Why Will Vehicle Event Data Recorders (“Black Boxes”) Be Required to Record More Detailed Data by September, 2027?

First generation event data recorders (“Black Boxes”) started appearing on 1999 General Motors products such as shown in this view. Although GM eventually increased the recording time up to 8 seconds before impact not much change has been seen in the detail and duration of recording in EDRs for the past 25 years. Now the U.S. National Highway Traffic Safety Administration will require manufacturers to increase the detail and duration of these recordings.

Seemingly, the “detailed” data now being collected whenever a motor vehicle crash takes place is enough to provide many experts, and the courts, with an acceptable understanding of how a collision occurred. Yet the U.S. National Highway Traffic Safety Administration (NHTSA) has completed a new ruling, effective January 17, 2025, that will require motor vehicle manufacturers to record data at a much higher detail and over a much longer time. The present requirement is to record at 2 samples every second over a time of 5 seconds. The new requirement will be to record at 10 samples every second over a time of 20 seconds. This requirement must be enabled by most motor vehicle manufacturers by September 1, 2027. Is this additional detail necessary? The average citizen has no idea.

In NHTSA’s discussion of the Final Ruling, they summarized the need as follows:

In another section of NHTSA’s report they discussed the content of an earlier Notice of Proposed Rulemaking (NPRM). In the NPRM the following comment was given:

So NHTSA is stating that there is a problem.

The requirement for additional detail and duration of recording comes with a cost. NHTSA argues that the cost is not that large as most current hardware is able to meet that requirement without much re-design.

It is worthwhile noting that NHTSA’s requirements as to what manufacturers must record were originally created in 2006, or almost 20 years ago. NHTSA’s position was that, these requirements must exist only if manufacturers chose to install an event data recorder (EDR). In other words manufacturers could refuse to install an EDR as their option, but if an EDR exists it must record a list of 15 required parameters. To this day manufacturers still have the option of not installing an EDR in their vehicles.

Driving in earlier times, without modern safety standards and electronics, was much simpler and much more dangerous. As the dice shown in this photo, if you drove your vehicle the chance that you would survive, sustain injury, or be fatally injured was often a matter of luck.

Trump Tariff Turmoil – An Impetus For Canadian Cycling?

Cycling is cheap. It does not require external fuel and it is healthy. In many instances business trips can be made by carrying modest amounts of cargo. All these points indicate that the bazaar tariffs on Canada by its southern neighbor may ultimately lead to some positives by forcing Canadians to become more self-reliant.

Threatened import tariffs by a deranged U.S. president have many Canadians believing its southern neighbour is the new “public enemy #1”. The transportation sector is an example where illogical tariffs could create turmoil on both sides of the border as some car manufacturing and parts plants may close and costs of motor vehicles may rise. If there is a silver lining in all this mayhem it is that cycling in Canada may get a boost.

Cycling is a non-technical mode of transportation that does not require expensive or complicated parts shipped across Canada’s border. Many things get done under the radar by the community of cyclists who are often invisible to the public eye. Yes there are the impressive-looking cargo bikes that could be useful in some circumstances. However a lot of work is done on simple bikes with no fancy design.

Cycles specifically designed to carry cargo are infrequently observed in the City of London. This may be due to their cost. Certainly they are able to carry significant cargo and, when accompanied by an electric motor, they can be far cheaper to operate than a gas-powered motor vehicle.

In remains a fact that small-scale business activities of Canadian society are often overlooked and never fully documented. This is because so much of it remains unofficial. Within the activities of cyclists there are numerous instances where business acts are completed without recognition of their importance. Yet there are a vast number of them.

This article will examine some recent observations of cyclists in London, Ontario taken from a broader study undertaken by Gorski Consulting over many years. The focus will be on the types of cyclists that are observed conducting non-official business activities, from very low-cost activities, to those that require greater expenditures to achieve their work. This will emphasize that cycling for business can be a viable option when dictatorial insanity to the south attempts to disrupt Canadian society. But this cycling activity needs government intervention to make it more organized and efficient. It also needs government involvement to provide public disclosure about how cyclist injuries and deaths are occurring so that corrections can be made and cycling can be a true benefit to Canadian society.

Low-End Cyclist Business Activities

Those at the lower end of the economical scale have developed unique ways to transport cargo and conduct personal business. At the cheapest end of the scale are those who carry cargo without any attachments to a cycle. Some of these instances have been observed on London’s streets recently and are shown below.

