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EFTAG response to draft Cycling Action Plan

Epping Forest Transport Action Group

Essex Cycling Strategy Leader
Highways, Ringway Jacobs
Essex County Council
Victoria House
101-105 Victoria Road
Chelmsford CM1 1JR

6 September 2017

Epping Forest Cycling Action Plan — response to draft plan


Epping Forest Transport Action Group (EFTAG) campaigns for better public transport and safer streets in Epping Forest. We want safer cycling facilities for all kinds of people on bikes, working with others to promote this healthy, convenient and cost-effective form of transport. We are working for a better cycling environment across the district: for getting to shops, schools or work, as well as for leisure cycling in and around the ancient forest. Routes should be suitable for all ages and abilities, for cargo bikes (for instance parents transporting kids) and for cyclists with disabilities.

The draft referred to here was distributed August 2016 and our copy is available at

1 – Introduction

1-1 Epping Forest Transport Action Group (EFTAG) welcomes Epping Forest District Council’s draft Cycling Action Plan (CAP). Recognition of the potential for cycling – in the district’s economic success, and in the health of its citizens – is long overdue.

1-2 Whilst we do not agree with all of the proposed infrastructure improvements, especially in some of the details, we are confident that this draft plan can be developed into a realistic blueprint for the future, particularly if attention is given to the CAP as and when other highways work is planned and executed.

1-3 It should be made clear that the CAP will be regularly updated (e.g. at least every 3 years) to account for progress made, and to ensure its proposals meet current best practice and national policy.

2 – Policy Review

2.2-1 The Highways Agency (HA) have published recommendations for building cycle infrastructure [HA 2016]: although this is targetted at the strategic road network specifically, these design requirements would be relevant to many rural roads in Essex and could be referenced.

2.2-2 UK government policy is to encourage the introduction of 20mph speed limits [Dept for Transport circular, 2013]. The 2016 TSRGD makes these cheaper to install and we would expect these to be a part of any plan to encourage active travel in the district. This should be referenced.

2.2.2-1 There should be a commitment to develop a Local Cycling and Walking Infrastructure Plan (LCWIP) for Epping Forest, either to complement or to replace the CAP.

2.3-1 The “Regional Policy Context” does not mention the Essex Cycling Strategy (ECS) [Essex County Council 2016]. Reference solely to the 2011 Transport Strategy is (with regards cycling) out of date, as the ECS is (now) a published policy of the Council.

2.3-2 The ECS aspires to “Continental Standard” infrastructure, which is largely absent from the proposals here. Reference should be made to other relevant, and specific, UK standards, such as the London Cycling Design Standards [TfL 2016], in recognition of this ECC policy.

2.3-3 The ECS says that “a cycling design reviewer [should] ensure all cycle infrastructure designs are of appropriate/consistent standard”: the CAP should ensure that all significant highways projects in the district are required to account for cycling, and thus are subject to this review.

3.4 DfT Count Data

3.4-1 In this section, improvements to the A104 in Buckhurst Hill are largely rejected in favour of quiet routes through the forest and then Roebuck Lane / North Farm (schemes 9 and 14.2). Whilst the latter are valuable routes, they do not help with connections to the London Cycle Network in Woodford Green, and make no impact on leisure cycling into the District towards Epping, which undoubtedly contribute to the flows observed and should be encouraged.

3.6 Collision Clusters

3.6-1 With regards collisions in Pyrles Lane / Hillyfields, the existing scheme, which has a large speed table, would appear to demonstrate that the ‘Hackney-style’ / shared-space approach does not work. The junction and adjacent roads is unpleasant for cyclists and often  hard to cross on foot. For a “Quietway” approach to be successful, the number of motor vehicle movements would need to be significantly reduced (i.e. the road would actually have to be quiet, which it clearly is not). It seems very unlikely that any of the roads leading to that junction could be filtered. If mention of the Hackney-style approach is retained here, it would need to be accompanied by clear evidence showing how any such scheme (absent a modal filter to actually affect flows and create a quiet route) has ever improved safety.

3.6-2 TfL-commissioned research [International Cycling Infrastructure Best Practice Study] notes that “key to the success of a bicycle street [Dutch/German ‘Quiet Street’ equivalent] is for traffic speeds and volumes to be relatively low, and cycle volumes to be relatively high”, and that does not seem to be applicable here at all.

3.6-3. We are encouraged by the mention of dedicated space for cycling in this area, but it is important to note that separated space for cycling is most needed at junctions, as this is where most collisions actually occur. Separation on the approach, but not at the junction itself, could offer extremely poor return on investment, i.e. most of the costs of a good cycling scheme, but none of the benefits.

