Ireland’s Climate Action Plan – Keep those cycling goals right up there!

We made an in-depth submission on the Climate Action Plan 2024 today, calling for continued investment in active travel, quicker roll-out of urgently needed protected, connected cycle tracks.

We pointed out that it’s not only our cities that matter; our towns should be focusses of active travel too. Local Authorities each now have to make an Action Plan, and we urged the Department to keep an eye on their quality – our Navan colleagues have found serious flaws in the Meath County Council version.

And we reminded the Department of the Environment, Climate and Communications that joined-up thinking is crucial when building new rail stations, bus stops and transport hubs. More cycle parking! And less car-focussed development and giant SUVs!

Here’s the text of our full submission:

Introduction

The Irish Cycling Campaign (formerly 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.

We are delighted to submit our observations on this vital and necessary plan. Our comments relate generally to specific Chapters 9 (Citizen Engagement) and 15 (Transport) within the Climate Action Plan 2024.

We set out general comments initially, then our responses regarding Chapters 9 and 15 to the questions posed in the Public Consultation Summary Document (red text), finally including some brief comments on Chapters 11 and 19 regarding local authorities.

2 General Comments

The Irish Cycling Campaign welcomes the updating of the Transport Appraisal Framework (TAF) to take account of Climate Change.

We welcome the statement that interventions under the Sustainable Mobility Policy include supporting a shift to active travel and public transport, including the reallocation of road space;

We welcome the proposed publication of a Demand Management Strategy

We welcome the proposal to amend legislation to extend the remit of the NTA to the 5 cities but think this does not go far enough, Page 268 of the CAP states “This will bring a coherent approach consistent with the Climate Action Plan objectives for transport” But why aim for consistency just in the 5 cities. Should not residents of Letterkenny, Tralee, Wexford, Drogheda, Navan, Sligo, Castlebar or Portlaoise etc be treated in the same way as residents in the cities?

We are disappointed that the Citizen Engagement chapter omits mention of Environmental NGOs and of PPNs as Stakeholder groups who should be an integral part of the consultation process given their expertise and outreach into communities. PPNs are mentioned in the context of Climate Conversation workshops only and NGOs in the context of global outreach. Both groups need to be at the table.

3 Specific Comments on the Shift Sector of Chapter 15

Ref 15.2.4.1 Active Travel Infrastructure and Accessibility Work Programme

Cycle Connects and The National Cycling Network are both welcome initiatives and we recognise this vast work programme will take many years and considerable resources to implement. However, these initiatives unfortunately still leave many communities unserved by cycle infrastructure including safe routes to school. SRTS is also mentioned as a priority in this section and we strongly urge the Departments of Transport, Climate Action, and Housing to consider ways in which measures can be taken to enable all communities to avail of safe walking and cycling infrastructure including safe routes to school. Dedicated walking or cycling infrastructure should be prioritised, where possible, including cycle lanes adjoining roads, cycle paths alongside waterways and re-allocation of road space to cycling and active travel. Where this is not possible, measures such as traffic calming, reducing speed limits, and developing the Rothar Road concept should be employed.

We welcome the recognition that the growing number of electric bicycles (E Bikes) means positive changes to the potential for modal shift become viable, but safe routes are the other essential requirement for this to happen.

BusConnects

We welcome the CAP’s support for the BusConnects scheme, particularly the 50% increase in services proposed in Cork. The BusConnects corridors, if constructed as planned, will provide a step-change in the quality and extent of cycle infrastructure, while improving walking facilities significantly (e.g. crossings across all arms of a crossroads, rather than 2 or 3 out of 4). A protected, connected cycle network – as planned by BusConnects for inner Dublin, for instance – has the potential to encourage a rapid and significant growth in cycle traffic: a step-change which could potentially become a tipping point in transforming Ireland’s transport culture.

Rapid social acceptance of cycling as a normal, daily travel mode is possible, in the same manner as attitudes to plastic bag use and workplace smoking changed rapidly, given rapid roll-out of infrastructure and good leadership. The communications and storytelling approach outlined in the CCCC and Chapter 9 will assist this cultural change. Ongoing social and behavioural research is crucial.

Opposition to BusConnects, often rooted in misinformation and micro-local concerns and sometimes touted by elected representatives, must be addressed and confronted by the NTA and local authorities, now that several of the required planning permissions have been granted and construction is imminent. The strengthened social contract dealt with in Chapter 9 is critical. Loss of street-side parking privileges, for example,, balanced against the common good of on-time bus services, must be put into accurate perspective.

However our reviews of BusConnects corridor plans, in the process of making many submissions during the various consultation phases, show that BusConnects infrastructure plans require improvements:

Cycle tracks often too narrow;
Junction designs (conflicts between motor vehicles and people on bicycles are made more likely than necessary by the designs/ traffic light phasing);
Compromise of designs for public and active travel at many locations, in order to maintain car traffic flows;
Failure to account for the real potential health benefits of modal shift, e.g. by using World Health Organisations’ HEAT methodology.

These issues must be addressed in detailed design. Thus, we would submit that the CAP should specifically endorse the standards set out in the National Cycle Design Manual, over and above the mention on p. 272.

