Cycling, motor vehicle safety and type approval
European Cyclists’ Federation
Ceri Woolsgrove [email protected]
ECF gratefully acknoledges financial support from the European Commission.
The information and views set out in this document are those of the author(s) and do not necessarily reflect the official opinion of the
European Union. Neither the European Union institutions and bodies nor any person acting on their behalf may be held responsi ble for
the use which may be made of the information contained therein.
Introduction – why cycling?
Using the Health Economic Assessment Tool (HEAT) for Cycling1, developed by the World Health
Organisation (WHO) it has been estimated that all internal and external benefits of cycling
together, based on current 7.4% of use in Europe, and adding the turnover of related industries,
cycling creates more than €200 billion annually, or more than €400 for every person that lives in
the EU. Most of this comes from the health side, with over €110 billion annually2. There are costs
to cycling that although are far less than the health benefits must be decreased in order to maximise
the overall benefit of cycling; the major cost being loss of life and serious injuries through road
accidents.
More than 30 % of trips made in cars in Europe cover distances of less than 3 km and 50 % are
less than 5 km3 yet 73% of European believe that cycling should benefit from preferential treatment
compared with cars4. This shows clear potential for moving to cycle use, but one of the major
barriers is road safety. Road safety then is an essential part of getting people cycling and of
squeezing the maximum social and public health benefits out of this active form of transport. If we
are to maximise the health and economic benefits of cycling we must increase safety. We have to
reduce the risk and perceived risk if we are to get more people cycling to move from polluting
forms of transport to more sustainable and active modes. Reducing speeds, making lorries safer
and manufacturing motorised vehicles that are fit for use in urban areas where people live, work
and travel is essential to creating liveable cities where people feel comfortable walking and using
a bicycle.
1
http://www.heatwalkingcycling.org/
Figures explained here
http://www.ecf.com/wp-content/uploads/ECF_Economic-benefitsof-cycling-in-EU-27.pdf
3 WALCYING How to enhance Walking and Cycling instead of shorter car trips
and to make these modes safer http://safety.fhwa.dot.gov/ped_bike/docs/walcyng.pdf
4 http://ec.europa.eu/environment/archives/cycling/cycling_en.pdf
2
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Cycling road safety in the EU
Infrastructure development and driver behaviour are important road safety interventions, but
vehicle regulation has an overriding European mandate. It is here that the EU can make a major
difference and move towards the 50% reduction of road fatalities by 2020. There has been an
increase in a number of possible vehicle safety measures, but if the EU wishes to achieve its 50%,
it must look beyond the occupant of the car and concentrate further on pedestrians and cyclists
that make up more than a quarter of all fatalities5.
The number of cyclists being killed and seriously injured is decreasing, but it is decreasing at a
slower rate than for car occupants.
6
A 2012 Netherlands report shows the fall in car fatalities and serious injuries, while cycling fatalities
have stagnated or even, in the case of serious injuries, risen. Although this rise could be partly
explained by a rise in cycling numbers, there has also been a rise in car use but still with a reduction
in casualties. The International Transport Forum (ITF) has shown that in IRTAD countries fatalities
among car occupants were reduced by 50% between 2000 and 2012, whereas decreases were
only 34% for pedestrians, 31% for cyclists and 17% for motorcyclists7.
In the EU vulnerable road users, in urban areas, make up more than two thirds of the fatalities8.
Although cycling fatalities in Europe has made good progress falling around 38% between 2001
and 20109, car occupant fatalities have fallen by 55% (from 27,700 to 12,345) in the same
period10; the fall in cycling fatalities is not keeping pace with other road user modes. Unfortunately
these figures do not take into account distance/time travelled data and so we are unaware of
whether the rise or fall of injury data is due to safety interventions or cycling numbers rising and
falling.
