Disgraceful: TfL’s “Towards a Road Safety Action Plan for London: 2020”

Transport for London is holding a consultation process about this document until 28th September 2012. Obviously we wouldn’t expect a break from traditional “road safety” ideology in such a
document, but this one is particularly bad. Our colleagues in the CTC, for example, have criticised it for victim blaming and not moving forward from the 1960s. And there is one absolutely disgraceful feature to it.

As the CTC say:  “Unfortunately, it doesn’t remotely reflect the very positive relationship which CTC, LCC and others have with TfL staff through their Cycle Safety Working Group “. What this may be referring to is something which has been repeated on various occasions by Transport for London at the CSWG (which is charged with progressing the Mayor of London’s “Cycle Safety Action Plan”.

This is the commitment towards a better measure of cyclists’ safety than that used traditionally in “road safety”, which is reflected in the kind of targets chosen.



This superior measure is generally referred to as the “rate-based target”. It means measuring the casualties among cyclists as a rate, or to be precise, as casualties per journey (or distance) travelled. (Another related alternative would be to measure the casualties per time travelled). At present casualties, if expressed as a rate at all, are per 100,000 of the population. As we have mentioned before, this can give precisely the wrong indication of the chances of cyclists being hurt or killed.

In other words, we are talking about giving a measure of exposure, so that the measure we employ reflects the experience of cyclists.

It is absolutely disgraceful that, despite making it clear that we would be moving to a proper “rate-based target”, TfL have not referred to it at all in the whole document.

This is in spite of persistent demands for them to do so from key partners RoadPeace, London Cycling Campaign, Borough Cycling Officers Group, and Living Streets , with no objections being made by anybody.

These alternative ways of measuring danger on the road is a key element of why the RDRF was brought into existence. We have been banging on about this since 1992 in pieces like this
and this .

For me it started in 1984 at a “road safety” conference where a Eurocrat informed us that there was “a problem with cyclist safety in Denmark” because, yes, there was a higher than Europe average number of cyclist casualties per 100,000 head of the population. Then there was the matter of pedestrian casualties being low at locations where there was so much danger for pedestrians that people would not walk there – and the “road safety” professionals had a “better road safety record” for pedestrians.

In fact we can go further.  Even KSIs per journey or time spent cycling would be inadequate as a measure. For us there is a qualitative, moral and political issue here: who kills /hurts/endangers whom? An elderly person riding an electrically-backed up bicycle too fast round a cornet (a current matter of concern in the Netherlands) becomes a different form of casualty from a cyclist
behaving carefully who is knocked down by a motorist breaking the appropriate rules and laws.

This kind of difference is not brought out in even the kind of metric we have favoured over that of the “road safety” industry. But there is no reason why it cannot.



Back to TfL, who haven’t even put forward the idea of a measure which would be the most basic and straightforward way of bringing the experience of the road user into the discussion, namely the simple rate-based target of casualties per journey (or distance, or time) travelled? Why has this contempt by TfL for its stakeholders – and for what many would simply regard  as common sense – been shown?



One suggestion is that it is too expensive for TfL and the Boroughs to actually measure the amount of cycling. But this is feeble. TfL already quote the indicators of cycling traffic that they do have in their Pedal Cycle Casualty Fact Sheets.

Obviously, it will be difficult to give a very accurate indicator of pedal cycle traffic – but then everybody knows that there are inaccuracies in casualty statistics anyway, not least with the amount of mis-reporting and under-reporting. It is also possible to give detailed analysis of key boroughs (one in outer London, one in inner London, for example) to get more detailed indicators, as TfL has already expressed an interest in doing. This is standard practice in statistical analysis. The quality of data is not as good as it could be, but then that could be solved by a minimal increase in resources to collate data.



It is admittedly far more difficult to assess the amount of walking. But we do not have to have the precise amounts of walking everywhere. Counts at designated locations could be made as an
indicator. There are already detailed counts of the amount of trips, or crossings, at specific locations where there has been a particular focus, such as Exhibition Road. It should at least be possible to measure the effects of interventions at a location receiving engineering treatment in terms of casualties per numbers of crossing journeys.

We will write some more about the failings of the “Road Safety Action Plan” in the next post. We reserve the whole of this one to something which stands out as being particularly, plainly, egregiously, wrong.