Too long for a blog entry really, but might interest some:
response to SBEG's
`Draft South Bank and Waterloo Cycle Strategy', September 2010.
Lambeth Cyclists, the borough group of London Cycling Campaign, are pleased to have been invited to comment on the draft report which the London Borough of Lambeth commissioned SBEG to write. The commission was to make recommendations about the development of cycling at a neighbourhood level in the South Bank and Waterloo area.
While we applaud the considerable amount of work has gone into presenting a lengthy draft document, some of which is very good, we consider that a further draft needs to be produced.
In large part the present draft appears to focus on `rationalising' or to some extent accommodating increasing levels of cycling rather than actively developing it. The final draft must have a vision for developing cycling.
The present draft superficially acknowledges the hugely increased number of people using the area and the South Bank's coming of age as a part of central London, but totally fails to address the unacceptable dominance of the motor-vehicle in the area of study (in common with much more of central London) as THE principal issue to be addressed.
This can be clearly seen in the way that the draft strategy makes no recommendations with regard to Westminster, Waterloo or Blackfriars Bridges and their respective junctions – though all are within the area of study as shown in the map on page 14 and all feature major obstacles to encouraging active travel.
In short the strategy should be rewritten as though part of a grander strategy:
`Developing active travel and reducing motor-traffic volume and speed within the South Bank and Waterloo'.
We are also concerned that, if we understand the footnote on P8 correctly, logical ways of developing cycling in the area have been excluded due to restrictions arising from the London Eye S106 monies used to fund the `South Bank Cycling Strategy'. If this is the case the report needs to be retitled, perhaps to `A Partial Contribution to a South Bank and Waterloo Cycle Strategy'.
Clearly it would be better to either secure additional funding or bend the rules in order to be able to write a proper strategy. The restrictions may explain why the local schools – whose pupils would benefit hugely from seriously improved cycling conditions - were not represented on the steering group when they clearly should be.
We have taken Counsel that suggests the statement in the strategy that `it is technically illegal to cycle on the River Walk' is incorrect. The report needs to give full details of the law(s) allegedly being broken by cycling and whether these apply to the full extent of the River Walk or specific parts.
Additionally, we note that the draft has been poorly proofed which makes it difficult to understand – one chart was wrongly reproduced (p26,27), several paragraphs are repeated, several statistics are very questionable (eg p34 various figures; p60 assertion of 24,900 employees at Waterloo Station) and several of the charts don't have axis labels explaining what they represent.
Rather than attempt to comment on each page, we have chosen to focus our reply on the Report Recommendations (pp 4 – 6)
CONSIDERATION OF REPORT RECOMMENDATIONS (p 4 – 6)
There are five headings provided and we comment on each briefly below:
a) Rationalising cycle provision and routes – this heading should be Enhancing cycle provision and routes. We examine this in detail further below.
b) Crime Reduction – We would prefer all the existing content of this to be within a sub-heading `Cycle Theft Crime Reduction' as the recommendations given exclusively relate to this aspect of crime. We support the measures proposed. An additional sub-heading is needed relating to enforcement of traffic law – with crimes such as careless driving, wanton and furious driving (incl. cycling), speeding, parking on red-routes on a cycle and bus lane; driving and parking on the pavement, and illegal use of Advanced Stop Lines by drivers being targeted.
c) Workplace Travel Planning – we encourage companies to write and implement travel plans that encourage active and sustainable travel by their employees but also by their suppliers and customers/visitors. We consider it unacceptable that the measures recommended here only relate to employees. The workplaces need to be working to find ways of reducing the need for deliveries by motor vehicle (e.g. providing drinking water fountains and taps for customers, visitors and staff rather than bottled water; and, reducing visitor parking and discouraging taxi use but instead promoting public transport and active travel).
d) Programme of Education – we support the measures proposed here. Within the area of `Cycling and Driving Behaviour', cycle awareness training should also be provided to drivers of the many smaller commercial vehicles that form a large part of the local motor-traffic: taxis, mini-cabs, and delivery, maintenance and ice-cream vans.
e) Other initiatives – Rather than a `sustainable transport group' we recommend establishing an `active and sustainable transport group'. We support the other aspects.
Detailed response to Rationalising cycle provision and routes
As previously stated we consider this should be re-titled `Enhancing cycle provision and routes'
The whole report suffers from being written in a way that suggests people on bikes should only use designated cycle routes, and through this blindness omits to make any strategic recommendations concerning Westminster, Waterloo and Blackfriars bridges and their approaches and junctions on the south of the river.
While recognising the increase in visits due to the London Eye etc., the report woefully fails to respond to the scale of residential and business development that has taken place and will take place in central South London. The neighbourhood strategy must be placed in the context of the Vauxhall, Nine Elms and Battersea development; Elephant and Castle regeneration and Bankside growth.
There is also no mention of air pollution or noise pollution, issues in the area that need to be addressed.
Reduction in the tendency to use motor vehicles and reduction in their speed is a major requirement to encourage active travel to and within the neighbourhood.
