A large part of’s advocacy work is conducted through making submissions to government departments, agencies, local authorities and other bodies in response to public consultation processes. In these submissions we set out’s position and make recommendations. 

Yesterday (18 May 2021), made a submission on the Call for Expert Evidence for the preparation of the Climate Action Plan 2021. A copy of our submission on the topic of transport is pasted below. 

The overarching context here is the commitment in the 2020 Programme for Government to an average 7% per annum reduction in overall greenhouse gas emissions from 2021 to 2030 (a 51% reduction over the decade), and to achieving net zero emissions by 2050. 

We note in particular that according to the EPA, the transport sector in Ireland accounted for 20.3% of greenhouse gas emissions in 2019. And between 1990 and 2019, transport showed the greatest overall increase in emissions at 136.8%, with road transport increasing by 142.4%.

The direction that transport takes over the next ten years clearly needs to change radically if we are to address the climate and biodiversity crisis which threatens our safe future on this planet.

We need to step up our campaigning.

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1 What further policy measures might be required to enable Ireland to meet the CAP 2019 target of 936,000 electric vehicles on the road by 2030? 

We need to be massively increasing the number of electric-assist bikes on the road, and not simply seek to replace a 1500kg+ fossil energy powered car with an equally heavy EV version which itself has a significant embodied energy from its construction and uses scare minerals with significant environment impacts from their mining. 

We need a new transport system, not the same one with electric cars. 

2 Is there scope to increase this target for 2030? What should the new target be? 


3 What specific measures might be required in the commercial transport sector to encourage a change to EVs or other zero carbon alternatives? 

The initial requirement here is to stop the steady degradation of the Irish rail network so that, in addition to increasing passenger numbers, rail freight can play a serious part in reducing the volumes of heavy goods vehicles on Irish roads. While DART+ is a key element of new rail development, a new full rail review needs to take into account the planned increase in the price of carbon, and hence the new economic calculus of transferring goods to rail. 

Optimise logistics efficiency and reduce freight demand: The reintroduction of the ‘guard’s van’ in addition to the existing rolling stock could provide a flexible solution for transporting smaller parcels/ freight goods along with bicycles, e-bikes and scooters. Introduce parcel hotels at train stations and use the rail network to transport the parcels. 

There is tremendous scope to develop the cycle logistics sector in Ireland, and to transfer over to e-cargo bikes much of the commercial / delivery activity currently happening in urban areas by motorised heavy goods vehicles. For more information on cycle-logistics, see the City Changer Cargo Bike website.

Municipal fleet of the City of Gdynia, Poland
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Note that besides carbon emissions, heavy goods vehicles are very much over-represented in road traffic collision statistics and especially those involving people walking and on bikes. 

Zero-emission urban freight zones (ZEZ-Fs): Well-designed ZEZ-Fs encourage more efficient logistics (reducing the number of trips); a better mix of transport modes (e.g. using shared cargo bikes or light electric vehicles for the last mile of delivery); and a transition of the remaining vans and trucks to zero-emission. 

The Irish government should prioritise zero-emission vans in the upcoming revisions of the CO2 standards Regulation and the Alternative Fuel Infrastructure Directive (AFID). 

4 What additional measures should be considered to promote greater use of public transport or active mobility options? 

Regarding the term “promote”, we believe strongly that we need to go far further than “promote” and to be “enabling” public transport. 

Public Transport 

Funding. After allocating 20% of the capital budget for active transport (see below), the remaining 80% of the capital transport budget should be spent with a  minimum ratio of 2:1 in favour of public transport over road building.

Increase investment in rail with a view to expanding the extent of the network, and increasing the frequency and quality of services available.

Expand the Local Link Bus Services 

Fund / construct conveniently located, high quality, secure and attractive cycle parking facilities at every single train and bus station (and stop) in the country, and provide high capacity bike parking facilities at the bigger stations taking inspiration from the state of the art facilities which one can find at train stations such as in the cities of Utrecht in Nl and Munster in Germany. See the link here (Utrecht):

Implement BusConnects in all of the Irish cities, while using the opportunity to develop high quality cycle networks in all the cities – and in towns. Pilot the introduction of traffic free town centres with only public transport and active travel access. 

Ensure all new urban buses are 100% electric. 

Pilot the potential extension and cost of a free public transport scheme in certain areas to reduce private car use, with a view to developing a nationwide scheme. 

Active Travel 

Funding. Continue to allocate 20% of the land transport capital budget for walking and cycling infrastructure. This will start to make up for the almost complete absence of investments in these modes in Ireland in the latter half of the 20th century and into the 21st century. 

Extend the Bike to Work scheme to include students and unemployed. 

Develop, agree, and ensure compliance with, the new updated suite of mandatory and guidance documents for active travel including the National Cycle Manual (NCM), Design Manual for Urban Roads and Streets (DMURS), and Rural Cycleway Design (RCD). 

Lower Speed limits, with 30km/h to be the default speed limit in built-up areas. 

Segregated cycle lanes with proper treatment of junctions. 

Pavement and cycle lane parking to become as unacceptable as indoor smoking or drink driving. Targeted measures at sporting organisations, event organisers whose supporters/fans are amongst the main offenders. They must tell their supporters that it is quite simply unacceptable to block the access of people walking or cycling and that it may be necessary to park some distance away and walk the last section of their route just as they do to Croke Park on all Ireland Final Day. Just as the Tidy towns competition has a biodiversity section, it should have a “liveability” section where entrants who have uncontrolled pavement and cycle lane parking lose marks. The same should apply to local Authority Tidy Estates competitions. 

