Cardiff Cycling Campaign
Helping to make Cardiff a Cycling City
33 The Balcony Castle Arcade CARDIFF CF10 2BY
Elliott Ball, Strategic Rail Authority
55 Victoria Street, London SW1H 0EU
14 July 2004

Response to Strategic Rail Authority Consultation on cycle provisions

Cardiff Cycling Campaign is a voluntary organisation with around 400 members and has represented the interests of cyclists in the capital city since 1985. It participates in the Cycle Campaign Network UK and includes people experienced at all levels, including in the design and implementation of cycling facilities. The Campaign has been a key partner in Cardiff County Council's development of their cycling strategy and plans for their strategic cycle network. The Campaign also submitted substantial feedback to the Welsh Assembly's consultations on Wales's Walking & Cycling Strategy and Transport TAN.

The SRA draft cycling policy if it properly followed Dept. of Transport and Welsh Assembly policies would not be so weak and hands-off, but would include specific guidance, standards and targets, rather than 'aspirations'. As the government is intending to take over the SRA, the document should be written to implement their declared cycling policy with targets analogous to the National Cycling Strategy.

The 3rd objective

Rather than aim for parking at all stations (at small unstaffed stations, it's risky to leave bikes) the aim should be properly designated parking at all major stations. Not all can be like Bristol (Temple Meads) but cities like Manchester/Piccadilly and Birmingham/New Street which make little and difficult provision (only a locked compound) should be required to put in cycle parking - and SRA funding go for these identified major stations. Whenever there's major refurbishment of a station, cycle parking must be included (cf. Bristol Parkway). There should be no requirement to show cycle parking gives an "economic" return, in view of the many non-economic benefits of cycling.

In relation to the 4th objective

we point out that under the Rail Vehicle Accessibility Regulations (RVAR), TOCs have to provide space for wheelchair users distinct from other flexible space. While wheelchair users have first call on it, cycle should be allowed to use it when unoccupied. In the new designs required by the Regs., some basic provision for cycles could and should be included, and the objective modified to include this phrase. Allowing the TOCs full choice has led to failures - trains which have no dedicated or flexible space for cycles (as Cambridge-Kings Cross) should be forbidden.

Comments on the business case method as applied to cycling

The Document states:

Road decongestion benefits. When passengers switch from car to cycle, there is a reduction in air

pollution and there are reductions in journey times for other road users.

Yet in a congested system, car journeys fill the space; cyclists don't reduce congestion but undertake economically beneficial journeys efficiently, at low cost (and low increment in GDP).

The Document states:

• Health benefits. Regular exercise can lead to substantial reductions in the risk of coronary heart

disease, obesity and high blood pressure. Stress levels can be lower for cyclists as they can avoid

traffic queues and overcrowded public transport. These health impacts are partially offset by any

increase in road accidents due to the high vulnerability of cyclists;

Roads should be safe for cycling, so it is bad policy to count accident costs against health benefits (part of the old system that would drive cyclists and pedestrians off the streets to avoid safety modifications and to 'improve' the accident statistics). The Mayer Hillman study cited (BMA 1990: Cycling towards Health and Safety) shows the health gains are 20 times higher than accident losses, so talking of the gains being "partially offset" is misleading - accident costs should be therefore excluded.

The Document states:

Social inclusion. As a low cost form of travel, cycling is widely accessible.

Yet neither Health benefits nor social inclusion are accounted in the economic appraisal.

The Document states:

Cycle commuting can reduce business costs as employees spend less time in traffic queues and

are less likely to take sick leave11. Within cities, cycling can offer journey time savings

Yes, and these are omitted in the economic appraisal, that has given the preliminary results that the SRA uses to justify its policy: eg.

"Negative" where capital investment is required for modification of rolling stock in order to accommodate cycles

We conclude that these preliminary results are unreliable and should not be used to predetermine the conclusions.

Comments on draft policies

The Document says on access to stations

• When carrying out enhancement or refurbishment schemes, station operators should consider

appropriate provision for cycle access

We disagree: the operators should make appropriate provision for cycle access

The Document says on cycle parking at stations

• Station operators should consider providing ‘secure’ cycle parking.

Parking spaces can often be provided on the platform of older spacious stations, provides much better security than outside the station; it is done in some cases and should be generally extended where feasible. This deserves much more priority than relatively few high-cost lock-up cages.

The Document says for policy on cycles on trains

• When buying new trains, or when carrying out rolling stock refurbishment, train operators should consider whether dedicated flexible space which can carry cycles can be economically provided.

We disagree: 'economic' as applies to a TOC ignores the wider costs/benefits.

• Train operators should decide the appropriate level of dedicated and shared cycle carriage spaces on each route after considering the level of demand and the needs of all railway users through consultation with relevant parties including the local Rail Passengers Committee and cyclist representatives.

We disagree. As pointed out above, new designs are required to accommodate wheelchairs (not 'economic') and, at the same time as stock is being modified, some basic provision for cycles could and should be included. There needs to be sufficient space for family/party travel (>4-6) on certain routes. Hung-cycle spaces are difficult for the physically less strong so are discriminatory.

• Non-folding cycles cannot normally be carried on heavily used services (for simplicity, defined as peak services), unless permitted by the TOC.

• The general presumption should be that non-folding cycles can be carried on off peak services although train operators may:

- Place restrictions on the carriage of non-folding cycles where this is in the interests of other passengers;

This phrase interests of other passengers should be cut out - it encourages exclusion of cyclists as a nuisance. Peak/off-peak has little relevance for long distance trains as in Wales; the distinction should be limited to the urban-metropolitan areas.

– Operate a pre-booking system for cycles and decline to carry cycles where the dedicated storage space is full; and

– Charge for the carriage of non-folding cycles.

• The carriage of folding cycles that can be accommodated as luggage within the passenger saloon should be unrestricted and should not be charged for.

• Where appropriate, and commercially viable to do so, train operators may use other ways of satisfying the demand for the carriage of cycles and may make a reasonable charge for such a service.

Most TOCs have abolished charges. The charge when no reservation of £3 is penalising and unrelated to cost - now used only by First Gt Western and Wales& Border/Wessex and often not applied being seen as unfair and unworkable.. The SRA should set a maximum charge (of £1 including booking).

The Eurostar charge of £20 each way is the result of an unnecessary bureaucratic system (franchised out). It does not conform to policy of encouraging cycling. Eurostar cycle-carriage should be made easy and flexible as on Ferries.

Max Wallis

Chair, Cardiff Cycling Campaign