'not without difficulties' The Royal Parks have no plan for Road Danger Reduction

As you should be aware, there is currently a TfL Consultation on the sections of the East-West Cycle Superhighway through and just beyond three major Royal Parks in London – St James’s Park, Green Park and Hyde Park. London Cycling Campaign have a strong summary here on the proposals, for which the consultation closes on Sunday 29th March.

In short, the East-West Superhighway is to be a segregated route giving cyclists dedicated space away from heavy flows of motor vehicles and pedestrians almost all the way, except when it reaches the royal parks. There had been conflict over what to do here as far back as 2013, when the Royal Parks were quoted as saying:

It is essential that any new routes are safe, not just for cyclists at busy junctions like Hyde Park Corner, but also for the many thousands of other people who use the parks, including pedestrians, children, runners and horse riders.

Within the parks the plans are amazingly timid, but actually propose cyclists sharing space with pedestrians, children, runners and horse riders, as the segment outside Buckingham Palace shows:

The number of traffic lanes is rather notable in this image. There is a lot of traffic through the Royal Parks. Unfortunately there are no count points within the royal parks themselves but there is a count point on the road from Parliament Square towards Birdcage Walk (CP 18664). On a typical day there is about 20,000 PCUs of motor vehicle traffic at that point, a figure that has remained stable since the year 2000.

Cars dominate within the Royal Parks, and a large number of those are taxis and private hire vehicles. The speed limit is 30 miles per hour, even in front of Buckingham Palace.

On the Sunday Politics in February, MPs of both Conservative and Labour parties representing seats in London felt it was ridiculous.

The alternative proposal from TfL would have had a segregated lane (using bollards) of cycles running in the road, rather than sharing space with pedestrians. Surely this should have been more to the Royal Parks liking? TfL, and Andrew Gilligan were not impressed, and nor were people who wished to cycle on a safe route.

In the time since little further news has appeared but first Peter Hendy has appeared in front of the London Transport Committee on February 25th:

Hendy was clear:

The Royal Parks ought to accept that the Mayor’s determination to have segregated cycleways is as justifiable a reason to have changes around the memorial in front of Buckingham Palace as it is to have them on the Embankment, on Lower Thames Street, on Lancaster Gate and on roads in London used by a lot of people.That is what I think and I very much hope they will come to that conclusion.

And then Andrew Gilligan:

Gilligan was clear that in Hyde Park the Royal Parks required the cycle superhighway to run on the roads rather than the paths. However in St James’s Park their position is the opposite, with them requiring that people on bikes share space with people on foot.

Gilligan said:

I’ve got concerns about that route, first because it’s less direct than the one we want and secondly because it does create major pedestrian/cyclist conflict at the bottom of Constitution Hill […] just by Buckingham Palace there is a pedestrian crossing at which on a sunny summers day there are regularly perhaps 150-200 pedestrians waiting to cross. […] At the moment the Royal Parks proposal is going to mean cyclists more or less cannoning into those people.

Gilligan said that after the consultation (on the scheme in a design that TfL and Gilligan did not want) the Royal Parks would then respond. Alright then, weigh the responses and then do something different, but what about the wider issues?

I myself found it strange that the Royal Parks continues to operate a number of heavily trafficked 30mph roads through major green spaces in a busy city. There have even been two deaths in St James’s Park, which I identified via my map of TfL’s collisions data looking at pedestrian and cyclist casualties from 2005-2013. The news report for one of them makes plain it was a collision between two luxury cars and a young woman on foot, one of which drove away from the scene. The other collision seems also to be in the early hours of the morning, but involved a single car. It is quite likely that these vehicles were minicabs or taxis who use the route to run through Central London at speed taking advantage of a 30mph speed limit.

KSIs here are mostly affecting people on foot:

But collisions involving people on bikes are in broadly similar areas:

And if you zoom out a bit, and look at all collisions, you can see that roads within the Royal Parks seem no less dangerous than those outside them:

So the outcome of a lack of safe space for cycling and a lack of a reduction in road danger will affect both people on bikes and on foot. The plans as proposed are not right, and need to be improved to at least the standard of the already approved East-West Superhighway.

I thought it would be sensible to ask The Royal Parks a few basic questions, to see if they had a clear idea of how they might reduce road danger. Had they considered 20mph? Did they have a strategy to reduced KSIs? I tried twitter, after all their initial response seemed relatively open to a conversation.

