Embassy response to Draft cycling and walking investment strategy (CWIS)

The Department for Transport has asked for responses to its draft Cycling and Walking Investment Strategy. 

Our responses to their specific requests for responses are below.

1) 'suggestions and evidence of innovative projects and programmes which could be developed to further our goal of increasing cycling activity' 

If - as is suggested by the Cycling and Walking Investment Strategy - governance and delivery on cycling is increasingly devolved to a local level, there absolutely has to be unambiguous engineering and planning standards for cycling infrastructure design so that there are consistent designs and ideas that local authorities can easily draw upon.

At the present time local authorities are - in our view - having to waste their time writing their own cycling design manuals and guidance, and improvising on a site-by-site basis. While local authorities should of course be allowed the flexibility to implement the kinds of design they might wish to build, the Department for Transport has to take the lead, presenting clear (and authoritative) design elements that each local authority can employ easily, with a reasonable expectation of good results when done so.

We would also add that clear increases in cycling, and cycling safety, will ultimately have to be delivered across all local authorities, not just those that express an interest. It is not acceptable for cycling to be neglected entirely as a mode of transport in areas where local authorities are unwilling to make changes, or improvements to the cycling environment. Clear, coherent standards need to be applied nationally, with new road designs audited (see below).

It is telling that the only place to have made a serious change to the levels of cycling is London, where the responsible body is investing in cycling, and has the capacity to take on projects like updating the previously poor guidance on designing for cycling and walking.

In short, the ‘innovative programme’ required is a) provide clear national design standards, and b) the sustained investment that will allow local authorities to actually implement it.

In terms of design specifics, there is no particular need for ‘innovation’, or reinventing the wheel. Instead, we need to emulate the best practice of countries with high cycling levels like the Netherlands and Denmark, and also to draw upon the good designs being developed and implemented by local authorities in England, particularly by Transport for London.

However, there are some design elements for which clear guidance and standards are lacking. It should not be left up to local authorities to develop solutions in isolation. This not only amounts to a wasteful duplication of effort, but will also lead to low-quality outcomes and compromises. There is no clearer evidence of this than the historical record of very low quality cycling infrastructure built across Britain over the last decades. We don’t need to keep repeating the same mistakes.

We list below some key issues for which there is little or no clear guidance, or for which there are potentially rule-specific issues that need to be resolved, at a national level.

  • Cycleway design at roundabouts, with or without priority.
  • Designing for cycleways at signalised junctions, in a way that ensures separation of modes. ‘Simultaneous green’ junctions.
  • Designing priority for cycleways across side roads.
  • ‘Bus stop bypass’ design.
  • Priority for cycling (and walking) over turning traffic at signalised junctions, which would simplify junction design and improve their efficiency for all users.

Unambiguous guidance needs to come from the top that core elements of cycling infrastructure that might prove to be 'controversial' at a local level (bus stop bypasses in particular) are safe and acceptable concepts when designed well.

In addition, new cycling infrastructure should be subject to an audit assessment (for instance, Transport for London’s Cycling Level of Service (CLOS) tool, already in use and easily applicable nationally) to ensure it meets an acceptable standard. Schemes falling below a threshold score should be revised, or not built at all.

We would also suggest that tools like the National Propensity to Cycle could be used constructively to identify the elements of cycling networks at a local level, ensuring that interventions are in places where they are needed, not where they cause least inconvenience.

2) 'suggestions and evidence of innovative projects and programmes which could be developed to further our goal of reducing the rate of cyclists killed or seriously injured'

Within the LCWIPs (Local Cycling and Walking Infrastructure Plans) it is set to be recognised that investment in cycling should be targeted at infrastructure if we are to improve cycle networks, to reduce the rate of injury and death.

We support this position, and would strongly argue that it is only by working continually and progressively to improve the quality of networks that we will be able to see an increase in cycling that is accompanied by a reduction in the rate of injuries and fatalities. For this to be effective it is vital that investment is not piecemeal, and that any extra cycling activity enabled by major routes on main roads is also supported by further work away from them on more local and residential ones. The evidence for this is to be seen in the successful cycle networks in the Netherlands and parts of Denmark, among others, where a comprehensive high-quality network quality enables safe, mass cycling for all users.

3) 'views on how to increase cycling and walking in typically under-represented groups'

With cycling at such a low level in England, it is unhelpful to focus on under-represented groups, principally because all user groups have very low levels of cycling. The focus should instead be on the barriers to cycling that affect everyone.

