DfT – TSRGD 2015 consultation

To a call by the DfT consultation on the revised Traffic Signs Regulations and General Directions 2015 Newcycling (Newcastle’s cycling campaign, 1,300 members, volunteer organisation, constituted, formed in 2010) would like to respond to your request about views. Our views on consultations like this one are reached by way of a Committee, formed to uphold aims, objects, vision and reputation of the organisation.

You state that “the draft has been put together following intensive consultation with stakeholders over the last few years” – the landscape is fast changing in relation to cycling, walking and their vital contribution to liveable cities, and we would like this statement to be re-examined. It may be necessary to consult and include organisations and views that had previously been left out. We have to warn that the proposed revision to TSRGD, as it stands, risks being out of date as soon as it went live next year.

As a close affiliate to CEoGB we support their views and comments wholeheartedly. In addition, we were hoping to make the following more general observations:

1. TSRGD – even in its proposed draft version – remains too unnecessarily complex. It has the feel of an evolved rather than a structured document. It’s complicated and at times convoluted set-up makes it difficult for a pragmatic and informed use of the practitioner. Locally, practitioners can too easily ‘hide behind’ a raft of regulations.

2. As TSRGD’s impact filters down to the actually road user, it can in its implementation even hinder a layperson’s interpretation too readily. Road signing and marking should be user-friendly, intuitive and hence must, above all, be simple to the end user instead of resulting in a forest of overbearing lines and signs drowning a street (street clutter). We suggest that the TSRGD requires a more thorough (root and branch) review to simplify for today’s demands and include for future plans of healthier cities and modal shift towards sustainable means.

3. We’d like to see more innovative cycling elements included. We suggest a gap analysis with, for example, Dutch documents and a robust needs-based assessment to translate it to the UK road user. Looking at what cycling infrastructure solutions work elsewhere, and putting them into a UK context and backdrop is much needed. From what we can see, DfT, in many ways, is stifling innovation. It is pushing innovation to the local level by asking local highway authorities for costly exemption applications. It is making local highway authorities pay for making innovation happen. Much more coordination and leadership must be shown by DfT to close the cycling infrastructure design gap, as well as guide and lead local highway authorities, constructively and cooperatively.

4. On a related subject, we’d like to express the urgency that high quality cycling design standards are needed. As a suggestion, CID LTN2/08 should be reviewed and updated to bring it in line with future transportation needs and modal shift and public health policies – before it’s then elevated into a standard, possibly under the DMRB document umbrella.

Naturally, we’d be happy to give further representation, in the meantime we hope our reply is of use.

Katja Leyendecker, chair