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

As we do each year in advance of the government preparing its budget, we made our Pre-Budget submission to the Minister for Finance at the end of last week. You can read a copy of it below. A sincere thanks to our super hard working team of volunteers for preparing this document. If you appreciate this work / are not yet a member of Irish Cycling Campaign, we would be delighted if you joined up – https://cyclist.ie/join/.

Aggressively Promote Climate Change Requirements 
Increase the Level of Transport Capital Funding Allocated to Create High Quality Conditions for Cycling and Walking Countrywide   

#1 – Introduction  
The Irish Cycling Campaign (formerly Cyclist.ie), is the umbrella body of cycling advocacy groups in Ireland (https://irishcyclingcampaign.ie) and the member for Ireland of the European Cyclists’ Federation (https://ecf.com/). Our vision is that cycling, as a mode of transport, becomes a normal part of everyday life for all ages and abilities in Ireland.  

As recognised in the Programme for Government (PfG), cycling as a mode of transport offers numerous well documented broad benefits to society as well as being “the most important tool in combating Climate Change” (European Commission Executive Vice President, Frans Timmermans, September 2021). Four years on from the publication of the PfG, unlocking these benefits has assumed even more urgency. 

We know from data that private cars are used for nearly 30% of journeys as short as 2km or less. We urgently need to enable and encourage travel by bike and on foot for shorter journeys by funding the required infrastructure to an even greater degree than at present. We also need to enable multi-modal bike trips by funding both bike share schemes, and adequate, safe and secure bike parking at bus, tram and train stations/stops in both urban and rural areas.   

Enabling cycling – whether stand-alone, or as part of intermodal trips – is the fastest and most cost effective means of meeting the targets set for transport in the Climate Action Plan 2024, and in the Climate Action and Low Carbon Development (Amendment) Act 2021. Cycling infrastructure and fiscal incentives for cycling can be rolled out on a fast timescale and offer a far better return on investment than other transport spend.  

 
#2 – Summary Asks  
In short, we seek the following: 
 

1. Infrastructure – Urgent need to further increase funding for high quality Active Travel schemes, from the present €360M.  We suggest that an increase to €500M for the coming year would go a long way to meet our climate commitments.  This funding also needs to support the critical small Active Travel teams in smaller local authorities.  

2. Policing – We are seeking a commitment that a 50% minimum of new Garda recruits are deployed to roads and community policing. This is in the context of the rising numbers of road traffic casualties over the last two years. Perceived danger on our roads deters people from taking up cycling. More visible enforcement will not alone reduce deaths and injuries but will encourage and enable more people to choose walking and cycling. 

3. Bike to Work Scheme needs to be restructured. Move away from the PAYE sector only to a system that will allow children, retirees, unwaged people, carers, people on disability allowances to avail of an equivalent system, and hence enable more bike use. The people most in need of subsidised bike purchase are not in the tax system, e.g. students, unemployed, pensioners. Also, it’s not just biking to work that needs to be subsidised but all journeys.  

4. Business focused Cargo Bike Schemes for the city centres of the five Irish cities.  While some schemes have been rolled out there needs to be a major commitment to driving their success. 

5. VRT. Review VRT levels for all sizes, weights and types of vehicles, to promote the use of greener and smaller vehicle models. Sports Utility Vehicles (SUVs) should be specifically targeted for increased VRT. This reflects the increase in road danger they create for people walking and cycling arising from the driving of larger, heavier vehicles. These vehicles now command 60% of the new private car market.  

6. VAT. Zero rate VAT on bicycles, accessories and bicycle repairs – to promote the circular economy, create jobs in the green economy, and make cycling more affordable for people of all incomes¹.  

7. Safe Routes to School Funding increased with the objective of the removal of all school motor traffic from internal school grounds and the immediate front of school zones in all urban and suburban schools by September 2026.  

8. Bike Parking and Bike Scheme Investment – Large indoor and supervised bike parks, for the variety of bike types, at all major city bus and train stations. Covered safe and secure bike parking at medium sized transport hubs, and bus shelters and stops. We would also ask that funding streams are developed to provide subsidies for bike parking at shops/shopping centres, workplaces, churches, sports clubs, stadia, gyms, plus for temporary bike parking at major events, including major sporting events.  

9. Education & Training – Funding to establish cycle training delivered by teachers as part of the primary school curriculum. This follows the identified priority for teachers to teach cycling within the new Primary Wellbeing Curriculum draft document. Please find the submission from the Irish Cycling Campaign at the link below. 

Link:
https://cyclist.ie/2024/06/irish-cycling-campaign-submission-on-primary-wellbeing-curriculum/ 

10. Adult Education – Expanded funding for adult cycling education with a particular focus on marginalised communities such as IPAS members and those living in areas of disadvantage. We would request that this funding be delivered via local authorities as part of their behaviour change initiatives in a format similar to the Cycle Confident schemes in the UK. 

Link: 
https://www.cycleconfident.com/sponsors/southwark

 
Further detail on the above items is provided below.  

#3 – Further Details 

Walking and Cycling Infrastructure  
While the Irish Cycling Campaign welcomes the serious and continued investment into active travel that this government has brought forward, it has become clear that our 2030 and 2050 decarbonisation goals in transport are rapidly slipping out of reach. In the recent EPA provisional reports on our emissions targets, they noted that transport was a key problem area that saw emissions increase yearly despite the significant increase in electric motor vehicles².  

Our current spend as per the Programme for Government is €360m per year. However, rising inflation levels has led to increases in the delivery costs of infrastructure projects, and this has has been earmarked by the NTA as a barrier to achieving the delivery of the full complement of projects³. This is placing an increase of approx 30% cost onto delivering active travel and other infrastructure projects. From our engagement with local authorities, active travel teams and the NTA, there is a clear demand and willingness to do more but limited funding does not allow this. Quite simply €360m in 2024 does not deliver the equivalent in terms of infrastructure that it did in the first year of the Programme for Government.    

