We respond to the further call for evidence per http://www.senedd.assemblywales.org/mgIssueHistoryHome.aspx?IId=5750, closing on 5 April 2013.

1. Is there a need for a Bill aimed at enabling more people to walk and cycle and generally travel by non-motorised transport? Please explain your answer.

Yes. The inappropriate use of public space by fast motorised transport impacts seriously on our high streets, our waistlines, and our society in general. All desperately need easy pleasant non-motorised transport.

2. What are your views on the key provisions in the Bill, namely –

the requirement on local authorities to prepare and publish maps identifying current and potential future routes for the use of pedestrians and cyclists (known as “existing routes maps” and “integrated network maps”) (sections 3 to 5);

Given sufficient ongoing authoritative and well-informed involvement by Ministers, this requirement may be useful. It is unfortunate that no definite criteria of quality are laid down - Edinburgh for example once presented an impressive mileage of "cycle routes" by asserting that all its bus lanes were suitable for cyclists. Which they weren't. I note the powers of direction given to Ministers to "enforce a suitable and consistent standard for mapping active travel routes across Wales." To allow for ongoing improvements to the relevant standards and guidelines and avoid reference to material which may become outdated, the aims should perhaps be defined as a network that will allow a grandmother to have a safe and pleasant journey with her six year-old grand-daughter. This or similar language should be part of the Bill.

the requirement on local authorities to have regard to integrated network maps in the local transport planning process (section 6);

Good. This will at least prevent responses such as a recent one from a senior Highways officer, dismissing a suggestion with "I am not responsible for promoting cycling".

the requirement on local authorities to continuously improve routes and facilities for pedestrians and cyclists (section 7);

Good, though it falls seriously short of a requirement to aim for an effective network.


the requirement on highway authorities to consider the needs of pedestrians and cyclists when creating and improving new roads (section 8)

Again, good, but "consideration" does not necessarily translate into real-world improvement. The requirement should be identify and map changes that would create a fully integrated network for walking and cycling, *with safe and appropriate routes for all journeys, including those on or adjacent to all present highways*, and to develop a prioritised list of schemes to deliver such a network. I note that the Explanatory Memorandum does contain such language (local authorities being required to "identify what enhancements, upgrades and new infrastructure would be required to enable people to make continuous and safe journeys by foot or by bike"), but does not give it the force of statute. Such language should be included in the Bill. 

3. Have the provisions of the Bill taken account of any response you made to the Welsh Government's consultation on its White Paper? Please explain your answer.

No - these remarks are substantially repeated from my earlier response.


4. To what extent are the key provisions the most appropriate way of  delivering the aim of the Bill?

Their intentions seem admirable but the language is vague enough to allow the present lack of progress to continue. We recommend minor but vital changes to give the process a momentum of its own, rather than depending entirely on routine Ministerial attention.  

5. What are the potential barriers to the implementation of the key provisions and does the Bill take account of them?

The key barrier is the perception, within Highways Departments in particular, that walking and cycling is something abnormal, done by eccentrics and enthusiasts only; as part of this perception, very few Highways departments have any expertise whatever in designing active transport facilities and any "improvements" are commonly a ludicrous waste of public money. Additionally, there is a concomitant perception that better transport requires, indeed is, faster motor transport. This is incorrect - mild traffic calming will be an important part of any comprehensive solution - but is a serious barrier to progress.

To the extent that Ministers are actively involved in pressing for genuine improvements, this Bill may allow these barriers to be overcome. Sadly the Bill as presently drafted will require ongoing, time-consuming, well-informed, forceful support from Ministers to achieve anything at all. More definite language is needed, requiring authorities to identify a good-quality aspiration and work towards it.


6. What are your views on the financial implications of the Bill (this could be for your organisation, or more generally)? In answering this question you may wish to consider Part 2 of the Explanatory Memorandum (the Impact Assessment), which estimates the costs and benefits of implementation of the Bill.

The wider costs and benefits of the legislation seem to be modelled without use of the best evidence, from international comparisons. The idea that genuinely better facilities might increase accidents and their costs, or might fail to give a dramatic improvement in cycling rates and economic activity, appears incompatible with the Dutch and other continental experiences. In the Netherlands and elsewhere, very large increases in walking and cycling and absolute reductions in accidents have followed from better facilities; Dutch accident statistics have improved far more than the British.

7. To what extent has the correct balance been achieved between the level of detail provided on the face of the Bill and that which will be contained in guidance given by the Welsh Ministers?

We note serious flaws which may condemn the entire effort to ineffectiveness. Authorities should be required not merely to "consider improvements", but to describe a good-quality aspiration and to work towards it.

8. Are there any other comments you wish to make on the Bill that have not been covered in your response?

No.

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Richard Keatinge

for Safe Streets Anglesey