Open letter from David Cox re: Coventry bus lanes
Dear Councillor Duggins and fellow cabinet members,
I am Chair of Cycling UK nationally and convenor of the Bike West Midlands Network which links up local cycling campaigns across the West Midlands Combined Authority Area and includes Coventry Cycle Campaign. Along with Living Streets Coventry and Warwickshire, we have become concerned about the proposed suspension of bus lanes in Coventry.
Tomorrow you are being asked to approve a plan not just to suspend a selection of bus lanes on a trial basis, but also to delegate the authority to remove all bus lanes permanently to the portfolio holder for city services. This does not seem to be moving the city to a more sustainable transport choice nor to be promoting active travel. It also appears to pay no regard to “Connected for Growth” the mobility strategy for the West Midlands to which we have given strong support in consultations. Cyclists are major users of bus lanes but your proposals make no reference to cycling. It is most disappointing to see one of our major Cities take this retrograde step.
The economic imperative
Coventry is a growing city, and this is obviously a good thing for the West Midlands economy. This growth is coming with a substantial amount of densification, especially in terms of an increasing number of high rise student accommodation developments within and adjacent to the city centre. As a city becomes more densely populated, then the case to improve public transport becomes further enhanced, as more pressure is put on existing road space.
As has already been pointed out by National Express Coventry, a full bus can carry in excess of 50 passengers, whereas even at peak times, the majority of cars are still carrying just one occupant. The core argument here is about peak traffic flows, because this is when congestion is highest.
The argument to return bus lanes to general traffic use is based on the observation that there can often be a large amount of empty space in the bus lane, whereas the general traffic lane remains full of traffic. However, an empty bus lane is actually a sign that the facilities the facility is working efficiently, not a sign of a problem.
Clearly, there is a minimum number of buses per hour which is needed in order for a bus lane to justify itself. If this bus lane review was being conducted on the basis of selecting out the bus lanes with the lowest usage (by all permitted vehicle types), then again, there would be little reason for opposition.
If the council were proposing a substitution of a lightly used single direction bus lane with a two way cycle lane, then we would again welcome this, as the cycle lane would be more space efficient, and it would provide a totally safe environment.
But buses can use general lanes too?
It could be pointed out that a general traffic lane can still carry buses, whereas a bus lane can only carry those vehicles which are authorised to use it, including taxis, bicycles and motorcycles.
However, this suggestion misses a key reason for having bus lanes, namely to give the buses a sufficient advantage to counterbalance the fact that passengers still need to spend time getting to and from the stop and waiting for the bus. Ultimately however, the real reason for having bus lanes boils down to the core need to move as many people as possible through restricted space as possible.
It has been suggested that the proposal to remove these bus lanes can somehow be offset by other measures to enhance bus patronage. Whilst no list has been provided, it is assumed that these measures include smart ticketing, marketing initiatives, or even pricing incentives, even if these are beyond the control of the council.
Any measure to offset the removal of bus lanes is also going to work, and of course to work even better, if the bus lanes are retained and enhanced.
It has further been suggested that bus lanes are an out of date, and even idealistic measure, and that they have no relevance in a modern city with the latest traffic management systems.
Far from being idealistic, bus lanes are an extremely pragmatic, even if essentially utilitarian way of moving more people through any given space than the equivalent general traffic lanes.
It is also completely confusing for the city to be talking about tram lanes with one hand and axing bus lanes with the other. To develop any kind of rail-based rapid transport system wouldn’t just require a substantial investment, but such a system would also need a much more tightly controlled right of way. On the other hand, retaining and further improving the network of bus lanes could be done at a relatively low cost, whilst also moving the same number of people or more, when compared to any equivalent light rail scheme. Unlike light rail, a guided or otherwise protected busway is entirely compatible with buses running in general traffic on more lightly trafficked parts of the route.
In order for junctions with active management to give priority to buses, the buses need to be approaching from a lane that is properly segregated for their usage.
The Traffic Management Act
The Traffic Management Act of 2004 makes very clear reference to the need to keep traffic moving, and also to selectively restricting certain types of traffic in order to manage congestion (Section 16.2 a/b).
There is no such requirement in the act to prioritise cars over other more efficient modes, and therefore the council is perfectly capable of retaining the right to prioritise the movement of buses and other sustainable modes, including walking and cycling, based on the simple grounds that they move more people per square metre of road space.
