Dr Bunbury
Bunbury Towers
Wildeville
7/3/2018
Director, Ops Directorate (Yorkshire and N.E.), Highways England
3rd Floor South , Lateral, 8 City Walk
Leeds LS11 9AT
Dear Sir/Madam,
I write to you concerning the A63 Trunk Road (North Cave Interchange to Daltry Street Interchange) (Prohibition of Cyclists) Order, currently in its consultation phase. I was highly concerned to read of the proposal to ban cyclists from this section of the A63. As a regular user of the road, both by motor vehicle and pedal cycle, I wish to register my strong objection to the proposal, which is based on several flawed premises and lines of reasoning.
The statement of reasons for the proposed TRO cites six incidents involving cyclists in five years, including one fatality. This is a very low figure, much lower than for many of the roads nearby in the region, or indeed in the country Please therefore:
• State what threshold frequency of incidents triggers you to seek such a TRO.
• Justify why this threshold is appropriate for a ban on cyclists - when as noted, by UK road standards the A63 is actually very safe.
• List the chain of actions you have so far taken in the course of cyclist risk reduction, before taking the extreme last resort of banning a class of user from a general purpose road.
• Show your analysis as to whether other user groups in addition to cyclists are placed at risk on the road, and your plans for improving their safety.
• Show your risk analysis of the alternative routes proposed for cyclists. Since this TRO is ostensibly about cyclist safety, and there are many roads in the region that have experienced more than the solitary fatality on the A63 this century, please justify that you are not pushing cyclists onto roads that are more dangerous than the A63 itself.
• Show that you are applying this policy consistently, by providing incident statistics for the other roads you manage, showing your course of action for each road that falls above the threshold.
• State why such a policy exists, and how it is within your remit to impose a blanket ban on road users from general purpose roads. If you are applying a policy of removal of cyclists or indeed any other user group on a national scale, this counts as a change in purpose of a whole raft of general purpose roads, and should be debated in parliament.
• Justify how a policy to remove people’s ability to cycle on general purpose routes at such a low, and unremarkable threshold of risk, fits with Highways England’s cycling policy of “identifying, prioritising and investing in ways to improve cycling conditions”.
• Alternatively, if no such policy and data exists, justify why you have taken an un-evidenced and ad-hoc approach to road safety.
Please note that I will not accept any responses that justify cyclist risk with reference to anything other than casualty and collision statistics. As a professional scientist I am used to working with evidence and probability; I note that the resolution to which a risk can be determined - the ‘standard error of the mean’ – improves with sample size. Cyclists have used the A63 for many years, so ample data exists to calculate risk based on evidence rather than supposition. Any safety concerns based on fear of future collisions, not on evidence from past use, are therefore invalid: e.g. high speeds may worry some, but the low collision rate shows that the road is well able to handle the speeds and is a safe place to cycle.
Further to this, the statement of reasons states that “Cyclists are travelling on a carriageway that carries average speeds of 65mph” as justification for this ban. Notwithstanding the fallacy of arguing a safety case based on average speeds – as discussed above – 65 mph is within 5 mph of the national speed limit for both single and dual carriageways outside towns. I fail to see why a car doing 65 mph near Melton is any more dangerous that a car doing 65 mph anywhere else in the UK. Please therefore:
• Explain to me why a 65 mph speed is more dangerous on the A63 than on hundreds of other roads where cyclists are permitted to ride, and hence why it uniquely justifies banning cyclists on a twelve mile stretch of the A63, and not on every extra-urban A and B road in England.
Your traffic count data also gives me reason for grave concern at the lack of thoroughness with which this TRO proposal has been written. Traffic counts of over 2500 vehicles per hour are cited in the statement of reasons; however, the annual average daily flow (AADF) for CP 56635 was last counted as 691 vehicles per hour - four times lower than the figure you cited - which is especially baffling given that most cyclists do not use the road at peak use times. Please therefore:
• Provide evidence to support the assertion that the road carries traffic four times in excess of the AADF figure. If you have used a peak flow figure, correlate it with the cyclist traffic count to show that a peak rather than an average vehicle count is relevant to cyclists using the road.
Finally, the statement of reasons claims that “East Riding of Yorkshire Council, Kingston upon Hull City Council and Humberside Police support this proposal”. Freedom of information requests have since revealed that the first two of those bodies were never consulted. This means that Highways England has misused public money to willfully misrepresent not one but two other public bodies, in an attempt to support one of its own measures. This double misrepresentation is a gravely serious matter, which I believe is amply sufficient to warrant disciplinary action against the culprits. Please therefore:
• Assure me that a full-scale investigation is being conducted to uncover the source of the misinformation, and that the full extent of your disciplinary policy will be used to reprimand those responsible and ensure this shameful misinformation-based approach is not used again.
I do not believe that ill-evidenced schemes such as this one are a good use of public money. I request that you respond to each of the objections I have bulleted above, and that you consider them when assessing the TRO proposal. I sincerely hope that the ensuing action is to scrap the proposal, as it is unjustifiable based on from crash statistics and average speeds, it cites inaccurate traffic counts, it misrepresents other public bodies and it lacks any analysis of alternative solutions. This proposal serves no purpose other than to needlessly curtail some taxpayers’ legal, safe and harmless desire to transport themselves from place to place along general purpose roads.
Yours sincerely
Dr B
