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

(continued from the previous post)

Seeing cyclists as the problem

I have already discussed the basic problem of how “road safety” measures and generally conceptualises the safety of cyclists. But a further element of this needs consideration. By looking at the people who are hurt or killed rather than those hurting or killing them, crucial issues for other road users are avoided. Consider these issues:


Excessive, illegal or inappropriate speed of the other vehicle involved does not  appear to be a major factor in cycling collisions.” (p.16)

Speed is indeed not implicated in most cyclist Serious Injuries in London. But this is because most cycling in London is concentrated in inner London where speeds are low.  Motor vehicle speeds are higher in outer London where there is little cycling. That doesn’t mean that speed is not an issue there – indeed, high speeds may be a deterrent and one of the reasons for relatively low uptake there. The suggestion would then be that speed control (or separate cycle paths on higher speed roads if speeds can’t be reduced) is indeed an issue.

But the more important issue is that excess speed is discussed solely in terms of its effects on (existing) cyclists. Speed has been a preoccupation for transport professionals concerned with safety from the beginning. Even Colin Buchanan, architect of the car-centred urban transport systems of the 1960s onwards, advocated default urban speed limits of 20 mph. Would it not make sense to be part of initiatives for speed control and 20 mph which primarily benefit pedestrians? If you look at reducing danger at source you would do that – for the benefit of the safety of all road users. If you concentrate on cyclists as casualties, you miss out on that.


  2. Other law breaking

The same applies to policing. There are areas where law enforcement would benefit the safety of all road users through a road danger reduction approach


 3. Conspicuity.

A key feature of focussing on those hurt or killed – essentially a victim-focused approach – is that it easily slips into victim-blaming. I have argued that this is a feature of the emphasis on hi-viz clothing for cyclists and pedestrians herehere , and here   ,for example. Despite the lack of evidence for the value of hi-viz, we have measure 12: TfL will work with manufacturers and cycle businesses to help cyclists be safe by: challenging cycle manufacturers to increase the conspicuity of bicycles, for example building into the frame… retro-reflective equipment…, through innovator seminars.


4. Lights

On the same theme, there is a strong focus on lights, which are at least a legal requirement.

2007 -2011 fatalities. Fourteen of the collisions in the sample (26%) occurred in darkness or partial light, and in half of these collisions the cyclist did not have lights. Bicycle lights are a mandatory requirement and this lack of compliance needs to be addressed Page19

But how important is this issue for cyclists in London as what might be considered a cause of collisions? Firstly, the analysis I have carried out in one London borough (confidentiality required by use of official figures means I can’t name it) indicates that in no more than 1.5% of cases is contributory factor 506 (non-use of lights) a factor for all casualties (see this ). Secondly, while I might have taken an unrepresentative borough, at least some 300 casualties’ were looked at, rather than some 64.

But most important, a detailed manual analysis – easily done with small numbers – would show whether this factor was actually key to the collision occurring. Was the behaviour of the cyclist and other road user(s) exemplary apart from the non-use of lights? Was it the case that an alert driver capable of seeing unlit pedestrians on typical well-lit urban roads would be unable to see an unlit cyclist?


 5. Close overtaking

during 2010-12 Conflict rank Manoeuvre description Seriously injured casualties (% of total) Fatal casualties (% of total)
1 Other vehicle turns right across path of cyclist 219 (13%) 2 (5%)
2 Cyclist and other vehicle travelling alongside each other. 180 (11%) 4 (10%)
3 Cyclist hits open door / swerves to avoid open door of other vehicle. 160 (10%) 3 (7.5%)
4 Other vehicle turns left across the path of cyclist 134 (8%) 9 (23%)
5 Other vehicle disobeys junction control & turns right into path of cyclist 114 (7%) 0 (0%)


One of the key complaints from cyclists is that drivers constantly overtake without giving enough room. Conflict types 2 and 4, covering some 20% of cyclist KSIs, involve changing driver behavior here. Some of this can be solved by segregation, but since this is not going to happen on most roads in London (and would take decades to install anyway even if desired) there is clearly scope for addressing the issue.

give motorcyclists, cyclists and horse riders at least as much room as you would when overtaking a car (see Rules 211 to 213 and 214 to 215).”. Lengthy discussion with MPS officers indicate that there are problems in addressing this without specific distances given, but there is apparently precedent with regard to cyclist “wobble-room” being required when overtaking. At the very least: Is it really too much to expect some sort of police activity in this key area when officers have been giving (misguided) advice to cyclists on helmets etc. in Operation Safeway?


 And also…

 “16: TfL will extend the safety principles of FORS”


Given the amount of time taken to get TfL to see sense over the “Cyclists stay back” stickers and the fact that they (with a new variant above) are still around, one hopes that these principles are properly sorted out.


  • The Boroughs :

    Although TfL is taking the lead to make roads safer, TfL cannot achieve safe cycling for all alone. Ninety five per cent of London’s streets are the responsibility of London’s boroughs, making them essential to the success of this draft plan.”. Matters like policing are actually much more in TfL’s control than the boroughs. Also, TfL often dictates – over matters such as “smoothing the traffic” – borough behaviour, and of course allocates substantial funding to boroughs. Can it not similarly direct boroughs in the right direction on safety?

  • 2.2 While only two per cent of all trips in London in 2012 were made on a bicycle its importance is greater in the places and at the times that matter most. (p.7)

    Why does it “matter” which times and places people choose to cycle, and who has the right to decide this?


  • The Cycle Task Force upgrade

    We have been critical of the way enforcement is done in London, but agree with a properly resourced enforcement programme. Only some of this will involve the Cycle Task Force but “increasing the number of police officers in the Cycle Task Force from 39 to 50 “ is hardly impressive.




We have made it clear to TfL, along with the other cyclist and road danger reduction organisations, that they need to measure danger in more appropriate ways in order to properly  understand safety of cyclists and other road users, and to implement measures to control road danger at source.  There isn’t much evidence that TfL are  listening to this message.



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

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

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