The National Cycle Strategy comes to Cardiff

In mid 1996 the Government published the National Cycling Strategy (NCS). Cycle campaigners generally welcomed this document as a positive contribution to the cycling cause. It includes a Model Local Cycling Strategy (LCS) as an example of what Local Authorities should be doing for cyclists. Cardiff County Council has just published their LCS, and it differs from the model LCS in several important areas. Would you believe it, in every departure from the model LCS, the Cardiff version is weaker! Since Cardiff was one of the places that were looked at when the model was drawn up, it seems surprising that the Local Authority has seen fit to water the document down so much?

We welcome the fact that Cardiff Council intends to implement a LCS but why such a weak and watery one? Read on for Our response to the Draft Strategy

These are all long documents and to avoid you having to scroll up and down through the page I have put a copy of the Cardiff County Council LCS below and our comments on each point in red.

The Cardiff County Council LCS

A CYCLING STRATEGY FOR CARDIFF

CONSULTATIVE DRAFT

INTRODUCTION

This strategy document provides an overview of all the policies of Cardiff County Council which can help promote cycling.

OBJECTIVES

The cycling strategy includes the following objectives:

Objective 1

To maximise the role of cycling as a transport mode, in order to reduce the use of private cars and improve the health and physical wellbeing of both the local and visiting population.

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 Road Traffic Reduction Act 1997 (RTRA).

 Objective 2

To develop a safe, convenient, efficient and attractive transport infrastructure which encourages and facilitates the use of cycling, has regard to walking and public transport and which minimises reliance on, and discourages unnecessary use of, private cars.

Objective 3

To ensure that policies to increase cycling and meet the needs of cyclists are fully integrated into all corporate policies, strategies, plans and initiatives within the economic, social and environmental dimensions.

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.

TARGETS

The strategy has adopted targets that are sufficiently challenging to maintain momentum, but are realistically achievable within the specified timescales. It is intended that by survey and other review techniques these targets will be further refined and in many cases numerically defined. The targets are listed below as follows:

Target 1

To seek to double the number of cycle trips by 2002

There are currently some 12,000 cycle trips made around the County each day. This is about 2% of the modal split. The former South Glamorgan County Council set a target of increasing the modal share to 10%.

The above target is based on the National Cycling Strategy and is by definition aspirational.

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

To complete 100 Kilometres of the strategic cycle network by 2002

 The Authority recognises that it is inevitable that most cycling in Cardiff will take place on the carriageway. It is essential therefore that the highway network is made increasingly suitable for cycling. There are 1000 kilometres of highway in the County.

 A key component of this transformation will be the creation of a strategic network. This will be designed to provide a series of radial routes, increasing with distance from the Central Area, with connecting circular routes linking across the radials. This strategic development will provide a network of 200 kilometres with a maximum distance between routes of 1000 metres, with improvements directed at difficult sections or junctions. Some 42 kilometres have already been completed with about 8 kilometres of these on-road (including the bus lanes).

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.

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

To seek to increase the modal share of cycling and walking journeys to school by pupils of 10 years or older by establishing partnerships with pupils, parents and teachers, reviewing latent demand and creating the conditions appropriate for a modal shift.

National statistics identify that in 1970, 80% of schoolchildren aged 9-11 made their own way to school, mainly by bike or on foot. Nowadays that figure is around 9%. A significant proportion of peak hour trips involve educational escort duties usually by private car. European experience indicates that modal shares for cycling to school of over two thirds can be achieved.

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

To match the current national average by seeking to reduce by 50% the rate for cycle casualties per 100 million kilometres cycled by 2002 compared to casualty rates in 1994. To seek to reduce casualties by a further 50% by 2012

Apart from the distress that accidents can cause, the perception of possible exposure to risk acts as a disincentive to potential cyclists.

Accident data is currently expressed in a way that indicates the distances travelled as well as the occurrence of accidents. Such distance data for Cardiff was last collected by home interviews in 1994. This gives a rate of some 1040 casualties for each 100 million kilometres cycled.

From 1995 statistics, the rate for Britain is about half this level at 554, although it should be noted that this includes both urban and rural areas. Given Cardiff's manly urban nature, this does not allow direct comparisons to be made.

Please see points point 1 and point 6 about this important point in our response below.

Target 5

To seek to work in partnership with the police in order to reduce the rate of cycle theft such that it does not act as a deterrent to cycle use.

