Going round in circles on Stratford High Street

Transport for London have created a video to explain how you turn right on a bicycle at major junctions on the Superhighway 2 Extension on Stratford High Street.

It is described as a ‘two stage right turn’, but in reality it looks a bit more complicated than that. In fact, much more complicated than that.

Screen shot 2013-08-29 at 19.15.36The procedure for turning right is

  • to progress through the junction – indeed, some distance beyond it
  • to turn left and mount the pavement
  • double back on yourself
  • to rejoin the carriageway in the ASL, before proceeding on the next green signal.

It goes without saying that this is far from obvious. Indeed, the fact that a video explanation has had to be prepared about how to ‘use’ this junction shows how complicated it is.

There is absolutely no reason why a two-stage right turn – the standard way of making these kinds of movements on equivalent Danish or Dutch junctions – needs to be this counterintuitive. What is being created here is a mess, that puts those on foot, and those on bicycles, into conflict.

It should surely have been simpler to provide a direct route to the ASL on the south side of the carriageway. This is, in fact, the kind of arrangement that is being proposed at a junction in Southampton, with a ‘waiting pocket’ that you can enter easily, and wait for a green signal to make your second crossing (thanks to Phil Marshall for reminding me).

Screen shot 2013-08-29 at 22.38.30This is close to the Danish approach  of simply waiting at the side of the road for your second crossing. Now I don’t think it is anywhere near as good as the Dutch approach, which protects you while waiting, and also allows ‘free’ left turns at all times. But it would be really easy to implement, and would involve no conflict with pedestrians, as well as being much more direct and understandable than what Transport for London are currently going to build.

As many people pointed out on Twitter, the sign says it all.

As many people pointed out on Twitter, the sign says it all.

TfL can’t say they weren’t warned; the Cycling Embassy response to the consultation had this to say –

The method for making right turns at the large junction of Rick Roberts Way appears to be by progressing through the junction, then mounting the pavement to enter the ASL in the side road, and waiting for a green signal. While this allows right turns to be made without having to negotiate across multiple lanes of motor traffic, and resembles (in principle) the Danish ‘left hook’ method of making these turns, we feel that there is possibility for confusion, and conflict with pedestrians. We would like to see dedicated cycle-specific waiting areas for those on cycles waiting to complete the second stage of a right turn, either on the Danish model, or the superior design of the Dutch model, which incorporates protected kerbs.

These suggestions have obviously been ignored. 

The presence of ASLs on the main carriageway itself is revealing, because it demonstrates that Transport for London do not expect people to use this design. The ASLs are there for those people who, quite reasonably, do not want to waste their time faffing around doing 270° turns on the pavement. But this is what happens when you design for two different categories of cyclist.

As I wrote in a long post way back in May last year, if you start from the assumption that ‘fast cyclists’ won’t want to use what you are designing before you have even built it, then you open the door to compromise. Namely, the construction of slow, fiddly rubbish just like what we are seeing at this junction, ‘designed’ for those ‘nervous’ or ‘less confident’ cyclists who apparently don’t mind being unnecessarily inconvenienced (it is curious why it is nearly always assumed that people who don’t like cycling in motor traffic are happy to take so much longer to reach their destination).

The Dutch, by contrast, design infrastructure that everybody on a bike wants to use, and will use; infrastructure that is both objectively and subjectively safe, and fast and convenient for all users, regardless of age, speed or ability. Quality is ensured when you create designs that cater for everyone.

One kind of user.

One kind of user.

Another kind of user.

Another kind of user.

Is this lesson being learned?

Posted in Boris Johnson, Cycle Superhighways, Cycling policy, Go Dutch, Infrastructure, LCC, London, Subjective safety, The Netherlands, Transport for London | 26 Comments

What is ‘clutter’?

Eric Pickles was in the news again yesterday with his fourth pronouncement – within a matter of weeks – on car parking. It comes ahead of some new Department for Communities and Local Government (DCLG) guidance that will, apparently, aim to make sure councils do not ‘undermine’ themselves with parking policies that make parking and driving in towns too difficult.

Pickles seems obsessed by the idea that High Street decline is entirely a consequence of the alleged onerousness of driving and parking within towns. This new guidance – to appear later this week – is accompanied by Pickles arguing that

“Anti-car measures are driving motorists into the arms of internet retailers and out of town superstores, taking their custom with them. Over-zealous parking wardens have inflicting real damage on local economies and given many towns and councils a bad name. Town Halls need to ditch their anti-car dogma. Making it easier to park will help support local shops, local jobs and tourism.”

Evidence for these assertions remains lacking. Indeed the document Pickles seems to refers to [pdf] on parking seems to contradict what he is arguing (H/T John Dales); namely, it shows that there is no clear relationship between footfall and the cost and availability of car parking.

In another soundbite, Pickles argues

“Draconian Town Hall parking policies and street clutter can make driving into town centres unnecessarily stressful and actually create more congestion because of lack of places to park.”

Again, no evidence for the assertion that a lack of places to park is creating congestion.

To be clear, I have no particular problem with car parking being provided for those who wish to drive to town centres, at a reasonable price. But what Pickles – and indeed his department – seem to be arguing is that car parking should be provided exactly where motorists want it to be. Right on the High Street itself; right outside the shops people want to visit.

It is surely this thinking about the ‘convenience’ of parking that lies behind Pickles’ silly ideas about allowing people to park on double yellow lines for short periods; the notion that a short walk from a car park to the places people actually want to shop or visit is incredibly difficult, or off-putting. Parking must be provided right where people want it, because we can’t expect them to use their legs.

Applying these kinds of policies would be tremendously counter-productive, because it would destroy the attractiveness of high streets. We know that pleasant, thriving streets – the ones people want to visit – are the ones where traffic and parking is restricted. There may be parking nearby, but the street itself is free from parked vehicles, and motor traffic in general.

By contrast, streets where driving is easy, and parking is provided directly outside shops, are usually awful, unattractive places, even if they lie in prime locations.

The A24 in the centre of Morden, south London

The A24 in the centre of Morden, south London

These are not thriving places. They are places where the street environment has been poisoned by accommodating motor traffic.

The most curious aspect of Pickles’ arguments is his opposition to ‘clutter’, or ‘unnecessary physical constraints’; the clutter that makes ‘driving into town centres unnecessarily stressful’.In another quote provided to the press, he argues that

“street clutter is a blight, as the excessive or insensitive use of traffic signs and other street furniture has a negative impact on the success of the street as a place.”

