Memorandum from CTC (RS 26)
INTRODUCTION
1. CTC, the national cyclists' organisation,
was founded in 1878. CTC has 70,000 members and supporters, provides
a range of information and legal services to cyclists, organises
cycling events, and represents the interests of cyclists and cycling
on issues of public policy. We welcome the opportunity to respond
to this inquiry.
2. We welcome many of the proposals put
forward in the PACTS report, Beyond 2010, particularly the links
it draws between road safety policy and the twin crises of obesity
and climate change. Although the Government is proud of its overall
record on road safety, Britain is still a poor performer compared
with our European neighbours on the safety of pedestrians, cyclists
and children (see paragraph 9). Road safety's most important contribution
towards health and sustainability objectives surely lies in improving
the safety of these particular groups. Hence it is particularly
regrettable that the paragraphs on road safety in "Towards
a Sustainable Transport System" (the Government's response
to the Eddington and Stern Reviews)[40]
fail to mention walking and cycling at all.
3. Our proposals echo many of those in the
PACTS report, notably its call for 20 mph to be the default speed
limit for urban streets.[41]
We also advocate reduced speeds on rural roads, addressing attitudes
towards and training amongst cyclists and drivers, traffic law
and enforcement, promotion of cycling, cycle friendly infrastructure
and safer vehicles.
4. A key principle underlying our response
is the strong (and growing) pool of academic and empirical evidence
that cyclists gain from "safety in numbers"ie
the more people who cycle, the safer it becomes (NB the same goes
also for pedestrians). Evidence suggests that a doubling of cycling
would only lead to a 32% increase in casualties[42]
and hence a significant overall improvement in cyclists' safety
(the Government has acknowledged this in recent guidance on the
appraisal of walking and cycling schemes).[43]
Cyclists also impose very little danger on other road users (see
paragraph 36). Hence increased cycle use has wider benefits for
the safety of all road users, not to mention its wider benefits
in tackling congestion and promoting social inclusion, health
and sustainability.
To what extent have targets for casualty reduction
been a useful tool for focusing professional activity?
5. Current targets for casualty reduction
have not helped vulnerable road users and in some areas have been
very damaging. The decision to adopt absolute numbers rather than
rate-based figures has led some local authorities to conclude
that reducing cycle use would help them meet their targets (and
vice versa), and hence to adopt policies which deter rather than
encourage walking and cycling.
6. This approach manifests itself particularly
in road safety awareness campaigns which use shock tactics to
impress on people (particularly children) that cycling is "dangerous".
This is unhelpful given that the Government itself acknowledge
that cycling's health benefits alone far outweigh the risks involved,[44]
and that you are in fact about as (un)likely to be killed in a
mile of cycling as a mile of walking.[45]
Such campaigns may even be counter-productive to cyclists' safetydeterring
people from cycling (or allowing their children to cycle) risks
undermining their "safety in numbers" benefits. Since
its much criticised (and initially factually inaccurate) "Cyclesense"
campaign,[46]
the Department for Transport has rightly desisted from such initiatives.
However examples are still widespread at the local level.[47],
[48]
7. Targets for casualty reduction have also
led to risk-averse behaviours amongst road safety professionals
and a systematic failure to adopt innovative approaches to road
safety on a wider basis, such as the principles of "shared
space."[49]
What further measures need to be adopted to reduce
deaths and injuries arising from drinking and driving?
8. The blood alcohol limit must be reduced
to 50 mg for most drivers and to zero for novice drivers. The
UK has the one of the highest blood alcohol limits in Europejust
5 out of 27 EU countries have a limit equal to or above that in
the UK; eight countries have limits half or below that of the
UK.[50]
Reducing the blood alcohol limit to 50 mg could save 65 lives
a year.[51]
How does Great Britain compare with other EU countries
in its approach to reducing deaths and injuries?
9. Although Britain's road safety record
is in overall terms better than most EU countries, the picture
is much more mixed when it comes to vulnerable road users. The
UK has the highest proportion of pedestrian casualties of any
of its EU peer countries but the third lowest level of walking.[52]
In terms of cycle safety Britain also performs poorly compared
with other European countries. Britain's casualty rate of 36 cyclist
deaths per billion kms travelled is three times worse than in
the Netherlands, where 27% of journeys are made by cycle.[53]
How do approaches in reductions in risk on the
roads compare to those adopted in other modes of transport?
