The Department of Transport Perspective on Chichester to Emsworth Shared Pavement NMU Scheme

West Sussex County Council and Highways England intend to remove the legal footway status of the pavements through the Harbour Villages and along the A259. The intention is to re designate 4km of pavements as two way cycle tracks that pedestrians are permitted to share with all the bicycle traffic using the National South Coast Cycle Route. More details of this scheme are available here.

ChiCycle, the Chichester Area District Cycle Forum and the West Sussex Cycle Forum, believe that this scheme is unsafe and will cause inconvenience to pedestrians and cyclists. Our understanding of National Policy for Cycling and Walking Gear Change and the Department for Transport guidelines for cycling infrastructure LTN1/20, is that both documents strongly advise against the conversion of significant lengths of pavement footways into shared use cycle-tracks.

On the 4th March 2021 We have sent a joint letter to Chris Heaton-Harris MP, who is the Minister of State for Walking and Cycling. (A picture of Chris Heaton-Harris is shown below)
Chris Heaton Headges MP

We have now receive a response from Chris Heaton-Harris which is available here.

Gabriel Adams of Fishbourne has also recently written to Gillian Keegan the MP for Chichester with her concerns about the A259 shared pavement NMU scheme. (An image of Gillian Keegan is shown below)
Gillian Keegan

Gillian Keegan kindly replied to Gabriel Adams, sending her a response from Chris Heaton-Harris. The response from Chris Heaton-Harris is available here.

Remarkably, Chris Heaton-Harris and the Department of Transport believe the NMU Scheme will meet Current Guidelines!!!

It seems likely Chris Heaton-Harris and his aids at the DfT have not been fully briefed on the details of this project. The following paragraph from the most recent correspondence with Chris Heaton-Harris shows there is no awareness long sections of pavement are going to be converted into cycle-tracks:

Following the publication of the new guidelines in July 2020 (Local Transport Note 1/20) (LTN1/20), Highways England sought to establish the impact of the guidelines on it’s feasibility recommendations. As a result, Highways England’s designs have evolved to a solution comprising of a mix of speed management zones, shared use paths and segregated facilities, which are compliant with LTN1/20 and will cater for all users. All of Highways England’s designs will be subjected to independent road safety audit review and an Equality Impact assessment.

The Department of Transport only use the term shared use paths to describe infrastructure away from traffic and roads. Shared use paths are the only form of shared use facility Chris Heaton Harris mentioned in his reply, but it is not these sections of the route where we have safety concerns.

Our specific safety concerns are over the plans to remove the legal status of 4km of urban pavements so that they will no longer classified as footways for pedestrian use only. These sections will be converted to shared use cycle tracks following the procedures of the Cycle Tracks Act 1984. The DfT would not normally describe shared use cycle tracks adjacent to or contiguous with a roadway as a shared use path.

Chris wrote the foreword to the LTN1/20 document which which mirrors the key principles and ideas embodied within the National Gear Change policy for Walking and Cycling. If he is fully aware of of the intended conversion of pavements to shared use, it is impossible to understand his reasoning for stating the scheme complies with LTN1/20. We can only assume he has been incorrectly briefed about these details.

Rupert Emerson also had correspondence discussing the NMU scheme with DfT in Summer 2020

Rupert Emerson wrote to the DfT on 4 August 2020 and received a response on 4 September 2020. The response letter is interesting because it confuses the distinction between paths, which in technical literature refer only to routes away from roads and cycle-tracks which critically have a different legal status and run adjacent or congruent to carriageways. This can be seen in the following paragraph taken from the DfT response dated 04/09/20:

The recent announcement of the Government’s new design guidelines for cycling infrastructure design (Local Transport Note 1/20) has necessitated a re-evaluation of the design process. These guidelines refer to shared use as the ‘last resort’ solution, but do quote some exceptions on where it may be appropriate, such as interurban routes with low pedestrian flow like the A259. Highways England is mindful of this new designation, but also note that shared use paths have been used widely for providing safe journeys for both cyclists and pedestrians across Highways England’s and the West Sussex network for many years. The existing network around Chichester includes popular examples of shared use paths such as Centurion Way and the path alongside the A259 between Chichester & Littlehampton.

Centurion Way is a shared use path as it away from motor-vehicle traffic but DfT guidelines do not classify the cycle-way between Chichester & Littlehampton as a path. It is classed as a cycle-track by DfT literature as it runs adjacent to a road.

Most stretches of the A259 between are Chichester & Littlehampton are intra-urban  which is in stark contrast to the Chichester to Emsworth sections that run through urban streets bordered by shops, churches and houses with frequent driveways.


Highways England A259 Chichester-Emsworth NMU Questionnaire and Presentation documents

Highways England have emailed a number of people inviting feedback on their proposals to adapt the pavements on the A259 to carry a two way cycle track that will in many places be shared with pedestrians.

The following links give access to documents used by Highways England when presenting the proposals for the A259 NMU scheme.

1. Story Board-Southbourne
2. Story Board-Sbourne to NBourne
3. Story Board-Nutbourne
4. Story Board-Bosham
5. Story Board-Bosham to Fishbourne
6. Story Board-Fishbourne
Chemroute factsheet v2
C2ENMU – Community Leaflet v3 (AC)

Please note that in the meetings with Highways England held on the 4th and 5th of February 2021, it was made clear that there would be sections of this scheme where pavements and cycle tracks would have widths restricted below those dimensions shown on the story board graphics. I would suggest taking the story board graphics as only an indication of the maximum widths that will be provided for walking and cycling on this scheme.

Shared pavements through urban areas of the route where there are frequent houses and driveways on the road will account for approximately 4km of the route’s length.

It is strongly recommended everyone who wishes their opinion to be heard fills in the following questionnaire provided by Highways England

A27 Chichester-Emsworth NMU Questionnaire

The deadline for completing the questionnaire is 17th March at 12pm.

I recommend giving your own perspective but my own notes on the questions are given in the following list and these may highlight issues where you may have  concerns.

  • (Question No 7) This only asks about the A259 and a significant number of people use Fishbourne Rd East. Highways England falsely claim this road is a very quiet street! You may wish to tick other and include “I use Fishbourne Rd East too” in response to question No 8.
  • (Question No 9) This question asks stakeholders to rate if parking is an issue. However parking can be an issue both because it is desirable to park at the side of the road in the cycle lane or for exactly the opposite reason, that if you are a cyclist or pedestrian it is undesirable to have cars parked on the cycleway or pavement. For this reason it may be best leaving this answer with a mid rating. Sadly, it is not possible to highlight traffic volume as an issue. This is unfortunate as it is the main issues preventing cyclists using the road and why the local authorities wish to convert the pavement into a shared use cycle track.
  • (Question No 11) With 150 driveways and access-ways crossing the pavements intended for conversion to shared use cycle tracks, this scheme is likely to have a negative impact on safety and convenience. Many of the driveways will be blind to approaching cyclists so the situation will be dangerous. This issue may cause cyclists to swerve knocking pedestrians over or even into the road. A score of zero is recommended as an answer to question 11.
  • (Question No 14) There is no reason why contraflow arrangements could not be employed on the A27 as an alternative to maintaining the A259 as a backup route in the event of road closures. This provides the opportunity to downgrade the A259 to a B road. The harbour villages are unsuitable for carrying in excess of 20,000 vehicles per day.
  • (Question No 15) The biggest obstacle preventing safe walking, cycling and community living in the Harbour Villages is the volume of traffic on the A259. The transport network could be modified so that private motor vehicles are not allowed to travel through the village centres. This will improve the quality for all residents but would require additional routes for existing motor-traffic such additional junctions onto the A27. Emergency vehicles and public transport could continue to pass through the centre of the Harbour Villages but other vehicles would need to take alternative routes. This would allow cyclists to use the roadway leaving pavements clear for the exclusive use of pedestrians.

A27 NMU Link Improvements Package Response from Michael Neville Bosham Parish Councillor

Michael Neville is a Bosham Parish Councillor and a lecturer at Chichester College.