5
http://ec.europa.eu/transport/road_safety/specialist/knowledge/pedestrians/index_en.htm
Netherlands policy document on road safety road safety ministry of infrastructure and the environment 2012
https://www.government.nl/binaries/government/documents/leaflets/2012/11/14/policy-document-roadsafety/policy-document-road-safety.pdf
7 ITF Road Safety annual Report 2014 Summary
http://www.internationaltransportforum.org/pub/pdf/14IrtadReport.pdf
8 http://ec.europa.eu/transport/road_safety/pdf/swd_2014_297.pdf
9 Dakota, Traffic Safety Basic Facts 2012 Cyclists. CARE Database
10 ETSC, Ranking EU Progress on Car Occupant Safety (PIN Flash 27), 2014
6
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However the UK does provide distance travelled figures, which saw almost a 44% drop in car
occupant fatalities per distance travelled from a 2005-2009 average to 2013, while cycling
fatalities only fell 16% between those years. There was a 34% drop in car occupant serious injuries
with a 31% rise in cyclist serious injuries over that same time period11. This trend has shown that
there has generally been an increase in road safety in general and this has been a great European
success story, in particular for motor vehicle safety and for those inside the vehicle; however there
is less success for those outside of the vehicle. In fact as the graph below shows it is in collisions
with motorized vehicles that are major factors in most cycling fatalities.
12
Cycling fatality vehicle collision
General Safety Regulations and Pedestrian Protection
Regulations
The EU leads the world in vehicle technologies thanks to European vehicle manufacturers and
leads the world in vehicle safety thanks to progressively stronger vehicle regulations.The European
commission will during 2017 put forward a legislative proposal to update the General Safety
Regulations and pedestrian protection type approval regulations13. These Regulations provide an
excellent opportunity to update vehicle safety to focus on safety for those outside the vehicle
We have a major opportunity with the technologies currently available to have genuine VRU
specific technologies and designs mandated for all new vehicles. A Transport Research Laboratory
11
UK DfT Reported Road Casualties in Great Britain: 2013 Annual Report 2013
https://www.gov.uk/government/statistics/reported-road-casualties-great-britain-annual-report-2013
12Pedalling towards Safety BIKE, ETSC 2012
13 http://ec.europa.eu/growth/sectors/automotive/safety/index_en.htm
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Cycling, motor vehicle safety and type approval
report14 for the commission which looked at the cost/benefit of potential new technologies that
could be included in the GSR update researched many excellent possible technologies that could
be mandatory for all new vehicles.
Recommended Vehicle Safety Measures to Reduce Cyclist
Casualties
Intelligent Speed Assistance (ISA)
Up to 30% of drivers exceed speed limits on motorways, up to 70% on roads outside built-up areas
and as many as 80% in urban areas, when asked if they ever broke the speed limit only 7% of
drivers replied that they did in urban areas15. Reducing speeds of motor vehicles in urban areas is
crucial in getting more people to use bicycles, not only does this decrease the real danger but it
also decreases the perceived danger that those interested in taking up cycling, feel1617. With
regards to actual safety, results from a study by the Norwegian Institute of Transport Economics
have shown that “…there is a strong statistical association between speed and road safety…it can
be estimated that a 10% reduction in the mean speed of traffic will result in a 37.8% reduction of
the number of fatalities18”. To put this in perspective it was estimated that a 10% reduction in
“Exposure to darkness” and “Drink-driving” gives reductions of only of 1.7% and 1.0% in fatalities
respectively. Enforcement is an extremely difficult operation in budget-stretched administrations,
ISA can help to improve levels of compliance enormously with many trials and studies showing the
beneficial effects of ISA on road safety.
Intelligent Speed Assistance is a range of motor vehicle technologies that assist drivers in choosing
appropriate speeds and complying with speed limits. Drivers receive the same information that
would be seen by the side of the road on traditional road signs through an onboard
communication system, helping them to keep track of the legal speed limit all along their
journey. There is usually an in-vehicle digital road map which has access to the road networks
speed limits which is then combined with a positioning system (e.g. GPS), though some systems
can also use speed sign reading and recognition. The system can then advise speeding drivers to
slow down or even prevent them from accelerating beyond the legal limit. ISA should not be
confused with speed limiters that are currently being used by Heavy Goods Vehicles (HGVs) and
buses which only limit the top speed of the vehicle (100 kmh for buses, 90 kmh for HGVs).
