This week Cyclist.ie made a submission to the National Transport Authority (NTA) in regard to the updated Transport Strategy for the Greater Dublin Area.

As per the NTA website, this strategy sets out the framework for investment in transport infrastructure and services over the next two decades to 2042. You can read the NTA’s draft transport strategy here.

You can read our own submission in full below.

Cyclist.ie wishes to sincerely thank its volunteers for the work involved in preparing and making this submission. It is this voluntary work and the membership subscriptions to Cyclist.ie that enables us to make these submissions.

1 – Introduction

Cyclist.ie, the Irish Cycling Advocacy Network (ICAN), is the Federation of Cycling Advocacy Groups, Greenway Groups and Bike Festivals on the island of Ireland. We are the Irish member of the European Cyclists’ Federation.  Our vision is for an Ireland with a cycle friendly culture, where everyone has a real choice to cycle and is encouraged to experience the joy, convenience, health and environmental benefits of cycling.

Cyclist.ie broadly welcomes this review of the GDA Transport Strategy, its extension to 2042, its broad objectives within the context of Climate Objectives, and its acceptance that many aspects of the original Strategy have not been achieved.  In particular, in relation to achievements on the cycling front, Cyclist.ie is highly critical of the lack of development on the 2013 GDA Cycle Network Plan to date, but welcomes the commitment to complete an updated network by 2030.

It is evident from the substantial number (4,000+) of submissions made to the initial call in late 2020, that there is great interest in the development of an appropriate transport strategy for the GDA, and Cyclist.ie congratulates the NTA on reaching out through various means, to encourage submissions.  We, in turn, have a number of other comments on the overall GDA Strategy document, which we outline below.  We also include a Summary section at the end of these comments for ease of referral.

2 – GDA Strategy 2021 – The Active Travel Perspective

2.1 Changes/Improvements from 2016 Strategy
Cyclist.ie notes the extensive positive changes in the overall approach to this latest Transport Strategy review, which is a major improvement on that produced in 2016, and deals with each area in relevant depth.  It particularly highlights and prioritises the need for an increased emphasis on sustainable travel, including Active Travel.

We also welcome the inclusion of many points raised in our January 2021 submission, but highlight below a number of items we feel should have been included, or should receive greater attention.

2.2 Cycling Related Proposals
The graphic in the Strategy outlines the broad proposals of this updated Strategy.  Cyclist.ie queries the relatively low – 12% – Bike Mode Share envisaged by 2042, which is higher than the national 10% target originally projected as part of the 2009 NCPF, but lower than what has been previously projected for the Dublin region.  This is an unacceptable  regression on previous target levels, which were demonstrably higher.  And target mode share needs to consider the timing and alignment with Climate Action Plan targets, as well as the proposed completion of the new Cycle Network by 2020 – see below.

2.2.1 GDA Draft Cycle Network
Cyclist.ie welcomes the new classification of cycle routes on the network. But, we note the reduction in overall network kms between 2013 and the latest 2021 draft proposal.  And, on examination of the individual mapping sections posted we note there are a number of omitted routes from the 2013 draft network in some areas, and the non-inclusion of some actual existing facilities, and some facilities in active planning?

Cyclist.ie would welcome a meeting with NTA officials on this issue, to clarify the accuracy of the proposed network in certain areas?

We are also happy to see the proposed ambitious completion of the cycle network by 2030, but doubt it can be achieved based on past performance.

We note that no clear figure for kilometres of the 2013 network completed to standard, has been posted in Chapter 2.2.  This would show clearly the low level of progress since 2013.

2.2.2 Traffic Management & Inter-Modal Travel Options
Cyclist.ie welcomes the proposals for increased access to public transport for people on bikes, although the proposal to only increase the number of bikes on inter city trains to 4, is disappointing, and falls below the 8 bikes, which the ECF, and the EU Parliament Transport & Tourism Committee are recommending on a European level.  These proposals are critical in helping to increase the volume of sustainable trips across the GDA.  This proposal should be revisited in the light of likely EU initiatives in this area. 

In particular we welcome the commitment to lower urban speed limits to 30kph, as declared internationally in the 2020 Stockholm declaration.  This will make our city and towns’ streets safer for all.  This issue needs to be tackled from within the Department of Transport initially by reviewing the Speed Limit Regulations, to ensure Local Authorities can legitimately introduce these lower limits, and the NTA must play an active part in this process.  