The person on the right shows how various carts and wagons are used by pedestrians to transport cargo. The cycle rider on the left shows how bulky cargo is transported in precarious ways throughout the City. In both instances these modes of transportation are extremely cheap and far more common than officially recognized.
Here minor cargo is transported on the cycle’s handlebar while the cyclist is also holding a coffee cup. The cyclist is also not wearing a helmet. Safety is compromised but this type of transportation is observed on a constant basis in the City.
For those murderers who must dismember bodies this view shows that the transportation of a chainsaw can be done on a cycle. Oh, and holding a cup of coffee, by the same hand, can be done at the same time.
Here a cyclist who has too much cargo resting on his handlebars simply steers by holding onto the cargo. Again, while such actions are not condoned, they exist and this is reality.
Even smaller pieces of cargo can become dangerous as shown here where the red scarf is hanging precariously in the spokes of the cycle’s front wheel.
Not every cyclist is capable of carrying cargo with the same level of ease. As shown here elderly riders may have difficulties when too much cargo weighs onto the handlebar. Yet, when necessity calls for it, such transportation is done, regardless of age.
Here we see another typical male cyclist with no helmet but riding with substantial number of bags hanging from the handlebars. This is done while higher speed motor vehicle traffic is nearby.
In younger years almost every cyclist has been a “taxi” to a friend. While many of these travels involved a passenger sitting on the top-tube those tubes do not exist on many newer cycles and they are no longer horizontal. In the modern age this passenger rides with his feet on the back axle. Still cheaper than Uber.
Here a larger table seems to be no problem for transportation on a cycle without any additional equipment. Yet in the narrowed environment of a protected cycling lane such an activity could be hazardous or incapable of occurring.
This may be an example of a cycling waiter or bartender. A tray filled with coffee cups is being delivered by cycle to persons unknown.

These are just a few of the many examples observed around the City of London where unofficial business is being conducted on a cycle without any specific designs or attachments. There are instances where cargo carrying on a cycle involves additional attachments and some observed examples of this are shown below.

Personal Business Cycling With Additional Attachments

Official “pannier” saddlebags are common in transporting limited amounts of cargo on cycles but that attachment involves a cost which, even though moderate, is not accepted by those with very limited incomes or no income at all.
The pushing of grocery carts while riding a cycle is a common activity in London that is not even discussed. While these carts can carry a substantial cargo they also can be difficult to manuveur while also attempting to steer the cycle on or across an urban roadway.
Given the lack of official recognition, a number of views of cyclists pushing grocery carts will be shown in this article because of the importance of this issue. This activity is common yet it is also unsafe. In this view the cyclist is also not wearing a helmet so any collision event could cause a needless increase in injury.
Here we see a cyclist who has stepped off his cycle and is walking on a sidewalk while also pushing a grocery cart. In a short distance this rider will mount his cycle. Again, no helmet is worn here.
In another example here we see a male cyclist with no helmet pushing a grocery cart but he rides on the sidewalk. This is safer for the cyclist but may not be safe for any pedestrians if care is not taken.
And here we see a somewhat uncommon situation where a cycle is being carried on top of a loaded grocery cart. It needs to be acknowledged that, although this seems unusual it is also not unique. Actions like these are occurring in the City of London.
This view shows a common situation where baggage is attached in various ways to a carrier on a cycle. Again, various methods are employed to enable the carrying of cargo through various attachments.
Here we see a situation where the cyclist has decided to dismount while pulling a loaded wagon. This is not always the case. In many instances cyclists will ride while pulling such wagons.
Here we see an entrepreneurial cyclist who has attached a large garbage bin to the back of his cycle. While uncommon a variety of such attachments are used by cyclists to complete some form of business.
Pushing grocery carts while riding a cycle is common in London. But the additional width of the cycle and cart lead to problems when attempting to fit within the limited confides of a painted cycling lane. Here we see that the cyclist is already at the extreme edge of the cycling lane but then he encounters an obstacle which causes a greater problem, as shown in the next photo.
A garbage can has been discarded into the cycling lane causing a cyclist to travel outside of the cycling lane and into the lane designated for motor vehicle traffic. Such complications are not officially acknowledged and dangerous scenarios like these persist without public recognition.
In this photo we see an extreme reliance on multiple cargo-baring carts while a cyclist walks his cycle in an urban area of London. These unique solutions are helpful in accomplishing a business need but also creating potential safety problems.

Having reviewed some unique cycling combinations there is one which, in our view, is most promising and it has been left for this last discussion. Cycles with mini-trailer attachments at the back of the cycle are the best solution because they can carry substantial cargo, are narrow enough to fit within the confines of typical cycling lanes and they are also the safest combinations of all. The photos below provide some examples of cycles and mini-trailers observed in London.

This photo provides a typical scenario where a cyclist has attached a mini-trailer to the back of his cycle. Even though the rider is not wearing a helmet the mini-trailer provides him with greater stability. Also any cargo in the trailer is positioned at a low level and this also improves stability. If the cyclist was carrying cargo above his wheel for example this could create an unstable situation even with moderate steering inputs.
In this example a female rider is transporting a child in a mini-trailer attached to the rear of the cycle. Again this does not reduce the stability of cycle. However it is not the safest situation for the child which might not be visible to drivers of motor vehicles.
In this example a cyclist has modified the mini-trailer by removing its sides thus allowing to carry cargo of larger dimensions. Even so this combination would fit within the confines of a typical cycling lane.
Here is another example where the sides of a mini-trailer have been removed thus allowing for the transport of a wider range of cargo.

