Object now to kill off DfI’s outdated cycling design culture


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Two Department for Infrastructure (DfI) consultations on cycle route Orders closing this December need to be objected out of existence if the Department are ever going to be compelled to use best practice design standards for cycling development. Your action is needed now!

The consultations

Cycle Routes – Ballymena (The Cycle Routes (Amendment No. 2) Order (Northern Ireland) 2021)

This consultation deals with proposals on main roads connecting housing estates on both sides of the Cushendall Roundabout in Ballymena, and from the Larne Road Roundabout towards the centre of town. The “cycleway” is exclusively shared footways, effectively rebadging of existing pavements and creation of / widening of other pavements. Because that’s the deeply engrained culture within DfI – tick-boxing cycle routes onto pedestrian space, while never daring to inconvenience drivers by touching the precious road carriageway.

Look at the shared footway (across a bus stop), look at how pedestrians and cyclists are taken off their desire line to suit vehicles, look at those ridiculous side road sweeps, look at the central hatching making a mockery of any claim to ‘space limiting separate cycling options’..

In fact of DfI’s four operational arms, DfI Roads Northern Division are the most hardened purists when it comes to shared footway cyclewashing, reporting that 100% of their cycle route projects in the last five years were shared footways. This is despite clear operational guidance not to deploy shared use schemes in urban settings. By track record and current work, they refuse to engage with modern thinking on cycling – it’s time to object them into the 21st century.

You can read the proposals and view the maps. Your consultation response must be in by 5pm on Wednesday 15 December 2021. See below for suggested text.

Cycle Routes – Belfast (The Cycle Routes (Amendment) Order (Northern Ireland) 2021)

This consultation deals with attempting to define a cycle route between the Comber Greenway at Tullycarnet through Ardcairn and the Stoney Road to the Stormont Estate. The proposal includes widening of an existing pathway from the greenway, adding chicane gates with the potential to reduce accessibility on another tighter path, (reasonably) using traffic-calmed residential streets, but relying yet again on shared footways through the Stormont Estate – and ignoring opportunities to tighten the radius of some epic junction sweeps which wouldn’t look out of place on a Formula One circuit.

That’s a two lane road with a junction into a two lane road, and the lovely dropped kerbs offering pedestrians (and cyclists, because, shared footway again) a whopping crossing distance of approximately 25 metres – DfI Roads Eastern thinking laid bare..

This consultation is on a smaller scale than the Ballymena one, but includes aspects where DfI Roads Eastern Division again are attempting to get away with substandard design to the exclusive benefit of vehicle traffic at the expense of pedestrians, and cyclists.

You can read the proposals and view the maps. Your consultation response must be in by 5pm on Thursday 15 December 2021. See below for suggested text.

The anticipated excuses

The excuses are already lined up on the Department’s side and are typical of the defensive “why aren’t you happy that we’re doing things for active travel?” tripe we’ve heard for years: 

  • These plans pre-date LTN 1/20 (the design document adopted by DfI in July 2020, which contains most inconvenient higher design standards, and is being largely ignored while DfI can get away with it) so our hands are tied and we have to proceed with the plans as they are.” When basic standards change, you react. When legislation (even if LTN 1/20 isn’t) requires you to stop doing an previous activity now deemed damaging, you don’t continue regardless. Either LTN 1/20 means something, and you take pride in creating the highest standard projects which will be in place for decades, or just come out and say “we don’t care, we’ll do what we like” and be honest with us. In terms of cycle route development, your world changed in July 2020, and legacy projects which don’t meet its requirements must be scrapped and reworked.

Frys Road, where DfI proposes to tarmac over grass strips (go sustainability!) yet cannot see any space to create a dedicated cycling facility, while the above Google Maps image shows there’s very little growth potential for cycling in simply retaining footway cycling

  • These schemes link communities with schools / workplaces etc and by objecting you deny active travel investment where it’s needed, and something is better than nothing.” Around 90% of these proposals are for putting cyclists on pavements. From a cycling perspective, it’s doing nothing that isn’t already there, or if you’ve created a new pavement, great – again that’s not where bicycles should be. Disability groups are clear that by mixing pedestrians movements with cycling alongside busy urban roads, you are excluding disabled users and putting everyone at risk. And no, greenways are not the same, as they’re wider and don’t have instant death waiting inches away if a mistake is made.

