Earlier today, Irish Cycling Campaign made a submission to the Department of Transport in respect to its Public Consultation on “Moving Together – A Strategic Approach to the Improved Efficiency of the Transport System in Ireland”. The full submission can be read below.

Irish Cycling Campaign wishes to sincerely thank all of our volunteers who contributed to the drafting of this submission. It is this ‘behind-the-scenes’ volunteering that helps to shape transport policy and practice for the benefit of people who cycle and those who would like to cycle if conditions were improved. If you are not already a member of ICC, do please considering joining or making a donation (via https://cyclist.ie/join/).

1 – Introduction

The Irish Cycling Campaign (formerly Cyclist.ie, the Irish Cycling Advocacy Network – ICAN), is the national cycling advocacy body with membership from individuals from urban and rural cycling advocacy groups, greenway groups and bike festivals on the island of Ireland. We are the Irish member of the European Cyclists’ Federation and an active member of the Irish Environmental Network.  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.

2 – General Comments 

Irish Cycling Campaign (ICC) warmly welcomes the development of the “Moving Together” Strategic Approach to the Improved Efficiency of the Transport System in Ireland, together with its updated Implementation Plan, as presented here https://www.gov.ie/en/consultation/b51b0-moving-together-a-strategic-approach-to-the-improved-efficiency-of-the-transport-system-in-ireland/.  

We note, and welcome in particular, the following elements of the Minister’s Foreword:

“Space is now at capacity in many of our historic medieval and market towns, and with an increasing population and a buoyant economy, it is apparent that the car-centric model has finally reached the limits of its efficiency…. This Strategy is about putting people, rather than cars, at the centre of our urban and transport planning…..  Heavy traffic makes public transport less reliable, often discouraging people from using it, and makes the environment for vulnerable road users, such as pedestrians and cyclists, less safe, again, too often, discouraging people from using active travel, particularly for shorter journeys.” (p6)

ICC wishes to stress that it is essential that each of the targets and the timelines set out in the Strategy and Implementation Plan are strictly monitored and reported on, given that transport emissions are currently still on an upward trajectory, if Ireland is to attain its climate targets in relation to transport. 

We strongly support the Draft Strategy’s adoption of the Avoid-Shift-Improve framework: this represents an effective hierarchy for tackling the multiple factors at play, while prioritising the common good.

3 – Specific Comments

3.1 – Overall Ambition and Sense of Urgency
We note the introductory words of the Executive Summary which read:

“The Strategy is a call for collective action across Government and society not only to help reduce carbon emissions from transport over the medium to long term but to address more immediate issues of congestion, road safety and air quality”. 

ICC would like to stress that the decarbonisation of transport needs to happen incredibly rapidly, and happen over the short term, and not just “over the medium to long term”. The year 2030 is less than six years away and, given the rapid post Covid rebound that has occurred in transport movements, it is very likely that the transport sector will exceed its Sectoral Emissions Ceiling of 54MtCO2eq for the first carbon budget period of 2021-2025 (as set out in the government’s Sectoral Emissions Ceilings document from Sept 2022 – https://www.gov.ie/pdf/?file=https://assets.gov.ie/234926/2ebb2431-d558-4a54-a15c-605817c37b2f.pdf (Table on p4)). This means that the Sectoral Emissions Ceiling for transport covering the second carbon budget period of 2026-2030 will need to be (potentially significantly) lower than the sector emissions ceiling of 37 MtCO2eq as set out in the same table of the above document. The challenge is far greater than initially assumed and therefore we implore the Department to express a far greater sense of urgency about the challenge at hand in the opening parts of this Strategy. 

We note also the following objective of the Strategy:
“To contribute to the national target of halving transport emissions, by reducing total vehicle kilometres travelled by 20% by 2030.” (page 19).

We are assuming here that the base year against which (i) transport emissions will have been halved and (ii) vehicle kilometre will have been reduced by 20% is 2018 (i.e. in line with the years stated in the Sectoral Emissions Ceiling document above), but this needs to be stated explicitly – otherwise the objective is unclear.      

