Response to DfT Cycling and Walking Consultation

Cycling and Walking Investment Strategy safety review: call for evidence

We have responded to this consultation which ends June 1st 2018. You can access the on-line page on the DfT website here

This is a response on behalf of 20’s Plenty for Us.


1.Infrastructure and traffic signs

Do you have any suggestions on the way in which the current approach to development and maintenance of road signs and infrastructure impacts the safety of cyclists and other vulnerable road users? 

How could it be improved?


Follow the advice of global road safety organisations and provide segregated walking and cycling facilities wherever the speed limit is higher than 20mph. There is a global consensus from many organisations :-

  • The EU Transport and Tourism Committee “strongly recommends 30kmh limits unless there are segregated cycling and pedestrian facilities.”
  • iRAP, the International Road Assessment Programme says that “urban roads without segregated cycle and pedestrian facilities will not get a 5 star rating unless the limit is 30kmh.
  • The Global Network for Road Safety Legislators says “there is strong evidence that wherever motorised traffic mixes with vulnerable road users the speed limit should be set at or under 30kmh”.
  • The International Transport Forum of the OECD in a recent report on “Speed and Crash Risk” is categorical that “Where motorised vehicles and vulnerable road users share the same space, such as in residential areas, 30 kmh is the recommended maximum.
  • WHO also say that “A safe speed on roads with possible conflicts between cars and pedestrians, cyclists or other vulnerable road users is 30 km/h (see Table 2).”

Where such segregated facilities are provided then it should be recognised that the funding should be associated with enabling motor vehicles to travel faster without creating danger for others. It not only protects the vulnerable but also protects drivers from placing those vulnerable road users in danger.

Allow traffic authorities to reverse the requirement for repeater signs on 20mph roads. Currently repeater signs are not allowed on 30mph lit roads yet are mandatory on 20mph roads. This may have been appropriate when 20mph roads limits were the exceptions but now that local authorities with a total population of 17m (including most iconic cities, most London Boroughs) have adopted 20mph limits for 70-80% of roads it would be far more sensible where 20mph is a default to allow traffic authorities to sign urban and village boundaries with a sign showing 20mph as the default and then only require repeaters on 30mph roads and above. This would assist in developing public consensus that 20mph was the norm and that higher speeds are only appropriate in certain places which are then clearly marked. Although the TSRGD 2016 updates did allow traffic authorities to use repeaters on a discretionary basis this neither empowers then sufficiently or set a national standard.


2. The laws and rules of the road

Set out any areas where you consider the laws or rules relating to road safety and their enforcement, with particular reference to cyclists and pedestrians, could be used to support the government's aim of improving cycling and walking safety whilst promoting more active travel.


The evidence is clear that 20mph or 30kmh limits are appropriate wherever people mix with motor vehicles. Where this is the case then a 20mph limit should apply. The 2013 guidance does endorse this in several aspects. However it is not clear enough in its guidance.


Even though para 32 states that “the needs of vulnerable road users must be fully taken into account in order to further encourage these modes of travel and improve their safety. Speed management strategies should seek to protect local community life.” many traffic authorities are ignoring this by creating arbitrary local policy rules that do not allow the setting of 20mph limits on certain roads due to the speed of vehicles or other arbitrary characteristics. There is conflation between the need to set the right limit and the means by which compliance should be gained.


In para 85 the guidance clearly states “To achieve compliance there should be no expectation on the police to provide additional enforcement beyond their routine activity, unless this has been explicitly agreed.” Yet some police forces, such as Hampshire Constabulary, refuse to provide any routine enforcement of 20mph limits.

This creates inconsistency across the country in the setting of urban and village speed limits. In some authorities nearly all roads have 20mph limits, with clear engagement and marketing in their values together with police enforcement. This has provided successful reductions in speed and better conditions for active travel. Others have put in the same 20mph limits but with minimal engagement and sometimes zero enforcement. This is within a context of many authorities setting very few 20mph limits and instead having the majority of roads where people mix with vehicles not at the 20mph recommendation, but 50% higher at 30mph. This inconsistency reduces compliance and maintains higher traffic speeds than are safe. On a national basis it creates a post code lottery of values and prioritisation of vulnerable road user needs.

We believe that it is time for central government to revise the national speed limit for restricted roads from 30mph to 20mph. It should reverse the repeater signage requirements and so enable local authorities to determine exceptions where the limit should be 30mph and use repeater signs to ensure that drivers know that a 30mph limit is operational. This is being considered by devolved national governments and should be considered by the DfT for England and Northern Ireland. The primary advantages are :-

·        A consistent speed limit that fully takes into account the needs of vulnerable road users.