From a man who seems hell-bent on increasing the amount of motor vehicles cluttering up our streets, this is a curious approach. To my mind, this is a cluttered street –

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Pickles doesn’t seemed concerned at all about this kind of clutter, concerning himself instead with intrusive signs, or bollards, or humps, which he thinks discourage people from driving. But this is just complete nonsense. Streets clogged with motor vehicles like this are unpleasant places.

There is a good example in my town, where the council has commendably taken action to convert a horrible, traffic-filled street into a place where people actually might want to hang around. About ten years ago, it looked like this –

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Just ghastly for anyone who wanted to visit the shops here on foot – that is, everyone.

About three years ago the street scene was improved with a ‘shared space’ surface, with restrictions on motor traffic to just loading and disabled access. Then last year the street was closed fully to motor traffic during the day, so the restaurants could use the space, and people could go about their business without having to worry about motor traffic.

The picture below was taken today, at the same location. Judge for yourself the difference to this street, from closing it to motor traffic and removing parking.

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Now of course I suspect many people here did arrive by car; not many people walk or cycle (or take the bus) into Horsham. However these motorists simply used the many car parks in Horsham, and then walked to the streets they wanted to visit. The same is true for most of the people walking on the streets in Horsham’s centre, which is now almost entirely pedestrianised. These people have not been put off by a bit of walking.

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Scenes like these would be destroyed by allowing parking anywhere on double yellow lines, or by by removing these constraints on motor traffic. Councils like Horsham would kill the very thing that makes High Streets attractive; they’ve worked this out form themselves.

Eric Pickles seems to want to declare a war on clutter; on bollards like this

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that stop people from driving and parking wherever they want. The clutter and unpleasantness that inevitably results when you remove restrictions on motor traffic in town centres is, amazingly, completely invisible to him. It’s shockingly shortsighted.

Posted in Absurd transport solutions, Bollards, Car dependence, Eric Pickles, Horsham, Infrastructure, Parking, Pedestrianisation, Permeability, Shared Space | 22 Comments

Southwark reverses away from ‘Going Dutch’

In the wider policy context of how cycling should be catered for on London’s streets, there’s some fairly astonishing guidance being drafted by Southwark Council on cycle lanes. It’s so weak that I think it is fair to say, as Southwark Green Party are arguing, that it represents a ‘U-turn’ on the council’s prior commitment to Going Dutch.

The Greens write

Cllr John [Labour leader of Southwark Council] promised to change the council’s approach last year following a campaign of tens of thousands of cyclists calling for more protection on main roads. In March 2012, Cllr Peter John appeared to sign up to the “Go Dutch” principles, telling Southwark News that the existing policy of integrating cyclists with main traffic “was not the best strategy”, and said his change of heart came “since the meeting with Southwark Cyclists” where they presented a new set of policies including proper, protected cycle lanes.

Last year’s change of heart does not appear to be reflected in this guidance, which seems to go out of its way to ‘integrate’ cyclists in Southwark with motor traffic.

On the very first page, we have this table, setting out Use Requirements.

Screen shot 2013-08-21 at 16.23.55

The important points to note here are that, in principle, no cycle lane is to be provided at all on any street with a 20 mph limit, apparently regardless of the volume of motor traffic on that street. Worse, on 30 mph streets cycle lanes are only to be used ‘potentially’, on a ‘case specific basis’ – and that if employed they should only be advisory, rather than mandatory, meaning motor vehicles are free to drive and park in them.

These proposals are explored in greater detail in the guidance, which states, in Section 2.2 –

With-flow cycle lanes should not generally be necessary on two-way 20mph streets. Other methods to improve the carriageway environment to make it safe and comfortable for cyclists should be used in preference.

‘All alternatives’ to cycle lanes on these streets should be fully explored, and indeed if cycle lanes are encountered in a project area, ‘they should be reviewed with the intention of designing them out if appropriate’. The only reasons given for actually retaining cycle lanes on streets with a 20mph limit are if other options are prohibitively expensive, or for ‘legitimate safety reasons’. And the sole permitted exception for cycle lanes on 20 mph streets is purely for bypassing mode filters; these cycle lanes ‘should not be longer than around 6-8m’.

It’s worth reinforcing, at this point, that cycle lanes on 20 mph streets (good cycle lanes, of course) are extremely common in the Netherlands.

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This residential street in the city of Assen, which has a 30km/h (19mph) speed limit, also has wide, continuous cycle lanes. One of the main purposes of this kind of arrangement is to ensure vehicle speeds are kept low, by narrowing the carriageway and removing the centre line, which creates uncertainly with oncoming motor traffic. But these kinds of arrangements – highly beneficial for cycling – are being explicitly ruled out in this Southwark guidance. 20mph limits mean no cycle lanes.

Indeed the guidance seems really quite keen to do away with cycle lanes on 30mph roads too; it states that ‘it will need to be demonstrated that… – on balance – a lane is the best means of addressing the needs of cyclists’. Likewise

any existing instances of mandatory or advisory cycle lanes encountered within a project should be reviewed to check that they remain both necessary and are still the best way of meeting cyclists’ needs.

In a cop-out, the guidance states that mandatory cycle lanes (lanes that are illegal to drive in, unlike advisory lanes) should not be introduced, because they are

problematic in terms of cost, street clutter, order making and enforcement. They are also unlikely to provide substantial additional benefit compared with advisory cycle lanes.

Why mandatory lanes cost more, or create more clutter, than advisory ones is not explained.

Concern with visual appearance extends to cycle lanes being painted a particular colour –

Generally, this is only likely to be permitted where cycle lanes on 30mph roads pass side road junctions and an evidenced safety need that could not otherwise be avoided (else addressed via less visually intrusive means) can be demonstrated

And the Appendix states that

guidance also emphasises that – even where providing cycle lanes or cycle tracks would appear justified – they may not always be appropriate for design and safety reasons. This is especially so in urban streets where the road environment can be very complicated because of the frequency of side roads, vehicle crossings, parked vehicles and other turning movements. This is supported by research. In relation to cycle lanes, this suggests that lanes encourage riskier overtaking of cyclists by other road users in some circumstances – even when cyclists are not using them.

Well, the road environment need only be as complicated for cycling as you are willing to make it. Bad cycle lanes will have problems with turning conflicts and parked vehicles, as well as encouraging close overtakes. This isn’t, however, a universal problem with cycle lanes, which can be designed properly.