Additionally, CAP should recommend revision of Transport Appraisal Frameworks e.g. National Investment Framework for Transport Infrastructure, to include HEAT or equal methodology: Human health impacts of transport are not only from vibration/ pollution/ access to services (as appraised in current practice) but also – and far more significantly – from access to or preclusion from active travel. Active travel facilitated by good cycle tracks, quality walking environments and linkages with public transport, can engender daily, habitual physical activity. Significant mental and physical benefits are known to result. Conversely projects that facilitate or enable motor dependence often worsen the environment for walking and cycling, thus denying opportunities for exercise. CAP is in a position to leverage health benefits for GHG abatement by addressing how projects are appraised and prioritised.

Ref 15.2.4.2: Major Public Transport Infrastructure Programme:

” Public transport projects will ensure quality active travel access and cycle parking for passengers”.

We suggest that this measure should not just apply to major new projects but to smaller projects such as bus shelters and include retrofitting of existing infrastructure. Connecting Ireland does not appear to be incorporating cycle parking in its enhanced services.

Rail

Facilities for combining bicycle/wheelchair/pram users and train travel should be improved through lifts at train stations which are long enough for non-standard bicycles and mobility aids, or providing other means for these vehicles to easily change platforms. Latency in lift capacity, i.e. additional provision to cater for breakdowns, should be built into station design.

Cycle parking at stations must be in compliance with development plan requirements and best practice. Neither Dublin MetroLink nor Dart + West projects, for example, have been designed with adequate cycle parking spaces, compared to local authority standards. Inadequate cargo bike/ disability trike/ non-standard cycle provision is shown on plans.

When procuring train carriages and buses, design of the train carriage or bus should include space which can be used by bicycles/wheelchairs/prams or seated passengers through fold-up/down seats, and straps for securing the bicycle when the seats are folded up. Embarking or disembarking with a bicycle/ wheelchair/ pram should be facilitated by ensuring there is not a large step up/down to embark/disembark.

If bicycles are allowed on particular train carriages within a train but not other carriages, this should be very clearly marked on the side of the relevant carriages so cyclists can easily find the carriage to enter.

Bus and bike

For buses, a rack on the back of the bus, or space in the hold of the bus, can be alternatives.

Secure parking facilities for bicycles, and availability of public shared bicycle schemes at train stations and bus stops, should be prioritised. A mix of parking provision is necessary, in some cases a simple Sheffield stand may suffice, in others more secure supervised indoor parking or secure bicycle cages/lockers may be necessary

Consistency of access for all wheeled modes to all public transport should be built into the Plan.

For overseas travel via ferry, cyclists should be offered the same choice of ferry routes and timetable as motorists are offered, and the same or lower prices based on the lower weight involved.

Omission from Shift Proposals: Transport and Sustainable Tourism

The preceding comments on integrating cycling with public transport were focussed on the needs of people who cycle for transport but could equally be applied to Cycling Tourism. We are surprised that the only reference to the promotion of Sustainable Tourism in the main CAP24 doc or in the Annex of Actions occurs in the chapter on a Just Transition for the Midlands. A major focus on the Midlands is entirely justified given the job losses arising from the cessation of exploitation of the bogs for production of electricity and fuel. Actions such as regenerative tourism, the development of walking and cycling trails and the decarbonisation of the bus fleet are laudable and welcome.

However, we would like to propose that the Departments of Climate and Transport engage with the Department of Tourism and with Local Authorities and bring the same imaginative thinking on regenerative tourism to bear on sustainable transport projects countrywide. We have already seen a significant expansion in rural bus services and we have seen many walking and cycling trails developed under ORIS, Community Recognition and other funding streams. What we have not seen is some joined up thinking and effective marketing to encourage tourists to avail of these new services and to access local walking routes.

The Midlands undoubtedly attracts fewer tourists than the Wild Atlantic Way but much of the tourism to the WAW is car and coach intensive and causes congestion on narrow roads.

We think a section on regenerative tourism on a national footing would be a worthwhile addition to the CAP. The aim should be to highlight and promote routes and itineraries which integrate different modes of transport, walking, cycling, train, bus. Maximum use should be made of the expanding network of Greenways.

For illustrative purposes we will look at an example from County Clare. At the moment it is difficult for someone based in Ennis to plan a day out in North Clare to visit some of the sights and get reliable information on bus stop locations and timetables as well as walking routes and cycling options. For example it is possible to take the bus from Ennis to the start of a walking trail, complete a walk on that trail in one direction and link up with a bus back at the end of this trail but information on the bus services is not integrated, eg 350 bus from Ennis to Fanore, walk to Ballyvaughan,local link bus from Ballyvaughan to Ennistymon and 350 from Ennistymon back to Ennis.

The TFI Live app could be an amazing resource if it was populated with all the Local Link information and if it was marketed effectively. All popular visitor destinations whether Walks, OPW sites, Historic Houses and Castles, Farm Attractions should be requested to display options for access by Sustainable Transport where such is possible. Bus companies should make their timetables widely available.