10. Reductions in road casualties over the
last few decades have been proportionately lower than those amongst
other modes of travel. An equivalent to the RAIB or AAIB is sorely
needed to provide expert investigation into road collisions and
"near misses".
11. Whereas "Signals Passed at Danger"
and "near-misses" are thoroughly investigated and their
frequency monitored on the railways and in the air, "close
shaves" on the road are ignored by police when brought to
their attention. CTC members often tell us of the difficulty of
persuading the police to take reports or witness statements of
dangerous incidents, even in cases where serious injuries have
occurred. This not only undermines legal actions against dangerous
drivers, but also deprives road safety officers of the data they
need to carry out their duties to investigate and minimise reported
sources of danger.
Are there specific blockages caused by shortages
of appropriately trained and skilled staff?
12. Part of the explanation for the above
problem is the shortage of police officers trained to investigate
road collisions. This in turn is a consequence of road traffic
policing having been under-prioritised for many years by the Home
Office.
13. There is also a need for traffic engineers
to be better trained in the planning and design of "cycle-friendly
infrastructure". Despite government guidance on this subject
being available since 1996 and a revision in draft form since
2004,[54]
street and junction layouts are often extremely cycle-hostile,
and even the facilities ostensibly provided for cyclists are generally
very poorly designed, often to the point of being positively dangerous.
Councils should be encouraged to adopt Cycle Audit and Cycle Review
procedures, not only because they can lead to more cycle-friendly
design solutions but also because they effectively provide engineers
with "on the job training" in how to "think bike"
when planning or designing highway and traffic management schemes.
"Cycle-friendly infrastructure" is discussed further
in paragraphs 28-30 below.
What further policies, not already widely used,
might be considered for adoption and what evidence there is for
their success?
20 mph urban speed limit
14. We wholeheartedly endorse the recommendation
by PACTS of making 20 mph the default speed limit in urban areas.[55]
Experience from Hull, and elsewhere in continental Europe (eg
in Hilden, Germany and in Graz, Austria where 30 kmh speed limits
cover 76% of the road network) show that 20 mph speed limits have
clear road safety benefits, particularly for non-motorised road
users and children.[56],
[57],
[58]
15. The Commission for Integrated Transport
has found that lower speed limits have wider benefits beyond road
safety. They found that cities which apply 30 kmh limits extensively
(typically between 65% and 85% of the road network) are "transformed
. . . from being noisy, polluted places into vibrant, people-centred
environments as well as facilitating the widespread re-allocation
of street space to PT, cycling and walking to meet increased demand".[59]
16. To facilitate the long-term goal of
achieving the 20 mph default urban speed limit and ensure public
acceptance we believe that greater flexibility must be given to
local authorities to implement widespread 20 mph limits such as
those in Portsmouth. The expanded programme of Cycle Demonstration
Towns, which forms part of Cycling England's recently announced
new funding programme, could provide a valuable opportunity to
pilot the use of "default" 20 mph limits, providing
both evidence and experience which can be used to build support
for rolling out this measure more widely.
17. The Home Office should complete the
long-awaited type-approval for time over distance cameras to enforce
speed limits below 30 mph, thus reducing the need for expensive
and often unpopular road humps and other engineering measures.
18. Greater use should be made of the innovative
approaches to speed reduction advocated in the Government's generally
excellent Manual for Streets (MfS), such as the removal of centre-lines
and "shared space" street designs.[60]
The scope of MfS should be extended from new-build residential
developments to encompass all "streets" where "people"
are more important than "traffic".
Reduced speeds on rural roads
19. A disproportionate number of deaths
and serious injuries occur on rural roads. Whereas by 2006 built
up roads have seen a 15% fall in fatalities over the 1994-98 average,
non-built up roads have seen a fall of just 10%.[61]
Speed limits on rural, unclassified roads must be reduced, with
40 mph default, reduced to 30 mph in villages being suitable.
As above, enforcement by time over distance cameras is required.