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The hostility to cycling provision that seeps from this document extends to the ‘segregation’ of cycle lanes, using kerbs. It states

In instances other than [the use of splitter islands to provide occasional physical separation] cycle lanes should not be separated from other vehicle lanes by lengthy kerbs or extended reservations/traffic islands. [my emphasis]

The reasons given for this policy are quite remarkable –

Creation of kerb separated cycle lanes is generally discouraged by national guidance owing to the considerable road safety issues that they pose – both for cyclists themselves and other road users. In addition, feasibility is likely to be limited within busy London streets owing to various factors. These include: spatial and engineering constraints; the considerable additional cost of adapting roads to accommodate such facilities (compared to other interventions to assist cyclists); and likely opposition from other street users to proposals (for instance in relation to loss of parking. [my emphasis]

At a time when separated tracks are now being adopted as policy across London (and indeed at a national and international level), Southwark have chosen to insist that they pose ‘considerable road safety issues’, based presumably on the opinions of dinosaurs like John Franklin.

The second part of the explanation essentially amounts to ‘we can’t be bothered.’

It is most interesting that the justification in this guidance for the refusal to build infrastructure, or to provide cycle lanes, lies with the Hierarchy of Provision (cited, wrongly, in “LTN 1/10 Cycle Infrastructure Design”, rather than LTN 2/08). Southwark’s guidance refers to it as follows –

Designers are encouraged to consider first reducing traffic speeds and volumes so that cyclists can share the carriageway with other vehicles without the need for any form of special facility. Designers are advised to consider the reallocation of carriageway space to create cycle lanes or the creation of segregated off-road routes only where reducing traffic speeds and volumes would not be possible

I think this is a textbook example of how the Hierarchy of Provision is open to exploitation by councils who find it difficult to bring themselves to cater for cycling in any meaningful way. They can point to LTN 2/08, and reference it, copying its argument that cycle lanes and tracks should only be considered last after other measures like speed reduction or traffic volume reduction – conveniently ignoring how 20 mph limits, in and of themselves, do little to create subjective safety, and how (as in this document) no mention is made of traffic reduction, or removal. Southwark seem to think that a 20mph limit on a given road is enough, and that nothing else is required to make cycling a safe and pleasant experience.

The Hierarchy desperately needs replacing by a network-based guidance approach, which sets out precisely how cycling should be accommodated on a given road street, with a certain volume of motor traffic travelling at a certain speed, and a particular function. That is, guidance which maximises the degree of separation of people riding bikes from motor traffic, either through the removal of through traffic from side streets, or through the physical separation on main roads. I’m hoping this will come in the new revised version of the London Cycle Design Standards; but, at the moment councils like Southwark seem to be able to get away with it.

Posted in Cycling policy, Go Dutch, Infrastructure, London, Subjective safety, The Netherlands | 11 Comments

Just how good is the cycling infrastructure in Bracknell?

A visit to the Transport Research Laboratory on Friday gave me the opportunity to cycle through Bracknell, a New Town designated in 1949.

A gentleman named Pete Owens of Warrington Cycle Campaign (perhaps most famous for the Facility of the Month site) would have you believe that Bracknell – like many other New Towns – is, in effect, a small piece of the Netherlands, parachuted into Britain.

He argues –

For 50 years our planners have bought into the “build it and they will come” segregationist hypothesis. Ever since Stevenage, every new settlement in the country has been built around a segregated cycle network. And it is not just Stevenage and MK – though those are probably the most comprehensive examples, but we have a whole premier leagues worth of “baseball stadia” that have been unremitting failures in terms of encouraging cycling. Indeed they have tended to be the most car dependent towns in the country. They built it and they didn’t come … to Stevenage, to Milton Keynes, to Harlow, to Bracknell, to Hatfield, to Telford, to Livingston, to Warrington … the list goes on.

And it really doesn’t wash claiming that this somehow doesn’t count because these were “botched”. They may not quite be up to the standard of the best examples from the NL (although in the ’70s the Dutch took our new-town planning guidelines as their model), but they certainly meet the central requirement that the segregationists claim is stopping people cycling ie people in these towns do not need to mix with busy traffic. [My emphasis]

The broad thrust of this thesis is that we have already tried the Dutch approach in Britain – specifically, segregation – and that it has failed to bring about mass cycling. Instead, so he argues, we should look instead to places in Britain that eschew cycle tracks – places like Hackney, among others – for how to increase cycling levels.

… it is the constraint on motor vehicles (or lack of it) that is the key to getting folk cycling and that building cycle paths (or not) is entirely irrelevent. This is why mainstream cyclists organisations have been making all along and why limiting traffic volumes and speeds (as they do in NL) are at the top of the hierarchy of measures and cycle specific infrastructure as a last resort.

It is notable that those places in the UK that do have some success at encouraging cycling are those that follow this approach and have reputations as anti-car towns. Hull – with the early take up of widespread traffic calming (though they are now slipping), Oxford – which actively discourages through traffic, Central London – with the congestion charge – and particularly Hackney (the only traffic authority in the country where more people cycle to work than drive) where they explicitly reject the segregationist approach.

Regardless of the relative degrees of success of these two different approaches (not something I wish to get bogged down with here), I have to say that Pete Owens gets it very wrong – astoundingly wrong – when he writes that places like Bracknell are ‘not quite up to the standard of the best examples from the NL’. In reality Bracknell is far, far below the standard of even the very worst Dutch cycling infrastructure.

There are, of course, cycling underpasses in Bracknell, that run under the large roundabouts. This means you can cycle across these roundabouts, without interacting with the heavy traffic on them.

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This is exactly the sort of thing the Dutch do at roundabouts carrying a similar volume of motor traffic (although to a much better standard) –

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So far, so good.

There are also some cycle tracks running around the town. In the main they seem to be some distance from the road network (indeed, if you were driving around Bracknell, you probably wouldn’t ever see a cycle track).

DSCN0057When these cycle tracks have to cross a major road, the solution seemed to be – just as at the large roundabouts – to put the track into an underpass. And in most cases, that means the cycle track has to slope down, then back up again. (You can see how the cycle track in the picture above undulates up and down – this is so the path to the left can pass under a road.)

DSCN0110And another example –DSCN0150

Note how the cycle track – looking quite tired – slopes down substantially into an underpass, while the roads remain flat and continuous.

