Cyclist.ie made a submission to Fingal County Council this week (on 7th July 2021) on the non-statutory consultation on the Royal Canal Urban Greenway, 12th Lock to Kildare Border. For anyone less familiar with the stretch, it runs westwards from the 12th Lock, located quite near the junction of the M50 with the N3 (Navan Road).

The overarching point in our submission is that we are fully supportive of the emerging preferred route along the north bank of the Royal Canal, that connects directly with the already agreed section from the Kildare Border to Maynooth.

Cyclist.ie supports the proposed North Bank Route because:

1  It is simpler, easier, and more economical to construct 
2  It is less invasive of natural areas and protects the rich natural environment of the existing south bank
3  It provides greater access to more people than a potential south bank route, which is severed from housing by the main railway line
4 It permits any plans for the DART+ project to advance separately along the greater part of its length
5  It retains the characterful walking paths along the Deep Sinking section
6  It avoids the huge engineering works that would destroy the environment along the South bank.

You can read a copy of our full submission below.

You can see the documentation issued by FCC to which we responded at this link here: https://consult.fingal.ie/en/consultation/royal-canal-urban-greenway

You can read Dublin Cycling Campaign’s web page on the topic here: https://www.dublincycling.com/cycling/royal-canal-greenway-needs-your-support 

1.0     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. Cyclist.ie is the Irish member of the European Cyclists’ Federation (https://ecf.com/). Our vision is that cycling will be a normal part of transport and everyday life in Ireland.

We commend Fingal CC for the advancement of this vital piece of commuter and leisure cycling/walking route, as part of the Dublin to Galway cross country greenway and the European EuroVelo Route 2 – https://en.eurovelo.com/ev2/ireland

We are fully supportive of the emerging preferred route along the north bank of the Royal Canal, that connects directly with the already agreed section from the Kildare Border to Maynooth.  This Greenway Route has the potential to provide a high-quality, safe, walking and cycling path for commuters, local residents, and visitors alike, and will ultimately link up with Greenway and commuter routes eastwards into Dublin City and westwards to the River Shannon. It is bound to encourage greater active commuter travel by bike, will undoubtedly attract more visitors to the area, and on its eastern end will serve as a commuter cycle route to and from a number of high employment locations in West Dublin and Dublin City.

We note that the present consultation phase is a non-statutory consultation, and we look forward to the final detailed development of the proposed route in due course? 

We also have a number of specific comments and issues, which we outline below in subsequent sections.

2.0 General Comments

2.1 Choice of North Bank Route

Cyclist.ie fully endorses the choice of the route on the North Bank for the following reasons:
1  It is simpler, easier, and more economical to construct 

2  It is less invasive of natural areas and protects the rich natural environment of the existing south bank

3  It provides greater access to more people than a potential south bank route, which is severed from housing by the main railway line

4  It permits any plans for the DART+ project to advance separately along the greater part of its length.

5  It retains the characterful walking paths along the Deep Sinking section

6  it avoids the huge engineering works that would destroy the environment along the South bank

2.2 Surface Proposals

On a major potential commuter and leisure cycle route such as this Royal Canal section, the necessary surface should be a bituminous tarmacadam (asphaltic concrete) surface for its full length. Recent research suggests that a bituminous surface is also more environmentally friendly than a loose grit/dust surface.  Bituminous surfacing is the preferred type of surface by cyclists in general, but also for wheelchair and pram users.  It is also the preferred surface type recommended in the TII ‘Rural Cycleway Design – DN-GEO-03047’ document. This should be made clear in any future design statements.

2.3 Route Width

We are delighted to see the proposed width standard of at least 4 metres, and only be reduced to 3 metres in areas of constraint, and in the rural sections. It could be aiming for 5m wherever possible, especially closer to built up areas from Clonsilla onwards into the city centre. 

In the more high volume locations, such as between the 12th Lock and Diswellstown Road/Dr Troy Bridge, the design team might consider an alternate to the standard shared pathway. A segregated path design, with the cycle track at a lower level than the footpath would reduce conflicts in the more high volume usage area. Here below is an image of the Royal Canal within Dublin City Council’s area for a high-volume area.

2.4 Access and Road Crossing Design Details

On the basis of the drawings exhibited it appears that there will be no use of restrictive access gates along the length of the route, as there are no details supplied for access gates on to the route.  Cyclist.ie warmly welcomes this decision, which will encourage access by all ages, types and abilities of users.  We assume that any potential access gates will, at the very least, comply with the recommended design given in Rural Cycleway Design – DN-GEO-03047.  We favour clear unobstructed access.  Photo montages of any proposed access gates would be particularly useful at further detailed design stage, as connections and road crossings all along the route raise a number of fairly standard safety issues. 

