Comments on draft UDOT Statewide Pedestrian and Bicycle Plan - November 2000 from Bob Bayn, North Logan, UT December 3, 2000 The November 2000 draft of the Statewide Pedestrian and Bicycle Plan has lots of good features and a few troublesome ones. Even though there are more good features, I will go into more detail about the troublesome ones. Good Features: Its name puts pedestrians first, because most everyone is a pedestrian but only a relatively few of us are bicyclists. That priority is carried through the document with few exceptions. It is also recognized that pedestrians and bicyclists most often need different facilities, since a cyclist is a vehicle operator and not a rolling pedestrian. So, we read of "pedestrian facilities and biking facilities" rather than of "pedestrian and biking facilities" as if the same facility should serve both user groups well. The plan recognizes the fact that pedestrian facilities (primarily sidewalks and crosswalks) suffer when the walkway network has gaps or poor maintenance. A walking route is much less useful if even a small part of the walkway is missing. Completing the missing segment gives the pre-existing portions greater value. The plan recognizes that cyclists should be expected and permitted on any roadway (save for urban limited access highways) with the rights and duties of the operator of a vehicle. The plan generally uses the terms "bike path," "bike lane" and "bike route" to describe those facilities rather than the non-descriptive labels of "Class I," "Class II" and "Class III." Because of their lack of descriptive value, those "Class" terms are becoming less common in the bikeway literature. The plan recommends some state law changes which are consistent with the current recommendations of the model Uniform Vehicle Code and with traffic engineering principles. The plan recognizes the "4 - E's" Engineering, Education, Encouragement and Enforcement (page 2 of Introduction) even though it admits that UDOT is only responsible for the first one. Troublesome Features: The discussion of the current mandatory side-path law (UCA 41-6-87) suggests that skilled cyclists prefer using the roadway while casual cyclists are safer on a side-path. All of the safety training programs that I have encountered, along with all of the safety research that I have found, indicate that a side-path is not generally safer for any bicycle rider, no matter what level of expertise. The conflicts created on side-paths are not primarily those of "mixing skilled cyclists with casual cyclists and pedestrians" but of sending cyclists of any skill level into roadway traffic at unexpected locations (crosswalks and driveways) and speeds (faster than pedestrians). Side-paths may provide some "comfort" or "perception of safety" but they actually create additional hazards that pose greater risks, especially for the untrained bicycle rider. The plan should acknowledge these results of transportation safety research and the application of those results in the variety of bicycle safety programs. For a well-documented synopsis of this view see Paul Schimek's "Dilemmas of Bicycle Planning" ( http://members.nbci.com/_XMCM/pschimek/dilemmas.htm ). The plan needs to distinguish bike paths (and MUPs) that follow a non-motorized route from side-paths that are in a sidewalk location along the sides of roadways. The non-motorized routes can provide a useful shortcut or a pleasant line of travel through a greenbelt. But a side-path is always (as a design standard) a poor substitute for the legal, and generally safe, accommodation of cyclists on the adjacent roadway. The AASHTO 1999 guide for bike facilities has a variety of cautions about side-path situations which collectively amount to a condemnation of that sort of facility. Our plan should emphasize those cautions and the safety problems that they address. At about the same point in the plan (page 14) the completely unsubstantiated claim is made that bicycle lanes "can improve the safety of bicyclists by reducing conflicts at intersections." I have never before seen the plan's argument proposed in favor of bike lanes but I have repeatedly seen the contrary argument that bike lanes direct bike riders into the WRONG position at intersections or arbitrarily specify some point at which the bicyclist should switch from channelization by speed (slower traffic to the right) to channelization by direction (left turning traffic nearest the center, right turning traffic nearest the curb) without regard to how varying traffic conditions might affect the location of that switch. The rather lengthy section about helmet use (pages 7-8) suffers from a one-sided presentation of the risks of cycling bare-headed, the