For instance, while levels of cycling are higher amongst men than women, the modal share for men cycling to work is still very low indeed - over 96% of trips made by men to work are not cycled (the figure is even worse for cycling in general). Focusing on what amount to slight differences between different groups in the context of overall cycling levels obscures the fact that there is a much more significant barrier to cycling across all groups, in the form of poor or hostile cycling environments.

Cycling levels are increased in all groups in precisely the same way: by providing safe, pleasant, and attractive routes, separated from motor traffic, where people - whether walking or cycling - do not feel threatened by other modes, and where they can complete their planned journey with the minimum of deviation, inconvenience or discomfort.

The CWIS already implicitly recognises the importance of proper routes, with its comments about providing dense network - the outcome must be to ensure these dense networks apply to everyone, to every journey, in every locality.

4) 'views on the approach and actions set out in the strategy to meet our key objectives'

Most importantly, the CWIS’s ‘key objectives’ are vague, and - where quantified - unambitious.

‘Increasing cycling activity’ amounts to a mere doubling of the absolute number of cycling stages by 2025, not even accounting for population growth, suggesting a (still very low) modal share of 3-4% by 2025. Set against a background of stagnant (and even declining) cycling levels, and with a lack of serious, sustained investment, it is far from likely that even this very low target will be met.

The high-quality cycling infrastructure built recently in London - the kind necessary to develop serious increases in cycling levels, and reductions in the rate of cycling KSIs - works out a cost of around £1-2 million per mile. Plainly, very little of the infrastructure that is necessary for a genuine cycling revolution is going to be built with the levels of investment proposed in the CWIS.

As for cycling casualty reduction, there is no target, merely ‘reducing the rate of cyclists killed or seriously injured on England’s roads’ each year - no quantifying of how big that reduction should be. Given that the cycling fatality rate in the UK is currently around four times higher than that in the Netherlands (with more vulnerable groups - children and the elderly - greatly under-represented in the UK cycling population), this is desperately unambitious.

Aims for walking and cycling need to be tied into wider government targets on health, climate change and local pollution, as well as into a constructive strategy that reduces pressure on the road network, and improves the quality of the urban environment. In those terms, the goal should not be merely to produce a minor increase in cycling levels, but rather to have a healthier population, more efficient roads, more attractive towns and cities, and a safer urban environment.

Were this merely a pilot strategy, a mere growth plan might make sense, but a much more ambitious growth in active travel is an absolute must if England is to successfully counter the multiple serious issues of inactivity, emissions from energy generation & transport and deaths & injuries on the road itself.

Rather than setting unambitious targets for cycling and walking, a sensible strategy would be to immediately invest a substantial proportion of the overall government transport budget into active modes, and then to plan out a strategy towards meeting longer-term targets based on progress.

5) 'views on the potential roles of government and non-government bodies in delivering the strategy, plus the how they work together'

The most crucial role of all is that of a national body providing clear, unambiguous guidance on what designing for walking and cycling looks like.

Non-governmental bodies - such as the Cycling Embassy of Great Britain - can advise on this, but what is really needed is the organisation and authority that can come from central government, in the form of endorsed, high-quality design elements that may be new or ‘foreign’ to most local authorities.

Recent examples of poor or substandard new cycling infrastructure - for instance, many sections of the Leeds-Bradford Superhighway - show plainly that there is insufficient experience and knowledge in many councils to adequately design for cycling in the absence of clear national standards, and also that there are no checks in place to ensure that potential investment is not wasted on poor, unclear, or even dangerous designs. Again, this strongly suggests the need for some form of national audit standard, similar to Transport for London’s Cycling Level of Service.

6) 'views on the assistance local authorities and local enterprise partnerships would find beneficial to support development of infrastructure plans'

We are neither a local authority nor a local enterprise partnership, but from feedback we have heard had from both, we are very concerned that there is a lack of will, knowledge and skill - especially in local enterprise partnerships - to make any kind of investment in active travel at all. It would seem prudent to learn from experience in places like London where overlapping levels of local power in TfL and borough hands may help to point the way forward. It would also seem essential that such development plans are at least supported by clear responsibility and accountability for each of these types of body, so that they can develop plans that show where the need to exercise power and provide investment lies.

We understand that the LCWIP due to be published after this consultation closes will initially be targeted at those bodies without current plans. It is welcome that, as with the CWIS, the LCWIP would be suggested as an iterative and refined process. It is vital that local campaigner involvement is used to support these. We also understand that an assessment tool (much reduced compared to TfL’s CLOS) will help inform assessment within these plans, it is helpful for all if these assessments are shared to enable support from local campaigners.

To summarise, the CWIS document requires substantial re-drafting to become a true national strategy for investment in walking and cycling.