In short, high quality infrastructure is what enables modal shift. Investment in this area will deliver huge value for money in meeting our climate targets. We are calling for an emergency measure raising this annual funding to €500m per year over the final year of this government. The allocation of €500M of Active Travel infrastructure funding between now and 2025 to meet what is required in our climate responsibilities would send a clear sign that the government is taking this aspect of the climate emergency and the need to decarbonise transport seriously and set a marker for the next government to follow.  

Policing 
2024 has been one of the worst years in recent memory for deaths and injuries of vulnerable road users such as pedestrians and cyclists. While we welcome the increase of 1,000 new garda graduates, we ask that their deployment be focused on Roads and Community Policing. 

We also ask that there is a funding stream made available via the Department of Justice to An Garda Síochána to develop a robust advertising and education programme around driver responsibility in regards to vulnerable road users such as pedestrians and cyclists. As part of this there should be an upskilling of all existing Garda through a CPD course outlining the dangers vulnerable road users face and the tools AGS members have, to enforce dangerous driving, overtaking and parking. 

Bike To Work Scheme and Bike Libraries 
While the Bike to Work Scheme was a success for its time it’s clear that the urgent need to decarbonise our transport system means we need to have a root and branch rethink of the current model. The current system, based on PAYE, is exclusionary and rewards the wealthiest with the biggest cost reduction. The system needs to have equitable access and social inclusion as its core guiding principle allowing children, retirees, those with limited mobility, carers, unwaged people and others to achieve bike ownership. 
 
We are calling for a decoupling of the Bike to Work scheme from PAYE tax and for a wider and more equitable roll-out allowing people from all walks of life to have affordable and easy bike ownership. 

Additionally, we ask that funding is made available through the Department of Education and Skills to all primary and secondary schools to facilitate the establishment of Bike Libraries. These comprise a fleet of cargo, electric or folding bikes that are operated by schools and parents’ associations where parents and teachers can borrow them over the school term to trial what bike would allow them to make the switch from the car⁴. To date the Dept of Education and Skills has been a laggard in terms of climate action with many of their current policies around school building projects incentivising car use and suppressing modal shift to active modes. We would request that funding be made available to all schools at both primary and secondary level to enable projects like this to take place.  

Business Focused Cargo Bike Schemes 
Irish Cycling Campaign requests that the Dept of Communications, Climate Action & Environment engages with Chambers Ireland to develop a series of pilot programmes across the country to roll out cargo and e-bikes for last mile urban city and town centre delivery.  

VAT and VRT changes 
Cyclist.ie calls for the review of taxation and fiscal policy to help further modal shift by:  

• Reviewing the VRT levels for all sizes, weights and types of vehicles, to promote the use of greener and smaller vehicle models. Sports Utility Vehicles (SUVs) should be specifically targeted for increased VRT. This reflects the increase in road danger created for people walking and cycling from the driving of larger, heavier vehicles, which now command 50% of the private car market.    

● Zero rate VAT on bicycles, accessories and repairs – to promote the circular economy, create jobs in the green economy, and make cycling more affordable for people of all incomes.  

Safe Routes to School 
Unnecessary school trips by car are a key journey type that need to be reduced significantly if we are to address our transport emissions. The Safe Routes to School programme and its associated schemes have been an excellent method to make active modes a safer and more accessible choice for parents and students. With the recent rise in deaths of children cycling and walking it is even more pressing that the immediate vicinity and the grounds of their schools are free from unnecessary car traffic. We would ask for a significant increase in funding and staffing levels to allow these programmes to move forward with the goal of the removal of car traffic from the internal roads and front of school streets of all urban and suburban schools by September 2026. 

Bike Parking and Bike Scheme Investment 
We know from data that private cars are used for nearly 30% of journeys as short as 2km or less. This is a startling statistic that needs to be tackled. We need to enable and encourage travel by bike and on foot for shorter journeys, by funding the required infrastructure to an even greater degree than at present.  

We also need to enable multi-modal bike trips by funding both bike share schemes  and adequate and safe bike parking at bus and train stations and bike parking at bus stops in both urban and rural areas. In urban areas more cycling trips are an obvious answer to traffic congestion and in rural areas the welcome expansion of Local Link services can be further leveraged by the provision of bike parking at bus stops.    

Education & Training
As we move to more active modes of transport, we need to ensure that all our children have the skills to cycle with confidence around urban and rural settings. It’s vital that we develop cycling as an integral part of the school physical education curriculum. This approach is taken in countries such as the Netherlands, where we see the majority of school children cycling to school.  

The Cycle Right training has been a moderate success in empowering and enabling children to cycle safely, but we need to see greater investment to ensure every child leaves primary school with an adequate level of cycle training with proper upskilling provided to allow teachers to be the primary cycling educators in schools.. 
 

This important life skill will not only build the child’s sense of confidence and independence while maintaining a healthy active lifestyle, but will develop their empathy and awareness of other road users if they go on to become drivers. 

#4 – Conclusion / Summary 

Unlocking the multiple benefits that cycling offers the economy, society and the environment requires continued targeted and sustained investment. Government and Local Authorities must continue to be steadfast in ensuring that these value for money and wide social benefits are availed of.  

We look forward to having the above recommendations considered favourably by the Department.  

Yours  

Neasa Bheilbigh 
Chairperson  
Irish Cycling Campaign
www.irishcyclingcampaign.ie
[email protected]  

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 Cyclist.ie, 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
www.irishcyclingcampaign.ie