RAC Foundation response to the consultation on the proposed segregated East-West Cycle Superhighway and North-South Cycle Superhighway
Insufficient information has been published for us—or anybody else—to form a rounded view of the merits of these proposals. Therefore we neither support nor oppose these schemes. There may be sufficient advantage to outweigh the considerable costs and disadvantages, but a case is not offered.
This is a large scheme. The proposal to restrict the flow of vehicles into the area of the schemes is likely to have significant impacts over much of Central London. This is illustrated by the examples TfL have published as part of the consultation, some of which are reproduced in our Appendix, below.
These examples confirm that road users (buses, cyclists, pedestrians, taxis, private hire, commercial vehicles and private vehicles) over a large area of Central London would be adversely affected, some of them seriously so. The disbenefits to a large number of road users of all types (including bus users and pedestrians) across a large area of Central London would appear to be be very substantial.
To make an informed, rounded judgement it will be necessary to quantify the magnitude of these disbenefits and to set them against the magnitudes of the benefits anticipated for the schemes. A proper business case needs to be published before the public (or the TfL Board and the Mayor) can take an informed view and our understanding is that is still being drafted. In accordance with TfL’s normal good practice this should quantify the costs and benefits of the proposals.
We note with concern the statements in the consultation documents that “Our latest analysis shows the proposals would mean longer journey times for motorists and bus, coach and taxi passengers along most of the route, both during construction and once complete. There would also be longer journey times for users of many of the roads approaching the proposed route and longer waits for pedestrians at some signalised crossings.” This seems to imply that almost everybody would be made worse off.
There should also be a properly articulated safety case. This should consider the balance of advantage in safety terms for pedestrians, cyclists and others, between the schemes under consultation and alternative ways of using the resources (including the road space). We understand some estimation has been made for casualty reduction along the schemes’ routes but what is the effect beyond them? Could the same or greater casualty savings be made in a more cost effective way?
There may well also be a need to carry out an analysis of the environmental implications: significantly worsening traffic congestion over a large area would have adverse implications for air quality and carbon dioxide emissions which could be at variance with the Mayor’s policies (and duties), some currently under consultation.
The published consultation material would allow comment on the fine detail of such things as junction designs and road layout. But our interest is in the overall merits of the schemes in relation to their disadvantages. That requires a thorough appraisal of the estimated effects on transport users affected across the relevant area.
We would expect TfL to apply the same rigour and completeness of appraisal for these schemes as they have for other schemes over many years, in accordance with good practice. To cite some examples:
- As for many public transport improvements, the case for Crossrail relies, in part on the benefits from decongesting road traffic through transfer of passengers from road to the new scheme. Models of the effects on traffic across the whole of London were used to evaluate these. These estimated benefits to road users are real enough but in most cases quite small for any one journey. By these standards some of the increases in trip time cited as examples due to the cycling superhighway proposals are enormous.
- The case for the Congestion Charging scheme relied on detailed modelling and estimates of the changes in traffic flow across Central and Inner London, and the benefits of to the reduced traffic (including buses and commercial traffic) in the charged area.
- The decision to proceed with the “World Squares” redesign of Trafalgar Square was based on analysis of the effects that scheme would have on traffic as far afield as the Inner Ring Road. An account by a TfL official of the traffic modelling relates that “Modelling of the wider network was undertaken by consultants, WS Atkins, during the development of the scheme using SATURN and, later, TRANSYT. SATURN work suggested that while the direct impact of the scheme is to reduce traffic flow passing though Trafalgar Square by approximately one third, the scheme would not displace trips beyond the Inner Ring Road.” Our point is that this kind of traffic appraisal possible, routine and good practice in cases similar to the cycling superhighways.
- The proposal for a cable car crossing of the Thames was subject to an appraisal of a business case, considered by the TfL Board, which estimated benefits and costs. This includes quantified estimates of the benefits of time savings to cyclists, which demonstrates that TfL believes that appraisal of this is possible.
- When London was constructing its bid to host the 2012 Olympics detailed traffic modelling was necessary in order to understand the implications for traffic. The analysis was considered by the TfL Board. Particularly relevant to the cycle superhighways were the reserved, “Olympic Lanes” and the Olympic Route Network. These proposals were controversial at the time, but concerns were mitigated by the facts that the disruption was only for about four weeks in total and, by design, that was at the quietest time of year. The cycle super highways are, of course, proposed to be permanent.
- Over the years proposals for new East London river crossings have been controversial. Discussions at public inquiry and elsewhere have centred on detailed estimates and evaluations of implications for traffic flows across large areas of London.
It is only reasonable to apply the same standards of analysis to the cycle superhighway proposals as would be normal for any other major London scheme.