4 Responses to Summary Document Questions

1. What do you think are the key challenges/risks to delivering the measures/actions set out in the Plan?

We agree with the statement in the Climate Plan (p247) which follows on the acknowledgement that transport emissions increased in 2021 and 2022 that “Decoupling the direct correlation between transport emissions and wider social and economic activity thus forms the fundamental challenge for the sector” Decoupling is extra challenging at a time when the population is increasing.
The shortage of student accommodation means that many 3rd Level students must commute long distances daily
Construction inflation is a major issue for delivery of transport projects.
If we are to meet our 2030 targets we need people to switch modes now, but many major public transport and active travel projects are still at the early planning stages
There is a sense in which some Local Authorities are citing National Policy re Sustainable Transport but not treating the necessary implementation plans with sufficient urgency. Local Authorities have now completed their own Climate Action Plans and submitted them to the DECC but there appears to be huge variance in the sustainable transport measures and targets (e.g. Meath, as noted above).
With respect to Active Travel, the original announcement in January 2021 about the setting up of Active Travel Teams stated “The new staff will be dedicated to delivering and promoting active travel in Ireland and will work across design, communication/community liaison and construction oversight functions.” However, outside of the cities, as far as the Irish Cycling Campaign can ascertain, Active Travel Teams comprise almost exclusively engineers with some technicians or administration personnel. This means that the teams do not have the expertise for the essential work of communicating with communities and “selling” sustainable schemes. It also means schemes may not be optimal in terms of enhancing liveability. Our experience is that Local Authorities are still falling back on online consultations as their main means of community engagement and this is unlikely to result in community buy-in.

2. Are there additional supporting actions that could be taken in 2024 to address or mitigate any identified challenges or risks to implementation?

Inflation proofing: It may not happen in 2024 but it is essential that the next PfG introduces a clause that funding for sustainable and active travel will be capped as a percentage of each year’s land transport budget and not as is currently the case as a % of the budget for the first year the current government takes office, as happened in 2020. €350 m annually represented exponential progress at the time but unfortunately it was insufficient to absorb shocks like the Pandemic and the War in Ukraine.
Active Travel Teams: We urge the Government to recognise that while engineers are essential for the delivery of AT schemes, engineer only teams lack some of the skills needed for successful roll-out and ‘selling’ of active travel projects. Areas outside the cities need multi-disciplinary teams just as much as their city counterparts. Clearly it would not be feasible to appoint large teams to each county but architects, planners, public liaison officers, could be shared between counties, possibly via the existing local Regional Design Offices. There are already many examples of local authority shared services and there are cooperation mechanisms in place via the Regional Assemblies.
Now that the Department should have received copies of their LACAPs from every Local Authority we suggest it would be a useful exercise to highlight examples of best practice of SMART measures and ask the more progressive authorities to share their thinking via CPD, podcasts, social media etc. It would be important to have a variety of exemplars that could be replicated by smaller, as well as larger, better resourced, areas.
Inclusion of the Irish Cycling Campaign in the relevant sections of the Annex of Actions and Citizen engagement as a key stakeholder in supporting the design and delivery of Active Travel infrastructure and a key facilitator of encouraging modal shift to cycling.
Irish Cycling Campaign should be included as a key stakeholder in the National Dialogue on Climate Action.and the National Climate Stakeholder Forum. According to Chapter 9, the Forum comprises Government, Departments, Local Authorities, Public Sector Bodies, national organisations, academics, representative bodies, voluntary organisations, and community groups but the Irish Cycling Campaign has not been invited in its own right.

Here is why the Irish Cycling Campaign should be added:

Electrification of the private car fleet is invested with doing a lot of the heavy lifting in meeting emissions targets but it is unlikely they will be met by 2030.
Major Public Transport projects, while welcome and necessary, will not be complete by 2030 either.
It is more important than ever that Active Travel is prioritised and the roll-out of infrastructure is accelerated. Funding of projects and of well resourced Active Travel Teams is essential but it would be foolish to discount the experience of people such as the advocate members of the Irish Cycling Campaign, who already engage with local and national officials, and in the everyday cycling to school, college, work, leisure activities that the Climate Plan and the Sustainable Mobility Policy wish to expand.

3. Do you have any specific suggestions on how the implementation of measures/actions in the Plan should take account of the four principles of Ireland’s Just Transition Policy Framework (as set out in Chapter 7 of Climate Action Plan 2024)?

The Just Transition section of the Transport Chapter already recognises the need to tweak the balance of avoid/ shift/ improve depending on the capacity of communities to absorb the proposed changes.

4. Are there any specific improvements that could be applied to the Plan in general, or to specific measures/actions or chapters in the Plan?

Annex of Actions (p67) SHIFT Public Transport Services and Escort to Education Journeys: TR/24/16/TG Connecting Ireland
In our view this excellent initiative merits a further degree of joined up thinking. Connecting Ireland has already made phenomenal progress in providing bus services in rural areas. It is truly remarkable that communities who had only one daily bus service now have up to 9 services including early morning and late night services. In other areas hourly bus services have become half hourly again with early and late services. Increased services and reduced fares are game-changers. The plan is only at the half-way stage so progress in rolling out services will continue. However in our view two further changes should be implemented at the same time as services are being improved.