Driver/cyclist training and attitudes
20. Despite publicity campaigns from Government
and elsewhere, there remains a lack of awareness amongst drivers
of the extent to which higher speeds increase the risk of killing
someone. More drivers and would-be drivers need to be informed
that the chance killing a pedestrian goes up by 5% for every extra
1 mph.[62]
There is similar lack of awareness that using a mobile is as dangerous
as exceeding the drink-drive limit,[63]
and that this is as true for hands-free as for hand-held mobiles.[64]
These messages should be central not only to driver awareness
campaigns but also to the training of novice drivers. People are
more likely to adhere to speed limits and other laws if they understand
the reasoning behind them.
21. Bikeability is the Government's recently
launched cycle training programme based on the National Standard
for Cycle Training. The Government's recent funding allocation
to Cycling England will enable a further 500,000 children to receive
Bikeability training over the next three years.[65]
However we believe that there is still scope to bring Bikeability
training to all children, extend it to teenagers and adults of
all ages. There is good evidence that it is highly effective in
increasing cycle use and improving people's confidence about cycling
(or allowing their children to do so).
22. There is less evidence however about
whether cycle training improves the safety of cyclistsand
such evidence as does exist predates the National Standard.[66]
On the other hand, anecdotal evidence from police forces, driving
instructors and others suggests that cycle trainees turn out to
be better drivers, and pass their driving tests more easily. We
also know that drivers who cycle have a much better understanding
than non-cyclists of what constitutes safe and responsible cycling.
Further research into the safety impacts of cycle training would
therefore help identify its potential contribution to both cyclist
and driver safety, and hence its possible role in either driver
or pre-driver training programmes.
23. The Government should also consider
the possible role of cycle training as a remedy for illegal or
irresponsible cycling, in much the same way that speed awareness
or driver retraining courses are offered to offending drivers.
The justification for taking a similar approach with errant cyclists
is if anything even stronger, given that many cycling offences
are due to the cyclist not having acquired the confidence or training
to be able to ride safely and legally on the roads in the first
place.
Traffic law and enforcement
24. Although the Road Safety Act 2006 will
shortly lead to the introduction of a new offence of causing death
by careless driving, we remain concerned that the legal framework
gives insufficient priority to the safety of vulnerable road users.
The new offence does nothing to clarify the distinction between
what is "careless" and "dangerous" driving,
nor does it remove the vast discrepancies between the sentences
available depending on whether a victim happens to die or "merely"
to be maimed. Where both problems arise (ie where a victim is
maimed by someone whose driving is judged "merely" to
be careless), the courts will still have only derisory penalties
available. We believe the Government needs to keep this area of
the law under review.
25. Vulnerable road user safety is also
under-prioritised by the police, prosecutors and the courts. As
discussed in paragraph 10, CTC members regularly report cases
of the police refusing to attend crash scenes, to take reports
or witness statements or to carry out proper investigations. They
also regularly object to proposals for lower speed limits arguing
that they have insufficient resources. The Health and Safety Executive
also pleads poverty when pressed to take its road safety responsibilities
more seriously. This too should be addressed urgently, given that
a disproportionate number of road collisions involve someone who
is driving for work,[67]
while HGVs have a disproportionate involvement in cyclist fatalities
(see paragraph 31).
26. Since hands-free mobile phones present
a similar level of distraction as ordinary mobile phones we believe
that they must be banned.[68]
27. The Government must follow the lead
of other European countries and introduce an insurance structure
whereby drivers in the event of a collision with a vulnerable
road user are held to be liable unless negligence can be proved
otherwise. There are good arguments of legal principle for making
this change. Although fears are sometimes expressed that it would
add to drivers' insurance premiums, a more likely outcome is it
would lead to safer driving, hence fewer collisionsie the
improvement in road safety could mean reduced payouts as well.
Cycle friendly infrastructure
28. Cyclists persistently complain of the
poor quality of highway and cycle facility design. This was particularly
apparent when 11,000 cyclists complained to their MPs then a draft
rewording of the Highway Code suggested that cyclists should use
cycle facilities "where provided", potentially undermining
their legal position if they decided not to use them for whatever
reason. Work on updating the current 1996 "Cycle Friendly
Infrastructure" guidelines has been in the pipeline for about
five years and, since 2004 the Government has consulted on a poorly
coordinated sequence of guidance notes.[69]
Parliament was assured in December 2006 that the process would
be completed in 2007,[70]
yet even now the Government cannot commit to a publication date,
saying only that they "expect to publish this year".[71]
We are appalled by the lack of urgency in addressing this crucial
issue.
