|Cardiff Cycling Campaign|
Response to the Consultation Draft of March 2001
We question how the detailed cycling measures (s.26) were drafted, oriented to vehicle users. The whole approach to cyclist segregation is wrong; it should have been drafted with cyclists, taken on board the National Cycling Strategy and been subjected to safety and financial audits. We give suggested changes but believe the process of office drafting, responses and amendments behind closed doors is an inadequate way of determining policy that will be used as guidance by local authorities and for the Assembly’s own expenditure. We therefore ask for a consultative Forum to follow up this specific part of the TAN.
We object strongly to the proposed "segregation of cyclists away from the carriageway where possible… high volumes of traffic or high speeds". This is a drastic and highly costly proposition. We are aware it is in the existing TAN, but that was without cyclists’ agreement and prior to the need for financial appraisal of policies. Depending on definition, this could require building 1000 to 2000 miles of segregated cycleway. Unless the segregation policy is to be dropped, we require to see a proper financial appraisal and comparison with alternative strategies for capital expenditure on cycling.
The Document omits to reference the Assembly's Sustainable Development Scheme of Nov. 2000. We consider of particular relevance are
Transport planning objectives that follow from this and other policy, including the integrated transport policy include
These points should be in the first section of the TAN.
Climate change s.15 needs references to Climate Change documents/legislation
Road Traffic Reduction s.16 needs reference to Assembly policy/targets.
Add that the design of all-purpose rural roads as fast for cars increase social exclusion by deterring use by cycling and walking. Designing for low speeds and safety should come first. This includes road designated as "non-core" trunk roads through eg. Llandovery and some "core" trunk roads through eg. Rhyader.
Cycling s. 25
Add "The UDP should give indicative targets for cycling and how these targets will be monitored. The targets should address the social inclusion requirement via categories such as journey to work, journey to school, shopping trips. Where the LTP does not yet contain a local strategy, the UDP must include the framework and principles of the cycling strategy."
Add in s.26 after "..effective network of cycle routes"
"so that cycling can become a mode of choice for all sectors of the community".
The list of measures is changed from the previous TAN and looks to have been written in the office rather than agreed with cyclists. The list is not comprehensive but might be taken that way. What is the point of a special list here, drawn up in a non-transparent way? The current TAN includes restricting car parking and speed-control measures on motor traffic, and their omission now suggests a car-oriented agenda. They should be restored.
The provision of cyclist changing facilities and secure lockers in all major developments is in the present TAN, taken from the NCS. It’s confused by being combined with secure parking in town centres and transport interchanges.
The "segregation.." clause should read
"segregation of cyclists away from the carriageway via physical or visual means where the road has a combination of high traffic volume and high speed" - certainly not ‘where possible’, nor where traffic speed can be reduced. The speeds should be reduced to secure safety and a cycle lane can be lined on the carriageway to emphasise the cyclist’s right and to psychologically affect the speed-merchants.
Segregation could apply on main distributor roads in urban situations, not generally on inter-town roads.
Cycling safety gets limited mention, only on the network of routes. All junctions should be designed for cycle-safety (not just ‘priority’ to ‘encourage cycling’) with cycling through junctions on-road and not via shared pedestrian crossings.
Cycle audits should be for existing roads – a rolling programme as in the NCS – not just in new developments.
Add new section after s.26 to cover
Cycling to school
plus ‘green transport plans’ with cycling to workplaces, hospitals, colleges etc. and reference to s.84
The UDP to have rolling targets for both categories, instead of treating them as experimental requiring special Assembly grants.
Transport Interchange s.31
Add a mention of secure cycle parking, also policies for bus and rail to carry cycles.
Traffic Management s.35
Add that the Assembly will consider sympathetically proposals for traffic calming on the single-carriageway trunk roads passing through rural villages and towns (as recently done for the A470 through Newbridge-on-Wye).
Add to s.45 local authorities should ..
s.43 and 46 on Common Parking strategy across local authorities.
