Response to TSRGD Consultation

The Traffic Signs Regulations and General Directions (TSRGD) - which sets out the design of official traffic signs and markings that can be placed on or near roads in England, Scotland and Wales, and also sets out the conditions for their use - is open for consultation, with a number of proposed changes.

The DfT consultation document, along with questions on the consultation, can be found here [pdf]. The Cycling Embassy has the following responses.

Question 1 - General views of traffic signs practitioners

We have no views on this proposal.

Question 2a) - 20mph limits

With regard to the deregulation of sign lighting, we support local authority flexibility, so as to reduce scheme costs, and to allow money to be spent more productively.

However, only allowing local authority judgement within 20mph limits seems arbitrary, and inconsistent with practice elsewhere. Why not allow local authority judgement in all circumstances, or - for instance - at 30mph? The DfT could produce guidance, and require local authorities to have regard for it, allowing a degree of flexibility.

We note that the proposal may tempt local authorities to reduce speed limits, simply to save energy costs (understandable in times of austerity and rising energy prices). While 20mph limits should be supported in appropriate circumstances (i.e. most urban streets by mileage), we would not wish to see 20mph limits (further) undermined by application on traffic routes (where they are not credible, and where separation for pedestrians/cycles is required), or without a supporting environment, so as to allow routine non-compliance. More detail on this, in response to Question 5, below.

Question 2b) - lighting of two-way traffic signs

We take a neutral position on lighting of two-way traffic signs.

Question 2c) - local authority estimates

We have no views on this proposal.

Question 3a) - reducing sign clutter

The Cycling Embassy of Great Britain supports Sustainable Safety. Whilst we principally support this from a cycling perspective, a key principle of Sustainable Safety is that the nature of roads and streets - and thus likely conflicts and hazards and regulations on them - is readily recognisable. This minimises the need for traffic signs, which contribute to the reduction in sign clutter (a stated aim of this review).

We note that poorly thought-out cycle infrastructure can be a considerable contributor to sign clutter - dismount signs, ‘end of route’, and so on. We would urge the Department to adopt Dutch-equivalent practices and standards, which demand – and result in – cycling (and driving) infrastructure that is self-explaining, resulting in a better experience for cycling (and less ‘nannying’ of motorists), as well as less sign clutter. Examples include -

• 20mph limits supported by the physical design of the street, rather than by the provision of hundreds of repeater signs or road markings;
• Major-minor junctions with minor streets in urban areas, which use the construction of footways and cycle tracks to give priority to all users of the major road without the use of any signing or lining; and,
• Construction of cycle tracks that are self-evident, as opposed to the construction of shared use footways which require the erection of signing to explain their function.

We would also support the deletion of signs which we consider to be required only to explain inherently inadequate techniques/designs. For example -

• 'Cyclists Dismount'
• 'End of Route'
• Shared use path signs

We would also support the deletion of (or at least local authorities being given discretion in the use of) signs that appear only to duplicate markings that should themselves be self-evident. For instance, signs associated with cycle lanes.

Question 3b) - views of traffic signs practitioners

We have no views on this proposal.

Question 4a) - yellow line restrictions, without a TRO

The Cycling Embassy of Great Britain broadly supports proposed policies to introduce single/double yellow lines without a TRO. However, we are concerned that a public backlash may arise if this approach is overused.

We would also suggest that this approach should not be used to prohibit the leaving of cycles (say if safely chained to a lighting column) - perhaps the definition of yellow lines should explicitly exempt cyclists left in a safe manner from the restriction, unless signs indicate otherwise (we understand many authorities do not exempt cycles from prohibition of waiting TROs. While in practice waiting restrictions are never enforced where cyclists are involved, we feel the opportunity should be taken to improve the regulations in this regard.)

We would prefer that this approach is used only to prohibit waiting in specific circumstances where parking is illegal or advised against, or is generally obstructive, for instance -

• at junctions
• where clear carriageway width <3.85m (this being the width required for a cyclist and a car to pass each other comfortably) 

We also feel that the requirement for a traffic order when providing parking places for cyclists should be revoked (for one thing, few authorities seem to bother with this requirement).

We would also be concerned if this proposal were to be used to remove, for example, existing double yellow lines (etc), to accommodate parking at junctions, or on narrow roads or footways, to meet local expectations for improved parking capacity, without regard for safety, or the needs of other road users.

