Donegal County Council recently ran a ‘public consultation’ on active travel plans for a series of streets in Letterkenny, its main commercial centre. Letterkenny has a population of over 22,000, but like many Irish towns it is very car-centric, with little space or thought given to walking and cycling around the town. This proposed multi-route project in the town is Project 18 of 26 demonstration projects as part of the government funded Pathfinder Programme. It is meant to be a stimulus for other similar sized towns to learn from. The Irish Cycling Campaign is highly critical of the Council, its plans, and the consultation process employed.
The Irish Cycling Campaign made two separate submissions on the posted consultation, one from our Infrastructure Coordinator, and the other from local member Eddie Bradley. As you will note from the submissions, we are highly critical of the approach of Donegal County Council to this nominally important Pathfinder project, both in terms of the ridiculously short two week consultation time frame, and the poor quality of the presentations. There also appears to have been little direct contact with local organisations, businesses and householders affected by the proposals, as evidenced by the lack of awareness of the consultation throughout Letterkenny, and no overall background material or context supplied as part of the consultation.
Letterkenny Town Proposed Active Travel Routes
The general public were left in the dark about the actual detail of any of the schemes shown, or how they might work as a unit, to improve active travel in the town. We in the Irish Cycling Campaign are highly sceptical about the ambition of Donegal County Council to progress these projects to a meaningful state of completion, which will be absolutely critical to increase greatly walking and cycling in the town. It is sad to see this regrettable approach from the County Council, which will lead to either the stymieing of these proposals, or at the very least delaying the implementation of a decent quality active travel network.
We have urged Donegal County Council to revisit the consultation process, the material posted and the design detail supplied! We await their response!
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.
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
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:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
In this article, Irish Cycling Campaign’s Infrastructure Coordinator, Colm Ryder, considers if ICC’s planning submissions are making a difference – and, if yes, in what way?
The Irish Cycling Campaign (formerly Cyclist.ie) has been making submissions to Planning Authorities and Government Bodies, on public consultations, for at least the past 15 years. This work is part of our broader efforts to improve conditions for active travel by engaging constructively through the planning system.
We ask here: do these submissions help to make a difference in how designers and planners view active travel provision? Our view is that they can certainly help to make alterations to proposed projects, as we also know from discussions and feedback with different local Councils, and from the issued “Part 8” Final Reports (i.e. Part 8 of the of Planning and Development Regulations 2001 (as amended)). But also we know that certain Local Authorities do sometimes ignore our comments, particularly if they are critical of the relevant Local Authority and its policies.
So, we continue to make submissions on schemes and policies right across the country – when, that is, we actually get to know if consultations are happening! Unfortunately this has not always been the case, as public consultations are difficult to track, and up to now there has been no standard website or tracker mechanism, which keeps on top of consultations published. There are also the cases where Local Authorities post consultations online, but do not encourage submissions (e.g. by not providing an email address to facilitate this), with the result that some schemes can have very few, or even zero, submissions. This is an unhealthy indication of the democracy of our planning system.
But, recently, the Local Government Management Agency has been trialling a national planning system, where many Local Authorities post their consultations and general planning information. The consultations at present are confined to Part 8 consultations, but we would hope that all public consultation processes, including Section 38 processes, will soon come under the umbrella of this overarching website. This will make it easier for Joe/Mary Citizen to access and find out what is happening both nationwide and in their own area. In the case of the Irish Cycling Campaign, we are of course interested in any proposed active travel schemes countrywide, and not just where our local groups are active!
In the first six months of 2024 alone, we have centrally made over 40 submissions to 18 Local Authorities and to four government agencies/departments. This does not include the many submissions made locally, directly from our network of local groups, on local schemes of interest. The vast majority of the schemes we have submitted on are specific proposed active travel improvement schemes in our towns and cities. But an increasing number of rural Local Authorities are working to develop greenways, to encourage mainly local leisure use, but also to attract tourism. Some of these proposed greenways will in the long term link into the developing National Cycle Network (NCN).
We, in the Irish Cycling Campaign will continue to advocate for cyclists and pedestrians, in order to make our streets safer and more liveable. It is important that we continue to make our voice heard through multiple channels, including through these formal planning consultation processes. Through these channels we can help to ensure that planning bodies and local authorities develop acceptable policies, and implement high quality active travel schemes in line with the the Cycle Design Manual, Design Manual for Urban Roads and Streets, and Rural Cycleway Design documents.
If you have any interest in supporting this work, or in making your own planning consultation submissions, why not contact us at [email protected]?
You can also support our vital work by making a donation, which will help to cover the administrative expenses of making submissions. Visit cyclist.ie/donate to contribute today.
Note – the featured image above was taken in June 2024 at Utrecht’s multi-story cycle parking facility by Irish Cycling Campaign’s reps en route to the Velo-city conference in Ghent.
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.
2General 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.
Earlier today (Fri 07 June 2024), Irish Cycling Campaign made a submission in response to the public consultation on the new Primary Wellbeing Curriculum. We have posted a copy of it below.
