The TSRGD Review - An Open Letter to the Department for Transport

The Transport 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 until the 12th of June.

The Cycling Embassy feels that the proposed changes are inadequate and muddled, and many opportunities to make substantial, genuine improvements to the standard of cycling provision in Britain have been missed.

Consequently we consider it essential that either this consultation is extended, or that the Department for Transport commits to immediate further review of the TSRGD. We set out these points in an open letter, below.1

We write in reference to the current review of the Transport Signs Regulations and General Directions.

Consultations like this should represent a serious opportunity to improve the standard of cycle provision in Britain. However, this consultation does not go nearly far enough, and is weak or muddled on the detail of the changes being proposed.

Indeed, we argue it fails drivers and pedestrians too, as well as falling short on the opportunity to reduce street clutter in the form of excess (and ineffectual) signage and markings.

Failure to employ proven solutions

Safe, attractive and convenient cycle provision at busier junctions is essential, yet this consultation has very little to say on this crucial issue, save for minor changes to the way Advanced Stop Lines (ASLs) are employed,2 changes which may actually worsen conditions for cycling.3

Rather than tinkering with an inadequate approach to designing for cycle traffic at junctions that require signals, the DfT must start employing the use of credible, proven alternatives, that provide safety on a continuous (rather than part-time) basis.

That means, either separate signalisation of left- and right-turning motor traffic,4 or 'simultaneous green' phases for bicycle traffic.5 Both these approaches remove conflict between motor traffic and cycle traffic, unlike Advanced Stop Lines, which are outdated and should no longer be employed at junctions with enough motor traffic to justify signalisation.

Cycle-friendly conditions should be achieved principally by design, rather than by legislation and signage

An important principle of safe roads and streets is that they should be self-explaining environments, through instantly recognisable road design. It should be obvious to anyone travelling on these roads or streets - whether on foot, on bike, or by car - what kind of environment they are in, and what behaviour is expected from them.

Unfortunately this consultation seems to ignore this principle in a number of crucial respects. It proposes 'cycle streets', but it appears that this intervention has been misunderstood as one of legislative technique, rather than - as in the Netherlands - one of physical design.

Dutch cycle streets work on the basis of low levels of motor traffic, combined with changes to the street layout that make it clear to drivers they are traveling on cycle-specific provision. Attempting to achieve cycle-friendly conditions through arbitrary speed limits and signage will, in our opinion, only lead to antagonism and misunderstanding between people cycling and driving.

Likewise, 20mph zones should look and feel like places where 20mph is an appropriate speed, to ensure compliance. Recent moves, reaffirmed by the proposed regulations, to allow local authorities greater flexibility in designing 20mph zones are welcome, but have the potential to erode this principle, allowing traffic authorities to fob off cycling, while only serving to antagonise motorists.

We therefore suggest the DfT retains a general requirement that 20mph speed limits are supported by the street environment, and where traffic volumes are limited.6

Missed opportunities for de-cluttering

Self-explanatory environments reduce the need for clutter. By contrast, the proposals described above will add clutter, in the form of signs and markings that attempt to control behaviour - control that should, instead, flow naturally from the design of the street, as far as possible.

We would also suggest that, in a consultation which mentions de-cluttering as a purpose, signs and markings that attempt to explain inherently inadequate provision for cycling7 should be deleted from the TSRGD. There should be no need for these signs if cycling environments are being designed properly.

Likewise, we would support the deletion of signs that duplicate on-road markings which should themselves be self-evident.8

Cycle-specific design required

On the proposed 'shared use zebra crossing', we are gravely concerned that - as with toucan crossings - this is simply a crowbarring of cycling into a pedestrian-specific way of allowing pedestrians to cross roads.

