Government Claims on Cycling

Open letter to the Minister of Transport on the matter of his office's claims with regard to "cycle facilities" 01/03/04.

Summary Here 

FAO: Mr Seamus Brennan TD, Minister for Transport

CC: Mr. Martin Cullen TD, Minister for the Environment, Auditor and Comptroller General's Office.  Mr Charlie McCreevy TD, Minister for Finance, Mr Mr. Micheál Martin TD, Minister for Health and Children, Opposition spokespersons on Transport/Environment, Relevant Dail Select Committees

Dear Sir

On behalf of the committee, I am to respond to claims on the matter of cycle tracks made in an undated letter received from your office during November 2003.  Your office issued this letter as a result of the recent rejection of roadside cycle-tracks by the Galway City Community Forum, which represents 90 community and voluntary organisations.

The safety of segregated cycle facilities

Your office has neglected to address the issue of the safety of segregated "cycle facilities".  This is curious as this was the primary reason for the Galway City Community Forum making a decision to reject the use of such devices.  Your office does not deny, that for over 28 years Irish government officials have had knowledge of Irish research indicating that the use of roadside cycle tracks could have serious negative safety implications [1].  Your office does not deny, that since 1998 at the latest, these same officials have had knowledge of studies in the international literature confirming the existence of serious safety problems with segregated "cycle facilities", including findings of significant increases in the rate and severity of collisions between cars and bicycles.  It is not credible that this state's senior engineers and transport planners do not have access to the standard journals such as Traffic Engineering and Control[2][3] or the Journal of the Institute of Transport Engineers[4].  It is most unlikely that these officials had not become independently aware of these issues even without their having been raised repeatedly by Irish cycling activists.  Despite this, Irish cyclists are finding themselves impeded and obstructed in going about their daily business, and are having their lives, safety and property endangered, by cycle track/cycle lane devices that flout self-evident safety principles and fundamental principles of Irish traffic law.  With respect, we must put the view that the activities of those officials involved in constructing these cycle-track devices and creating this situation are a national disgrace and constitutes a national scandal.  With respect, we find your office's failure to acknowledge these issues inexplicable.

Cycle facilities as a means of attracting new cyclists

Writing on your behalf, your officials have claimed that the reason for constructing high quality segregated cycle tracks is that such devices attract new cyclists.  Further it is claimed that the construction of cycle-tracks is the most effective way to get non-cyclists on the bicycle.  With respect, based on the evidence available to us, this claim is false and untenable.  There are numerous examples of cities that have enjoyed robust levels of cycling without recourse to segregated cycling networks.  Examples include Galway, Limerick, Dublin, Cork, Oxford, Cambridge, Nottingham, York, Groeningen, Odense, Delft, Amsterdam, Ferrara and sundry other Northern European cities See Note .  It is acknowledged that many of these cities now have cycle-networks.  However, our information is that in many cases the cyclists were there first and in some cases the explicit purpose of the cycle track networks was to benefit motorists not cyclists.  We must put it to you that in many cases the primary measure to further increase the convenience and safety of cycling in many these cities would be the removal or modification of much of this "cycling infrastructure".  For example in Helsinki it is now proven categorically that cyclists are safer cycling on the roads mixed in with the traffic than they are using that city's 800 km of cycle paths[5].  It is reported that the Berlin police came to a similar conclusion in the 1980's[6][7].  

It is reported that the German bicycle boom of the 1970's and 1980's actually occurred in response to fuel prices and traffic congestion.  This was prior to, and independently of, any cycle-promotion policies, with German cities "struggling to catch up" with the growth in cycling and implementing such cycle-promotion policies after the fact [8].  A similar effect may also have occurred in Sweden.  (Irish cycling levels also showed robust 27% growth in the 1980's without any government intervention) In 1995, the UK Dept of Transport released the results of a ten-year study into the effects of cycle routes in the following UK towns and cities: Canterbury, Exeter, Kempston (Bedford), Nottingham Stockton, Cambridge and Southampton [9].  The findings were very clearly stated.  The construction of such cycle routes "did not of itself encourage those who own cycles - but do not currently use them - to start cycling".  Similar findings were previously reported for Denmark in 1989[10].  The Dutch experience is exemplary.  In 1995, the then head of the "Dutch bicycle masterplan" presented the following conclusion to an international conference [11].  

