Cyclist.ie made a submission today, Thu 12 Jan 2023, on the Options Selection Phase of the Development of the Lough Derg Greenway in County Tipperary. Information on the project can be read here https://loughderggreenway.ie/. You can read our submission below.

Note that the Options Selections Phase, in terms of its position in the sequencing of phases of the project, can be understood from the following graphic:

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 member for Ireland 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, climate, and environmental benefits of cycling. An Taisce is the National Trust for Ireland – https://www.antaisce.org/.   

Cyclist.ie is and An Taisce are delighted to see the planning for this greenway / high quality cycling route on the eastern shores of Lough Derg progressing.  When constructed it will hopefully form part of a lacework of cycle and walking routes around the iconic Lough Derg, which will encourage local people to travel actively more frequently, and also entice visitors to the area to experience the many attractions and activities.

We have only some general comments at this early Route Options stage, in response to the non-statutory public consultation as set out on the https://loughderggreenway.ie/ webpage. We outline these below.

2 – General Comments
2.1 Population Access
It is critical that whatever route option is chosen that the route services the largest catchment population possible, so as to ensure that it is used all year round by the local population of close to 19,000, as well as by visitors to the area. We highlight, in particular, the need to link seamlessly to schools, sports grounds, shops and employment locations. We need to nurture a culture where it is safe and easy and enjoyable to cycle to school, sports training and other destinations where distances are amenable to this.  

2.2 Constraints
As outlined in particular in Section 6 of the Feasibility & Constraints Report , there are a variety of design difficulties to be overcome in choosing the best option for this proposed greenway. National greenway design standards will limit the choices for the different route options outlined, but it is obvious that a mix of sections along the various route options will likely be the final route choice. In other words, the chosen route will likely comprise a mixture of quiet back (L) roads (with reduced speed limits – see below), of providing segregated facilities alongside any short sections of R road that are to be followed, plus elements alongside field boundaries when done in an ecologically sensitive way.

2.3 Use of L Routes and the need for lower / safer speed limits.
It is unclear from the documentation supplied as to whether some of the L routes on the different route options are proposed to be used directly without widening – with improved surfacing – or with additional width provided. Cyclist.ie advocates for the development of L routes for cycling and walking, without major upgrades, but crucially with consideration of reduced speeds and some possible design interventions, as outlined in our Rothar Roads document. 

We would argue in particular that having 80km/h as the speed limit on these back roads (some of which have grass up the centre) is totally inappropriate (even if road side separate facilities are created). We highlight here the back road shown (below) as Figure 11 of the Feasibility and Constraints report (page 33) and where the text indicates that there is “little room for widening on one side… and significant earthworks would potentially be required to widen the road to accommodate the greenway”. Cyclist.ie wishes to challenge the idea that such attractive roads with grass running up the middle (which suggests low motor traffic volumes) need to be widened in order to make them cycling friendly. The crucial intervention here is to have lower, safer speeds on these roads and with driver behaviour improved so that cyclists are “expected and respected”. The use of some type of (lateral or vertical) physical interventions to reduce speeds on these roads would seem appropriate. 

TII, in the latest update of their Rural Cycleway Design standard, endorses much of this thinking, particularly in its section 3.4, which could be utilised in developing the alignment and design of this proposed greenway.   

2.4 Landscape- and ecology friendly route design
Cyclist.ie wishes to stress the need for minimal ecological and habitat disturbance in the development of this route – and this point relates back to our previous point challenging the apparent approach of seeking to widen some extremely quiet back roads in the creation of the route. In essence, rather than seeking to create a continuous ‘greenway’ all the way around Lough Derg, it would seem more prudent to include some lengths of very quiet L-roads, where there are some motor vehicle movements (of a local access nature) but where these happen at lower / safer speeds.

2.5 Connecting to the National Cycle Network and CycleConnects routes
We are aware of the bigger picture here of the development of the NCN (by TII) and the CycleConnects Routes (by the NTA). We would urge the designers to liaise closely with both of the relevant teams here, so that the Lough Derg Greenway / Cycle Route connects seamlessly with those other national and county level cycle networks (which themselves will connect to the EuroVelo#1 and EuroVelo#2 cycle routes).

3 – Summary/Conclusion
In conclusion, Cyclist.ie and An Taisce strongly supports the creation of this greenway / cycle route, where it is done in an ecologically sensitive manner. We also endorse the use of quieter back roads – especially those with grass running up the middle – as part of the overall route, but where attention is paid to reducing the speed limits from the completely inappropriate 80km/hr existing limits. 

We would be more than happy to discuss our ideas further with the project team in due course. 

We would be grateful if you can acknowledge receipt of this submission. 

Thank you.
Damien 

Dr. Damien Ó Tuama
National Cycling Coordinator, Cyclist.ie http://cyclist.ie/ and An Taisce https://www.antaisce.org/
Vice-President, European Cyclists’ Federation (2016 – 2021) https://ecf.com/
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