There is insufficient difference between the proposed 'cycle zebra' and an ordinary zebra crossing, and consequently drivers may not appreciate the need to yield to (faster) approaching cycle traffic. This ambiguity will pose danger. We would suggest that diagram 602 ‘Give Way’ signs should be provided at these crossings, with an option to use diagram 962.1 sign as a sub-plate, where further explanation is required. The regulations will also need to give sufficient flexibility, to cater for situations where crossings are provided in the immediate vicinity of junctions.

What we would like to see instead is flexibility being offered to designers; the flexibility to employ straightforward (and existing) ways of giving cycle traffic priority across streets, in conjunction with zebra crossings, and other markings/signing where used at junctions.9

Action

Given these problems, we feel that it is essential either that this consultation is extended, or that the DfT commits to further review of the regulations in the immediate future, to avoid the risk of the TSRGD becoming immediately outdated. We are happy to assist the Department in identifying and explaining the required changes.

The inadequacy of current regulations represents a significant barrier to the uptake of cycling in Britain, with all the documented attendant benefits of that increase. They also serve to promote waste on the part of local authorities, in encouraging authorities to provide designs that are not effective in increasing cycling levels, and thus do not generate a return on investment and serve only to clutter our streets - something we are sure the Department does not support.

The DfT must take action to enable authorities to design to the highest standards. We would welcome the opportunity to help you achieve this.

• 1. Our detailed response to the consultation questions [pdf] can be found here.
• 2. Namely, deeper ASL areas, removing the requirement for a ‘feeder’ cycle lane, and allowing the addition of headstart ‘filter’ signals
• 3. Notably, the removal of the feeder lane requirement will allow local authorities to install what is already low-grade cycle infrastructure at an even lower standard
• 4. With respect to the Traffic Signs Regulations, we consider that this is achievable within existing Regulations. However, it is rendered more difficult than it should be by over-complicated requirements with respect to the provision of signal heads. This also results in considerable amounts of street clutter caused by duplicate and triplicate signal heads, and excesses of islands and guardrailing. Conflict-free signalling by separate signalling of turning movements would be facilitated by simplifying requirements for the placing of signal heads, by allowing a single signal head to be provided above each traffic lane, and for signal heads to display (where appropriate) arrows in all aspects, so it is clear to motorists which signal controls which movement. Guidance would also need to be issued, detailing the conflict-free method of operation, and how this can be optimised to maximise capacity for motor vehicles while providing direct, convenient and protected crossings for pedestrians and cyclists. The Cycling Embassy of Great Britain is happy to provide further information on these techniques and their advantages, and to assist the DfT, as required, to achieve these changes.
• 5. Again we consider that this can be achieved within existing legislation; we would see the Government’s role here as one of issuing guidance to explain the technique to practitioners, and perhaps to provide an explanatory sign. The Cycling Embassy of Great Britain is happy to provide further information.
• 6. This is for two important reasons - 1) To ensure that the speed limits are credible and are obeyed in practice without being dependent on unsustainable consumption of police resource; noting that above 500vph, 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, 2) To ensure that it is as attractive as possible for drivers to use routes on which separate cycle & pedestrian infrastructure is provided, relative to other routes, so as to ensure traffic volumes on those other routes where cycle traffic must share the carriageway are kept to a minimum, preferably below 200vph, and never greater than 500vph.
• 7. For instance, ‘Cyclists Dismount’, ‘End of Route’, among others
• 8. For instance, cycle lane signs beside a cycle lane.
• 9. We would prefer to see controlled area 'zig-zag' markings, zebra crossing markings, and elephants' footprints cycle crossing markings prescribed separately as 'building blocks', allowing flexibility in how cycle priority crossings and zebra crossings are used - either separately, or adjacent to each other - and that it should be the responsibility of the designer to identify how or if these should be combined in each particular instance. The regulations also need to allow designers the flexibility to provide such crossings at junctions, including giving flexibility as to how and where give way / stop markings and signing is provided relative to crossings. Tying the use of elephants' footprint markings to zebra crossings and controlled areas removes this flexibility.