Cyclist.ie made a detailed submission today, Sun 22 Nov 2020, to the Road Safety Authority in regard to the preparation of their Road Safety Strategy 2021-2030 (as per this formal consultation process). You can read our submission below. A big thanks to the Cyclist.ie Executive Committee for leading on this and to our many volunteers for their valuable inputs.
Questions 1 and 2:
What are Our Road Safety Priorities for the coming 10 years?
And Suggestions to Meet Them.
1.1 Stockholm Declaration 2020
Ireland is a signatory at this year’s Third Global Ministerial Conference on Road Safety. The agreed Stockholm Declaration is a wide ranging document that sets out the basis for a broader road safety approach, and recognises that ‘the overwhelming majority of road traffic deaths and injuries are preventable and that they remain a major development and public health problem that has broad social and economic consequences’.
In this upcoming RSS, the RSA needs to ensure that the statements and resolutions of the Stockholm Declaration are mirrored in Ireland’s RSS.
Cyclist.ie urges that the RSA take full cognisance of the 2020 Stockholm Declaration statements and resolutions, as signed by the Government, and seek to ensure we fully meet our international commitments under this declaration.
1.2 Beyond Vision Zero
The RSA has outlined that the main principle of the new 2021-30 RSS is for a Vision Zero approach. This Vision Zero approach ensures that broader aspects of road safety planning are considered such as road design, speed limits, as well as the road user.
But a further development on this approach has evolved titled Beyond Vision Zero (BVZ) – This approach advocates not just for reduction of road fatalities and injuries, but also for the parallel promotion and increase in cycling and active travel, a broader whole society approach. This approach also mirrors aspects of the 2020 Stockholm Declaration. Resolution 2 of the Stockholm Declaration broadly describes this approach – see below.
Address the connections between road safety, mental and physical health, development, education, equity, gender equality, sustainable cities, environment and climate change, as well as the social determinants of safety and the interdependence between the different [Sustainable Development Goals] and targets are integrated and indivisible;
Essentially, more people walking and cycling is an indication of a safer and healthier transport system, as people grow to have greater confidence in the overall safe road designs. These increased levels of participation need to be also backed up by regular monitoring and research.
Cyclist.ie urges the RSA to move from Vision Zero to embed a Beyond Vision Zero concept into our national Road Safety Strategy 2021-30, to ensure a more holistic approach to road safety, and public health.
1.3 Collision Data and Analysis
As in all systems approaches, good data is a critical baseline information point to enable clear analysis of the issues arising. Throughout the last RSS the ready availability of good quality data, on all aspects of road incidents, has been found wanting, much of this problem related to doubtful GDPR-related decisions, but also to the lack of resources invested in data researchers. An example of the paucity and delays in data analysis is exemplified by the latest detailed analysis on Serious Injuries available now in late 2020, is from 2017, 3 years ago. Is this really acceptable?
If high quality data is unavailable it is more difficult to diagnose the problems and the required solutions. It is critical that the public availability of anonymised data is delivered regularly, and as soon as possible following road incidents. This will likely involve additional training for Gardaí, to ensure all data is recorded at locations of incidents, that there is increased cooperation between An Garda Síochána (AGS) the RSA and the Health Service Executive in regard to hospital Emergency Department data. That there will be improved technology in collecting the relevant information, and increased investment in data analysis, to ensure the timelines between incidents and analysis is reduced. That annual reports are published jointly by Garda and RSA on all aspects of road incidents from death and serious injury analysis to conviction levels for driving offences.
Cyclist.ie wants any GDPR-related issue to collection and analysis of road incident data be resolved, resources for data research to be increased, and data be released to Ireland’s research community as soon as possible for speedy analysis and feedback into ongoing RSS development. Annual reports must be delivered to measure how we are performing on the various measures set out.
1.4 Reduction of Injuries to Vulnerable Road Users (VRUs)
As road deaths to VRUs have generally decreased or flatlined in recent years, available analysis from AGS / RSA would indicate that serious injuries to VRUs have been increasing, both in terms of absolute numbers, and disproportionately in comparison to vehicle occupants. This data, which unfortunately is only available up to 2017 highlights the need to seriously target issues which will support the safe use of our roads by VRUs. More frequent, and more detailed reports such as the recent Cyclist Injuries 2016-18 report need to be made available. But also, and this has not been a factor in reports issued by AGS and RSA, through analyses of the information obtained, solutions need to be developed. Solutions such as infrastructure design improvements, reductions in speed limits and technology use, to make our roads safer, need to be put forward.