2.5 Multi Access Proposals

Despite objections from a number of residents in the area of Brompton and Delwood estates in the Coolmine area, we are happy to see a number of potential access points highlighted from nearby roadways and housing estates where most of the proposed route is located.  In the future we feel that  these residents will recognise the real benefits of having these access points.  Fingal CC need to ensure that this proposed greenway is also accessible from densely populated areas to the south of the canal. This will necessarily involve re-evaluating all roadways and in particular safe cycle facilities in these areas, and general access to the Greenway.

2.6 Lighting and Security

It is critical, not only for local perception and peace of mind, but also for general safety and ability to use the proposed greenway at all times winter and summer, that appropriate lighting (bat friendly) be put in place, particularly in the areas of high residency.  This lighting should also be supplemented with appropriate and effective security monitoring in these areas.

2.7 Park & Ride Access

Consideration might be given to the provision of Park & Ride sites along the route, for multi modal commuters to be able to drive to locations beside the canal, park their car and continue their commute by bicycle, or by train, from that location to their destinations.

2.8 Specific Location Related Points
In our submission to the previous non-statutory consultation process in 2019 Cyclist.ie made a number of specific location related observations.  These were at the following locations:
–  Collins Bridge
–  Hansfield SDZ and potential new rail station
–  Pakenham Bridge
–  Callaghan Bridge
–  Kennan Bridge
–  Sheepmoor Lane

We assume that the issues raised in these areas will be addressed at the detailed design stage due at either Part 8 planning or ABP application stage.

3.0 Summary

Cyclist.ie warmly welcomes this proposal to develop this section of Royal Canal Urban Greenway. We hope that our comments above will be helpful in examining the issues along the proposed route, and we look forward to the publication of the further detailed design at the final planning stage.  Once again we would be happy to meet with the Council and designers at any stage to develop any of the points raised above

Colm Ryder
Chairperson
Cyclist.ie – the Irish Cycling Advocacy Network
http://cyclist.ie/ 
Registered Charity Number (RCN): 20102029
7th July 2021

Cork Cycling Campaign have won the inaugural Active Community Group Award from the Cork Sports Partnership!

There were four categories in the awards: group, campaign, inclusion and champion.

There were lots of entries and three finalists in each group. A short video was made of each group: 

Note that the Cork Cycling Campaign video starts at about 14 minutes.

Cork Cycling Campaign was nominated by the Chairperson, Conn Donovan. 

The Campaign gets a medal, a certificate, some goodies and a hamper! 

Congratulations to all the crew in CCC from Cyclist.ie!

“We have a strategy. We have a team. We’re missing just one thing – you.”

In 2020 the Irish Cycling Advocacy Network Cyclist.ie adopted a new strategy. This strategy sets out the vision, mission, values and strategic aims. It also makes clear who we are, and why we do what we do. Our strategy is a high-level framework that will guide our Council, Executive Committee (EC), volunteers, and the National Cycling Coordinator (NCC) in their work. Its main purpose is to help direct our limited time and energies on what we decide our key aims and objectives are. It is about providing guidance on where we should concentrate our efforts in terms of campaigning priorities and organisational development.

Following the adoption of the strategy, the next challenge was to organise ourselves in a way to enable us to take action and achieve the aims and objectives outlined in the strategy. We’ve now taken the first step by proposing a structure that allows us to handle the ongoing day-to-day operational tasks, whilst progressing our strategic aims. The concept is to create a number of “portfolio groups” that are each responsible for particular areas.

We’ve identified eight portfolio groups, each with the same structure:

• A liaison from the Exec team, and also a non-exec liaison to promote wider involvement from the cycling community
• A set of day-to-day or reactive tasks that this group is responsible for, handling all the many and varied activities that keep Cyclist.ie moving forward
• A set of strategic or planned tasks aimed at delivering on our overall goals

So far, so good. So what parts of the strategy are each of the portfolio groups responsible for?

How we’ll achieve our strategic objectives

After a number of workshops we arrived at the result shown in the table below. Note that our six main strategic aims are shown on the left hand side (each of which has several objectives sitting within it), while our 8 portfolio groups are shown in blue on the top.:

The numbers indicate the number of strategic objectives in each portfolio – noting that the objectives vary widely in scope and scale.

We expect this structure to adapt and evolve over time as we put this into practice, and the first step is to invite you to get involved.

How to get involved

Each portfolio has a liaison from the exec team, and the first job of the liaison is to present their portfolio at the June Council meeting and invite you to get involved. Involvement can be as small or large as you have capacity for, so please get in touch! Shown below are the eight portfolio groups and the liaison person (or persons) associated with each

Cyclist.ie’s newest member group, Drogheda Cycling, has penned the following piece outlining why it came into being and what it is focusing on. Welcome on board!