Cycling Insecurity Due To Theft

While unofficial business activities take place in the City of London, there are hazards that remain and need greater government intervention. One of the greatest problems for cyclists is theft. Whenever a cycle is left in a public, or even private space, it is vulnerable to being stolen. Some examples of observations are shown below.

While this view does not show any additional attachment, it shows that other cycles are transported, possibly for dubious reasons, by simply steering them in a riderless fashion. Unfortunately stealing cycles in not that difficult to do but it is a business in which some persons excel.
As a demonstration that possible cycle theft is not uncommon, here is another rider who is pushing an unoccupied cycle for unexplained reasons.
And again, here we have another unoccupied cycle that is being transported for suspicious reasons.

Cycling has the potential of being a great benefit to Canadian society but headwinds like theft exist that prevent it from being what it could be. This mode of transportation is fragile. It requires public attention and action to expand its benefits.

Discussion

These photos have shown unorthodox ways in which cyclists in London carry cargo to achieve unofficial business. Each rider and their circumstance is unique. Because of these homemade alterations the efficiency of them is mixed while the threat to their safety is real. Mini-trailers attached to the rear of cycles provide the best combination, both in terms of cargo carrying capability but also in terms of cycling safety. Governments could improve these conditions by making mini-trailers more available especially to those a the bottom of the income bracket. Many cyclists use their cycles as an essential mode of transportation because they cannot afford other alternatives and they tend to develop home-made improvisations due to necessity. These improvisations may solve their initial problems but they add to the likelihood that a collision will occur either with motor vehicle traffic or via single-cycle loss-of-control. Yet carrying cargo and conducting business in these inexpensive ways can provide Canadians with independence from foreign agencies that would wish to destabilize the Canadian economy.

Access to Vehicle Infotainment and Camera Data Complicates Court Evidence and Owner Rights

A page taken from a typical, modern, vehicle owners manual shows just some of the numerous options available. Those complicated options come with a wide variety of data stored throughout a vehicle’s complex electronic system of modules and software. While this data should be available to a vehicle owner in reality it is not.

The technology existing in newer motor vehicles is quickly becoming more complex while causing questions to be asked about ethics and vehicle owner rights. Data from Event Data Recorders (“Black Boxes”) have been available to download from vehicles as early as 1999 (GM products). As technology has evolved so have the complications of what kind of data is captured, who can retrieve it and how this affects the rights of vehicle owners involved in collisions who should be able to use that data in their defense.

The U.S. National Highway Traffic Safety Administration set out rules to be followed by vehicle manufacturers as to what kind of data those manufacturers were required to capture and how that data was to be made available to vehicle owners. That law was to become effective with 2013 model vehicles. The success of that rule was marginal. Although most manufacturers complied with that ruling in terms of capturing the required parameters, the availability of that data has fallen short. Many manufacturers have allowed their vehicles to be compatible with crash data retrieval hardware which has been purchased by almost all police forces, insurers and research institutes, However a number of manufacturers have opted out and created their own hardware. All this hardware is expensive and requires trained personnel to conduct a download which adds more cost to the activity. The bottom line is that the average owner/consumer is in no position to obtain the data from their own vehicle. Yet police can access the data for criminal matters and insurers can access it by requiring the owner to surrender their rights of defense to the insurer. And large research institutions can assess it for “benign” purposes.

In recent years matters have become even more complicated. Vehicles no longer have a single EDR module, but the complete vehicle electronics system is a complex of integrated modules that store a variety of data in a variety of locations. Now vehicle infotainment systems can be interrogated by specialized software (Berla) and many vehicles are now equipped with multiple cameras whose views can also be downloaded by specialized equipment.

As an example, Nissan is offering owners the option to purchase an app which will allow them to download camera data on select 2024 and 2025 vehicles. Some details of the plan are discussed on the Nissan website but the cost is not revealed.

It remains questionable how these complications will apply in court proceedings where a vehicle owner ought to have the right to examine evidence in their own defense. If hardware, software and technician costs are too high does that take away the owner’s right to the evidence? What happens if police do not download all the available data in a criminal case because there could be significant costs associated with that? Will this be a matter of “evidence spoilation” that have been a point of argument in historic criminal cases?

Unfortunately the laws are slow to react to quickly developing technologies and vehicle owners may suffer these consequences for many years before the “wild west” is brought to order. Or it may never be brought to order.

