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