3.2 – Planning & Land Use integration
We particularly support the ‘Avoid’ principles and measures of the Draft Strategy, for example the recommendation to place Local Authority plans which integrate planning and transport onto a legislative footing.  This will enable Local Authorities to refuse permission for excessively car-dependent developments.  We note that the 2022 National Sustainable Mobility Policy (SMP) cites the integration of land use with transport planning as one of its primary goals.

3.3 – Sustainable Transport Support
The draft Strategy is commendable in its support for existing policies that encourage cycling for transport, and sustainable transport generally. The draft Strategy aligns strongly with the Town Centres First policy, and will underpin and support implementation of more specific guidance such as the Design Manual for Urban Roads and Streets and National Cycle Manual.

3.4 – Polluter Pays
We commend the ‘user and polluter pays’ approach outlined in Section 9, and we support the measures aimed at reducing tax incentives for car use – particularly of larger, heavier SUV type vehicles, and their use in congested areas, as was examined by the TII’s BRUCE project. Recommendations 2, 18 and 20 of the draft Strategy offer potential benefits, if considered with care and effectively implemented.  The example of higher parking charges for larger vehicles as introduced in recent months in Paris refers (see https://urban-mobility-observatory.transport.ec.europa.eu/news-events/news/paris-introduces-triple-parking-fees-suvs-2024-02-12_en).

3.5 – More Effective Road Traffic Law Enforcement Required
Excessive car use in Ireland is, arguably, facilitated by our ineffective and underfunded road traffic law enforcement regime. Speeding, mobile phone use, and drink and drug driving have increased since the pandemic, and the worsening road toll is the result. An effective road traffic law enforcement system is, arguably, a demand management measure that current laws and policies already endorse, and should be considered as part of the Strategy.

3.6 – Consumer Education & Awareness
Action 30 of the draft Implementation Plan may offer further potential benefits arising from social and behavioural change. The power and reach of car advertising needs to be challenged as a matter of public health. Consumer awareness of the overall costs – external and personal – of car dependency is an important part of awareness raising (not just which cars emit less Greenhouse Gases than others). Such external and societal costs include: congestion; the use of land that could otherwise provide public amenites; tyre and brake dust pollution; mining of rare earth materials for battery production; and the public health costs induced by sedentary lifestyles.  In turn, the growth in the availability of car sharing options needs to be amplified to dampen demand for individual car ownership, and should be included.

3.7 – Optimal Spaces
The Irish Cycling Campaign very much welcomes the recognition, in the Optimal Spaces sub-committee report, of the health and climate implications of optimising space for active and sustainable travel. We commend the authors’ acknowledgement that optimisation of space applies in both urban and rural areas.

3.8 – School Supports
We note that Action 25 – Increase sustainable mobility supports for primary and secondary children – inexplicably fails to include reference to improved Cycle Training.  The Irish Cycling Campaign advocates that investment in this area should be diverted through the new Primary School Wellbeing curriculum by delivering professional development courses and upskilling to class teachers, as cycling education now falls directly under their remit. See also ICC’s recent submission on this topic, available at https://cyclist.ie/2024/06/irish-cycling-campaign-submission-on-primary-wellbeing-curriculum/. 

3.9 – Transport Appraisal Framework (TAF)
The Transport Appraisal Framework – https://www.gov.ie/en/publication/c9038-transport-appraisal-framework-taf/ – is the present tool used for the assessment of project benefits. It appears that this TAF only considers broadly economic parameters (TAF Module 8), but it must also consider social, public health, environmental, pollution, and population effects as well as the economic effects. We request a review of this latest Guideline, as part of this Moving Together strategy.

3.10 – Empowering & Supporting Local Authorities
We strongly welcome the emphasis in the above section of the Implementation Plan to further empower LAs to better deliver transport projects. LAs are the cornerstone of delivery mechanisms across the country, and the 7 supportive Actions (Nos 3 to 9 inclusive) as outlined will be critical in rolling out the required transport changes.