Observed Differences In Cyclist Characteristics & Safety Across City of London Ontario

Cyclist observations by Gorski Consulting in the City of London Ontario reveal important facts. There are large differences in the characteristics and safety of cyclists depending on what area of the City is examined. Such findings could help those interested in cyclist safety. This article will discuss cyclist observations as a whole within London and then this city-wide data will be compared to four sites where obvious differences were observed.

Review of City-Wide Cyclist Observations

Zygmunt Gorski has been conducting road safety research and motor vehicle collision analysis in the City of London and southern Ontario for over 44 years. While the focus of that work has been varied, cyclist collisions and safety have always been a part of that work. In the last 12 years a greater focus has been applied to cyclist safety as society has recognized that it needs to increase the number of persons using bicycles for their mode of travel. Special studies involving synchronized, multiple video cameras have always been part of collision analysis at Gorski Consulting however these became more focused toward cyclists, particularly since 2018. These studies provided details of cyclist motions and characteristics. Some of this testing was conducted along the Thames Valley Parkway in London but also at other sites where cyclist issues needed to be assessed. This focus was increased even further in 2020 as Gorski Consulting began to make specific observations of cyclists, either riding on roads, or existing on roadsides and sidewalks. The data from these roadside observations in the topic of the present article.

Since 2013 over 5000 cyclist observations have been made by Gorski Consulting along various roadways in London. The majority of these observations took place since 2020. The table below provides a glimpse of some of the characteristics of these cyclists. This table also provides some information about the differences found at four sites in London.

In the above table it can be seen that the percentage of observed female cyclists throughout the City of London has been about 13.8%. This is obviously small. There have been a number of theories discussed in the research, much of it based on interviews of females and why they do not ride bicycles.

The above table also shows that the percentage of cyclists wearing helmets throughout the City has been about 35.5%. If one were to relate this to seat-belt usage in motor vehicles the percentage of helmet users is substantially smaller than those wearing seat-belts in cars. Yet occupants of cars are protected by an additionally wide range of safety devices which generally make occupants of motor vehicles much safer than cyclists, beyond the mass difference.

The above table also shows that cyclists observed to be riding in the lane of a roadway or in a designated cycling lane is 34.6%. The rest of the cyclists were found either riding on a sidewalk, walking their bike on a sidewalk of stopped on a sidewalk. Since laws of the City of London and the Province of Ontario prohibit cyclists from riding on sidewalks this result makes for interesting discussion.

The results from the selected four sites shown in the above table will be reviewed in the following segments of this article.

Views of Sites Where Comparisons Were Made

1. Hamilton Road

Hamilton Road is an arterial roadway in the south-east of the City of London. Historically it used to carry motor vehicle traffic out of the City and toward the slightly larger City of Hamilton, Ontario. The area of Hamilton Road selected for study here is about 4.4 kilometres in distance from Maitland Street at the edge of downtown, up to Highbury Ave in the south-east of the City.

Over time many small, independent businesses developed along this road which was originally just two lanes in width. A number of years ago Hamilton Road was widened to four lanes with no median between the two directions of traffic. While this widening helped with the flow of motor vehicle traffic it also created a problem for vulnerable users, such as pedestrians and cyclists, who sometimes needed to get across the four lanes.

Recently several cyclist fatalities have occurred along this stretch of Hamilton Road. While basic information about these occurrences was released by local news agencies nothing of any usefulness was revealed about how these fatalities occurred and therefore how cyclists and drivers of motor vehicles could prevent such incidents.

Observations of cyclists along this roadway revealed that there were slightly less female cyclists (12.8%) than the City average. Larger differences were noted in helmet use (only 25.2% versus 35.5% city-wide) and more cyclists were observed not riding on the road (26.4% versus 34.6% city-wide. When compared to the other three sites these data suggest that Hamilton Road is an unsafe location for cyclist travel.

In this eastward view from April, 2022 we can see the four lanes of motor vehicle traffic on Hamilton Road and a westbound cyclist riding on the north sidewalk of the road. While laws prohibit cyclists from riding on a sidewalk this view shows the danger posed to the cyclist if indeed he followed the law and rode in the lane shared by motor vehicles.
This view on Hamilton Road at Adelaide Street shows a cyclist stopped within the westbound lane with minimal room between the curb and adjacent SUV. Similarly, an elderly female with her back turned reminds viewers that vulnerable users of Hamilton Road also exist.
In this view of Hamilton Road looking west from west of Rectory Street we can see a cyclist attempting to cross the four lanes while holding a parcel and not wearing a helmet. These are the types of cyclists and behaviours that need to be documented and considered before decisions are made about permanent solutions to the road’s safety problems.

2. Dundas Street

Much like Hamilton Road, Dundas Street east of Highbury Ave is an arterial roadway with conditions that are unsafe for cyclist travel. The segment of Dundas reviewed in this study is from Highbury Ave eastward to Clarke Road. Dundas has remained a four-lane roadway for well over half a century. It benefits from a centre-left-turn lane which is often used by pedestrians and cyclists when needing to cross this busy roadway.