29. We nonetheless welcome the inclusion
in the draft guidelines (and in the Manual for Streetssee
paragraph 18) of a "Hierarchy of Provision",[72]
which advises planners that they should look first solutions involving
traffic reduction, speed reduction or road-space reallocation
before introducing specific cycle facilities. The Hierarchy should
be widely adoptedand we have already highlighted the need
to train planners and engineers in how to implement it (see paragraph
13), Adherence to its principles will reduce conflict between
cyclists and other road users, particularly pedestrians, with
road safety benefits for all concerned.
30. Cycle collisions occur disproportionately
on rural major roads with 21 deaths per million vehicle kmsthe
same as motorcyclesrecorded in 2006.[73]
The failure of the Highways Agency to cater for cyclists and other
vulnerable road users also needs to be addressed. The HA's Non-motorised
User Crossings projects, promised in the Government's Walking
and Cycling Action plan, needs dedicated funding and a timetable
for its completionat present it is unclear when it will
be completed, if ever. Major trunk roads must be audited to ensure
that safe cycle access is provided, either on-road or with wide,
well-maintained cycle tracks where links alongside major roads
are required.
Safer vehicles
31. In 2006 HGVs were involved in just 2.4%
of collisions with pedal cyclists but 16% of cyclists' deaths
occurred as a result of these collisions.[74]
Inclusion of near-side, front-view and wide-angle mirrors need
to be mandated for all lorries together with near-side equipment
to warn the driver of the presence of a cyclist.
32. More needs to be done to improve vehicle
front safety with regard to cyclists. Safety measures promoted
by the European Commission have focused on head-on collisions
with pedestrians, whereas most cycle collisions result in different
impact points on the vehicle.[75]
33. Intelligent Speed Adaptation must be
brought into the motor vehicle fleet, especially in hire-cars
and commercial vehicles, with the incentive to employers that
its use will encourage eco-driving.[76]
34. Use must be made of Event Data Recorders
which gather information on vehicle handling and performance in
the event of a crash. These could be trialled initially in particular
vehicle types or for high-risk driver groups.
What should be the priorities for government in
considering further targets for casualty reduction beyond 2010?
35. Given that 83% of all road casualties
result from collisions involving a motor vehicle (97% for cyclists),
targets for reduction of motor traffic and increasing modal shift
to non-motorised modes of transport must be part of any future
targets.[77]
36. As stated above, priorities must include
tackling the discrepancies in vulnerable road user casualties,
preferably through focussing on rate-based per hour and per trip
casualty reduction targets. These rate-based targets for casualty
reduction must be based not just on exposure to risk but also
the level to which each road user poses risks to othersout
of the 13,182 collisions between cars and cycles in 2006, 78 cyclists
and 0 car users were killed, 99% of cyclists were casualties from
these collisions, whereas just 2.7% of car users were slightly
injured.[78]
Setting rate-based targets would make it clear that the aim should
be to achieve "more" as well as "safer" cycling,
rather than seeing these objectives as being in conflict with
one another (see paragraphs 5-7).
37. Sheer volumes and fear of traffic are
two of the chief deterrents to cyclingamongst non-cyclists
around 61% of one survey's respondents agreed or very much agreed
that "fear of traffic would frighten them".[79]
The perception of safety is one of the chief barriers to higher
levels of walking and cycling, therefore qualitative data on the
perception of the safety on the roads, especially with regard
to walking and cycling, must be included in any future targets.
38. Rigorous enforcement and reduction of
speed limits must be a priority for the next decade of road safety
activities. A default 20 mph speed limit, such as recently proposed
by the Mayor of London,[80]
would, we believe, do more than anything else to reduce road casualties.
Targets for proportion of the road network reduced in speed limits
and adherence of traffic to these speeds must be adopted.
39. With the theme of climate change assuming
ever greater attention in wider policy we believe that this should
be reflected in the priorities for the next Road Safety Strategy.
The importance of road safety policy in tackling greenhouse emissions
from the transport sector cannot be overstated. If people are
to be encouraged to reduce the carbon footprint caused by their
travel, then it is essential to create conditions outside their
front doors where they feel able to walk and cycle in safety,
and to allow their children to do likewise.
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