An already-constructed section of the plans being consulted on, a shared footway crosses a bus stop, and a hatched median shows how much space is available for a separate cycling facility – see more on Google Maps

  • As some of these facilities have already been constructed, this is not a consultation exercise on the design standards of proposals.” This is part of why DfI is not fit for purpose when it comes to active travel, and reform of the whole system is needed. In researching this, we found that several sections in the consultation have already been constructed in the past few months. This is unfortunately typical of the contempt which DfI’s operational divisions demonstrate towards cycling schemes and the public consultation process. While new urban pavements where none existed before are welcome for pedestrians, they still ARE NOT AND MUST NOT BE DEEMED CYCLING INFRASTRUCTURE. A footway is a footway – just because you’ve gone ahead and slathered some red paint on it (thinking forgiveness is easier to ask for than permission) you do not deserve to gain retrospective legislative cover for your mistakes. 

Update 14 December
Minister Nichola Mallon was asked during NI Assembly Questions whether the schemes covered by these two consultation would adhere to LTN 1/20. If you weren’t sure how much DfI Roads would scratch and claw to not use LTN 1/20 unless compelled to, the Minister’s answer removed any doubt:

I’m struggling to remember a more damaging statement on active travel by an Infrastructure Minister. The only way left to make an impact here is to raise your voice in objection. 

The objections

Feel free to reuse and recut this any way you want – the basic thrust is the same for both schemes.

The Department cannot proceed with the Orders without discharging objections – basically offering excuses as to why they’re not doing their jobs correctly by applying current standards, or (extremely rare) taking action to remedy the situation. It’s important that when objecting, and then being asked to remove your objection in future correspondence, that you do not withdraw until new plans are drawn up which apply guidance, best practice and highest standards from LTN 1/20, in full consultation with active travel groups, disability groups, and the Walking and Cycling Champion stakeholder group.

If you are contacted asking to withdraw your objections, without remedy, and feel uncertain on how to proceed, you can copy the correspondence to nigreenways@gmail.com for further help.

The simplest way to object is to replay the words of DfI’s own current guidance, standards and advice on cycle route development, as it lays bare the failings on these proposals. You will need to email two separate objections as follows:

Don’t forget, if you’re reusing the text below, to delete as appropriate!

I write to object in the strongest terms to proceeding with The Cycle Routes (Amendment) Order (Northern Ireland) 2021 / The Cycle Routes (Amendment No. 2) Order (Northern Ireland) 2021. While the text of my objection may be used by others, I am an objector in my own right and you may not discharge my objections en masse without allowing me proper recourse to further comment to retain or withdraw.

These plans will do nothing to enhance active travel in Northern Ireland or raise the levels of active travel. They cynically greenwash the appearance of progress while locking in desperately substandard facilities, and leave vehicle carriageways almost entirely untouched, where space is readily available for best practice separated facilities to benefit both pedestrians and cyclists.

I will outline my objections in detail, while stating clearly that you should not make this Order, nor proceed with any outstanding projects outlined within it.

Shared footways
I object to the use of shared footways in these schemes. The basis is that footways are for pedestrians. Separate cycling infrastructure is for cycling. This is the definition of a footway from LTN 1/20 which may help clarify matters for you:

“Footway: A way comprised in a highway, which also comprises a carriageway, over which the public has a right of way on foot only [Section 329(1) Highway Act 1980]. Footways are the pedestrian paths alongside a carriageway, referred to colloquially as the pavement. Driving a vehicle (including cycling) or riding a horse on a footway is an offence under the Highways Act 1835.”
Cycle Infrastructure Design LTN 1/20 2020 

I will be happy to consider withdrawing my objection if you demonstrate why the roads and streets in these schemes are so unsuited for separate cycling facilities that you need to go as far as creating legislation which adds to the overall confusion among the public about whether cycling on footways is, or should be, allowed. LTN 1/20 is crystal clear on shared footways:

“Cycles must be treated as vehicles and not as pedestrians. On urban streets, cyclists must be physically separated from pedestrians and should not share space with pedestrians. Where cycle routes cross pavements, a physically segregated track should always be provided. At crossings and junctions, cyclists should not share the space used by pedestrians but should be provided with a separate parallel route.”
Cycle Infrastructure Design LTN 1/20 2020 

I will be happy to consider withdrawing this objection if you demonstrate how these schemes do not treat cycles as pedestrians, physically separate cycles and pedestrians, and how cyclists and pedestrians do not have to share space at crossings and junctions.