In this view of Dundas Street looking eastward near First Street two cyclists are observed in the centre left turn lane at an unusual time of minimal motor vehicle traffic. Normally such motions would be difficult for cyclists when traffic volume is normally more dense. Unlike Hamilton Road here cyclists gain some protection from the existence of the centre turn lane.

The above table shows that significantly less female cyclists have been observed on this roadway (9.8% versus 13.8% city-wide). Helmet use is also less than the City average (22.7% versus 35.5% city-wide). And cycling on a lane is very low compared to the City average (10.2% versus 34.6% city-wide). These data indicate that, like Hamilton Road, Dundas Street is an unsafe location for cyclist travel.

In this view looking eastward on Dundas Street at Second Street a cyclist is observed riding in the eastbound lane while a pick-up truck is changing lanes to pass the cyclist. While the cyclist is wearing a traffic vest it is partially covered by a black knapsack. This is a dangerous area for cyclist travel in the lane and the vast majority of cyclists prefer to break the law and ride on the sidewalk.

3. Ridout – Upper Queens

In contrast to the data from Hamilton Road and Dundas Street, the data from the busy collector road of Ridout-Upper Queens shows far safer cycling conditions. The section of Ridout examined here is from Horton Street at the south edge of the City’s downtown, through the community of Old South and toward the newer community toward Ferndale Ave where Ridout is re-named Upper Queens. This roadway travels north-south. It carries traffic from trendy locations such as Wortley village which is one of the more desirable locations of the City. The City has installed a painted cycling lane along this roadway and the benefits of this can be seen in the cyclist observational data.

In this view looking north along Upper Queens near Chiddington Ave the existence of the cycling lane is clearly visible and a cyclist with bright clothing, a bright headlight and a helmet is seen riding southbound within the cycling lane. Painted cycling lanes become less safety when they exist in areas of horizontal and vertical curves. Although Upper Queens contains some minor vertical curves the full length of Riddout-Upper Queens is generally straight with minimal horizontal curves.

Female cyclists along this roadway were observed to be higher than the City average (15.7% versus 13.8% city-wide). Helmet use by cyclists along this roadway was exceptionally high (78.9% versus 35.5 city-wide) and the percentage of cyclists observed using the cycling lane was very high (78.9% versus 34.6% city-wide). Thus female cyclists would appear to have less concern riding on this roadway and all cyclists used their helmets at an exceptionally large percentage.

This view is looking northward along Ridout Street near Grand Ave. This “zoomed in” view has been purposely selected to highlight an important fact about the differences in roadways experienced by drivers of higher-speed motor vehicles and cyclists riding at lower speeds. Roadways that appear to be straight in a cyclist’s point-of-view are experienced differently by drivers of motor vehicles because the length of the roadway is compressed or “zoomed in” because of the higher speed motor vehicle travel. Thus, as shown above, slight horizontal curves are more exaggerated and must be accounted for by turning a steering wheel to stay within the centre of a lane. Often motor vehicle drivers are not attentive enough to these changes and can allow their vehicle to wander into a painted cycling lane. This concept is rarely discussed with cyclists.
In this view of a southbound cyclist on Upper Queens we see a more expensive cargo bike that would a rare sighting in areas like Hamilton Road and Dundas Street. This view highlights the importance of cyclist observations and understanding the characteristics of cyclists using a particular roadway and the purpose of their trip.

4. Colborne North Of St James

Results similar to the Ridout-Upper Queens roadway were observed on Colborne Street near St James Street. Colborne Street runs north/south north of the City’s downtown. Colborne travels through the Old North neighbourhood which is also a desirable real estate location. Here observations were made at a point just north of St James Street. This specific location was selected because in 2022 Gorski Consulting was in the process of gathering cyclist data in preparation for the City’s installation of a new, painted cycling lane. The site has been included in this discussion because of the unusual character of the observations made in 2022.

This Googlemaps view of Colborne Street is looking south toward St James St before a cycling lane was installed in 2023. The southbound lane is exceptionally wide and there are wide grass boulevards on both sides of the road. The road is also straight. These features made it desirable for a cycling lane however a vast majority of cyclists were already using the road for their travel rather than riding on the sidewalk.

From the 2022 data at the Colborne site the number of observed female cyclists was significantly higher than the City average (25.6% versus 13.8% city-wide).

The number of cyclists wearing helmets at this site was much higher than the City average (62.2% versus 35.5 city-wide. But this average was lower than at the Ridout-Upper Queens site. What was interesting however is that there was a large difference between males and females with respect to helmet use. Only 56.7% of males were observed to wear helmets yet 78.3% of females were observed to wear helmets.

Even though a cycling lane was not yet in existence in 2022 the number of cyclists riding within the road lane was exceptionally high (97.8% versus 34.6% city-wide).