It comes in three forms;
 informing the driver of the limit (advisory ISA),
 warning them when they are driving faster than the limit (warning ISA)
 actively aiding the driver to abide by the limit (assisting ISA)
14
http://bookshop.europa.eu/en/benefit-and-feasibility-of-a-range-of-new-technologies-and-unregulatedmeasures-in-the-field-of-vehicle-occupant-safety-and-protection-of-vulnerable-road-users-pbNB0714108/
15 http://archive.etsc.eu/documents/Intelligent_Speed_Assistance_FAQs_2013.pdf
16 http://www.gov.scot/Publications/1999/10/38560fea-6e19-4098-95cd-37be45958aa8
17 http://www.ncbi.nlm.nih.gov/pmc/articles/PMC1763332/pdf/v058p00837.pdf Morrison D, Thomson H,
Petticrew M. Evaluation of the health effects of a neighbourhood traffic calming scheme. Journal of
Epidemiology and Community Health. 2004;58(10):837-840. doi:10.1136/jech.2003.017509
18 Elvik, R et al (2004) Speed and road accidents: an evaluation of the Power Model
https://www.toi.no/getfile.php/Publikasjoner/T%D8I%20rapporter/2004/740-2004/740-2004.pdf
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The possibility to use at least advisory ISA is a standard fitment in most high end new vehicles
already, as is some kind of top-speed limiting function. The combination of the two of these provide
a crude assisting ISA system and are currently required within EuroNCAP testing to receive a top
star safety rating. However this is not as effective as a fully functioning assisting ISA.
This third ‘assisting’ option can either physically limit the engine from providing the necessary
power to go above the limit, or can provide haptic feedback, for example by making it increasingly
difficult to push down on the accelerator pedal. ECF would support this third option with at least
haptic feedback.
The European Commission published a study19 last year looking at the positive safety benefits of
speed limiters for larger vehicles. We would like to see ISA replacing speed limiters in larger
vehicles as well.
ECF Recommendations –



Move towards full EU wide mapping of speed limits
Mandatory fitment of ISA in HGVs, eventual extension to vans and other large vehicles
Adoption of assisting ISA systems in all motorised vehicles within type approval
Lorries, HGVs, Trucks and Larger Vehicles
According to the European Transport Safety Council, lorries are involved in around 4,200 fatal
accidents in Europe every year. Many of these fatalities, almost 1,00020, are vulnerable road users
such as cyclists and pedestrians. In countries with high rates of cycling, lorries are often the single
biggest threat to cyclists: In Belgium, 43% of cycling fatalities involve larger vehicles 21, in the
Netherlands 38% and in the UK 33%22. In some cities, like London, lorries are responsible for
around 56% of cyclist deaths23. HGVs have a much higher relative danger in urban areas, as
shown below by data based on UK Department for Transport figures;
19
http://ec.europa.eu/transport/road_safety/pdf/vehicles/speed_limitation_evaluation_en.pdf
FKA, Design of a Tractor for Optimised Safety and Fuel Consumption 2011.
21 www.etsc.eu/documents/BIKE_PAL_Safety_Ranking.pdf
22 According to the EU CARE database the ratio of HGV to bus involvement within all type of collisions is
around 5:1, meaning that HGVs are the main contributor
http://ec.europa.eu/transport/road_safety/specialist/statistics/index_en.htm
23http://www.lbhf.gov.uk/Directory/Council_and_Democracy/mgHomepage.asp?mgpage=mgAi.aspx%26amp
%3BID%3D11596
20
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24
2012 data HGV traffic and fatal accidents by road type
The data shows that relative risk of HGVs on minor roads, in and
around urban areas has risen over the past 6 years25 from 352.6%
in 2007 to the 514% of 2011.
2007
352.6%
2008
361.8%
2009
384.3%
2010
427%
2011
387%
2012
514%
Rise of relative risk of HGVs in urban areas
in the UK
Better direct vision26
There have been many studies that have underlined the danger of the current design of HGVs 27
with one of the occurring themes is that of better direct vision. In Europe, unlike with motor cars,
there are no rules guiding what a lorry driver should be able to see directly through the windscreen
(direct vision). Instead European regulation focus on indirect vision, i.e. through mirrors, but while
these are useful, the multitude of mirrors and their often distorted images are no substitute for
decent direct vision. There are problems with indirect vision, a slight mistake in adjusting the mirrors
can leave a large blind spot in the driver’s vision28. A Danish study29 found that of the 25 HGVs
they studied that were involved in collisions with cyclists, 21 had incorrectly adjusted mirrors, 8 of
which were directly related to the collision.
It has been estimated that it takes about a second for a driver to glance into a mirror and then turn
to the next mirror30. So there are three/four main mirrors at the passenger side, one up front, a
look ahead through the windscreen and then the manoeuvre. That’s about 4-6 seconds from
looking in the first mirror to looking in the last and then making the manoeuvre. A lot can happen
in that first mirror in five seconds. This really is another blind spot, a temporal blind spot rather
than a spatial one, but a blind spot none the less. Better direct vision would reduce glance time
and improve cognitive visual appreciation of the environment around the cab.