We note here that the consultation is open until 5pm on June 18th. This new curriculum will encompass both Physical Education and Social, Personal and Health Education and is the first revision of the curriculum since 1999. This curriculum will most likely be in effect for the next few decades in our primary school system, so it’s essential that we have a stronger focus on cycling within it. Do please take 10 mins over the coming days to send in your own request that utility cycling and cycling as transport be given a prominent role within the final draft.
Written submissions can be sent to [email protected] from now until 5pm on June 18th. More on the background to the consultation can be read via this link.
And we wish to sincerely thank our Irish Cycling Campaign volunteers for their excellent work on the submission that you can read just below.
Dear Sir / Madam, Irish Cycling Campaign (formerly Cyclist.ie, the Irish Cycling Advocacy Network), is the national organisation of 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 friendly culture, where everyone has a real choice to cycle and is encouraged to experience the joy, convenience, health and environmental benefits of cycling.
We are very thankful for the opportunity to submit our observations of the new draft Wellbeing Curriculum Specification and fully support its vision to holistically empower children with skills across subjects such as Social, Personal and Health Education (SPHE) and Physical Education (PE) to live healthier, more connected and happier lives.
Our submission has been drafted by a number of primary teachers supported by experts in paediatric health with direct experience of delivering support to children of all mobilities.
Introduction:
The Irish Cycling Campaign believes that cycling should be an integral component of the physical education curriculum, aimed at fostering holistic development and promoting well-being among primary school students. The inclusion of cycling aligns with the overarching aims of the curriculum, as outlined below:
1. Physical Well-being: Cycling encourages regular physical activity, contributing to the development of cardiovascular fitness, muscle strength, and overall physical health. Through cycling, students enhance their motor skills, coordination, and balance, laying the foundation for a healthy and active lifestyle.
2. Social Well-being: Cycling offers opportunities for social interaction and collaboration, promoting teamwork, communication, and peer support. Group cycling activities foster a sense of community and belonging, while also cultivating empathy and respect for others.
3. Emotional Well-being: Engaging in cycling activities can have positive effects on mental health and emotional well-being. Riding a bike provides a sense of freedom, independence, and achievement, boosting self-esteem and confidence. Moreover, outdoor cycling experiences promote connection with nature and community, reducing stress and promoting relaxation.
4. Cognitive Well-being: Cycling stimulates cognitive development through problem-solving, decision-making, and spatial awareness. Navigating different terrains and traffic conditions requires critical thinking and concentration, enhancing students’ cognitive skills and resilience.
5. Climate Responsibilities: Children cycling not only benefit from the activity themselves but also contribute positively to mitigating climate change. By adopting cycling as a mode of transport, students reduce their carbon footprint, thereby fostering a sense of environmental stewardship from a young age. Emphasising the climate responsibilities associated with cycling empowers students to recognize their role in addressing global environmental challenges and encourages them to make sustainable choices in their daily lives.
Incorporating cycling into the primary school curriculum reflects a commitment to holistic education, encompassing physical, social, emotional, cognitive, and environmental dimensions of well-being. By providing students with opportunities to cycle safely and confidently, the curriculum aims to empower them to lead healthy, active, and sustainable lives while fostering a sense of responsibility towards the planet.
A further point to note here is that Irish transport policy, investment plans and the mobility culture are all having to change quickly now in response to the need to rapidly decarbonise the transport sector. Therefore it important to equip school children with the skills to be able to use the transport infrastructure networks of the future – i.e. those ‘active travel’ routes which are being developed extensively countrywide as part of the National Cycle Network Plan, CycleConnects plans, BusConnects bus and cycle network plans and the metropolitan cycle network plans such as the Greater Dublin Area Cycle Network Plan. Training in being a competent bicycle user at a young age will help pupils to confidently navigate the multi-modal transport systems which will become increasingly common in Ireland (and indeed abroad) over the coming years. Becoming a competent cyclist is a skill for life in a rapidly changing world.
Requested Amendment:
The Irish Cycling Campaign is recommending the following changes to the Table 9: Description of Physical Education activity areas contained within Section 6D: PE Activity Areas on pages 43 and 44 of the Draft Primary Wellbeing Specification to strengthen the place of cycling as both an enjoyable activity and a key travel mode for children in our primary school system.
From the section labelled “Adventure” we recommend the removal of “Wheel based activities are also an important element of adventure activities incorporating a focus on the lifelong activity of cycling, alongside other wheel-based activities such as scooter and scooter board.”
With this deletion we would recommend the inclusion of a new separate section titled “Cycling, Wheeling and Walking” to replace this reference to cycling.
Within this “Cycling, Wheeling and Walking” section we would suggest the following as the body of text to better support cycling within the curriculum:
Cycling empowers independence and connection in children allowing them the freedom and safety to travel to and from school in a method that both enables activity and climate responsibility. Direct teaching of cycling skills will enable them to travel in a safe and enjoyable fashion while learning to be considerate road users.