Disability needs
I object to the designs used for footways and crossings. The basis is that they disproportionally impact upon, and are exclusionary to, disabled users. You surely must be aware of Imtac’s advice to DfI on shared footways:

“In most circumstances Imtac does not support the use of shared footways between cyclists and pedestrians. Shared footways can impact negatively on all users, but has a particular impact on some older people and disabled people by creating an environment where they feel unsafe. More generally this type of infrastructure is likely to create conflict between users and frustrate both cyclists and pedestrians in equal measure.”
Imtac statement on cycling 2018 

I will be happy to consider withdrawing this objection if you demonstrate how these shared footways and shared crossings do not impact negatively on the needs of disabled users.

Junction design
I object to these schemes on the basis that dropped kerbs are and paint are almost the only changes made to junctions. The existing geometry (designed to prioritise vehicle movements) has not been touched. LTN 1/20 has options for making junctions safer for vulnerable users:

“Junctions should be designed to remove or manage conflicts between cyclists, motor traffic and pedestrians by one or more of the following:

  • separating cyclists from motor traffic and pedestrians in space and/or time;
  • banning one or more motor traffic movements;
  • providing priority for cyclists over motor traffic; and/or
  • reducing the speed and volume of motor traffic movements so that cyclists can safely be integrated with them

“The occasions when cyclists need to stop or to give way should be minimised. In all cases, speed reduction through and on the approaches to junctions, and on turning, are recommended as measures that will benefit both cyclists and pedestrians. Features [which] may be considered to help achieve this [include] tight corner radii and raised entry treatments or wider junction tables that slow vehicles at the conflict points.”
Cycle Infrastructure Design LTN 1/20 2020

I will be happy to consider withdrawing this objection if you demonstrate how these schemes have redesigned junctions to reduce vehicle speed, to remove or manage conflicts to the primary benefit of pedestrians and cyclists, or any examples of where cyclists do not need to stop or give way to vehicles.

Route quality
I object to the routes on the basis that they do not represent the highest quality facilities available to deploy. No good reasons have been given for selecting interventions to the low end of quality. You should refer to the Bicycle Strategy:

“We appreciate that many people feel that provision is frequently fragmented and of varying quality. Creating a network of high quality, direct, joined up routes is a key element of delivering the vision.”
Bicycle Strategy for Northern Ireland 2015 

I will be happy to consider withdrawing my objection if you demonstrate how these schemes create high quality, direct and joined-up routes which have a consistent high quality and are not fragmented, eg at poorly designed and prioritised junctions, crossings and roundabouts, to deliver the Minister’s vision for cycling and active travel.

“While there are examples of good quality provision which have led to the transformation of some areas there are also many cases where infrastructure provision is disconnected and this is of limited benefit. In developing cycling infrastructure, we will adopt the ‘three-pillar approach’. This includes careful planning, high quality infrastructure and effective behaviour change campaigns. The intention is that these three pillars will all be taken forward across the 25 years of the Strategy.”
Bicycle Strategy for Northern Ireland 2015 

I will be happy to consider withdrawing this objection if you demonstrate how these schemes provide high quality infrastructure, as understood at:

  • the publication of the Bicycle Strategy for Northern Ireland
  • when any were were constructed
  • at the time the associated legislation was published for public consultation 

Road User Hierarchy
I object to these schemes as there is no evidence of using the road user hierarchy in determining designs and priority at key points of conflict. As you’ll know, use of the road user hierarchy was integral to the Bicycle Strategy:

“The objective of [the road user] hierarchy is to ensure the needs of the most vulnerable road users are fully considered and adequately provided for in all highway schemes.”
Bicycle Strategy for Northern Ireland 2015 

I will be happy to consider withdrawing this objection if you demonstrate how you have applied the hierarchy of road users in these schemes, to the correctly weighted benefit for each user group, with particular attention to the safety, comfort and priority for the most vulnerable users.

