J
Just Zis Guy
Guest
Here's the contents of a document I received yesterday from Chris Juden at CTC. I aven't asked his
permission, but it should be OK to post here as it's a "position paper" rather than the formal
response at this point, and was fairly widely circulated.
ROAD VEHICLES LIGHTING REGULATIONS
==================================
CTC Position Paper – by Chris Juden, CTC Technical Officer –
2003.01.28
The proposal from DfT to allow flashing lamps on bicycles is most welcome, but only addresses one
issue, whereas there are several further ways in which the lighting regulations have become out of
touch with the means employed by intelligent cyclists to improve their conspicuity. This is clear
from the mere admission that "the use of flashing front and rear lights on pedal cycles is becoming
common". That was the situation 10 years ago. "Has become" and "ubiquitous" would be more accurate
descriptions of the current situation!
Red flashing lamps on breakdown vehicles etc.
---------------------------------------------
Before cycle lighting issues, DfT raise this other suggestion. As mentioned above, red flashing
lights are now so commonly used by cyclists as to now send one clear message: BIKE. Their adoption
by breakdown vehicles would dilute and confuse that message, so we strongly oppose the appropriation
of this, our unique marker, by any kind of motor vehicle.
It is not too clear why breakdown vehicles need red flashing lights when they are already allowed to
use yellow flashing lights. It is alleged (in the Background paragraph) that yellow beacons have may
have lost their effectiveness through inappropriate use. Are we to give the naughty child another
toy to replace the one he’s broken?
The need uniquely to identify such vehicles was mentioned. We respond with the need uniquely to
identify bicycles! However it is true that red flashing lights are also used by joggers and
equestrians. And cyclists don’t have a problem if this identifier becomes just a little less unique
by association with other /vulnerable/ road users.
In their Regulatory Impact Assessment, DfT mentions the need to warn about breakdown personnel in
the road. We accept this point and consider it entirely appropriate for such personnel to wear red
flashing lights attached to their hi-vis clothing etc. We note and regret the number of persons
killed or injured on the hard shoulder or verges. Let people therefore directly identify and protect
themselves by wearing red flashing lights – not by hanging them on the vehicles they have vacated.
We therefore suggest an option A3: encourage people vacating or attending broken down vehicles to
wear red flashing lights.
Red and Blue flashers
---------------------
We agree that the conditions under which Police are allowed to use red flashing lights should be
more tightly controlled. Anything which keeps red flashing lights more clearly and uniquely
associated with vulnerable road users has to be a good thing.
B2 or B4 – flashers only?
-------------------------
Permission to use flashing lights in addition to approved, steady lights, option B2, probably needs
no further work from us to make it happen. But that is no longer enough. It is clear that what most
cyclists really want is to be allowed to use flashers only, at least at the rear, and as we cannot
see an overwhelming reason why they shouldn’t, CTC supports that desire.
The fears of some cyclists that flashing lights don’t pinpoint location and might not be so safe are
now known to be exaggerated. The cyclist’s main problem is to grab the motorist’s attention, which
flashing lights do best. After that any tracking issues become insignificant.
*Option B4* is the only one that lets a flashing red LED be one's only rear lamp, so that’s the one
we must support. Unfortunately the DfT have muddied that option by lumping in a load of gimmicky
flashing pedal and wheel reflectors. Cyclists are not queuing up to add LEDs to their pedals and
wheels. Products like this have been around for as long as LED rearlamps but you do not see many on
bikes. DfT fears of a “profusion of flashing lamps” are unfounded. But if that’s a problem, we say
take them out of option B4.
The real problem for DfT and flashers only, is the lack of any equivalent to BS6102/3 for front and
rear lamps that allows DfT simply to say "okay if it passes that".
Some (not many) rear lamps which claim compliance with BS do also have a flashing mode, but there is
no testing regime in the BS to check the flash rate or the relative duration of the on/off phases.
Both these matters would have to be controlled before a flasher could be approved and neither are
likely to be added to the BS on a shorter timescale than this legislation.
The reasons to cut loose from BS
--------------------------------
The solution is to write these criteria into the regulations rather that 'calling up' an existing
standard. That, however, would be seen by DfT as a retrograde step. That's how the Regulations used
to be, when they spoke about a "white" front light "visible from a reasonable distance" – before
they got the BSI precisely to define the colour and intensity in all directions. The trouble with
precise definitions is, they root you to a point in history – but that’s another matter.