Hello, Noel Hogan here. I’m the Chairperson of the newly formed Drogheda Cycling group. The group first came into existence as a twitter account (@droghedacycling) before being established as a proper organisation earlier this year. 

Growing up in the 1980s/90s in Ennis in County Clare, bicycles were our ticket to greater freedom. No longer did we need the mammy taxi to bring us to places far away. Looking at my own six year old, I realised that – if something wasn’t done – his childhood would be robbed of this sense of freedom. This led me to reach out to others who wanted to create a safe environment for cyclists (and others) in Drogheda, and this group is the result. 

Our aims are to create a safe environment for cycling in and around Drogheda and to raise the awareness of cycling for all as a practical alternative to car use. Like many towns around Ireland, it would be fair to say Drogheda is not a cycling friendly town – busy roads, a lack of cycling friendly infrastructure – but much the same was said of many European cities until quite recently. I really think Drogheda is primed for a renaissance and our group is going to play a major part in making it a more pleasant, liveable town for everyone.

Our focus this year is to establish and grow our group – we have made submissions to Louth County Council regarding the planned active travel routes for the town and have recently held our first community cycle. We believe that we must be the change we seek – and having regular family friendly cycles is one way to demonstrate the benefits of cycling to all (and being part of Cyclist.ie is a great help in this regard). We hope to broaden our engagement with stakeholders and gain more community support as the year goes on. 

One of the great things about Cyclist.ie is that it allows you to engage with other like minded groups – here in Drogheda we have been happy to engage with the Navan Cycling Initiative and hope to further our engagement as time goes on. It really helps when you can learn how others have approached engaging with local authorities and other stakeholders. 

You can contact Drogheda Cycling via:

Email – [email protected]
Twitter – @droghedacycling
Facebook – /Drogheda-Cycling-102975298149028

Cyclist.ie and all our members are supporting medical aid for Palestine, by cycling next weekend the 19th and 20th of June.  All you have to do is organise your cycle, by yourself or with friends, and collect any small donations which you can donate directly online to the medical relief fund via the link https://www.justgiving.com/fundraising/muhannedb.  Cyclist.ie is delighted to support Islamic Relief in this Cycle for Palestine Challenge. These fundraising cycles can be done individually or in groups anywhere in the country. 

For more details see here or the enclosed booklet.

Last September (2020) the Cyclist.ie Rural Cycling Collective officially launched our Vision for Cycling in Rural Ireland with the 8 priorities which we believe will enable more people in rural Ireland to cycle more often for everyday journeys.

Since we launched the Vision we are pleased to see changes have been made, linking to each of our 8 priorities. Some of these changes are big, others small but we believe all changes in the right direction are worth celebrating.

Below is a summary of the 8 priorities and what’s happened so far as of mid-2021.

1 – Create an environment in our cities, towns, villages and rural roads where Cyclists are Expected and Respected.

There is a growing recognition that,in addition to dedicated cycle lanes and tracks, there is huge potential to create environments in our urban and rural areas where people on bicycles feel expected and respected. Glimpses of this welcoming environment have been seen in a number of different towns and villages such as Ennis, where they redesigned the streets to create more space for active travel; Clonakilty where they removed motor traffic from some streets; Kilkenny where they introduced traffic calming measures; many towns where they introduced lower speed limits; and across the country where signs such as the 1.5m safe passing distance signs have been installed.

Within and between many towns and villages, cycle friendly infrastructure could include identifying safe routes along the existing smaller rural roads. With extra signage, traffic calming measures and lower speed limits, these “Rothar Roads” would allow people in rural areas to have the opportunity to cycle to schools, shops, work, and amenities knowing that they are ‘expected and respected’ by all road users. Community based projects have been started to identify and map these for example the ‘Share your Rothar Roads project in Leitrim.

2 – Create and map a network of useful, Connected Cycle Routes throughout Local Authority Areas

The Rural Cycling Collective knows that quality network planning is key to quality cycle infrastructure, securing funding, garnering support, promoting cycling as a real alternative and so much more. In December applications opened for a €50M active travel fund for towns and villages, which was subsequently increased to €70million due to the volume of requests. In March the projects were announced. Several counties have received funding for transport studies including: Monaghan where they have drafted a Cycling & Walking Strategy; Kerry, where both Tralee and Kilarney will get interconnected cycleway networks; and Leitrim, where a County Cycle Network Plan Study is being planned. We hope this is the start of network plans being created in every local authority area. 