There needs to be a major acceleration in the programme for the provision of bus shelters in both rural and urban areas. From the emissions reduction point of view Connecting Ireland will only be successful if it brings about a modal shift. Current bus users will appreciate the lower fares and extra services but in terms of achieving the substantial reduction in kilometres driven mandated by the Climate Action Plan, people who currently choose to drive need to be persuaded to take the bus instead. For example, surveys undertaken by Sligo PPN and Sligo Comhairle na nÓg cite the lack of bus shelters as a major deterrent to choosing to travel by bus.
The second related issue is that the take-up of bus services is hugely dependent on their perceived reliability. Two issues related to reliability, i.e. a shortage of drivers and a shortage of buses are being addressed. However a third issue; the extension of the LA winter gritting programme to cover routes used by local link services requires DECC and DT to liaise with DEHLG, and of course will require a larger winter maintenance budget. The very nature of Local Link services means they use Local Roads for part of their routes and these roads are currently not included in the winter maintenance programme. Gritted roads means that on days when there is frost the service is often cancelled or curtailed, and this unreliable. This leaves people unable to get to work or to appointments and is the last thing that should be happening if the policy is to encourage a move from car-dependency to sustainable transport. Gritting of roads used by Local Link services could be regarded as a just transition measure.

Active Travel: TR/24/15(TF) SMP Pathfinder: Accelerate implementation of Safe Routes to School Programme:
It is welcome that it is planned to identify additional phase 3 schools and bring them into the SRTS Programme but a more basic step also needs to be taken. The CAP makes reference to whole of government collaboration and in Chapter19 to the essential role of Local Authorities in achieving our emissions reduction targets. In this context it is almost incredible to read on https://irishcycle.com/ this morning about a brand-new school which the Department of Education and Mayo County Council has allowed to be built without provision being made for active travel access. https://irishcycle.com/2024/04/04/a-new-school-at-the-edge-of-town-is-opening-on-an-80km-h-road-with-no-footpath-or-crossing/. SRTS involves retrofitting walking and cycling infrastructure at existing schools. The idea that in 2024 one is permitted to build a new school and retrofit active travel at some later date is unacceptable.

Smart, Shared and Integrated Mobility: TR/24/17(TF) Development and publication of Policy Statement on Mobility Hubs

15.2.4.4 (p277) of the Plan is about mobility hubs. It states, ” it is intended that the NTA will go to tender in 2024 for the staged commencement of services across the 5 Cities.” and also, “Policy underpinning the approach to shared mobility and mobility hubs on a national basis will be advanced in 2024 with plans to develop a Policy Statement on Mobility Hubs in the third quarter of 2024”.

Proposals for mobility hubs already feature in some draft town transport plans as part of County Development Plans so it is important they are not seen as merely being for cities. Pilot hubs need to be established in urban centres of different population sizes.

TR/24/18(TF) Rollout of expanded Regional Bike sharing schemes in Limerick, Cork, Waterford and Galway, including enhanced e-bike provision.
This is a welcome development but our understanding is there are problems with the maintenance of the current fixed station bike-share schemes in the regional cities, so merely adding a greater variety of bikes without ensuring the stations and bikes are well maintained will not lead to greater take-up. In some of our cities, one-way systems make bike routes circuitous and unattractive so local authorities need to be encouraged to provide for more contra-flow routes.

5 Chapter 19: Local Authorities Climate Action Plans (LACAPs): Need for Enhanced Guidance:

5.1 Consistency of Guidance and Assessment
While we welcome the statement that “A monitoring and reporting system for the LACAPs will be developed and best practice examples of LACAPs will be identified and disseminated across the sector through peer-to-peer engagement”, we are concerned that the statement, “Local authorities can take their own approach to the style and structure of the LACAP but it must be aligned with the key principles set out in the statutory guidelines; ambitious, action-focused, evidence-based, participative and transparent” has led to inconsistencies across the system and less than robust targets for sustainable transport.

The current guidelines for Local Authorities are vaguely-worded and contain optional phrasing such as “should” and “could”. In practice, this allows for unsatisfactory plans by Local Authorities, as the guidelines can be argued to have been followed. We would like to see more specific guidance so that local authority plans can be objectively assessed as having met or not met the guidelines.

An example of the outcome of this is that our Meath sub-group, Navan Cycling Initiative, have found the Meath County Council Climate Action Plan to have very few measurable and scheduled targets for the development of active travel, for instance having no annual targets for rapid-build cycle infrastructure, and no specified, measurable, timed actions set out regarding speed limit reductions.

We note that one of the actions listed in the Citizen Engagement chapter of the CAP is “Delivering robust systems to measure climate action at all levels”.

Measurement of climate action through citizen engagement will only be possible if measurement metrics are in place to start with. Having read the transport section of several LACAPs we note a distinct absence of robust measure/monitoring systems for active travel in many of them.

5.2 Clarify Consequences for Local Authorities for failure to meet Targets
While the emissions targets are statutory, the consequences for Local Authorities failing to meet these targets are entirely unclear. The targets are therefore being prioritised alongside every other KPI (e.g. NOAC KPIs). Clarifying consequences if any will allow Local Authorities to prioritise appropriately.

6 Spatial and planning policy (Chapter 11):

Local authorities are continuing to permit low-density and one-off, car-dependent housing developments on the periphery of towns and cities. Such planning denies access to healthy active travel.