So, to be sure we were getting something equivalent to existing approved lamps, we could ask DfT to
extract just the most important criteria out of the BS, write them into the regs and let the free
market take care of the rest. That, I am afraid, is the only way to make flashers legal as a
cyclist’s only lights, in the short term. It could also solve some other problems.
Lights that are TOO good!
-------------------------
Increasing numbers of cyclists are resorting to very bright so-called off-road rechargeable
headlights in order to make themselves more conspicuous from the front. At present these are legal
as additions. However: when one has 20W of rechargeable halogen power on the handlebars, it is
ridiculous to add a comparatively puny fig-leaf of an approved headlamp and still shell out on
disposable batteries. For one thing there is seldom enough space left to mount it. So almost nobody
bothers and it really doesn't matter - except that it's illegal.
Why are these lamps not approved? There are various highly technical reasons to do with beam
pattern, the size of the writing on the battery pack etc., none of which has much bearing on road
safety. I'm sure that they could be manufactured to BS, but we have to accept that Britain is a
commercially insignificant cycling country with peculiarly restrictive cycle lighting laws. Anything
goes in the USA and the southern half of Europe, so why should manufacturers bother? After all: they
can sell it in the UK just the same – it's only the users who may have a legal problem and few of
them know it. Fewer still policemen.
Without a European Directive on cycle lighting standards, and there's no prospect of that, foreign
lamp manufacturers (we no longer have any significant ones in Britain) will continue to say: "ah
yes, very nice standard, but I think my lamp will sell better if I make it like this". And it will.
Performance criteria
--------------------
The writing into the lighting regulations of common minimum performance criteria for headlamps and
rearlamps is, I suggest, the way forward. BS6102/3 could still be mentioned as one of the ways to
ensure they are met.
DfT already propose to write some performance criteria into the regulations. Flashing additional
lights will be allowed between 1 and 4 flashes per second. For them to replace steady lights, we
should require that they at least deliver an equal amount of light energy, averaged over time. For a
rear lamp that would be 4cd (so a lamp that flashed with equal on and off periods should reach a
peak intensity of 8cd or more). I think we should also require the duration of each “on” phase to be
at least 125 milliseconds (half of the time at fastest permitted flash rate). This may be needed to
avoid strobe-type flashes of blinding intensity. These criteria are equally applicable to flashing
and non flashing lights and could easily be written into the regulations, opening the market to all
responsibly designed flashing lights.
The same should be said of front flashing lights, for which the BS minimum is 400cd, peak
brightness. An upper limit on peak brightness is also advisable and I’d suggest the same limit as
that applying to car headlamps: 24000cd.
BS6102 presently limits the light emitted 3.5° above beam centre to 70cd to stop cyclists dazzling
oncoming traffic. This is design restrictive (none of these higher-power lamps control the beam this
tightly) and ultimately futile, since the Lighting Regulations say nothing about how the lamp is
mounted on the bike. And any cyclist can simply reach down and twist his lamp to point as desired.
No one, however, should need their lamp aimed higher than 1° below the horizontal, and I suggest
that writing that requirement into the Lighting regulations would compensate for breaking free from
BS6102/3 and its pointless 70cd limit.
It remains only to ensure that both these lights also direct some light to the sides. This is easily
done by defining zones within which the averaged intensity must exceed certain levels, e.g. 1cd
everywhere 10° up and down and 45° R&L from the centre, 0.05cd throughout 15° U&D and 80° R&L.
Pedal Reflectors
----------------
It is most regrettable that DfT have ignored the problems experienced by cyclists using modern
clipless pedal systems. Most simply cannot have pedal reflectors, so cyclists wear reflective ankle
bands etc. It is all very well to talk about flashing lights on pedals and in the wheels, but it is
much more important to recognise these alternative means of providing the mandated reflectorisation
in cases where no such hardware can be applied. Nothing brings the law into greater disrepute than
when well-informed, law-abiding people find that it ignores their attempts to satisfy its
intentions.
I believe that reflective ankle bands exist that can equal the performance of pedal reflectors.
Also, since the only function of front pedal reflectors is to take the place of rear ones when the
pedal rotates, front reflectors need only be fitted when a pedal is capable of being used either way
up. The regulations must be amended so that reasonable alternatives can be used. If necessary,
cyclists could add additional fixed reflectors to the rear of the bicycle, but alternatives of some
sort must be allowed, not on the pedals.