He is a committed environmentalist and has always commuted between his home and collage on his bicycle apart from a few extremely rare occasions when he used to bring in a vintage car on dry summer days. Mike has a young family and often brings his kids to work with them riding in a bike trailer so they can attend the College crèche. He has been living without a car for some time but finds local infrastructure is hostile to anyone trying to move away from car dependency.

On the 4th of February Mike attended the Highways England Workshop that introduced the revised NMU scheme planned to run between Fishbourne to Emsworth. Mike’s assessment of the proposals is similar to the ChiCycle view that the scheme may increase danger for pedestrians and cyclists and represents a reduction in provision for pedestrian.

Michael Neville has produced the following video explaining his response to this proposal. The video is almost an hour long because there are so many issues that Mike is justifiably concerned about.

If the embedded video above fails to appear in your browser, please follow this alternative link to Mike’s video

Fishbourne Road East is NOT a Quiet Road Suitable for Cyclists to Share the Road-space with Motor-vehicles

ChiCycle will shortly be writing to Highways England in the hope of correcting misrepresentations they have made in recent presentations.

On Friday the 5th of February 2021, ChiCycle members attended a virtual meeting hosted by Highways England about their proposed for an NMU scheme that intends to move cyclists onto shared pavements on the majority of the route between Chichester and Emsworth.

While presenting the NMU proposal Helen Littler of claimed that traffic data indicates that Fishbourne Road East is a very quiet road where it is suitable for cyclists to share the road space with motor-vehicles. This is certainly not a justifiable assessment if current guidelines for cycle infrastructure are considered. Why have facts recorded by WSCC traffic count data been misrepresented in this way to local councillors and other stakeholders?

The most recent traffic data (publicly) available for this road was recorded in August 2009. Since this date there has been significant housing development along Clay lane that feeds onto Fishbourne Road East. Therefore, it is unlikely that typical traffic volume on this road will have declined since August/September 2009.

West Sussex County Council provide the following traffic count data:
Site Number: 00004581 Site Reference: C0123005L02
Vehicle Count Report August/September 2009.
Traffic volume ranged between 5129 & 2452 Vehicles Per Day

DfT Guidelines LTN1/20 (Page 74) state that:

7.1.1 Where motor traffic flows are light and
speeds are low, cyclists are likely to be able to cycle
on-carriageway in mixed traffic, as shown in Figure 4.1.
Most people, especially with younger children, will not
feel comfortable on-carriageways with more than 2,500
vehicles per day and speeds of more than 20 mph.
These values should be regarded as desirable upper
limits for inclusive cycling within the carriageway.

Of the 33 days when full daily traffic data was recorded at Site Reference: C0123005L02 during 2009, only two dates reported vehicle traffic counts below 2,500 vehicles per day! Sunday the 9th Aug and Sunday the 16th Aug. This shows that during the period of this survey the traffic volume on Fishbourne Road East was only appropriate for cycling in mixed traffic on 6% of these days.

It should also be noted that on two days the traffic volume on this road exceeded 5,000 vehicles per day! DfT guidelines LTN1/20 make the following comment on traffic volumes above 5,000 vehicles per day:

7.1.4….. At flows of above 5000 vehicles per day few
people will be prepared to cycle on-street…..

ChiCycle recommend that the project scope is significantly expanded to allow compliance with DfT guidelines and the current inadequate proposals are discarded. It seems reasonable to expect intervention on this route of a national cycle way so that minimum DfT recommendations are met. It is not credible to dismiss intervention on this cycle route where traffic volumes can exceed 5000 vehicles per day using the pretext that this is a quiet street.

Thank you in advance for accepting our guidance in how best to provide safe cycle infrastructure between Chichester and Emsworth.

Mark Record (Secretory of ChiCycle)

Example charts below show typical hourly traffic volumes on Fishbourne Road East during Aug/Sep 2009


Areas on the chart indicating over 300 vehicles passing the counter each hour will have had on average more than one vehicle passing every 12 seconds. With cyclists competing for narrowed road space where cars are parked at the street edge, this is not a quiet environment allowing relaxed inclusive cycling.


Safety Concerns over Highways England Proposal to Convert Pavements into Cycle Tracks between Chichester and Emsworth

ChiCycle will be contacting Chris Heaton-Harris (the minister for cycling and walking) and Baroness Vere of Norbiton (the Parliamentary Under Secretary of State at the Department for Transport) to get national governments official response to the following concerns.

Highways England proposals to convert West Sussex pavements into shared use cycle tracks between Chichester and Emsworth contravene Department for Transport standards for road safety!

The Chichester to Emsworth Route for Non-Motorised Users is a scheme 8.85 km in length that will remove cycle lanes from the A259 carriageway with the intention of relocating cyclists onto urban pavements/footways. Approximately 4 km in of urban pavement will be converted into shared use cycle tracks.

It is proposed that two way cycle traffic will be carried on single pavements on  only one side of the road. These pavements are intersected by over 150 side roads and driveways. The proposal will give cyclists priority over traffic at many of these intersections but the cycle track is designed with “no setback” at these crossings against recommendations in LTN1/20. The DfT guidelines clearly indicate (on page 108) that this design is unsuitable for two way cycle traffic.

Design priority, no setback
10.5.24 This approach is suitable for one way tracks
travelling in the same direction as the adjacent traffic
lane, as shown in figure 10.17. Drivers must give way to
cyclists when leaving the side road, but there is no
priority for cyclists over traffic turning in

For cyclists to be granted priority where motor vehicle intersections cross the pavements, the position where motorists must give way will have to be moved back by approximately 3 meters from the existing carriageway kerb-line. Unfortunately this will leave many of the exists blind so that motorists will have virtually zero visibility along the main axis of the A259. When drivers commit to pull out onto this road they will therefore be unable to adequately see traffic approaching in either direction. This contravenes guidelines for junction geometry given in both the DfT Manual for Streets 2 and in LTN1/20. The following advice is given within LTN1/20.

LTN1/20 5.8 Visibility splay
Any crossing of a highway or junction
between cycle routes should be located such that all
users have full visibility as shown in with Figure 5.4.
The x distance is in Table 5-6 and y distances are as
shown in Table 5-5 (SSD)…

Figure 5.4: Visibility x and y distance for a cycle track as the minor arm
Figure 5.4: Visibility x and y distance for a cycle track as the minor arm

In the diagram of splay visibility shown above the absolute minimum distance for dimension X1 is 2.4 metres and the Y1 dimension for the recommended cycle design speed of 30 kph, is 31 metres. Dozens of the cycle-track crossings will fail to come anywhere close to meeting absolute minimum DfT road safety standards.

The justification for the Highways England proposal to convert pavements into shared use cycle tracks is that the existing provision for cycling is considered unsafe. However, DfT guidelines indicate this proposal will be counter productive and increase risks for people using all modes of transport on this route.

Moreover, national policy on cycling and walking Gear Change states that:

Appendix (page41) Summary principles for cycle infrastructure design
2. Cycles must be treated as vehicles and not as pedestrians.
On urban streets, cyclists must be physically separated
from pedestrians and should not share space with

A significant concern with conversion of  pavements into shared use cycle-tracks is the threat of bikes colliding with pedestrians. This is a particular issue for our many elderly residents who often have mobility issues and/or visual impairment. These people will be terrified by sharing a pavement with a design speed for 30 kph two way cycle traffic.

LTN1/20 6.5.4… Shared use facilities are generally not favoured by either pedestrians or cyclists, particularly when flows are high.
It can create particular difficulties for visually impaired

Safety issues caused by putting a cycle track onto these urban pavements will be worsened by the projects failure to adhere to either recommended or absolute minimum DfT cycle track widths. Indeed, it is hard to identify any elements of the Highways England proposals that meet current standards for walking and cycling or any preceding standard for walking and cycling introduced within the last 25 years.

