On Friday last, 28 May 2021, Cyclist.ie made a detailed submission to the Department of Transport on the National Investment Framework for Transport in Ireland, or NIFTI for short. 

According to the department’s website (where you can find all of the background papers on NIFTI:  

NIFTI is the Department of Transport’s contribution to Project Ireland 2040, Government’s long-term strategy for accommodating population growth in a sustainable manner and making Ireland a better country for all of its people. NIFTI has been developed to ensure that our transport sectoral strategy is underpinned by and supports the achievement of the spatial objectives and National Strategic Objectives set out in the National Planning Framework.

So the question is, will the new investment framework be ‘nifty’ in a traditional sense of that word? It’s too early to say because the final NIFTI document is not due to be published until Q3 of this year, but we are doing our best within Cyclist.ie to help shape what the document looks like. 

You can read our full submission below, but the essence of our it is that transport policy-makers in Ireland need to engage far more seriously with the concept of decarbonisation to the degree that we need to have net zero emissions by 2050 across all sectors – and to have a 50% reduction in emissions by 2030, less than 10 years away from now. 

We stressed throughout our submission that transport investment needs to be massively weighted and front-loaded towards active travel and public transport over the coming decades. We raised in our submission the point that the digital revolution in recent years has enabled people to work on screens while travelling on trains or buses, but crucially this is not possible when one is driving. We urged the Department to promote intermobility so that one can travel to/from rural communities in a low carbon way – with the bulk of the distance covered on public transport – and to do this there needs to be proper funding of conveniently located, high quality and secure cycle parking facilities at every single train and bus station (and stop) in the country, and with high capacity facilities at the bigger stations such as one sees in the cities of Utrecht (NL) and Munster (Germany) for example.

Additionally, we made the point that there needs to be serious engagement by the Department and Transport Infrastructure Ireland with the reality of “induced demand” – i.e. that the provision of extra road capacity results in a greater volume of traffic. The evidence for this has been mounting for 25+ years – e.g. see Goodwin’s 1996 paper entitled Empirical evidence on induced traffic. The policy of seeking to expand road capacity is completely at odds with our commitments to decarbonise transport. 

A sincere thanks to our talented team of volunteers who fed into the preparation of our full submission below – all done at rapid pace while juggling lots of other campaigning jobs. Kudos to you all! 

FULL CYCLIST.IE SUBMISSION ON NIFTI

Section 2: Supporting the Project Ireland 2040 Vision

The National Planning Framework has established a clear direction for the sustainable development of Irish society in the coming decades, as articulated by its ten National Strategic Outcomes. How can transport investment support this vision?

• All of the 10 national strategic outcomes have their part to play. However, the decarbonisation of all transport, both public and private, is the most critical and cross-cuts all broad outcome areas.
  
• While the proposed national Sustainable Mobility Policy (SMP) concentrates on public transport and active travel, the scope of this SMP policy needs to be revisited – and broadened out. All private transport and commercial transport needs to decarbonise and become sustainable, not just the active and public strands of it.
  
• In considering the proposed transition to Electric Cars, one needs to bear in mind that burning fossil fuels to provide energy for mining, drilling, processing and transportation of materials for battery and other vehicle components leads to CO2 emissions embodied in a typical EV. See https://sitn.hms.harvard.edu/flash/2019/how-electric-cars-can-become-truly-green-once-and-for-all/. Irish transport policies must take into account the energy and emissions costs of creating the vehicle and disposing of it at the end of its life; only considering the emissions when the vehicle is in use does not provide a complete picture. This needs to change.
  
• Clear policies on demand management and the suppression of unnecessary motor vehicle travel by businesses and individuals must be implemented in order to increase active and public transport travel and restrain unfettered growth in private/commercial movements.
  

Section 3: Delivering the National Strategic Outcomes

How can transport investment support the delivery of compact growth in our towns and cities in the coming years?

• Resource Local authorities with the required professional staff to plan, promote, and implement the necessary projects in line with national policy.
  
• Implement major ‘place making’ public developments so as to encourage social and business improvement.
  
• Adopt at a national level the 10 minute town / 15 minute city policy with appropriate practical measures.
  
• Improve the quality of data collection on traffic movements, both locally and nationally, and include in this pedestrian, cycle and personal powered transport – and intermodal travel.
  
• Provide greater resources for road safety research and improvements.  The cost to the economy and society of the yearly toll of road injuries and deaths needs to be more fully accounted for and acted upon. The 2020 International Road Safety Conference ‘Stockholm Declaration’ stated as follows: “Acknowledge that the overwhelming majority of road traffic deaths and injuries are preventable and that they remain a major development and public health problem that has broad social and economic consequences which, if unaddressed, will affect progress towards the achievement of the SDGs;” We must adopt a clear Vision Zero approach to road safety and a safe systems approach to any transport developments in order to reduce economic and social losses. See https://www.roadsafetysweden.com/contentassets/b37f0951c837443eb9661668d5be439e/stockholm-declaration-english.pdf 

How can transport investment enhance regional accessibility in the coming years?