Asking highways officers and leading Councillors to agree on common parking restrictions is proven to fail. The Assembly office should put forward a firm view and encourage it to be openly and publicly considered, on the basis of encouraging and facilitating non-car use. The TAN should repeat or echo the LTP guidance to Local Authorities to adopt maximum, rather than minimum, parking standards, and a more restrictive parking regime for on-site / long-stay commuter parking.
Planning for Transport Infrastructure, s.52-
It is wrong for the TAN to ignore the need for cycling infrastructure, for the ‘roads’ section to pay no trace of regard for cycling. It needs to state that principal all-purpose roads must be designed for all classes of users including cyclists (except for designated clearways and motorways).
Road schemes 52-58
Trunk road and motorway schemes are no longer to be decided from on high, but under the integrated transport strategy to take into account all relevant transport planning and environmental issues. The ‘New Deal’ Transport White Paper says that "new roads can lead to more traffic, adding to the problem not reducing it, all plausible options need to be considered before a new road is built." As the Trunk Road Review says (para. 5) it is "essential" to "look at wider issues including the need to manage the existing road network more efficiently and effectively and the scope to promote alternative modes of transport".
s.54 should expand the 4th sentence to read
"The Local Authority in collaboration with the Welsh Assembly should ensure that proposed trunk road and motorway schemes are subject to NATTA (New Approach to Transport Appraisal) and environmental impact assessment under the 1999 Regulations, so that the UDP can address environmental issues, wider transport issues including the need to manage the existing road network more efficiently and effectively and the scope to promote alternative modes, and any land use pressures created by the proposed schemes" with references to the integrated transport documents and s.87-88 on EIA.
The TAN should recognise that many road schemes have been adopted by Councils on outdated and/or defective criteria
• no or deficient environmental impact assessment
• prior to the 'New Deal' integrated transport policy, or without regard to its "all plausible options need to be considered before a new road is built".
• big schemes split into stages and the first approved without consideration of the whole
• schemes adopted without regard to huge demand on resources
• schemes adopted under encouragement of the old Welsh Highways Directorate which the resources problem as solved by PFI, gave little regard to integrated transport planning and wanted to build up pressure for new highways.
UDPs must consider the range of transport options, especially in relation to choices between road schemes and alternatives: reducing (traffic demand) car & freight traffic flows / generation along the traffic corridor by modal shift to public transport, bus and/or rail. This should be covered in the TAN and s.57 be re-written to say that
"inherited schemes need to be reviewed under the 1998 integrated transport policy and NATTA, and should be assessed though the UDP process"
Notification to the Highways Directorate (s.58) has proved a formality, with inadequate and faulty justification submitted. This was true of the Vale of Glam's Airport Access Road (later over-ruled) which was approved by the Council prior to the Environmental Impact Assessment and used a faulty traffic model (flows took no account of capacity limits; congested network modelling was needed, and used subsequent to the Directorate's approval. Despite these basic errors, the scheme was submitted for (and won) EC funding on the basis of supposed government approval.
s.58 should add at end that
"Notifications of such schemes will be expected to be supported by the full EIA (where this is required under planning legislation), evidence of full public consultation, and evidence that all plausible options have been considered including the need to manage the existing road network more effectively and the scope to promote alternative forms of transport" with relevant references to the integrated transport policy.
"identifying opportunities" for enhanced stations and interchanges is insufficient – the development plan should "safeguard" the site as is done for roads.
Specific reference needs adding to cover Light Rail (being proposed for Cardiff ) with the need for interchange facilities - cycle parking and carriage - and design for safety at passenger stops and particularly in crossing the rails.
Aviation ss.66 - 67
There is no reason why an airport is excluded from the requirements of access by public transport and/or cycling, given that it is such a big generator of passenger traffic. This and the requirement for an airport access plan should be stated in the TAN.
Annex B on Visibility Standards needs amending to include design for cycling, including cycle paths crossing side roads and through junctions. It should adopt the existing work on this, following from the National Cycling Strategy. We question whether all this designing for cars is needed, being well-known, in contrast to the little known designing for cycling.
Cardiff Cycling Campaign 21 May 2001
Secretary Ken Barker, 33 Castle Arcade Balcony, Cardiff CF10