Our Response to the Cardiff Local Cycling Strategy

To avoid having to scroll up and down through the page you can see a copy of the Cardiff County Council LCS with our comments on each point in red.

Formal response of Cardiff Cycling Campaign to the Cardiff County Council’s Local Cycling Strategy (LCS)

22 January, 1998

Cardiff Cycling Campaign welcomes the fact that the County Council has now produced its own draft Strategy in response to government proposals in this area. However, it is disappointed that the document, which has been released for comments represents a significant dilution of central government’s National Cycling Strategy (NCS) document. No reasoned case has been produced to justify the dilution.

Safety

Our major concern relates to the recorded cyclist accident figures for Cardiff. These were represented in the County Strategy in terms of an accident rate/estimated distance travelled. The Strategy explains that the Cardiff figure is worse than the figure for the whole of the UK as a result of Cardiff being an urban area. This is an implausible explanation, since the UK population predominantly resides in urban areas. Crucially, the figure of double the national average rate would indicate, with accident rates following the expected form of statistical distribution, that Cardiff’s cyclists suffer in the extreme through accidents.

Requirements of a Local Cycling Strategy

The National Cycling Strategy produced by the then Department of Transport in July 1996 represents a reasonable basis for a local strategy through its Annex 2. However, central government thinking has progressed since its introduction under the last Conservative government. The Labour government is showing much stronger signs nationally of promoting the use of cycling, particularly for local transport, and is firmly committed to a reduction in the use of motorised traffic and seeks a reduction in the emission of greenhouse gases. It is therefore reasonable to expect that a progressive County Council would wish at least to match, and probably exceed the former government’s goals.

Specific targets

In our submission of comments concerning the Draft LCS, these are regarded as being of crucial importance. They form the foundation upon which the remainder of the LCS should rest.

1. The targets proposed in Cardiff for accident reduction are derived directly from the National draft. In view of the appalling cycle accident record in Cardiff in recent years, the target should be revised to promise that Cardiff shall achieve an accident rate of no worse than the mean national value within five years. It will undertake at least to track that mean in subsequent years.

Measures that will be undertaken to assist in achieving this target shall include

· A programme of supporting the police with traffic law enforcement

· Undertaking Highway traffic management measures to eliminate known dangers.

· Where necessary, it is expected that Highway layout should be revised to reduce the need for cyclists to compete for road space. In many instances two traffic lanes have been designated at junctions in Cardiff where room only exists for one.

2. The LCS shall commit the County to develop standards, for the quality of cycle-specific facilities, which shall be published. Amongst these, the standards should commit to:

· Follow the most practical direct route and not be required to give way to crossing traffic in cases where a parallel adjacent main road does not.

· Ensure that cycle facilities are given adequate priority over motorised traffic at junctions.

· Develop improved environments for cyclists on previously used routes when the latter are replaced by schemes that improve the major highway infrastructure.

· Construct off-road facilities with durable materials which do not damage the users’ cycles or clothing.

3. Best engineering practice shall be used in the construction of traffic calming measures, such as constrictions or road humps, to provide clear safe paths for cycle users. Specifically, in these cases, special provision shall be made which is not subject to obstruction through parking, to ensure that the cyclist is not required to compete with motorised traffic or be forced to use highway incorporating measures that are detrimental to control of the cycle.

4. The overall objective of the Cardiff LCS should be to increase the modal use of cycling. It is insufficient merely to propose to increase the number of cycle journeys made, since current government projections are for increasing traffic levels. Ultimately, the LCS should also incorporate a Council Policy to reduce motorised traffic within the County, as is required by the Road Traffic Reduction Act (RTRA) (1997).

5. A meaningful statement of policy must incorporate a commitment to the provision of an adequate proportion of the Council’s financial resources for it to be achievable. This should not form an insuperable difficulty for a County whose resources have been increasingly constrained: the cost of provision of adequate and safe facilities for cycle transport is many times lower than that for motorised traffic.

