Consultation - Birmingham Road Safety Strategy

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Birmingham City Council (BCC) is consulting on a Road Safety Strategy with the goal of reducing the numbers and severity of road traffic collisions in Birmingham. This consultation is important because it will influence how our roads are made safer for vulnerable road users, including cycle users. The Road Safety Strategy states that BCC will be adopting the "Safe System" approach which is advocated by the World Health Organisation. The Royal Society for the Prevention of Accidents (RoSPA) defined this approach (in their submission to the BCC scrutiny report on cycling 3 years ago) as:

"The safe system approach considers that often mistakes do happen, and given this, roads and cars should be designed so that mistakes do not frequently result in death. It does this by placing human vulnerability to injury at the centre of road design, and proposes that roads, vehicles, and traffic speeds should be modified to prevent exchanges of energy which are likely to cause fatal injuries.... In general the Safe System philosophy identifies ways of separating traffic, especially vulnerable road users on high speed roads. Where this cannot be achieved, the roads are designed to reduce traffic speed.


The adoption of this attitude to road safety would mark a substantial change in road safety in Birmingham, and is a change that Push Bikes believes would be very important. For many years road safety in the UK has focused on delivering better motor vehicles that protect their occupants, but can make drivers over-confident and more likely to take risks. The "Safe System" approach would rebalance that focus to provide changes for the most vulnerable road users who do not have the benefit of crumple zones and air-bags. Whether or not the Road Safety Strategy consultation document adheres to the "Safe System" approach, however, is a different question, and one which we consider in our response.

Our response is below. First we have put our recommendations, and after that we have given our discussion of the Road Safety Strategy.

Push Bikes' response:

While Push Bikes welcomes the adoption of the "Safe System" approach to road safety, we are concerned that the Road Safety Strategy consultation document hasn't fully escaped of older approaches to road safety as well as having serious statistical misunderstandings which could threaten to undermine the use of the "Safe System" approach.

(1) Push Bikes is very concerned that the final step of consideration for 'Local Safety Schemes' is that the cost of the scheme must be less than the savings that will be made in the first year after the scheme has been carried out ('First Year Rate of Return' FYRR - See Figure 12 on pg 25). Without further clarification being offered, it appears that expensive infrastructure changes would be seen as not offering a sufficient FYRR, despite the fact that they would might have a lifespan of over 25 years. Painted markings on roads might be considered to meet the FYRR measure despite having a lifespan of only 3 or 4 years. This could result in necessary schemes being shelved because they fail to meet this FYRR test. In other Road Safety Strategies, such as the Bristol one, this stipulation about FYRR has not been made. This final step in the decision making process for 'Local Safety Schemes' needs to be re-thought and there needs to be further clarification about how factors other than FYRR will be considered in that final step of the process.

(2) The document 'Further analysis of road safety data' that analyses the road safety data makes some very serious statistical errors in its measurement of road casualties. It measures all casualties as per 100,000 population, with no reference whatsoever to casualty rates per billion vehicle miles, as specified on pg 5 of the main consultation document. Thus the analysis of road safety data states that the count of child cyclist casualties is lower than the national average, offering a false analysis that Birmingham's roads are safer than the UK average for child cyclists. In the section of overall cycle figures, the document states "The Birmingham constituencies that tend to experience the higher cyclist casualty rates tend to be those with the higher recorded levels of cycle use." (pg. 5) which is a useless statement that tells us nothing of the comparative safety of different areas of Birmingham for cycling. The delivery framework in the main document then compounds this error by setting a goal of reducing KSI casualties by 40% by 2020 (page 52), with no reference to the casualty rates per billion vehicle miles. It is of vital importance that useful measures of casualty rates are used, as stipulated at the start of the main policy document, so that we can make informed judgements about the road safety of different parts of Birmingham.

(3) Road design needs to be the primary focus for reducing child casualties in deprived areas. Page 30 of the document notes that children in deprived areas have a risk of injury on the roads that is 5 times higher than that of children from the most affluent areas. Push Bikes suggests that this is most likely due to the differences in the types of roads that these children are living and playing on and that RoSPA's recommendations 3 years ago that changes to road design and the implementation of 20mph should be the primary focus for reducing child casualties in deprived areas. The 'Play' report by the All-Party Parliamentary Group notes that the outside space in which children are allowed to roam has shrunk by 90% since the 1970's (page 28). Children play in the spaces that are available to them, and while road safety education can make some impact on casualty rates, changing the environment to make the spaces safer for children will be much more effective in the long run. The 'Play' report argues that children's journeys must be included in traffic calculations, and that journeys that children would make to outdoor areas to play would make a very substantial impact on the local travel patterns (page 40). Birmingham City Council has a duty to plan for the short local journeys that children want to make, to go outside to play and to use active transport to go to school with their friends.

