Spokes Canterbury
Advocating for Cycling
P.O. Box 1606
Christchurch
www.spokes.org.nz
secretary@spokes.org.nz
24 October 2014
Safer Journeys for People who Cycle:
Cycling Safety Panel Draft Report and Recommendations
SUBMISSION FROM SPOKES CANTERBURY
Thank you for the opportunity to make this submission. Spokes Canterbury is a local cycling
advocacy group with approximately 1,300 members that is affiliated with the national Cycling
Advocates Network (CAN). All submissions are developed online and include member’s input.
Spokes is dedicated to including cycling as an everyday form of transport in the greater
Christchurch area.
We would like the opportunity to appear at any public hearing that is held to consider
submissions on this Plan. Should there be an officer’s report or similar document(s) we would
appreciate a copy(s).
If you require further information or there are matters requiring clarification, please contact
our Submissions Convenor Dirk De Lu in the first instance. His contact details are:
38 Thorrington Road
Cashmere, Christchurch 8140
Phone: 337 1790
Email: dirk4@paradise.net.nz
Don Babe
Chairperson, Spokes Canterbury
Spokes Canterbury is very satisfied with the recommendations of this Panel. Our
representatives to the citizen’s advisory panel were fortunate to interact with the panel
members and uniformly pleased with the experience. It was a real pleasure to work with such a
well-run and focused effort that wasted no time and produced a document worthy of the
important issues addressed.
Spokes is, in principle, in support of all recommendations. We learned from our representative
to the Panel that the feeling of the other advisory members is that the panel adopts stronger
language, by insisting rather than ‘recommending’ the actions be fully adopted and
implemented if the goal of safe roads for all is to be achieved.
There are, however, some recommendations we wish to make. We see these as essentially
minor improvements to a good report.
GENERAL COMMENTS
1. Measure of success (p. 6)
The suggested measure of success, a reduction in the death and serious injury (DSI) rate per
million kilometres cycled is a good starting point. We suggest that the Panel additionally include
the significant increase in the rate of uptake of cycling, measured in cycle kilometres travelled,
since we know that with increased numbers comes increased cycle safety. We are confident the
Panel can think of a valid target rate.
2. Setting priorities
In order to maximise the return from this consultation it is important to get some early wins.
Therefore priority has to be given to those recommendations that will produce the biggest
improvements in the shortest time. Given the overwhelming involvement of trucks in cycle
fatalities efforts should be directed towards this area first. Often speed is not an issue in these
accidents so the efforts need to look at safe roads, safe road use and safe vehicles.
DON’S BIT: DOES IT GO HERE OR UNDER SAFE VEHICLES (RECOMMENDATION 12)
Truck priority routes are often Roads of National Significance. Active modes need to be
considered during the delivery of these assets. Some areas will have completely separate
provision made for active modes whilst others may have separate facilities within the corridor
but some sort of provision needs to be made. This will lead to better outcomes for the trucks
also with less risk of accidents and smoother traffic flows.
Safer road use by trucks will be enhanced quickest if there is corporate responsibility for
employed drivers and contractors. Truck drivers should be treated the same as drivers that do
not leave the owners' premises like forklift drivers. Health and Safety legislation should treat
both drivers the same. The systems are in place for safe forklift use and would be easy to
extend to truck drivers.
Safe trucks will have side under run protection and proximity warnings covering blind spots.
The recommendation to investigate side under run protection needs to be extended to include
the use of proximity sensors. Maybe the sensors will negate the need for the under run
protection. The cost will fall on the trucking company but the benefit of not having a vehicle
and a driver involved in a fatal accident will go some way to mitigating the cost.
SAFE SYSTEM ENABLERS
Recommendation 1: Planning and Investment - safe provision for active modes is considered at
all stages of road transport planning and investment.
This recommendation is completely open-ended. A small increase in the priority status of active
transport could meet this recommendation with no discernible benefits to active travellers.
This recommendation could be re-written to be something like:
The safe passage of users of all modes of road transport be the over arching
consideration at all stages of road transport planning and investment.
This would avert some of the current practices where some infrastructure is designed for
dominant use by a few modes so other modes are ignored or made to use sub-standard
infrastructure. Obviously motorways would still exclude walkers and cyclists but all other roads
need to provide safe facilities for active modes.
We support for all Actions under this recommendation.
Spokes urges that the Panel add:
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Local bodies, Road Controlling Authorities (RCAs) must be included if improvements are
to be achieved. Benchmarking of cycling provision needs to be mandatory. Key
Performance Indicators (KPIs) for cycling and safety need to be meaningful and are
required for funding. Designs need to be credibly audited for compliance. The current
approach under-serves the poor and other disadvantaged social minorities, leaving
them with poor transport provision and greater injury risk.
Specify in (ii) the benefits to be included i.e., public health, congestion and pollution
reduction, positive impact on balance of trade, etc.
Mandate meaningful early involvement of cyclists/cycle advocacy groups at all levels of
government in planning and projects, including land use planning.
Increase funding for cycling to support goals of 10-20% of trips by cycle. The current
funding levels are grossly inadequate while over allocating far lesser ‘value for money’
big road projects.
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Redraft the Transport GPS in alignment with future needs and best practice. We can
furnish you with our submission on the GPS if needed.
Recommendation 2: Leadership and Accountability - establish strong leadership and
accountability practices for safe cycling
We support for all Actions under this recommendation.
Spokes urges that the Panel add:
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Current practice is to allow drivers to escape responsibility for their actions resulting in
serious injury or death to cyclists and failure to enforce even basic road code rules in
many instances.
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The culture of ‘car is king’ is dominant in how people use the roads and accepted as
simply ‘the way things work’. In large part, this road culture and the lack of proper
infrastructure creates chaotic and unacceptable interactions with all road users, too
often ignoring the road code. Cyclists may find that they break the ‘rules’ simply to
survive, mounting the footpath, passing on the inside of intersections to be at the head
of the queue, etc.
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An attitude of ‘every one for themselves’ is the logical outcome when the rule of law in
support of the public good is drafted without recognition of all road users and applied
inconsistently. It is sincerely hoped that this panel’s report will make large strides in
changing what has been a system delivering unacceptable outcomes for decades.
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Mutual respect is furthered when road users have faith that unacceptable behaviour
will not be tolerated. Legal consequences for unacceptable and/or illegal behaviour
must be fit for purpose.
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Adopting the premise that motorists must be proven innocent in collisions with nonmotorised road users is a first step to overcoming the sense of superiority currently
ingrained by practice and too often supported by authorities. Cyclists too must be held
accountable with consequences commensurate with the threat posed to other road
users and themselves from unacceptable behaviour.