6. In addition to the education of potential cyclists of school age to improve their appreciation of safety related issues, there is considerable need to extend training to motorists. Motor vehicles represent the primary source of danger to all road users: much of their danger emanates from inconsiderate driving, such as excessive speed, the failure to observe minimum safe distances either from vehicles in front, overtaking in inappropriate situations and passing too close. Apart from highway traffic management measures that may reduce aggressive behaviour on the part of motorists, there is a serious need to improve their awareness of the needs of other road users. This need must be tackled at the source of the problem, rather than by passing responsibility for safety to the potential victim of the inconsiderate behaviour.

Specific comments on present draft strategy

Cardiff LCS reference

Cardiff Cycling Campaign Comment

Objective 1

Replace the words "in order to reduce the use of private cars and" with "and follow a policy of lowering the capacity of highways and thus". This change would reflect the requirements of the RTRA.

Objective 3

NCS point about obtaining resources through bidding has been omitted from the Cardiff draft and should be reinstated. The ‘Education’ dimension should also be included.

Target 1

Doubling the number of trips whilst motorised traffic levels continue to rise will not double the modal use! This target is borrowed from NCS Annex but is too weak: it would not in itself begin seriously to meet Objective 2 which seeks to minimise private car use. It also takes no account of the RTRA. The RTRA’s requirements could be met if the words "and reduce the capacity of the highway for private cars to the level of 1990" were appended.

Target 2

This target is meaningless unless an unequivocal statement is made in respect of the quality of these routes. It is plain that much of the distance included in the 42km figure is fragmented, obstructed or of very low quality, being designated as a "leisure route": the routes signally fail to reach most crucial destinations in the City. It is therefore essential that the figures for achieved routes quoted by the County for its policy shall be of statutory Highway standards and not classified as permitted or shared use paths. This will be a clear signal that the County accepts a meaningful commitment to development to a standard in which safety of the user is taken into proper account.

The time scale on which the remaining 100km quoted will be implemented is absolutely essential.

Text following Target 2

Speaks of a network of 200km. This should be revised to say that the entire road network should ultimately be included by virtue of it being safe for all road users.

Target 3

The draft strategy is somewhat confused on this point. It notes a strong commitment to the provision of safe cycling routes to schools, which is to be commended. However, whilst it notes that a serious increase in school based motorised traffic has taken place, it fails to observe that the greatest element of this increase relates to primary schools. Its proposed developments of cycling to school are mainly targeted at secondary school children, and unfortunately inadequately address the problem. We strongly urge that attention be given to reducing the target age range, but are well aware that the excess traffic problem is part of the cause of reluctance of parents to permit their younger children to travel other than by car. However, the point is crucial, as early conditioning to the use of a car, for short trips, is probably the biggest barrier to cutting car use.

The NCS quantifies the development of the modal use of cycling to school: the LCS should comply.

The LCS would be significantly improved if the words "the conditions appropriate for a modal shift" were replaced with "create conditions, which reduce the use of private vehicles going to schools".

Target 4

Please see points 1 and 6 above.

Target 5

NCS quantifies levels for 5 and 10 years. A policy that does not incorporate a quantitative aspect cannot be subsequently assessed for its effectiveness. Note that 1300 thefts were reported, so that there may be a much higher underlying figure.

This target could reasonably propose a degree of responsibility for security on the cyclists themselves. The wording "and make cyclists aware of the problems of theft which could be reduced by more effective cycle security" should be appended to the target.

Target 6

NCS does not use the word "encourage" and is thus much firmer. This is clearly a case in which the County, through its education service, should be taking a central role in the provision of the resources to make this policy effective. For reasons given against target 3 above, the emphasis is too late - the policy must be extended to provide training at the critical primary age.

The nature of the training to be provided should be specified. It would be prudent to include teaching of defensive cycling techniques.

NCS target 6

Has been omitted - it refers to a policy to seek funding through external bids. This surely is important to the County owing to present financial stringency?

Target 7

Outright theft is not the only problem. Enclosed lockable parking would prevent tampering.

Also suggest appending "in accordance with and to assist in the implementation of target 5" to this target.

Policy Context

A number of documents have been omitted (not including those just for Scotland etc.) Is there any reason for this? The crucial omission is probably Welsh Office/DoT Local Planning Note 1/89.