This continuing large increase in serious injuries to VRUs needs to be tackled and solutions addressed. Simply presenting figures related to deaths and injuries is not enough. The figures need to be drilled into, and need to be analysed critically, and without delay. The impact of serious injuries on people’s livelihoods, and the economy in general, is profound and needs to be factored into RSS 2021-30.
While recognising the specific commitment to VRUs in the Draft RSS 2021-30, Cyclist.ie demands particular emphasis on more frequent, timely, and critical analysis of serious injuries to VRUs, to enable timely solutions to these serious injuries to be addressed.
1.5 An Garda Síochána to set up a dedicated online portal for the processing of video evidence
The recently introduced ’Dangerous Overtaking of Cyclists’ law has given some increased protection for cyclists on our roads, but the law needs to be strengthened through the use of technology, common in other jurisdictions, e.g. London’s Metropolitan Police. This technology allows cyclists and other VRUs, and all road users, to report dangerous overtaking offences via a dedicated police online portal, from where the footage can be triaged by a dedicated team and sent for prosecution as deemed appropriate. At present this reporting can only be done by physically visiting a Garda station and reporting the incident with camera footage of dangerous overtaking and other driving offences. This reporting system needs to be completely updated.
We also want to see the implementation of all the recommendations made in the RSA 2018 Report on Minimum Passing Distance (MPD), and ensuring that Garda Traffic conduct Operation Close Pass as part of these recommendations.
Cyclist.ie wants to see the rapid introduction of incident reporting via a dedicated online portal, as is common in other jurisdictions, and the implementation of RSA’s recommendations on MPD.
1.6 Speed Limit Reduction
Speeding accounts for a significant portion of road traffic deaths, and despite this awareness, drivers continue to exceed posted speed limits regularly, as indicated by all recent RSA Free Speed Surveys. There is no doubt that vehicle speeding also accounts for a significant proportion of serious injuries, which have debilitating social and economic effects. As outlined in the Stockholm Declaration (Resolution 11), and recently introduced in the Netherlands all default urban speed limits should be reduced to 30kph. We also need a suite of lower ‘fit for purpose’ speed limits on our rural roads, and not a blanket 80kph limit. Cyclist.ie recommends consideration of a new ‘Rothar Road’ designation (minor rural roads waymarked for cyclists) where the speed limit is tailored to the safety of all potential users, and where people on foot and on bikes are ‘expected and respected’. See https://cyclist.ie/ruralvision/
We would also like to see annual Free Speed Survey updates to measure progress on speeding issues. Additionally, we would like to see the RSA making formal submissions on all measures affecting road safety, and especially in regard to proposals for Local Authorities to introduce lower safer speed limits. We also want to see the national Speed Limit guidance updated, the corresponding website https://www.speedlimits.ie/ kept up to date, and engineering features introduced into speed limit setting.
Cyclist.ie seeks the introduction of a default 30kph speed limit in all urban areas, the introduction of ‘fit for purpose’ speed limits on rural roads, and the updating of our national speed limit guidelines.
1.7 Safe Routes to School
The present Programme for Government outlines the provision of Safe Routes to School as a transport priority. This is a critical proposed development, as the numbers of young people cycling have dramatically dropped since the mid-1980s, and the school gate car drop has become a feature of our modern obsession with the car. Shockingly, just 694 girls cycled to secondary school in 2016 (as per the most recent Census data and as discussed on page 14 of the 2018 Get Ireland Cycling Strategy Framework produced for Sport Ireland). These graphs of both ‘Active Travel’ and cycling to school indicate the vast range across the country.
The growth of Cycle Buses, parent-led initiatives to protect children cycling to school, is a development that should not be necessary. Children should be enabled to travel safely to school by bike or on foot as far as possible. Safe routes to school, and not just designated ‘school streets’, need to be prioritised, and also accompanied by lower speed limits for motor vehicles.
Cyclist.ie seeks a concerted national effort, with appropriate guidelines, to ensure that facilities for children countrywide to cycle and walk safely to school are provided.