In 1996 Cardiff cyclists suffered 1300 cycle thefts. The possibility of cycle theft deters some cyclists. It has been shown to be possible to reduce the prevalence of such theft by the use of a variety of means. These have necessarily involved partnerships with the Police, local Neighbourhood Watch and other individuals and organisations.

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

To encourage the provision of on-road cycle training for all children of secondary school age.

Much of the cycle training currently provided occurs on safe off-road segregated routes. Carefully planned and delivered on-road training can prepare cyclists better for the real-life conditions. This will require not only suitably qualified tutors but also the selection of appropriate routes. Appropriate and available sources of finance will also need to be identified.

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

To seek to ensure that a further 700 cycle parking stands are installed in public areas within 10 years and to encourage the provision of additional cycle stands by the private sector.

Cardiff has, at present, some 100 stands in the public realm. On the basis of present cycle usage, some 700 more stands need to be provided to cater for 25% of users in the inner areas and 10% of users in the outer parts of the County.

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.

TIMESCALES

The strategy has targets relevant over 10-15 years. Progress and policies will be reviewed annually.

POLICY CONTEXT

This strategy forms part of an integrated multi-modal transport strategy which emphasises the discouragement of the use of the private car, the minimising of its adverse effects and the promotion of environmentally-friendly modes. It supports the development of a complementary package of measures in which cycling is an essential element of transport within the City.

The strategy takes account of the aims and guidance set out in the following documents:

1. DEPARTMENTAL SERVICE PLANS
2. CARDIFF LOCAL PLAN - January 1996
3. APPROVED STRUCTURE PLAN -
4. REPLACEMENT STRUCTURE PLAN - February 1996
5. ENVIRONMENTAL STRATEGY (LOCAL AGENDA 21)
6. PUBLIC TRANSPORT POLICIES 1992
7. TPP 1997/8 - September 1996
8. ROAD SAFETY PLAN - September 1996
9. TRAFFIC MANAGEMENT POLICIES AND STANDARDS - 1996
10. TRANSPORT STRATEGY - 1995
11. TRANSPORTATION GOOD PRACTICE GUIDES - 1995
12. REGIONAL PUBLIC TRANSPORT STUDY -
13. PPG (WALES)
14. NATIONAL CYCLING STRATEGY
15. DISABILITY DISCRIMINATION ACT
16. ENVIRONMENTAL ACT, PART IV
17. HIGHWAYS ACT 1980 (Sections 38 & 278)
18. PLANNING ACT 1990 (Section 106)
19. TRANSPORT ACT 1985
20. ROADS AND STREET WORKS ACT 1990

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.

MECHANISMS TO DELIVER THE OBJECTIVES

As part of its integrated approach to transport, the Authority will undertake programmes of engineering, enforcement, encouragement and education in order to increase the level of cycling as a means of transport. These programmes, actions and associated resource allocations will be continually evaluated through a process of monitoring and review.

Engineering

The primary aim of engineering measures is to provide a cycle-friendly infrastructure. This will comprise of the highway network, modified where necessary and supplemented by cycle routes and cycle parking, to enable cyclists to reach destinations safely and conveniently.

Policy 1

The Authority will ensure that measures taken to facilitate cycling take full account of pedestrians and people with mobility difficulties

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

A high quality route network will be provided for cyclists to enable safe and convenient access to all destinations.. The route network will mainly occupy carriageway space within the highway network, modified where necessary, but may also involve segregated sections and other cycle specific facilities.

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

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

Policy 3

The route network will achieve high standards of coherence, directness, safety, attractiveness and comfort, and design criteria will adopt the hierarchical approach recommended by the IHT/DOT/CTC/Bicycle Association publication: Cycle-Friendly Infrastructure, Guidelines for Planning and Design (1996).

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 4

Priority will be given to the development of routes as follows:

1. Major routes which serve utility cycling trips; in particular "safe routes to schools", routes from residential areas to significant journey attractors such as retail centres, major employers, public transport interchanges, hospitals, other education facilities and leisure facilities
2. Other connecting routes used for utility cycling, including inter-urban links
3. Recreational routes, including links to non-urban sections of the National Cycle Network

 Append words "where secure cycle parking will be provided" to Policy 4i.

Policy 5

The Council will set appropriate standards for the construction and maintenance of segregated cycle routes and for the whole cycle network

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

The Council will adopt highway design standards to ensure that wherever alterations or additions are made to the highway network, best practice is applied to meet the needs of cyclists.

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

All highway land-use and development schemes will include a cycle audit to ensure that schemes provide improvements to, or safeguard, the coherence, directness, safety, attractiveness and comfort of routes used by cyclists.