Underpasses like this are actually rather rare in Dutch towns and cities, and are typically only employed when a very large junction, usually on the periphery, has to be negotiated. In Bracknell, however, I found myself constantly cycling up and down, through numerous underpasses, just to get around. The picture above is taken only a few hundred yards from the shopping precinct in the centre of town. A flat town has been converted into a  hilly one.

Indeed, it was while musing about the large number of underpasses in Bracknell – and why they are so rare in Dutch towns and cities – that I realised why cycling in New Towns was always going to be doomed. And why, despite claims to the contrary from the likes of Pete Owens – they bear absolutely no resemblance to the Dutch approach.

The only form of ‘segregation’ available to their designers, back in the 1950s and 60s, was precisely of this form – placing roads and cycle tracks on different levels. A kind of vertical segregation, that the Dutch employ only when they have to (crossing railways, for instance) or when the volume of motor traffic necessitates it.

By contrast, where cycling is designed (or ‘designed’) at the same level as a particular road or street, Bracknell is just as pitiful as most other towns and cities in Britain.

Where cycle tracks meet distributor roads on the same level, they just give up. They end. Proper provision ceases if you want to cycle along this road.

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Indeed, I was struck by the complete absence of cycle tracks alongside all but the most major roads I encountered, despite copious amounts of space being available (this is a New Town, remember).

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These are not attractive places to ride a bike.DSCN0132

And these roads – which connect cul-de-sacs to the main road network – often do not even have pavements, let alone cycle tracks.DSCN0119

Where cycling ‘infrastructure’ does exist directly alongside roads in Bracknell, in almost all cases I saw it took the form of a shared use pavement.

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These have all the horrible design flaws you would expect at junctions.

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DSCN0067As I have already said, where cycling infrastructure in Bracknell exists at road level, and directly intersects with the motor vehicle network (rather than being placed below it, or far away from it), it is pitiful, with very few exceptions. I did come across this nice junction treatment, but it is a two-way track, shared with pedestrians, and rather over-engineered for the entrance to a cul-de-sac.

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The cul-de-sacs themselves – which should theoretically prioritise cycling, by making driving more indirect – are themselves a problem. In many cases, they are impermeable to cycling; they don’t form through-routes, so the most obvious route is the distributor road, which usually doesn’t have any provision at all, beyond a shared use pavement.

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Other cul-de-sacs do have access through them onto the cycle track behind, but it’s not particularly obvious.

DSCN0080On the right. Behind the wall. Then around the fence.

Typically, in trying to find the most direct route, you will find yourself bumping along a bit of tarmac, unsure of whether you are on a cycle track, a shared use route, or a footpath, until it becomes clear that it’s the latter.

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The ambiguity of these (foot?)paths is obviously problematic, with people apparently cycling in places that were not designed for cycling. Guardrail provides a clue to difficulties or collisions that might have occurred in the past.

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And in Bracknell the rule when it comes to guardrail seems to be ‘too much is never enough’.

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The pedestrianised centre of Bracknell is enclosed by two concentric rings of road, neither of which have any provision for cycling on them. The outer one looks like this –

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And the inner one – ‘The Ring’, which resembles a race track – looks like this –
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Did someone say ‘Dutch’?

The final irony is that in ‘cycling friendly’ Bracknell cycling is not permitted at any time in the shopping precinct at its centre (although a van was driving through while I took this picture).

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It is a sick joke to pretend that Bracknell – or indeed any other New Town that put in similar ‘infrastructure’ to a greater or lesser extent – is anything like a Dutch town, transplanted to the UK. At the time these places were built, there was only a very limited kind of ‘segregation’ on offer, the kind that places cycling far away from roads, either vertically or horizontally, and that has little or nothing to offer whenever cycling provision has to come into close contact with the road network. Given the way cycling was designed for, the only way in which cycling in New Towns could ever have been a comfortable or viable experience would for it have to been placed entirely on a different level from the road network, which would have been monstrous, as well as impractical.

This shouldn’t really be news; as long ago as 1978 Mike Hudson’s Bicycle Planning Book described how the cycling network in a number of New Towns, including Bracknell, was ‘incoherent and incomplete, and often inconsistent’. (Hudson also states that ‘cycle tracks are absent from Hatfield and Warrington’, which contradicts Pete Owens’ claim that they ‘built it’ in these two towns). That incoherence and inconsistency must surely be a direct consequence of the failure to design cycling in – with both objective and subjective safety – at ground level, and across the entirety of the town, not just the provision of underpasses at the biggest roundabouts.

It would be a little unfair to blame the original designers for these problems. In a way, the networks they built did partly function in the way a Dutch cycle network functions today, in terms of insulating anyone cycling from interactions with motor traffic. This is because, back in the 1960s, there was not the volume of motor traffic there is today. Cycling around on the distributor roads (the ones that have horrible shared use pavements today) would most likely have been fairly pleasant and traffic-free, in much the same way you can cycle around Dutch towns and have very few direct interactions with motor traffic. And in the places where motor traffic would have been substantially heavy and off-putting in these New Towns – at the large roundabouts and alongside the dual carriageways – the cycle tracks (albeit limited and circuitous) were usually provided.

But this kind of separation was fragile, and could never last, because it relied upon people not adopting the car as a mode of transport. As increasing numbers of people began to own cars, so the distributor roads would have become less and less subjectively safe, and less pleasant to use by bike. Over time, these roads have been converted to ‘provide’ for cycling, but only by the apparent legalising of cycling on existing pavements. Modern Dutch-style measures to separate cyclists from motor traffic are almost entirely absent. To that extent Bracknell is essentially no different from any other town in Britain, and not in any way an example of how segregation has failed, or will fail, in this country.

Posted in Bracknell, Infrastructure, Subjective safety, The Netherlands, Town planning | 18 Comments

Helmets and appropriate safety clothing

From the Lancashire Evening Post. Presented without comment.

The number of cyclists killed and seriously injured on Lancashire’s roads has almost doubled in a year.

Police said that between April 2013 and July 2013, 53 cyclists were killed and seriously injured on Lancashire’s roads compared to 29 in the same period in 2012.

Now officers are urging cyclists to wear helmets and appropriate safety clothing when riding their bike.

Chief Insp Debbie Howard said: “We have seen an increase in the popularity of cycling in recent years so there are now more cyclists on our roads.

“Despite falling trends in the number of people killed and seriously injured on our roads, the proportion of casualties which cyclists account for is an increasing one.