Recent National policy on cycling and walking Gear Change has promised that:

Funding only schemes which meet the new standards (page31)

We will not fund or part-fund any scheme that does not meet the new
standards and principles described in theme 1 and in the Appendix. We
will not allow any other agency or body to fund such schemes using any of our money…

ChiCycle members and other stakeholders joined a virtual meeting with the WSP project manager for this scheme (email Paul Goodenough) on the 5th Feb 2021. Remarkably, Paul stated that there is no mandate for this project to abide by the standards and principals included in current Gear Change national policy on cycling and walking!

Please provide your insight into why this scheme in West Sussex is permitted exemption from UK DfT road safety standards and why the scheme is not required to abide by national policy minimum standards for cycling and walking.

Many thanks in advance for addressing our concerns over this matter,

Mark Record (Secretary for ChiCycle)

 Southbourne Highstreet

The image above shows Southbourne’s northern side high street pavement which is planned to be inappropriately converted into a  two way shared use cycle track.

Chichester Observer reports A259 Conversion of Pavements to Shared Use Cycle Tracks

On the 17th February 2021 the Chichester Post published a story explaining scepticism from residents after proposals were revealed to narrow a road in Emsworth, to make way for a ‘shared use pavement’, and to relocate a Southbourne bus stop, to allow a narrow pavement to be used as a two-way cycle-track. Full details of the story can be read here: Latest proposals for ‘two-way cycle track’ between Emsworth and Chichester divide opinion.

Andrew Gould, Gabby Adams and Mark Record were shown simulating what pedestrians will face when the narrow Pavement at Nutbourne is converted into a shared use cycle-track.

On Thursday 11th Feb when the Observer’s photographer Steve took the photos, there was horrendous levels of traffic on the A259. Indeed the WSCC traffic counter on the A259 (A259 SOUTHBOURNE, W. OF THORNEY RD, O/S NO.44) recorded 21,429 motor vehicles passing over only 16 Hours! Total recorded traffic flow for 11th Feb 2021 at this location was 22919 motor vehicles!

Gabby rides cargo trailer on soon to be shared pavement

 Mark and Andrew looking moody

Pavement with two way traffic

Controversial Plans to Convert A259 pavements into Cycle-Tracks

On Friday the 5th of February 2021,  ChiCycle members Gabby Adams, Sarah-Sharp and Mark Record attended a virtual meeting hosted by Highways England. This meeting was held to discuss revised proposals described as improvements to the Chichester to Emsworth Route for non-motorised users. The meeting was attended by approximately 30 people representing the Borne communities, and advocates for pedestrians, cyclists and people with sensory impairment.

There was wide concern over the proposal to convert pavements along the A259 into shared use cycle tracks. Jeremy Board who was representing the group Gina’s Cycle Path, was the only person I could identify from the local community who voiced support for converting town/village pavements to shared use.

ChiCycle are strongly opposed to the proposals primarily because placing cyclists on the pavement will be a huge reduction in the level of provision for pedestrians. Conversion of pavements is likely to have a particularly severe impact on elderly residents and people with sensory impairment. Other concerns include the failure for the scheme to meet essential visibility criteria so cyclists can be seen at junctions and that cyclists will loose right of way at many junctions making use of the route impractical.

Details of matters discussed in the Chichester to Emsworth Route for Non-Motorised Users Cycling/Road Users Workshop

After introductions and a preamble about health and safety when working from home, a series of slides were shown to explain the revised proposals for the route.

Slides Showing Highways England’s Revised proposal for the route between Chichester and Emsworth

It is nessesary to click on the 1 to 3 numbers buttons at the bottom of the gallery to access the full three sets of slides!

Key points revealed about the new proposals by the workshop meeting.

At Emsworth just east of Queens st narrowing of the road to 6 metres is being considered to allow a shared use pavement to the North side of the road of 3 metres width. ChiCycle note that since the cycle track is bounded by vertical features, the shared use cycle track would need to be 3.7 metres width to comply with current guidelines LTN1/20 sections Table 5-3 and Table 6-3.

Between Emsworth and Southbourne pinch points were described along the route likely to limit the width of the path below the recommendations in LTN1/20. Visibility issues of the scheme were also acknowledged at driveways and shops.

At Southbourne Highways England suggested a re location of the bus stop to allow the narrow pavement past St John’s Church to be used as a two way cycle-track.

A section of two way segregated cycle track is proposed parallel to the pavement just after the Eastern exit from the Southbourne roundabout. This would stretch slightly beyond Inlands Road before reverting to being a shared use cycle track as Nutbourne is approached. It was acknowledged that there were issues with Chichester Caravans crossing the proposed cycle track.

It is being proposed to reduce the speed limit through Nutbourne to 20 MPH incorporating the use of traffic calming features such as build outs.

From just East of Inlands Road to Broad Road the pavement on the North Side of the road is proposed to be converted to a two way shared use cycle-track.

East of Broad road to Cutmill Creak a two way segregated cycle track is proposed that will be predominantly 3 metres wide but narrowing at some pinch points.

From Cutmill creak to Bosham, the proposal suggested allowing two routes for walking and cycling. A new route on the North side of the A259 was suggested following existing quiet roads. However Ian Sumnall of the Chichester District forum later voiced doubts that these were public roads that WSCC highways has jurisdiction over.  To the South of the A259 the existing shared use path would be retained but users would still be required to cross over the road to the north side before reaching Bosham to use existing residential quiet streets to reach the village.

The northern arm of the Bosham roundabout is proposed to be modified by the inclusion of a crossing island for pedestrians and cyclists.

The route through Bosham is proposed to remain as is  apart fom the posibility of it being widened in places. The provision will remain leaving the Bisham village on a two way shared use pavement. It was claimed by Highways England that they were constrained from acquiring additional land to improve facilities but Ian Sumnall later pointed out this land was part of a development proposal and was available for carrying walking and cycling provision.

Using highway land between Bosham and Fishbourne currently occupied by existing hedges was ruled out from use on the grounds it might disturb ecological habitats.

It was proposed to improve the path to the North of the A259 between Hilliers Garden centre and Fishbourne as a two way shared use facility.

It is proposed to introduce a 20 MPH zone through Fishbourne incorporating the use of traffic calming features such as build outs. They gave an example of the proposed type or build outs and road narrowing shown below.

ChiCycle have doubts a road intervention as shown above is realistic without other revisions to the road network to reduce traffic volume to below 16,000 vehicles a day.

From the entrance to the West of Fishbourne Village to the start of Legionnaires Way, it is proposed to use the Northern pavement as a two way shared use path,

It was acknowledged that although Legionnaires Way and Roman Way would remain a route for cyclists, many cyclists would find these routes inconvenient and would cycle in the carriageway through Fishbourne.

Fishbourne Road East was deemed from traffic data and Highways England site visits to be very quiet street and therefore it was claimed additional provision for cycling is not necessary at this location. However, ChiCycle have searched WSCC database of traffic data and can only find implausibly low traffic volume figures recorded in August 2009!

It was explained that once the route crossed the cycle/pedestrian bridge between Tesco and Bishop Luffa, the route would join where other proposals are happening. It was not made clear what these other proposals were or who was responsible for them. It was explained that they were outside of the Highways England scheme.

Key discussion issues

Andrew Gould (secretary of Chichester District Cycle Forum) raised the point that LTN1/20 states that…

LTN1/20 page 9 – 1.6 Summary Principles: (The following summary principles form an integral part of this guidance) …
(2) 1.6 Summary Principles
Cycles must be treated as vehicles and not as
pedestrians. On urban streets, cyclists must be
physically separated from pedestrians and
should not share space with pedestrians.
Where cycle routes cross pavements, a
physically segregated track should always
be provided. At crossings and junctions,
cyclists should not share the space used by
pedestrians but should be provided with a
separate parallel route.

