely positive - the consultation draft is a vast improvement on earlier drafts we saw at pre-consultation stage.
In terms of areas for improvement though, we have highlighted the following concerns:
Conflicting targets: Whilst we are keen to support ambitious targets, CTC remains concerned that TfL's aims both to substantially boost cycle use and to reduce casualties by 40% may be overly ambitious - it would require cycle safety in London to transform from being 2-3 times more risky per mile than in Dutch cities, to about 8 times safer! (We would obviously be delighted if this happened,though!)
However, if push comes to shove, it is much more important to boost cycle use than to be deterred from doing so for fear of missing a laudable but wholly unachievable road safety target. TfL should measure cycle safety in terms of the casualty risk per mile or per trip, rather than simple casualty numbers (and the nonsensical table which makes London appear safer than the Netherlands by comparing casualties per head of population should definitely be removed!). If cycle casualties go up slightly but cycle use is rising steeply, this still represents a reduction in the risk of cycling. Cycle safety needs to be measured in a way that make this clear.
Policing: CTC strongly supports increased priority for roads policing - indeed this is a key demand of CTC's Road Justice campaign. However, we are concerned that the police responded to last November's awful spate of cyclist fatalities not only with a welcome crack-down on bad driving but also by targeting cyclists for utterly trivial Highway Code breaches, including stopping them for not wearing helmets or issuing fines for straying marginally from an unclearly marked cycle track. TfL needs to work with the Met Police to ensure that they too take an evidence-led approach to improving cyclists' safety, so that police resources are prioritised on tackling the real sources of danger - e.g. irresponsible drivers and lorry operators.
We have reiterated our points about the need for a more proactive approach to 20 mph limits and road maintenance.
* * *
I trust TfL will take on board CTC's comments, and those of the London Cycling Campaign, Sustrans, the Cycling Embassy of Great Britain and other groups who are supportive of cycling. Above all, though, I very much look forward to seeing how the Level of Assessment process works in practice.