3 – Implement Best Practice Design to ensure routes are safe and comfortable for cyclists of all ages and abilities

In January the Department of Transport announced the creation of 248 new active travel posts 218 in local Authorities and 30 in TII Regional Design Offices – see the story on our website here. In announcing these posts, Minister for Transport, Eamon Ryan said that the new structure for the delivery of active travel is intended to “ ensure that the increased levels of expenditure planned deliver the right type of infrastructure, in the right place and at the right time.”  

The new posts are yet to be filled but the Rural Cycling Collective are pleased to see the emphasis is on creating multi-disciplinary teams that acknowledge the complexity of reallocating road space and the need for not just engineering and architectural skills, but also communication and promotion. We hope that these new posts will help raise standards across the country.

Cyclist.ie also note that the National Transport Authority are expanding their team to ensure they have the capacity for oversight of all the new active travel schemes. Simultaneously a review of the National Cycling Design Manual is being undertaken – another welcome step. 

A team within Cyclist.ie have also been busy the last few months creating an ambitious tool to be used as part of the design process to help ensure that none of the 5 needs of cycle route design (coherence, comfort, directness, attractiveness and safety) are overlooked. The latest prototype is currently being trialled and Cyclist.ie would welcome your feedback. To find out more about the Cycle Route Assessment Checklist (CRAC) and to get involved in trialling it follow this link – https://cyclist.ie/crac/.

4 – Prioritise Safe Cycle Routes to Schools and car free zones at school gates

The school year began optimistically with Cycle Buses popping up and more and more children cycling to school everyday. Some of these were inspired by the Rural Cycling Collective’s Get to School on Your Own Fuel campaign which saw families practising their routes to school before the September rush. 

Safe Routes to Schools became an issue on many people’s minds. In March, Minister of State, Hildegarde Naughton, announced the allocation of €15million for the Safe Routes to School programme – see here. Dun Laoghaire Rathdown County Council have initiated a safe routes to school project with widespread consultation. We look forward to seeing similar schemes in other Local Authorities.

 

5 – Lower Speed Limits to make our roads and streets safer and more accessible for everyone, and to reduce casualties

Lower speed limits are a simple but vital way to make our roads and streets more accessible and safer for children, pedestrians and cyclists.  Love 30, the campaign for 30km speed limits, issued a press release in April, calling on the Minister for Transport to mandate a default 30km per hour speed limit in urban and built-up areas and outside schools – see https://www.love30.ie/call-default-30-kmh-all-urban-areas. 

Kilkenny County Council are set to introduce a Gateways project at the entry points into the city – within this area a 30km/h speed limit is to be applied. Dublin City Council are also introducing reductions in speed limits which again we hope will be an inspiration to local authorities across the country – see here. 

6 – Ensure clear and timely Access to Funding by improving capacity at all levels of local and national government

A few months before the Vision for Cycling in Rural Ireland was launched it was announced that the new Programme for Government included a commitment to allocate €360M per year in capital funding to walking and cycling over the next 5 years. This was an exciting announcement and the strongest endorsement towards Active Travel ever seen in Ireland.To find out more about the detail of this commitment check out the full Programme for Government here.

This progressive announcement has been followed up with subsequent rounds of additional funding – further welcome steps forward in the country’s commitment to taking climate action. 

7 – Collaborate with all Stakeholders including cycling and community groups – at all stages of planning and design

If the promises in the Programme for Government are to lead to meaningful change, collaboration with all stakeholders is going to be important – the right people need to be asked the right questions at the right time. 

In Skibbereen, collaboration is happening between cycling activists, councillors, local engineers and the local community.  A  recently formed Greenway group is looking into the permeability of Skibbereen, connecting the town within. Mapping is being developed to link schools and amenity areas with households and shops (for more info contact [email protected]). More information on this can be found by emailing [email protected]. 

Stakeholders have also come together from various organisations in Kilkenny, including Kilkenny County Council, Kilkenny LEADER Partnership, Kilkenny Recreation and Sports Partnership, Healthy Ireland and Waterford Institute of Technology (WIT) to work collaboratively on the CycleKilkenny project. The group has been working closely with Kilkenny Cycling and Walking Campaign group. See here.    

Cyclist.ie’s ambitious Cycle Route Assessment Checklist (CRAC – http://cyclist.ie/crac/) has the aim of enabling a wider range of stakeholders to get involved in the design process. A perceived lack of ‘technical know-how’ and a lack of time can prevent ordinary people from participating in public consultations and assessments. It is envisaged that this user-friendly checklist will give people a quick, simple and meaningful way of allowing their voices to be heard.  The National Transport Authority and a number of Local Authorities are now trialling this tool.