Policy 1

The original (NCS policy 12) states that "cycling will be permitted in pedestrian areas wherever possible". The NCS policy 12 is much stronger and should be preferred. Please also refer to Welsh Office/DoT Local Planning Note 1/89, and Cycling in Pedestrian Areas – TRRL Report.

Append to policy "and to approve policy measures which seek to reduce the use of private cars".

Policy 2

The reference in NCS about using traffic calming and restraint should be reinstated.

Add words after "necessary" "in favour of cyclists".

Policy 3

The paragraphs following NCS Policy 4, which relate to a hierarchy of measures: traffic reduction, traffic calming etc. should be in the text here.

Policy 4i

Append words "where secure cycle parking will be provided".

Policy 5

NCS is much firmer and includes guidance about the quality of maintenance. Cardiff's proposed policy is a serious weakening of the original. Replace "appropriate" with "high".

NCS policy 5

Has been omitted. This is a very serious omission, as the policy relates to taking measures to improve cyclists' safety, to ensure that routes are not disjoint and that cyclists receive priority where they are broken. These are precisely the areas where the County’s standards have been their most inadequate. In view of the very high numbers of cyclist casualties in Cardiff, this is possibly unsurprising, but it is strongly indicative of an urgent need to accept government advice in a crucial area. NCS policy 5, together with its qualifying notes, must be incorporated into the Cardiff LCS.

Policy 6

Appears to have its origins in NCS policy 7, but it is so watered down as to be virtually meaningless. Without a statement of the quality of that used in NCS policy 6, one must suspect that the County is attempting to use words that may readily be circumvented.

Policy 7

NCS wording (from its policy 1) has been incorrectly edited. [Swap "and" ahead of "land-use"; after "audit" add "in conformity with the strategy"; between "that", "schemes" add "all"].

Insert before "improvements to" words "additions to,"

Policy 8

The policy is to be welcomed, when it is put into practice.

Replace "to aid" with "to provide additional routes and aid".

Policy 9

This has been weakened from the NCS version for no obvious reason.

Policy 10

Append the words "and that cyclists are identified separately in all traffic counts".

Policy 11

This should include access to transport interchanges as well as storage and space on vehicles.

Insert "suitable" before "space".

Policy 12

This policy should include a statement about access and clarity about the requirements to be placed upon employers and developers.

Encouragement

Please see point 4 above.

Policy 14

In view of the very poor achievements in safety in Cardiff, this is dealt with separately in points 1 and 6 above.

Policy 16

NCS proposes measures, whereas they are omitted from the LCS, and should be reinstated.

Policy 17

Please see target 3 above. There should be an additional policy commitment to ensuring that exceptional engineering measures may be necessary in the vicinity of schools to ensure cyclists’ safety if additional cycle usage is to be promoted.

Append to the policy "The Authority will act positively to discourage the use of private cars as a means of transport to schools."

Policy 18

There is no statement of measures to bring about the reduced use of private cars in the policy. Please see also point 4 above.

In the notes following this Policy, insert "and the reduction of private car usage" following "cycle movements".

Policy 19

The liaison meetings should be properly incorporated so that their results are reported back to the participants reasonably promptly.

Policy 20

The NCS policy (22) quantifies this provision: why has this been omitted?

Policy 21

The NCS policy (23) does not use the word "adequate", but states "highest possible". NCS includes notes about speeding and dangerous driving. Also it speaks of "Protection of pedestrians". Is this from cyclists or motor vehicles? Without the level of protection proposed in the NCS, will Cardiff continue its present unacceptable accident rate?

Policy 22

A date should be included for production of an action plan.

Policy 24

Replace "staffing levels" with "levels of expert staff".

Policy 25

Replace present wording with:

The Authority will seek to identify an expansion of funding sources for cycling, retain established budgets as a minimum and ensure that schemes funded from other sources incorporate cycle friendly features in order to meet the targets that have been set. It will also encourage government to provide additional funds specifically to aid cycling as a mode of transport through approaches both to the Welsh Office and the proposed Welsh Assembly.



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