Transport for London’s “Cycle Safety Action Plan”: Still getting it wrong.

Earlier this year the RDRF responded to Transport for London’s Draft Cycle Safety Action Plan (CSAP) here  and here .

I argued then that: “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.”

The new CSAP is now out . Apart from some typographical differences, there are only two noticeable changes. One of these changes seems to be simply cosmetic, the other could potentially have an effect, but I suggest is unlikely to. (So much for the effects of consultation). I discuss these changes below along with general comments: if these seem the same as before it’s because (apart from the two changes) the criticisms remain the same. So:

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 which was prominently displayed in the draft CSAP – and which has been dropped from the final version:

Figure 2 : International cyclist fatalities per million population, 2012



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 in the draft CSAP: “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. 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.

Now, let’s consider the dropping of this graph and the quote above from the final CSAP. What we have instead is :”Other cities across Europe may have proportionally more cyclists, but London had fewer cyclist fatalities per million population in 2012 than many of these European cities”.

Which is still saying exactly the same thing: the metric which is valued by TfL is the cyclist death rate per head of the population, rather than per cyclist journey, or per kilometres cycled.

To be fair to them – following the persistent criticism of TfL made by RDRF and others for years – they do now admit the following in the final version of the CSAP:

International data comparisons of cyclist fatality should ideally be normalised for exposure using a common denominator such as journeys cycled or distance cycled. However, a lack of data in major international cities, including those where cycling is a popular mode of transport, presents a challenge for international benchmarking. Given that population data is readily available, it currently provides the only measure for comparison. TfL continue to seek accurate data to benchmark cycling risk in London with cyclised cities. (p.10)

Or to put it another way: we’re using the wrong measure but we have to because we haven’t got proper data.

But this is nonsense. It is quite easy to show that the chances of having been killed on roads in European cities that have far more cycling are lower. My suggestion is that TfL – and the “road safety” industry generally – are inherently biased against cycling (and for that matter walking, particularly by the elderly and children). This is because with far more cycling it is quite likely that we can get a lower casualty rate (per journey or distance cycled) but that the numbers of injured cyclists per head of the population may rise. To take the usual example: nationally the Dutch have a far lower death rate for cyclists when exposure is considered, but a far higher one per head of the population.

This is not just some sort of abstruse technical discussion: it goes to the heart of whether cycling is to be supported or not.

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. Indeed, in the Foreword to the CSAP, Leon Daniels, MD of TfL Surface Transport, says:

 “Our high-profile marketing campaigns will bring balance to the debate (my emphasis) by showing drivers and cyclists how they can keep themselves and each other safe.

Rather as if drivers on the one hand, and cyclists on the other, pose the same sort of potential threat to other road users.

In this context, Figure 2 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 builds on the original, published in 2010,” (Page 5). 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.

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:

  1. Speed: A change of heart?

This is the other apparent change from the draft CSAP, which said

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

We commented on this by saying in our consultation response that :

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.

But now we have an apparent change of heart: on Page 18 of the final CSAP, where the fact that speed can be a contributory factor is recognised, along with “…reduction in (motor traffic) speed may assist with the perception of cycle safety”.

But will this actually lead to any change in terms of attempting to reduce speeds of motor vehicles? There is nothing new in the CSAP to suggest this (Para 21 , page 36 is referred to but doesn’t mention speed and is no different from the draft CSAP). Speed law enforcement is essentially about fixed cameras at sites where the “right number” of personal injury collisions have been recorded, and there are much discussed problems with a lack of enforcement in the new 20 mph areas.

And this is really the only significant change that TfL has made in response to consultation…


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 Page22

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?



  1. 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 are still around, one hopes that these principles are properly sorted out.


  • 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?
  • 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.


Our response to the draft CSAP concluded:

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.

Removal of an embarrassing graph indicates that the message has been noted. But TfL are still not taking on board the message.






3 thoughts on “Transport for London’s “Cycle Safety Action Plan”: Still getting it wrong.

  1. T.Foxglove

    Thank you for your time & effort putting together such a thorough critique TfL’s Cycle Safety Action Plan.

    As this mayoral term is winding down it is possibly unsurprising that TfL seem to want to present a relatively good news story & be seen to be doing something about safety (training, role reversal) despite its limited effectiveness.

    Perhaps the next mayor on taking office would be more open to changing the assessment measure of cyclist safety as they could blame Johnson for how bad it is.

    1. fonant

      For sane transport planning for London, I hope Londoners and people who work there take Christian Wolmar’s campaign very seriously. London needs efficient people movement to work, and it could do with a lot fewer deaths and injuries (and less pollution) caused by motor transport.

  2. Pingback: TfL: road danger reduction or road safety?

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