We would support accessible, medium-density, mixed use neighbourhoods and the 15-minute city concept. We support Chapter 11’s section 2.3 and its reference to the National Planning Framework, particularly National Policy Objective 53, in seeking to minimise car-dependent new housing. We submit that the Climate Action Plan 2024 should include an Action strengthening its support for this Objective and highlighting its importance.

7 Summary/Conclusion

In summary; the Irish Cycling Campaign welcomes many aspects of CAP 24 and is cognisant of the work being undertaken by both the Department of Environment Climate and Communications and the Department of Transport to move us from car dependency and high emissions to a more sustainable means of transport with reduced emissions. We are happy with the Sustainable Mobility Policy, the proposed Demand Management Strategy, the Avoid Shift Improve approach, the expansion of Bike Share schemes, the concept of Mobility Hubs and the proposals for a Citizen Engagement strategy. We welcome Cycle Connects and the National Cycling Network Plans.

We feel the Plan would be improved by having a more robust integrated strategy for multi-modal transport, by accelerating the roll-out of the bus shelter programme and by expanding the Local Authority Winter Maintenance Programme to include bus routes served by Local Link.
In recognition of the volume of carbon emissions generated by the tourism sector and mindful of the benefits of sustainable tourism to rural communities, we would like to see a section on Transport and Tourism added to the Plan
We are concerned that the Department’s current strategy for engagement with stakeholders excludes groups such as the Irish Cycling Campaign and does not include environmental NGOs such as An Taisce or PPNs except in a minor way. We would like to see this change.
We are also concerned with the variation we have observed in LA CAPs re the measurement and monitoring of sustainable transport targets and feel guidance for LAs needs to be more robust.
We are disappointed no start date is mentioned for the commencement of the proposed Smart and Sustainable Mobility Accelerator Project. This project featured in CAP23 but appears not to be on target. Meanwhile LAs are going ahead with projects without the relevant training.
We strongly urge the creation of Regional Active Travel Teams so as to incorporate the genuine multi-disciplinary skills that are available to larger city teams.

Photo by Mika Baumeister on Unsplash

Irish Posts

RSA Review 2024 – Irish Cycling Campaign Submission

5 Apr '24 damien.otuama 4 Comments

Earlier today (Fri 05 April 2024), Irish Cycling Campaign made a submission in response to the Department of Transport’s consultation on the Review of the Road Safety Authority. You can read a copy of it below.

We wish to thank all of our fabulous volunteers who contributed to this submission. We sincerely hope that it helps to reshape the institutional context which has a huge bearing on the real and perceived safety of those who travel on foot, by bike and indeed by any other mode of transport.

Introduction

We in the Irish Cycling Campaign are a network of knowledgeable and passionate cycling advocates from across urban and rural Ireland. We are the member for Ireland of the European Cyclists’ Federation (https://ecf.com/) and also a member of the Irish Environmental Network (https://ien.ie/).

We know that cycling is part of the solution to many of society’s problems, from health to the environment to the economy. We have a vision for Ireland where everyone has the opportunity to cycle safely to the shops, to school, to workplaces regardless of their age or ability. Our expertise in research, policy, transport planning, infrastructure design, event management and behaviour change means we are the trusted voice on everyday cycling in Ireland.

The Department of Transport (‘the Department’) is currently undertaking a review of Ireland’s Road Safety Authority (RSA) via an independent third party, Indecon International Consultants. We set out our views below in the form of responses to the seven online questions posed by the Department on the downloadable public survey.

Executive Summary

We welcome the opportunity to make this submission. In short, we have serious concerns about the performance of the RSA:

Institutional and financial adherence to car dominance
Cultural blindness to the needs of vulnerable road users
Failure to advocate for better road designs and effective enforcement
Silence on the rapid growth of ever larger and more dangerous private motor vehicles (SUVs)

Views on Services Provided by the RSA

Q 1. The RSA currently provide a range of services and functions, including Driver Testing and Licencing, NCT and CVRT Vehicle Testing, road safety advice, road safety promotional and media campaigns, and road safety education programmes, as well as working with other stakeholders to enhance road safety enforcement and inputs to road safety legislation. What do you believe to be the most important of these services and functions? And are there any other services or functions which the RSA should be undertaking that they are not undertaking currently?

We believe that any authority concerned with road safety in Ireland must carry out all those functions. However, the current dominance by private car use (whether EV or ICE) leads to poorer safety outcomes, compared to a holistic approach to road use (and transport generally) that tackles car dominance and unrestrained driving.

We see a crying need to shift Ireland’s road use and culture to one that is both safe and healthy, and one that prioritises vulnerable road users (as required by the Department’s own guidance and investment frameworks). Thus the education, promotional and legislative functions must take priority. We believe any effective road safety authority will also have an active role in enforcement of traffic legislation, and in advocacy for better roads, cycleways and walkways.

Implementing road safety measures can be unpopular and is often faced with local and political opposition, especially when it involves prioritising road users who are not driving. It should be a core function of the Road Safety Authority (RSA) to dispel misinformation and clearly educate the public in relation to the importance and benefits of reduced speed limits and the infrastructure that improves road safety.