Chicane gates (Belfast only)
I object to the use of chicane gates at Abbey Park. Chicane gates are exclusionary to many, and DfI especially needs to set an example to councils who are deploying them against standards. In case you haven’t read LTN 1/20:

“Access control measures, such as chicane barriers and dismount signs, should not be used. They reduce the usability of a route for everyone, and may exclude people riding nonstandard cycles and cargo bikes. They reduce the capacity of a route as well as the directness and comfort. Schemes should not be designed in such a way that access controls, obstructions and barriers are even necessary; pedestrians and cyclists should be kept separate with clear, delineated routes as outlined in the principles above.”
Cycle Infrastructure Design LTN 1/20 2020

I will be happy to consider withdrawing this objection if you scrap the plans for chicane gates and engage with active travel and disability stakeholders for better options in their place.

Roundabout cycle design and crossings (Ballymena only)
I object to the lack of high quality cycle route design at roundabouts, and the awful crossings being proposed where traffic control measures are not being deployed to allow safe movements for the most vulnerable users. LTN 1/20 should be consulted when looking at options:

“Abrupt reductions in the quality of provision for cyclists – such as a busy high-speed roundabout without facilities – will mean that an otherwise serviceable route becomes unusable by most potential users. At existing normal roundabouts the options for improving conditions for cycling are:

  • Remodel the junction as a Compact Roundabout, with or without protected space depending on motor traffic volumes and speeds;
  • Provide protected space for cycling around the junction, with suitable crossings of each arm;
  • Provide grade separated cycle tracks around and/or across the junction;
  • Introduce signal control to the roundabout, with protected space or other suitable facilities for cycling; or
  • Replace the roundabout with a signal controlled or other form of junction, with appropriate cycle facilities.”

Cycle Infrastructure Design LTN 1/20 2020

I will be happy to consider withdrawing this objection if you outline plans to redesign the roundabouts with priority for active travel.

Repeating old mistakes
I object to these schemes on the basis that they will not contribute to Programme for Government outcomes. They clearly repeat the failed interventions of the last two decades, which have produced no demonstrable increase in cycling levels. You should consider the words of the recent Belfast Cycling Network Plan:

“There are 22 good design principles that should guide the design of the infrastructure set out in this Network which are found in LTN 1/20. These principles are fundamental to achieving the Bicycle Strategy Vision and in encouraging more cycling journeys. They have been developed having taken into account the main shortcomings of the existing infrastructure – shortcomings which have worked against the achievement of a significant increase in cycling.”
Belfast Cycling Network 2021 

I will be happy to consider withdrawing this objection if you demonstrate how these schemes are different from existing infrastructure which has worked against the achievement of Bicycle Strategy and Programme for Government outcomes. If it helps, you can see here how many shared footway cycling schemes have been deployed by DfI in the last five years – http://bikefast.org/2021/04/30/shared-past-shared-present-shared-future/

Proceeding with out of date designs – just because – is a terrible idea
I object to proceeding with these route designs and the Order on the basis that they are out of date, and will lock in terribly substandard design for decades, for little more reason than saving face for the Department’s historic spending on consultant fees. Not choosing to redesign these schemes in line with LTN 1/20 runs contrary to commentary seen the recent Belfast Bicycle Network Plan: 

“There are five core design principles for the design of this network which were adopted for the development of the Belfast Metropolitan Transport Plan (BMTP) and which are restated in LTN1/20. In addition to these this Cycling Network also recommends that infrastructure should have adaptability to provide an element of future proofing. The objective of these design principles is to take cycling infrastructure beyond the general level of existing provision and raise it to the level of what is commonly provided in established cycling societies such as those in northern Europe.”
Belfast Cycling Network 2021 

I will be happy to consider withdrawing my objection if you can demonstrate why it is preferable to justify historic spending on poor scheme design by proceeding to construction (lumping communities with decades of substandard facilities) rather than accept the world has moved on and apply the latest guidance on a redesign to ensure the level of provision is raised and future proofed. I would also appreciate if you could signpost me (for any schemes under the Order which have already been constructed) to where plans were made available for public consultation and input on options ahead of time.

Since 2015 the Minister’s position has been very clear on developments reflecting best available standards:

“The Minister has set out his determination that the development of Northern Ireland’s cycling infrastructure should reflect best practice design guidance. The guidance that is adopted will promote a ‘common standard’ to work to, and will give those who use the bicycle confidence that their safety is taken seriously and steps are being taken to make the network as safe as possible.”
Bicycle Strategy for Northern Ireland 2015 

I will be happy to consider withdrawing this objection if you demonstrate how these schemes reflect best practice at the time they were constructed and at the time the associated Order was published for public consultation.