The Stop Climate Chaos coalition of which Cyclist.ie is a member has been holding a series of workshops about aspects of the Climate Plan. On Tuesday, May 4th the Rural Collective had an opportunity to input to the workshop on Transport. On behalf of the Collective, Joan Swift explained how implementing the Rural Vision could contribute to reducing emissions from transport.  She stressed that in Rural Ireland, as elsewhere many trips currently done by car are short and lend themselves to active travel. Cyclist.ie submission on the Climate Action Plan can be read here: here.    

8 – Provide Cycle Training for all ages, especially children

Under a national program Cycle Right (https://www.cycleright.ie/), is being rolled out across the country, run by Cycling Ireland. 

Cycle Training is an important piece of the jigsaw to build a culture of cycling. It improves bike skills and road awareness. For some children it is the first real opportunity to use a bike. Cycle training combined with quality cycle infrastructure, Safe Routes to schools. and a reduction of speed limits will provide opportunities for young people to gain the confidence they need to be able to cycle safely, not just to school but as they grow and gain more independence, to meet friends, to go to college, to work – it really is a skill for life.  

Outside of schools we have also seen cycle training sessions for families (e.g. the Sligo Cycling Campaign Family Fun Cycle) as well as sessions for teenagers wanting to cycle on road and for parents wanting to steward cycle buses (e.g. the Leitrim Cycling Festival Cycle Confidence Programme).

And finally, to spread the love of bikes and work towards their manifesto goals the Rural Collective launched #RotharRides in February of this year. These take place on the first weekend of every month and are fun cycles that everyone can get involved in by simply enjoying a ride in their local area. Already we’ve seen rides happening from Donegal to Clonakility and many places in between. 

Despite the pandemic we have a lot to be positive about. 

The Rural Cycling Collective which only formed last summer has been busy building momentum, bringing media attention to the potential of everyday cycling in rural Ireland and creating something well worth shouting about! 

We can’t wait to see where the roads will take us next!

Note: Further images below kindly provided by Luciana Prado.

Cyclist.ie is thrilled to see the announcement of the programme of events for the 10th Annual Clonakilty Bicycle Festival.

As always with the Clon Bike Fest, a proper celebration of all things two-wheels is planned! From humble beginnings in 2011, the Clonakilty Bicycle Festival has held true to its organic DIY ethos and become a popular and much-loved town festival over the years, signalling for many Clon people ‘the start of the summer.’ 

Taking place on the second weekend in June every year, Clon Bike Fest has always aimed to be as inclusive as possible, hosting four days of free events involving all kinds of fun with bicycles – from the hugely popular ‘Meals on Wheels’ (a 5 course mystery dinner party on bikes), the annual ‘Cycle-In Cinema’, kids hullabaloo, yoga and picnic events, and the Free Bike Clinic (which grew into ‘The Bike Circus’, Clonakilty’s community bike workshop). 

Memorable events over the years have included: Clon’s first ever ‘Cycle-Powered Cinema’ in 2016 set up in The Venue of O’Donovan’s hotel with four stationary white bikes needed to be constantly cycled to power the film projector; ‘To Will or not Two Wheels’ with a Shakespeare performances on bikes; the birdwatching ‘Estuary Cycle’, and who could forget 2019’s ‘Bikeoke’ in DeBarra’s, karaoke while riding a bike! 

This year, due to public health interests, an interactive line-up is planned, with most events broadcast on YouTube live and solo or family/pod group cycles to be incorporated into the fun.

The festival kicks off with an international welcome and the annual ‘Blessing of the Bicycles’ online. Other events include a ‘Big Kids Public Art Project’ with a competition to create the funkiest craft bikes that will be displayed around the town, a pop-up bike workshop to drop into at Inchydoney, a film screening event live on YouTube, an Art/Music Collaboration between composer Justin Grounds and artist Becky Hatchett, a zoom fractal ride (a zoom group call on bikes!), a wine, chocolate and bikes evening on YouTube with Fionnuala Harkin and Allison Roberts and a final blow-out zoom dance party! 

There is also a 10th Anniversary ‘ZINE!!’ to get your hands on, and a special edition collection of 10 illustrated postcards to purchase, which all helps fund the festival into 10 more years! 

To get involved or to check out the amazing schedule of events, head over to www.clonakiltybicyclefestival.org

On Friday last, 28 May 2021, Cyclist.ie made a detailed submission to the Department of Transport on the National Investment Framework for Transport in Ireland, or NIFTI for short. 

According to the department’s website (where you can find all of the background papers on NIFTI:  

NIFTI is the Department of Transport’s contribution to Project Ireland 2040, Government’s long-term strategy for accommodating population growth in a sustainable manner and making Ireland a better country for all of its people. NIFTI has been developed to ensure that our transport sectoral strategy is underpinned by and supports the achievement of the spatial objectives and National Strategic Objectives set out in the National Planning Framework.