24
Traffic statistics table TRA0104, Accident statistics Table RAS 30017, both DfT. In
http://www.bettertransport.org.uk/sites/default/files/research-files/HGV_fatal_ax_cf_to_all_2012.pdf
25 ibid
26 http://www.ecf.com/wp-content/uploads/ECF-_-HGV-Vision-_-Directive-9653.pdf
27 http://www.transportenvironment.org/sites/te/files/media/4846_defreportEdB.pdf;
http://www.ecf.com/wp-content/uploads/ECF-_-HGV-Vision-_-Directive-9653.pdf;
http://www.tfl.gov.uk/cdn/static/cms/documents/construction-logistics-and-cyclist-safety-technical-report.pdf;
http://www.transportenvironment.org/publications/ending-lorries-deadly-track-record-matter-direct-vision;
28 Dodd, M. 2009. Follow on study to the heavy goods vehicle blind spot modelling and reconstruction trial.
Published report PPR403
29 Danish Road Accident Investigation Board , 2006, Ulykker mellem højresvingende lastbiler og
igeudkørende cyklister
30 Taoka, 1990, Duration of Drivers’ Glances at Mirrors and Displays
http://www.ite.org/membersonly/itejournal/pdf/JJA90A35.pdf;
Sodhi, M. & Reimer, B., (2002) Glance analysis of driver eye movements to evaluate distraction
http://link.springer.com/article/10.3758%2FBF03195482
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This is relevant also in the work being done with the revision of the Weights and Dimensions
Directive 96/53. Parliament has called for, and which we very much support, better direct vision
and better deflective shape, for lorries and trucks that are allowed a larger cab design for better
aerodynamics. This should also be considered for type approval of all new larger vehicles, in other
words if longer cabs would assist better direct vision (lower seating position for example) this should
be made clear as this process is underway and may clash with possible future recommendations
on direct vision and GSR/type approval. A better deflective shape should also be considered;
again this would be in the context of the work being done on Directive 96/53. Work on this has
been done with the APROSYS project which also looked at the deflective shape of HGV/lorry
fronts31
Underrun Protection
Currently side underrun protection does exist for trucks and trailers, which are used to prevent
cyclists, pedestrians and motorcyclists from falling under the wheels of a truck if they are knocked
to the floor, mainly at a right turn incident. However the legislation in place allows for an ‘open
frame’. We believe that a closed frame would be an excellent update. ETSC have estimated32 that
there could be a reduction by as much as 45% if cycling/pedestrian fatalities in these types of
crashes with trucks and lorries.
A major issue with regards to underrun protection is that many vehicles are exempt from their use.
This includes many tipper, construction, cement lorries etc. These vehicles involved in the
construction industry are often responsible for many of the cycling fatalities; these exemptions need
to be tightened up. Another issue that needs to be cleared up is the exclusion of ‘off road’ vehicles
or ‘special purpose’ vehicles. These are the vehicles that are often doing the most harm, for
example ‘off road’ vehicles are often construction or tipper lorries which are responsible for a many
cycling fatalities. The TRL makes excellent points on this and should be followed up. TRLs work for
TFL on construction lorries and cycling fatalities33.
Position of accidents with HGV and two wheel vehicles
31
http://www.transport-research.info/web/projects/project_details.cfm?id=35419
2001 Priorities for EU Motor Vehicle Design
33 http://www.tfl.gov.uk/cdn/static/cms/documents/construction-logistics-and-cyclist-safety-technical-report.pdf
32
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ECF Recommendation





There seems to be a glaring omission in larger vehicle regulation, there is nothing dealing
with direct vision. We would like to see Direct Vision regulations for new HGV as it is with
other motorised vehicles
Side underrun protection should be closed off so as to stop pedestrians or cyclists being
caught in or through the guard
Exemptions for the use of underrun protection must be tightened up as this often affects
those vehicles that are most likely to be involved in VRU/HGV collisions
Investigations on the possibility of amber side markers on the side of lorries acting as turning
indicators should be undertaken
Work being undertaken in the Commission expert working group on the amendment of
Directive 96/53 Weights and Dimensions of HVs should not be overlooked as issues
concerning direct vision/better deflective shape etc. could be fundamentally related to size
of the cabs.
