London Cycle Design Standards Draft Consultation: My Comments

Published 2014-07-23 at 08:08

The updated London Cycle Design Standards draft has been out for consultation for a month now (still open until 11 Aug) and I've finally got around to trawling through it. In my defence, it is over 350 pages long. I encourage you to read it and send TfL your comments, if only because that's what public consultation is for. Despite common opinion, sometimes we (the industry) consult on things because we actually do care what you think.

All in all I think it's a good document. It certainly aspires higher than the last version of the LCDS and than some national cycle groups (that shall remain nameless). As ever, if it falls down, it'll be on the implementation. Let's hope we can get some buy in from Local Authorities because realistically, these are going to end up being de facto national standards soon enough.

I believe comments are ultimately public record anyway (or at the least FoI-able) but in case anyone cares, or if I have picked up something someone else didn't notice, these were my comments to TfL. They'll likely only make sense alongside the consultation document; sorry about that.


Section 1
  • 1.1.3 (and 1.2): "Levels of Service" means something specific in transport terms; e.g. the Highway Capacity Manual traffic LoS A-F measure or Fruin pedestrian LoS. It should be called something else in this context to avoid confusion as this is explicitly not the same thing.
  • p9, Para 5: Specify the US cities. Some have done well (i.e. NYC) but others have made a hash of it.
  • p11, Para 12: The cyclists dismount sentence should be amplified. This is a key point which is rarely understood by stakeholders or less-skilled designers.
  • 1.3: How does this relate to LCN and LCN+? Are we integrating these or abandoning them?
Section 2
  • Mixing 0,1,2 (0, 3, 6) ranking with RAG status is confusing. The CLoS starts with numbers. The junction starts with RAG and suggests you can number it. Inconsistent.
Section 3
  • Fig 3.1 Directness is not (also) being measured by ratio of actual route distance to crow-flies or shortest road distance.
  • 3.2.10 Why are we not adopting the 450mm clearance for bicycles too? The justification is the same as for motor veh.
  • 3.2.19 Worth drawing attention to more innovative drainage solutions in these cases such as Aco Kerbs or similar; this could avoid the need for major carriageway crossfall adjustment.
  • 3.2.21 Or we could recommend some clearance (if possible) so as to avoid the possibility of door collisions.
  • 3.2.32 Also an issue with enforcement of banned turns/U-turns; see Pennsylvania Ave in Washington DC as a demonstration of these issues.
  • 3.2.34 Appropriate speed choice but doesn't match with DMRB/LTN2/08 design speeds. Should be noted.
  • 3.2.39 A "bad practice" picture here might be helpful to highlight the issue.
  • 3.3.4 If it was busy enough to warrant a bus lane to begin with, it's almost certainly not going to be appropriate to call it a Quietway.
  • 3/03 These are only appropriate where the motor veh speed is already similar to the cycle speed. They should not be used as a traffic calming measure in of themselves otherwise you're forcing higher speed veh to encroach into the cycle lane.
  • 3.3.32 Wide advisory lanes in this context may risk being perceived as a running lane or markings delineating parking.
  • Fig 3.10 These values for full-shared shared-use is unlikely to be enough given we have just established above it that even low flow segregated shared-use required 3.0m.
  • 3.4.16 1.8m may be too narrow for modern cars. These numbers should be more clearly an absolute minimum otherwise there is a risk that many vehicles may encroach the 0.5m gap and reduce its effectiveness.
  • 3.4.23 Overtaking veh traffic on the inside by bike is potentially dangerous but not illegal in the absence of lane markings.
Section 4
  • 4.1.16 This point is absolutely key. Often the LHA can insist on refuse or LGV dimensions which drive the design and yet are only appropriate a few times per week.
  • 4.1.18 Second bullet: Low flow should be clarified because protrusion is likely to be a hazard to the cyclist.
  • 4.2.7 To the cyclist, a push-button is rarely a good option.
  • 4.2.9 Fig Right: I don't know where this is but I'm certain that "keep clear"s across a three(!)-lane carriageway on the TLRN is not a permeable or good solution.
  • 4.2.12 Should we not be working towards the first option being shared-use zebra crossings (reinforcing existing compliance and understanding) instead of this more complex arrangement?
  • Fig 4.7 Why shouldn't refuge islands be considered on a CSH?
  • 4.3.5 All of these examples are signed incorrectly (diag 610s); the markings are a disaster (wrong hatching, and the dbl yellows on the top one?!) and the left hand one clearly deviates the cyclist.
  • 4.3.9 Last bullet: this shouldn't be in the overrun zone of the corner or you risk the cycle stands being regularly demolished by drivers.
  • 4.3.13 If the material has no tactile differentiation then how is this appropriate for the visually-impaired?
  • 4.4.4 Even the standard 120s is likely to be way too long given existing compliance issues with many cyclists. Pedestrian considerations are more likely to be appropriate here. The pedestrian countdown project may be instructive here.
  • 4.4.26 Also, taking LGVs off inappropriate local routes seeing as these carry the disproportionate fatality risk.
  • 4.4.38 Current trial of this at the western end of the Itchen Bridge in Southampton.
Section 5
  • 5/02 Realise this is a draft but some of the dimensions are illegible.
  • 5.6.22 "Research shows..." ...what research? Citing it would be useful to the practitioner.
  • 5.8.8 3rd Bullet: This is a good point for any sort of parking. Particularly where those conflicts interfere with cycle facilities (e.g. mandatory lanes).
Section 6
  • 6.2.10 Bullet 3: Again, disagree with this. Should be aiming to provide edge-shyness outside of the facility in the same way we do for motor veh.
  • 6.3.4 Would suggest "very unlikely to be appropriate" instead.
  • 6.3.12 Second picture: Still think this is a terrible example of a cycle crossing.
  • 6.3.16 Image: if we are going to show the unstretched version then we still need the vertical measures to be in the correct dimensions. The height is shown as 2750 but the grid division is still shown at 100?
  • 6.4.12 Route conf signs: Half mile? Why abandon metric at this point in the document?
Section 7
  • 7.2.14 General comment: Is there any experience of inter-Authority colour transition?
  • 7.2.14 There is no RAL5075.
Section 8
  • 8.5.3 Typo line 3: "provided" should be "provide"
  • 8.5.13 A very good point for making a case; should be elucidated more.
  • Background para 3. The first sentence is incomplete.
General Comments
  • Seems to skim the enforcement issue which is key for making a lot of these things work. TfL should be engaging with The Met more on this rather than letting them penalise cyclists trying to avoid being injured/killed in current poorly designed spaces.