“Cyclists can leave themselves vulnerable when riding on our roads and we want to remind them of the importance of wearing a cycling helmet and appropriate safety clothing when riding their bike.

Pedal cyclists accounted for seven per cent of all casualties in Lancashire in 2012.

 

Posted in Helmets, Police, Road safety | 10 Comments

Why don’t people cycle in Durham?

A little while ago I visited Durham for a short break. It’s an attractive, small city of around 80,000 inhabitants, with a narrow, historical street pattern that precludes the use of the motor car in much of the centre. Indeed, there is a congestion charge for motorists who wish to access the Durham peninsula.

Given that there is a university here, with 16,000 students, and also that the city centre is only a short ride from much of the outskirts – no more than around 2-3 miles – the bicycle could and should be a predominant form of transport in Durham, despite the city being rather hilly.

Yet in a full 48 hours in the city, spending much of my time walking around as a tourist, I only managed to see a grand total of seven people using a bike. Admittedly, this was (just) out of university term time, but this is a miserable number. I saw thousands of cars being driven around the city, and only a handful of people using bikes, enough to count on my fingers.

But this is evidently not some kind of anomaly. The data I’ve managed to dig out on my return suggests that cycling is next to non-existent in Durham. The figure for cycling commuting share in Durham (which, remember, will be significantly higher than overall cycling mode share) was just 1% in 2001 [pdf], and it seems this figure has not improved in the intervening years.

Only 0.3% of County Durham primary schoolchildren cycle to school, and the figure is not much better for secondary schoolchildren – just 0.7% cycle to school cycle to school ( it is worth noting, incidentally, that five times more children take a taxi to school in this region, than ride a bike.)

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Durham County Council’s literature is filled with pictures of people haring around on mountain bikes in the countryside (see left), which is fine as a leisure pursuit, but isn’t really going to do anything about changing the way everyday journeys are going to be made, and doesn’t suggest serious engagement with the issue of cycling as a mode of transport.

The latest cycling strategy, for 2012-15, is a bit sexier, with some pictures of bikes with wicker baskets in amongst those of people engaging in cycle sport (although the cover again features mountain bikers and pictures of disc brakes), but there doesn’t seem to be any acknowledgement that cycling is going absolutely nowhere in the area, and has been for decades.

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There has, apparently, been a detailed review of the previous cycling strategy, but I can’t find it anywhere on the County Durham website, and the current Cycling Strategy isn’t very helpful in locating it either, listing the website for it as durham.gov.uk/xxxxxxxxx (right). There aren’t any figures for current cycling levels in Durham contained within the document, so there’s absolutely no way of knowing whether cycling is increasing or decreasing. The talk in latest strategy document is encouraging (there is an acknowledgement that behaviour change programmes are unlikely to have any effect without an improvement in physical conditions), but talk is one thing, and actual progress in creating a safe, pleasant and inviting environment for cycling is another.

Another insight into how marginal cycling is in Durham comes from this story about four (yes, just four) bike lockers at Durham bus station, which remained unused for five years, because the council can’t work out how to operate them. Nobody even seemed to notice!

From walking around the city, it’s quite obvious to me why cycling is non-existent in Durham. The main roads I saw were dire.

DSCN9048 DSCN9059 DSCN9031 DSCN9020Fast, wide and open, with absolutely no concession made for anyone daring to ride a bike. It’s impossible to imagine ordinary people choosing to ride on these kinds of roads, mixing with motor traffic.

Despite delays in and out of the city, nobody appeared to have been tempted to cycle instead, to beat the queues.

DSCN8997 DSCN8992It is on these main roads that physical separation from motor traffic is desperately needed, but despite there being plenty of space available, cycle tracks (and not even cycle lanes!) were not in evidence.

Surface and multi-storey car parks cost at least £1.40 for the minimum stay (the multi-storeys rather more), but again this cost does not appear to have prompted locals to opt for cycling into the city instead.

Cycle stands were empty.

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Or littered with the sad, decaying carcasses of bikes that appear to have been there for years.

DSCN8985There is a Sustrans route across the city – part of National Cycle Network 14 – but to call it ‘indirect’ would be generous.

Twice the straight line distance, would you say?

Twice the straight line distance, would you say?

Instead of crossing the large roundabout, and the main dual carriageway bridge over the River Wear (which both feature in the second photograph in the set of ‘main roads’ shown earlier) you are diverted to the south, and then several hundred metres to the north, to cross on an attractive (but rather narrow) pedestrian and cycle bridge.

DSCN9014Absurdly, on the second leg of this diversion (heading south back towards the city) this National Cycle Network Route becomes a one way street, with no exemptions, or cycling permitted.

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People have obviously been taking to the pavement here (which is really quite wide on the other side of the road) to avoid this restriction, but the problem has been solved with a ‘Cyclists Dismount’ sign. Plainly there is no way road space could be reallocated on this busy street. To repeat – National Cycle Network.

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If you can be bothered to get as far as the bridge, then – miraculously – a contraflow cycle lane appears out of nowhere. It is unclear how you are supposed to join it, given that you can’t cycle in the road or on the pavement prior to it.

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You can use it for about 50 metres, and then it promptly gives up as abruptly as it started. Dismount again!

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Your ‘route’ then involves walking up the ramp on the right, to cross to the other side of the dual carriageway, on the bridge. NCN14 then continues on a narrow pavement, fenced off from road, before descending into a really quite scary underpass to return back to the side of the dual carriageway you were originally on.

DSCN9028So the ‘traffic-free’ route is circuitous, stops you cycling in many places, is narrow and unsuitable for heavy cycle flows, and is socially unsafe.

Apart from that, it’s fine.

If you don’t fancy doing this, then your other option is to ‘man up’ and cycle across the bridge, and the two roundabouts at either end.

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No thanks.

DSCN9001Beyond forcing people who might want to cycle to choose between lethal roads and a trek that requires a map, there are many other tiny things in the city that act to make cycling unattractive.

Perfectly serviceable tracks, that become roads into the city centre, are blocked off in ways that make cycling inconvenient, like in the example pictured left.

And besides a huge number of wide one-way streets that have no exemptions or contraflows for cycling, Durham also has restrictions on vehicles accessing some streets at all times, with no exemptions for cycling, despite loading by motor vehicles being allowed at off-peak times.

That means HGVS can legally drive on these streets before 10am, and after 6pm, for loading purposes, but cycling is not allowed at these times (unless they are ‘loading’ perhaps?). Completely illogical.

