To: Mr Keegan, Chief Executive, Dublin City Council

Thank you for meeting us recently to discuss issues related to the development of cycling and pedestrian networks in Dublin City. We are taking this opportunity, having studied the Dublin City Centre Transport Study, of commenting on the proposals. We welcome the overall thrust of the proposals in the Study. We have laid our submission out in such a way that all bulleted points below are issues which we feel are not fully addressed in the Study and need to be.

General

Overall Dublin Cycling Campaign welcomes these proposals which are generally in line with the DRAFT Development Plan, should help to safeguard the future of the City, cater for the increasing commuter numbers, and develop the Public Realm. We do however note that,

• While a specific sum of €150million is suggested as being ‘protected’ for the various projects proposed – other than LUAS – over the next 8 years, there is no breakdown of approximate costings for individual proposals, or even approximate timelines for the different projects. There are a number of substantial projects proposed within the overall bundle and we would welcome clarification that this suggested sum is adequate to cover these projects.

As with the overall GDA Transport Strategy we fully agree with the prioritisation of modes, while understanding the needs of certain sections of the population to be able to access critical services. We fully endorse the Principles guiding the transport proposals as set out in Section 4.2 of the Study.

Traffic Network

Through Traffic – We fully agree with the proposal to remove through traffic from the city centre. Besides the major visual effect this traffic has on various streets, it also has a major effect on pedestrian and cycle mobility and health, and the effectiveness of Public Transport.

• But, we note that there does not seem to be any particular emphasis on identifying private and public sector car parking destinations, which are major causes of the present private car traffic levels. A reduction in the available car spaces could potentially be achieved by a variety of standard methods. Dublin City Council itself might take the lead on this by reducing their own level of car parking availability and encouraging greater use of sustainable transport by its own staff! Methods of taxation of car park spaces could also be explored.

Reallocate Road Space – We commend the proposals to reallocate road space and convert a number of streets/areas to Public Transport/Cycling/Pedestrian only. But,

• We would like to see some of these design ideas extended to the North City Centre area, particularly along the full length of O Connell Street, and parts of Abbey Street.

Car Parking – Controlling the access and egress to car parks is critical for smooth traffic movement, and we commend the possibility of possible relocation of some car parks, but

• Further work needs to be done to develop Park & Ride sites away from the City Centre, which would encourage mode transfer, and reduce the impact on the City Centre itself.
• The possible use of car parks as taxi ranks, as suggested in the Study, should be given some priority given the difficulty, particularly at night, with illegal parking and dangerous practices by taxi operators.

Freight Movement – The management of delivery systems in the city centre is absolutely necessary, in order to provide safer streets and less conflict between road users. This particular problem has been highlighted recently by Dublin Cycling Campaign’s #Freethecyclelanes project. While we commend the suggestions outlined in Section 5.3.6 of the Study we are disappointed that there is no specific reference to the possibility of diverting a major percentage of city centre freight deliveries to bicycles. The benefits and possibilities of such a policy are well documented: European Examples

The European Cyclists’ Federation Cycle Logistics project has further data on this.

Public Transport

Dublin Cycling Campaign has already voiced its support of the BRT concept and its potential to also improve cycle facilities and inter modal travel. We are delighted to see the proposal to remove bus termini from the city centre. This leads to clogging up of transport arteries. We suggest that

• All Dublin Tourist Coach termini on O Connell Street should also be included in this proposal and alternative locations sought.

We welcome the promise to introduce simpler fare structures for public transport as this will undoubtedly lead to an increase in usage.

The development of high quality areas of passenger interchange proposals is welcomed as this will also encourage greater usage.

The rail proposals including LUAS extension are welcomed but

• Interim provision for the efficient and safe use of road space during LUAS works needs to be critically improved, and well advertised.

Cycle Network

Section 8.1 of the Study outlines the 8 cycle schemes that are at present ‘either in design or moving to construction’. As only one of these schemes is at present ‘moving to construction’, Dublin Cycling Campaign would be very happy to see the ‘acceleration of funding’ referred to, as it is a ‘key element of this study’!