This photo was taken in 2022 on Colborne St at St James. Red markers were placed on the pavement in order to study the lateral position of cyclists and motor vehicles before a painted cycling lane was created in 2023.

Discussion

This article has reviewed the results of cycling observations in London, Ontario. Data has been presented from a city-wide perspective showing the characteristics of over 5000 cyclists over a period from 2013 to 2024. These data were then compared to characteristics of cyclists at four local sites in the City. Two sites, Hamilton Road and Dundas St presented evidence of poor safety for cyclists. Two other sites, Ridout-Upper Queens and Colborne Street showed evidence of reasonably good safety conditions for cyclists. The purpose of these discussions is to draw awareness to the importance of studying cyclists as they travel or exist on roadways before conclusions are drawn about what permanent and costly changes are made to the roadway infrastructure to better accommodate cyclists. A thorough understanding of the details surrounding cyclist characteristics, the reasons for their journeys and the actions they undertake are crucial to developing an infrastructure that is sensitive to the unique needs at specific roadway sites.

City of London Has Difficulty Accepting Citizen Advice

While we do not expect, nor need, a citizen uprising, some level of non-apathetic interest in the goings on of government keeps our society healthy.

To put it in astrological terms the City of London often operates like a black hole. A very large amount of data, analysis and general information is created in its operations but very little escapes into the public domain. A recent controversy surrounding the City’s Mobility Master Plan (MMP) is an example of this black hole functioning.

On the surface the City appeared to be open toward informing the public about its plans for transporting citizens within its jurisdiction through to the year 2050. Billboards were erected through the city announcing that four public information sessions were prepared where Londoners could examine the City’s future plans. In the midst of these arrangements news became reported that one of the City’s advisory committees expressed criticisms about the MMP and how its decisions were generated. The critical report came from the Integrated Transportation Community Advisory Committee (ITCAC). Previous politicians had dissolved several such citizen committees in the past such that the ITCAC was only one of the few left standing. And politicians determined that the ITCAC would also be dissolved in 2025 leaving no official citizen participation.

Why Is Citizen Participation Important?

There are numerous examples where the City of London operates in unaccountable ways that are unhelpful and sometimes dangerous to its citizens. An example is shown in the photos below, taken recently at the road construction taking place along Wellington Road in London.

In recent years the City of London has failed to ensure that road construction projects within its jurisdiction comply with safe practices. While “guidelines” have existed for decades in manuals from various transportation groups the City has recently chosen to ignore them. With respect to roadway markings there are explicit details in existence that explain how these markings need to be created, along with proper signage, to guide vehicles through construction zones. Those procedures are not being followed in London. A number of these problem areas have recently been reported on the Gorski Consulting website. The following photos provide another example for traffic operating westbound on Bradley Ave and travelling through the intersection at Wellington Road.

In this recent photo taken on January 17, 2025, we see the view looking westward on Bradley Ave and approaching the busy intersection with Wellington Road where road construction has been in existence for a number of months related to the Bus Rapid Transit project. The driver of the white vehicle is attempting to travel within a westbound lane that has a yellow, centre-line painted within the lane. The lane itself is extra-wide so that it is almost twice as wide as a typical lane.
Unknown to the westbound driver on the right the lane ahead terminates on the other side of the intersection. Quick thinking is required to decide whether to pass the vehicle on the left or to steer behind it.
In this instance the westbound driver on the right chose to drive ahead of the driver on the left because the right lane was not longer in existence. Such forced quick decisions are not always successful. Other confusing markings shown here are the existence of two westbound stop bars.

In scenarios like those shown above collisions occur that are of a sideswiping nature and the threat of major injury is low. But significant costs can be incurred by both drivers from damage to their vehicles. Current mandatory collision reporting thresholds have risen to over $5,000 in total cost so that such an event would be unlikely to be attended by an “independent” police officer who could officially document fault. In reality London City Police are paid by the City of London and their independent assessment of City fault is questionable. Instead fault is determined by insurance companies based on predetermined “Fault Determination Rules” that are based on the geometry at which vehicles collide and not based on the reality of who was actually at fault. The result may be that both drivers could be viewed at fault, their insurance rates will rise but no fault will be placed on the City of London for causing the collision.

The City of London operates a well-equipped Risk Management Department with lawyers whose purpose is to protect the City from liability. Many such Risk Management departments advise city politicians and its staff to hide road safety problems that could bring a claim against the City. In this manner the City comes to prey on innocent citizens of London who are not in a position of financial strength to negotiate with a large Risk Management team. Without independent public scrutiny such operations get out of hand as there is no independent authority to watch over the development of unethical actions. This is just one example as to why citizen participation is extremely important in keeping an eye of City operations. Citizen committees cannot be just puppet structures that rubber stamp every action of the City. These independent committees must be given sufficient information about how City operations take place in order to ensure the proper functioning of municipal government.

