Dear Ms Hassell,

Ref: Regulation 28: Report on prevention on future deaths (1) following the inquest touching the death of Francis Nelson Golding

I write in response to the Regulation 28-Report to Prevent Future Deaths that you served on London Borough of Camden, dated 14th April 2014, following the inquest into the death of Francis Nelson Golding. We note that the conclusion of the inquest was “road traffic collision”.

I was very sorry to hear of the death of Mr Golding and of the circumstances leading to his death.

Road safety, particularly that of vulnerable road users such as pedestrians and cyclists, is a strong priority in Camden and our transport investment programme. The Camden Transport Strategy (CTS) places pedestrians and cyclists at the top of the road user hierarchy and road safety is a priority of this strategy.

Please treat this letter as Camden’s written response to your Report and in particular our response to your concerns, including that the location of Vernon Place / Southampton Row would benefit from early consideration.

Although your concerns relate to a single junction, I have taken this opportunity to explain how the Council sets its priorities for investment across the borough and the process involved in delivering significant and transformational change. I hope this context will be useful not just in this case but in general. If anything in this response is unclear please feel free to contact , Camden’s Assistant Director for Environment and Transport, who will be able to help further.

Policy context Camden is responsible for approximately 286km or 89% of the total road network in the borough that vary from quiet residential roads to the very busy central London streets such as those around Holborn. It is necessary to have a solid policy basis and then an evidence led approach to optimise the value of investment. Camden ensures that it maximises the

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value of the capital programme of road improvements by working with a number of partners, and gaining developer contributions to assist in improving our streets. The CTS sets out Camden’s overall transport strategy for the borough for a 20 year period (until 2031), a copy of which is available on the Council’s website at

implementation-plan.en. The CTS also forms Camden’s Local Implementation Plan (LIP), as required by the Greater London Authority Act 1999. The focus of the CTS is on making travel and transport in the borough as sustainable, healthy and safe as possible. To that end it includes objectives, targets and policies to help guide a programme of investment, which includes capital projects (making physical changes on street) and revenue expenditure (training, education and awareness). The scale of Camden’s ambition in terms of what we would want to see delivered across the borough in terms of improvements to transport is unfortunately not matched by the level of funding available. It is therefore necessary to take a long term strategic approach to developing the programme of investment and prioritise the funding so that it is directed to the areas of greatest need.

The areas of greatest need are identified through consideration and analysis of a range of data, including casualty data. This results in a rolling three year programme of investment, which is updated annually and extensively reviewed every three years in order to take account of and respond to changing context and emerging trends and patterns in things such as safety and travel behaviour.

In general the intensity of demand from all types of road users in the south of the borough – a busy part of central London that is experiencing significant growth – means that there are more opportunities for collisions and therefore more pressure to optimise designs to minimise risk. It is no surprise that the borough’s investment programme concentrates on areas south of the borough as they are more intensely used. As part of this the entire Holborn gyratory had already been identified for an Area Based Scheme to look at how improvements could be made to deliver a safer and more fitting road environment. Casualty statistics played a strong role in this.

Collision statistics As part of Camden’s approach to improving road safety, officers undertake a robust analysis of casualty data for the whole borough, to identify those locations (corridors and neighbourhoods) with the highest number of KSI (killed and seriously injured) over the most recent three year period. This analysis includes looking at a level of detail that will enable officers to identify patterns or common issues, such as being a ‘left hook’ issue or all collisions occurring at a particular time of day (light or dark). This is the standard industry approach and is considered a sufficient period of time to pick up trends and identify areas of concern, not least to reflect that as traffic and vehicle movement patterns change over time, situations can be very different from longer periods ago.

Officers have analysed the collision statistics (Stats 19 data provided by the Police) for this location and this shows that there have been 24 recorded injury collisions at the junction of Vernon Place, Southampton Row and Theobalds Road in the three years to October 2013, prior to the incident involving Mr Golding. Of these collisions, four were classed as serious and resulted in injury to five people (two pedestrians, one cyclist and one passenger on bus/coach and one driver were seriously injured), the remainder recorded as resulting in slight injury. There were no fatal collisions recorded during this three year period.