1.8 Roads Policing and Legislation
The need for continued enforcement of road traffic infractions is unfortunately a continuing requirement of a road safety policy. In line with the resolutions of the Stockholm Declaration, Ireland must ensure that the requisite resources for this necessary policing are provided and that all road traffic infractions are punished in line with legislation. Legal loopholes need to be clearly eliminated to ensure that all unacceptable driver behaviour is properly prosecuted. Crucially, the road traffic legislation needs to be consolidated and simplified to ensure that all enforcing authorities and road users can understand it. Cycle-friendly legislation, such as ‘presumed liability’ measures, contra-flow cycling, and left-turn-on-red traffic lights, needs to be introduced, similar to our European neighbours, to encourage more people to cycle, and thus make our towns and cities healthier and more people friendly. Gardai need to be regularly updated and trained and able to comprehend road traffic legislation in its entirety, including new laws introduced.
Cyclist.ie wants to see the full complement of the Roads Policing Unit in the Garda reached. We also seek a consolidation of the existing road traffic legislation, and elimination of legal loopholes. New cycle-friendly legislative initiatives need to be introduced to encourage greater levels of cycling. And Gardai must be au fait with traffic legislation.
1.9 Targeted Education Programmes
Where data and research indicate particular road safety issues, the RSA needs to develop specific messaging for different groups (across age, gender, class, ethnicity, locality, etc) with stories told in their own words. Local Authorities could, for instance, do this through their Healthy Ireland / Local Community Development Committees. But a particular opportunity for further education and updating of drivers on road safety issues occurs during the times of mandatory vehicle NCT testing. It is a chance to put drivers through a form of ‘revision’ testing or at the least reminder points, while they await the results of their NCT. Cyclist.ie would also like to see taxi drivers undergo a Certificate of Professional Competence (CPC) test.
Cyclist.ie wants to see targeted messaging of different population sectors to increase the impact of the messaging, as well as the introduction of specific programs for drivers having their vehicles NCT tested, and a CPC for taxi drivers.
1.10 Language Used in Messaging
So often in the media the use of language, in such descriptions as ‘cyclists versus cars’ or the continuous use of the term ‘accident’ when the word ‘collision’ or ‘crash’ is more appropriate, can lead to a perpetuation of the misguided assumption that people on bikes are somehow fundamentally different than people who drive. In the UK, guidelines are being developed to encourage responsible reporting around cycling road collisions and incidents, and to avoid particular language that can lead to the ‘othering’ of people on bikes. In short, those choosing to cycle or walk need to be spoken about as people using a particular form of transport – and, most likely, they will be multi-modalists, i.e. users of different transport modes for different trip types. We need to get away from the divisive language of ‘cyclist’ versus ‘motorist’ versus ‘pedestrian’ “at war with each other” as the tabloids unhelpfully describe it.
RSA and Gardaí interacting with posts on social media will allow opportunities to educate road users on issues they may have little understanding of. The addition of a cycling module in the rules of the road would help with this in the future but as a beachhead strategy, behaviours such as riding in primary position are not widely understood beyond those who cycle. Other misunderstandings will also present themselves and allow further education opportunities. Many UK police forces use their social media accounts for this purpose.
Cyclist.ie would like to see media guidelines developed on collision reporting, and general road incidents, in line with the developments taking place in the UK.
1.11 Rules of the Road and Driver Testing
During this upcoming RSS we would like to see an open consultation process on suggested amendments to the RSA Rules of the Road (ROTR) publication, whereby stakeholders provide inputs on particular elements of the publication. Up until now, the process by which the ROTR publication was updated has been opaque.
Additionally, we recommend that there is a specific cycling module as part of the driver testing process, such that any prospective driver learns to understand the expected positioning of cyclists on the road, and their safety requirements. We would further strongly recommend that every trainee driver of a heavy goods vehicle needs to undertake on-bike training to understand experientially what it is like to be on a bike as part of the mix of vehicles in a busy (multi-lane) road environment. Currently, HGVs are over-represented in the road traffic statistics on serious and fatal collisions involving people on bikes.
Cyclist.ie wants to see an open consultation on the Rules of the Road publication, and the introduction of a specific cycling module as part of the driving test.