Paul Goodenough of WSP relied to this by saying that “so I take on board what you are saying Andrew in terms of that summary principal, however it is a principal within the guidance and not a mandate,  and I would draw your attention to paragraph 6.5.6 paragraph 3 (shown below)

LTN1/20 page 67- 6.5.6
Shared use may be appropriate in some situations, if well-designed and implemented. Some are
listed below:….
>In situations where a length of shared use may be acceptable to achieve continuity of a cycle route

ChiCycle do not accept Paul Goodenough’s position in regard to this critical element of LTN1/20 section 1.6 summary principals not being mandatory. The specification states that “On urban streets, cyclists must be physically separated from pedestrians”. It is also states that “The following summary principles form an integral part of this guidance”.

Paragraph 3 in section employs the use of the word “may” which suggests there could be situations where achieving continuity of a cycle path might not be appropriate (such as on an urban high street with shops a church and a bus stop)

ChiCycle will be contacting Paul Goodenough to ask him why he feels summary principles preceded by the instruction “must” might be considered optional guidance rather than mandatory directives.

Andrew Gould (secretary of Chichester District Cycle Forum) raised the point that LTN1/20 states that…

LTN1/20 page 9 – 1.6 Summary Principles: (The following summary principles form an integral part of this guidance) …
(2) 1.6 Summary Principles
Cycles must be treated as vehicles and not as
pedestrians. On urban streets, cyclists must be
physically separated from pedestrians and
should not share space with pedestrians.
Where cycle routes cross pavements, a
physically segregated track should always
be provided. At crossings and junctions,
cyclists should not share the space used by
pedestrians but should be provided with a
separate parallel route.

Paul Goodenough of WSP relied to this by saying that “so I take on board what you are saying Andrew in terms of that summary principal, however it is a principal within the guidance and not a mandate,  and I would draw your attention to paragraph 6.5.6 paragraph 3 (shown below)

LTN1/20 page 67- 6.5.6
Shared use may be appropriate in some situations, if well-designed and implemented. Some are
listed below:….
>In situations where a length of shared use may be acceptable to achieve continuity of a cycle route

ChiCycle do not accept Paul Goodenough’s position in regard to this critical element of LTN1/20 section 1.6 summary principals not being mandatory. The specification states that “On urban streets, cyclists must be physically separated from pedestrians”. It is also states that “The following summary principles form an integral part of this guidance”.

Paragraph 3 in section 6.5.6 employs the word “may” which suggests there could be situations where achieving continuity of a cycle path might not be appropriate (such as on an urban high street with shops a church and a bus stop)

ChiCycle will be contacting Paul Goodenough to ask him why he feels summary principles preceded by the instruction “must” might be considered optional guidance rather than mandatory directives.





Highways England Responds to Bognor Regis Cycle Forum Questions on Emsworth To Chichester Cycle Route Plans

Adam Bell, raised questions on behalf of Regis Cycle Forum, over issues with Highways England plans to alter the Chichester to Emsworth Cycle route along the A259.

The Highways England reply skirts many of Adam’s issues by claiming the provision is for a share use Non Motorised Users (NMU) and not a dedicated cycle way. This categorisation allows national standards for cycling to be avoided and seems unlikely to provide a realistic alternative to cyclists continuing to use the road carriageway space.

The HE response followed by Adam’s original questions are below the horizontal line.

———- Forwarded message ———
From: A27 Designated Funds <>
Date: Wed, 2 Sep 2020 at 16:56
Subject: RE: Chichester to Emsworth Designated Funds A27 Link Improvement Package Feasibility Study
To: Bognor Cycle Forum <>
Cc: A27 Designated Funds <>

Dear Mr Bell

Thank you for your letter on 1st September 2020 regarding the Chichester-Emsworth NMU (Non-Motorised User) project. Thank you for showing an interest into this scheme and conducting such a comprehensive analysis of the Feasibility Study.

I would like to reassure you that no decision has been made yet on a solution for the project. We are still in the process of reviewing the Feasibility Study recommendation against the new released guidance and testing its viability. The Feasibility Study is used as a baseline, but we are now working on taking thinks forward and identifying a solution that performs best in terms of space availability, adhering to all relevant best practices/guidance and offering the best value for money. Throughout this process, we are working in close relation with both West Sussex County Council, as the local highway authority and asset owner, and Chichester District Council, as the local planning authority, who are both supportive of our proposals.

The recent announcement of the Government’s new design guidelines for cycling infrastructure design (Local Transport Note 1/20) has necessitated a re-evaluation of the design process as you have rightly pointed. These guidelines refer to shared use as the ‘last resort’ solution but do quote some exceptions on where it may be appropriate, such as interurban routes with low pedestrian flow like the A259. We are mindful of this new designation but also note that shared use paths have been used widely for providing safe journeys for both cyclists and pedestrians across both the Highways England and West Sussex networks for many years. The existing network around Chichester includes popular examples of shared use paths such as Centurion Way and the path alongside the A259 between Chichester & Littlehampton.

The A259 road is not a trunk road and is maintained by WSCC, hence CD 195 isn’t mandatory although represents good practice. That is why the options proposed in the Feasibility Study applied the principles of CD 195 only where that was applicable given the constraints of the road.

As one of the initial activities in our design phase, we will review the feasibility report in light of the new guidance contained in LTN 1/20.  We will be conducting a series of early engagement meetings where we will be engaging with stakeholders from the local authorities (parish, district and county) as well as local and national cycling organisations to understand any concerns or aspirations they may have.  We will also be exploring what can be delivered in light of LTN 1/20, aiming for the highest possible safety standards within the space available, whilst still providing value for money and without affecting the need for the A259 to be a HGV diversion route in case the A27 is blocked. The main objective of the scheme is to enable a growth in journeys made by active modes along the A259, but with the corridor being the main diversion route for A27, reducing car use or lowering vehicle speeds would impact the corridor’s strategic importance.

With regards to the query on widths, we specified a 3.5m wide path where achievable which gives scope for inclusion of a formal 0.5m strip whilst maintaining 3m width as recommended in Table E/3.1. Paragraph E/3.5 CD 143 allows for a minimum of 2.0m width where flows are less than 200 users per hour, therefore a 0.5m strip could be achieved where path widths are 2.5m. Furthermore, where a hard strip is provided on the carriageway, it can be considered as part of the separation distance for shared use routes. Therefore, there is scope to achieve greater separation as the design is further developed in the future. This will be further assessed during the next stages of the design.

In relation to the Cycling Level of Service query, the assessment doesn’t specifically need the inclusion of driveways. With that in mind, pedestrians/cyclists have priority at driveways similar to the priority proposed at some side roads.

Our current focus is to procure a design partner and we are currently in detailed contract negotiations. We expect the design phase to commence this Autumn.

I would like to reassure you that we will be engaging with all stakeholder groups at key points throughout the design phase to ensure we can agree on the best deliverable solution for the corridor and gauge any feedback.

Thank you once again for contacting us and expressing your interest in this project. Please rest assured that part of the appraisal we are currently undertaking involves raising the exact same issues you have in your letter and we are looking into progressing the scheme in a safe and cost-effective way, adhering to all relevant best practice and guidance.

Kind Regards

Adriana Chirovici

Project Manager

Regional Investment Programme South and East

Mobile: 07712 407 985

Tel: +44 300 470 1468
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From: Bognor Cycle Forum <>
Sent: 01 September 2020 07:59
To: A27 Designated Funds <>; Elliott, Simon <>
Subject: Chichester to Emsworth Designated Funds A27 Link Improvement Package Feasibility Study

For the attention of Mr S Elliott

The need to improve NCN2 on the section westwards from Chichester has been recognised locally by cyclists for many years.  The fact that Highways England are looking at a package of measures to improve cycling facilities is welcomed.  The WSP Feasibility Study states that it would explore the options to create a consistent, safe route for pedestrians and cyclists.  

However, the Bognor Regis Cycle Forum have a large number of concerns about the methodology used and the numerous discrepancies and inconsistencies throughout the study.  In addition, despite the Study stating it conforms with the requirements of CD195, this is not the case.  All of these reasons mean the whole basis for selecting a mainly off-road shared use path (Option A) is incorrect and better, safer solutions need to be considered instead. 

