What’s wrong with Transport for London’s Cycle Safety Action Plan (Part One)

This is our response to the draft Cycle Safety Action Plan  issued by Transport for London, which you can respond to here  by Thursday July 25th .

The draft CSAP is a fundamentally flawed document which fails in three main respects. Firstly, its idea of “safety” for cyclists is measured in a way which can indicate that having fewer cyclists and a higher cyclist casualty rate is BETTER than having more cyclists and a lower casualty rate. Secondly, it fails to differentiate between measures which reduce danger to cyclists (and other road users) and those which do not. Thirdly, it has no real way of assessing the effects of measures implemented.  

Let me refer to my experience here: for some years I sat on the Cycle Safety Working group at Transport for London (then representing the Borough Cycling Officers Group) and had a role in preparing the first CSAP. Reviewing its effects in September 2012 I wrote The above report indicates ways in which the CSAP has been inadequate. It also shows that insofar as issues are addressed and attempts made to implement necessary changes, the impacts made have been minimal or very limited. Pursuing the overall objectives of the CSAP will require substantially more commitment and resources to achieve a significant reduction in danger to cyclists (and often other road users) and a reduction in the cyclist casualty rate.”

I don’t think there has been any fundamental change since then. In fact, we seem to have gone backwards on the key issue of actually defining what the problem is. This is so basic that nothing worthwhile can really progress unless a clear definition of what the problem is has been agreed upon.

What is ”Cyclist safety”? The measurement issue.

This is not an abstract academic issue. It is absolutely critical as a basis for any discussion about cyclist safety.

As far as traditional “road safety” is concerned, “Cyclist safety” is about the total number of reported cyclist casualties (generally “Killed and Seriously Injured”) per head of the population or in a given location – in this case London. It is NOT about what the cyclists’ organisations asked for – and what TfL for many years at the CSWG agreed on – namely an indicator based on exposure. This is sometimes referred to as a “rate-based” indicator, in that casualties are expressed in terms of the exposure of cyclists, for example cyclist casualties per journey made, distance travelled, or time taken cycling.

At various places in the draft CSAP the casualty rate is indeed considered as the indicator, but elsewhere it is not. For example, take this graph prominently displayed:

Figure 2 : International cyclist fatalities per million population, 2012

CSAPgraph So, the casualty rate per journey, per mile or per hour spent cycling may be far lower in Amsterdam than in London. The experience of cycling in Amsterdam may be far more pleasant and inviting because of the lower levels of danger presented to cyclists. But for TfL, reviewing this graph: “ “Internationally, in terms of cyclist fatalities per million population (Figure 2), London had fewer cyclist fatalities in 2012 than many other cities such as Amsterdam and New York. (Page 9). TfL takes precisely the opposite view that we take, and as far as we are concerned this is a fundamental problem. Unless they invert this position we disagree on what we are trying to achieve.

In fact we need to go a lot further. Even casualty rates are inadequate as measures. We should be looking at whether casualties result from a third party’s rule- or law-breaking, or from careless behaviour on the part of the cyclist. We should be stating that locations laid out so that cyclists are subjected to unacceptably high  levels of road danger  (gyratory systems like Bow Roundabout or Staples Corner) are just that: particularly dangerous locations for cyclists, and that this is objectively so. When actual or potential cyclists are scared to travel through such locations we don’t need to talk about “subjective safety” – these people are making a correct analysis of the objective danger presented to them.

But considering these issues systematically – as I attempted in Local Transport Today last year – is apparently not on TfL’s agenda. There is some reference (“This draft plan, taken as a whole, seeks to improve the reality and the perception of cycle safety.” Page 9)  to concerns about people being deterred by their perception of safety – but this is not followed through.

This is a classic difficulty with traditional “road safety” which we have pointed out numerous times before, whether the offenders are TfL or  Government ministers  and where we agree with our colleagues in the London Cycling Campaign: “London Cycling Campaign has always called for casualties to be measured against exposure to risk. How risky is cycling per mile travelled compared to other ways of travel? Without such measurements the benefits of increasing cycling can be misrepresented in casualty data.”

 

Road Danger Reduction versus “Road Safety”: The “Who-Kills-Whom” question.

Our colleagues in the LCC correctly say: “…(we) will be assessing the 32 actions in the plan for their impact on reducing road danger. For each action we will ask:

  • Does this reduce the source of danger on the roads?
  • Will this action tend to encourage more people to choose a sustainable mode of transport?

