Here are my notes which I plan to forward to TfL in response to their Cycle Safety Action Plan https://consultations.tfl.gov.uk/cycling/draft-safety-action-plan
CASP 2 draft feedback
General points additions and amendments:
While safety is and should be at the heart, cycling promotion should also be explictly stated from the outset. Promotion of Active travel needs to be stated and included in the 6 road safety commitments to include a target for increasing trips by bike. While this may not seem a pure road safety commitment more people cycling (and walking) and the effect of this in getting drivers used to sharing the road with cyclists helps greatly to improve road safety.
With a view to promoting cycling and taking into account the current lack of any legislation regarding the wearing of helmets we think that the images on the front showing every person on a bike wearing a helmet isn't balanced or realistic. Change the front cover to show a mixture of helmeted and helmetless cyclists. (images throughout the rst of the doc are more balanced
Vulnerable road users (VRUs). While it is easy to categorise people out of cars as VRUs and to focus the CSAP (and MCSAP/PSAP) on VRUs we think a better focus and more in line with a general harm reduction focus is to prioritise actions around the groups which CAUSE the most harm rather than the current focus on people who get harmed. This would create a significantly stronger document and send the message that people liable to cause harm need to be managed and therefore there needs to be a stronger emphasis on driving skills and enforcement of bad driver behavior. This point doesn't negate the need to up-skill cyclists at all but recognises that a mistake by a cyclist or pedestrian is much less likely to harm other people whereas a mistake (or recklessness by) a driver is more likely to harm others.
So based on the above comment we believe that this document should start with a focus on the people who cause the harm rather than the victims. On p13 there is an analysis of who kills or seriously injures cyclists which is good. On page 16 there is an analysis based on evidence as to what drivers do that kill or seriously injure cyclists This analysis is good and actions in the CSAP need to focus much more on what to do to minmisie the source of the KSIs whic are mainly driver behaviours.
For example 10% of KSIs are caused by drivers opening their car door in the path of cyclists -while clearly cyclists should be and are taught to ride away from car doors (and may get beeped and scared back into the car door zone by drivers who don't understand why the rider is in the middle of a lane), focusing on drivers teaching them to check before opening their doors AND helping them understand why riders ride away from car doors, is a much better evidence based action likely to lead to fewer incidences of car-dooring.
The comparison of fatalities per million population doesn't take into account of the number of miles traveled by bike so having fewer absolute fatalities compared with Amsterdam is pointless. This could lead to a conclusion that in order to have fewer fatalities we need to have fewer people riding! This is why a cycling promotion target is important.
As per above the link between more cyclists and fewer casualties must be made and prioritising the reduction of harm would inevitably lead to improved safety. It is important to know who is being injured but even more important to know who is doing the injuring, where when and how, in order to mitigate it happening.
In the spirit of the comments above who causes the harm should be the main focus. It would also be useful to include cycles in that table to be able to assess to what extent cyclists are the cause of injury to others and the ratio of cycles involvement as a ratio of modal share. (I suspect cyclists harming other cyclists (KSI) would be pretty low which would therefore lead to more focus on groups with a high ratio of involvement. (The ratio for cabbies (4) is astounding and should lead to TfL prioritising actions to mitigate harm this group causes.)
Junctions- how useful is the fact that 84% of casualties are within 20m of a junction. In London you are always within this distance from a junction.
Referring to action 23 in chapter 4. There is no action here about driver skills and checking before opening doors.
Good point about driver inexperience but not followed through to actions on this point. Action 13 is about technology and action 19, while better and about vru awareness in HC revisions and driver training there needs to be a TfL action about driver skills.
The note about contributory factors shares responsibility equally between drivers and cyclists. A much better moral position should be to apportion more responsibility to those able to cause more harm as in many European countries.
Is TfL proposing therefore to gather evidence as to what experience cyclists require to build up skills for riding on urban roads. What about evidence looking at whether drivers who are cyclists are better drivers
Regarding operation Safeway and exchanging places. There needs to be more emphasis on the balance here. Some in the cycle community see this as targeting cyclists and some officers offering their personal opinion regarding PPE. So for example a rider is pulled over while a driver on their mobile passes by unchallenged. The SUD element of any exchanging places should be extended to taxis and other vehicles and priorites over getting cyclists in the cab of a lorry.
There is a strong case for a driver safety (harm reduction) action plan DASP