Question 1: What category of stakeholder do you represent (e.g. private, company, organization etc)?  Non-governmental organisation: Cyclist.ie – the Irish Cycling Advocacy Network (https://cyclist.ie/)

Question 2: Do you think that the use of PPTs should be permitted in Ireland and why? Yes. The nature of mobility, and urban mobility in particular, is changing throughout Europe (and globally) in response to several structural shifts: the crippling economic effects of congestion arising from allowing too many cars (most of them single occupancy) into cities; the need to make cities and communities more liveable and safer, by reducing the volumes of motorised vehicles in them; the need to decarbonise transportation because of the sector’s very significant contribution to CO2 emissions (approx 20% of emissions in Ireland and higher elsewhere). 

The future of urban mobility, which we need to shape through policy and legislative interventions – as well as being shaped by quite rapid developments in (battery) technologies – must be characterised by:

• high quality and high capacity public transportation (and electric in nature – i.e. moving away from diesel fueled vehicles)
• active travel (walking, cycling, e-bikes and including various bike-sharing systems)
• Powered Personal Transporters (PPTS). These are incredibly space efficient (both when moving and ‘parked’), do not contribute to noise pollution and use minimal energy when compared with the energy use of 2000 kg+ cars. 
• Clever integration between all of the above. Intermodality is what we need to be thinking about in which using several (low carbon) vehicle types over the full length of a (longer) journey becomes the norm. 

The model of (generally single occupancy) cars and Sports Utility Vehicles driving into (historic) towns and cities is a fantasy notion from the 1950’s where unlimited motorised auto-mobility was assumed to be both desirable and possible. It is neither! The future of mobility needs to be very different from the models of the past – and the models still foisted on us through the all-pervasive car advertising that dominates our everyday media. 

Therefore, the starting point for this discussion needs to be around facilitating small, quiet, efficient vehicles – and radically de-prioritising the space provided for large, uneconomic, inefficient, 2000 kg+ single occupancy vehicles. The answers to the questions below follow on logically from this vision of the future.  

Question 3: Are there any types of PPTs (e.g. Segways, eScooters, electric unicycles etc) that you think should not be permitted to be used and why? No. These new technologies should generally be welcomed as incredibly space-efficient new mobility forms which, when used in combination with public transport in particular, offer smart solutions to decongesting towns and cities, and reducing the (thus far stubbornly high) carbon footprint from the transportation sector.  

Question 4: If the use of PPTs on our roads is to be permitted do you think that they should have some form of identification (i.e. a registration plate/marking)? No. We need to encourage their use and not create barriers. We need to make it easy to use smart sustainable transport – and hard to use space inefficient forms which cause proven dangers to people walking and cycling. 

Question 5: If the use of PPTs on our roads is to be permitted do you think that users should (a) be of a minimum age (if yes – what age?) and (b) have some form of licence covering their use (e.g. category AM driving licence – mopeds)? 

(a) Yes/No? Minimum Age ____  No. Non-electric scooters are already common and traditional modes of transport that have been used by people of all ages and e-scooters can be seen as an extension of this micro-mobility concept (albeit without the ‘active travel’ component).
(b) Yes/No? No. Once again, we need to make it easy to use space efficient forms of transportation and denormalise the notion that large individualised motorised mobility is a sensible way to organise our systems of mobility. We need to flip our existing assumptions and systems around. 

Question 6: If the use of PPTs on our roads is to be permitted do you think that their use should be covered by some form of insurance (i.e. liability cover)? No.  Similar to bicycles, this should not be a requirement.  The use of these PPTs, along with more active travel, will help to decongest our cities. However, it should be possible for users, who so wish, to insure themselves against liability for any damages they may cause.

Question 7: If the use of PPTs is to be permitted do you think that can be used on: (a) footpaths, (b) cycle lanes (c) bus lanes (d) normal traffic lanes? 

(a) Yes/No? No.
(b) Yes/No? Yes – but there is a need to widen and generally radically improve the quality of cycle-lanes and (off-road) cycle tracks.
(c) Yes/No? Yes, if there is no separate good quality cycle-lane / track provided on the route.
(d) Yes/No? Yes (in non-motorway contexts) but in the interest of safety for all, lower speed limits (particularly in urban areas) are needed and other progressive traffic management interventions which favour active travel and lower carbon modes. The definition of ‘normal traffic’ will need to change in transport discourses over the coming years so as to embrace these new mobility forms (including also e-bikes and e-cargo bikes for example). 