So the question is, will the new investment framework be ‘nifty’ in a traditional sense of that word? It’s too early to say because the final NIFTI document is not due to be published until Q3 of this year, but we are doing our best within Cyclist.ie to help shape what the document looks like. 

You can read our full submission below, but the essence of our it is that transport policy-makers in Ireland need to engage far more seriously with the concept of decarbonisation to the degree that we need to have net zero emissions by 2050 across all sectors – and to have a 50% reduction in emissions by 2030, less than 10 years away from now. 

We stressed throughout our submission that transport investment needs to be massively weighted and front-loaded towards active travel and public transport over the coming decades. We raised in our submission the point that the digital revolution in recent years has enabled people to work on screens while travelling on trains or buses, but crucially this is not possible when one is driving. We urged the Department to promote intermobility so that one can travel to/from rural communities in a low carbon way – with the bulk of the distance covered on public transport – and to do this there needs to be proper funding of conveniently located, high quality and secure cycle parking facilities at every single train and bus station (and stop) in the country, and with high capacity facilities at the bigger stations such as one sees in the cities of Utrecht (NL) and Munster (Germany) for example.

Additionally, we made the point that there needs to be serious engagement by the Department and Transport Infrastructure Ireland with the reality of “induced demand” – i.e. that the provision of extra road capacity results in a greater volume of traffic. The evidence for this has been mounting for 25+ years – e.g. see Goodwin’s 1996 paper entitled Empirical evidence on induced traffic. The policy of seeking to expand road capacity is completely at odds with our commitments to decarbonise transport. 

A sincere thanks to our talented team of volunteers who fed into the preparation of our full submission below – all done at rapid pace while juggling lots of other campaigning jobs. Kudos to you all! 

FULL CYCLIST.IE SUBMISSION ON NIFTI

Section 2: Supporting the Project Ireland 2040 Vision

The National Planning Framework has established a clear direction for the sustainable development of Irish society in the coming decades, as articulated by its ten National Strategic Outcomes. How can transport investment support this vision?

• All of the 10 national strategic outcomes have their part to play. However, the decarbonisation of all transport, both public and private, is the most critical and cross-cuts all broad outcome areas.
  
• While the proposed national Sustainable Mobility Policy (SMP) concentrates on public transport and active travel, the scope of this SMP policy needs to be revisited – and broadened out. All private transport and commercial transport needs to decarbonise and become sustainable, not just the active and public strands of it.
  
• In considering the proposed transition to Electric Cars, one needs to bear in mind that burning fossil fuels to provide energy for mining, drilling, processing and transportation of materials for battery and other vehicle components leads to CO2 emissions embodied in a typical EV. See https://sitn.hms.harvard.edu/flash/2019/how-electric-cars-can-become-truly-green-once-and-for-all/. Irish transport policies must take into account the energy and emissions costs of creating the vehicle and disposing of it at the end of its life; only considering the emissions when the vehicle is in use does not provide a complete picture. This needs to change.
  
• Clear policies on demand management and the suppression of unnecessary motor vehicle travel by businesses and individuals must be implemented in order to increase active and public transport travel and restrain unfettered growth in private/commercial movements.
  

Section 3: Delivering the National Strategic Outcomes

How can transport investment support the delivery of compact growth in our towns and cities in the coming years?

• Resource Local authorities with the required professional staff to plan, promote, and implement the necessary projects in line with national policy.
  
• Implement major ‘place making’ public developments so as to encourage social and business improvement.
  
• Adopt at a national level the 10 minute town / 15 minute city policy with appropriate practical measures.
  
• Improve the quality of data collection on traffic movements, both locally and nationally, and include in this pedestrian, cycle and personal powered transport – and intermodal travel.
  
• Provide greater resources for road safety research and improvements.  The cost to the economy and society of the yearly toll of road injuries and deaths needs to be more fully accounted for and acted upon. The 2020 International Road Safety Conference ‘Stockholm Declaration’ stated as follows: “Acknowledge that the overwhelming majority of road traffic deaths and injuries are preventable and that they remain a major development and public health problem that has broad social and economic consequences which, if unaddressed, will affect progress towards the achievement of the SDGs;” We must adopt a clear Vision Zero approach to road safety and a safe systems approach to any transport developments in order to reduce economic and social losses. See https://www.roadsafetysweden.com/contentassets/b37f0951c837443eb9661668d5be439e/stockholm-declaration-english.pdf 

How can transport investment enhance regional accessibility in the coming years?

• Transport investment needs to be massively weighted and front-loaded towards public transport. Of particular relevance here is the digital revolution in recent years which enables people to work on screens while travelling on trains or buses, but crucially which is not possible when one is driving. This point needs to be fully acknowledged when arriving at a new transport investment framework.
   