Traffic light timings must be adjusted to favour people moving by active means. 

Given that there are 3000 primary and post-primary schools, Safe Routes to School need to be prioritised at more than the current plan for 100 per year. 

Active Travel in Rural Areas / Rural Cycling Vision 

1. Create an environment in our cities, towns, villages and rural roads where CYCLISTS ARE EXPECTED AND RESPECTED. This would mean for example that provision of bike parking becomes mandatory at all public buildings, for example post offices, libraries etc and that provision of bike parking at workplaces and commercial premises becomes the norm. 

2. Create and map a network of useful, CONNECTED CYCLE ROUTES throughout Local Authority Areas LAs must be instructed to think Networks, not isolated segments of routes. This priority is allied to the overall integration of Transport and Planning, to the concept of the 10 minute town and the viability of rural villages. 

3. Implement BEST PRACTICE DESIGN to ensure routes are safe and comfortable for cyclists of all ages and abilities. National oversight of design, otherwise what we sometimes get is unusable and will not contribute to reducing emissions. 

4.Prioritise SAFE CYCLE ROUTES TO SCHOOLS and car free zones at school gates. Increase funding available for routes to school – the school run is one of the prime causes of short car trips. The €15 M allocated this year is welcome, but it will cover just over 100 schools. There are 4,000 primary and post primary schools in Ireland. 

5. LOWER SPEED LIMITS to make our roads and streets safer and more accessible for everyone, and to reduce casualties. Lower speed limits in built up and in rural areas will promote active travel which in turn will lead to a reduction in emissions. It is not feasible to expect people to walk and cycle on rural roads with a speed limit of 80 km/h. It is absolutely essential to introduce a default 30 km limit in built up areas and around schools as agreed by our Government at the Stockholm Convention 2020. You can read the Stockholm Declaration here.  

6. Ensure clear and timely ACCESS TO FUNDING, by improving capacity at all levels of local and national government. Active Travel Teams within LAs to expand – we need to ensure they are multi-disciplinary. The programme announced in January is welcome but many counties are only getting an allocation of 2 extra staff which is not enough to form a team. Consideration should be given to combining resources to form larger teams to serve smaller counties.

7. COLLABORATE WITH ALL STAKEHOLDERS – including cycling and community groups – at all stages of planning and design. Adopt and promote the Cycle Route Assessment Checklist tool (or a version of CRAC) as a national tool to be used as part of the design process by both designers/engineers and people participating in the process – create a common language and common understanding of good quality design and provide a simple way for people to meaningfully input. 

8. Provide CYCLE TRAINING for all ages, especially children. Expand Cycle training budget and number of Cycle Right trainers. Currently only one class (usually 5th) can apply but training needs to start earlier to build the cycling habit and reduce cars/emissions on the school run. A whole school approach to cycle training should be adopted. Transport emissions reduction cannot happen if only one child in a family receives training and siblings still have to be driven to the same school. 

Photo Credit – Luciana Prado


Climate proofing of all proposed public projects must be implemented and seen to be observed. 

Economic assessment of transport projects needs to be more broadly assessed and realistic, and values for parameters such as the ‘value of time’ must be regularly updated to reflect the shift in technology and people’s ability to work while in public transport. This assessment must include the use of the WHO HEAT tool (Health & Economic Assessment Tool), to give full weight to health and societal benefits of proposed projects 

Formalise legislation which encourages greater levels of cycling and makes it safer, as for instance exemplified in the TFL report ‘International Cycling Infrastructure Best Practice Study’ – 

5 What specific policies might be required to reduce overall passenger kilometres driven within the private car fleet? 

The lessons from the Covid-19 pandemic in terms of the ability for many employees to work from home or alternative local hubs need to be acknowledged and  the new practices encouraged. Remote working must be supported.

Introduce a scrappage scheme for cars to be replaced by e-bikes or e-cargo bikes. Cf. the scheme introduced into France recently whereby car users are given a €2500 voucher for an e-bike. See this ECF article on the scheme.

Make the centres of cities car free – as is happening in Paris (see here). 

Expand Safe Routes to School 

Make public transport cheaper especially for families. When making travel choices families don’t consider the embedded cost of driving; they consider that a journey between X and Y will cost €20 in fuel or combined bus fares of €30 and make their choice accordingly. 

Space for public transport needs to be prioritised in towns and cities. 

6 Is there scope to effect a change in the composition of the private car fleet to shift the vehicle mix away from higher emitting classes? 

Introduce a ban on SUVs in city centres – as per the example in Paris. They are too wide, too high and too long for city centre streets, in addition to the emissions and negative road safety impact in relation to collisions with pedestrians. 

Increase taxation levels on higher emitting vehicles even further 

7 Is there scope to further increase biofuel blends rates beyond those already planned under the 2019 Climate Action Plan?


8 Are there any specific obstacles in the planning system preventing greater modal shift? 


9 Are there specific further measures that should be undertaken to increase the availability of electric vehicle changing points, whether in public areas or on private property? 


10 What could be done to make the public sector transport fleets more climate friendly? 

Commission and publish a peer reviewed independent study to assess the impact of reducing speed limits on motorway, N-roads and other roads in Ireland. 

11 What changes should be considered in relation to the management of Ireland’s road network (e.g. reducing speed limits, additional road pricing, or restrictions for specific vehicles in urban areas) to promote emissions reductions? 

12 What other opportunities exist to support the decarbonisation of the Transport sector? 

13 What specific measures could be undertaken in transport infrastructure to address existing and future locked-in climate change impacts? 

See this link here from the Department of the Environment, Climate and Communications for more information on the call for expert evidence:

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