London Nautical secondary School on Stamford Street does not actively promote cycling to and from school for its pupils due to concerns about the motor-traffic, particularly along that street and for those pupils living north of the river. It is unacceptable that the draft strategy fails to address these problems.
It is appalling that there is not an easy-to-follow, quick, relaxing cycle route with light traffic between St Thomas' and Guy's Hospitals – and again this strategy doesn't offer a way to resolve this, but in fact proposes to reduce options by banning cycling on the River Walk.
Through improving conditions for cyclists and pedestrians throughout the area fewer people are likely to choose to ride their bike along the pedestrian congested riverside, removing the temptation for landowners to try to introduce a ban with its concomitant costs of enforcement. This allows mellow tourists cycling the length of the Thames to continue to enjoy seeing the sights along the river rather than the road-side wall of St Thomas' and the back of the Royal Festival Hall.
a) Make the entire area 20mph – particularly including the bridges and approach junctions in order to ensure cyclists feel welcome within the main traffic areas. Use speed camera enforcement.
b) Improve permeability for cyclists by making all local one-way streets (eg Roupell Street, Lower Marsh and Royal Street) two-way for cyclists.
c) Lobby TfL and the boroughs to create a clear, wonderfully cycle friendly route east-west running along the south side of the river feeding all the bridges (e.g. Nine Elms Lane; Albert Embankment; Lambeth Road, Hercules Road, Baylis Road, The Cut, Union Street, Newcomen Street, Snowfields, Crucifix Lane, Druid Street.)
d) Reduce the volume of motor traffic on Upper Ground and Belvedere Road and improve the surfacing. Page 29 refers to `the Spine Route' as a service road for HGVs, a bus route, a national and local cycle route and a key walking route but omits to include the large numbers of taxis, mini-cabs, delivery vans and private cars that also use this road, Part of these roads should be made access only for motor vehicles save buses. Taxi drop off and pick up points could be provided along York Road and Stamford Street so taxis needn't use Belvedere Road or Upper Ground.
e) Take action against the owners of Belvedere Road behind County Hall for failing to implement a satisfactory traffic management system for cyclists and force them to make changes.
f) Improve the Westminster Bridge Un-roundabout for cyclists. Simplify the lane options, eg through only have one lane turning right to go under the railway line towards Lambeth North. Give it less of a fast gyratory feel through landscaping and speed reduction measures.
g) Increase parking restrictions on Waterloo Bridge to ensure cycle lane remains in use 24/7
h) Reduce the number of general motor-traffic lanes going into and around the IMAX cinema.
i) Replace the cycle traffic island in the middle of Blackfriars Road with traffic lights allowing a right turn out of Upper Ground for cyclists and cycle lanes. Tidy up of the cycle lane approaches which is currently very confusing and encourages pedestrian/cyclists conflict.
j) Other aspects as outlined in original draft
When working on cycling infrastructure, Cycling England's five Key Design Features for a Cycle Network should be adhered to:
Coherence : The cycling infrastructure should form a coherent entity, linking all trip origins and destinations; with a continuous level of provision;
Directness : Routes should be as direct as possible, based on desire lines, since detours and delays will deter use;
Attractiveness: Routes must be attractive to cyclists on subjective as well as objective criteria. Lighting, personal safety, aesthetics, noise and integration with the surrounding area are important;
Safety : Designs should minimise the danger for cyclists and other road users;
and Comfort: Cycle routes need smooth, well-maintained surfaces, regular sweeping, and gentle gradients. Routes must be convenient to use and avoid complicated manoeuvres and interruptions.
River Walk Policy
We do not support a ban on cycling on the South Bank. Resources to enforce a ban would be better used to enforce considerate cycling. A better use of resources would be to stop the continuing flouting of the law by ice cream vans trading illegally while illegally parked on the red-route, bus lane and cycle lane on Westminster Bridge.
a) Focus on encouraging considerate cycling with pedestrian priority emphasised through signage and education, plus CPSO's picking up on inconsiderate cycling.
b) Ensure that alternative routes appeal to commuters over the River Walk
c) Reduce clutter, especially A-boards, that narrows the walkway.
The report should cite
Advice on this issue is set out in TAL 9/93 Cycling in Pedestrian Areas. This emphasises that, on the basis of research, there are no real factors to justify excluding cyclists from pedestrianised areas and that cycling could be much more widely permitted than is current without detriment to pedestrians. This was confirmed by TRL research "Cycling in Vehicle Restricted Areas" published in 2003 that established that cyclists alter their behaviour according to the density of pedestrian traffic by modifying their speed or dismounting.
Furthermore, the evidence of the case studies contained within the report shows that very few collisions actually occur between cyclists and pedestrians. It also showed that as pedestrian flows rise, the incidence of cyclists choosing to push their cycle also rises and those cyclists who continue to ride tend to do so at a lower speed.
It would be useful if the appendix to the report could include details of the number of cyclists and pedestrians killed or seriously injured (KSI) in the area and the cause.
We agree with the points made here, though emphasise that more cycle parking is required in all streets. Where possible this should be at the expense of car parking rather than pavement.