Resignation Letter of Vincent Lubrano III

Before the ITCAC could be officially dissolved one of its members, Vincent Lubrano III, decided to write a formal resignation letter effective December 31, 2025 (although this date may have been a typo and possibly was meant to be December 31, 2024). Mr. Lubrano wrote that his resignation was “…in direct protest of the City Council’s decision to dissolve the ITCAC”. He further indicated that he was “…deeply troubled by the process used to eliminate an Advisory Committee, whose primary Term of Reference is to provide advice and guidance on the Mobility issues in this city…”.

It was clear that Lubrano was upset with the process as his comments in his letter continued: “The manner in which it was handled reflects a stunning lack of respect for the significant personal time and effort that ITCAC members invest…” and “…It became clear that Council views this Advisory Committee as a road block to be removed as opposed to a valued resource…” and lastly: “This protest is the only means we have to highlight the inconsistency between the Council’s stated commitment to public input and its actual practices.

These were harsh words. Without context or a detailed understanding of the goings on between the ITCAC and the City it would be difficult to judge where the truth lies. But from the experience of Gorski Consulting much of what Mr. Lubrano stated is accurate. In 2019 Zygmunt Gorski became a member of two City of London Advisory Committees. It only took a matter of a few meetings to reveal that the City was not interested in independent advice. The City Clerk controlled what agenda items were included in any meeting and if the Clerk did not like a proposed item it was simply excluded. So committee members could not even discuss issues of importance amongst themselves. Gorski resigned within a few months for reasons similar to that expressed by Lubrano.

ITCAC Report of December 16, 2024

One can look at the report of the ITCAC from December 16, 2024 to examine if its complaints were valid. It would appear that the City of London created a team that was responsible for generating the MMP and the ITCAC was interacting with this team by providing independent comments and advice. The ITCAC report demonstrated repeated instances where the MMP team provided minimal for no details about how it developed its plans. This was essentially a black hole not allowing information to escape about how the City was operating.

A consulting firm called Arcadis was mentioned as being part of the MMP team. Arcadis advertises itself as a global firm, operating in over 30 countries with over 36,000 employees. It reports to hold an office in London on Oxford Street near Beaverbrook Ave. The role of Arcadis in the MMP team was not made clear, not even by Mr. Lubrano or the ITCAC. And it is possible that they actually know very little about the involvement of Arcadis. The City of London appears not to have provided any public information about Arcadis and if any studies or data have been generated by the firm.

In part the ITCAC complaints about the MMP team process can be encapsulated by the following segment of the ITCAC report:

On reviewing the reports and presentations from the MMP team, various factual errors, contradictions, and gaps have been noted. This casts doubt on the thoroughness and competence of any analysis that has not been shared with ITCAC or the public. If we cannot trust the analysis without expert review, how can we trust the resulting recommendations? Council is dependent on competent, well-reasoned, evidence-based recommendations from expert and experienced staff and consultants. A very strong case must be made to counter any tendency towards decision-making based on misinformation, emotion, partisan ideology, beliefs based only on personal anecdotal experience, populist politics, etc.

Again, much like Mr. Lubrano’s resignation letter, these words of the ITCAC represent strong criticisms. There is particular mention of “… decision-making based on misinformation, emotion, partisan ideology, beliefs based only on personal anecdotal experience, populist politics” which seems unusual. It is not clear, and it may not be possible to know what circumstances generated these comments.

Mobility Master Plan Drop-In Public Meetings

Some understanding of the City’s operations can be gained from examining what was reported to the public during its information meetings about the MMP. Gorski Consulting attended one of those meeting and the following was observed.

The attended meeting took place in a large room surrounded by numerous billboards positioned around the room’s perimeter and visitors were encouraged to walk around and view each board. The boards appeared to be grouped into areas reflecting the segments of the MMP. So boards located closest to the entrance door displayed general information about transportation systems in London. Other boards contained more specific information about mass transit, cycling networks and pedestrian issues. Members of City staff stood at various points associated with their areas of expertise.

One of the first boards showed the general philosophy of expected changes in the modes of transportation in the City. The content of this board is shown below.

The displayed data showed that the City was expecting to shift the modes of transportation from personal use vehicles to greater involvement of “walking cycling and transit”. With respect to these categories the billboard showed that in 2019 “walking cycling and transit” represented 23% of the City’s transportation and this was expected to increase to 32.5% by the year 2050, or slightly less than a 10% increase.

It was obvious from viewing the billboard that the categories of “walking cycling and transit” were all grouped together so that there was no information about the current levels of each individually. It would seem reasonable that the City was able to calculate these individual items otherwise they could not report the total of 23%. But it is not clear why they did not itemize these important modes separately. Again, it reflects the general process of the City’s providing only minimal information to the public.