It is not good enough to dismiss “keen” cyclists, the users of high-tech pedals, as an unimportant
minority. In many parts of Britain conditions are so hostile for cycling that, especially after
dark, such enthusiasts are almost the only cyclists out there.
Stationary in traffic
---------------------
The existing law requiring an unlit cyclist to be at the kerbside seems very reasonable until you
consider the practicalities for dynamo users. There you are, approaching a junction in the correct
lane for going straight ahead, when the traffic grinds to a halt. However the left-turn filter is
still moving and fast. What to do? Stay put, which is illegal since your lights are out, but
perfectly safe because everything fore and aft has stopped like you? Or try to hop across that
stream of traffic on your left! The latter course is ridiculously hazardous and leads to even
greater danger when a few minutes later you must try to cross it again and re-enter the now
accelerating stream of traffic so recently vacated!
Modern dynamo systems are the most reliable of cycle lights and their use should be encouraged by
anyone who is serious about road safety. We suggest that cyclists are allowed to remain unlit not
only when stopped at the kerbside but also in all other circumstances where an approaching vehicle
would also have to stop, even if the cyclist were not there. To summarise these conditions:
A cyclist should be allowed to be unlit on a road if stationary:
2004. at the kerbside
2005. at a give-way or stop line, and prevented from advancing by traffic signals or vehicles
crossing in front that have right-of-way
2006. at any place on a road immediately behind a vehicle that has stopped in front.
I should mention that the Continentals, who are ahead of us in so many cycling ways, have developed
dynamo rear lamps that stay on when you stop, albeit at somewhat reduced brightness. A sensible
compromise, that would encourage dynamo users to upgrade their rear lamps, would be to allow the
front light to be extinguished in all the above suggested circumstances, but still require at least
2cd output from the rear lamp (50% of the level normally required).
Guy
===
** WARNING ** This posting may contain traces of irony. http://www.chapmancentral.com (BT ADSL and
dynamic DNS permitting)
NOTE: BT Openworld have now blocked port 25 (without notice), so old mail addresses may no longer
work. Apologies.
permission, but it should be OK to post here as it's a "position paper" rather than the formal
response at this point, and was fairly widely circulated.
ROAD VEHICLES LIGHTING REGULATIONS
==================================
CTC Position Paper – by Chris Juden, CTC Technical Officer –
2003.01.28
The proposal from DfT to allow flashing lamps on bicycles is most welcome, but only addresses one
issue, whereas there are several further ways in which the lighting regulations have become out of
touch with the means employed by intelligent cyclists to improve their conspicuity. This is clear
from the mere admission that "the use of flashing front and rear lights on pedal cycles is becoming
common". That was the situation 10 years ago. "Has become" and "ubiquitous" would be more accurate
descriptions of the current situation!
Red flashing lamps on breakdown vehicles etc.
---------------------------------------------
Before cycle lighting issues, DfT raise this other suggestion. As mentioned above, red flashing
lights are now so commonly used by cyclists as to now send one clear message: BIKE. Their adoption
by breakdown vehicles would dilute and confuse that message, so we strongly oppose the appropriation
of this, our unique marker, by any kind of motor vehicle.
It is not too clear why breakdown vehicles need red flashing lights when they are already allowed to
use yellow flashing lights. It is alleged (in the Background paragraph) that yellow beacons have may
have lost their effectiveness through inappropriate use. Are we to give the naughty child another
toy to replace the one he’s broken?
The need uniquely to identify such vehicles was mentioned. We respond with the need uniquely to
identify bicycles! However it is true that red flashing lights are also used by joggers and
equestrians. And cyclists don’t have a problem if this identifier becomes just a little less unique
by association with other /vulnerable/ road users.
In their Regulatory Impact Assessment, DfT mentions the need to warn about breakdown personnel in
the road. We accept this point and consider it entirely appropriate for such personnel to wear red
flashing lights attached to their hi-vis clothing etc. We note and regret the number of persons
killed or injured on the hard shoulder or verges. Let people therefore directly identify and protect
themselves by wearing red flashing lights – not by hanging them on the vehicles they have vacated.
We therefore suggest an option A3: encourage people vacating or attending broken down vehicles to
wear red flashing lights.