* Since 1990, the total length of cycle paths has increased to almost 19,000 km, generally speaking double the length in 1980.  (The Netherlands has around 108,000 km paved and asphalted roads, including 2200 km of expressways).  Besides cycle paths, there were also investments in roundabouts, reconstructions of junctions and pedestrian/cyclist crossings, cycle tunnels and bridges and parking facilities for cyclists; totalling an estimated 1.5 billion guilders.  The costs were split up into approximately fifty percent for the municipalities, 15% for the provinces and the remainder for the national government.

*Results: In 1994, the total distance cycled was 12.9 billion km, compared with 12.8 billion in 1990.  (The number of km travel-led by car was 125 billion in 1990 and 129 billion in 1994).  Consequently: Expansion and improvement of the infrastructure does not necessarily increase the use of bicycles .

This then raises a simple question.  In the late 80's and early 90's the Dutch could spend 1.5 billion guilders (the equivalent of IR£ 600 million at 1995 exchange rates).  This achieved a total of 19,000 km of cycle paths, which resulted in no demonstrable benefit in terms of increasing cycling.  How then could anybody come to the conclusion that a caricature of Dutch practice, imposed on a fundamentally different Irish infrastructural and legal foundation, would encourage a switch to cycling? Especially when it had demonstrably not done so in the Netherlands? Two alternative conclusions are invited 1) the Irish state's senior transport advisors and planners chose not to conduct the most rudimentary cost-benefit analysis of their proposals or 2) those officials seeking to divert state funds into this "cycle-infrastructure" never actually intended it to benefit cyclists or to encourage cycling.

Clearly, the high levels of cycling achieved in other European cities is attributable to factors other than the quantity of "cycle network" available.  Equally clearly, the collapse in cycling levels in Ireland is primarily attributable to factors other than any lack of "cycle facilities".

The Traffic and Parking Regulations SI 274/98 SI 273/98

Your office has made reference to the Road Traffic (Traffic and Parking) Regulations relating to cycle tracks.  These were imposed by Mr. Bobby Molloy TD, Minister of State at the Department of the Environment and Local Government, on 31st of July 1998.  With respect, we would remind you that from the day they were published these regulations have been viewed as an attack on the lives and safety of Irish cyclists and as an attack on Ireland's native cycling culture.  We would prefer not to have to point this out but there are clearly unsavoury parallels between this Irish legislation and the similar legislation imposed by the German Nationalist Socialist Regime in the 1930's.  In July 1998, Mr. Molloy's department already had prior knowledge of, and had already been made aware of, serious safety problems surrounding the use of cycle-tracks.  Three weeks later, in a submission dated 27/8/1998 and prior to these regulations coming into effect, we put the following view to Mr. Molloy

It is our view however, that the Traffic and Parking Regulations (SI 182/97, SI 274/98) do not permit the use of such cycle lanes or cycle tracks.  There is an explicit element of compulsion in Article 14.3 of the regulations as they now stand.  The clear intent is to coerce pedal cyclists into driving without due regard to the traffic situation, their own safety or that of their property.  In our view there is a serious query as to whether or not Article 14 is itself compatible with the governing legislation.  This is a separate legal matter that requires clarification.  It is also of note that the implied purpose of the legislation is to remove priority from those drivers who chose to use pedal cycles.  At present the net effect is to render cycle tracks doubly unsafe and as such to preclude their construction and use within this jurisdiction.

The issue was still being raised two years later on 5/5/2000 in a letter to Mr. Noel Dempsy TD, Minister for the Environment, regarding the DTO's discredited, and demonstrably dangerous, "Cycle Facilities Manual"

We find your letter confirms our previous views regarding the lack of "relevance" or "application" of the DTO's Cycle Facilities Design Manual.  It remains our view that the accompanying "cycle track" regulations (SI 274/98, 273/98) are demonstrably incompatible with both the normal traffic regulations and the governing legislation.  We also remain unclear as to what provisions of the constitution or the governing legislation would actually give you any authority to make regulations seeking to coerce private citizens into behaviours that are known to be associated with increased risk of death and injury.  

