Response from Bristol Cycling Campaign to May 2014s draft of Policing the Roads Strategy

19 June 2014

It is crucial that A&SP documents and maintains its strategy for policing the roads. Bristol Cycling
Campaign (BCyC) welcomes the opportunity to contribute to this strategy.

To respond to this draft is a challenge for the volunteers of Bristol Cycling Campaign, who have limited
time available. We regret not having the time or space to commend several of the interventions listed in
this strategy. This response instead focusses on the gaps between what is proposed and what we believe
is missing.

General Comments

Given the PCCs priorities, we believe it is important that the strategy includes the commitment to
ensure that all Vulnerable Road User (VRU) victims of road traffic collisions are provided with the Basic
category of service and information as described in the VCOP and reiterated on your Road Traffic
Collision - Police Response and Victim Service flow chart.

With e.g. between 1 and 2 KSI suffered by pedestrians and cyclists each week in Bristol City Council area,
current interventions by all authorities are clearly inadequate. BCyC feels that this strategy should
document an eventual desire to implement a fully comprehensive range of interventions to protect
vulnerable road users. We feel that many of the interventions being adopted around Britain and the
world are not even being considered in Bristol, possibly not in the other districts either. For example,
there are several interventions discussed and agreed at the Bristol Cycling Partnership meeting which do
not appear in this strategy.

BCyC feels that the strategy is written around motorists, including motorcyclists. The strategy should
recognise that the greatest harm is being perpetrated by those least at risk towards those most at risk. In
doing so, it will be ensuring victims are at the heart of the criminal justice system at least as far as the
police are concerned.

This draft strategy in relation to collisions focuses to an almost exclusive extent upon KSI incidents. BCyC
suggests that the strategy should recognise, in the introduction, that there are many lesser degrees of
severity of road crime which nevertheless warrant interventions from the police. BCyC suggests that the
following degrees of severity could be recognised:

1. KSI eg. paraplegia
2. hospital visit injury eg. operations and NHS expense
3. injury, no hospital visit eg. weeks off work
4. collision eg. damage and expense to property
5. incident which could have resulted in KSI eg. shocking and intimidating close shave
6. disempowering threat & intimidation eg. children not empowered to walk to school

It is experience of the lesser degrees of severity which are thwarting the attempts of the authorities in
our four districts to encourage uptake of walking and cycling. For example, in Bristol, 63% of the
population would like to be able to cycle, but perceive the threat and intimidation from using the roads
in this way to be too great. We would also question whether, in relation to vulnerable road users, it is
practicable or sensible, to separate off action to prevent KSIs from action to prevent other injuries. FOr
example, whether the opening of a car door on a cyclist causes a KSI or a lesser injury will be due to a
slight random combinations of events.

As discussed at your meeting, BCyC suggests that repeated reference to Road Safety reflects an out-of-
date approach to reducing danger presented to VRUs on the road. An alternative term, Road Danger
Reduction has been developed by local authority traffic officers for many years. Please see

http://rdrf.org.uk/about-2/

and a one-page summary from 2010 by Dr. Adrian Davies may be found at:

www.travelwest.info/sites/default/files/Essential%20Evidence%20No%2055%20Casualty%20and%20Dang.pdf



Specific Comments relating to sections/paragraphs of the draft document
Sections of the draft document to which these comments relate are named in italics.

Aims and Objectives #1 (page 1)
This document prioritises KSIs, but almost to the exclusion of injuries, threat, intimidation and
inconvenience other than KSIs caused by illegality on the roads. This document is a strategy rather than a
plan, and a strategy document should include the strategic vision eventually to address all requirements
comprehensively. It is the place of a plan, not a strategy, to prioritise and to exclude, based upon
timescales and resources. To prioritise some requirements to the exclusion of others is a tactic and not a
strategy.

Aims and Objectives #3 (page 1)
Whilst this paragraph documents the aim and objective to combat anti-social use of the roads, the
ensuing strategy offers almost nothing in the way of addressing antisocial behaviour towards vulnerable
road users (VRU).

Aims and Objectives #5 (page 1)
BCyC welcomes and is keen to collaborate in this.

Introduction, 2nd paragraph (page 1)
BCyC believes it is important to add to this introduction that: The efforts of the NHS and the local
authorities to improve health and mobility, and to reduce congestion and pollution, through the
encouragement of walking and cycling, are being thwarted by perceived threat and intimidation by
motorists on the streets (and pavements).