In particular, the Authority will ensure that development does not disadvantage existing use by cyclists or pedestrians or unjustly prejudice accessibility by walking or cycling.

 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 Authority will make use wherever possible of development opportunities to improve transport infrastructure to aid cyclists.

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

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

Policy 9

The Authority will identify any disused transport corridor and facilities where protection to benefit cyclists may be appropriate.

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

Policy 10

The Authority will ensure that cycle infrastructure developments are based on regular monitoring of cycle flows and demand.prediction.

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

Policy 11

The Authority will ensure that cycling is fully integrated with public transport to facilitate cycle use as part of longer journeys, primarily by ensuring the provision of secure storage at interchanges and by encouraging operators to allocate sufficient space on vehicles.

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

Insert "suitable" before "space". 

Policy 12

Adequate cycle parking will be provided, according to standards defined in the local plans, at educational establishments, retail centres, public transport interchanges, leisure facilities, and other major journey attractors. Employers will be encouraged to provide cycle parking at workplaces.

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

Policy 13

The Authority will continue to apply cycle parking design standards to ensure that cycle parking facilities are secure and accessible, and where possible are well lit, under shelter, and conveniently serve the cycle route network.

Encouragement

The Authority recognises that, whilst there is a reservoir of latent demand which could well respond to the fulfilment of the engineering policies outlined above, there will still remain a scepticism amongst many in the County and a reluctance to support the achievement of the modal shift. It will be necessary for the County to carry out a number of initiatives, in parallel with the engineering measures, in order to explain the basis of the strategy and to encourage an increase in cycle use.

Please see point point 4.

Policy 14

The Authority will continue to develop a road safety plan to monitor accidents and identify opportunities in order to ensure that the desired increase in cycle use does not result in an increase in cyclist casualties. The approach of this plan will be to reduce road traffic danger at source, through programmes of engineering measures, and education and enforcement strategies.

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

Policy 15

The Authority will encourage theft reduction measures, recognising that fear of cycle theft is a major deterrent to cycling for utility journeys.

Policy 16

The Authority will encourage the establishment of a programme of cycle-friendly employer initiatives

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

Policy 17

The Authority will encourage and facilitate walking and cycling to school (in combination with public transport use, where necessary) as a means to improve the safety, fitness and independent mobility of school children, and to reduce congestion and traffic danger around schools.

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

The Authority will support its infrastructure measures with a sustained programme of complementary publicity to publicise the cycle network and other facilities, to emphasise the health, financial and environmental benefits of cycling and the need for reduced use of private cars.

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".

Education

The County Council, through its Highway and Transportation Services Department, carries out an annual programme of schemes that are not primarily motivated by cycling interests. These will be subjected to a cycle audit procedure and monitored for their effect on cycle movements and the results fed back into the Department's design and build process. The Authority will also become involved in on-road cycle training.

Policy 19

The Authority will ensure that its programme of highway schemes and all cycling infrastructure proposals are supported by monitoring of cycle use (as described below in "Monitoring and Review of Policies and Action") and by regular consultation with local cycling organisations, mainly through the quarterly Cycling Development and Liaison Working Party.

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

Policy 20

The Authority will endeavour to provide on-road cycle training for children and encourage, in partnership with local cycling organisations, on-road cycle training for adults.

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

Enforcement 

Use of the highway, both carriageway and footway, is constrained by both statutory legislation and local traffic Orders and bylaws. The Council define the local conditions but enforcement is a matter for the Police.

Policy 21

The Authority will liaise with the Police to ensure that the enforcement of traffic law receives adequate priority. Particular attention will be paid to the protection of pedestrians and the minimising of the adverse effect motor vehicles can have on cyclists.

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?

MONITORING AND REVIEW OF POLICIES AND ACTION

The Strategy will require a systematic programme of action to guide its implementation and to act as a benchmark to measure progress. Also required will be adequate resources, both time and finance.

Policy 22

An Action Plan will be produced to outline the timetable for implementing the Strategy.

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

Policy 23

The Authority will undertake comprehensive monitoring of cycle use, accidents involving cyclists and cycle theft, to confirm its programme of infrastructure development and to measure progress towards its targets.

Policy 24

The Authority will seek to ensure adequate staffing levels and expertise to meet the targeted increase in cycling as a mode of transport.

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

Policy 25

The Authority will seek to identify an expansion of funding sources for cycling, retain established budgets and ensure that schemes funded from other sources incorporate cycle friendly features in order to meet the targets that have been set.

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.

Our Response to the above

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.

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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