1.12 Reduce Emphasis on High-visibility Clothing as a Solution
While the ‘Be Safe-Be Seen’ message is important for all road users, the preponderance and ubiquity of RSA hi-viz jackets has sent out a message that walking or cycling is an inherently risky exercise. In court cases and inquests following incidents, the references to wearing or non-wearing of hi-viz has often skewed the verdict against the victims of the incidents. This emphasis on what the person cycling or walking needs to do to keep safe, creates a false impression that once you don hi-viz and/or a helmet you’re safe. It shifts the onus from the real source of danger, the large vehicle, the speeding vehicle, the drunk or distracted driver, or the unsafe infrastructure.
Hi-Viz is not a solution to road safety. The messaging and level of distribution of hi-viz has tended to ‘dangerise’ the simple acts of walking and cycling. Positive messaging, such as the safety, health and fun aspects of walking and cycling, and greater emphasis placed on road planning and driver behaviour, as illustrated in the hierarchy of controls graphic below, and all road schemes, whether, maintenance, upgrades or new developments, must include consideration of walking and cycling. PPE is at the bottom of this hierarchy.
Cyclist.ie would like to see greater emphasis on better planning of roads to factor in safe walking and cycling, greater emphasis on the safety, health and fun of cycling, and less emphasis on wearing of hi-viz by pedestrians and cyclists.
1.13 Working Together Groups
The proposal under the previous 2013-20 strategy of recommending the setting up of ‘Working Together’ groups in Local Authorities in order to progress the Strategy, was a positive idea. Unfortunately, as it was just a proposal, many Councils did not set them up, and the difference in approach to the Strategy varied from Council to Council. We propose that the setting up of these Working Together Groups in each Council area should be obligatory, and should contain at least the following representatives:
Council officials and engineers; Councillors; Garda Traffic senior person; RSA representative; NGO sector groups, including cycling representatives.
Cyclist.ie recommends that the Local Authority Working Together groups be made mandatory for Councils to set up, and with an agreed membership.
Any Comments on 2013-20 Strategy?
While a mid-term review of the 2013-20 strategy was carried out in 2016, we still await a final review of the Strategy in 2020. This necessary review is critical in evaluating the past strategy and in trying to shape the ambitious targets for the new 2021-30 strategy.
The 2013-20 Strategy specifically targeted a decrease in road fatalities to 124 in 2020. While road deaths have decreased considerably we note that the most recent available data shows that there have been 129 deaths already in 2020, so unfortunately this target will not be met.
Similarly, with serious injuries the previous strategy targeted a level of 330 serious injuries in 2020, as being ‘realistic’. But we know from the most recently available data in the RSA-Garda analysis from 2019, but related to 2014-2017, that serious injuries were increasing year on year, and had reached a level of 981 in 2017 nearly 3 times above the original target. 43% of these serious injuries were to pedestrians and cyclists, the most vulnerable of our road users.
So, as can be seen from the above data we have patently failed to meet the targets set out in the 2013-20 strategy. The question must be addressed as to what form targets should take, and how can we really move towards a Vision Zero, or Beyond Vision Zero strategy for the 2021-30 strategy?
While government departments and agencies were listed stakeholders in the previous 2013-20 strategy, no other NGO or Community stakeholders were listed. All stakeholders should have been listed, and the value of community and NGO stakeholders was borne out by a number of legislative and legal interventions during the period of the previous strategy.
Any International Examples that would help improve Ireland’s Safety Performance?
Operation SNAP is a good example from Wales of the use of a dedicated online Police portal for the reporting of video footage of alleged traffic violations. http://gosafe.org/
Here is an example from Northumberland Police on Twitter, encouraging cyclists to send in their footage. Note the Police staying with the conversation and pointing out any misinformation or misunderstandings – https://twitter.com/northumbriapol/status/1328281713785643009?s=21
Any other Comments?
Cyclist.ie would have wished that:
1 – The Review of the 2013-20 strategy was published prior to advancing this new Strategy in order to ensure that all elements were captured. A few months delay in developing the new strategy would have little effect on the outcome.
2 – The initial consultation period was longer to allow local groups, NGOs, and individuals to fully consider the implications and possibilities within a new Strategy.
3 – Wider advertising of the Strategy 2021-30 consultation had been undertaken, to encourage greater participation and input from the wider population.