Greenwashing and cyclewashing
I object to these schemes on the basis that they are the most basic cosmetic changes to existing street and road layouts, which offer negligible benefits for active travel – and for many users make the situation worse. LTN 1/20 is very clear on this point:

“Largely cosmetic interventions which bring few or no benefits for cycling or walking will not be funded from any cycling or walking budget. Too many schemes badged as being for cycling or walking do little more than prettify the status quo, such as installing nicer-looking pavements and road surfaces but doing little or nothing to restrict through traffic or provide safe space for cycling. Schemes whose main purpose and/or effect is aesthetic improvement of the public realm must be funded from other budgets.”
Cycle Infrastructure Design LTN 1/20 2020 

I will be happy to consider withdrawing this objection if you demonstrate how these schemes restrict through traffic, provide safe space for cycling, are anything but pavements being rebadged for cycling, or go beyond prettifying the status quo, and (if pavement improvements are the primary outcome) why this is being funded and delivered by DfI instead of the Department for Communities.

Deliberate misinterpretation of LTN 1/20
I object to these schemes on the basis that there appears to be a deliberate misinterpretation of LTN 1/20 at play. On 14 December 2021 Infrastructure Nichola Mallon answered a question in the Northern Ireland Assembly which revealed the Department’s hostility to the standards which LTN 1/20 places on scheme designers:

“LTN 1/20 emphasises that separated cycling space should be prioritised, and that is the kind of quality infrastructure that I want to see introduced. It also indicates:
‘A well-constructed shared use facility designed to meet the needs of cycle traffic — including its width, alignment and treatment at side roads and other junctions — may be adequate where pedestrian numbers are very low.’ ”
NI Assembly Official Report: Tuesday 14 December 2021

You will no doubt be aware that the Minister quoted a minor note in LTN 1/20 (for the main guidance see Summary Principle 2: “On urban streets, cyclists must be physically separated from pedestrians and should not share space with pedestrians.”) which requires to be set in context missing (in bold below) from this selective quote:

Where a route is also used by pedestrians, separate facilities should be provided for pedestrian and cycle movements. However, away from the highway, and alongside busy interurban roads with few pedestrians or building frontages, shared use might be adequate (see Chapters 6 and 8). Such facilities should be designed to meet the needs of cycle traffic, however – including its width, alignment and treatment at side roads and other junctions. Conversion of existing footways to shared use should only be considered when options that reuse carriageway or other (e.g. verge) space have been rejected as unworkable.”
Cycle Infrastructure Design LTN 1/20 2020 

I will be happy to consider withdrawing this objection if you demonstrate how these schemes are either away from the highway, alongside busy interurban roads (rather than surrounding and connecting residential areas), and provide me with the written basis on which options for reusing carriageway in all of the schemes were rejected as unworkable.

The Minister also suggested that shared footways were an interim step to fully realised separate cycling facilities:

“The challenge that we face in Northern Ireland is that we are moving from a situation in which there is little infrastructure to one in which we will have the best-quality infrastructure. It is not always possible to do that in one step.”
NI Assembly Official Report: Tuesday 14 December 2021

I will be happy to consider withdrawing this objection if you can demonstrate within these schemes (now classed by the Minister as an interim project) any documentation of the timescale and general layout expected for the future step to higher quality schemes.

When Minister Nichola Mallon launched the latest headline cycling document published by DfI – the Belfast Bicycle Network in June 2021 – she called it “a blueprint for the development and delivery of coherent, connected and safe infrastructure for everyday cycling in the city over the next ten years”. The continued use of shared footways makes these routes incoherent, unconnected and unsafe for all vulnerable road users for decades to come.

You must halt any ongoing development of these schemes, redesign everything in line with current best practice design standards, in partnership with appropriate outside stakeholders, before proceeding any further. For any aspects of these schemes which have already been constructed, it demonstrates contempt for the process of public consultation. The Order must not be made, and DfI must accept these will remain pedestrian-only routes, until the integration of cycling can be achieved in line with current design guidance – on its own terms and not to the detriment of pedestrians.

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