Separate to this, nothing in the proposals makes any attempt to materially reduce car use, lower vehicle speeds or attempt to try and achieve modal shift to make cycle use the default for shorter trips, as required by the Government.

 Design Criteria

Page 3 refers to the West Sussex Cycling Design Guide (2019), and states “WSCCs aim is that these design standards become commonplace in all new schemes throughout the county” and page 12 confirms the assessment of the existing cycling facilities was examined in line with the core design principles set out on the DfT LTN 1/12, and the Sustrans Design Manual : Handbook for cycle-friendly design.  Page 64 states that design guidance for cycle provision set out in CD195 is used for assessing the 2 options.

 Q1.    CD195 states that it is for cycle only routes, not shared use paths and covers the requirements for trunk roads and the motorway network. The A259 is not a trunk road and the proposed option is not a cycle only route.  Therefore, why was this design manual used as the reference for the study?

 Q2.    Why were the design principles from LTN1/12 not used for assessing the 2 proposed options?

 Q3.    Bearing in mind the recent release of LTN 1/20 along with the “Gear Change” document from the Government, and the recent announcement from the Transport Minister that authorities must follow LTN 1/20, will the proposals be amended to reflect the changes required by LTN 1/20?

Page 65 states that Table E/3.1 (from CD195) was used to determine the required width for the proposed cycle infrastructure and that due to the speed & volume of traffic, the minimum provision is off road cycle tracks.

Q4.    For the majority of the proposed route, in the main, a 3.5m path is stated.  However, there is no mention of the separation strip as required by CD195.  A separation strip, by its very definition, does not form part of the useable path.  CD195 states an absolute minimum separation strip of at least 0.5m is required in 40 mph areas and 2m in 60 mph areas.  Why has this separation strip not been provided along any part of the route?

There are large sections of 2.5m shared-use path which go alongside many walls and hedges which are higher than 0.6m.  Table E/3.2 of CD195 requires an additional width of 0.5m to maintain the effective width of the path.

Q5.   Why does the proposed option not comply with Table E/3.2 of CD195 in providing the additional width required?

 Q6.   Why does the proposed option not comply with Table E/3.1 of CD195 in stating that the maximum length for any sections which are only 2.5m wide is only 100m?

CLoS assessment

 The scores look at each section as a whole both eastbound and westbound, when there may only be an issue creating a lower score in 1 direction only.  This factor doesn’t seem to have been taken into account.  The study tends to look at a journey from the west, heading east.  In addition, no differentiation is made between a side road junction into a cul-du-sac.  Therefore the whole basis of Table 5-1 on Pages 68-69 comparing the existing route with Option 1 and Option 2 is flawed.

 Link 1 Havant Road Emsworth.

It’s not stated in the report when the site visit occurred, but it’s implied it was early 2020.  That being the case, it’s odd that for the assessment of Link 1 – Havant Road, there’s no mention at all of the approx. 250m stretch of new shared use path which was in use from May 2019 on the north side of the A259, from Selangor Avenue up to where the existing section of NCN2 crosses from the south of the A259 to then access the off road section and tunnel under the A27. The shared use path does however appear in the Preliminary Design drawing in App. C.

Table 3-1 on Page 15 provides a score of 19% with one of the reasons being frequent side road junctions with conflicting movements not separated.  There are 9 junctions each on the north and 8 on the south side of the A259.  It also mentions the 30mph limit and high volumes of traffic results in a low score.  However, the assessment doesn’t take into account that some side roads might be a cul-de-sac with only 4 houses and would not therefore be generating large volumes of traffic.

Table 3-2 Emsworth High Street scores higher at 42% for safety despite no segregation due to traffic speeds and volumes being low.  This is not consistent with Table 3-1 when the traffic volumes must be the same.  The safety score would be improved due to 20 mph and also the toucan crossing at West Street, but this would only be of benefit for cyclists heading eastwards.

Page 68 For Link 1 Havant Road (Emsworth) Option 2 states the Proposed CLoS would be 70% for 1.5m on-road cycle lane due to improved light protection where possible.  However, for Link 4 Southbourne to Farm Lane, the similar improved 1.5m wide cycle lane for Option 2 only achieves 33%.

 Page 69 Link 6 Broad Road to Cutmill Creek.  Under Option 2, the improved 1.5m cycle lane has a CLoS of 36% and yet Link 10 Hillier Garden Centre to Salthill Road scores 41%

 The differences CLoS percentages between the various different Links does not seem at all consistent.

Page 64 States that Option A would be an off-carriageway 3.5m to 2.5m two-way cycle track (shared use path for some sections).  However, Page 66 only refers to a 3.5m to 2.5m bi-directional shared-use path and a two-way shared use path is also referred throughout Table 5-1 on Page 68, and shared use is used from then on. 

 Q7.   Is any of the route to be a cycle only track or is the entire route to be shared use? 

 Q8.   Are horses to be allowed on the route or part of the route? 

The CLoS assessment confirms that 8 factors are deemed to be critical and have a greater score.  This is one of the reasons Option A is deemed to be the most suitable option, as stated by the summary on page 66 “The removal of cyclists from the carriageway will also considerably lessen the risk of collision of cyclists with all types of motorised traffic”.  For the Personal Injury Collisions taken into account for this study affecting non- motorised users, 66% occurred at a junction, roundabout or side road.  Some of these are pedestrians, but the figure is similar to national data regarding road traffic incidents and cyclists. However on Page 88, for the section along Havant Road in Emsworth the study states ”Due to the conflicts associated with a shared use path facility and numerous private access driveways with restricted visibility, the option of off-road cycle provision was excluded for this section”.

In numerous places along the proposed route, there are large numbers of private driveways as well as side junctions.

 Q9.   Why does the CLoS assessment used not include the private driveways in respect of the “risk of collision with turning vehicle at junctions” criteria?

 Q10.    How can a feasibility study recommend as safe a shared use facility which has multiple private access driveways with nil visibility but elsewhere state such a facility wouldn’t be acceptable due to conflicts from driveways with limited visibility?

 If a shared-use path is provided, then as well as the large number of private driveways now being added to the list of junction hazards to be encountered by cyclists coupled with the zero or limited visibility for car drivers emerging from their driveways, to stop on the path, there is also the factor of limited visibility for cyclists when crossing many of the side roads, when they no longer have priority.  An example of this is in Link 5 Farm Lane to Broad Road, where due to the position of the crossing point across Broad Road, cyclists would be positioned round the corner and not have a good field of vision for checking back in the direction of Emsworth, and in addition would not comply with the visibility splay requirements stated in Table E/3.5 of CD195.  The recommended crossing point here does not comply with the bent-out crossing of a minor road as set out in E/4.7 of CD195, and this failure to provide an adequate and compliant crossing point occurs for the numerous times the shared-use path crosses a minor road.

Option Appraisal (Page 66).

There are discrepancies in the way this is worded as well as important safety factors not being taken into place, leading to an incorrect selection of a mainly off-road shared use path as the preferred route.

Section 5.2.2 states “the A259 is a relatively high-speed and highly trafficked link, with signposted speed limits exceeding 30mph in the entirety of all three sections” and “This guidance indicates that off-road provisions for cyclists are the most appropriate for this link”.

The study has 12 sections or links listed.  There are only 3 links with above 30 mph areas in the entirety, one of which is Link 7 Cutmill Creek to Old Bridge Road which is intending to use the existing off-road path anyway.  The option appraisal incorrectly uses the existence of above 30 mph in those 3 links as justification for off-road provision along the entire route.

Section 5.2.3. states that the shared-use path in Option A is able to meet desirable minimum requirements set out in Table E/3.1 of CD195 and retain 3.5m width for the majority of the route, with some small sections the width being down to 2.5m (the absolute minimum set out in the CD 195 guidance).

As stated above, there is no mention of the minimum 0.5m separation strip (rising to 2m where the national speed limit applies which would be needed for Link 7).