In the interests of reducing local authorities’ workload and sign clutter, we would prefer that parking at junctions and on narrow roads were outlawed as a general rule of the road, enforceable as per parking at dropped kerbs under the Traffic Management Act.

Question 4b) - views of local authorities

We have no views on this proposal.

Question 5 - measures to improve cycling facilities

See the detailed response below on cycling matters considered in this consultation.

ASLs and headstart filters

Changes are proposed to ASLs (Advanced Stop Lines) in this Review, including the way they are laid out (their use without feeder lanes, or only covering part of an approach), and the addition of 'headstart' filter lights.

However, we feel strongly that ASLs do not represent an acceptable level of provision for cycle traffic at those junctions busy enough to warrant traffic signals.

Headstarts do not give any physical or temporal protection for cycle traffic. ASLs similarly do not offer adequate protection. Both these measures - if they work at all - only do so on a part-time basis, only for those cyclists who have been delayed at the signals. We would also point out that the (Dutch) maximum flow criteria for ASLs would not qualify for traffic signals at all in the Netherlands, on basis of traffic flows.1

Instead of tinkering with a flawed system, the government should instead employ more advanced solutions to protect cyclists at traffic signals. In particular -

• Separate signalisation of left- and right-turning motor traffic (protecting cycle traffic from these turning movements)
• Simultaneous green phases for cycle traffic

We believe these can be achieved within existing regulations, and we would welcome the opportunity to work with the DfT to develop guidance explaining how they could be implemented.

There are a number of matters in which changes to TSRGD could assist in the design and development of such layouts -

• Allowing signals to display arrows in all aspects (red, amber and green), and an option for 300mm diameter aspects, to aid motorists' recognition of which signal applies to which movement.
• Simplification of regulations to allow for the placing of a single signal for each traffic lane, mounted above or immediately adjacent to each lane (and perhaps elsewhere in conjunction with low level repeaters where necessary).
• Cycle signals, including arrows, to allow separate signalling of cycle movements.
• Explanatory 'simultaneous green' and 'cyclists free to turn left' signs, for circumstances where design has been unable to make this readily apparent.

Flexibility in designing 20mph zones and limits

We support measures to enable local authorities to introduce 20mph limits. We are concerned, however, that the current trend is simply to fob people off with poorly complied with, and poorly enforceable, schemes. We also acknowledge that previous regulations were overly onerous in the micromanagement of what traffic calming should be provided.

We therefore consider that the regulations should include -

• A general requirement that the highway authority acts to provide such measures as may be required to ensure compliance with the 20mph limit;
• A requirement that features that might encourage higher speeds (in particular, centre lining and designation of priority at road junctions (except at main cycle/public transport routes) are removed from, and not introduced in, 20mph zones.

We would also like guidance on the use of 20mph zones to be strengthened, in particular with regard to -

• The need to ensure motor traffic volumes do not exceed 500 PCU/hour in 20mph zones (cycle tracks should be provided above this threshold), and
• the need to ensure that minimum carriageway widths are maintained, to minimise conflict between opposing vehicles (minimum 3.85m where motor vehicles are permitted to travel one way only, 4.4m in other circumstances).

This is for two important reasons.

Firstly - to ensure that the speed limits are credible, and are obeyed in practice without being dependent on unsustainable consumption of police resources (noting that above 500 PCU/hr, the separate infrastructure required to protect pedestrians and cyclists from traffic volumes, and the measures needed for the street to carry the volume of traffic more generally, will undermine the credibility of a speed limit of 20mph) and,

Secondly - to ensure that it is as attractive as possible for drivers to use those routes on which separate cycle and pedestrian infrastructure is provided, relative to other routes, in order that traffic volumes on those other routes where cyclists must share the carriageway are kept to a minimum, preferably below 200 PCU/hr, and never greater than 500 PCU/hr.

Similar regulations and guidance will be required for 40mph zones, and changes to traffic calming and road humps will likely be required as part of this.

5.9/5.10 ‘Cycle zebra’

We are concerned that the proposed 'cycle zebra' is simply repeating the mistakes of shared use paths and toucan crossings - namely, that cyclists are simply 'botched in' to an existing design, without concern for the needs of cyclists.