DSCN8975While some of these locations are probably too busy with pedestrians for cycling to be allowed at peak times, it might at least be worth a trial.

DSCN8974This chap – one of the seven people I saw riding bikes in two whole days – is breaking two rules; cycling the wrong way on a one-way street, and disobeying the ‘no vehicles’ restriction. However, there doesn’t seem to be any sensible reason why cycling should not be allowed on this bridge (which, incidentally, is the only other alternative to the two bridges into the city from the west that have featured already).

I don’t think it would be unreasonable to describe Durham as institutionally anti-cycling. I doubt the city has consciously drawn up plans to design out the use of bikes, but – unconsciously or otherwise – it seems every effort has been taken to ignore cycling, or to make it as unpleasant or as inconvenient as possible. The statistics bear out the results.

Posted in Cycling policy, Durham, Infrastructure, One-way streets, Subjective safety, Sustrans | 70 Comments

Update on Royal College Street

Back in January I blogged enthusiastically about the plans for Royal College Street in Camden, and I’m pleased to say the scheme is nearing completion.

It’s a little hard to make definitive comments because the new arrangement isn’t finished, but what’s there already suggests that this will be an excellent, pleasant and safe street to cycle on. It’s not going to be A-grade Dutch quality, but for the money that has been spent on the entire length of the street – around £50,000 – I think it’s really good value for money.

The old arrangement – a two-way track on one side of the street, kerb-separated from the one-way carriageway – has of course been replaced by single-direction cycle tracks on each side of the street. But the one-way flow for motor vehicles has been maintained.

DSCN0027It is important to stress at this point that removing the one-way systems in Camden – part of the process of ‘gyratory removal’ that is very popular in some campaigning circles – would mean this street reverting to two-way for motor vehicles, and that in turn would mean great difficulty in implementing cycle tracks of this width and quality on it. The space required for two-way flow for motor vehicles here would mean very poor quality cycle tracks, or indeed no cycle tracks at all. Subjective safety would disappear.

By contrast, keeping this street one-way for motor vehicles has allowed a generous amount of road width to be allocated to protected space for cycling. (It also makes driving less convenient, relative to cycling). This is a point I have made before – in the desperate rush to remove one-way systems, we shouldn’t overlook how keeping them in place, but for motor vehicles only, can allow the creation of pleasant streets for cycling, and indeed privilege walking and cycling at the expense of driving. This is a common tactic in the Netherlands, and we should copy it.

The separation between the cycle track and the main carriageway is achieved simply – through heavy box planters (yet to receive the plants on the day I visited).

DSCN0026The width of the track is exactly 2m. This is sufficient to overtake, or to be overtaken, in relative comfort (as in the picture above). However, looking at the width of the street, it seems to me that the tracks could have been substantially wider. A bit of a missed opportunity, but one that I hope can be rectified at a future date (and not at great expense, given the ease with which planters and ‘armadillos’ can be moved, relative to the cost of rebuilding a kerbed cycle track).

The high kerbs between the pavement and the track remain, meaning the full width of the track can’t be used, due to the risk of pedal strike – but replacing all the kerbs on the street would have added substantially to the cost of the scheme.

The protection and separation on the southbound track, on the other side of the street, mostly comes in the form of parked cars. I posted some photographs on Twitter, and I don’t think it was particularly clear – judging by some of the responses – that the vehicles nearest the cycle track are parked. But that’s the arrangement.

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The parking bay is separated from the track by the humped ‘armadillos’, bolted to the road (these also appear on the other side of the street, between the planters). They seemed to be doing a pretty effective job in keeping the parked cars off the cycle track; there isn’t really any reason to park on it in any case, with the marked parking bays. The Ranty Highwayman did point out to me that these ‘armadillos’ could constitute a trip hazard, especially as they are new and therefore unfamiliar, and not particularly visible. I don’t know if there’s any particular solution to this problem!

As I was heading south, I noticed a van driver parking up and getting out of his vehicle, helpfully providing an illustration of how much infringement there is on the cycle track from a vehicle door.

DSCN0036There’s enough space there to swerve around an opening door.

Of course the risk of ‘dooring’ remains, but is lower than it might first appear. For a start, the drivers will be looking forwards, towards where bike users are coming from, different than the usual ‘dooring’ problems which result from a failure to use mirrors, or to look over one’s shoulder.

In addition, open car doors will be at an obtuse angle to oncoming bike users, meaning an impact – if it occurs – will be a glancing blow, pushing the car door shut again, rather than a halting impact straight into an unyielding door. And finally, any bike user unfortunate enough to be hit will not be deflected into the path of passing motor vehicles; only over to the side of the track, or onto the pavement, where the risk of further injury is much lower.

It was really enjoyable cycling up and down the street – I did so several times! – especially cycling southbound, which felt really comfortable and safe. There is an issue, however, at the very end of the street, where you wait at a light to cross St Pancras Road.

DSCN0043The vehicles heading into Royal College Street (towards the camera) are queuing in two rows at the lights (in the left of the photograph), even though Royal College Street is a single carriageway road. That means there is some jostling for position as they set off from the lights, with vehicles cutting the corner, right across the place where you are waiting at the stop line, which is quite unnerving. The driver of the car in the picture below seemed determined to get there ahead of the taxi beside him, passing within a foot or so of where I was waiting.

DSCN0044The stop line here does feel quite exposed, and could do with some form of physical protection, or with moving back slightly to the point of the last armadillo.

The crossing as a whole, however, is quite neat, with the two tracks on either side of the street converging in one crossing point, and ‘elephants’ feet’ marking the crossing routes.

DSCN0025The other big issue that deserves comment is that of the bus stops, which are ‘Danish style’, in that bus passengers alight directly onto the cycle track itself.

Royal College Street bus stopThe only concession here is that the cycle track is raised up to pavement level, the hump presumably aimed at slowing those on bikes, as well as raising the bus stop to pavement level.

It’s not ideal, but from the couple of buses I saw stopping on the street, enough common sense was being exercised by all parties for the arrangement to work reasonably well. People stepping off the buses seemed aware they weren’t stepping on to a pavement, but onto somewhere they were going to encounter bikes, and likewise people approaching the bus stops in the cycle track were sensible enough to realise that there would be potential conflict.

I even managed to video myself cycling across the bus stop as a bus stopped and people got off.