@theroyalparks Does The Royal Parks have a strategy for KSI reduction?

— Alex Ingram (@nuttyxander) February 10, 2015

Note: Going by Gilligan’s comments, the Royal Parks could and should have been clearer that they would make their response after the consultation had closed.

I tried again to ask about KSI reduction.

@theroyalparks Right, I give up asking via this medium and have sent you an email. If I have to, I'll send you a letter.

— Alex Ingram (@nuttyxander) March 4, 2015

I gave up and send them the following email:

I am amazed that in the ten years that I have lived in London I have seen no measures taken to calm or reduce traffic in the royal parks. Why is this?
In particular I am troubled that from my own experience of riding The Mall by bike in the hours of darkness and of reviewing the collision data inside the park that it is a dangerous and potentially fatal piece of road.
In other locations like this councils in London are clearly taking forward work to reduce road danger and KSIs [deaths and serious injuries], so I would like to know:
What is the Royal Parks view on road danger on the roads through the parks?
What strategy is there in place for reducing that danger and the consequence KSIs?
What studies have been made considering a lower speed or width for traffic on The Mall and Constitution Hill?

Today I received their response, which I think is disappointing in several ways:

Dear Mr Ingram

Thank you for your email and again please accept our apologies that you did not receive a response via our twitter account.

Firstly I can confirm that The Royal Parks take all health and safety issues in relation to the Parks and to the Roads very seriously and works very hard with its partners to try to ensure that neither pedestrians or cyclists are put at any unnecessary risk whenever visiting or using either.

With regard to the two roads you refer to, both are subject to 30 mile per hour speed limits and enforcement of those speed limits are managed by the Metropolitan Police Service.

We are aware of the cycle superhighway consultation which is being led by Transport for London and the proposals are intended to improve the safety of cyclist and other road users. We note however that they are limited to a number of specific routes and those routes do not include the Mall or Constitution Hill.

Any changes that we make that involve traffic calming, reducing the speed limit or other safety measure have to be done in compliance with the 1997 Royal Parks and Open Spaces Regulations as amended. These regulations govern what can and cannot be done in relation to the Parks and Roads and any changes to those regulations have to be by way of a statutory instrument. For that to be done a bill would have to be introduced and passed in Parliament, which as I am sure you appreciate is not without difficulties not least because of the considerable pressure already on government time.

We have in recent years introduced a cycle lane on the Mall North Horseride running parallel to the Mall and introduced traffic signals for cyclists to cross Marlborough Road; we have installed cycle lanes under Admiralty Arch; we have increased the width of the cycle path in The Green Park adjacent Constitution Hill and introduced a shared pedestrian and cycle path at the rear of Canada Gate; and we have made improvements to the traffic junction of Horse Guards Road and Birdcage Walk. We are also currently working with Transport for London on their proposals for cycle quietways through St James’s Park and The Green Park, for which TfL’s public consultation closes on 29th March.

I trust this deals with your query but if we can be of any further assistance please don’t hesitate to contact us.

Yours sincerely
Mark Wasilewski
Park Manager
St James’s Park and The Green Park

Now these are issues that go far beyond the cycle superhighway raised here, there is clearly no vision for making The Royal Parks into safer places and they are hiding behind the complexities of governance as being a reason for no change.

It raises so many questions: Are we really to believe that parliament would not look favourably upon a 20mph limit in the Royal Parks? Is there any enforcement even of the 30mph limit now? Hasn’t the general political commentary been that the final year of this coalition has run short of legislation? Aren’t people’s lives actually more important than some dry detail about how we choose to define speed limits in a park? Why doesn’t the Royal Parks have any plan to deal with the danger on what are some of London’s most busy roads?

I haven’t done a thorough check, but the Royal Parks own website appears to show statutory instruments having been passed to change regulations in 2012, 2010, 2004. Yet they ask me to believe that change is “not without difficulties” and yet as recently as 2012 two statutory instruments amending Park Regulations were passed in the same year.

Regardless, the job in hand just now is to be clear in the response to the consultation on the Cycle Superhighway that it needs clear, safe, dedicated and protected space for cycling if it is to go through the parks properly. So, if you haven’t, go and do that now!

But longer term, we need to be thinking about how we want green spaces in London to be used, and if having high volumes of fast motor traffic is a priority. I’m going to go out on a limb, and say they’re not.