Of the 24 collisions, nine involved injury to cyclists, although none occurred on the northwest corner of this junction, and none involved left turning vehicles. One of the nine involved serious injury to a cyclist, which resulted from a cyclist who did not comply with

traffic signals and collided with another cyclist. The remaining eight resulted in slight injury to cyclists; of these one involved a pedestrian who ran into the road and into the path of a cyclist, four involved a vehicle driving too close to a cyclist and struck the cyclist from behind, one involved a cyclist who disobeyed traffic signals and collided with a car, one involved a cyclist who went into the back of another cyclist. One involved a vehicle who struck a cyclist whilst trying to overtake it, and the final one involved a cyclist who turned into the path of a vehicle. Examination of the collision data on all 24 collisions at this junction shows no consistent pattern.

In relation to the ten year data that was referred to in the report and at the inquest this shows that, prior to the collision involving Mr Golding, there were two other collisions which resulted in the death of two cyclists. The previous fatal collisions occurred in 2008 and
2009. Of those two fatalities one involved a cyclist in collision with a left turning vehicle. As the investigation into the circumstances leading to the collision did not result in any recommendations put forward by the Police, officers did not need to take any immediate action. However following a study on the Bloomsbury Way / Theobald’s Road corridor that was undertaken in 2011 officers did make recommendations to address collisions and these measures, laying anti-skid material across the junction, were completed in 2012. Casualty statistics relate to the intensity of use of a location, with more users meaning that there are more opportunities for collisions. However, to make real improvements requires the identification of a pattern that can be addressed. Where that is the case, action is more directed and more effective.

Details of action taken or proposed to be taken It states in the Prevention of Future Deaths report that you believe that action should be taken to prevent future deaths and that Camden has the power to take such action, but it is not clear from the report what specific action you expect Camden to take. However, from the content of the report we have taken the action to be early consideration of the Vernon Place / Southampton Row junction for improvement.

As stated in the Council’s evidence provided to the inquest, following the incident on 5 November 2013 a site meeting was held on 26th November and was attended by the Council and the Metropolitan Police. There were no significant issues identified with the layout of the junction that contributed to the incident on 5 November 2013 and no further actions were recommended by the Police. If the Police had identified any action to be taken this would have been prioritised by the Council and implemented at the earliest opportunity.

The report states that this junction leaves cyclists particularly vulnerable. As noted above, this location is a constrained central London location and the demand from motor traffic, cyclists and pedestrians is high and competing for limited space. The Council is legally obliged to consider all of these demands and provide arrangements and facilities that best balance these competing uses.

The road network in Camden is large and complex with a number of different demands and it is necessary for Camden to take a strategic view of that network when implementing change and developing proposals. Implementing changes to any signal junction on the central London network impacts upon the wider area, and the result is that no significant change at any one location can or should be considered in isolation. Furthermore, the introduction of such changes is not solely within the control of Camden as it would require working closely with and approval from TfL, particularly in relation to what the wider impacts would be. I explain the different roles of each authority below.

Where it is possible for Camden to implement changes we do so. One of the most recent examples, which is also referred to in the report, is allowing cyclists to use the contra-flow bus lane on Bloomsbury Way. When the bus priority scheme was first implemented, in 2009, cyclists were not permitted to use the contra-flow bus lane as, due to lack of road space and issues with junction capacity, the bus lane could not be widened to safely accommodate cyclists passing buses. This resulted in cyclists travelling west having to use the Holborn gyratory via Drake Street, Proctor Street and High Holborn to re-join the corridor at New Oxford Street, which has been raised as a concern by cyclists.

In response to these concerns officers undertook site visits and commissioned an independent safety assessment of the two routes, which also involved representatives of Camden Cycling Campaign (CCC). The assessment concluded that that the existing route via High Holborn / Procter Street placed cyclists at greater risk when compared to the contra-flow bus lane on Bloomsbury Way corridor. Although there were hazards associated with the contra-flow bus lane, it was accepted that they present less of a risk than the existing route. The findings of the assessment were discussed with the Police to reach agreement of how the findings of the report could be implemented whilst addressing the continued safety concerns regarding the width of the carriageway and cyclists overtaking buses at bus stops. A series of bollards were therefore placed just prior to the two bus stops, with additional other measures like signing and a clear box junction. It was agreed that with these measures in place the ban on cyclists could be lifted and this was implemented under an experimental order which came into effect on 31 January 2014.