To date we have still not received a reply on the substance of this matter.  Perhaps you, as Minister for Transport, are in a better position to furnish such a reply.  If so we would be grateful for a resolution of this matter.

Cycling facilities manual: Provision of Cycle Facilities - National Manual for Urban Areas

Your office also makes reference to the Dublin Transportation Office's discredited and demonstrably dangerous, "cycle facilities" guidelines: Provision of Cycle Facilities - National Manual for Urban Areas. Your office has made the claim that this document "is intended to be of assistance to local authorities in ensuring that such facilities are implemented to a uniform and high standard". With respect, it is our view that this claim is untenable, does not stand up to scrutiny, and is not supported by the available evidence.

Your officials have no doubt already made you aware of the history of this matter from the files.  Nevertheless we would remind you of the relevant details.  The Galway Cycling Campaign reviewed a draft of this design manual in 1998.  The conclusion reached was that the draft document was unlikely to be of relevance to, or applicable within, the Irish situation.  This was on the obvious grounds that it was based on previous Dutch practice and therefore based on series of underlying legal and infrastructural assumptions that do not apply on this country.  This was all brought to the government's attention in 1999.  Despite these obvious flaws, these "cycle facilities guidelines" apparently remained in circulation.  Had it been immediately withdrawn at that time, then the defence could have been offered that it had been mistakenly adopted in good faith (alternative guidance based on legal and infrastructural assumptions relevant to Ireland was already readily available).  That the DTO document remained in circulation after 1999 removes this defence from those involved.  

Subsequently, a further review was conducted of the final document as circulated by the DTO/DoELG.  As you are already aware, this review was published by the Galway Cycling Campaign in February 2002 and is available in all copyright/university libraries, local authorities and is also available to your office[12].  This review revealed that the DoELG and DTO "design manual" had endorsed the use of cycle track designs associated in the international literature with up to 12 fold (x12) increases in the rate of collisions between cars and bicycles.  Comparison the draft document with the final, "Irish", version showed that some of the Dutch cycle track designs were changed by removing those road markings that were intended to reduce the safety risks to those cyclists who choose to use them.  In addition, key designs were changed so as to remove priority from the cyclists using the cycle tracks and give it to motorised traffic.  Cycle track users who could have proceeded normally if they had stayed on the road were expected to stop and yield to turning and crossing motor traffic at every side road.

These facts seem to confirm what many Irish cycling activists have long suspected, that the "design manual", most Irish "cycle facilities", and the accompanying legislation, were neither intended to enhance safety nor to promote and encourage cycling.  Instead, the evidence provided by the "cycle facilities manual" suggests that these devices actually represent a crude attempt to manage and control bicycle traffic for the benefit of motorists.  Despite the serious safety issues that were raised, this "cycle facilities manual" has apparently remained in circulation, is still being used by some local authorities, and is still being supported with state funds (the Limerick City Strategic Cycle Network proposals being the most recent example).   With respect, we must put it to you directly that this latter fact must raise serious questions as to the motives and intentions of the officials involved within your department, the DoELG, the DTO and the NRA.  With respect, we must put it to you that a neutral outside observer, being appraised of these facts, would feel compelled to draw most unsavoury conclusions regarding the intentions of the officials involved.