3.6-4 With regards collisions on the A121 High Road, we note that the width of the A121 is for the most part greater than that of Valley Hill/Loughton Way, which is suggested as an alternative. There are certainly good arguments for providing infrastructure on the latter route, but citing lack of carriageway width as a reason that the A121 must be less ‘suitable’ for cycling does not appear to be supported by evidence. Roads through the forest such as this, where addition of cycling infrastructure might reduce speeds but not affect capacity at all, should not be ruled out. In this case, infrastructure could be relevant to several of the Aims (i.e. Connecting employment and town centres, and opportunities for Leisure cycling); Scheme 9 provides a good leisure facility for similar destinations but is not a like-for-like substitute for commuters that want an all-weather direct route.

4.1 Existing cycling infrastructure

4.1-1 The map in figure 4.1 has its legend backwards (for example the signed quiet route to Buckhurst Hill from the top of Goldings Hill in Loughton is described as an ‘off-road’ route, but the off-road cycle track along Rectory Lane in Loughton is, according to the legend, ‘on-road’).

4.1.1 Epping

4.1.1-1 Describing the Epping-Coopersale route as ‘high-quality’, but then listing a number of serious flaws (unlit; variable-quality surface), does not set a sufficiently high standard for the CAP. The facility may be adequate for the current level of usage, but that’s not the point.

4.1.1-2 The cycle lanes along the Epping New Road are probably not in fact “used by confident cyclists”, as they are so narrow and so near the kerb as to be full of detritus. Most confident cyclists, positioning themselves the correct distance from the edge of the carriageway, would in fact be using the main traffic lane. Actually using a cycle lane of that width only encourages motorists to make close passes – section 4.1.2 has better notes on these particular cycle lanes and the two sections could agree with each other better.

4.1.1-3 The CAP’s notes on cycle parking in Epping are excellent.

4.1.2 Loughton, Debden, Chigwell

4.1.2-1 Mention should be made in this section of local schools, and the lack of safe routes for cycling and walking across Debden, a self-contained estate where many school-run journeys should not have to be done by car.

4.1.2-2 The CAP’s notes here are excellent, but there should be a clear action point for the County Council to ensure that future developer-financed improvements (i.e. like the Chigwell Lane work) are never again allowed to ignore the council’s own Cycling Strategy / Transport Policy!

5 Cycling Potential

5-1 Despite ECC’s goal to have a cycle network that “connects key destinations” (1.1), and 1.4.2’s discussion of the Route-Based Strategies (RBS), relatively little attention seems to have been paid in the CAP to longer-distance routes, between towns such as Harlow, Epping and Ongar.

5-2 Although 4.2 calls out the B181 between North Weald and Epping, this important route is then apparently forgotten, with no mention here or in the detailed plans. There is potential to reduce car journeys to/from Epping if safe cycling facilities could be provided.

5-3 There is also the potential to make cycling in the rural areas to the north and west of Epping safer. The character of the area is spoilt by fast driving along roads (like the B181) apparently designed to cater for nothing else. But there is potential for increased cycling into shopping/leisure/transport destinations in Broxbourne, Epping and Harlow.

5-4 We consider it essential that schemes developed under the RBS proposals are well-integrated into the network envisaged by the CAP. Even if the funding and timescales are independent of the rest of the CAP, an outline of possible options should be discussed here.

5.3 MOSAIC Propensity to Cycle

5.3-1 Whilst MOSAIC analysis is useful for prioritisation, it is important not to dismiss population groups that do not cycle given current infrastructure. MOSAIC is based on UK trends, and international evidence suggests that all population groups can cycle, if safe facilities are provided. In the Netherlands, “bicycle use is the same for almost every population group” [Cycling in the Netherlands].

5.3-2 We particularly welcome the CAP’s notes about the potential for cycling to Tube stations, and the positive effect this could have in terms of commuter parking and congestion.

6.2 Proposed Infrastructure Improvements

6.1-1 The ECS goes further than the CAP draft, in that it requires that “cycling is prioritised over motorised transport in all new developments”. They should be consistent.

6.2-1 The proposals here do not make use of a number of useful recent innovations in allowable design provided by the Department for Transport, for example Hybrid cycle tracks [LTN 1/12 4.15] and Parallel Pedestrian & Cycle Crossings (TSRGD 2016 item 53). When specific schemes are taken forward, it is essential that use is made of best practice from the DfT and from neighbouring areas with higher cycling levels such as Cambridgeshire and Greater London.

6.2-2 We consider many of the proposals fail to meet the standards set by the CAP and the ECS, either in terms of route quality (such as being direct enough to form a useful part of a network) or in terms of infrastructure quality (safety and convenience).

6.2-3 We will give our responses for each of the specific areas in further separate documents, when they are ready.

7. Proposed Smarter Travel Measures

7.1.3-1 Schools could be encouraged to develop best-practice travel plans through A ‘safe routes to schools’ policy should be a key component of the CAP, informing many of the route choices and prioritisation, but seems largely missing.