Question 8: If the use of PPTs is to be permitted do you think that they should be restricted to (i) a maximum speed (if yes – please suggest such a maximum speed) and (ii) only used on roads with a maximum speed limit of (a) 30kph, (b) 40kph or (c) 50kph? 

(i) Yes/No? Maximum Speed _____ Yes. 20-25km/hr.   

(ii) (a) 30kph? (b) 40kph? (c) 50kph? The broad approach here should be to reduce the speed limits on urban roads to 30km/hr so that walking, cycling and the use of PPTs is as safe as possible. 

Question 9: If the use of PPTs on our roads is to be permitted do you think that users should be required to wear (a) protective head-gear, (b) high-visibility clothing (i.e. be mandatory)? 

(a) Yes/No?  No. It should be similar to the existing requirements for cyclists in which helmets are non-mandatory.

(b) Yes/No?No. Referring back to the desired vision of the future as described earlier, the broad approach needs to be to reshape the urban environment so that those modes which we want to encourage are made to feel welcome and can operate in as safe an environment as possible – as opposed to a general approach of throwing ‘high hiz’ and helmets at the issue (and naively assuming this solves the problems) while leaving the hostile nature of the road environment largely unchanged. We would emphasise that these should not be necessary under daylight conditions, but that users need to take reasonable responsibility for their visibility to others (like cyclists). We do however think it should be a legal requirement to have lights on the vehicles/pilot at night-time. 

Question 10: If the use of PPTs on our roads is to be permitted do you think that users should (a) have some form of training

Mandatory training is not desirable here. However, training on the use of scooters and bicycles should be a standard component of the driving test so that the drivers of motorised cars, vans and trucks have a proper experiential understanding of moving in ways other than by being ‘behind the wheel’. However, it would be desirable for initial training in using the new vehicles to be made available for those who seek it because these vehicles will become part of the normal repertoire of transport options very soon. Additionally, we feel that the Rules of the Road should be introduced into the school curriculum so that school children leave school with a basic proven knowledge of the subject.    

(b) if so, by who? Ideally by the suppliers of the vehicles.  

Question 11: If the use of PPTs on our roads is to be permitted do you think that it should be left to local authorities to decide whether or not to regulate their use in their respective functional areas? Most broadly, we would support a national directive that LAs should support and cater for PPTs, but the LAs would have the authority to restrict use on some named roads on specific grounds. Local authorities are generally responsible for matters within their functional areas subject to nationally issued legislation, guidelines etc., so we would support a similar approach in planning for this new mobility form. 

Please provide any other comments relating to the use of PPTs that have not be address above.

How PPTs are legislated for and provided for in policy terms should follow on logically from the use of bicycles on our roads. I.e. they should be welcomed for all of the positive arguments about the efficient use of limited (urban) space, their broad alignment with the idea of making towns and communities more liveable and less noisy and, crucially, their low carbon footprint. 

We welcome the commissioning of the TRL research report (by the RSA). However we would urge DTTAS to explore the subject of PPTs more in terms of how they can form part of a low carbon new mobility system – as against one in which individualised motorised mobility in vehicles with a mass of (sometimes far greater than) 2000kg has, sadly, become the norm. Additionally we would urge DTTAS and the RSA to work with An Garda Síochána to develop more refined collision reporting forms/procedures so that the exact types of vehicles (SUVs, bike-share bike, e-bike, e-scooter etc.) are recorded at the time of collisions. 

Ultimately, the emergence of the new low carbon mobility forms we have already seen on our streets – and those which will emerge – must prompt a reshaping of our legislative, traffic management, infrastructural and street maintenance regimes, which in turn will bring about a paradigm shift in how people move above – i.e. mobility practices will evolve in response to the new regime. This positive, low carbon and more diverse vision of the future of mobility needs to be kept to the fore as we seek to recast our laws and regulations around transportation. 

The Minister for Finance, Paschal Donohoe has now presented Budget 2020. Prior to this, Cyclist.ie, the Irish Cycling Advocacy Network, sought 10% of the Land Transport capital investment to be allocated to cycling. This was in accordance with the Dáil vote last January, the report by the Joint Oireachtas Committee on Climate Change and the All of Government Climate Plan 2019. The reasons have been fully detailed in our Budget Submission 2020 and include climate change, congestion, health, pollution and sustainability.

Cyclist.ie notes that the government has allocated €1942 Million to the Land Transport capital budget and is perplexed that Minister Donohoe has announced only €9 Million for sustainable mobility. How much has been allocated to cycling? When will the government target on cycling be achieved? Either the government is unaware that there is a climate emergency or else they are releasing the good news in bite sizes.