Data:

High quality research and data is needed to lead road safety interventions. The RSA should be bringing together multidisciplinary research teams in universities to carry out comprehensive research and data analysis. Such teams would include behavioural scientists, experts in public health and epidemiology, statisticians and engineers.

The absence of any road traffic collision data made publicly available for researchers and public engagement, is a major deficiency in one of the core roles of the RSA.

By contrast, such data is not only available in the UK in machine-readable format amenable for analysis, but is also collated and presented for better public information with dashboards and interactive maps. See for example the following:

Road accidents and safety statistics – GOV.UK;

THINK Map;

Reported road casualty statistics in Great Britain: interactive dashboard, from 2018.

Arguments about GDPR preventing the release of these data in Ireland do not appear to hold much water, since other European jurisdictions are subject to the same regulations.

We note that a road traffic collision map was previously available on the RSA website, covering collisions until 2016. Although limited in its function, it had a role in road safety audits and could be used for simple research, public information and advocacy purposes. This map was removed in late 2020, and on November 30th 2020, the following statement appeared on the RSA’s website:

“Access to road safety data”

We are in the process of reviewing our road traffic collision (RTC) data sharing policies and procedures. Record-level RTC data can’t be shared until this review is complete.”

(Source here)

After more than 3 years, there appears to have been no visible progress on this issue. This is an obvious concern for all stakeholders. The impression given (whether true or not) is that this is not a priority for the RSA, or that there is something to conceal in these data. We would strongly argue that the RSA follows the example from other states in making the data available and useable.

Q 2. Do you have any other views on the focus and balance of the Road Safety Authority’s functions, between the driver and vehicles testing and licensing services it delivers to the public, on the one hand, and the road safety policy, promotion, education, and research functions it undertakes, on the other? (See: Role of the RSA)

Decoupling of Services:

We propose a re-evaluation of the RSA’s structure to potentially decouple those two roles. Whether intentional or not, the RSA’s approach to road safety is extremely motor-centric. We expand on this below.

Culture and norms around driving instruction and testing

Respect for people cycling and understanding of cyclist behaviour needs to be prioritised in the driver training curriculum. We are concerned that some Driving Instructors have difficulty observing rules that are there to protect people walking and cycling, such as parking in cycle lanes and footpaths, even when engaged in training novice drivers.

There seems to be no understanding, for example, of the role played by bike-boxes with their advanced stop-lines among the ADIs. Drivers regularly invade these safety features, so it is clear that their importance is not covered by instructors or testers.

The test must be reformed so that there is a vulnerable road user category added with mandatory questions posed in the on-line assessment; in addition, we would urge that a mandatory requirement be introduced into the training and testing of professional drivers that involves safe interaction with bike users, where the novice or a driver undergoing annual CPC assessment must ride a bicycle in traffic in an urban area to have experiential awareness of extreme vulnerability.

The medical fitness to drive assessment requires reform

GPs need to carry out a thorough investigation beyond focusing on blood pressure and eyesight. The exam should include checking peripheral vision or ability to rotate the head in a horizontal plane. This latter function is of critical importance in keeping bike users safe on our roads – drivers are failing to turn their heads in order to look properly so it is our view that many may not actually do this due to age related cervical vertebra mobility issues.

Taxi drivers must be subject to mandatory CPC

The exclusion of taxi drivers from mandatory CPC assessment is unacceptable. They drive as a profession and therefore must be treated as a professional driver. Sharing bus lanes with bike users carries additional responsibility and awareness.

Views on the approach to funding of the RSA

Q 3. The RSA’s functions and operations are mostly self-funded, from the fees it charges for the provision of services, including driver licensing and testing, and passenger and commercial vehicle roadworthiness testing services (the NCT and Commercial Vehicle Roadworthiness Testing), with little direct Exchequer/public funding received. What are your views on this self-funding model rather than an exchequer funded model or a mixed funding model?

The Irish Cycling Campaign fundamentally opposes the current self-funding model of the RSA, which relies heavily on the growth of private car ownership and use. This model creates a conflict of interest, as the RSA’s financial well-being is directly tied to the proliferation of vehicles and increased vehicle-kilometres travelled (VKT) on our roads. We strongly advocate for an exchequer-funded model to ensure the RSA’s independence and ability to take necessary actions to enhance road safety for all users.

It is deeply inappropriate for the RSA to use motor industry sponsors in road safety campaigns.

Views on the future of the RSA

Q 4. Do you have any views on the future role of the Road Safety Authority?

We have set out our views on future funding models, and on the cultural norms of the Authority. We would submit that there are other changes that would potentially be useful and effective.

Different indicators of success

The current mission of the RSA is “to save lives and prevent injuries by reducing the number and severity of collisions on the road.”

The statistics on death and injury should not be the only indicator of how safe our roads are. Another important key performance indicator which should be applied is the number of people walking and cycling on our roads. The number of children walking and cycling to school has plummeted in the past 30 years as the number of car journeys has soared. Parents no longer feel safe letting their children commute by bike or even playing outside in many places.

Counting not just victims by mode of transport but the perpetrators of road violence:

Since the primary hazardous exposure on roads and streets in Ireland is driving, reducing the total number of kilometres driven nationally by enabling more walking, cycling or public transport journeys will itself make roads safer.

