The most crucial aspect of an overarching plan such as the Road Safety Action Plan is its target and the way it is measured.
For ease and simplicity, local authorities and Government have historically adopted a target based solely on the number of people killed and seriously injured.
Intuitively, this seems to make sense: a target based on numbers killed or seriously injured tackles the public health problem of road injuries directly.
However, because cyclists and walkers, the children and elderly are relatively higher risk groups than drivers (or public transport users), authorities may focus on them directly. They may also be tempted to decrease levels of cycling or walking, or children and older people's independent mobility in their efforts to reduce the overall numbers of people killed or seriously injured and, as a result, achieve their target.
This creates an internal conflict and perverse incentives within a local authority: of course they want to increase cycling and walking, and get more children travelling actively to school etc. - but at the same time their target is to reduce overall casualties, and those sorts of activities are perceived to be more risky.
CTC is pleased that TfL have taken on some of our concerns about the need to distinguish between the risk - or perceived risk - of cycling, and simply counting numbers of people killed or injured on bikes.
"If we want a radical shift to cycling, we don't want policies to promote cycling to be undermined by concerns about absolute numbers of casualties increasing. We're therefore disappointed that TfL have retained an overall target to reduce absolute numbers, whilst at the same time proposing better indicators that measure risk. This is likely to lead to confusion in the future."
CTC Senior Campaigner
To solve this problem, CTC have consistently suggested through our 'Safety in Numbers'  campaign, that measurement of cycle (and walking) safety should be disconnected from the number of people injured, and instead look at the risk per mile, hour or trip made by that mode. This is a better indicator of actual safety and avoids the problem of perverse incentives.
CTC had suggested in its response to the consultation that indicators based on risk and/or the perception of safety, be used instead of absolute casualty reduction targets.
London's new plan - has it changed?
Although the Plan commits to investigate the distinction mentioned above, an absolute reduction target remains. This is problematic and potentially weakens the political commitment to achieving a 400% increase in cycle use by 2025. To achieve a 40% reduction in absolute numbers of killed or seriously injured road casualties - as suggested by the new indicators - would mean that the risk of cycling would need to reduce by 85%. This is virtually impossible.
TfL have managed to create a set of targets that are internally inconsistent. Either cycle use can increase by 400%, or casualties can reduce by 40%. Achieving both seems extremely unlikely.
However, better news is that TfL have committed to "develop innovative new approaches to monitor risk and road safety performance in London. This will be achieved by augmenting collision and casualty data with information on the journeys made, infrastructure data, and behavioural data to better understand and reduce levels of danger." (page 84) This goes some way to answering CTC's concerns, but is unlikely to solve the problem of a single, blunt target of reducing overall casualties.
A curate's egg
Overall, the Plan is certainly an improvement on its draft, which CTC criticised highly. More actions are focused on reducing danger at source, rather than targeting 'high risk' groups, like pedestrians and cyclists. There is also a welcome stronger commitment to 20 mph on borough, as well as Transport for London operated roads.
London's 'Cycle Safety Action Plan' will be refreshed next, setting out the detailed steps to be taken to improve cycle safety whilst improving conditions to maintain the growth in numbers of people cycling.
You can download CTC's response to the consultation from December 2012 below. A copy of the Plan itself is also available below.