Therefore, we await with interest from the Department of Transport, Tourism and Sport details of:

• The allocation for Improvements and Maintenance of Roads (ref B3)
• The Allocation for Public and Sustainable Transport (ref B8)
• Proposed grants for E-Bikes for reasons outlined in our pre-budget submission

As the saying goes: Don’t tell me where your priorities are. Show me where you spend your money and I’ll tell you what they are. We shall soon see where this government’s priorities are and if they are the same old, same old …

Clonakilty Bike Circus, which organises the repair and refurbishment of Clonakilty Town Bikes, among other activities, is inviting potential apprentices to apply for a comprehensive training course in bike repair and maintenance.  The course is free to attend, but requires a significant time commitment.  Check out the attached information sheet from the coordinator Jack Kelleher.  And apply via the email address  [email protected]. Jack and his team are also inviting you to be creative, and make your own bike from odds and ends!?  They want this bike to be readily and easily usable, and are terming it the ‘VolksBike’, following on from the original people’s car idea.  Can you build the ‘People’s Bike’? Its a real challenge with a €500 prize for the best built bike!  Check out the attached information and get building your ‘VolksBike’!

See also Bike Circus Apprentice Program and Bike Circus Contest

Galway City Council Disappoint with the Martin Roundabout Traffic Scheme

We urge all our supporters to let Galway City Council know that they need to up their game in designing for Cyclists and bus transport.  Based on the proposed scheme for the Martin Roundabout which is out for public consultation till 4pm on Monday 12th  August, the City Council and its consultant designers, do not appear to have studied the relevant guidance manuals!  The proposed scheme is available here

But, while the basic idea, from the proposal, of improving safety for all users at the roundabout is to be commended, the detailed design is of a shoddy quality that leaves a lot to be desired.  Check out our DRAFT submission below and feel free to copy part or all of it and make your own submission. The more people who point out the issues with this proposed design the better for public transport users and for cyclists.

Submissions should be made by 4pm on Monday 12th August directly to [email protected]

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 that cycling will become a normal part of transport and everyday life in Ireland.

We broadly welcome this proposed intervention in the change of design of the Martin Roundabout from a roundabout to a signal controlled junction, which will undoubtedly help to make the area safer for all users.   The public notice states that the proposed measures at the upgraded signalised junction include: provision of public transport priority measures, as well as  provision of cycling facilities and associated pedestrian enhancements and traffic calming measures.

However, we are unhappy with the proposed detailed design elements, particularly in relation to cyclists and public transport, which merit review.  In our submission below we have a number of comments to make on some general and specific design elements, which we suggest will improve the overall design and the safety elements of the proposed scheme, and encourage an increased rate of cycling and public transport enhancement.

2    Design Issues

2.1    General

2.1.1    Context

Galway has a growing population of cyclists, and congestion and private car use is a major everyday problem for the City and its health and economic wellbeing.  The growth of everyday cycling, as well as visitor cycling, needs to be encouraged. But the scheme as advertised is lacking in basic context. How does it link with existing road design?  How does it fit within the overall transport context of Galway City? What is the overall purpose over and above improving safety at the Martin Roundabout and improving access to the Galway Clinic?  Greater explanation of this context needs to be supplied and the exhibited material should have included a full Design Report.

2.1.2    Publicly Available Materials/Drawings

The scheme as advertised has 2 exhibited drawings, both nearly identical, with the same title, but one with a slightly greater extent than the other.  No Design Report, cross sections, or visual mock-ups are supplied, which make it nearly impossible to gauge the quality of parts of the design. It is difficult to understand why no cross section details are supplied at this public consultation stage, and this is unacceptable.

2.1.3    National Cycle Manual Compliance

Due to the paucity of exhibited material it is not clear how this proposed scheme complies with the guidance of the National Cycle Manual (NCM).  But in particular it appears to ignore the basic needs of cyclists as outlined in the NCM. The NCM outlines in Section 1.2 the critical ‘5 needs of cyclists’ when designing for the bicycle.  These five needs are outlined as:

• Safety
• Coherence
• Directness
• Attractiveness
• Comfort

It is not clear from the exhibited material how these issues are dealt with in the proposed design?   All of these issues need to be addressed in a comprehensive Design Report.