Introduction, 4th paragraph (page 1)
In addition to these encouraging statistics and charts, BCyC believes it would be instructive to include
the statistics showing the trend of KSIs for vulnerable road users such as pedestrians and cyclists. Whilst
improvements in vehicle safety (eg. air bags) have contributed to falling trends for motorists KSIs, this
strategy should recognise that KSI trends per kilometer travelled for pedestrians and cyclists are not
encouraging.

Furthermore, this introduction could helpfully include some statistics about the causes of injury and
inconvenience to vulnerable road users. These causes tend to be inattention on the part of motorists. Of
the four contributory factors listed in this paragraph, one (no seatbelt) is not a cause at all in injuries to
VRUs and motorcyclists. The other three (mobile phone, speeding, drunk/drugged driving) were almost
totally absent in the analysis undertaken by BCyC of the causes of injuries on Gloucester Road in Bristol.
BCyC suggests that a list of all the statistically significant contributory factors from Stats 19 reports
which resulted in injury to vulnerable road users be included in an appendix.

BCyC repeatedly requests that interventions be evidence-based.

Introduction, 5th paragraph (page 2)
As well as regular engagement activity with road user groups deemed most at risk, BCyC request that
there should be parallel regular engagement activity with road user groups most causing risk.

BCyC does not agree with this paragraphs claim that proportionate traffic enforcement is undertaken
to disrupt criminality on the road network since there is considerable evidence that criminality is often
ignored. BCyC has escalated some more serious instances of this to A&SP. BCyC request that this wording
is changed to reflect what is the strategy, rather than what is the current status.

Diagram 1 (page 4)
Protecting Those Most at Risk often requires Enforcement as well as Engagement, Engineering,
Education

LPA Delivery (page 6)
BCyC is surprised that online and app reporting of bad behaviour is not part of the strategy. There is not
currently a way to report on-line to A&SP. This web link

https://www.avonandsomerset.police.uk/contact-us/report-a-crime-or-incident/

only advises to dial 101. The link fails to gather any information or data. And advises that unless there is
damage or injury, it is not appropriate even to dial 101.

In discussions with A&SP, BCyC had understood that A&SP recognises the value of intelligence gathered
through the reporting of bad behaviour (or worse). This draft should document the strategy for attaining
an online reporting tool for A&SP. There is also no reference to the setting up of Incident Assessment
Teams to decide on follow-up actions, as discussed with A&SP in recent communications.

LPA Delivery bullet #3 (page 6)
Add a new bullet Working with statutory and voluntary partnerships to deliver a comprehensive list of
interventions to reduce road danger, in addition to the Fatal 4 offences.

A comprehensive list of interventions, delivered in conjunction with statutory and voluntary partnerships,
should usefully be included in an appendix.

LPA Delivery bullet #7 (page 6)
Please elaborate on Develop. How develop? Develop into what?

BCyC welcomes that the response to Neighbourhood Forum concerns should be appropriate, and
strongly believes that policing should be evidence-led rather than politically-led.

Integrated Victim Care Teams (page 7)
(Please see comment at head of this document.)

Protecting Those Most at Risk (page 8)
Several agreed actions were listed in the minutes to the meeting March 2014 of the Bristol Cycling
Partnership, not all of which have found their way into this strategy or its plan. We summarise them
here:

Improved investigation standards from Bristol officers. This will result in an increase in
prosecutions for road traffic offences.
Evidence-based problem solving approach to be adopted in the 5 Bristol policing areas
Bikeability training to be delivered to police officers across all Bristol LPAs as required
Bike awareness literature to be considered to support the NDORS scheme
Near miss reporting portal to be developed within the Avon and Somerset Police website

It is necessary also to list and to include in the strategy (for the future) many other interventions,
including, but not limited to, those listed as in the ice box for future consideration by Bristol Cycling
Partnership in the minutes of the March 2014 Bristol Cycling Partnership meeting, ie.

Improved victim focus for vulnerable road users/cyclists by the linking of ATLAS recording system
to the Integrated Victim Support Team
Improved use of data from CSW, NDORS, NHS and Cycling City for effective long term problem
solving
Research and analysis on victim profiles
Development of a standard evidenced based Bristol approach to problem solving including all
relevant agencies
Research in relation to national evidence for problem solving
Police and partners to deliver Safer Systems Approach strategy
advanced training for motorists

Action Plan Ref. 14b (page 11)
Public feedback should include taking steps to countering misinformation about the dangers on the roads
and pavements. Just as perceived fear of burglary is greater than actual risk of burglary, so also is
perceived danger on the pavements from cyclists much greater than actual danger. It is many times more
dangerous to cross a road than to encounter a cyclist on a pavement.