Cycle Safety Action Plan

I have put together some comments on behalf of TABS regarding this.
I known it's tl:dr but if you have a chance to look and comment and make any suggestions there is time this week before I forward this to TfL

Cycle Safety Action Plan
(see - https://consultations.tfl.gov.uk/cycling/draft-safety-action-plan)

CASP 2 draft feedback

General points additions and amendments:

p1
Cycling promotion:
While safety is and should be at the heart, cycling promotion should
also be explicitly stated from the outset. Promotion of active travel
needs to be stated and be included in the 6 road safety commitments to
include a target for increasing trips by bike. While this may not seem
a pure road safety commitment more people cycling (and walking) and
the effect of this in getting drivers used to sharing the road with
cyclists helps greatly to improve road safety.

(front cover)
With a view to promoting cycling and taking into account the current
lack of any legislation regarding the wearing of helmets we think that
the images on the front showing every person on a bike wearing a
helmet isn't balanced or realistic. Change the front cover to show a
mixture of helmeted and helmet-less cyclists. (images throughout the
rest of the doc are more balanced)

p4
Vulnerable road users (VRUs). While it is easy to categorise people
out of cars as VRUs and to focus the CSAP (and MCSAP/PSAP) on VRUs we think a better focus and more in line with a general harm reduction is to prioritise actions around the groups which CAUSE the most
harm rather than the current focus on people who get harmed. This
would create a significantly stronger document and send the message
that people liable to cause harm need to be managed and therefore
there needs to be a stronger emphasis on driving skills and
enforcement of bad driver behavior. This point doesn't negate the need
to up-skill cyclists at all but recognises that a mistake by a cyclist
or pedestrian is much less likely to harm other people whereas a
mistake (or recklessness by) a driver is more likely to harm others.

p6
So based on the above comment we believe that this document should
start with a focus on the people who cause the harm rather than the
victims. On p13 there is an analysis of who kills or seriously injures
cyclists which is good. On page 16 there is an analysis based on
evidence as to what drivers do that kill or seriously injure cyclists
This analysis is good and actions in the CSAP need to focus much more
on what to do to minmisie the source of the KSIs whic are mainly
driver behaviours.

For example 10% of KSIs are caused by drivers opening their car door
in the path of cyclists -while clearly cyclists should be and are
taught to ride away from car doors (and may get beeped and scared back
into the car door zone by drivers who don't understand why the rider
is in the middle of a lane), focusing on drivers teaching them to
check before opening their doors AND helping them understand why
riders ride away from car doors, is a much better evidence based
action likely to lead to fewer incidences of car-dooring.

p9
The comparison of fatalities per million population doesn't take into
account of the number of miles traveled by bike so having fewer
absolute fatalities compared with Amsterdam is pointless. This could
lead to a conclusion that in order to have fewer fatalities we need to
have fewer people riding! This is why a cycling promotion target is
important.

p10
As per above the link between more cyclists and fewer casualties must
be made and prioritising the reduction of harm would inevitably lead
to improved safety. It is important to know who is being injured but
even more important to know who is doing the injuring, where when and
how, in order to mitigate it happening.

p13
In the spirit of the comments above who causes the harm should be the
main focus. It would also be useful to include cycles in that table to
be able to assess to what extent cyclists are the cause of injury to
others and the ratio of cycles involvement as a ratio of modal share.
(I suspect cyclists harming other cyclists (KSI) would be pretty low
which would therefore lead to more focus on groups with a high ratio
of involvement. (The ratio for cabbies (4) is astounding and should
lead to TfL prioritising actions to mitigate harm this group causes.)

p16
Referring to action 23 in chapter 4. There is no action here about
driver skills and checking before opening doors.

p17
Good point about driver inexperience but not followed through to
actions on this point. Action 13 is about technology and action 19,
while better and about vru awareness in HC revisions and driver
training there needs to be a TfL action about driver skills.

p20
The note about contributory factors shares responsibility equally
between drivers and cyclists. A much better moral position should be
to apportion more responsibility to those able to cause more harm as
in many European countries.

p21
Is TfL proposing therefore to gather evidence as to what experience
cyclists require to build up skills for riding on urban roads. What
about evidence looking at whether drivers who are cyclists are better
drivers

p22/23
Regarding operation Safeway and exchanging places. There needs to be
more emphasis on the balance here. Some in the cycle community see
this as targeting cyclists and some officers offering their personal
opinion regarding PPE. So for example a rider is pulled over while a
driver on their mobile passes by unchallenged. The SUD element of any
exchanging places should be extended to taxis and other vehicles and
priorites over getting cyclists in the cab of a lorry.

There is a strong case for a driver safety (harm reduction) action plan DASP