Red and Blue flashers
---------------------
We agree that the conditions under which Police are allowed to use red flashing lights should be
more tightly controlled. Anything which keeps red flashing lights more clearly and uniquely
associated with vulnerable road users has to be a good thing.
B2 or B4 – flashers only?
-------------------------
Permission to use flashing lights in addition to approved, steady lights, option B2, probably needs
no further work from us to make it happen. But that is no longer enough. It is clear that what most
cyclists really want is to be allowed to use flashers only, at least at the rear, and as we cannot
see an overwhelming reason why they shouldn’t, CTC supports that desire.
The fears of some cyclists that flashing lights don’t pinpoint location and might not be so safe are
now known to be exaggerated. The cyclist’s main problem is to grab the motorist’s attention, which
flashing lights do best. After that any tracking issues become insignificant.
*Option B4* is the only one that lets a flashing red LED be one's only rear lamp, so that’s the one
we must support. Unfortunately the DfT have muddied that option by lumping in a load of gimmicky
flashing pedal and wheel reflectors. Cyclists are not queuing up to add LEDs to their pedals and
wheels. Products like this have been around for as long as LED rearlamps but you do not see many on
bikes. DfT fears of a “profusion of flashing lamps” are unfounded. But if that’s a problem, we say
take them out of option B4.
The real problem for DfT and flashers only, is the lack of any equivalent to BS6102/3 for front and
rear lamps that allows DfT simply to say "okay if it passes that".
Some (not many) rear lamps which claim compliance with BS do also have a flashing mode, but there is
no testing regime in the BS to check the flash rate or the relative duration of the on/off phases.
Both these matters would have to be controlled before a flasher could be approved and neither are
likely to be added to the BS on a shorter timescale than this legislation.
The reasons to cut loose from BS
--------------------------------
The solution is to write these criteria into the regulations rather that 'calling up' an existing
standard. That, however, would be seen by DfT as a retrograde step. That's how the Regulations used
to be, when they spoke about a "white" front light "visible from a reasonable distance" – before
they got the BSI precisely to define the colour and intensity in all directions. The trouble with
precise definitions is, they root you to a point in history – but that’s another matter.
So, to be sure we were getting something equivalent to existing approved lamps, we could ask DfT to
extract just the most important criteria out of the BS, write them into the regs and let the free
market take care of the rest. That, I am afraid, is the only way to make flashers legal as a
cyclist’s only lights, in the short term. It could also solve some other problems.
Lights that are TOO good!
-------------------------
Increasing numbers of cyclists are resorting to very bright so-called off-road rechargeable
headlights in order to make themselves more conspicuous from the front. At present these are legal
as additions. However: when one has 20W of rechargeable halogen power on the handlebars, it is
ridiculous to add a comparatively puny fig-leaf of an approved headlamp and still shell out on
disposable batteries. For one thing there is seldom enough space left to mount it. So almost nobody
bothers and it really doesn't matter - except that it's illegal.
Why are these lamps not approved? There are various highly technical reasons to do with beam
pattern, the size of the writing on the battery pack etc., none of which has much bearing on road
safety. I'm sure that they could be manufactured to BS, but we have to accept that Britain is a
commercially insignificant cycling country with peculiarly restrictive cycle lighting laws. Anything
goes in the USA and the southern half of Europe, so why should manufacturers bother? After all: they
can sell it in the UK just the same – it's only the users who may have a legal problem and few of
them know it. Fewer still policemen.
Without a European Directive on cycle lighting standards, and there's no prospect of that, foreign
lamp manufacturers (we no longer have any significant ones in Britain) will continue to say: "ah
yes, very nice standard, but I think my lamp will sell better if I make it like this". And it will.
Performance criteria
--------------------
The writing into the lighting regulations of common minimum performance criteria for headlamps and
rearlamps is, I suggest, the way forward. BS6102/3 could still be mentioned as one of the ways to
ensure they are met.
DfT already propose to write some performance criteria into the regulations. Flashing additional
lights will be allowed between 1 and 4 flashes per second. For them to replace steady lights, we
should require that they at least deliver an equal amount of light energy, averaged over time. For a
rear lamp that would be 4cd (so a lamp that flashed with equal on and off periods should reach a
peak intensity of 8cd or more). I think we should also require the duration of each “on” phase to be
at least 125 milliseconds (half of the time at fastest permitted flash rate). This may be needed to
avoid strobe-type flashes of blinding intensity. These criteria are equally applicable to flashing
and non flashing lights and could easily be written into the regulations, opening the market to all
responsibly designed flashing lights.