As you are already aware, it is a matter of historical fact, that much of the German cycle-track network was constructed by the Nazi-regime in the 1930's and 40's for the express purpose of facilitating motorists and encouraging a switch to mass motoring [13].  It is a matter of historical fact, that post-war German governments maintained these policies for the same reasons [14].  It is a matter of fact that, as in Ireland since 1997, German guidance deliberately removed priority from cyclists in favour of motorists.  Despite these attacks, German cycling levels held their own until the 1950's when they went into sudden decline.  With respect, we must put it to you that the available evidence invites the conclusion that similar motivations lie behind official efforts to procure the construction of "cycle-track" devices in Irish towns and cities.  In 2002, a consultant engineer for Galway City Council, felt entitled to tell a Bord Pleanala oral hearing that cyclists would be expected dismount and become "pedestrians" at every single junction on a proposed "cycle route" along the Seamus Quirke Rd.  You will appreciate that from the Galwegian perspective, the parallels with the activities of the Nazi regime in the 1930's are readily apparent and indisputable.  With respect, we must put it to you that the available evidence strongly indicates that, as in 1930's Germany, the distribution of the DTO's "cycle facilities manual" and the current imposition of cycle tracks in Irish towns and cities is primarily intended to benefit motorists and is primarily intended to reinforce and strengthen the switch to mass use of private motor cars.

The claimed desire to encourage cycling

Your office's letter appears to suggest that it is government policy to promote cycling. Again with the utmost respect, we must put it to you that such a claim is untenable and is not supported by the available evidence. In other countries it is an accepted principle of traffic management that road network design should take account of the likely mix of traffic.  Under successive roads acts, Irish roads authorities were explicitly required to consider the needs of all road users in carrying out their functions.  Despite this, it is apparently standing Irish road design practice to focus on attempting to create a state of "free flow" for private car users to the practical exclusion of all other considerations.  The decision by the Irish authorities to promote the use in urban areas of interurban-type road geometries, "warrant" based pedestrian crossing policies and such features as:

• One-way streets
• High capacity roundabouts
• Large kerb radii
• Excessive visibility envelopes
• Banned right turns
• Free left turns
• Filter lanes/Left turn only lanes
• Slip roads
• Car centred traffic control systems
• Cul de sac - based residential layouts

Represents a decision to exclude cyclists, pedestrians and public transport users from the safe convenient access to the state's primary transportation infrastructure.  (Most public transport users are by definition also pedestrians).  Concerns over of the use of roundabouts and one-way streets were raised in Irish reports as far back as 1979 and have been ignored[15].  A 1987 report[16] raised "serious reservations" about the use of roundabouts where two-wheelers might be present (and was ignored).  Established road design guidance has long forbidden the use of slip roads or merge tapers on low speed roads of an urban character[17][18].  In Ireland, even the provision of pedestrian crossings was based on a "warrant system" whose stated goal was to reduce the "delay" caused to motorists by people who choose to cross the road while going about their lawful daily business on foot[19].  An independent observer being appraised of these facts has several conclusions.  1) for the last twenty years the state's senior engineers and planners chose by turns not to inform themselves of

• the content of official reports going back to the 1970's *
• the contents of their own road design guidance *
• international best practice in sustainable road design and sustainable planning.  

The alternative conclusion is that the officials responsible within your own and other departments view the lives and safety of Irish motorcyclists, cyclists and pedestrians with contempt.  Whatever the reasons, in 1997, 1998 and reportedly 2001, the Irish republic had the highest child pedestrian death rates in Western Europe[20][21].  However, it must be acknowledged that the latter situation is also driven by 1) the failure to adopt the standard, northern European speed limit regime and also 2) by an apparent national practice of non-enforcement of the speed limits in urban areas.  

With respect, we must put it to you that it is ludicrous to construct the type of roads networks favoured by Irish officials and then suggest it would be possible to superimpose, a functioning, "segregated cycle network" on top of it.  It would be insulting peoples intelligence in the extreme to make such a suggestion.  Therefore the strong implication is that these "cycle network" schemes are being imposed in Irish towns and cities for some reason other than the promotion of cycling.

It is an undeniable fact that your government and its immediate predecessor have continued to tolerate and fund the use of demonstrably cyclist-hostile road designs in violation of your own reports.  To our knowledge, at no time has your government, or its predecessor, withheld roads funding from any local authority, such as Galway City Council, on the grounds that they have sought to retain the use of such demonstrably unsustainable features as roundabouts, slip roads and one-way streets.  In fact, your government and its immediate predecessor has actually funded, and to our knowledge has continued to fund, the further use of such devices in Irish towns.  