• Review transport/freight companies and their locations and possible grant system to encourage coordination of resources and possible relocation of businesses closer to major transport hubs and routes.
  
• Provide inter town segregated greenways with adequate width and sealed surfacing to attract commuters as well as recreational cyclists, similar to the European cycle super highways – see for example https://ec.europa.eu/transport/sites/default/files/cycling-guidance/cycle_superhighways_2018.pdf 

How can transport investment strengthen rural economies and communities in the coming years?

• There needs to be an additional focus on strengthening the local public transport bus system and ensure it connects seamlessly with the rail system.
  
• In regard to promoting intermobility so that one can travel to/from rural communities in a low carbon way, there needs to be serious funding of 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.
  
• Review the practical and economical use of the public transport fleet to improve the effectiveness of transport options particularly in rural areas.
  
• Accelerate the implementation of EV charging points countrywide. 

How can transport investment deliver sustainable mobility and encourage modal shift in the coming years?

• There needs to be serious engagement by DoT and TII with the reality of “induced demand” – i.e. that the provision of extra road capacity results in a greater volume of traffic. The evidence for this has been mounting for 25+ years – e.g. see Goodwin’s 1996 paper “Empirical evidence on induced traffic” – https://link.springer.com/article/10.1007/BF00166218. The policy of seeking to expand road capacity is completely at odds with our commitments to decarbonise transport.
  
• Public transport options need to be improved greatly, particularly rail and bus. Currently we do not have a rail “system”, we have mainly a series of radial lines running to / from Dublin.
  
• Every local authority in Ireland needs a high quality cycling and walking policy – https://www.bypad.org/. 
  
• In rural Ireland, a policy of ‘rothar road’ development should be implemented in line with the Vision for Cycling –  https://cyclist.ie/ruralvision/. 
  
• Promotion of the use of sustainable transport options needs to be upgraded to counter-balance the impact of car advertising.
  
• People who choose to cycle to their destination need to know that it will have secure bicycle parking and that workplaces have drying rooms. State agencies, public services and health bodies in particular have an obligation to ensure that employees and visitors are provided with bicycle parking.
  
• The Safe Routes to School scheme announced in 2021 is welcome, but if we are to enable sustainable mobility on the school run, funding in future years needs to be greatly increased as, at the rate of 100 schools per year, it will take too long to cover our 3000 primary & post primary schools.

How can transport investment in surface access support high-quality international connectivity via our ports and airports in the coming years?

• Again, in the context of decarbonisation, the rail and sail journeys need to be far more seamless and pedestrian / cyclist friendly. To take the example of the trip from Dublin city via Dublin Port and Holyhead to London, the existing trip for pedestrians is unnecessarily fragmented, unattractive and grim. If seeking to promote surface transport, we need to make proximate trips – such as Ireland to Britain – much more attractive.

How can transport investment help us to transition to a low carbon and climate resilient society in the coming years?

• See many of the points above, but the overarching policy needs to be centred around a radical shift from investment in new roads to investment in public transport and active travel; otherwise our national carbon footprint will continue to expand.
  
• Demand management must be implemented to suppress growth in private vehicle travel.
  
• 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 https://ecf.com/news-and-events/news/electric-bikes-replace-polluting-cars-france-introduces-innovative-scrappage.
  
• Last mile low carbon delivery systems must be implemented in towns and cities to reduce need for access for HGVs and large vehicles to town centres.
  
• Introduce Zero Emission Zones and low traffic neighbourhoods in towns and cities.
   
• 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.
  
• Commission and publish a peer reviewed independent study to assess the impact of reducing speed limits on motorway, N-roads and other roads on transport emissions in Ireland. 

Section 4: Transport Investment

What challenges and opportunities exist with regard to decarbonising the transport sector?

• The big challenge is to reduce the extent of car dependency and give as many people as possible the option of alternative sustainable modes of transport and being able to live without owning the depreciating asset that is a car. There is an opportunity there for the Department of Transport to transition into being a leader in supporting people to live car-free through the provision of radically improved public transport, improved conditions for active travel and high quality information to knit everything together.
  
• Encourage businesses to have virtual meetings rather than in-person ones.
  
• Obviously provide more charging points for electric cars – Norway has an estimated 16,000 charging points – Ireland has a fraction of these but we must ensure that the space for them is reallocated from cars not from pedestrians or cyclists.
  
• Complete the updating of the Common Appraisal Framework to take carbon emissions, and all ancillary issues, into consideration when appraising and making decisions on road projects.
  
• Introduce road pricing as in Sweden and London.
  
• In the future, the extent of flying must be reduced. Short haul flights nationally should be reduced – similar to what the French government is doing.
  