We are particularly concerned that there is insufficient difference between the proposed 'cycle zebra' and an ordinary zebra crossing, and that drivers may not appreciate the need to yield to (faster) approaching cyclists. We would consider it essential that the revised regulations allow give way, (and, exceptionally) stop signs and markings to be provided at crossings where cyclists may cross with priority.

We also note that there is potential for great ambiguity (and hence danger) in the existing rules for zebra crossings, whereby drivers must give way only once pedestrians are on the crossing itself. The dangers of this ambiguity are intensified with faster moving cyclists.

We also feel that the regulations with respect to crossings do not give sufficient flexibility to allow for appropriate crossings to be designed in many circumstances, particularly in the vicinity of road junctions. (For instance, the use of elephants' footprint markings, with give markings, to indicate cycle track crossings across junctions).

Consequently we suggest that controlled area 'zig-zag' markings, zebra crossing markings, and elephants' footprints cycle crossing markings should be prescribed separately as 'building blocks', and that it should be the responsibility of the designer to identify how or if these should be combined in each particular instance, including allowing for combinations with stop and give way lines at junctions. In particular, this should also allow for traffic authorities to omit controlled areas – this would ease the design of crossings near junctions, so as to better serve pedestrian and cyclist movements, and would reduce street clutter in areas where zig-zags are ineffective, intrusive, or unhelpful.

5.11/5.12 Low-level signals

We support low level cycle repeater signals, and cycle symbols in all three aspects for signals controlling cyclists only. However, it should be stressed that these represent minor improvement, and not the fundamental change in approach for designing cycling infrastructure. These signals should merely complement properly-designed junctions, with methods of operation that incorporate conflict-free cycle crossings.

5.13 'Cycle streets'

Whilst we support, in principle, moves to introduce cycle streets, we are gravely concerned that the consultation document appears to misunderstand this to be a legislative technique, rather than something that is physically built.

Dutch cycle streets are simply streets where the carriageway has been narrowed to the width of, and constructed and marked in a manner to give the appearance of, a cycle track. Motor traffic must be limited to a very low volumes, and one that is less than the flow of bicycle traffic – this typically requires the use of TROs to limit motor traffic to that serving fronting premises only. The additional width required for motor vehicles, including that to pass other vehicles (including cycles) is provided in the form of over-run areas.

The above measures can already be provided in the UK under existing legislation. We would support an additional simple sign to explain cycle streets, but we consider it vital that highway authorities are prohibited from using the signs on streets that have not been physically altered, have too much motor traffic (specific thresholds should be supplied), or too few cyclists, so as to avoid the technique becoming a 'quick win' gimmick, as (for example) ASLs have.

We consider that the proposed regulations/advice with respect to overtaking and speed are unlikely to be effective. The change in behaviour required is achieved through the design of the street and the genuine predominance of cycle traffic. Such regulations may serve only to antagonise motorists, and further burden the police with enforcement of rules lacking proper supporting physical measures.

Question 6 - pelican crossings

From a cycling point of view it would be advantageous if prescribed/type-approved PBUs incorporated a push button that can be operated by the heel of the hand, as in the Netherlands, and other countries. This would be more convenient for cyclists than current more fiddly designs, and there may be additional accessibility benefits with regard to pedestrians.

Question 7 - local authority views on boundary signing

We have no views on this proposal.

Question 8 - new definition of tourist destination

We have no views on this proposal.

Question 9 - proposal to remove Guildford Rules from sign design

We are ambivalent about the abolition of the Guildford Rules in general. However, some provision will need to be retained, to allow for the route for cyclists to be indicated where this is different to that for motorists.

Any new or retained provision for the indication of differing cycle/motor routes should require that the indicated cycle route is no longer than the equivalent for motor vehicles.

Question 10 - expanding the use of exemptions to 'no entry' signs

We would prefer that no entry signs are reserved to one-way streets for private motor traffic.

Question 11 - the use of sub-plates as an explanatory option 

We support explanatory plates as an option, to avoid unnecessary/accidental non-compliance.

Question 12 - revised signs for camera enforcement operations

We have no views on this proposal.

• 1. Maximum traffic flow for ASLs is 500vph per link, or 800vph per junction (Design Manual for Bicycle Traffic p 208). We can provide further information on how these relate to the Dutch traffic volume criteria for traffic signals on request.