Cyclist.ie – the Irish Cycling Advocacy Network
The Tailors’ Hall
Dublin, D08 X2A3
Date – 14 Oct 2022
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 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.
Cyclist.ie welcomes the opportunity to respond to the public consultation on NR2040. However, we are very disappointed in the limited options for submission of comments in this form – and with the word limit here which limits the ability to respond to the consultation.
We welcome the broad “NIFTI approach” where the intervention hierarchy is (in this order):
Maintain > Optimise > Improve > New
Active Travel > Public Transport > Private Vehicles.
2 – Main Points
What the draft does not set out clearly enough is how exactly, with figures underpinning the strategy, NR2040 and investment priorities ensuing from it will align with the overarching aim of the Government’s Climate Action Plan, which sets a 51% reduction in overall greenhouse gas emissions by 2030 and sets Ireland on a path to reach net-zero emissions by no later than 2050. The section on Decarbonisation (5.1), referencing the EPA Ireland’s Greenhouse Gas Emissions Projections, 2021-2040 (June 2022), states the following:
“Emissions from the sector are estimated to reduce to 39% below 2018 levels by 2030 if additional measures in plans and policies are implemented, including significant EV share by 2030 and measures to support more sustainable transport.”
However, in the 2022 OECD report entitled Redesigning Ireland’s Transport for Net Zero: Towards Systems that Work for People and the Planet, (Paris, https://doi.org/10.1787/b798a4c1-en), two of its key findings are as follows (pages 8 to 9):
“The Irish transport system fosters growing car use and emissions by design, and is thus unfit to enable the country to meet its greenhouse gas reduction goals while improving well-being. Growing car use in Ireland is largely determined by car-dependent transport and urban systems, organised around increased mobility and characterised by three unsustainable dynamics: induced car demand, urban sprawl, and the sustainable modes low-attractiveness trap.”
“Aiming at decarbonising the system via private vehicle improvements is unlikely to lead to substantially different patterns of behaviour, rapid emissions reductions, and large well-being improvements. Car-dependent systems make rapid electrification slow and difficult, by locking-in large and growing vehicle fleets. Even with improved (and fully-electric) vehicles, they also fail to reduce lifecycle emissions, address accessibility gaps and other negative impacts (e.g. road fatalities).”
The same report recommends the following (page 9):
- Redefine the goal of the transport system as sustainable accessibility.
- Prioritise the up-scale of policies with high potential to transform the car-dependent system.
- Redefine the electrification strategy to support the transition towards a sustainable transport system.
- Embrace a systemic approach to policy decision-making across government departments.
It is our view that the current NR2040 strategy needs to engage with and respond to these recommendations.
In short, the final / adopted version of the NR2040 strategy needs to respond fully to the newly published OECD analysis.
It also needs to set out how the implementation of the strategy will contribute, in concrete terms, to the steady decarbonisation of the Irish transport sector over the years and decades. This needs to be set out in quantitative terms.
OUR SUB IS CONTINUED ON ANOTHER FORM – VERY FRUSTRATING FORM WITH ITS WORD LIMITS.
THIS IS PART 2 OF THE CYCLIST.IE SUBMISSION. VERY FRUSTRATING FORM WITH ITS WORD LIMITS.
3 – Conclusion
NR2040 needs to articulate much more clearly how the strategy objectives and investments will lead to a reduction in carbon emissions – and not simply rely to a very large extent on assumptions that the electrification of the car fleet will solve most of the problems in this domain.
Please acknowledge receipt of this submission. Thank you.