Furthermore, for some inexplicable reason, Irish towns and cities are characterised by an apparent practice of non-enforcement of the speed regulations.  In addition, your government has failed to adopt the standard Northern European hierarchy of speed limits with 30kph (20mph) as the standard urban speed limit.  Since the 1980's, the widespread use of linked, 30kph, "tempo 30" zones has been viewed elsewhere as a key measure in promoting walking and cycling, particularly among schoolchildren.  Various authorities are pushing a compulsory seatbelt law despite a lack of demonstrable benefits and widespread international evidence of increased deaths and injuries among those outside cars such as pedestrians, cyclists and moped users[22].   With respect, we must put it to you that any informed observer being appraised of these facts would conclude that the government's claim of a desire to encourage greater use of bicycles is untenable and is not supported by the known facts.  With respect, we must also put it to you forcefully, that the activities of your officials and their colleagues in the DoELG are logically consistent with a desire to discourage, in so far as is possible, cycling as a form of transport in Irish towns and cities.  Confirmation of this is provided by recently released census data.  Since 1996, the last two governments have achieved a 28% fall in cycle commuting, a 39% drop in cycle use among third level students, a 61% drop in cycle use among secondary school children and a 59% drop in cycle use among primary school children.  As a result of your government's hostile, anti-cyclist activities, more girls now drive themselves to secondary school in cars, than use bicycles.

The DTO's Traffic Management Guidelines

Your office has made reference to the DTO's recent and deeply flawed Traffic Management Guideline wherein it is claimed that "recognition is given to the status of all vulnerable road users including cyclists".  We have reviewed this document and can find no apparent reference to the legal status of Irish cyclists as drivers or of bicycle as vehicles.  Nor is there any apparent statement of the requirement to vindicate and defend cyclists' use of the roads in accordance with this legal status.  In fact the opposite is the case as frequent reference is made to the DTO's discredited and demonstrably dangerous "cycle facilities" guidelines wherein the status of Irish cyclists was demonstrably undermined in favour of an alien, and offensive, Dutch model based on inapplicable legal assumptions

If these Traffic Management Guidelines were a draft document intended to act as a basis for discussion then it might be viewed as potentially representing an advance on its predecessors.  As is stands it is deeply flawed, particularly with regard to the safety and promotion of cycling, and should be withdrawn from circulation. There is much of merit in the document.  However it's discussion of traffic management is also full of curious fudges and glaring omissions.  Curiously, this "traffic management" document appears to contain no discussion at all of the issue of one-way streets or of the need to eliminate one-way street systems from Irish towns and cities.  There is no apparent mention of widely endorsed, standard, treatments for promoting cycling such as wide kerb lanes.  It is our view that such omissions are inexplicable in a document that dates from 2003.

In our view, the chapter on priority junctions neglects key aspects of design with regard to cyclists' safety particularly with regards to discouraging excessive entry and turning speeds by entering motorists.  Having given advice which can lead to excessive entry speeds the authors then compound the offence by referring the reader to the DTO's discredited, and demonstrably dangerous, cycle facilities manual for remedial treatments.  The key issue of central islands is also fudged with no reference to the issue of critical widths and the need to ensure that lane widths below 5-5.5m are not used at such locations (Indeed, the advice given regarding cyclists suggests that the authors do not understand the issue).  Serious questions also arise as to the level of expertise of the authors.  For instance, it is claimed with regard to cyclists at traffic signals that "the absence of cycle tracks make them particularly vulnerable".  In fact the reverse is the case and cycle tracks have been identified as causing serious safety problems at signalised intersections.  The advice on lane widths at traffic signals raises concerns and seems to provide explicit justification for those traffic engineers who wish to remove road capacity from cyclists so as to store queues of waiting cars.  This section also apparently neglects any mention of the need to eliminate or restrict the use of left-turn only lanes at such locations - a key issue for cyclist convenience and safety.  As with wide kerb lanes or one-way streets the failure to address this issue is in our view inexplicable.  