In particular, we emphasise the proposals of Action 6 on ‘Integration and Multi Disciplinary Teams’  and Action 8 ‘Communications & Engagement’.  We elaborate on both these points here.

Integration – As an active travel advocacy body connecting with LAs countrywide, we notice the vast differences in approaches and resources across the landscape, mainly between major urban LAs and smaller rural LAs. It is critical that, in particular, the skills of multi-disciplinary teams are made available to the smaller LAs on an organised and agreed basis. This Action 6 is likely to be implemented by particular skills being shared across small groups of LAs, but the mechanism must be established. We also note the very tight timeline outlined of Q3 and Q4 2024 for actions under this heading.  Is this realistic?

Communications & Engagement – In our countrywide / nationwide experience, this aspect of LA duties is often sadly neglected, and in some LAs even discouraged.  We welcome the proposed commitment to ensure funds for this area are made available. For projects to gain acceptance and buy-in by local communities these skills must be urgently developed to the required level.  We note again some tight timelines and hope these can be achieved?

3.11 – Implementing Demand Management  
We note and endorse the strong and multiple references to the development of demand management practices in the public and private sectors, across a large number of proposed actions, and different organisations.  The development of these practices will, in the long term, lead to greater use of sustainable transport for everyday use and for special events.

In regard to congestion charging, one strand of a wider package of demand management measures, we note here the argument that is sometimes presented – that ‘congestion charging is a regressive tax and that the better-off are privileged by being better able to absorb it’. However, we know from the experience of the introduction of congestion charging in cities such as London and Stockholm that the people who benefit the most from congestion charging are, in fact, bus users who comprise people from much broader socio-economic backgrounds. These bus users benefit greatly from reduced and far more predictable journey times, and especially when the income from congestion charging is re-invested in further improving the public transport system. In other words, congestion charges save bus users both time and money. See the paper on “Equity effects of congestion pricing: Quantitative methodology and a case study for Stockholm” available at https://www.sciencedirect.com/science/article/abs/pii/S0965856405001618.     

3.12 – Legislation Development
We endorse the need for a full legislation review to ensure that the various measures proposed do not come up against legal challenges.

3.13 – Oversight Mechanism
It is critical that the proposed National Demand Management Steering Group be adequately empowered to fulfil the requirements of Action 35, so it can compel and facilitate actions by national and local bodies and ensure that all potential benefits of this Draft Strategy to Irish society come to fruition.

3.14 – Timelines
We have referred above in paragraph 3.10 to some tight timelines on actions related to Empowering & Supporting Local Authorities. The multiple actions outlined have many tight timelines, and it will be critical for the Steering Group to ensure that these timelines are adhered to, and that full regular update reports are supplied to all stakeholders such as the Irish Cycling Campaign and others.

4 – Summary / Conclusion

The Irish Cycling campaign welcomes, commends and supports this draft Moving Together Strategy and its related recommended actions. Subject to our comments above, we look forward to its implementation. 

In particular we emphasise:

• The need for the Strategy to express far greater urgency to rapidly reduce emissions from the transport sector – starting immediately / in the short term, as well as over the medium and long term. This urgency follows on from the requirements of our own Climate Action and Low-Carbon Development (Amendment) Act 2021 and the tight carbon budget programme that follows on from it. 
• The importance of strong oversight and reporting via the proposed Steering Group
• The need to include adequate traffic law enforcement within the overall demand management proposals
• School cycle training to be included under Action 25
• Include a review of the Transport Appraisal Framework, with a view to ensure inclusion of social, public health, environmental, pollution, and population effects
• The necessary supports for the empowerment of Local Authorities, in particular the smaller rural LAs to ensure multi disciplinary skills are available to them.
• The need for regular updates on progress from the Steering Group
• The need to ensure that the tight timelines are adhered to and that progress is being made

Colm Ryder
Infrastructure Coordinator
Irish Cycling Campaign
www.irishcyclingcampaign.ie