Section 5.2.4 states “The provision of a consistent, segregated route also meets the standards set out in WSCC design guidance, which states that on primary distributor roads, where speeds are greater than 30mph, off carriageway provision must be provided”. However, this omits the rest of the description which continues “(cycle tracks), preferably segregated”.

The proposed option A actually drastically increases the number of potential incidents due to the large numbers of entrances and side roads onto the shared use path.  This is flagged up as an issue in App. F  Road Safety Review, which states the number of private drives with no visibility to/from the shared use path.  It also states a number of side roads and field accesses have limited visibility.  All of these add a large number of potential conflict points with cyclists. 

Page 67 states “The initial design process for Option B related to the improvement of the existing on-carriageway cycle facilities along the A259. However, after further design considerations, this Option was discounted from the scheme due to identified constraints relating to the speed of vehicles between the A259 and A27 as well as a high number of PICs involving cyclists being identified along this route”.  As stated above, the vast majority of incidents occur at junctions or wherever a car might turn into a cyclist. 

In the analysis of the various options shown in Table 5-1 on Page 68, this shows Link 1 Havant Road Emsworth with mainly 1.5m cycle lanes currently has a CLoS of 33%, but this can be increased to 70% with the lanes amended to always be 1.5m wide and some light protection.  There has been no proper consideration of improving the cycling provision by looking to provide similar light protection on the existing cycle lanes.

There is no consistency in the treatment of the shared use path when crossing side roads.  In some places, cyclists will have priority, but in the main, cyclists will be expected to give way.  To have a mix of priorities will be dangerous and confusing for all users.  At a typical cycling speed of 12 mph, being required to come to a halt regularly will not satisfy the requirements for safety, directness nor comfort.  In addition, by being required to regularly accelerate away from junctions will not be conducive to encouraging cycling and will merely encourage some people to ride on the road.  By removing the existing cycle lane marking will therefore encourage vehicles to drive closer to any cyclists on the road and increase the likelihood of incidents.

In addition, in the various built-up areas, especially in the numerous long sections of only 2.5m width shared-use path, there is not adequate and safe width for two way cycling and pedestrians, and the design and use of such a provision is contrary to LTN 1/20 and does not even comply with the Highways England Design requirement for shared-use paths set out in CD143. 

The path will also increase the numbers of incidents between pedestrians and cyclists.  In addition, LTN1/12 highlights the fact that two-way cycle tracks on one side of the road can significantly increase the potential for conflict due to drivers being less likely to expect cyclists to come from both directions.

Overall therefore, the selection of a shared-use path for the entire route not only will be more dangerous for cyclists than the existing provision, does not comply with CD195, CD143, nor LTN 1/20, and will not satisfy the core requirements of a safe, consistent high-quality route which promotes sustainable travel.

Adam Bell


Bognor Regis Cycle Forum

Highways England Chichester to Emsworth Cycle Route Concerns

The new scheme for the Chichester to Emsworth Cycle Route threatens to reduce the level of local provision for both pedestrians and cyclists alike. It will also encouraging faster and larger volumes of motor vehicle traffic along the A259.

There are a great many reasons why it is unsatisfactory for the cycle scheme to relocate cyclists onto the existing pavements through the harbour villages.

Removing the existing cycle lanes will encourage greater volumes of motor vehicle traffic that will also be likely to travel at higher speed. This will make the villages environments less pleasant for residents.

Putting cyclists on the pavements will threaten vulnerable pedestrians who will have to contend with high speed two way cycle traffic where they walk.

Cyclists will not be able to progress quickly along the route because of conflict with pedestrians and people exiting their properties unable to see cyclists approaching.

ChiCycle contacted the project manager Simon Elliott by post and by email on Monday 29 June 2020. Simon is overseeing the new Highways England Cycle Route scheme between Chichester to Emsworth.

We asked Simon for assurance that Highways England would reconsider removing the  existing cycle lanes along with the expectation that cyclists should thereafter cycle on the pavement. Highways England have not yet responded to our communication.

Roger Elkins has informed ChiCycle that he believes “it is best that Highways England respond to your concerns” and he will “note their response with interest”.

Andrew Frost, Director Planning and Environment Chichester District Council has explained:

The District Council’s remit does not extend to technical highways related matters and so we do not have officers specialised in this area. When the District Council requires input on technical highways related matters then we take advice from WSCC as the Local Highway Authority and occasionally through the employment of external contractors. The matters you raise are technical highway design issues and concerns around the application of highways related guidance. For the reasons outlined above, it is not appropriate therefore, for me to comment in any detail in respect of the concerns raised. Can I suggest that you send your concerns to both HE and WSCC as the ‘owner’ of the scheme and the Local Highway Authority respectively. Both have the appropriate in-house technical competency to consider the points that you raise.

ChiCycle advise local residents who have concerns over their pavements being converted into a cycle-tracks, to contact Highways England and Simon Elliott directly. Their contact details are as follows: is an official email for concerns over the project and emails sent to this address are logged and recorded as part of the planning process.

Simon Elliott is the project manager for the NCN2 [A259] cycle route.
Simon Elliott
Simon Elliott. Programme Manager (Construction) – Regional Investment Programme South East Highways England | Bridge House | 1 Walnut Tree Close | Guildford | Surrey | GU1 4LZ
Web: Mobile : 07901 110659



Open Letter to Highways England regarding the Chichester to Emsworth Cycle-way

We have now received the following reply from highways England:

Subject: FW: ChiCycle Chichester-Emsworth A27 Designated Funds
Date: Fri, 24 Jul 2020 15:51:48 +0000
From: Elliott, Simon <>

Dear Mr Record
Thank you for your email regarding the Chichester to Emsworth Non-Motorised User (NMU) route.
Firstly, may I apologise for the length of time it has taken to respond to your letter.
As you are aware, we are currently in the process of procuring a design partner to progress the recommendations of the WSP feasibility study for a shared path on the northern side of the A259 between Chichester and the border with Hampshire. We currently hope to have them on board for a start to their commission in September.
As you will appreciate, the layouts detailed in the feasibility study are high level. The next stage will involve working these up in further detail and considering both localised constraints and compliance with the specified design standards (both our own DMRB and the West Sussex cycle design guide). Any design outputs will be subject to safety audits and technical reviews during the course of the design lifecycle.
We will be providing our designers with a copy of all comments received on the feasibility study from stakeholders to ensure they take on both local knowledge and any technical concerns raised. We will also be working with West Sussex County Council throughout the design process to ensure the design meets their needs as both local highway authority and asset owner.
Finally, with regards to your comments on town planning, I note your points but will decline commenting on these as they are local matters for the local authorities and I note you have written to them separately with your list of concerns.
Kind Regards
Simon Elliott
Simon Elliott BEng(Hons) CEng FCIHT DMS NEC3&4 ECC Accredited PM
Programme Manager (Construction) – Regional Investment Programme South East
Highways England | Bridge House | 1 Walnut Tree Close | Guildford | Surrey | GU1 4LZ
Web: Mobile : 07901 110659

Dear Highways England A27 designated funds team,

ChiCycle are delighted that funds and planning efforts are being invested into walking and cycling infrastructure between Chichester and Emsworth.

However, we are reluctant to support the designs within the feasibility study because they involve relocating cyclists onto the pavement in built up areas. This will result in a significant reduction in provision for both cyclists and pedestrians alike.

Please find  a detailed list of our concerns, observations and recommendations at the end of this correspondence, that we hope will be considered during the further development of this scheme.

ChiCycle would welcome an assurance from you, that plans to put fast two way cycle traffic onto the pavement, in built up areas, with the cycle-way running on a single side of the road, will be thoroughly reconsidered.

Please let us know how you intend to review and revise the existing designs.  Ideally we would like a statement that you are happy for us to share by publishing on our website.