While discussing the mode change with one of the City’s staff it was revealed that there was no specific plan that has been developed as to how the City intended to create the mode shift that they reported. Specifically with mass transit the City official stated that they operated on the basis of “if you build it they will come”. Meaning that, if the quality and quantity of mass transit is increased then ridership will naturally increase. These are very general beliefs without any specifics.

Another billboard was entitled Road Safety, as shown below. This was focused on London City Police data from the year 2023. The data contained in this billboard is misleading.

In general police data is known to be incomplete. While collisions where fatalities occur are likely to be fully reported, other categories such as injury-producing collisions and property damage collisions are less complete. This has been known throughout the history of collision reporting but in recent years the thresholds at which collisions are required to be reported have risen.

The above data is of greater concern with respect to cyclist collisions. Here the City has reported that only 70 persons were injured in 2023 when riding a bicycle. The City ought to have known that this information is greatly in error. This information is taken from police reported data which is greatly incomplete – something the City would be well aware of. Recent research reported several times on this Gorski Consulting website taken from hospital emergency department data shows that only about 8% of incidents of cyclist visits to emergency departments are reported in police data. So the police know nothing about the 92% of cyclist injury incidents that actually occur. By reporting the police data in the manner that they have the City of London has greatly misinformed its citizens about an important safety issue.

While the MMP is reported to be in its infancy there are additional concerns about its proposed actions at selected safety problems such as the area of Hamilton Road between Maitland Street and Highbury Ave. A billboard shown at the public meeting indicated that changes were being proposed in the near future along this roadway. What those changes are is not clear. When asked about those changes a City staff member could only hypothesize that they might include a reduction in the four lanes of traffic to just two lanes and then new cycling lanes would be installed. Although there is public information that 3 fatal cyclist collisions occurred along this stretch of Hamilton Road in the past 5 years no further information about cyclist collisions was available. When asked if the City was conducting any additional investigations with respect to cyclists on Hamilton Road it was reported that no such activity was taking place. The City staff member confirmed that cameras located at important intersections in the City are able to gather information about traffic volumes, characteristics and patterns. But it was unknown if any such studies were being conducted along Hamilton Road. The data from these permanent locations is likely analysed but it is unknown who does that analysis. It is unlikely that the ITCAC is informed of the results of such analysis.

The City staff member was also asked about their portable “Scout” camera installations which could be deployed to study certain safety-problem locations in the City. The City staff member confirmed the existence of these portable units and that the collected data is taken off-site to a private firm where it is analysed. But the staff member was unaware of any such installations being placed on Hamilton Road.

Summary

As expressed in the City of London ITCAC and in the resignation letter of Vincent Lubrano III the City of London is involved in a secretive, black hole proceeding where little information is being released to the citizens of London about the details of the Mobility Master Plan (MMP). It appears that the City is hiring private firms that conduct a variety of analyses that are not being shared in the public domain. When the City’s advisory committees complain about this process they are being shut down as is the case with the ITCAC.

Over the years a member of the City’s council who has been particularly vocal about shutting down advisory committees has been the Deputy Mayor, Shawn Lewis. In 2019 he was instrumental in attacking a report from the Cycling Advisory Committee, a group of unpaid, citizen volunteers. That committee presented information and ideas that were counter to Lewis’ vision. Instead of accepting that an opposing view is essential to the proper functioning of municipal government he instead went on to attack the committee. As reported by London’s CTV News in a article of February 22, 2019: “The City’s Deputy Mayor, Shawn Lewis appears to have led the charge in removing citizen advisory committees altogether.”

And again in an October 24, 2019 CTV News article: “At Tuesday evening’s meeting, Lewis stated that the advisory committees are there to “advise” and not to direct council. The comment prompted mixed reaction on Twitter…” and further: “The role of advisory committees is to advise us on the stuff we’re working on. It’s not to reinvent the wheel; it’s not to call to question the decisions we’ve made.”

And finally in an October 27, 2919 CTV News article: “Lewis said he wants to see advisory committees reviewed for overlap and effectiveness, saying the cycling group has gone “rogue.”

Through Lewis’ efforts the Cycling Advisory Committee was disbanded by the City. And the various volunteers from several committees transferred into a newly-formed Integrated Transportation Community Advisory Committee (ITCAC) which is now also being disbanded.

Lewis has previously complained that interaction with citizen advisory committees costs a considerable amount of time of City staff and this is wasted time. This is a strange viewpoint. In a society labelled as “democratic” the information about important issues is released to the public which becomes informed, leading to informed opinions expressed by a wide spectrum of the populace. When politicians view this transfer of information as a waste of time, and a needless expense, it is a disturbing development. Dictatorships are highly effective in directing how matters will be dealt with but the problem with such a system is that it only reflects the needs of the dictator, not those of the people as a whole.

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