Learning from Liverpool
Liverpool is a city which has seen a substantial amount of regeneration in recent years. However, it is virtually never cited as an example of a city with an effective road management policy, and the result of bus lane removal has been largely negative, with one operator reporting that they have had to buy 2 extra buses, just to be able to maintain the same route frequency without carrying any more passengers. In some instances what were once bus and cycle lanes have been relegated to car parking.
Bus lanes are not an ideal place in which to cycle, but they are a very substantial improvement when compared with a busy two lane general traffic carriageway.
Although buses are much larger than cars, they are driven by highly trained professionals, who on the whole respect cyclists better than regular traffic.
The right to cycle in bus lanes
Naturally, the best kind of bus lane for buses is one to which they have the exclusive right of usage, and the best space in which to cycle is a dedicated cycle lane.
It has been suggested that Coventry’s bus lanes are “just for buses”, but this is not the case, except for a small number of locations where a parallel cycle lane exists on the near side. Were cycles to be banned from bus lanes, it would create a situation where cyclists could be both overtaken by fast moving cars on the right, and slammed into the path of heavy buses on the left – clearly this would be untenable, and for this reason cycling is permitted in bus lanes across the UK.
What about car drivers?
In the early weeks of this trial, there might well be an improvement to general traffic flow in some areas, based on the fact that general traffic now has two lanes to use instead of one. However, such a change can only lead to the well-documented problem of induced traffic, partly through drivers making journeys they wouldn’t otherwise make, but also because it is entirely inevitable that when faced with both longer journey times outright, and the loss of any time advantage over general traffic, those remaining bus passengers who can switch to driving will almost certainly do so.
It may well appear counterintuitive, but the best way to make driving easier is always going to be to improve the public transport and active transport offering. It’s only once this is done that those people who already own cars can then happily make the choice to take alternatives, because the alternatives are just as convenient. It has been shown the world over that cities with a genuine balance of all users, ie with a modal share which reflects this, are also the ones in which congestion is lowest.
There will always be residual traffic, including vans and other utility vehicles, and of course private car drivers and passengers for whom public transport is not an option. However, the best way to ensure that these drivers can still move freely is to ensure that the number of cars blocking the way in front of them is kept as low as possible.
Do nothing or do something?
Bus lane removal is presented as a do nothing or do something option, when any number of measures are available in order to discourage driving, not through Draconian tactics, but simply by making the alternative is a great deal more attractive.
Such measures might be improvements to the bus services themselves, but also effective investment in a really workable walking and cycling network, such that the combined modal share of these two modes grew into the region of 40-50%, not the mere 15% it is at today.
The need for an Equality Assessment
Approving this bus lane trial puts the council at substantial risk of a complaint under the Equality Act 2010, because no assessment of the potential impacts of bus lane removal on disabled people has taken place.
Even if the trial results in a decision not to close any bus lanes, the trial itself still presents 6 months of very substantial and unacceptable danger to cyclists with protected characteristics, and these include age (young and old) and gender as well as disability. Phasing the trial could mean some cycling routes merely end up being severed in different places across a period of 2 years.
It is also worth noting that no consultation has taken place with concerned groups – invitations have been made twice from the Coventry and Warwickshire Accessible Transport Committee, yet this group has yet to meet, something which is entirely unacceptable, given the need to raise concerns before the trial takes place.
Cycling isn’t just one of the most popular form of exercise for people with disabilities, the propensity for vulnerable users to cycle is even more proportional to the quality of cycling facilities than it is with potential cyclists who don’t have protected characteristics.
The Cabinet report for this agenda item claims that there is no need for any equality impact assessment, because the impact of the bus lane removal trial will be minimal.
Very clearly, it will not be minimal at all, it will be very severe, especially as there is no proposal to replace any of these bus lanes and cycle lanes, in fact, the report doesn’t even mention the word cycling once.
For this reason alone, this trial must be halted, until much more information is provided about the methodology which might be used to select bus lanes for potential removal, and the council at the very least publishes information about how it considers the movement of people rather than just the movement of private cars together with publishing traffic counts which include the number of cyclists which are using these bus lanes.
A more specific trial which clearly selected a small number of bus lanes which have a relatively low level of service, and where there is either a low level of cycling, or where a parallel cycle path is available would be a reasonable and measured approach to take.
However, given what is before you for tomorrow, I can only respectively asked that you reject this proposal.
David Cox OBE
Chair of Trustees