The imminent appointment of a Cycling Officer for Dublin City should help to accelerate some of these projects and promote greater bike usage. Promotion will remain key to the development of Dublin’s bike culture. In the meantime many parts of the City Centre remain hostile to bike users and in the interim we propose that

• This Study should prioritise the identification of unsafe areas for bike usage and develop temporary proposals to improve the situation, before the completion of the various major projects.
• This Study should promote the improved identification and enforcement of the 30kph city centre zone to increase safety for cyclists and pedestrians.
• We would like to see a movement to 24 hour cycle lane facilities to encourage all time usage of bikes, and not just an emphasis on commuter cycling. This would also help to reduce night time and weekend ‘conflict’ situations for bike users.
• The Study needs to ‘signpost’ the necessity for proper direction and guidance signage for Cycle Routes, and a long term identification process.
• The Study needs to highlight the difference that getting more people to walk and cycle can make to the overall health of the City. These new proposals need to be included within the Healthy City Dublin agenda. Everyday mobility is critical to population health!

We welcome the commitment to the enhancement of safety for cyclists, the development of contra flow routes, and the cycle friendly land use cells. We also note the proposal to develop high density cycle parks. A Cycle Parking report is about to issue from Dublin City Council, which will move things in the right direction but

• Contra Flow routes should be prioritised on all one way street systems, in line with best European practice.
• Present cycle parking proposals are nowhere near meeting the expected demand, and further options need to be developed, and guidance for cycle parking design criteria for developments needs to be implemented.
• We note some changes in the ‘Priority Cycle Routes’ (Figure 8-2) from the very recently published GDA Cycle Network, and some particular omissions. We are unclear why these are proposed?

Pedestrian Network

We applaud the proposals to develop a series of strategic pedestrian routes and public spaces, but

• We suggest that the ‘proposed pedestrian routes’ outlined in Figure 9-1 should be revisited, and clarified in relation to their logic within the overall cityscape.

We are fully in favour of reprioritisation of space at junctions and along streets in favour of pedestrians.

Specific Measures

We applaud the measures proposed for the development of specific public locations in favour of pedestrians, bikes and public transport, but

• We seek clarity on the proposed ‘pedestrian area’ at Stephens Green North, which indicates in the graphic that cycling would be permitted, but under present regulations for pedestrian zones this could not happen. This area is also part of a designated cycling ‘feeder route’ in the GDA Cycle Network
• The wider issue of the movement of bikes through pedestrian zones also needs to be addressed.
• We suggest that, together with the development of the LUAS Green Line, there is great scope to introduce a specific measure for a complete redesign of the existing Parnell St area from Gardiner St through to Capel St/Bolton St. This is a particularly busy pedestrian area, with high cycling usage, and includes the wonderful Parnell Square.
• The strict definition of ‘local access’ needs to be spelt out to ensure the integrity of the proposed plans.

We look forward to development of Masterplans for Connolly/Amiens St/Busáras and Heuston interchanges. Both of these areas present clear opportunities for enhancement of the public realm and improvement of mobility options for pedestrians and cyclists, but

• We wonder what is the timetable for development of the Masterplans? This should be spelt out.

We note and applaud the pedestrian bridge proposals as shown in Figure 10-8 but we question the need for 2 pedestrian bridges in this Eastern Docklands area while

• Advancing the proposed cycle/pedestrian bridge over Liffey at Winetavern St, as proposed under the GDA Cycle Network, seems to be ignored, and would be of more immediate benefit!?

We are fully in favour of rationalising coach parking, which at present causes major disruption to road users at a number of locations. We also support the review of taxi rank locations with a view to improving overall road safety. We look forward to the enhancement of the general streetscape and public realm as part of these plans.

Conclusion

Overall we are very supportive of this latest vision for Dublin City Centre, and we suggest it is based on good science, and on the results and evidence provided by many other international cities. We would ask that the separate bullet points and queries listed above in relation to the Study, be addressed, and we look forward to your responses. We would be happy to meet with yourself and/or your officials, at any time, to elaborate on any of the above points.