• Introduce a frequent flyer tax. Frequent flying needs to discouraged, not incentivised. 

What challenges and opportunities exist with regard to protecting and renewing the existing transport network?

• In particular the continued upgrading of existing transport hubs and stops to acceptable standards that enables and promotes greater public transport usage.
  
• A shift to rail, especially for freight, will reduce HGV damage to roads. 

What challenges and opportunities exist with regard to improving mobility for people and goods in urban areas?

• Provide high quality segregated cycling infrastructure to agreed high standard under new developed National Cycle Manual guidelines.
   
• Restrict the movement of private cars in areas of high pedestrian and cycling use.
  
• Reconfigure road space to reflect the person carrying capacity of vehicles.
  
• Further restrict vehicles such as HGVs and Sports Utility Vehicles which provide an increased threat to vulnerable road users in urban areas.
  
• Encourage and facilitate the use of cargo bikes for last mile deliveries.

What challenges and opportunities exist with regard to enhancing regional and rural connectivity, including to our ports and airports?

• The biggest challenge is improved public transport, including rail transport for freight, to all major ports and airports. It need to be super easy to get everywhere by public transport – currently it is not. 

Do the four NIFTI investment priorities help to deliver the National Strategic Outcomes? Should anything change about them?

We support these four priorities.

However, renewal should refer more explicitly in the documentation to our too-often-forgotten rail infrastructure, not just the road infrastructure. 

Section 5: Further Comments

Do you have any further comments to make on the National Investment Framework for Transport in Ireland?

• With the requirement to decarbonise transport completely over the next 29 years – really not a lot of time – we have a unique opportunity, and indeed legal and moral obligation, to shift the direction of transport investment in Ireland away from its utterly unsustainable trajectory to one which is in line with the ecological limitations of the planet. We cannot waste this opportunity. 
• The government’s target is to reduce carbon emission in transport but any new roads will increase emissions due to induced demand (as per Section 3 above). However, some new roads are unavoidable if we are to improve road safety at particularly unsafe locations. The increase in emissions from the induced demand must be offset by investment in additional sustainable transport schemes, which reduce carbon emissions due to change in modal share in the local authority area.
  
• SFILT and SIFLT largely reflected 20^th century thinking on investment in transport with a ‘roads first’ policy. The suite of documents did include a paper on climate change, but the paper was published before the 2015 Paris Agreement and the 2018 Citizen’s Assembly report. The inclusion of updated reports is welcome as part of NIFTI.
  
• It is accepted that decarbonisation of transport is essential to meet national targets on climate action, but the carbon impact of projects must be an essential part of decision making on project appraisal, rather than simply being noted or “taken into account”.
  
• Irish engineers generally use a largely UK database such as TRICs to predict the number of journeys generated by private vehicles. However, the result of Ireland emulating a country with one of the highest car dependency rates in Europe (rather than a country such as the Netherlands with one of the lowest), reinforces the status quo and in Ireland in the last twenty years has contributed to flat-lining in the proportion of people cycling nationally.
  
• TII sets out the calculation of future demand on national roads for the next 30 years in its Project Appraisal Guidelines for National Roads Unit 5.3 – Travel Demand Projections. As it specifies a growth rate in future years of between 1% and 3% per annum depending on the county and assumed growth rate, TII are in theory designing roads on the basis of up to 90% more trips in 2051 than at present. In recent years TII has published National Road Indicators annually which report the actual growth of traffic on the national road network. Between 2015 and 2019, the actual annual growth of traffic on national roads is even greater than the TII’s highest prediction with some regions of the country experiencing rates in excess of 5% per annum. This gives rise to questions about the sustainability and cost benefit analysis of current road plans.
  
• Phil Goodwin, emeritus professor of transport policy at a number of UK universities, has challenged the cost of carbon used in the cost benefit analysis of new roads and also how the increase of carbon emissions from cars using new roads is minimised by comparison to the percentage of overall carbon emissions. This is in contrast with employment, where additional employment, whether for 10 or 1000 new jobs, is welcomed as a positive thing rather than comparing the increase as a percentage of overall employment levels.
  
• Neither the Department of Transport nor the Joint Oireachtas Committee on Transport acknowledges in a meaningful way the central role of transport in creating unhealthy communities and the financial burden it imposes on society. If this government is to be successful, the current road projects in the National Development Plan must be completely reviewed with revised appraisals and realistic models to ensure that future investment is in accordance with current government objectives rather than ones that belong in the past.

• We wish the Department the very best in producing the final NIFTI document – and, crucially, in reconfiguring the direction of transport in Ireland in a properly sustainable way – and we look forward to engaging with you again soon.