2.2    Specific Design Issues

While this proposed scheme is a small step in meeting the requirement of greater safety for road users, a number of basic design elements for safer cycling, and for public transport priority, appear to have been ignored in the proposed design:

2.2.1    Cyclists Sharing with Pedestrians

The principle of bikes sharing with pedestrians is one that is not recommended by the NCM as a first option.  As no Design Report has been included in this consultation it is impossible to know what other design options were considered here.  The NCM clearly states that ‘Shared facilities between pedestrians and cyclists generally result in reduced Quality of Service for both modes and should not be considered as a first option’.  We note the extensive sharing areas proposed at the main junction and we are unhappy with these proposals, which could be very easily upgraded to an acceptable standard.

2.2.2    Junction Design

At the new Martin junction cyclists are asked to revert to pedestrian mode, by sharing (ill advisedly) with pedestrians and  to wait for pedestrian signals, and are not being facilitated to cross with main traffic green lights as recommended by the NCM.  This is clearly not in line with NCM guidelines and we refer the designers to Section 4.4 of NCM – for further advice.  This needs to be altered.

2.2.3    Cycle Track Widths and Segregation

The width of the proposed cycle routes should conform to the recommendations of the National Cycle Manual; this is impossible to determine from the drawings exhibited, and, due to no cross sections being included, we are unsure if the cycle facilities proposed are segregated from pedestrians and traffic, or proposed as on road cycle lanes.  The drawings exhibited indicate cycle lanes, which would normally refer to on-road facilities rather than segregated. In the context of traffic levels in this area and the apparent 80kph speed limits this would be non compliant with the NCM, and unsafe for cyclists.  Segregated cycle tracks are required, not ‘cycle lanes’.

2.2.4    Speed Limit Reduction Possibilities

We are delighted to see the proposed reduction in speed limits to 60kph on the approaches to the proposed junction along the R446/N67.  This is a logical and welcome feature. However, we do not see any concomitant proposal to reduce the speed limits on the Old Dublin Road or the access road to and from the Galway Clinic, where cyclists are being facilitated by a new proposed cycle lane or track.  The logic of this omission escapes us, when considered together with the R446 speed reduction proposal. The proposal to apparently retain the 80kph limits is unacceptable and out of line with the recommendations of the NCM. There is a need to review the  speed limits on both of these junction legs.

2.2.5    Bus Lane Improvements

Public transport will play a continually greater role in the future of transport here in Ireland, and Galway.  While it is good to see some improvements in the proposed bus lanes along the R446/N67 and the Old Dublin Road, they do not go far enough in ensuring that buses get clear access right up to the junctions, and are given clear priority through the junction.  The design as outlined for the bus lanes is unacceptable in the context of where we need to go in relation to public transport improvements. We refer the designers and Galway City Council to some of the developing designs for the Dublin Bus Connects project

2.2.6    Limits of Scheme

The proposals, as outlined in the limited documentation available, show the proposed scheme terminating abruptly on the Old Dublin Road and on the Galway Clinic access road, as illustrated in the clips below taken from the scheme Drawing Number 5186221 / HTR / DR / 0101.

Despite the obvious links needed on the Old Dublin Road into a busy junction with the Doughiska Road, and obvious links on the eastern side to the Galway Clinic, the scheme has been terminated in ‘open country’ at both ends, making no sense in the context of desired links, and encouragement to use the facilities.  These ‘terminations’ are a shoddy piece of design.

Scheme Drawing   5186221 / HTR / DR / 0101

2.2.7    Permeability

The proposed scheme, particularly on the Old Dublin Road, lies right beside a major housing estate, Renmore.  The opportunity to open walking and cycling links into this estate have not been availed of. This should be examined when this scheme is being reviewed critically.

3    Summary/Conclusion

While we in Cyclist.ie welcome the conversion of the Martin Roundabout to a signalised junction, we are overall disappointed with the quality of the detail as shown in the very limited exhibited drawings.  In essence:

• The drawings and material exhibited are not sufficient to enable a proper assessment of the proposed scheme.  There is no Designer/Engineer’s Report and no cross sections or visualisations of the proposals.
• The proposed scheme does not appear to comply with the guidelines of the National Cycle Manual in a number of respects and needs to be completely reviewed in that context.
• The Bus Lane provision is limited and poor and does not conform to best practice.
• The proposed scheme has physical boundaries, which appear to bear no relation to the broader context of travel in the area, with stark unacceptable endings at both eastern and western ends that do not encourage greater cycling levels, and do not link into obvious destinations.
• There is a need for consistency in the proposed application of speed limits, which is not shown in these proposals, as outlined above.

We wish to see a comprehensive review and design report for this scheme, to place it in context and to demonstrate compliance with national design guidelines.  We in Cyclist.ie would be happy to meet with the designers and Galway City Council at any stage, to discuss any of the points raised above.