As an example of the dominance of RSA’s culture by car use, a simple search of one particular social media channel shows the @RSAIreland account only replying to queries and comments regarding driver licensing:
https://twitter.com/search?q=(from%3ARSAIreland)%20filter%3Areplies%20-(to%3Arsaireland)&src=typed_query&f=top

This has the effect of signalling to the public that the RSA only engages or values input from such “paying users” of its services.

Future Board Make-up / Expertise

In the make-up of the RSA board, we see a need for much wider ranges of expertise than are currently represented.

Such expertise might include, for example, vulnerable road user requirements, public health, health effects of sedentary lifestyles, of climate change, or of air/ noise pollution, and hazard and risk assessment in road use. There also appears to be an absence of non-drivers on the board. It is essential that road safety is approached representing the experience of people who do not use a car.

We are unaware of specialist sub-committees of the board, who may have expertise in the various relevant fields (e.g. public health, air pollution, social change). We would urge consideration of the establishment of such sub-committees, which might provide useful input to Board decision-making.

Q 5. Do you think there are any functions currently undertaken by the RSA that would be better delivered by another body/agency or any functions completed by others that would be better undertaken by the RSA?

Road Safety Commissioner

As outlined in Q.2 above, the two main functions of the RSA conflict with each other, and there is a strong argument for separating them. The appointment of a suitably empowered and resourced Road Safety Commissioner, working either in parallel or as an overarching authority above the RSA, should be considered. Such a Commissioner would take a broader view of road safety, particularly drawing out the implications of the existing Road Safety Strategy Safe System Priority Area Six, which

‘…involves promoting these safer modes, such as public bus and train, and providing safer environments for healthier modes, such as walking and cycling.’

Strong advocacy for reduction in car use across society is the ultimate outcome of this Priority Area. Switching travel mode from private car to public and active travel is the ultimate road safety tactic, and should be a central task of any authority concerned with road safety.

Engagement with the RSA

Q6. Please indicate any involvement you may have with the work of the organisation and your views on their road safety information campaigns, education work or other services.

The Irish Cycling Campaign meets regularly with RSA officials to advocate for safer cycling and measures to control poor driver behaviour. Under its former name, Cyclist.ie, and under sub-groups such as Dublin Cycling Campaign, the organisation has engaged with RSA since its inception.

Hierarchy of Controls

The Vision Zero approach refers to a hierarchy of controls. The Authority have noted in their own document “Guidelines for Improving Road Safety Around Your School” (2021), that personal protective equipment (hi-vis) is the last level of control (p15, Fig 3).

The RSA should allocate funding to all levels in the hierarchy, with proportionally more to earlier levels – i.e. Elimination, Substitution. This is not to say that no funds should be allocated for hi-vis, but that funds for hi-vis should be lower than all other measures. Currently huge emphasis is placed on the wearing of hi-vis clothing. The emphasis on hi-vis has also meant that the message that it is a legal requirement to have bike lights in hours of darkness has been lost, with many people now cycling with hi-vis vests, but without lights.

Road Safety and Children

We urge the organisation to shift its focus away from victim-blaming campaigns centred on the wearing of high-visibility clothing. Is it an appropriate use of resources to be distributing 40,000 hi-vis vests to pre-school and school children annually, while there is little intervention to deal with driver behaviour around schools, sports grounds and playgrounds? It is an erroneous message to give children the impression that hi-vis will protect them. The responsibility for road safety lies with adults driving ever large motor vehicles recklessly and flouting road traffic laws – and not with small children.

Children lack the capacity to be responsible for road safety and must absolutely not be held accountable or held to blame. Children have the right to play, they have the right to be safe outside. Our car culture has negated this right. Driving is a privilege and it is viewed in Irish society as an entitlement. Driving has removed safe places for children to play outside.

The RSA education programme to primary school students is actively disempowering in that it creates a sense of danger around walking and cycling outdoors. It perpetuates the removal of this freedom. The driver is 100% responsible for a child’s safety. These RSA primary school campaigns are public health campaigns around a group of people who do not drive. In short, the RSA is failing children.

Much of the “Guidelines for Improving Road Safety Around Your School” document is commendable, as it follows the Hierarchy of Controls, but it places the onus on already overburdened school management to create and implement a road safety plan.

Most schools do not have the capacity to implement and sustain such a plan and certainly do not have the power or authority to enforce the main elements that would actually have an impact on road safety around schools.

We need to see a move away from spending on PPE and hi-vis for small children and, instead, see a reprioritisation of the education message in primary schools from children to parents and other drivers.

We would recommend education nights by RSA educators and partners (AGS, etc) delivered to parents facilitated by school management and parents associations.

Additionally the RSA need to measure modal shift to walking, wheeling and cycling as one of their metrics to measure a successful safe school environment.

30kph Campaign

While we commend the RSA for its recent positive 30kph speed limit campaign (along with the campaign to urge drivers to allow sufficient space when overtaking people on bicycles), the Authority has failed to persuade An Garda Síochána to enforce 30kph limits. Furthermore, it is vital that traffic calming infrastructure is rolled-out quickly to ensure average traffic speeds are compliant with the posted speed limit. This involves engaging proactively with each of our 31 Local Authorities.