We broadly welcome the proposals to introduce more car free zones, car parking restrictions, and in particular the reduction in public service parking facilities.  In an ideal world this initiative should begin with our legislators in Dáil Éireann?

2.2.3 Personal Mobility Vehicles (PMV)
Cyclist.ie broadly welcomes the introduction of PMVs, particularly if it increases the number of people opting to use them instead of a private car.  But, it is critical that clear legislation and regulations define their usage, and in particular the power and speed levels therein.  The present level of legislation is unclear, and many E-Bikes and E-Scooters are clearly travelling beyond the 25kph cut off speed.  We welcome the NTA’s commitment to ‘respond as required to any legislation adopted’, and would welcome a clear commitment to engage with organisations such as Cyclist.ie as part of any responses.

2.2.4 Covid Learnings
Cyclist.ie welcomes the recognition outlined in Section 11.2 of the Strategy, of the valuable learnings from the trial cycle route constructions during the height of the Covid lockdowns.  As a result of these ‘trials’ many of these protected/segregated cycle tracks will remain in place.  This points to the need to recognise in legislation, as happens in other countries, the right of local authorities to trial installations, without the need for a full long drawn out planning process.  We deal with this point further, among others, in Section 3 below.

2.3 Walking, Accessibility & Public Realm
Many of the issues related to improvements in walking/pedestrian conditions, such as speed limits, junction design, permeability, public realm, and wayfinding also apply to cycling requirements.  Changes in these elements of our infrastructure can have important benefits for both cyclists and pedestrians, and also bring immediate improvements in sustainable travel numbers.

We welcome the commitment to remove slip lanes, and to narrow junctions, and would like to see these commitments moved on rapidly within a specified time frame.  Together with these suggested changes we would like to see a gradual program of improvement in side road junction design to benefit both pedestrians and cyclists, by also including raised ‘at-level’ crossings for pedestrians, clearly indicating priority for pedestrians and for private vehicles to give way.  These raised entry crossings have the added benefit for both cyclists and pedestrians of slowing down vehicles entering and leaving the side roads.  They should be introduced gradually,as a matter of course, throughout the local authorities within the GDA.  We have previously referenced these issues and others in our January 2021 submission.

2.4 Public Transport
Cyclist.ie broadly welcomes the proposals for public transport outlined in the Strategy, and we would hope that the general timelines outlined can be adhered to, particularly in the initial major Bus Connects project, which also has significant impact on proposed cycle routes. We have referred to the issue of bikes on trains above, but in general we support the proposed improvements in the DART system as well as the proposed LUAS lines.  

2.5 Roads
Cyclist.ie welcomes the retrenchment decision on the Eastern Bypass, and the proposed development of the bypass corridor for sustainable transport.  We await definitive plants for these proposals. We also welcome the  ‘Principles of Road Development’ outlined in Chapter 13.2, and the low level of proposed road developments;

We note the broad ‘place making’ proposals in Chapter 13.6, in relation to Urban Roads and Streets, but would like to see this associated with the ‘Low Traffic Neighbourhoods’ outlined in 14.6, and in particular the reduction/removal of rat runs.

3 – Missing Elements from GDA Transport Strategy?

3.1 Planning Issues
Over the past decade and more it has been obvious that most major sustainable transport and public realm schemes, including cycle related initiatives, have been inordinately delayed, or even halted, due to issues arising as part of the statutory planning processes.  Within the context of Dublin City alone we have seen innumerable project timelines being adjusted at an embarrassing rate through the years, and poor progress being made.  While there have been learnings, as a result of these problems, it is incumbent on the NTA as the overall ‘overseer’ of these projects, to examine and report on these planning issues, and recommend possible solutions.

We do not see this critical planning problem being addressed as part of the GDA Transport Strategy, and we feel it should.

3.2 Trial Projects
As referred to above in section 2.2.4 the Strategy has realised the value of Covid Trial/Temporary projects in being able to demonstrate to the general public what effects a possible long term project can have, but also to enable the designers to tweak on the ground any perceived faults or difficulties.  These trial projects, common in many countries, need to be placed on a legislative footing and must be part of this Strategy.  This would enable Local Authorities in particular to demonstrate the value of their proposals to the public.  In general they have resulted in positive outcomes for both the planning authority and the public.