In particular, proper forecasts of the number of users need to be constructed and scrutinised. With a major infrastructure proposal it is never enough to publish the maximum expected carrying capacity: capacity is not the same thing as usage and there are many infrastructure schemes round the world that are not “used and useful”. Of course we recognise that absolute precision is not to be expected. But it is normal practice in a case such as this to estimate numbers and origins and destinations of trips that might divert to a new facility such as this, and to justify any assumptions as to the number of new trips that might be generated. In other contexts (new railways, road bridges, road improvements, bus services) these analyses are, rightly, subject to close scrutiny.
We believe that, in accordance with its usual good practice, TfL must have carried out comprehensive modelling of the impacts of traffic of these proposals—and if it has not, it should.
Having done the traffic and economic and environmental modelling TfL will have the information necessary to calculate, in the normal way, estimates of the total benefits and disbenefits to those affected. Then the general public (and the Mayor) will have the information necessary to come to a judgement on the balance of advantage of the schemes.
The appraisal will need to reflect the fact that according to TfL’s estimates (Drivers of Demand for Travel in London: A review of trends in travel demand and their causes, 2014) “the proportion of network capacity for private motorised trips lost relative to 1996 … is estimated to be 30 per cent in central London, 15 per cent in inner London and 5 per cent in outer London”. Competition for road space in Central London has always been intense and the fact that so much capacity has already been given up for other purposes makes it much harder to accommodate new schemes without causing disproportionate disadvantage to existing users.
The nature of the traffic on the proposed lines of route is only a small part of the story. Because traffic will be diverted onto many roads in the Central area, all that traffic may be affected. (See TfL’s examples in our Appendix.) In particular, there may be important implications for reliability and cost of operation of bus services throughout. Further, a glance at any Central London street during the working day confirms the significant proportion of traffic that is commercial. The appraisal of these proposals needs to take proper account of the costs to the London economy due to adverse effects to buses and commercial traffic.
We note that the proportion of traffic in Central London that is private cars is now quite low—maybe close to an irreducible minimum. This is partly because of the success of the Congestion Charging scheme. Also, we suspect that some of the historical increase in cycling is diversion from walking and, particularly, public transport. So, whatever its merits, the case that the cycling superhighways will be material in reducing private car use is not made.
We note that TfL funds are proposed to be used on bus measures to mitigate the impacts of the proposed cycle scheme. Assuming—as must surely be the case—that these funds would have had a beneficial alternative use for bus services elsewhere then that cost should be accounted as one of the costs of the cycling proposals. (And that would be to disregard the net benefits they would have generated in the forgone applications.) Similarly, the business case will need to cost in realistic mitigation measures for commercial traffic and general traffic control across the affected area.
Appendix
TfL have published some illustrations of the effects of the east-west scheme on journeys here:
https://consultations.tfl.gov.uk/cycling/be832fad/user_uploads/east-west-cycle-superhighway-modelling-results—230914.pdf
The biggest changes to journey times would not occur in central London or on the superhighway section, but on the A1203 and A13 east of Tower Hill, where road space would remain the same as now but westbound traffic will be held longer at various points to control the flow on to Tower Hill and Upper Thames Street. To evaluate the scale of these impacts, we have modelled a journey between the eastern end of the Limehouse Link Tunnel and Hyde Park Corner. The current journey time westbound is currently 34 minutes 34 seconds in the morning and 30 minutes 51 seconds in the evening. Once the scheme is built, journeys for general traffic in this direction would be 50 minutes 28 seconds in the morning and 44 minutes 20 seconds in the evening. The same journey eastbound is 27 minutes 51 seconds in the morning and 30 minutes 51 seconds in the evening. Once the scheme is built, these journey times would increase to 35 minutes 29 seconds in the morning and 35 minutes 6 seconds the evening.
TfL have published some illustrations of the effects of the north-south scheme on journeys here:
https://consultations.tfl.gov.uk/cycling/7e3b634b/user_uploads/north-south-cycle-superhighway-modelling-results—230914fn.pdf
Travelling northbound from Elephant & Castle to Farringdon Station, average journey time in the morning peak would rise by 41 seconds, from 11 minutes 28 seconds to 12 minutes 9 seconds. In the evening, in the same direction, journey times would increase from 10 minutes 56 seconds to 15 minutes 12 seconds. Travelling southbound from Farringdon Station to Elephant & Castle, average journey time in the morning peak would rise from 10 minutes 50 seconds to 14 minutes 43 seconds. This journey in the evening would increase slightly from 12 minutes 17 seconds to 14 minutes 20 seconds.
We have also modelled a journey for general traffic between Stamford Street and Queen Victoria Street. Journeys for general traffic starting on Stamford Street and travelling north over Blackfriars Bridge to Queen Victoria Street would increase from 3 minutes 45 seconds to 15 minutes 43 seconds in the morning, and from 3 minutes 20 seconds to 12 minutes 41 seconds in the evening. Much of this increased journey time would be on Stamford Street itself, approaching the junction with Blackfriars Road. Journeys heading south in the opposite direction would be quicker by 2 minutes 11 seconds in the morning and by 1 minute 41 seconds in the evening.
