Great principles, with significant gaps

Thank you for the careful planning that has clearly gone into this document. As a regular pedestrian, cyclist and user of public transport, as well as as a citizen and professional committed to supporting a more sustainable, climate resilient and just urban future, I view having such a strategy as a crucial first step in the right direction.

I also strongly applaud the focus on traffic safety and the disproportionate burden of risk carried by marginalised and oppressed communities. The focus on intra-governmental co-operation is also welcome. I look forward to viewing the detailed implementation plan, which I hope will also be made publicly accessible for comment. It is utterly essential that the

However, I have the following significant concerns:

1. Figure 6 is valuable (also statistics in 6.1), but not sufficiently clear. How many pedestrians and cyclists were killed in each district in each year? What is the total number? And what about serious injuries. What is the long-term trend? What types of motor vehicles (SUVs, double cabs?) and motorist behaviours were involved? Were motorists ever successfully prosecuted? The map also makes clear the risk associated with major stroads, which is unfortunately not explicitly noted. The City should be accountable for the policies and targets proposed. This requires transparency in reporting of relevant data.
2. There is not nearly enough emphasis on strict enforcement of laws prohibiting reckless driving and parking by motorists. Such life-threatening behaviour has become utterly normalised in Cape Town, as elsewhere in South Africa. Furthermore, where enforcement of traffic law is mentioned explicitly in the strategy (page 36, table point 5), transgressions by cyclists and pedestrians are equated to those by motorists. This fundamentally misses the point. When motorists park on sidewalks, pedestrian crossings or cycle lanes; or speed across pedestrian crossings and behave in similar ways, this directly threatens the lives of vulnerable road users. Millions of pedestrians and cyclists die or are seriously injured in this way. Most pedestrian and cyclist transgressions are either a minor inconvenience or become a risk only in combination with high speed motorised traffic. Enforcement should prioritise those who place the lives of other road users at risk. Traffic officers in Cape Town routinely disregard pedestrian safety in their behaviour.
3. More broadly policies need to be developed to encourage a change in motorists’ attitudes towards roads. Accessing public roads in a private vehicle should be regarded as a great responsibility and as a privilege, not a right, and subject to strict conditions. Otherwise, all other road users will continue to live at the mercy of the whims of distracted and reckless motorists. Motorists who cross red pedestrian traffic lights at schools where learners are crossing (this happens frequently) should be branded publicly as child murderers (this sort of approach appears to have worked in NL...). Radical intervention is needed. 
4. The use of the term “accidents” to refer to traffic collisions is deeply concerning (although I note it is only used in parts of the document). Recent literature on the topic clearly demonstrates that using this term reinforces tacit acceptance that mass death and serious injury in traffic is unavoidable and isn’t really anyone’s responsibility or fault. The reality, in contrast, is that we choose to regard traffic violence as acceptable and that both infrastructure design, social attitudes, power dynamics and systematic injustice overwhelmingly determine who is at risk, where and when.
5. It is not clearly apparent how the City plans to approach conflicts that will inevitably emerge when motorists’ hegemony on the roads of Cape Town is challenged.  Making walking convenient, fast and relatively more pleasant, which is crucial for increased uptake, will require reversing strategies and policies implemented and supported by powerful groups and for a, particularly CIDs and neighbourhood watches. Locking parks, overpasses and subways severely negatively affects walkers and cyclists, especially since this appears to be done arbitrarily and with no signage to indicate times of access or alternative routes. Accessibility and routes removed from heavy traffic and pollution are essential.
6. Similarly I am strongly opposed to any suggestion that infrastructure should be developed to discourage pedestrians from risk taking behaviours. Infrastructure be adapted to reduce the risk itself. Alcohol use by motorists is far more structurally dangerous and should be the focus of related interventions (Personally, I don’t drink at all). The framing used in 4.2.5 in relation to young men comes dangerously close to victim blaming.
7. There are simple actions the City can take to demonstrate that it really no longer regards pedestrians as third-class citizens, for example, stopping the practice of disabling all pedestrian traffic lights during electricity supply disruptions, while keeping car traffic lights operational.
8. There are many other valuable concerns raised by interest groups and well-informed people who have much more personal and relevant experience of pedestrian infrastructure routinely used by the communities and people most exposed to traffic risk. Please take these suggestions seriously and regard them with the necessary care