I guess this will be typical behaviour. Hopefully everyone riding a bike will approach the bus stop, when a bus is stopping, in a similarly slow and cautious manner, and the people getting off the bus will be aware of what they are stepping onto.

These are not busy bus stops, with only one small bus stopping on this street at infrequent intervals, so I don’t think there will be difficulties here. But some pedestrian comfort has been lost.

So there are some minor niggles about this scheme, but it is really hard to complain about it, when it has cost so little, and it is so far ahead of pretty much anything else that exists on the streets of London right now. From what I could see when I visited, it is already very popular – despite still being under construction.

I look forward to it being finished!

Posted in Go Dutch, Infrastructure, London, One-way streets, Subjective safety, The Netherlands | 15 Comments

British Social Attitudes Survey 2012: public attitudes towards transport

The annual British Social Attitudes Survey covering attitudes towards transport was published last month. The report is worth a read in its own right, but there are are some very interesting details that deserve highlighting.

The Survey confirms what we already know from reports like the National Travel Survey – that a huge number of short trips continue to be made by private car in Britain. The NTS revealed that nearly 40% of all British trips under two miles are made by car.

Courtesy of Joe Dunckley

The Social Attitudes Survey tells us something slightly different, namely that

On average, respondents reported making five journeys of less than two miles by car in a typical week

This is an average figure, so some respondents will be making fewer than five trips of under two miles by car per week, and some rather more. Nevertheless it’s a pretty astonishing figure, one that reflects the lack of attractive alternatives for trips of this length. The cost in terms of congestion, public health, infrastructure repair, environmental damage, happiness, and loss of amenity that lies behind these kinds of figures is staggering, but the present government do not seem to have any interest in addressing this issue (indeed, they seem rather inclined to make it worse, judging by recent policy pronouncements from the Communities Secretary).

Unsurprisingly it is danger and lack of safety that play a significant part in keeping people from using bicycles for these short trips. The Attitudes Survey reveals that 65% of ‘non-cyclists’ feel it is too dangerous for them to cycle on the roads. Even 48% of ‘cyclists’ similarly agree that it is too dangerous for them to cycle on the roads – presumably these are people who take their bikes on holiday, or who find places to ride away from roads.

Subjective safety affects females more than males, with 66% of females saying it is too dangerous for them to cycle on the roads, compared with 53% of all males.

Screen shot 2013-08-08 at 23.52.35This figure is even worse for the elderly – 73% of those aged 65+ feel that the roads are too dangerous for them to cycle on. Indeed, the older people get, the less keen they are on riding with traffic. These figures are abysmal – the vast majority of females, and of the elderly, are simply excluded from British roads.

Screen shot 2013-08-08 at 23.54.34Another interesting detail from the Survey is that trying to persuade people to cycle on environmental grounds currently seems doomed to failure. The Survey reveals a steady downward trend in the degree of concern about exhaust fumes in urban areas –

Screen shot 2013-08-08 at 23.55.27… and although 78% of respondents agree that climate change is taking place as a result of human activity, only 39% of people said they would be willing to reduce the amount they travel by car. 62% of respondents did not feel that car users should pay more for the sake of the environment. (It is noteworthy, however, that there is increasing public support for making driving cheaper for those with cars that are less polluting). This evidence suggests that trying to price people out of their cars will meet with stiff opposition, certainly without attractive alternatives.

Likewise, the failure to make cycling a reasonable and pleasant option for short urban trips surely lies behind public resistance to making driving itself less easy. While the Survey demonstrates that people are increasingly in favour of 20 mph limits on residential streets (now up to 72% in favour), resistance to closing residential streets to motor traffic is at an all-time high. Only 31% of respondents were in favour of these kind of closures, part of a continuous downward trend from 51% in favour in the year 2000.

Make of that what you will!

Posted in 20 mph limits, Car dependence, Cycling policy, Infrastructure, Subjective safety | 9 Comments

The psychology of riding on the pavement, and jumping red lights

Plenty of excellent stuff has already been written about the woefulness of the material that has finally emerged today from the Nice Way Code. I’m not going to add to that, because there’s really no need! What I would like to do instead is take a look at the real reasons people cycle through red lights, or cycle on the pavement, because as far as I can tell, those behind the Nice Way Code campaign have dismally failed to grasp what motivates this kind of behaviour.

A clue to where they’re coming from lies in their ‘Don’t Give Cyclists a Bad Name!’ video that appeared yesterday.

As was pointed out yesterday, the red light jumping behaviour being re-enacted in the video doesn’t really correspond to the way red lights are jumped by those motivated to do so while cycling.

We see the actress approaching the lights, and as they go to amber, she gives a ‘determined’ expression, and accelerates –

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Passing into the junction just as the lights turn from red to amber.

To give this behaviour its official term, this is amber gambling – something motorists do with extraordinary regularity. Stand on any junction where there are significant queues, and you’ll see it happen repeatedly. Indeed, it’s how motorists generally jump red lights; by chancing their way through the junction just after the lights have changed.

However, this is not the way people on bikes generally jump red lights. They do so by inching their way across the junction in stages, using islands in the middle if they are available. (There is an example in the masthead at the top of this blog.) Or, they may choose to pedal through what they know is a pedestrian phase on the lights, when all the lights on a junction are green for pedestrians, and they know no motorists will be driving through the junction.

Obviously this kind of behaviour can be anti-social, and indeed dangerous if carried out with little regard for the safety of pedestrians. But in general it takes the form of ‘creeping’, a slow and progressive trundle through the junction, looking and watching to see where traffic is coming from. There’s a good reason for this slow and careful behaviour; if you’re on a bike, you really don’t want to get hit by a motor vehicle.

So why do it? Clearly a minority of people are doing it because they are impatient. But a much more important reason is, I think, an eagerness to get away from the motor traffic stacked up behind you. This is part of the reason I and many other people dislike Advanced Stop Lines (ASLs). They put you right in front of a revving array of motor vehicles that will be faster at accelerating than you, and eager to get back past you. It’s like being a small mammal placed in front of some fast and angry bears.

Once I’d left the tranquility of the closed roads of the FreeCycle circuit in central London last Saturday, I found myself heading along Horseferry Road, cycling towards a pub for a post-ride meeting with friends. Just before I got to the pub, I caught a red light at this junction –

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It’s a little hard to see, but on the other side of the junction – where I was headed – there are parked cars, right beside a central island.