3.3 Legislative Issues
There are innumerable legislative proposals that have been discussed and debated over the years, which could be initiated in order to increase the ease and safety of travel for cyclists.  Cyclist.ie has highlighted these proposals in meetings with the NTA and the Department of Transport on a number of occasions in the past 7 years.  In particular we have referenced the 2014 Transport for London (TFL) Study as an exemplar of what could be done.  It will be appreciated that this study is already 8 years in publication, and Dublin was one of the referenced cities in the lead-in study.

There needs to be a sense of urgency in translating ideas into legislation to improve conditions for cycling.  This needs to be addressed in the Strategy.

3.4 Data Evaluation & Monitoring
Cyclist.ie, in our submission of January 2021 to the GDA Strategy process, highlighted the issue of poor data/information and ongoing monitoring of active travel data.  While the areas of collection of available data sources, such as through CSO or other agencies, is referenced in Chapter 19.2 of the Draft Strategy we see no reference to improved internal collection of additional data from the NTA itself or via the local authorities, particularly in relation to active travel.  This is a serious omission.  A single ‘Monitoring Report’ in 2025, as proposed in Section 19.2.4 is woefully inadequate to address the need for assessment of progress.

It is incumbent, via this proposed Strategy, to ensure that sufficient and regular data collection is carried out, and published, to enable a true and full assessment of all projects to be progressed.  We have yet to see any such comprehensive data in the context of active travel projects.  In turn we have yet to see the upgrading of the Common Appraisal Framework used for project assessment, to enable the assimilation of the benefits of active travel and climate change.  This urgently needs to be addressed.

We call on the NTA and the Local Authorities to ensure that detailed traffic related data is regularly collected, which enables comprehensive assessment of all transport projects, but particularly active travel projects. This assessment should be combined with an updating of the Common Appraisal Framework, to ensure that all health, environmental, social and economic benefits are included as part of the assessment process.

3.4.1 Road Safety Data
We fail to understand why the national Road Safety Authority (RSA) has not been included as a data source within this monitoring Chapter 19.  As it stands, road safety data, in particular that related to serious (and minor) injuries, is simply not made available regularly or soon enough.  As a result, while we have seen road deaths generally decrease year on year recently, there has been a concomitant and frightening increase in serious injuries, as highlighted in table 5.1 of the Draft Cycle Network Report. 

The last available comprehensive and  reliable data on serious injuries dates back 5 years to 2017.  This is simply not good enough and must be addressed as it is germane to improved transport, and in particular active travel.

4 – Summary / Conclusion

As stated above Cyclist.ie gives a broad welcome to this new Draft GDA Transport Strategy, but with certain reservations and major omissions.  Our main points are as follows:

4.1 The Strategy does not address the ongoing problems with project delays, and how the planning process ‘works’.

4.2 Trial Projects, as demonstrated during the Covid period need to be addressed long term and put on a legislative footing.

4.3 There are a number of legislative proposals that have the potential to actively support an increase in active travel that have been on the table for a long time and need to be enacted.

4.4 Data gathering and assessment needs to be seriously upgraded, and NTA and Local Authorities ensure that ongoing travel related data is available to ensure rigorous monitoring of Strategy targets, and individual projects.

4.5 The RSA need to be data partners with the NTA, and  the collection, assessment, and publication of road safety statistics needs to improve to ensure road safety issues are addressed with speed. 

4.6 The low target level mode share for cycling by 2042 of 12% is a regression on previous targets 

4.7 There are perceived faults and omissions in the published Draft Cycle Network Plan 2021.  Cyclist.ie seeks to meet with the NTA to begin to address these faults.

4.8 The proposals for a minimum 4 bike places on the new trains  is inadequate in light of EU proposals for 8 bike places, and needs to be upgraded.

4.9 The introduction of clear legislation for PMVs needs to be accelerated, to ensure clarity on usage, and the safety of all road users, in particular active travellers.

4.10 We want to see a clear commitment to the quick introduction of the simple  initiatives proposed in Chapter 10 related to junction design and pedestrian crossings, which can have immediate impact.

Colm Ryder
[email protected]