Where traffic calming is ineffective or absent, there must be active enforcement. Without enforcement, people do not observe these limits as outlined in the RSA’s own Free Speed Survey 2018, which show that 98% of drivers speeding on urban national roads with 30kph limits, and 70% of drivers speeding in residential 30kph streets – (Appendix I, page 11, of FREE SPEED STUDY Survey Report 2018 | RSA

We also note that the Free Speed Survey in 2021 does not contain data on 30kph zones – Free Speed Survey 2021 | RSA.

It is critical that the RSA continue to gather data on compliance in 30kph areas, call for enforcement in 30kph zones, and advocate the use of static speed cameras where AGS or Go Safe vans cannot provide enforcement.

A 2022 AECOM/ TII report pointed out the higher GHG emissions from ICE cars travelling at less than their optimally efficient speeds of 50 – 90 kpm. But it is important that, in urban and built-up areas, road safety is prioritised over minor possible savings in fuel efficiency. We would support the report’s recommendation for there to be a focus on the reduction of congestion in urban areas, and we maintain that this is best achieved through the allocation of road space to public transport and active travel. This would also improve road safety, if accompanied by measures to improve pedestrian and cycling infrastructure.

The apparent absence of the RSA in policy discussions about speed limits on the national road network means that economic and GHG mitigation considerations have, in some cases, trumped the most obvious road safety benefits of reducing traffic speeds – and we are thinking here in particular of cases where schools are located right next to N-roads.

Call for effective and widespread enforcement in regard to conditions for people on foot / on bike

There needs to be an education and enforcement campaign with regard to motor vehicles parking on footpaths and cycle-lanes / cycle-tracks. This behaviour has become habitual, especially in residential areas. It creates hazards for vulnerable road users, especially those walking and cycling with children, elderly people and those with vision or mobility impairments.

Schools around the country have tried to educate and inform parents around illegal parking but to no avail. Safe Routes to school is progressing far too slowly to have the required impact on driver behaviour. In the interim, we need enforcement and RSA has not effectively advocated or demanded it.

Supporting implementation of road safety interventions: Advocate for infrastructure:

For many years the RSA have shown their support for investment in motorways and road upgrades to improve road safety outcomes. The RSA’s voice has been and is generally completely absent in educating the public on the positive road safety impacts arising from the reallocation of road space to modes other than private motor vehicles. This would include traffic calming measures such as junction redesign, road narrowing, and infrastructure to create a safe environment for people walking and cycling, segregated cycle paths, continuous raised footpaths across junctions and pedestrian and zebra crossings.

Providing public transport alternatives to driving also reduces the risk of people opting to drink/drug drive.

False equivalence

The RSA must improve the language they use around people walking and cycling. The “Be Safe, Be seen” messaging is jarring, especially when so many collisions are due to drivers’ failing to observe. People cycling have a legal requirement to have front and rear lights in hours of darkness. People are clearly visible in daylight hours but they cannot make themselves seen by drivers who are distracted or failing to observe.

People cycling do not pose the same risk as people driving cars. The weight and speed of a motor vehicle means the driver bears far more responsibility when sharing the road with others.

Sports Utility Vehicles / SUVs

The striking difference in the mass, momentum and kinetic energy of motor vehicles versus people on (10-20kg) bicycles, is accentuated further by the disturbing growth of ever larger Sports Utility Vehicles (SUVs) on our roads and streets. According to a recently published research paper:

New cars in Europe are getting 1 cm wider every two years, on average. That’s according to research by Transport & Environment (T&E) which says the trend will continue due to the rising sales of SUVs – unless lawmakers take action. Around half of new cars sold are already too wide for the minimum on-street parking space in many countries. https://www.transportenvironment.org/discover/cars-are-getting-1-cm-wider-every-two-years-research/

The RSA has been silent on the frightening phenomenon whereby almost two out of every three cars sold in Ireland are of SUV body types (https://www.ft.com/content/fba7a808-e03e-40c6-9795-38c05abc844a). The trend towards wider vehicles is reducing the road space available for other vehicles and people on bikes (as shown in the image below), while parked cars are further encroaching on footpaths. The wider designs have also enabled the height of vehicles to be further raised, despite crash data showing that a 10 cm increase in the height of vehicle fronts carries a 30% higher risk of fatalities in collisions with pedestrians and cyclists.

Figure from the Transport and Environment report, link above.

From an emissions perspective, Prof Brian Caulfield, regarded as one of the leading authorities in transport emissions in Ireland, and someone who has conducted extensive research on decarbonising transport, said SUVs need phasing out (https://www.irishexaminer.com/news/spotlight/arid-41132380.html) – but from a road danger perspective, SUVs are contributing to a more hostile and hazardous road and street environment for everyone else in their vicinity.

The RSA, or a replacement road safety organisation, needs to engage with the latest research on this topic, step up and advocate strongly on this topic.

Other Comments

Q7. Finally, please provide any other comments which you feel may be of relevance to this review of the RSA.

In summary, we need an expedited, national motor traffic reduction plan and a paradigm shift in how we think about road danger. We need to stop diverting ourselves from the real issue – which is the physical presence, destructive and violent potential of ever larger forms of private individualised mobility.

We again thank the Department and Indecon for their attention to our submission.

Irish Cycling Campaign

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