Safe leadership and accountability must include all involved, including enforcement.
Infrastructure and improved skills on their own will not be enough.
Recommendation 3: Information collection systems relating to cycling safety be improved and
expanded.
We support for all Actions under this recommendation.
SAFE ROADS AND ROADSIDES
Recommendation 4: Minimise crash risk - RCAs take action to minimise conflict (crash risk)
between people who cycle and other road users, especially heavy vehicles.
We support for all Actions under this recommendation.
Spokes appreciates the Panel pointing out the outdated and unsafe design practices furthered
by Austroads and the recommendation that best practice European standards which recognize
the vulnerability of and paramount concern for vulnerable road user’s safety be considered.
Spokes urges that the Panel make the following changes:
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That New Zealand call for Austroads to be amended in alignment with international best
practices and that these approaches be implemented during the Austroads updating
period.
Item (ix), concerning cyclist safety at road construction, should definitely be made high
priority.
Recommendation 5: Road Controlling Authorities provide safe on-road connections to the NZ
Cycle Trail and other nationally significant cycle trails.
We support for all Actions under this recommendation.
SAFE SPEEDS
Recommendation 6: Manage Motor Vehicle Speed – to minimise crash risk and severity.
We support for all Actions under this recommendation.
SAFE ROAD USE
Recommendation 7: Minimum passing distances – mandated via the Land Transport Act and
Regulations
We support for all Actions under this recommendation.
Recommendation 8: School Travel Plans and Cycle Skills Training – increased support from the
Transport Agency and local government.
We support for all Actions under this recommendation.
Spokes urges that the Panel add:

Require cycle skills training in all schools up to skill level ‘grade 3’. Even students who do
not go on to cycle may have a better understanding of the needs of people who cycle
and hence have better driving skills.
Recommendation 9: Road User Behaviour and Awareness – the Transport Agency to develop
programmes to improve road user (both drivers and cyclists) behaviour and awareness.
We support for all Actions under this recommendation.
Spokes urges that the Panel make the following changes:

Combine Actions 8 and 9. They are closely related and the two may result in better
outcomes.
Recommendation 10: Corporate responsibility - WorkSafe New Zealand and ACC and other
stakeholders encourage corporate responsibility for employed drivers and contractors so that
they practise safe behaviour towards cyclists.
We support for all Actions under this recommendation.
See comments made on Action 2 which also apply here.
Recommendation 11: Legislative Review – the Ministry of Transport refresh its legislative
review of provisions relating to cycling.
We support for all Actions under this recommendation.
However, should a review take place, a body such as this Panel should be closely involved in the
process from the outset.
Spokes does not have an official position on the requiring of helmets. Spokes is aware that
some people who might cycle may be put off cycling by this requirement. Requiring helmets
also conveys the message that cycling is dangerous. Moreover, research has shown that
occupants of motor vehicles would also be advantaged by wearing helmets. While it is unlikely
that any government would mandate helmet use in cars, the fact that it would be wise to do so
should be as widely disseminated as the information on helmet requirements for cyclists.
SAFE VEHICLES
Recommendation 12: Truck Side Under-run Protection - investigation of side under-run
protection and other vehicle features to minimise the risk to cyclists from heavy vehicle
crashes.
We support for all Actions under this recommendation.
Furthermore, we ask that consideration of the life-altering consequences for victims as well as
the cost to society in medical expense, lost productivity and full social costs of truck/bicycle
collisions be fully included in the cost / effectiveness of requiring safety equipment on trucks.
Recommendation 13: Bicycle Lights and E-Bikes – the Transport Agency adopt improved
standards for bicycle lights and the European Union standard for e-bikes.
We support for all Actions under this recommendation.
We support the Possible Performance Measures provided.
REGARDING ALL SUGGESTED ACTIONS
Medium Priority Actions
It is understood that the Panel is trying to take a balanced and realistic approach as to what can
reasonably be achieved. With fundamental social change and transport mode choice priority
being clearly implicit raising all of the medium actions to high may well be an honest approach.
What is sought here is fundamental change. An incremental approach is traditional, but unlikely
to achieve the safety goals in a reasonable time period.
Thank you to all those involved in making this excellent report and recommendations.