 

… too few of the actions really address sources of danger.”

For us there is a fundamental issue about the difference between those road users who kill, or hurt, or endanger others and those who are killed, hurt or endangered. All road users may well have responsibilities, but there is a fundamental difference in actual or potential lethality between (broadly speaking) the motorised and those outside motor vehicles endangered by them. This difference is routinely and systematically neutralised by the “road safety” lobby. So:

Sharing the road

Research also shows that Londoners are concerned by safety on the roads; however they tend to consider the need for change to lie with others rather than themselves. This is a fundamental barrier to improving safety at present. Even though many people acknowledge that they take risks at times, they feel that they have appropriately accounted for the safety of themselves and others and that any risks that they take are calculated and ‘safe’.”

This paragraph perfectly demonstrates the determination to deny the difference in lethality between the different modes.

In this context, Figure 3 is interesting, because it shows that casualty rates for cyclists and pedestrians vary with age (excluding the over-80s) much less than for drivers and motorcyclists. This strongly implies that it is largely the behaviour of others, rather than their own behaviour, that causes cyclist and pedestrian casualties. For pedestrians and cyclists, the ratio between highest and lowest risk  ages is just over 3 to 1. For drivers it’s over 12 to 1, and for motor-cyclists 33 to 1.

 

Analysing effects

Even without tackling this basic moral issue properly, there is a point about analysing the effects of interventions. “This new draft Cycle Safety Action Plan (CSAP) builds on the original, published in 2010,” (Page 4). But, as I argued in 2012,   with the possible exception of resources directed at the freight industry to reduce cyclist deaths involving HGVs, there was precious little evidence for the effects of interventions. This doesn’t stop TfL baldly stating:  “There are some notable successes achieved through the previous CSAP that have made cycling safer in London (Page 25)”

These “notable successes” are:

  • The publicity “cycling tips” campaign: publicity has the least success of all interventions, even according to the official “road safety” lobby.
  • The “exchanging places” campaign to warn cyclists of danger from HGVs. No doubt of some use until lorries (and the roads they travel on) are properly designed to minimise danger, but – as with all education – of limited benefit for fallible human beings. And no use for the (majority of?) cases of HGV/cyclist collisions where lorries overtake and cut across cyclists or hit them from behind. Or for the vast majority of cases of cyclist Serious Injury collisions.
  • Changes in regulations on lorry design and design of signals. No doubt worthwhile, but of limited benefit and yet to roll out in most cases.

That may seem like grumbling, but I can’t help wondering whether the changes achieved so far – or even those mentioned as potentially to be lobbied for  in the new CSAP – are rather less than might be pushed for with other modes of transport. For example: “TfL will lobby vehicle manufacturers and representative organisations to make vehicles safer for cyclists by pushing for:

  • Autonomous Emergency Braking Systems to be fitted to all new cars as standard
  • research into the potential of a Rapid Emergency Impact Braking System (RIBS) to rapidly stop HGVs if they hit a cyclist, in order to prevent fatal crushing injuries

Which is all very well, but how about consideration for systems to be retro-fitted? And what happens in the meantime while the motor industry considers these devices? To take just the example of under-run guards on HGVs which could prevent cyclists (and pedestrians) from being crushed? Is it too much to suggest that TfL could actually part- finance installation of such devices – after all, with a £6 billion a year budget it shouldn’t be too hard to find the money. (continued in next post)

3 thoughts on “What’s wrong with Transport for London’s Cycle Safety Action Plan (Part One)

  1. Pingback: Transport for London’s “Cycle Safety Action Plan”: Still getting it wrong | Road Danger Reduction Forum

  2. David Daly

    Hello, I found your forum very interesting.
    As regards improving safety do you think my products will make a significant difference?
    After success with horse riders we are soon to launch our high viz tabards with micro video recorders and text “Smile You’re On Camera” ..Giz a YARD.

    I would appreiciate your thoughts on these…kind regards Dave Daly M.D

    Reply
    1. rdrf Post author

      David, on hi-viz see the various posts on conspicuity.

      A few thoughts:

      There are a lot of cyclists using helmet cams and other devices to produce recordings which may be used in evidence in court, although whether we want to encourage everybody to do that that is another thing. Of course, that is different again from having black box type recorders on motor vehicles to record driver behaviour and events leading up to collisions.

      Another point is whether you alert people to the fact that they are “on camera”. Will that encourage errant drivers to eb els careful with those horse riders who don’t have the device?

      Another

      Reply

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