• Transport investment needs to be massively weighted and front-loaded towards public transport. Of particular relevance here is the digital revolution in recent years which enables people to work on screens while travelling on trains or buses, but crucially which is not possible when one is driving. This point needs to be fully acknowledged when arriving at a new transport investment framework.
   
• Review transport/freight companies and their locations and possible grant system to encourage coordination of resources and possible relocation of businesses closer to major transport hubs and routes.
  
• Provide inter town segregated greenways with adequate width and sealed surfacing to attract commuters as well as recreational cyclists, similar to the European cycle super highways – see for example https://ec.europa.eu/transport/sites/default/files/cycling-guidance/cycle_superhighways_2018.pdf 

How can transport investment strengthen rural economies and communities in the coming years?

• There needs to be an additional focus on strengthening the local public transport bus system and ensure it connects seamlessly with the rail system.
  
• In regard to promoting intermobility so that one can travel to/from rural communities in a low carbon way, there needs to be serious funding of conveniently located, high quality, secure and attractive cycle parking facilities at every single train and bus station (and stop) in the country, and provide high capacity bike parking facilities at the bigger stations taking inspiration from the state of the art facilities which one can find at train stations such as in the cities of Utrecht in Nl and Munster in Germany.
  
• Review the practical and economical use of the public transport fleet to improve the effectiveness of transport options particularly in rural areas.
  
• Accelerate the implementation of EV charging points countrywide. 

How can transport investment deliver sustainable mobility and encourage modal shift in the coming years?

• There needs to be serious engagement by DoT and TII with the reality of “induced demand” – i.e. that the provision of extra road capacity results in a greater volume of traffic. The evidence for this has been mounting for 25+ years – e.g. see Goodwin’s 1996 paper “Empirical evidence on induced traffic” – https://link.springer.com/article/10.1007/BF00166218. The policy of seeking to expand road capacity is completely at odds with our commitments to decarbonise transport.
  
• Public transport options need to be improved greatly, particularly rail and bus. Currently we do not have a rail “system”, we have mainly a series of radial lines running to / from Dublin.
  
• Every local authority in Ireland needs a high quality cycling and walking policy – https://www.bypad.org/. 
  
• In rural Ireland, a policy of ‘rothar road’ development should be implemented in line with the Vision for Cycling –  https://cyclist.ie/ruralvision/. 
  
• Promotion of the use of sustainable transport options needs to be upgraded to counter-balance the impact of car advertising.
  
• People who choose to cycle to their destination need to know that it will have secure bicycle parking and that workplaces have drying rooms. State agencies, public services and health bodies in particular have an obligation to ensure that employees and visitors are provided with bicycle parking.
  
• The Safe Routes to School scheme announced in 2021 is welcome, but if we are to enable sustainable mobility on the school run, funding in future years needs to be greatly increased as, at the rate of 100 schools per year, it will take too long to cover our 3000 primary & post primary schools.

How can transport investment in surface access support high-quality international connectivity via our ports and airports in the coming years?

• Again, in the context of decarbonisation, the rail and sail journeys need to be far more seamless and pedestrian / cyclist friendly. To take the example of the trip from Dublin city via Dublin Port and Holyhead to London, the existing trip for pedestrians is unnecessarily fragmented, unattractive and grim. If seeking to promote surface transport, we need to make proximate trips – such as Ireland to Britain – much more attractive.

How can transport investment help us to transition to a low carbon and climate resilient society in the coming years?

• See many of the points above, but the overarching policy needs to be centred around a radical shift from investment in new roads to investment in public transport and active travel; otherwise our national carbon footprint will continue to expand.
  
• Demand management must be implemented to suppress growth in private vehicle travel.
  
• Introduce a scrappage scheme for cars to be replaced by e-bikes or e-cargo bikes. Cf. the scheme introduced into France recently whereby car users are given a €2500 voucher for an e-bike. See https://ecf.com/news-and-events/news/electric-bikes-replace-polluting-cars-france-introduces-innovative-scrappage.
  
• Last mile low carbon delivery systems must be implemented in towns and cities to reduce need for access for HGVs and large vehicles to town centres.
  
• Introduce Zero Emission Zones and low traffic neighbourhoods in towns and cities.
   
• Introduce a ban on SUVs in city centres – as per the example in Paris. They are too wide, too high and too long for city centre streets, in addition to the emissions and negative road safety impact in relation to collisions with pedestrians.
  
• Commission and publish a peer reviewed independent study to assess the impact of reducing speed limits on motorway, N-roads and other roads on transport emissions in Ireland. 

Section 4: Transport Investment

What challenges and opportunities exist with regard to decarbonising the transport sector?

• The big challenge is to reduce the extent of car dependency and give as many people as possible the option of alternative sustainable modes of transport and being able to live without owning the depreciating asset that is a car. There is an opportunity there for the Department of Transport to transition into being a leader in supporting people to live car-free through the provision of radically improved public transport, improved conditions for active travel and high quality information to knit everything together.
  
• Encourage businesses to have virtual meetings rather than in-person ones.
  