I include this example within the Council’s response not only to demonstrate that Camden does take action where possible, but also to illustrate that there is often not a straightforward solution to issues that addresses all concerns. When this is the case we take a considered and informed decision in relation to the best course of action taking into account all of the available information and evidence.

Roles of the borough and TfL By law the Council is responsible for the creation, maintenance, improvement and stopping up of the highway. The Council is therefore the traffic and highway authority for Southampton Row and Vernon Place. However the operation of signals across London is the responsibility of TfL, as Traffic Signal Authority, and any changes that a London Borough wants to make to signals on their road network needs to be agreed and implemented by TfL.

In addition, under the Traffic Management Act (TMA) 2004, both Camden and TfL have a Network Management Duty to manage their road network with a view to achieving, so far as may be reasonably practicable having regard to their other obligations, policies and objectives, the following objectives— (a) securing the expeditious movement of traffic on the authority's road network; and (b) facilitating the expeditious movement of traffic on road networks for which another authority is the traffic authority. (note that “traffic” in the Duty is taken to include pedestrians).

Therefore, although Camden seeks to provide the best facilities for pedestrians and cyclists, it does need to take into account its responsibility under the TMA. Additional traffic queues need to be considered sensitively because it can result in safety concerns as, for example, road users may then take risks if they have to wait a longer period at junctions.

The TMA also provides for the designation of strategic roads in London. Boroughs remain the highway authority for these roads but they need to seek the consent of TfL to carry out highway works that might affect a strategic road. Southampton Row is part of the Strategic

Road Network (‘SRN’). Therefore any changes proposed which has an impact on the TLRN or SRN requires approval from Transport for London and they have the power of veto on this.

This interaction of powers and responsibilities, along with the potential safety impacts of action at any one location, mean that investigating and planning for such change needs to be considered jointly and carefully.

Holborn Area Based Scheme The Holborn area based scheme was already part of our work programme before Mr Golding’s death, driven in significant part by concerns for cyclist safety across the area. Funding had been allocated to develop options for transformative change in the area and deliver significant improvements for pedestrians and cyclists. A scheme of this scale and complexity will necessarily take a significant amount of time to complete in order to understand the wider impacts. Those impacts are not only about delays and congestion but in themselves can have safety implications at other sites, so it is right and proper that we consider matters in this wider holistic way.

Officers have been working with the CCC to develop a strategy for the area and have also begun to collect data to inform the development of proposals. To date traffic counts for the whole of the Holborn area based scheme project area, including High Holborn / Theobalds Road / Kingsway / Southampton Row and Clerkenwell Road have been collected. We have also collected cycle count data and pedestrian data within this study area at all junctions. Collision data is already always available to the Council and doesn’t specifically need to be collected.

A brief will be issued to traffic consultants by the end of May 2014 to invite tenders for the next stage of development. Consultants will be commissioned to undertake traffic signal modelling for the whole Holborn area based scheme area, which includes the Southampton Row/Vernon Place junction. Under the current programme it is anticipated that consultants will be appointed in mid June 2014. A range of options will be considered as part of this commission which will explore possibilities to significantly improve facilities for cyclists. This stage of the process is expected to take 9 months.

Once this phase of project development has been completed the options will continue to be discussed with TfL and agreement reached with regard to which option(s) should be taken forward. The proposals would then have to be subject to a public consultation which would include residents, businesses and stakeholders such as the emergency services, CCC and London Buses, to name a few. A decision on the scheme is therefore not likely to be taken until next financial year and implementation will follow, subject to the outcome of the consultation, acquisition of funding from a variety of sources, and coordination with other significant projects in the area. If large scale changes are proposed then we would seek to phase implementation over a number of years.

Release of publication of our response The Council does not object to the release or publication of this response.

I trust that this letter provides you with sufficient information with regard to how Camden will be responding to the report on prevention on future deaths and demonstrates that Camden takes cyclist safety very seriously and will continue to do so.