Thank you in advance for sharing your intentions,

Mark Record (on behalf of ChiCycle)

ChiCycle Concerns, Observations and Recommendations regarding the Highways England Designated Funds A27 Link Improvement Package Feasibility Study Plans

30 kph Commuter/Utility Cycle Traffic on Shared Use Pavements will Threaten Vulnerable Residents

 DMRB CD195 Designing for cycle traffic (page 17) recommends a cycle-way design speed of 30 kph. It indicates an absolute minimum design speed of 20 kph. However, the standards states this minimum speed can only be applied over a short distance:

E/3.17 Absolute minimum values for cycle track design speed shall only be used for distances up to 100 metres.
E/3.17.1 Where absolute minimum design speed values are used for cycle tracks, ‘SLOW’ markings should be included.

30 kph will be an intimidating speed of traffic  for vulnerable residents sharing the pavement. Parents may be discouraged from walking young children to school, choosing to make these journey by car instead. This may force a car-dependent lifestyle on the very youngest members of our community. Frail elderly residents may also lose the confidence to go shopping locally when fast moving cycles are relocated onto the pavement. This could prevent elderly people living independently. People with sensory impairment may feel particularly at risk.

DfT LTN 1/12 Shared Use Routes for Pedestrians and Cyclists (page 6) discusses  related issues:

The Equality Act
1.13 Shared use schemes are often implemented to improve conditions for cyclists, but it is essential that they are designed to take into account the needs of everyone expected to use the facility. Poorly designed schemes, and schemes where the available width is insufficient to comfortably accommodate the expected flows of pedestrians and cyclists, are likely to reduce the amenity value of the route.
1.14 Disabled people and older people can be particularly affected by shared use routes. Ultimately, however, it will depend on the quality of the design. Consideration of their various needs is an important part of the design of shared use, and the duties under the Equality Act 2010 are particularly relevant.

ChiCycle are concerned that removing existing cycle lanes from the carriageway  and re-locating fast cycle traffic onto existing pavements will represent a significant reduction in the quality of provision for both pedestrians and cyclists alike.

Our recommendation is to preserve the existing pavements/footways for pedestrian use only.

Feasibility Study Incorrectly Relies on CD195 Specifications for Shared Use Pavements/Foot-ways

Feasibility Study 5.1.4.  (Page 65) States:

To determine the required widths of proposed cycle infrastructure, based upon peak hour cycle flow, reference has been made to Table E/3.1 of the Highways England guidance. Table E/3.1 has been re-produced below in Figure 5-3.

However,  DMRB CD195 Designing for cycle traffic does not contain any specification for shared use pavements/footways!

The Introduction of CD195 makes the following statement:

This document refers to the provision for cycle traffic only which allows for a higher design speed when separated from pedestrian and equestrian traffic.

Chapter 1 of CD195 clarifies that the scope of the document excludes shared use paths.

1. Scope (Aspects covered)
1.1 This document shall be used for the design of routes and assets used by cycle traffic.
NOTE This document does not cover the design of shared use facilities for pedestrians, equestrians and cyclists.

ChiCycle observe that CD195 recommendations have been inappropriately applied and therefore falsely indicate a shared use pavement might be an appropriate solution in built up areas. This mistake casts doubts over the conclusions of the entire study. We recommend the proposal of reallocating pavement space for shared use is reconsidered.

Side Road Junctions do not follow CD195 Standard

DMRB CD195 Designing for cycle traffic (page 27) identifies only two methods where a cycle track can cross a side road while maintaining priority.

E/4.7 Cycle tracks which intersect the minor road at priority junctions shall cross the minor road in one of two ways – either bent-out or bent-in crossings.

The “bent in” method is not appropriate for use with two way cycle tracks.

E/4.16 Cycle tracks at bent-in crossings shall be one-way.

ChiCycle doubt there is adequate space in the built the up areas to “bent out” the cycle track by a minimum of 5 metres at all access roads and minor junctions .

E/4.15 At bent-out crossings, where cycle tracks cross minor private access roads carrying less than 2000 AADT, there shall be a minimum set-back distance of 5 metres.

ChiCycle recommend stepped cycle tracks as a more appropriate solution. CD195 indicates stepped cycle tracks are acceptable as long as a speed limit of no more than 30 Mph is applied where they are employed.

Table shows a stepped cycle track is a suitable solution even with the high 15697 AADT traffic flow of the A259.

LCDS Recommends Against Running Two-Way Cycle Tracks Across the Mouths of Side Road Junctions

LCDS Ch5 Junctions and crossings (Page 25 – Priority junctions) gives design advice on side road junctions for two way cycle tracks that is similar to that given in CD195.

For two-way tracks crossing two-way side roads, ‘bending-out’ by 5 metres is the recommended option. Where island separation is wide, this can be achieved with little or no deviation of the cycle track. Continuing a two-way track through a priority junction without deviation is possible, but brings with it various risks, related to the visibility of cyclists to turning motorised traffic. It is not recommended unless traffic speeds and volumes are very low and other measures can be put in place to enhance visibility of cyclists – even then, it should be subject to a site- specific risk assessment. Closing side streets to motorised traffic is likely to be the only reliable way of dealing with these risks.

LCDS recommend that if a two way cycle track can not be “bent out” at junctions the only reliable way of making the arrangement safe is to close the side streets to motorised traffic!

The Feasibility Study may have considered the use of two way cycle tracks parallel to the road due to the misconception that this arrangement requires the least highway space to accommodate it. However CD195 and LCDS both include bending out the cycleway by 5 metres where cycle tracks cross minor roads or access-ways. ChiCycle consider the proposed two-way cycle track an inefficient use of available space due to the requirement of bending out the cycle way at each junction/access-way.

For these reasons ChiCycle recommend that in built up areas, either stepped cycle tracks should be provided on both sides of the road or alternatively traffic volumes and speeds should be reduced to levels where cyclists can safely share the carriageway with motorists.

Proposed Plans Require Properties Adjacent to the Cycle Track to Limit Boundary Heights to 600mm for Visibility Splay Compliance

DfT LTN 02/08 Section 9.1 (page 53) explains visibility requirements at junctions and crossings of cycle tracks. It states:

9.1.1 Where a cycle track meets a road, visibility splays are required to ensure cyclists can see and be seen by approaching motorists. Splays are defined by their X and Y distances, and Figure 9.1 shows the
basic layout. Figure 7.18 in the Manual for Streets (DfT/CLG, 2007) (MfS) shows how splays are measured on curved alignments.

Boundaries of properties immediately adjacent to the cycle track will need to be free from visual obstructions. This is so motor-vehicles at junctions or vehicles emerging from driveways can see and give way to cyclists before pulling out into approaching cycle traffic. A 31 metre SSD is recommended for 30 kph design speed cycle tracks which will be the Y distance a motorist would need to see oncoming cyclists in advance of pulling out across the cycle way. Maintaining adequate visibility will require boundary planting, fencing and walls on private properties, being brought down and maintained at below the DfT recommended height of 600mm.

ChiCycle are concerned residents may be reluctant to comply with requests to modify their front gardens and that future policing of these visibility requirement may prove difficult to enforce.

All Current UK Highway Standards Recommend Against Converting Pavements to Shared Use for Two-Way Long Distance Commuter/Utility Cycle Routes running through Built Up Areas

LCDS Ch4 Cycle lanes and tracks (Page 79) –  makes the following statement about shared use footways:

4.6.3 – Partially separated and shared use footways are not generally recommended alongside the carriageway where there are better ways of providing for cyclists. They suffer from many of the drawbacks outlined for equivalent off-road facilities in section 4.5 above, with regard to compliance, compromising pedestrian comfort and deterring use by many people who find sharing with cyclists intimidating, including people with mobility or visual impairments. They also represent a low level of service for cyclists.

DfT LTN 02/08 (page 10) Table 1.2 Outlines a hierarchy of provision intended to ensure that the needs of the most vulnerable road users are fully considered in all highway schemes.

hierarchy-of-provision from LTN02/08

DfT LTN 1/12 Shared Use Routes for Pedestrians and Cyclists (page 22) explores some of the disadvantages of relocating two way cycle traffic onto a shared pavement/footway.