Detection of VRUs and Automated Braking
By November 2015 all new Heavy Goods Vehicles (HGV) are to be fitted with advanced
emergency braking, however many HGV vehicles will be exempt. However the types of automatic
braking systems that are referenced with this regulation (Regulation 347/2012 and 2007/46) are
not those that are useful in urban scenarios with vulnerable road users. The major cause of
collisions between cyclists and HGVs is the right hand turn over a cyclist (left in Cyprus, Ireland,
Malta and UK). An automatic braking system would very much help avert these kinds of accidents
saving many cyclist and pedestrian lives per year.
Progress is being made with regards to automated sensing and braking/warning for pedestrians
and cyclists34. Though this technology is harder to perfect than with straight ahead vehicle
recognition and braking (cyclists also ride to the side and behind the vehicle unlike pedestrians), it
could be a powerful tool to prevent blind spot and turning accidents with cyclist/motor vehicle
collisions. However targeting a specific collision such as the HGV/truck right hand turn at low
speeds may yield better implementation of this type of technology and it is certainly a technology
that should be encouraged.
34
http://www.volvocars.com/uk/top/about/news-events/pages/default.aspx?itemid=175
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ECF Recommendation

To include cyclist AEB within safety Type Approval regulations. The lead in time for this
should be in line with pedestrian AEB, if the technological is not as ready as it is for
pedestrian AEB funding and research should be prioritised for its development.
Dooring
Dooring is when an occupant ion a parked car opens their door without looking and hits a passing
cyclist. This can result in injuries from hitting the door, but can also lead to deaths by being pushed
into passing traffic. It is difficult to work out the scale or prevalence of these types of crashes,
particularly within Europe but with more and more competition for space at the side of the roads
for car parking, pavement/sidewalks and cycling infrastructure, and the rise in taxi use these
incidents may become more and more prevalent. One of the major problems with collecting data
is that many of these incidents may go unnoticed in a study based on police statistics if these crash
types are not distinguished.
Data we do have is that
 A UK parliamentary question from Stephen Hammond in 2013 showed nearly 600 cyclists
in the UK were injured during 2011 after vehicle doors were opened in their path35 67%
increase in cycle serious injuries due to ‘dooring’ in just 3 years in the UK
 Transport for London claim that dooring was the second most common cause of serious
injury 48 collisions (11%) in 2011 (39 collisions [9%] in 2010; 35 collisions [8%] in 2009)36
 In the US in Chicago37 there were 127 reported dooring crashes in 2010 for a rate of 0.35
doorings per day; making up 7.25% of all reported bike crashes. In 2011, there were 344
reported dooring crashes, for a rate of 0.94 doorings per day; making up 19.7% of all
reported bike crashes. And by 2012, there were 132 reported dooring crashes, for a rate
of 0.55 doorings per day
 In Toronto, "motorist opens door in path of cyclist" collisions were 11.9% of all reported
car/bike collisions in 200338.
 In Victoria, Australia between 2000 and 2010, both police and hospitals reported an
increase in dooring crashes. The police reported 1,088 cyclist-door crashes, with an
increase in these crashes of 125% from 2000 to 2010
 Between 2007 and 2011, 245 cycle dooring injuries were reported in New Zealand, 6%
of all cyclist injuries involving motor vehicles39
35
http://road.cc/content/news/78298-number-cyclists-injured-dooring-incidents-quarter-2009-2011-says-mp
Topic Fact Sheets here http://www.tfl.gov.uk/corporate/publications-and-reports/road-safety
37 http://gridchicago.com/2012/doorings-in-chicago-and-nyc-are-still-a-sorry-state-but-one-of-them-is-doingsomething-about-it/
38 http://en.wikipedia.org/wiki/Door_zone
39 https://blogs.otago.ac.nz/ipru/research/cyclistdooringmap
36
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ECF Recommendation

To explore the possibilities of ‘dooring’ sensors and warnings for new motor vehicles with
a view to including this in cost/benefit and eventually new vehicle type approval. If the
benefits are unknown compared to some other interventions the costs may be extremely
low as well addition of a warning light on the door for example may be the only addition if
a sensor system is already on the vehicle. Bundling this with sensor systems around the car
would be relevant in assessing the cost/benefit of such as system
Passive Safety for cyclists
The conclusion that there are “small numbers of pelvis and upper leg injuries caused through
pedestrian accidents with modern cars” should take into account the continued growth of
SUVs/4x4s/LTVs type vehicles. They are becoming a great deal more and more popular40 in many
European countries and they typically result in impacting the upper leg and pelvis as well as worse
ground-related injuries for VRUs as being flung up in the air and landing heavily on the ground.