The biggest problem with the Traffic Management Guidelines is an apparent infatuation with "cycle facilities".  The comments on cycle facilities are seen to be unsubstantiated propaganda with claims that we have already refuted elsewhere in this letter.  Nowhere is there any apparent reference to the established fact that many "cycle facilities" are demonstrably more dangerous than unsegregated roads.  Indeed, the opposite is the case and an unsubstantiated claim is offered for cycle tracks as an "accident reduction" measure.  In a document that dates from 2003 this is inexplicable and in our view this indicates a serious lack of professionalism on the part of those involved.  Numerous issues are fudged by referring the reader to the DTO's discredited and demonstrably dangerous cycle facilities manual.  As an example, the DTO Traffic Management Guidelines refer the reader to the DTO's "cycle facility" guidelines for guidance on cycle facilities at roundabouts.  However the DTO's cycle facilities manual recommends a roundabout "cycle-lane" treatment that resulted in a doubling of the casualty rate when tried elsewhere. With respect, we must put it to you directly that, as with the "cycle facilities" guidelines, serious questions must arise as to the motives and intentions of the officials within your department, the DoELG, the DTO and the NRA who were involved in circulating these Traffic Management Guidelines.  The result has been to fatally undermine what might have eventually become a very worthy and useful document.  With respect, we must put it to you that the public interest would be best served by your repudiating the current DTO Traffic Management Guidelines and ordering its withdrawal from circulation.

The inducement of children and old people to cycle.

Perhaps the most offensive aspect of the letter from your office is the suggestion that cycle-tracks are being built as a means of encouraging cycling by Irish children and old people.  As an example, take Galway City where there are approximately 10,000 school-age children and 5000 old age pensioners.  In 1979, a study of bicycle travel in Galway city found the following proportions of bicycle travel.

• Morning traffic: For every 100km travelled by car 11 km were travelled by bicycle *
• Afternoon traffic: For every 100km travelled by car 19 km were travelled by bicycle

In 1979 the following secondary schools, including your own alma mater, had in excess of 20% of pupils using bicycle as their primary means of transport.

Since 1979 the DoELG and Galway City Council have used state funds to procure the construction of at least 15 roundabouts of a design on which cyclist are reported to have an injury accident rate at least 14-16 times that of motorists.   These roundabouts were constructed despite the fact that the available design guidance questioned their use in precisely these circumstances.  Worse still, the use of such roundabouts was continued and was expanded despite the fact that "serious reservations" were expressed about such use in a 1987 report.  A situation has now been created whereby it is impossible for many urban/suburban communities, who include 12,000 third level students, to access Galway city without negotiating one or more of these roundabouts.  In particular, elderly cyclists from the rural periphery have been put in an impossible situation.  

Within the city, slip roads/acceleration lanes and merge tapers are used at inappropriate locations in direct conflict with standard road design guidance and despite the fact that they are reported in the international literature as creating extremely dangerous conditions for cyclists.  Roads with a "design speed" of 60 mph are being imposed at locations with (theoretically) mixed traffic of all modes and a stated speed limit of 30mph.  There is an absence of fixed speed cameras on Galway's streets despite the fact that the city suffers from that same flouting of the speed regulations that blights other Irish towns and cities.  

In 1998-99 the DoELG and Galway Corporation chose to impose a "pedestrianisation" scheme that they knew conflicted directly with internationally established design guidance.  In the process the DoELG and Galway Corporation deliberately shut down the major Shop St. route used by generations of child-cyclists from the east side of the city to access the schools concentrated in the west side of the city.  This includes of course your own alma mater.  (These children are now apparently expected to use a multilane one-way system via the docks.) In defiance of international best practice, Galway City Council has been granted state funds for the Eyre square enhancement scheme. This involves deliberately closing even more roads to cycle traffic and is to revise the city centre traffic system so as to remove priority from pedestrians and facilitate the increased use of private motor cars.  The city's one way system continues to be expanded and the one-way restrictions continue to be imposed on cyclists.  This is despite the fact that such use and imposition of one-way streets flies in the face of best international practice.  It is now 24 years since a Foras Forbartha report recommended the provision two-way access for cyclists on Galway's one-way streets.