The same should be said of front flashing lights, for which the BS minimum is 400cd, peak
brightness. An upper limit on peak brightness is also advisable and I’d suggest the same limit as
that applying to car headlamps: 24000cd.
BS6102 presently limits the light emitted 3.5° above beam centre to 70cd to stop cyclists dazzling
oncoming traffic. This is design restrictive (none of these higher-power lamps control the beam this
tightly) and ultimately futile, since the Lighting Regulations say nothing about how the lamp is
mounted on the bike. And any cyclist can simply reach down and twist his lamp to point as desired.
No one, however, should need their lamp aimed higher than 1° below the horizontal, and I suggest
that writing that requirement into the Lighting regulations would compensate for breaking free from
BS6102/3 and its pointless 70cd limit.
It remains only to ensure that both these lights also direct some light to the sides. This is easily
done by defining zones within which the averaged intensity must exceed certain levels, e.g. 1cd
everywhere 10° up and down and 45° R&L from the centre, 0.05cd throughout 15° U&D and 80° R&L.
Pedal Reflectors
----------------
It is most regrettable that DfT have ignored the problems experienced by cyclists using modern
clipless pedal systems. Most simply cannot have pedal reflectors, so cyclists wear reflective ankle
bands etc. It is all very well to talk about flashing lights on pedals and in the wheels, but it is
much more important to recognise these alternative means of providing the mandated reflectorisation
in cases where no such hardware can be applied. Nothing brings the law into greater disrepute than
when well-informed, law-abiding people find that it ignores their attempts to satisfy its
intentions.
I believe that reflective ankle bands exist that can equal the performance of pedal reflectors.
Also, since the only function of front pedal reflectors is to take the place of rear ones when the
pedal rotates, front reflectors need only be fitted when a pedal is capable of being used either way
up. The regulations must be amended so that reasonable alternatives can be used. If necessary,
cyclists could add additional fixed reflectors to the rear of the bicycle, but alternatives of some
sort must be allowed, not on the pedals.
It is not good enough to dismiss “keen” cyclists, the users of high-tech pedals, as an unimportant
minority. In many parts of Britain conditions are so hostile for cycling that, especially after
dark, such enthusiasts are almost the only cyclists out there.
Stationary in traffic
---------------------
The existing law requiring an unlit cyclist to be at the kerbside seems very reasonable until you
consider the practicalities for dynamo users. There you are, approaching a junction in the correct
lane for going straight ahead, when the traffic grinds to a halt. However the left-turn filter is
still moving and fast. What to do? Stay put, which is illegal since your lights are out, but
perfectly safe because everything fore and aft has stopped like you? Or try to hop across that
stream of traffic on your left! The latter course is ridiculously hazardous and leads to even
greater danger when a few minutes later you must try to cross it again and re-enter the now
accelerating stream of traffic so recently vacated!
Modern dynamo systems are the most reliable of cycle lights and their use should be encouraged by
anyone who is serious about road safety. We suggest that cyclists are allowed to remain unlit not
only when stopped at the kerbside but also in all other circumstances where an approaching vehicle
would also have to stop, even if the cyclist were not there. To summarise these conditions:
A cyclist should be allowed to be unlit on a road if stationary:
2004. at the kerbside
2005. at a give-way or stop line, and prevented from advancing by traffic signals or vehicles
crossing in front that have right-of-way
2006. at any place on a road immediately behind a vehicle that has stopped in front.
I should mention that the Continentals, who are ahead of us in so many cycling ways, have developed
dynamo rear lamps that stay on when you stop, albeit at somewhat reduced brightness. A sensible
compromise, that would encourage dynamo users to upgrade their rear lamps, would be to allow the
front light to be extinguished in all the above suggested circumstances, but still require at least
2cd output from the rear lamp (50% of the level normally required).
Guy
===
** WARNING ** This posting may contain traces of irony. http://www.chapmancentral.com (BT ADSL and
dynamic DNS permitting)
NOTE: BT Openworld have now blocked port 25 (without notice), so old mail addresses may no longer
work. Apologies.