(4) The document on Pedestrian Crossing Facilities refers to the use of 'an off-set pedestrian facility' (2. Crossing option vii) at traffic controlled junctions. It is very important that crossing facilities provide a straight path across the arm of a junction to reduce conflict in paths between the different people using the crossing. Where users have to turn twice through 90 degrees on the central island of a crossing, the width of the crossing is reduced and users can bump into each other and slow each other down. Where cycles and pedestrians, or mobility scooters and pedestrians, are on the same crossing, this results in discomfort for the users even if there are no collisions.

(5) The document on Pedestrian Crossing Facilities also refers to an assessment of potential schemes that measures pedestrian and vehicular flow. It is important that the potential for an increase in pedestrian flow is considered, as many main roads at the moment have low volumes of pedestrian flow across them simply because the road crossing is too hostile. The junctions of Bristol Road and Pershore Road with Priory Road are a perfect example of this, where local residents drive across the two junctions to go half a mile to the supermarket because the junctions are so dangerous to cross on foot. If this potential pedestrian flow is not taken into consideration, then some schemes that would be highly valuable to the local community may be deemed low priority.

(6) Where pedestrians crossings are provided through a narrowing of the carriageway, or the provision of a pedestrian refuge, it is important that the needs of cycle users on the carriageway are considered. As a minimum, the narrowing of the carriageway must be sufficient that motor vehicles behind the cycle user do not feel that they can squeeze past, but best practice is to provide a cycle by-pass to the carriageway narrowing so that there is no risk of motor vehicles having a collision with the cycle user at that point.

(7) It is important that signal controlled crossings provide a timely response to pedestrians, and do not keep pedestrians waiting too long to cross. It is very common for pedestrians to press the button and then cross the road in gaps in the traffic before the motor traffic is brought to a standstill by the red light. This results in delays for motor traffic for no visible purpose for the drivers being held up as well as presenting safety risks for pedestrians trying to judge the speed of motor vehicles. The timely response of signal controlled crossings is very important to encourage safe crossing behaviour of users. Action SR4 should be amended to include an action to "Ensure that all signal controlled crossings respond to requests within 10 seconds, or 20 seconds if the signal has been used in the last minute." 

(8) Community Speed Watch initiatives and Vehicle Activated Speed Signs (VASS) are ineffective and a waste of resources, yet they are recommended as appropriate measures for combatting excessive speeds. Even the consultation document itself says that VASS are ineffective if over-used or where drivers can see no reason for driving more slowly. These two measures must be removed entirely from the road safety document and no more money must be wasted on them. The focus must be on road design to indicate to drivers the appropriate speed and on speed cameras which are proven to provide real deterrence to speeding. Action SR5 must be modified to remove these two options.

(9) Action Plan SR3 requires very substantial modification. Firstly, it is wholly unacceptable that an action point that is supposed to be focussed on road infrastructure changes includes any reference to training. SR3 must only discuss the infrastructure changes that the Birmingham Cycle Revolution will be delivering. Secondly, by focusing on the 20 minute radius of the original Birmingham Cycle Revolution scheme and having no other action point covering cycle infrastructure, the document could be seen as suggesting that cycle users needs only need to be considered within the work done by the Birmingham Cycle Revolution. SR3 should be changed to read: "Plan, design and deliver infrastructure to enhance the attractiveness of the transport network for cycle users and increase their safety, building upon, but not restricted to, the work being carried out through the Birmingham Cycle Revolution." In the outcomes section, an additional measure needs to be added: "Accommodation of cycle users' needs in all new highways work, to a standard laid out in the Birmingham cycle design guide.", while the target area must be the whole of Birmingham.

(10) Push Bikes is very concerned that SR6 does not include the extension of 20mph speed limits to the rest of the Birmingham area. This is a very significant step backwards in attitudes to road speed in Birmingham at a time when other British cities are introducing 20mph speed limits across their whole area. It is vitally important that 20mph speed limits are widely implemented to improve the safety of Birmingham's transport network. Action point SR2 refers to the delivery of safer routes to schools, but that can only work if the routes are safe from door-to-door. The implementation of a short section of 20mph outside of a school is pointless if the children are being driven to school along roads that are 30mph because their parents are too scared of motor traffic to allow their children to cycle.

(11) In action point SP8, the outcome uses the phrase 'particularly as motorists and pedestrians'. It seems counter-productive to miss the opportunity to promote cycling when engaging with newly arrive community groups, and so we strongly recommend that action point SP8 specifically refers to the promotion of cycling with these community groups in order to encourage engagement with the Birmingham Cycle Revolution.

(12) In action point SP12, reference is made to 'exploring extending awareness sessions to bus operators', but Push Bikes has been informed that BikeRight! are already delivering this training to bus drivers in the West Midlands area. It is important that this training is ongoing, and does not finish in 2017, as seems to be suggested by the timeline in SP12. New drivers are joining these companies all the time, and it is essential that as new drivers arrive, they receive awareness training.