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A fairly typical ‘pinch point’. So as the lights turned green, I pedalled off as fast as I could, a small mammal pursued by a horde of angry bears, all heading into this narrowing gap. Of course they all wanted to get ahead of me before this gap, so I had to fight my out into the stream of bears coming past me.

It was unpleasant. To avoid it, I could (and probably should) have trundled my way across the junction, through a red light (gasp!), while the lights were green for pedestrians. I would have escaped from the junction, and been far away, a good distance down the road at the moment the lights turned green and all the hard acceleration and revving occurred.

This is why so many people jump red lights; a desire for subjective safety, to be away from the fast angry bears, rather than stuck right in front of them waiting for the signal that will release them from captivity behind you.

I’ve chatted with friends about the delicious feeling of cycling through a junction just as the lights turn to amber, because doing so comes with the knowledge that you will have momentary respite from motor traffic being behind you. Rather than ASLs, I’ve often thought that I would probably prefer a box that places me at the rear of a queue of traffic, so that I am the last thing to go through the junction on a given green phase. Why would anyone ordinary person want to place themselves back in front of fast heavy traffic, that has just barrelled past them on the way to the traffic lights?

But it doesn’t seem that the Nice Way Code have paid a moment’s thought to the reasons why people jump red lights. Not only does their video show a cyclist jumping a red light like a driver would, instead of the way cyclists typically jump red lights (as described here), but they seem to have framed red light jumping by cyclists as some kind of ‘cheekiness’, the behaviour of a miscreant child who should really know better. ‘Respect the rules’, says the campaign, as if this was merely a matter of naughtiness.

In other words, the campaign is being presented to those cycle directly from the viewpoint of people who drive, not from the perspective of people who are currently tempted to jump lights while cycling.

The same failure of understanding appears in the Nice Way Code’s treatment of pavement cycling, presenting it as childish, and something you should ‘grow out of’.

Pavement cyclingWill people too terrified to cycle on the road chose to stop using the pavement now they’ve been told it’s ‘mature’ to use the road? I doubt it. The message here is basically ‘man up’; but that’s not going to work on the people who aren’t willing to ride on the road in the first place.

Pavement cycling is fairly common on this bit of road in Horsham.

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It’s the principal route in and out of the town from the north, and one of the few routes over the railway line that divides the town. How many people currently cycling on the pavement here might be persuaded to ride on the road by a campaign that tells them they are immature? None at all.

It would have been more useful to ask people who do cycle on the pavement to dismount and walk when they are around pedestrians; but that would have involved thinking about this issue from the perspective of the people this campaign is trying to target, instead of one that simply assumes people who ride on the pavement are fully-grown children who need to be shamed into being more ‘mature’. This attitude is quite prevalent among cycling groups, who think people on the pavement need to ‘grow up’ and get on the road – I hope this aspect of the campaign hasn’t emanated from the groups lending their support to the Nice Way Code.

So, in summary, the two kinds of cycling misbehaviour that the Nice Way Code is trying to change haven’t been understood in any sensible or meaningful way. It leads me to believe that they have only been included in the interests of ‘balance’ – and indeed presented from the perspective of  motorists – purely in order to create the impression that ‘all users’ are being targeted by the campaign. Pretty miserable stuff.

Posted in Road safety, Stereotyping | 61 Comments

More on the Nice Way Code – research

Robert Wright (a.k.a. The Invisible Visible Man) left this perceptive comment on the Nice Way Code website on Monday

Have you considered the possibility that you’ve simply completely misdiagnosed the problem? The problem isn’t that cyclists, pedestrians and motorists are treating each other with too little respect. It’s surely that motor vehicles kill lots of other road users and motorists don’t realise that’s mostly motorists’ fault. Under those circumstances, “addressing all road users” is an insult. It’s like addressing rapists and their victims as equal parties.

All the research I’ve seen says the majority of cyclist/motorist crashes are the motorist’s fault. I’m not so sure on pedestrians but I’d bet that motor vehicle speed and inattention are the main issues there too. You’re legitimising motorist misbehaviour by addressing the victims as if they were also perpetrators.

That’s pretty much it. This comment on Twitter from Michael Macleod expressed much the same point, but more succinctly.

Amazing that with five years of rising cycle deaths (nine cyclists already killed in 2013) in Scotland, the response is “be nicer.” 

People walking and cycling about are not killing or injuring motorists in great numbers. By contrast, motor vehicles are killing and seriously injuring pedestrians and cyclists in large numbers, and in the majority of cases, it is the motorist’s fault.

In the light of these facts, it seems completely bizarre to focus on asking all parties to behave nicely, instead of focusing on a root cause of the problem – poor behaviour from motorists, ranging from inattention, right up to dangerous driving. (This is to say nothing of how the Nice Way Code is being funded from the Sustainable Transport budget, instead of from funding that might impinge upon motoring).

The Nice Way Code website responded to Robert Wright’s comment –

Hi invisiblevisibleman,

Our research showed that an even-handed approach would be the most effective way to reach to all road users, rather than singling out any one group. Drivers are obviously a hugely important part of this, but all of our testing showed if you single them out, they will not listen. We need them to listen, so we’re speaking to all road users. We ‘re not saying all behaviours are equal – we’re just saying everyone can play a part in making the roads a safer place.

The claim here is that a road safety campaign that targets drivers – and drivers alone – would be ineffective, because drivers ‘will not listen’. In order to get drivers to pay attention, the Nice Way Code therefore has to simultaneously present messages to pedestrians and bicycle users (like ‘tolerate HGVs’ and ‘don’t cycle on the pavement’). That’s why the Nice Way Code is so ‘even-handed’, asking everyone to play their part in making the roads a safer place – because apparently drivers won’t respond to a campaign that doesn’t ask pedestrians and cyclists to play nicely too. It seems the Nice Way Code don’t think drivers can be asked to behave without messages about cyclists riding on the pavement being tacked on too.

I find this quite odd – safety campaigns are frequently aimed solely at drivers (for instance on drink driving) – and said so in a comment that remains in moderation long after many others have been approved.

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So my question about the testing that has informed the Nice Way Code that drivers ‘will not listen’ to a safety campaign that happens to target them, and not pedestrians, remains unanswered.

Gary Dawes subsequently asked if the research was going to be published, but didn’t receive an answer either.

Given that this campaign is costing £424,000 of public money, it would be ‘nice’ to see the research which has justified its approach. Where is it? 

Posted in Road safety | 15 Comments