• Obviously provide more charging points for electric cars – Norway has an estimated 16,000 charging points – Ireland has a fraction of these but we must ensure that the space for them is reallocated from cars not from pedestrians or cyclists.
  
• Complete the updating of the Common Appraisal Framework to take carbon emissions, and all ancillary issues, into consideration when appraising and making decisions on road projects.
  
• Introduce road pricing as in Sweden and London.
  
• In the future, the extent of flying must be reduced. Short haul flights nationally should be reduced – similar to what the French government is doing.
  
• Introduce a frequent flyer tax. Frequent flying needs to discouraged, not incentivised. 

What challenges and opportunities exist with regard to protecting and renewing the existing transport network?

• In particular the continued upgrading of existing transport hubs and stops to acceptable standards that enables and promotes greater public transport usage.
  
• A shift to rail, especially for freight, will reduce HGV damage to roads. 

What challenges and opportunities exist with regard to improving mobility for people and goods in urban areas?

• Provide high quality segregated cycling infrastructure to agreed high standard under new developed National Cycle Manual guidelines.
   
• Restrict the movement of private cars in areas of high pedestrian and cycling use.
  
• Reconfigure road space to reflect the person carrying capacity of vehicles.
  
• Further restrict vehicles such as HGVs and Sports Utility Vehicles which provide an increased threat to vulnerable road users in urban areas.
  
• Encourage and facilitate the use of cargo bikes for last mile deliveries.

What challenges and opportunities exist with regard to enhancing regional and rural connectivity, including to our ports and airports?

• The biggest challenge is improved public transport, including rail transport for freight, to all major ports and airports. It need to be super easy to get everywhere by public transport – currently it is not. 

Do the four NIFTI investment priorities help to deliver the National Strategic Outcomes? Should anything change about them?

We support these four priorities.

However, renewal should refer more explicitly in the documentation to our too-often-forgotten rail infrastructure, not just the road infrastructure. 

Section 5: Further Comments

Do you have any further comments to make on the National Investment Framework for Transport in Ireland?

• With the requirement to decarbonise transport completely over the next 29 years – really not a lot of time – we have a unique opportunity, and indeed legal and moral obligation, to shift the direction of transport investment in Ireland away from its utterly unsustainable trajectory to one which is in line with the ecological limitations of the planet. We cannot waste this opportunity. 
• The government’s target is to reduce carbon emission in transport but any new roads will increase emissions due to induced demand (as per Section 3 above). However, some new roads are unavoidable if we are to improve road safety at particularly unsafe locations. The increase in emissions from the induced demand must be offset by investment in additional sustainable transport schemes, which reduce carbon emissions due to change in modal share in the local authority area.
  
• SFILT and SIFLT largely reflected 20^th century thinking on investment in transport with a ‘roads first’ policy. The suite of documents did include a paper on climate change, but the paper was published before the 2015 Paris Agreement and the 2018 Citizen’s Assembly report. The inclusion of updated reports is welcome as part of NIFTI.
  
• It is accepted that decarbonisation of transport is essential to meet national targets on climate action, but the carbon impact of projects must be an essential part of decision making on project appraisal, rather than simply being noted or “taken into account”.
  
• Irish engineers generally use a largely UK database such as TRICs to predict the number of journeys generated by private vehicles. However, the result of Ireland emulating a country with one of the highest car dependency rates in Europe (rather than a country such as the Netherlands with one of the lowest), reinforces the status quo and in Ireland in the last twenty years has contributed to flat-lining in the proportion of people cycling nationally.
  
• TII sets out the calculation of future demand on national roads for the next 30 years in its Project Appraisal Guidelines for National Roads Unit 5.3 – Travel Demand Projections. As it specifies a growth rate in future years of between 1% and 3% per annum depending on the county and assumed growth rate, TII are in theory designing roads on the basis of up to 90% more trips in 2051 than at present. In recent years TII has published National Road Indicators annually which report the actual growth of traffic on the national road network. Between 2015 and 2019, the actual annual growth of traffic on national roads is even greater than the TII’s highest prediction with some regions of the country experiencing rates in excess of 5% per annum. This gives rise to questions about the sustainability and cost benefit analysis of current road plans.
  
• Phil Goodwin, emeritus professor of transport policy at a number of UK universities, has challenged the cost of carbon used in the cost benefit analysis of new roads and also how the increase of carbon emissions from cars using new roads is minimised by comparison to the percentage of overall carbon emissions. This is in contrast with employment, where additional employment, whether for 10 or 1000 new jobs, is welcomed as a positive thing rather than comparing the increase as a percentage of overall employment levels.
  
• Neither the Department of Transport nor the Joint Oireachtas Committee on Transport acknowledges in a meaningful way the central role of transport in creating unhealthy communities and the financial burden it imposes on society. If this government is to be successful, the current road projects in the National Development Plan must be completely reviewed with revised appraisals and realistic models to ensure that future investment is in accordance with current government objectives rather than ones that belong in the past.

• We wish the Department the very best in producing the final NIFTI document – and, crucially, in reconfiguring the direction of transport in Ireland in a properly sustainable way – and we look forward to engaging with you again soon.