·        Reduced signage costs.

·        Reduced administration for Traffic Regulation Orders (only required on excepted roads).

·        Optimal marketing and engagement initiatives that can be operated on a national level.

·        A significant national statement that people and active travel are beneficial to society.

·        Liaison with Home Office to ensure that a consistent approach is taken to 20mph enforcement

One issue that affects the rights of vulnerable road users is civil liability. UK is one of the few Western European countries not to have some form of presumed or strict liability. If the balance of responsibility for road danger is to be put clearly in the person introducing the danger then presumed civil liability should be introduced for collisions between motor vehicles and vulnerable road users. This does not presume guilt but only civil liability unless otherwise proven. Such a law would make a clear statement on the value of protecting vulnerable road users.

UK has one of the softest regimes for speed control and enforcement. The reliance on fixed cameras primarily at casualty locations and hi-viz enforcement communicates the message that compliance is only important in some places. New technology can provide for far cheaper, smaller and ubiquitous enforcement of speed. Such a growth in enforcement would ensure that drivers felt that any road could have its speed monitored and enforced. This would have a dramatic effect on reducing vehicle speeds and increasing compliance. Drivers could expect enforcement on any road at any time and the public would be far more confident in walking and cycling.

3. Training - 

Do you have any suggestions for improving the way road users are trained, with specific consideration to protecting cyclists and pedestrians?


Cycle training should be a mandatory element of applying and gaining a driving license.


4. Educating road users - 

Do you have any suggestions on how we can improve road user education to help support more and safer walking and cycling?


Traditionally road safety education in local authorities has been within traffic departments and also focussed on reducing KSIs. However when looking at increasing active travel with local authorities then KSIs are usually at far too small a number to be statistically significant from year to year. The embedding within traffic departments also provides little benefit in terms of the health benefits from active travel. Indeed a focus on absolute KSIs may well predicate against introducing initiatives which encourage walking and cycling.


What has become clear in implementation of wide-area 20mph limits is that those authorities who have led their engagement and education via public health have achieved far greater behaviour change to encourage walking and cycling. Such evidence comes from authorities such as Bristol and Calderdale which have had a significant public health lead and involvement.


Public Health also have considerable expertise in behaviour change and we would like to see far greater public health involvement and funding for active travel initiatives and road danger reduction. This to include not only responsibility for reducing direct casualties but also increasing public health through increasing active travel and air quality.


The adoption of national initiatives, such as a default 20mph limit for restricted roads, would allow far greater economy of scale and sophistication of message than is possible with local education initiatives.



5. Vehicles and equipment - 

Do you have any suggestions on how government policy on vehicles and equipment could improve safety of cyclists and pedestrians, whilst continuing to promote more walking and cycling?


Intelligent Speed Assistance is an obvious inclusion. This is particularly effective in an urban environment where a minority of vehicles complying to limits has the effect of calming all traffic. We would recommend that the government fully adopts the latest European Commission’s Third Mobility Package mandating ISA and AEB in all new cars from 2021. However early adoption by vehicles driven for work would have a large impact. HSE regulations provide additional requirements to protect workers and the public. ISA could be made mandatory for these vehicles in advance of 2021. This could also include taxis and other licensed vehicles.


The government also needs to develop a digital speed map of the whole country so that reliable data on limits is available for manufacturers of vehicles and vehicle equipment.


6. Attitudes and public awareness - 

What can government do to support better understanding and awareness of different types of road user in relation to cycle use in particular?


Most drivers do not understand the limited abilities of the young, elderly or disabled vulnerable road users to protect themselves in a high speed (30mph) environment.  Whilst training of vulnerable road users can be helpful, it can never be relied upon to protect them without drivers taking responsibility for the consequence of their mistakes or limited visual acuity or mobility. There needs to be far greater understanding of that vulnerability. Inclusion is an important factor so that cyclists, in particular, are not seen as “others” but merely people who may sometimes cycle. This can be linked to awareness of the benefits of active travel so that it is seen as a possibility for the many rather than the reserve of the “fit and the brave”. An education program around 20mph limits as a national default could provide a great opportunity to create empathy with people who walk or cycle rather than “walkers and cyclists”.


In doing so government also needs to be far clearer about the values that it communicates. Evidence from other countries shows that active travel will not be dramatically increased without a suppression of private motoring. Simply making active travel more attractive whilst at the same time making private motor vehicles more attractive will never achieve the radical changes required for public health improvements. Central government must be far more honest with society that an over-reliance on motorised private transport is bad for our cities, bad for our economy and bad for our public health. Only when that is done will it be able to explain why and how it can increase active travel to the benefit of society as a whole.

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