Within current type approval testing procedures there is the assumption that cyclist and pedestrians
impact vehicles in the same way; this is not strictly true. Cyclists will hit windscreens and A-pillars
more than pedestrians; they will also be hit at a different part of the leg than pedestrians41. Though
windscreen safety is not seen as the most important aspect of pedestrian safety it is more important
for cyclists and should be included in testing42.
Within current type approval specifications there are testing methods which are only collected for
monitoring purposes including the adult headform to windscreen protection test. These should be
considered for mandatory testing.
ECF Recommendations

ECF has commissioned a research study to be performed by AGU Zurich on passive safety
for cyclists within the context of updates to the Pedestrian Protection Type Approval
regulations, recommendations will be made available on its completion
Autonomous vehicles
The buzzwords in road transport at the moment are autonomous vehicles and driverless cars. The
UK is allowing autonomous vehicle son the roads to experiment we have manufacturers claiming
that these vehicles will be on the roads by 2020. The technologies that are necessary for these
vehicles are all described above. They are essential to the use of autonomous vehicles on the road.
40
http://left-lane.com/european-sales-2014-q3-premium-large-suv-segment/
http://www.acea.be/statistics/tag/category/country-comparison-tool
http://www.beepbeep.ie/stats?sYear[]=2014&sYear[]=2008&sRegType=1&sMonth[]=&sMonth[]=&x=47&y=11
41
Simms, CK. and DP. Wood, Pedestrian and Cyclist Impact – a Biomechanical Perspective. 2009: Springer
42
http://tcdlocalportal.tcd.ie/pls/public/staff.detail?p_unit=mechanical_engineering&p_name=csimms
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The hype surrounding these vehicles is currently at fever pitch, this is good news as it means that
the technologies that we have been advocating in this paper and elsewhere (the TRL report for
example) are virtually ready. ISA is an absolute necessity for autonomous vehicles, it is also one of
the technologies that is the most mature. This all bodes well for implementation and mandating
for the introduction of these technologies in all new vehicles. Lead in times should also be short
since the industry as a whole is actively moving towards this future vision of driverless cars.
Comments on Cost Benefit
Wider social externalities
It should be important to mention aspects that are not so easy to define within a traditional road
Cost/Benefit analysis within the remit of traditional transport road safety. For example the benefits
associated with a rise in quality of life in areas that see lower speeds, or the increased
health/air/congestion benefits in the shift to active modes of transport with safer, calmer traffic, or
the decrease in carbon/particulate emissions that road safety measure like lower speeds/safer
HGVs can bring.
With regards to cycling specifically if safer vehicles, calmer roads, lower speeds (through ISA for
example) can lead to increased cycling there are a whole host of wider social benefits that could
be taken into account. ECF has tried to quantify many of these43 with regards to an increase in
cycling and though they may be difficult to shoehorn into a traditional road safety CBA there could
be at least the inclusion of these elements as qualitative caveats or guidance.
Future trends
The level of urbanisation is expected to rise to 82% by 205044 this will mean increased demand
for goods, services and building works in our cities. HGVs/lorries and trucks of all types will
become a more common vehicle in our cities. We have to make these vehicles fit for purpose to
be allowed in urban areas, with the rise in these vehicles mentioned as something that may affect
cost/benefit calculations. As will the increase in cycling, the future may mean more exposure
between these two vehicles, given the higher levels of risk that HGVs pose for cyclists this should
also be taken into account.
Bundling costs and benefits
It should be mentioned in the report that there would be considerable leeway and margins for
improved benefits and reduced costs if they were bundles together.
If sets of technologies were bundled together (sensing technologies with automatic braking or with
‘dooring’ warning systems for example) this would dramatically improve inclusion of the
technology. Costs would be spread across different technologies, and different technologies would
assist each other in reducing various accident types.
43
www.ecf.com/wp-content/uploads/ECF_Economic-benefits-of-cycling-in-EU-27.pdf and
http://www.ecf.com/advocary/bicycle-economics.
44
http://ec.europa.eu/transport/themes/urban/doc/ump/swd(2013)524-communication.pdf
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