6.12 A common reason for taking cyclists off the carriageway is the perception that it will improve safety. However, it is important to understand that a shared use route will not necessarily be safer than an on-carriageway alternative. In particular, careful consideration is needed where a cycle track running alongside a road crosses side a road – see Figure 6.1. At these locations, there is significant potential for conflict, which can sometimes negate the safety benefits of segregating cyclists from motor vehicles. Section 10.3 of LTN 2/08 discusses this in greater detail.
6.13 Where cycle tracks alongside roads accommodate two-way flow, the potential for conflict can increase significantly. It is probable that drivers are less likely to expect cyclists to come from both directions because, intuitively, they might assume cyclists would be travelling in the same directions as traffic in the adjacent part of the carriageway – see Figures 6.1 and 6.2.

The now obsolete Sustrans Design Manual Handbook for cycle-friendly design
April 2014, Chapter 4 – Streets and roads (page 14) explains the manuals philosophy towards reallocation of road space:

Reallocation of road space. A fundamental aspect of the provision of cycling facilities is the reallocation of carriageway from motor vehicles to cycling. This can be seen in the majority of figures within this document. The provision of cycle tracks in urban areas at the expense of the footway is not encouraged (it tends to be unpopular with pedestrians and cyclists)

Routeing the South Coast National Cycleway along pavements, through built up areas, will prove counter productive to road safety. Motorists often show aggression  towards cyclists who choose not to use poor quality cycle provision. This aggression is frequently accompanied by dangerous driving endangering cyclists. West Sussex already contains many examples of unsuitable cycle schemes that cyclists normally bypass by riding in the roadway.

If national cycle design standards are ignored, the Designated Funds A27 Link Improvement Package risks becoming a waste of public money. It may then produce unusable and useless infrastructure that the community do not want to see constructed.

ChiCycle advise that the A27 Designated Funds should only be spent on high quality, national standards compliant (preferably CD195) infrastructure. This will enable the uptake of safe, convenient and confident cycling along the South Coast National Cycle-route.

Plans Confuse Actual Widths Measured between Vertical Features with Recommended Usable Effective Widths Prescribed by National Cycle Standards

ChiCycle have surveyed sections of the A259 pavement and concluded that there has been a misinterpretation of national cycle design guidelines regarding usable track widths. Widths shown in the Feasibility Study appear not to make allowance for the vertical features adjacent to the path such as boundary walls and hedges.

As already discussed  DMRB CD195 Designing for cycle traffic does not contain any specification for shared use pavements/footways. However, even if pedestrians could be removed from the pavement to make way for a dedicated cycle-way, then the standards for track widths have still been misapplied.

DMRB CD195 Designing for cycle traffic (page 12) states:

E/3.2 Additional width shall be added to cycle tracks to make allowance for fixed objects adjacent to or within the cycle track in accordance with Table E/3.2.

E/3.2 Additional width
E/3.2 Additional widths
E/3.2 Additional width diagram
E/3.2 Additional width diagram

DfT LTN 02/08 (page 43) Table 8.2 Additional width required for footways and cycle tracks gives similar guidance:

Although DfT LTN 1/12 Shared Use Routes for Pedestrians and Cyclists indicates a shared pavement is an inappropriate solution for carrying the National South Coast Cycle Route, it is the current specification to follow for designing shared use paths in situations where shared use is advisable. It gives the following specifications in LTN 1/12 Table 7.5 & 7.5 (Page 43 – 44):

ChiCycle are unable to replicate LCDS Cycle Level of Service (CLoS) analysis figures shown in Feasibility Study report

Details of the studies LCDS CLoS scoring for existing infrastructure was given in Appendix A, but the report omits detailed scoring analysis of Option-1 and Option-2. ChiCycle performed their own CLoS analysis for  link number 4 for Option-1 (Southbourne to Farm Lane) but have been unable to replicate similar score to that reported in the feasibility study.

The Feasibility Study awards Option-1 link number 4, an extremely high CLoS score of 85%. Several legitimate concerns resulted in the existing infrastructure on the same section, being awarded a low score of only 24%. There are a number of scoring issues we are unable to follow:

    • The existing traffic arrangement is marked as a critical fail due to “Heavy streams of turning traffic cut across main cycling stream”. However, it is not clear how moving cyclists onto the pavement will resolved this issue.
    • Another critical fail identified in the existing arrangement is “Cycle Lanes <1.5m alongside parking loading with no buffer. This raises the issue of conflict with “Kerbside activity or risk of collision with door”. Because CD195 requires two way cycle tracks to be divided into opposing direction lanes, Option-1 presumably will have a lane less than 1.5 meters wide, adjacent to the kerb where “collision with door” are to be expected. It is also difficult to see how a cyclists riding on a pavement might be isolated from kerb side activity?
    • Option-1 fails to provide the convenience or directness of a route absent from frequent road crossing or free from obstruction from other road users, so it is difficult to understand how a CLoS scoring of 85% has been calculated. DfT LTN 02/08 states that:

      8.2.1 On commuter routes, cyclists usually want to be able to travel at speeds of between 12 mph and 20 mph, preferably without having to lose momentum. Frequent road crossings, tight corner radii, the presence of other users and restricted width or forward visibility all affect the speed with which cyclists can travel and the effort required. Cyclists tend not to favour cycle routes that frequently require them to adjust their speed or stop.

ChiCycle recommend future CLoS assessments are conducted with input from the community of cycle users in the area. A full cycle audit and review should also be conducted with the input of local cycling groups following the recommendations of  DfT LTN 02/08 1.7 (page 15).

Scope of the Cycle-way Improvement Scheme may be too Narrow and Ignores Wider Aspects of Town Planning.

There are a significant number of housing developments under construction in the South East of England with significant pressure from National Government to build even more. Fishbourne, Nutbourne, Bosham and Southbourne are small village high streets that could become appealing local centres. However for the street scene of these villages to remain appealing as local centres, something needs to be done about the increasing volume of traffic travelling on the A259.

The expansion of housing will bring an associated rise in local population. This seems likely to increase motor vehicle use still further unless steps are taken to mitigate against it. With the A259 being the main conduit for local traffic between Chichester and Emsworth it is difficult to imagine the small villages retaining an appealing sense of place with increasing traffic flow along the A259. Perhaps solving this problem requires stepping back from the narrow details of cycle track specification and considering wider issues from the alternative perspective of town planning.

ChiCycle have the following town planning recommendations for the A259 corridor between Chichester and Emsworth.

  1. Provide employment, shops, schools and other local amenities to reduce the need for motor vehicle journeys.
  2. Improve the convenience of public transport by providing more train stations, more frequent trains or a parallel tram service. This will provide viable alternatives to journeys by car.
  3. Expand and improve the cycle network in the region to provide further alternatives to motor vehicle dependency.
  4. Provide local roads with new access connections onto the A27 to relieve village centres from heavy traffic. If there must be an increase in motor vehicle use then infrastructure will be needed to divert this traffic away from the National South Coast Cycle Route and the villages/communities it connects together.
  5. If it is not possible to reduce traffic volumes on the A259, an alternative, direct and high quality cycle route should be constructed parallel to the railway line.


The transport sector is now the UK’s greatest contributor of CO2 emissions. It is generally accepted that unless global CO2 emissions are halted by 2030, there will be a bleak future for humanity. ChiCycle also believe getting around by bike is more health and fun than a sedentary lifestyle with hours spent stuck inside stuffy motor-vehicles. Considering the urgency of Climate Crisis, ChiCycle hope the Designated Funds A27 Link Improvement Package plans can be reconsidered to include something more aspirational and appealing than cyclists riding on existing pavements. At this time of Climate Crisis it is vital we move away from unsustainable motor vehicle dependency and embrace sustainable modes of transport.

I hope this provides a constructive input to the Designated Funds A27 Link Improvement Package scheme,

Mark Record (on behalf of ChiCycle)

A copy of this email has now been sent to (Simon Elliott Programme Manager Regional Investment Programme South East Highways England)