Draft High Risk Rural Roads guide

Thank you for the opportunity to give feedback on the draft High Risk Rural Road Guide (the draft Guide).

This submission has been prepared by members of the Cycling Advocates' Network (CAN).
CAN is the overarching body of the national network of cycling advocates. It is a voice for all cyclists - recreational, commuter and touring. Its membership includes nearly 1500 members with more than 2000 additional ‘friends' who are on an email network. As well as taking on board the extensive cycling experience of many of our members who are both commuting and recreational/sporting cyclists, our submission is also based on contributions from those well versed in broader road safety policy, engineering and research.

CAN supports any measures that will make the land transport system safer for people who ride bikes. To that end CAN strongly supports improved infrastructure for cycling as well as other road safety initiatives as outlined in our submission on Safer Journeys. We welcome efforts to address safety on rural roads.

CAN is concerned, however, that the draft Guide gives very little attention is given to cycling and the perspective, experience and needs of people who ride bikes on high risk rural roads. While the aim of the draft Guide is to focus roads and road user groups with the worst safety record, it needs to be recognised that the crash statistics on which the draft Guide is based are not as up-to-date as would be desirable (given the inevitable lag with data collection and reporting). What needs to be included in the analysis and the measures proposed is some discussion about likely trends in injury and fatality crashes involving cyclists. We note that, for example, that the Chief Coroner is currently conducting an enquiry into cyclist fatalities in response to the significant number of deaths in 2010. The recent spike in cyclist crashes may be in part related to the growing numbers of people taking part in recreational and competitive road cycling events (and training for these) and also a growing number of people riding bikes for other journeys as result of the increasing price of fuel and in response to health promotion campaigns that promote active transport.

CAN recognises that because cycling's mode share is so relatively small and cycle crashes are dispersed across a very large rural roading network the authors of the draft Guide may find it challenging to address the safety concerns of cyclists. However, we consider that it is important to give visibility to this road user group in the draft Guide for the following reasons:

1. Cyclists are particularly vulnerable on roads where vehicle speeds are higher - which is the case in much of the rural roading network.

2. The recent cutbacks in funding for local roads are likely to result in reduced maintenance and upgrades to roads which already are poorly designed for cyclists.

3. For economic efficiency reasons, the needs of cyclists must be given full recognition in both new roading projects and major upgrades in order to avoid expensive retrofitting at a later date if the road is subsequently found to be of high risk for cyclists.

4. With the full implementation of the New Zealand Cycle Trail (Nga Haerenga) there is likely to be increasing cycle tourism which will mean greater numbers of cyclists on rural roads. (In particular, those rural roads which are between key sections of the Cycle Trail will carry a greater number of cyclists.)

5. With greater pressure on district council roading budgets, there is often an opportunity in local road maintenance to make small yet significant gains for cycle safety with shoulder widening and other treatments which don't require a significant budget line item for a more expensive cycle infrastructure project.

6. As argued in other CAN submissions, driver education rather than, or as much as engineering, will result in improved road safety yet without a focus on cyclists as a group of road users, driver education initiatives will be of limited value.

As well as giving greater attention in the draft Guide to current and potential future use of rural roads by cyclists, CAN recommends that emphasis be placed on three priority measures:

1) Reduced vehicle speeds overall and more comprehensive use of variable speed limits to achieve safer speeds on roads where there are hazards - e.g. limited visibility due to corners or hills, very narrow shoulders, etc.

2) Standardisation of consistent 1-1.5m shoulders on key cycle routes and, in particular routes, where there is a significant number of cyclists and/or no alternative for cyclists. This must include a review of the implementation of ATP markings which in many parts of the roading network have resulted in a reduced shoulder for cyclists and/or forced them off the shoulder and into the main vehicle lane.

3) Comprehensive consultation with national and local cycle advocacy groups in the development of draft guidelines for managing high risk rural roads and in design of rural roading projects.
In conclusion, CAN notes there are important co-benefits for other user groups in ensuring cyclist safety on rural roads. Available statistics used in the preparation of the draft guide are unlikely to reflect the recent observed increases in numbers cycling on rural roads for commuting and for
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recreation/sport and the current and future cyclist crash rate on rural roads. As well as the NZ Cycle Trail there is growing interest in cycling for recreation/tourism as seen for example in the Hawke's Bay where the Rotary Clubs and other partners have established an extensive network of cycle trails along stopbanks and the coast. With these local and regional initiatives increasing numbers of people are being attracted to riding a bike.

CAN thanks you for the opportunity to make a submission on the draft rule and is happy to provide further information if required.

Yours sincerely
Christine Cheyne
CAN Submissions Co-ordinator