value of a helmet, and the effect of helmet legislation on the incidence of injury. I've been a helmeted bicycle rider for more than 20 years. If you have a helmet, it makes sense to keep it with your bike. While riding your bike, your head is the most convenient place to keep your helmet. I have a helmet that I wore for 13 years. It didn't save me from any injury. But understanding how to handle my bike, and understanding that the rules of the road I learned in Drivers Ed applied to my cycling, probably did save me from a variety of cycling injuries. That is where the "Education and Safety" section of the plan should place its emphasis. The oft quoted 85-88 percent reduction in head injuries (NHTSA, 1996) should at least be accompanied by the follow-up research that demonstrated that the same analysis of the same data set yields the comparable conclusion that helmet wearing is associated with a 70% reduction of injuries to the rest of the body. ( http://ourworld.compuserve.com/homepages/quinze/ digest/cy_helm2.htm ) Clearly, a helmet cannot prevent broken legs, arms and collarbones so it is easy to see that the helmet may not be the sole cause of the reported difference in head injury rate among helmet wearers. It has also been reported in Great Britain that cycling, as it is currently practiced with a relatively low percentage of helmet use, confers an overall health benefit that is 20 times as great as the added risk. Putting styrofoam around the heads of cyclists (easily accomplished in principle by passing a law) may not be nearly as beneficial to the cycling public as putting the correct training and safety facts inside of those same heads (something that is "outside the mission of UDOT"). The level of training of bicyclists brings us to the next troublesome feature, adopted from federal guidelines. NHTSA has promoted the notion of A (advanced) versus B/C (basic adult and child) cyclists. They estimate a hundred million bicycles in the country, but fewer than five million A cyclists. "A" cyclists are characterized as an elite minority, while B/C are the clueless masses who can't figure out how to ride without getting hurt or are too paralyzed by fear to ride without special considerations. We have the same dichotomy with motorists. However, our public policy chooses to believe that a 5-week Drivers Ed course or a few training sessions with pa on some farm roads or a parking lot, followed by a multiple choice exam and a parallel parking test, will make the average (B/C) 16 year old into an "A" driver, ready to use the streets, left turn only lanes, right turn on red, acceleration lanes, SPUIs, etc. in a multi-ton car or truck with manual or automatic transmission. Why do we believe that anybody can safely drive a car but only a few can safely ride a bike on our roads? Based on my experiences as an "A" cyclist, and as a bicycle safety instructor for the League of American Bicyclists, I would suggest that the "A" designation is easily obtainable by most people who would like to ride a bike. The elitist secret is simply that following the rules of the road is the safest way to arrive alive in a car or on a bike. We should consider the B/C designation as the very temporary status of people who are learning to become competent (A) cyclists, with some simple, but widespread education, awareness and encouragement programs replacing the current mythology of fear. The NHTSA's 5% "A" and 95% B/C model is a fiction promoted by those who make their living designing, talking municipalities into, and building elaborate bicycle facilities that do not provide either effective transportation opportunities or improved safety for people on bicycles. That fiction is abetted by the popular myth that the car behind presents the greatest danger to a bicyclist. In fact, the car ahead about to cross the path of the cyclist is the greatest hazard. The risk associated with that hazard can be minimized by riding where that motorist is already looking for conflicting traffic. That's not on the side-path (a.k.a. sidewalk) where it crosses an intersection or driveway, nor on the wrong side of the road, nor in the gutter. That concludes my major conceptual concerns with the plan. To a certain extent, some of these concerns have already been acknowledged in the plan, but the focus of the document remains aligned with the notion that misinformed cyclists should be accommodated with special facilities that address, but do not correct, their fears and misunderstandings. Specific comments, complaints and suggestions about topics and wording in the text follow: Page 6: Make it clear that 4.1 deaths per million is an annual rate. It would also be useful to place that in the