The situation for cyclists in Galway is so bad that one major cycling tour operator now refuses to bring their customers through the city by bicycle on grounds of road danger.  Their customers are met outside town and taken through this small, medieval, University-city by bus because it is considered too dangerous to cycle through.

If we understand your official's letter correctly, your department's officials intend to construct isolated cycle tracks on selected routes.  This is being done with the apparent aim of enticing small children and old people into a traffic situation that is considered too dangerous for fit, adult, cycling-enthusiasts who cycle up to 80km per day.  With respect, we must put it you forcefully that there must be serious reservations as to the moral character of any central, or local, government official who would deliberately create such a traffic situation and then deliberately seek to lure either child or elderly cyclists back out into it.  This offence is made worse when one considers the demonstrably spurious and demonstrably unsupportable predictions of "safety" that Irish officials have used, and continue to use, in support of such cycle schemes.  (The Limerick "Strategic Cycle Network" Proposals are the most recent example of this).

Finally, the idea that such cycle track devices represent some kind of suitable "nursery area" for child cyclists was refuted in the English language literature at least 24 years ago.  To quote directly from the Beaver Book of Bikes, 1980 (specifically aimed at children getting their first Bicycles)[23].  

Starting Out

"The cyclists' lanes, built on some main roads over the past half century aren't really good places to learn [...] they are rarely in such good order as the main road itself.  Not only that, but at roundabouts and junctions they simply dump the cyclist onto a busy road swarming with trucks and cars - and as a novice rider you don't want this."

Collisions with HGVs

Your officials have requested details of incidents where cyclists using cycle tracks were killed in collisions with HGV's.  With respect this misses the point.  It is overwhelmingly established in the international literature that cycling on urban roadside cycle tracks is frequently more dangerous than cycling on unsegregated roads.  Your officials and their colleagues already had independent access to this information and had already been made aware of this fact when they sought to impose, or retain, such devices in Irish towns.  The officials involved have also apparently chosen to keep the public ignorant of the risks involved and have in fact made, or tolerated, demonstrably unsupportable and demonstrably spurious predictions regarding the effects and safety of cycle tracks.  Clearly therefore it is your officials who must prove that they have not through their actions, procured unnecessary, and avoidable, deaths and injuries to Irish cyclists.  

There is also a wider issue, cycling on cycle-tracks is more dangerous because in many instances it involves cyclist manoeuvres that conflict directly with established safe cycling practice and also conflict with established principles of Irish traffic law.  These manoeuvres are dangerous whether or not the cyclist engaging in them happens to be using a cycle-track/cycle-lane at the time.  Clearly the officials promoting these alien and dangerous cycle-track/cycle-lane devices have sought to create in the public mind the idea that various, normally illegal, manoeuvres are now permissible and safe for cyclists.  Key among these manoeuvres is the passing of left-turning HGVs by cyclists on the inside.  Collisions taking in place in such circumstances are established to carry extremely high risk of fatality.  In one study it was found that HGVs were involved in 14 of 15 cyclist fatalities due to collisions with left turning vehicles[24].  Relative to their proportion in traffic, collisions between goods vehicles and cyclists are 25 times more likely to have a fatal outcome than car/cycle collisions[25].  Clearly it is arguable that the officials involved in encouraging cyclists to pass left-turning HGVs on the inside are culpable in any such deaths regardless of whether or not they happened to involve a cycle track at the time.  

Conclusion

We trust this clarifies our position with regard to your office's claims.  Notwithstanding the activities of your officials and their colleagues in other departments, we must assume that at a political level, the claimed governmental desire to encourage cycling has been made in good faith.  Therefore we would restate our view that that a direct meeting between you and a delegation from the Galway Cycling Campaign represents the best available means to progress this matter.  As previously stated, we also extend this invitation to the Minister for the Environment.

Yours Sincerely

References

[1] The bicycle, a study of efficiency usage and safety., D.F. Moore, An Foras Forbatha, 1975.

[2] The Safety Effect of Sight Obstacles and Road Markings at Bicycle Crossings, M Rasanen and H. Summala, Traffic Engineering and Control, pp. 98-101, February, 1998.

