Irish Cycling Campaign submission on R448 Road Space Pilot Scheme (Kildare)

Earlier this week, Irish Cycling Campaign (ICC) made a submission on the consultation on the R448 Road Space Pilot Scheme being developed by Kildare County Council. You can read details of the consultation here, and our submission below.

In short, ICC is disappointed at the poor quality of the consultation material presented and the dearth of background context.  We urge Kildare County Council and TII to revisit the material and the general proposed designs, and to give interested parties, such as ourselves, a clear idea of why this trial is being proposed and where this design proposal fits into the national context. 

1 Introduction
The Irish Cycling Campaign (formerly, the Irish Cycling Advocacy Network), is the national cycling advocacy body with membership from 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 and pedestrian friendly culture, where everyone has a real choice to cycle and move about safely, and is encouraged to experience the joy, convenience, health and environmental benefits of cycling and walking.

The Irish Cycling Campaign is happy to see this project being advanced under a Section 38 process, ideally allowing a rapid turnover to this trial construction.   However, we are nevertheless disappointed at the shoddy presentation of this important pilot scheme for space reallocation on a 3.8 km section of regional road R448.  In the assumed context of the long term development of a National Cycle Network (NCN), any proposed developments along these lines need to be clearly signposted, explained, and contextualised.  While the presented material provides food for thought, there is not enough background explanation of why different systems have been chosen or different junction types proposed.  We elaborate on our criticisms below.  Public consultation should be about clarity and ease of access overall.  This is not the case here.

2 General Comments
2.1 Poor Information on Consultation
The proposals on this nearly 3.8km section of the R448 route, a former N route, to trial various pilot designs, is presented without any proper context, and thus difficult to understand.  There is no background explanation of why the various different forms of carriageway cross section have been chosen, or any outline of why the 4 different proposals were chosen above others?  The consultation documentation requires a clear concise explanation of the context, the choice of site, and the chosen length of the trial section?
We can only assume that this trial is related to the envisaged national NCN proposals, and proposing possible solutions for the application on old N road?  This is not good enough from Kildare CC and TII.
We also deplore the lack of clearly identifying each map/drawing for context rather than Map B, Map C etc.  

2.2 Carriageway Cross Section & Cycle Lane Width
We note the overall ‘typical’ carriageway width of 14 metres presented, and its division into 7 (2×3.5) metres of main carriageway, 2×1 metre hard shoulders, 2×1 metre separation areas, and 2×1.5 metres cycle lane.  It is not made clear if this 14 metres is a rigid dimension for all or most old N routes, or what level of variation exists?

As a cycling advocacy organisation we are particularly interested in the cycle lane details and overall comfort and safety.  The proposed width of 1.5 metres is in the ‘absolute minimum’ category acceptable width for a one way cycle lane, as outlined in Table 2.2 of the National Cycle Design Manual(CDM).  This proposed width does not allow for comfortable overtaking or cycling two abreast.  If this pilot is geared towards a national NCN design it needs to factor in the allowance of side by side cycling of friends, and the use of these routes by groups of cyclists from clubs around the country, as well as individuals, otherwise cycling groups will continue to use the main carriageway.

In the above context we recommend that ideally a cycle lane width of 2 metres be chosen where feasible, which is the ‘desirable minimum width’ of a one way cycle lane as outlined in the CDM.  However, a lower width may be acceptable over short distances.  A reduction in the hard shoulder width may also be a possibility, to ensure a workable cycle lane width?

2.3 Junction Treatment
We note the varying forms of junction treatment outlined at different side road junctions.  In general cycle traffic is downgraded and not given priority along the main route at the larger junctions, having to give way to traffic coming off or exiting on to the R448.  This is not acceptable.  It is incumbent on the designers, in the light of national policy and ambitions, and in the context of climate change, to treat cycle traffic as a main element of vehicle movement.
In this light traffic coming off or into the side road must give way to mainline cycle traffic and the junctions should be designed accordingly.

2.4 Junction Radii
We note the proposed variation in junction radii at different junctions, which we feel needs re-examination.  For junctions such as the 50kph speed limit routes (Moone Road & Timolin Terrace) and the various small cul de sacs, a 13 metre radius is excessive and unlikely to encourage vehicles to negotiate the junctions more slowly.  The design context for these smaller local junctions needs to be factored in, including the prioritisation of mainline cycle traffic over turning vehicles.  Reducing the junction radii will also simplify the junction design for cyclists and pedestrians.

2.5 Main Road Crossings
We endorse the proposals to include a 2 stage crossing of the main (R448) route close to sizeable side road junctions.  We fail to understand why this should not also apply to the R747 junction?  This type of decision requires background and clarity.

2.6 Carriageway Layout, Material Variations
We note the 4 different proposals for carriageway layout, and assume that the ‘modular island’ design shown in Inset B includes either a continuous fence or series of bollards on the elevated modular island?  If this is the case, it would be our preferred design choice, providing overall greater protection for cyclists.  We are happy to see a clear kerb/upstand provided in each proposal, which provides extra protection for the cyclist.

2.7 Speed Limits
We wonder if the issue of varying speed limits along the R448 or other main routes might be considered on approaches to major junctions?  This would encourage slower speeds of vehicles in general, but also enable safer turning and exiting manoeuvres for vehicles using the side roads.

3 Summary / Conclusion
In summary, the Irish Cycling Campaign is generally disappointed at the poor quality of the consultation material presented and the dearth of background context.  We urge Kildare County Council and TII to revisit the consultation material and the general proposed designs, to give the general public and interested parties, such as ourselves, a clear idea of why this trial is being proposed and where this design proposal fits into the national context.  The other comments above in Section 2 remain germane.

Colm Ryder
Infrastructure Coordinator
Irish Cycling Campaign 

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