Submitted by Southwark Cyclists, a cycling promoting and campaigning group of 600 members. This response has been discussed at agreed with the members. It also incorporates some but not all of the ideas of the CTC response which we endorse.
The over-riding objectives are characterised by the lack of robustness in terms of the requirements upon TOCs to facilitate the provision for cyclists. The vagueness of obligation allows plenty of scope for TOCs to ignore the exhortations of this documents and potentially use of some of the many caveats as an excuse to do nothing. What for example is 'unusually high' in terms of costs of provision? Why does the SRA only 'aspire' to see cycling provision in all but the most lightly used stations. Why are there not targets to measure against? Why is the generation of off peak leisure trips only 'believed' to be important? The SRA needs to commission or access some neutral research to quantify current and suppressed demand and set appropriate and measurable targets for provision in line with these findings.
Question 3: Do you agree with the high level description of the facilities required for cyclists to use rail?
A good summary. However, the statement that commuters should use a 2nd cycle or a folding cycle could be contrary to the broader social inclusion objectives stated later in Chapter 4 (p.10). A Brompton for example is around £500. It is not clear why TOCs should refuse to accept the costs of providing public goods (an environment which benefits from the use of public transport) and that the SRA should support this by recommending that individuals shoulder such costs.
The summary fails to identify that under certain circumstances, an integrated cycle and train journey is an alternative to other modal options but one that can be funded at much smaller cost, hence creating savings. For example:
• The potential for journey times to be reduced (compared with walking or use of congested roads) without the need for State funding for other road or rail enhancements
• Reduced congestion on inter-connected public transport services (tube/bus) reducing the need for additional provision
This section lists costs of provision as if they are inevitable and absolute. In fact a number of the supposed costs reflect the lack of adequate and farsighted provision. If the SRA train specification had included requirement for separate bike carriages, the costs such as 'reduction in comfort and accessibility for other passengers' or 'potential safety impacts' would not arise. It is only because there is no provision or provision is shoe-horned in to a small corridor compartment that such difficulties occur. Where the cycles are loaded via a discrete entrances (Cattle tuck/intercity guards van) loading and unloading can be accomplished as quickly as passenger disembarkation. In any case, it could be argued that the real safety issues arise from the overcrowding which is due to numbers of trains not cyclists.
The business case methodology is extremely opaque. The calculation used to produce the results is not clear at all and thus does not generate confidence. In any case, it does not incorporate all the benefits and over-attribute costs so it needs to be re-calibrated.
The emphasis on working with local authorities is very welcome. The policy on provision within stations needs expanding (to be considered with question 3) to encourage the modification of steps /bridges between platforms so that bikes can be wheeled up. This is particularly important for the encouragement of leisure cycling as carrying fully loaded bikes up and down stairs can be difficult and dangerous (Lifts are an alternative although not feasible in many instances).
Question 8: Do you believe that the SRA should work towards the provision of cycle parking at all but the most lightly used stations or where the costs of provision are unusually high.
The SRA should encourage provision at all stations although clearly the number required will vary according to station usage. To fail to make any provision at all even in the most lightly used stations may act as a barrier to those considering cycling and thus is in contradiction to the general presumption that cycling should be encouraged
Question 9: Do you agree that the SRA should not specify a fixed number of spaces to provided because the appropriate number will depend on local demand?
Yes. However, TOCs should be required to audit the number of bicycles stored within the stations to monitor the adequacy of provision. At Waterloo, one of Southwark Cyclists local hub stations, provision is hopelessly inadequate. Bikes are locked up two abreast and then onto any accessible railings. The SRA should define what constitutes 'evidence of frequently unmet demand' (p15)
TOCs may wish to consider yearly bike audits to remover bikes which have been effectively dumped. All bikes could be labelled with information on the forthcoming clear-out. Any bikes still left with labels after the elapsed warning time (say 1 month) could be given to charity.
Question 10: Do you agree that station operators should be free to charge for the use of cycle parking facilities where there is a specific reason to do so?
All stations should provide basic cycle provision which should include undercover provision for free. It is reasonable for TOCs to charge for premium services such as cycle lockers but the SRA should clearly specify what constitutes a premium service and ensure that it is provided as a supplement not as a substitute for open access parking facilities.
Question 11: Should a charge be made for the carriage of cycles and if so, in what circumstances?
This section does not ask for comments on the general statement of policy which is flawed in several ways. Point One states that TOCs should consider whether cycle space could be economically provided when buying or refurbishing trains. As is shown by the business case, the benefits of cycling provision are considered not just in terms of costs/benefits to the TOCs but in terms of the broader public benefits (health, alternative to public transport investment, reduction in congestion etc). It is thus inappropriate that TOCs consider only whether provision can be “economically provided”. Provision should be basic requirement of the franchise, supported by the SRA if necessary.
Point two says that TOCs should decide on the appropriate level of dedicated provision. Further guidance is needed including challenging targets as the TOCs are not responding to current market demand. We have recent experience using SWT services to Dorset and Hampshire. Provision is hopelessly inadequate: we or other cyclists have been turned away all along the route and these are routes which are ideally suited to encourage sustainable tourism. It cannot help but to discourage cycle usage when people are left on the platform for the next train.
The SRA should outline more clearly who should be consulted when setting this level of provision. Which cycle groups? National groups? Their local chapter at point of departure? or terminus? or stations along the way? Given the broad social and environmental objectives of encouraging cycling provision, the DoE and DCMS should also be consulted.
In terms of the substance of Question 11, we believe it is reasonable to make a reservation charge to guarantee a space on the train. This should however cost no more than a seat reservation
Question 12: Should charges for the carriage of cycle be uniform throughout Britain or should operators be free to make charges according to local circumstances?
Charges should reflect the cost of seat reservations and thus could vary to the extent that these vary
Question 13: Should the pre-booking of cycle spaces on trains be mandatory for all journeys?
No. This would limit flexibility and be inappropriate for many off peak short distance journeys. However, in many instances in particular where there is limited space, cyclists will wish to reserve spaces to avoid the kind of uncertainty described above. At present the system is chaotic. SWT does not even have a consistent policy for all its trains.
It should be possible for cycle reservations to be collected from the pre-paid ticket machines in the same way as other tickets. TOCs should also consider ticketing the cycle berths in the same way that seats are allocated.
It should also be mandatory for guards to make all allocated spaces available. Our members report a guard refusing to take cyclists on board, claiming lack of space whilst a second area of cycle provision at the other end of the train was locked and empty (SWT service)
Yes. But is it is not appropriate that cyclists are placed into a hierarchy of users of space which includes disabled passengers. Provision for all these types of users should be guaranteed in the way that provision for cyclists should be guaranteed to respect the dignity and public good of providing for all such passengers. The flexibility should mediate between cyclist space and seats or alternatively disabled spaces and seats.
This section makes no mention of provision for cycles on replacement bus services. These tend to be scheduled at weekends, exactly when the kind of leisure travelling that this policy is encouraging is likely to be higher. By refusing passage, large sections of the network are effectively blocked.
Question 15: Should station operators consider encouraging the provision of commercial cycle hire and repair facilities
Yes but it does not seem to be a core part of the SRA’s remit. Rather local/region sustainable transport and tourism officers should be leading on this
Questions 16-18: What information should train and station operators provide to assist cyclists/What are the most effective channels for disseminating information to cyclists?What are the key issues that cyclist need to know about before they travel?
Information is generally quite clear and the ATOC “Cycling by Train” is useful.
E. Purser, Secretary, Southwark Cyclists. Eleanorpurser@yahoo.co.uk
13th July 2004 (minor amendments 14th August 2004 to improve clarity)