context of the death rate for other voluntary activities (e.g. http://www.magma.ca/~ocbc/comparat.html ). Page 7: A reference is made to helmet use for motorcyclists and the head injury rate but there is no indication of how that information is relevant. Does this lead the reader to an unsubstantiated conclusion? Some horseback riding organizations require helmets at their shows and competitions ( http://www.horse-country.com/safety3.html ). They specify that a bicycle helmet is inadequate protection. That might suggest to some that we should mandate helmets for horseback riders before we consider the same for cyclists. Page 11: "...how much demand would increase if good facilities were available..." Do good facilities create demand or might they increase participation? I think demand is created somewhere else. This section also indicates that B/C riders need facilities but says nothing about their need for education. Page 12: (near the bottom) Some recommendations of the National Biking and Walking Study are "outside the mission of UDOT." So what? Is this a UDOT P/B Plan or a State Plan? How will UDOT "support other agencies?" Do other agencies even know there is a "state" plan that calls them to address these issues? Does the Department of Education know about this? They help out with Drivers Ed programs, maybe they should know this plan has uncovered a need for a "Transportation Ed" program. Page 13: What can we do to make the Transportation Enhancement program better meet local needs for sidewalk improvements? ISTEA and TEA-21 basically force local governments to plan for motor vehicle needs, why not force the issues for pedestrian needs, too? Page 14: This is where the side-path safety misunderstanding begins and the unsubstantiated bike lane safety claims are made as well. At the bottom of the page appears the AASHTO recommendation against using sidewalks as bike facilities. Recognize that a side-path is a sidewalk and suffers from the same hazards whenever a side-path cyclist crosses a driveway or crosswalk or switches between path and roadway. Page 18: Here is where the 20:1 health benefits of cycling should be mentioned (British Medical Association, 1992). Page 25: "UDOT has adopted the AASHTO Guide..." Please believe what the AASHTO Guide says about the inappropriateness of side-paths. Page 31: The CMPO established a "Pedestrian Bicycle Advisory Committee" We followed UDOT's lead and put pedestrians first, and the committee was not formed solely to be advisory on the development of the plan. Page 32: Add a mention that the Logan Transit District has bike racks on all busses and has for several years. They are well used, especially to get bikes up Old Main Hill from downtown. Page 33: The observation that pedestrians are not organized for advocacy like cyclists are includes a reference to the Bicycle Federation of American, as if that were a membership organization for advocates. It is not. It is a consulting firm that makes its way by promoting the development of funding opportunities for bicycle facilities. It has no education program for cyclists. Page 40: I'd surely like to know which "only 7" states still have a side-path law because my research shows at least ten ( http://cc.usu.edu/~bob/bike/law/other_states.html ). That's not to say that we shouldn't get rid of Utah's side-path law. I hope that happens in the 2001 legislative session. Page 41: It is the legal, engineering definition of "roadway" that excludes shoulders and sidewalks. Part Two: Page 45: A.02 - "consider ... needs ... and ...potential ...by providing sidewalks and crossings" Where? At every intersection? Along every (non limited access) roadway? It's this sort of waffling that gives us a complete roadway network and an incomplete walkway network. Page 45: A.03: - "efforts should be made ... to avoid discontinuous sections of sidewalk." Great! If those efforts are effective. How should this policy be implemented for good effect? Page 45: A.05: Sidewalks are preferred on both sides of the road. Good. That's sort of like accommodating vehicular traffic in both directions, isn't it? What about safe crossings? Should we have some other warrant for pedestrian overpasses besides a tragic death and the subsequent clamor from regular users and their parents? Page 46: A.06: - "Option" - Distinguish between bicycles on sidewalks and bicycle-riding on sidewalks. If prohibitions are necessary, they should prohibit the action (riding) not the device (bicycle). Page 46: A.07: - What is the legal basis for requiring bike riders to dismount and walk their bikes when using a posted crosswalk? This may well be a good idea but I haven't seen any basis in our current state law which provides