SUBMISSION – City of Stirling Draft Integrated Cycling Strategy – 2010

The City of Stirling recently published for public comment its, Draft Integrated Cycling Strategy – 2010.  The Strategy can be downloaded here and comments can be made in writing (the old fashioned way) up to Wednesday February 23, 2011.

Submissions should be in writing and addressed to:

Mr Stuart Jardine
Chief Executive Officer
City of Stirling
PO Box 1533

My own personal submission is published below. It may help you with ideas and of course you are welcome to use it as you deem appropriate.

I thank you for this opportunity to comment on the draft City of Stirling Integrated Cycling Strategy as dated October 25, 2010. Before commenting further on the Strategy I would like to take a moment to make a couple of more general observations and in particular with reference to the City’s website page,

I get the impression from reading the Strategy that the City is looking to encourage participation in cycling at least at some levels if not all, however, when I read the website page I found the language used quite discouraging with inappropriate labels based on the choice of clothing to describe certain groups of people. I find such generalisations really lacking in substance. I remind you Mr Jardine of the your own Council’s Code of Conduct as amended December 15, 2009 and I ask that the staff concerned with the authoring of this page are reminded of the Code and that the website is re-written to remove the inappropriate language and is written in a manner both inclusive of all members of the community and one that reflects a standard of professionalism that would be reasonable to expect from an organisation such as the City of Stirling.

My second general observation is that I note numerous references within the Strategy to the Council’s own bylaws and in particular the speed limit of 10 km/h on Council property. Whilst in principal I have no issues with this by-law I do however have issues with the hypocritical application of it by the Council and the apparent insistence that the by-law should be applied to cyclists because of issues with pedestrian interaction, yet the Council sees fit to put up signage in its own car parks recommending speed limits which are 100% greater than the limits as specified in the by-law. Does the Council seriously consider the risk of motor vehicle pedestrian interactions are worse than those with cyclists? Please ensure that once again your own by-laws are applied consistently and fairly to all local government property users and that your own by-laws are enforced to protect vulnerable users. The Australian Road Deaths database clearly shows the sources of the greatest risk are motorists not cyclists despite the Strategies implication otherwise.

In respect to the Strategy itself I wish to make the following comments:

  1. Referring to page 26 and the reference to bicycle lanes. The statement as made may be misleading. The Road Traffic Code 2000 as amended December 8, 2010 Section 213 requires a cyclist to ride in a bicycle lane only if it is a reasonable condition. More specifically the Code defines a bicycle lane as one that is marked at each end by signs as defined in the Code. On road markings of “bicycle lanes” do constitute a bicycle lane. I suggest that the Strategy is worded correctly here to ensure no misunderstandings of what a bicycle lane is and hence is application. The City should also ensure that where it wishes to install bicycle lanes that it does so in-accordance with the Road Traffic Code.
  2. Referring to page 29 and the comment that “Shared Paths may well be appropriate where faster cyclists have an alternative (adjacent) on road option.” I do agree with this statement and encourage the Council to take action to implement this approach in respect to one of its most significant “shared paths”; the one that runs alongside West Coast Drive. Currently there are no safe reasonable options for cyclists on either the road or the regional shared path.
  3. Referring to Recommendation 1 – “Under 10 km/h rule.” I support this recommendation in principal however I do believe that the recommended 10 km/h is too slow and a more reasonable limit is 15 km/h for all users. Furthermore I remind the Council that under the Western Australian Road Traffic (Bicycles) Regulations 2002 there is no legal requirement for a bicycle to have a speedometer and hence I suspect that despite the comments to the contrary in the Strategy enforcement of a speed limit will be very difficult if not impossible. I also suggest that the Strategy is amended to demonstrate an understanding of the relevant State regulations.
  4. Referring to Recommendation 2 – “Collection of cyclists accident data”. I support this recommendation and encourage the Council to urge the development of a model that captures accurately motor vehicle/cyclists crashes as well as pedestrian/cyclist crashes so we have a better understanding of the causes of such accidents rather than adopting the prevalent view in this Strategy of cyclist fault.
  5. Referring to Recommendation 3 – “Signage”. I support this recommendation but do encourage the extension of this recommendation to include development and installation of “educational” signage to encourage responsible sharing of paths by both pedestrians and cyclists. Both parties have responsibilities to share and it is disappointing to not see this coming through in the Strategy.
  6. Referring to Recommendation 4 – “PSP”. I support this recommendation and do encourage the City to take steps to address the interaction points at is own car-park driveway on Cedric Street and the Cedric Street crossing. Both risky places for cyclist/vehicle interaction more so given the lack of implementation at the car-park entrance of road markings reflective of the WA Road Traffic Code 2000. I do however question the implication that the PSP is an “essential part of the local footpath network” and would be interested in seeing the statistics, which suggest high pedestrian use of the PSP to support this statement. If the statistical data is lacking then really the question needs to be addressed as to the veracity of the claim and hence whether the emphasis shouldn’t be on focusing on developing a higher standard cyclist commuter path given the importance of the PSP to commuting to the City and return.
  7. Referring to Recommendation 5 – “Think 20”. I support this recommendation.
  8. Referring to Recommendation 6 – “Non-motorised User Audits”. I support this recommendation and encourage the Council to make the audits public.
  9. Referring to Recommendation 7 – “ State Government Consultation.” I support this recommendation.
  10. Referring to Recommendation 8 – “Local Area Traffic Management”. I support this recommendation.
  11. Referring to Recommendation 10 – “Funding”. I support this recommendation.
  12. Referring to Recommendation 11 – “End of Trip facilities”. I support this recommendation.
  13. I also encourage the Council to establish a reference group to engage with the various cycling groups and members of the cycling public. A starting point could be the approach currently being undertaken by the City of Fremantle with the establishment of a Fremantle Bicycle User Group (BUG). Such a group can provide a means of inputting into the Council on cycling matters. However such a group should ensure proper representation of all cyclists; an approach now reflective in the Strategy.
  14. I encourage the Council to reflect carefully on the narrow focus of the Strategy put forward and to consult more widely as it does appear to reflect the biases of the author and as per my opening statement has a discriminatory tone to it. I would hope that the Council adopts a more inclusive approach to the development of an integrated cycling strategy.
  15. I note the strong focus on cycling on paths in the strategy and remind the Council that there are significant corridors of on-road cycling within the municipality and some focus on these issues also needs to be addressed in the Strategy, e.g., development of cycling space on roads for example.
  16. Finally I encourage the Council to review its strategy in line with the National Cycling Strategy 2011-2016 and ensure where appropriate it puts in place action plans to meet the National Cycling Strategy at the local level. Currently the draft Strategy appears to have minimal reference or integration with the National Cycling Strategy.

In closing I again thank you for the opportunity to make a submission and I look forward to the City of Stirling progressing in a positive manner its focus on cycling at all levels.

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