The issue of the UK Government U-turn on alcohol minimum unit pricing (Godlee, 2014) is not the only evidence based public health policy that has failed to materialise recently.
Just as in January 2013 public health campaigners and policy makers were confident that a minimum unit price would be introduced across the UK, those of us working in the public health discipline of road injury prevention were similarly confident that the UK Government would carry out its commitment to publish a Green Paper on young driver safety with proposals for robust, evidence based change. However, at the end of the year a paper still had not been published.
Amongst teenagers, motor vehicle crashes (MVCs) are a leading cause of death and disability (Peden et al., 2008). In the UK, MVC injuries account for a quarter of all fatalities of 15 to 19 year olds (ONS, 2011; DfT, 2011).
The Department for Transport (DfT) made a clear commitment to producing a Green Paper in the spring of 2013 that would set out options for addressing the burden of young driver crashes on health and health services. This was to be supported by an evidence review carried out by TRL (Transport Research Laboratory), commissioned by DfT, and addressing specific questions of concern with regards to Graduated Driver Licensing (GDL).
GDL is a legislative approach used in the USA, Canada, New Zealand and Australia, which has consistently been shown to have only beneficial effects on young driver crashes (Russell et al., 2011).
The TRL review (Kinnear et al., 2013), initially delivered in April 2013, concluded that there was compelling evidence for the introduction of GDL in the UK, and supported the findings of previous modelling work demonstrating that there could be substantial reductions in crashes, casualties and fatalities on the roads of the UK if GDL was introduced (Jones et al., 2012). The conservative estimate delivered by Kinnear et al., based on observed levels of effectiveness internationally, is that a GDL system in the UK would save 4,471 casualties and £224 million annually.
The publication date for the Green Paper was pushed back to June and then September 2013. At the Road Safety GB Conference in October 2013, representatives from DfT told the audience that the paper would be published before the end of 2013. In late December, in response to a Parliamentary Question, the Parliamentary Under Secretary of State for Transport Robert Goodwill MP admitted that the Government was still “wrestling with the issues” and would “issue a paper when we have considered this further.”
It appears that the Government is now looking at alternative approaches, including the use of telematics or ‘black box’ driver monitoring technologies. Telematics is an emerging field. It shows promise, but as yet is unproven as a public health intervention. We would see telematics as complementary to a GDL regime, not as an alternative.
The need for GDL is clear and there is widespread support for its implementation from the road safety sector, the insurance industry, those working in public health, the police, road safety charities and politicians.
It is not too late for Government to forward the debate. It still has the opportunity to present a range of options to reduce death and injury on the roads. The international evidence for GDL is compelling and to exclude this option from the Green Paper would significantly reduce its potential as a stimulus for evidence based change.
We remain hopeful that the Green Paper will be published after this significant delay, that it will recognise the beneficial effects of GDL witnessed internationally and include the recommendations from the Government commissioned TRL evidence review, and that a frank and open public debate will follow.
Sarah Jones, Consultant in Environmental Health Protection, Public Health Wales
Frank McKenna, Emeritus Professor, The University of Reading
Stephen Stradling, Emeritus Professor, Edinburgh Napier University
Nicola Christie, Director of Centre for Transport Studies, University College London
Tom Mullarkey MBE, Chief Executive, The Royal Society for the Prevention of Accidents
David Davies, Executive Director, Parliamentary Advisory Council for Transport Safety
Elizabeth Box, Head of Research, RAC Foundation
Julie Townsend, Deputy Chief Executive, Brake, the road safety charity
James Dalton, Head of Motor, Association of British Insurers
References:
DfT. Reported Road Casualties: Great Britain 2010: Annual Report. 2011.Department for Transport: London.
Godlee, F. (2014) Minimum alcohol pricing: a shameful episode. BMJ, 2014;348:g110
Jones, S., Begg, D. & Palmer, S. (2012). Reducing young driver crash casualties in Great Britain – Use of routine police crash data to estimate the potential benefits of graduated driver licensing. International Journal of injury Control and Safety Promotion, 1-10, DOI: 10.1080/17457300.2012.726631
Kinnear, N., Lloyd, L., Helman, S., Husband, P., Scoons, J., Jones, S., Stradling, S., McKenna, F. and Broughton, J. (2013). Novice drivers: evidence review and evaluation – pre-driver education and training, graduated driver licensing, and the New Drivers Act. Published Project Report (PPR673). Crowthorne: Transport Research Laboratory.
Office for National Statistics. Leading Cause of Death, 2009. 2011 http://www.ons.gov.uk/ons/publications/re-reference-tables.html?edition=… 16 Apr 2012].
Peden M, Oyegbite K, Ozanne-Smith J et al. World Report on Child Injury Prevention. 2008. WHO. Geneva.
Russell, K.F., Vandermeer, B. & Hartling, L. (2011). Graduated driver licensing for reducing motor vehicle crashes among young drivers. Cochrane Database of Systematic Reviews 2011, 10, CD003300.