for such a restriction. USU has this sort of prohibition stenciled on the sidewalk at crosswalks, and I don't believe it can be enforced. I have never heard of the term "three-point turn" being used to refer to a "pedestrian-style" left turn for bicyclists. A three-point turn is how a motorist makes a U-turn on a narrow roadway. Page 47: B.03 - Here is where it would be useful to distinguish "side-paths" from paths that follow routes away from highway corridors. Class III Routes are not equivalent to wide curb lanes and neither is a subset of the other. This is also a section where the "Class" designations should be replaced by the named designations, as is correctly done later in C.10. Page 48: B.05 - contra-flow bike LANES should be prohibited without exception. Contra-flow bike PATHS in a highway corridor (i.e. side-paths) should be prohibited unless it is made impossible for a cyclist to shift from the PATH to the wrong side of the roadway, or to cross a roadway or driveway. Page 48: B.06: I need a diagram to see if this is as bad as it sounds. I think this means, if you build a hazardous configuration, do all you can to keep users from getting hurt on it. Maybe these are situations where education works better than engineering, and attempts to make a facility will attract users who aren't prepared to protect themselves from the hazards. Page 48: B.07: All induction loops should be bike-sensitive by design. Since bikes are allowed on all roads, one loop design should be used everywhere. Then, additions to bike route designations won't require reinstallation of loops and bad loop configurations won't prevent an otherwise suitable bike route designation. Page 48: C.01: The reasoning is right but the conclusion is wrong. For these reasons, a shared use side-path should not be a part of urban corridor design. Then maybe once or twice in the life of this plan someone will justify an extremely unusual case where a design exception should be made. "...Carefully considered ... " just isn't a strong enough denouncement of the side-path design. Page 48: C.02: - If the shared use path is in the highway corridor, it is not safer for the B/C masses while the "A" cyclists use the roadway. If the shared use path is away from the highway corridor, it may well be a useful shortcut for "A" cyclists, too. Page 50: C.09: - Contra-flow Paths adjacent to motorized travel lanes just shouldn't be there - except as a rare design exception with barriers to prevent bike riders from becoming wrong way cyclists on the roadway, or from becoming surprises at intersections and driveways. The "preferred method" is not 5 feet of separation; the preferred is DON'T DO IT. Five feet of separation is just an occasionally tolerable design exception. Page 50: C.10: - Yuck. The plan just describes the preferred way to make a mistake. If a two way path is adjacent to a roadway, it's beginning and ending and all points of access and departure should be away from that roadway. That is the only way to insure that untrained, misinformed riders will not switch to the wrong side of the road. Use the project money on education instead. Page 50: C.11: - what is a "sharp right angle turn?" Is a sharp turn OK if it isn't a right angle? Page 51: - What is a "corridor?" Is it bigger than the highway right-of-way? Can a UDOT transportation corridor have a path that isn't a side-path? Page 55: Widen pavement at Railroad Crossings. Good! Especially at non perpendicular crossings, like Logan's 600 West at about 800N. A paved shoulder bulbout would allow cyclists to cross the tracks at right angles without swerving into the path of motorized traffic. Here's a spot where a "bike lane" stripe could give guidance to cyclists who haven't had training or a previous bad experience with an angled railroad crossing. Page 67: C. All induction loops should be bike-sensitive. Use of a Pedestrian call button by a cyclist puts the cyclist in an unsafe lane position to go straight through the intersection. If cyclists must use the pedestrian call button, then motorists should as well. Induction loops should work for all roadway users. Appendix A - Definitions Bicyclist - someone riding a nonmotorized bicycle. This is redundant because a bicycle is already defined as nonmotorized. Class II Shared Use Path - Class II is an on-road lane. Where'd this come from? Later on is a definition for Shared Use Path (Class I Path). Helmet - "...from impact during a crash." How about just "from impact" since helmets provide better protection during a fall than during a crash. Sidewalk - says nothing about its location relative to the roadway or other transportation facilities. How does this compare with the definition in State Law?