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15 August, 2018

Reply from Transport for NSW

"Your comments have been taken into consideration, along with other submissions received during the public consultation, in finalising the draft Roads Regulation 2018. The proposed clause in question (clause 41) has been removed from the draft Regulation and current provisions about regulating access to tunnels by signage remain unchanged from the current regime."

22 July, 2018

To: Transport for NSW


Draft Roads Regulation 2018

Thank you for the opportunity to comment on the Draft Roads Regulation 2018.    Bicycle NSW has been the peak bicycle advocacy group in NSW for over forty years, and has over 30 affiliated local Bicycle User Groups throughout NSW.

We wish to comment specifically on Clause 42, which states:

41 Pedestrians and cyclists prohibited in tunnels

(1) A pedestrian must not travel in a tunnel.

Maximum penalty: 30 penalty units.


(2) A person must not ride a bicycle, animal or animal-drawn vehicle in a tunnel.

Maximum penalty: 30 penalty units.

While we agree that some tunnels are unsuitable for bicycle riders, we cannot agree with a blanket ban on cycling in tunnels.  There is no definition of what constitutes a “tunnel”.  Although Clause 49 allows exemptions, there are none listed in the Draft.

There are a number of tunnels which are presently used quite safely by bicycle riders.  In some of the following examples, riding is encouraged by marking the shoulder as suitable for riding with a PS2 cycle symbol:

  • M1, Stotts Creek
  • M1, St Helena Tunnel
  • A1, Pine Creek
  • M2, Epping
  • General Holmes Drive, Mascot

Undoubtedly, there are further examples through NSW.

Rather than a blanket ban on riding in tunnels, this Clause should be reversed in its operation so as to refer to a list of specific tunnels where riding is prohibited.  This list would be in (say) Schedule 3, and include tunnels such as Sydney Harbour Tunnel, Eastern Distributer Tunnel, Cross City Tunnel, and M5 Tunnel.  The link between riding a bicycle and riding an animal needs to be removed.

The present Clause 41 is poorly drafted, and is not acceptable without major change.  Should you wish to discuss these matters further, please contact Bicycle NSW.