[3] Two decades of the Redway cycle paths of Milton Keynes, J. Franklin, Traffic Engineering and Control, pp. 393-396, July/August 1999.

[4] Risk factors for bicycle-motor vehicle collisions at intersections, A. Wachtel and D. Lewiston, Journal of the Institute of Transportation Engineers, pp 30-35, September, 1994.

[5]The risks of cycling, Dr. Eero Pasanen, Helsinki City Planning Department, Traffic Planning Division, http://www.bikexprt.com/research/pasanen/helsinki.htm

[6] Verkehrsunfälle mit Radfahrern, Der Polizeipräsident in Berlin. Berlin Police, Germany, 1987.

[7] "(Un)Sicherheit auf Radwegen" by Bernd Sluka.  http://bernd.sluka.de/Radfahren/Radwege.html

[8] Another look at Germany's bicycle boom: implications for local transportation policy & planning strategy in the USA, H. Maddox, World Transport Policy and Practice, Vol. 7, No.3 pp. 44-48, 2001

[9] Cycle Routes, Traffic Advisory Leaflet 5/95, UK Department for Transport, 1995

[10] Cycling in Denmark - from the past into the future, Niels Jensen and Jens Erik Larsen, Road Di-rectorate, Ministry of Transport and the Municipality of Copenhagen, 4th Department, 1989. (Cited in: A Review of Bicycle Policy and Planning Developments in Western Europe and North America - A Literature Search Director-General of Transport South Australia 1992)

[11] The autumn of the Bicycle Master Plan: after the plans, the products, Ton Welleman, Dutch Ministry of Transport, Velo-city conference Basle, 1995,

[12] Irish National Cycle Facilities Manual (Provision of Cycle Facilities: National Manual for Urban Areas) , A Review, Comparison with International Practice and Exploration of the Wider Issues Facing Irish Local Authorities Shane Foran M.Sc., Galway Cycling Campaign February 2002

[13] History of cycle tracks, Volker Briese, ForschungsDienst Fahrrad, FDF 218, Allgemeiner Deutscher Fahrrad-Club, (German Cycling Federation) 28.05.1994

[14] From the Decline of a Mass Mode Of Transport - to the History of Urban Cycle Planning, Burkhard Horn: ForschungsDienst Fahrrad FDF 136, Allgemeiner Deutscher Fahrrad-Club, (German Cycling Federation) 09.03.1991

[15] RS.242, Bicycle Travel in Galway City, Brennan M.J., An Foras Forbartha, October 1979

[16] R.286 Design and Use of Roundabouts in Ireland, An Foras Forbartha, 1987

[17] RT 181 Geometric Design Guidelines (Intersections at grade) An Foras Forbartha, 1983

[18] Design Manual for Roads and Bridges, Vol. 6- Road Geometry, Section 2-Junctions, Part 6, TD 42/95 Geometric Design of Major/Minor Priority Junctions.

[19] RT 206 Warrants for pedestrian crossing facilities, M.M. Staunton, An Foras Forbatha, 1981.

[20] Source: Tomorrow's roads: safer for everyone, The Government's road safety strategy and casualty reduction targets for 2010, UK Department of the Environment, Transport and the Regions, March 2000

[21] Child predestrian death rates in republic are highest in Europe.  S. Breen, Irish Times 02/09/03

[22] Seatbelt Laws, Why you should be worried, Galway Cycling Campaign, November 2000

[23] Beaver Book of Bikes, H. Hossent, Beaver Books, Hamlyn Pubs. 1980

[24] Cyclist road deaths in London 1985-1992: drivers, vehicles, manoeuvres and injuries, M. McCarthy, K. Gilbert, Accident Analysis and Prevention, 28(2) pp. 275-279, March, 1996.

[25] Delivering Safer Roads: Managing the interaction of Cyclists and Lorries, Cyclists Touring Club/Road Haulage Association (UK), 2000. Galway Cycling Campaign -Feachtas Rothaiochta na Gaillimhe c/o Galway One World Centre, the Halls, Quay St., Galway. 15