Social cycling to school instils within children a habit of regular, daily activity within their lives. It creates a connection to their peers and their wider community further fostering active citizenship and acts as a base for a healthy and active lifestyle.
Cycling, walking and wheeling also provide opportunities for children to be active outside directly taught PE classes and organised sports. Taken together these movement types instil a lifelong love of movement that includes children of all abilities.
Additional Observations:
Teacher Training and Upskilling
Existing cycle training programs in schools tend to be outsourced to external cycle training providers. This poses challenges for many schools as they may not be in a position to provide funding for these training providers or book training providers due to timetabling issues or geographical location.
We recommend that the Wellbeing curriculum encourages and expects class teachers to directly engage with teaching and learning related to cycling. We appreciate that there will be training needs in this area but feel that this may be achieved through the provision of Continuous Professional Development and EPV training courses and events.
These training courses should intend to enable class teachers to ensure that the children in their class are able to:
Develop the foundational skills in order to cycle safely between two points.
Carry out basic checks and tasks on a bike (move saddle height, check brakes, pump tyres).
Understand the rules of the road.
Develop an interest and curiosity in cycling.
(b) Health benefits
HSE guidelines on physical activity in children say that children over 5 should have at least 1 hour of energetic play a day – ‘where they sweat and breath faster than normal’. Staying fit is imperative for a child’s growth and development to have a healthy body, develop self confidence and improve learning and attention (HSE, 2022). We argue this activity could be done on route to and from school where possible.
Additionally, being overly car-dependent poses both direct and indirect risks to children. An Irish child’s outdoor environment is made physically more dangerous with increasing number and size of vehicles and their associated pollution. The indirect effects to health in taking sedentary transport to school is the opportunity cost of not walking, cycling or scooting to school. In effect, this is about more than teaching a child to cycle a bike; rather, it is about using it it as a transport tool and supporting this positive transition can improve baseline paediatric health and create lifelong healthy habits. According to the Department of Children in 2018, approximately 50% of children aged 10–17 reported being physically active for at least 60 minutes per day on more than four days per week, early intervention at primary school level can help develop these healthy habits.
Walking or cycling to where you are going will be good for a child and allow them to engineer physical activity into their daily lives by transport. An easy win. According to the Road Safety Authority figures show that 2 of 3 child casualties on our roads were child pedestrians or cyclists. Between 2014 and 2022 there were 56 fatalities aged 0-15 years and 852 seriously injured road users, representing 4% of total fatalities and 8% of total serious injuries. Although we believe the responsibility of reducing road danger lies with the adult driving the car, road safety awareness starts by being a pedestrian or cyclist. Cycling is a core life skill, a building block to road safety to improve awareness, it should be part of the syllabus at primary level.
Cycling is inclusive, children with different physical and mental needs are capable of cycling a bike. This may not be the same for children during other activities.
(c) SEN Children: Focus on Cycling and Autism
Children with autism are very often some of the most creative and detail oriented children within the classroom. They are keen observers and are incredibly resilient, accepting and honest. In addition to the huge positives children with autism bring to school and family life, they also have a number of common challenges which may include:
• Difficulty with social interaction.
• Delayed or limited communication skills.
• Sensory processing difficulties.
• Restrictive patterns of behaviour or interests.
• Delays and difficulties with motor skills development.
• Stereotypical behaviours.
• Concentration difficulties.
Some of the motor skills problems that children with Autism experience include difficulties with balance, postural stability, joint flexibility and movement speed. The secondary consequence of motor skills difficulties include avoidance of group activities including team sports and therefore decreased opportunity for physical activity and social interaction. We would firmly maintain that our cities and schools must provide support and facilities to allow all children to avail of the right amount of physical activity for optimum health and wellbeing.
Exercise of all kinds increases opportunities for social interaction and improves social motivation and communication for all children but especially for children with autism. It promotes calmness and relaxation while also having clear improvements in physical health. Physical stimulation obtained through body rocking, arm flapping and spinning can decrease with regular daily exercise. As with all school children, physical exertion helps children with autism to complete classroom tasks with increased accuracy.
Motor Skills and FUNdamental Movement Skills
If we examine motor skills and fundamental movement skills we can very clearly focus on the benefits cycling in particular can bring to children with autism. With many of these children experiencing roadblocks in developing different aspects of their motor skills, the development of physical literacy is a key part of their schooling and life skills development. They may need more time and support to learn to cycle but once accomplished their sense of achievement is powerful. The therapeutic and emotional benefits gained are very worthwhile.
The Move Well, Move Often programme (PDST, 2017) has been rolled out in schools in recent years and has a far more skills and assessment focused take on physical literacy than previous physical education programmes. It has been adapted for use by many Special Education Needs (SEN) teachers in Irish primary schools over the past number of years for both individual and group teaching of fundamental movement skills. When looking at these skills it’s important to understand that while they may be given specific instruction during motor skills teaching with children with autism, all of these physical literacy skills are complementary and interconnected. While locomotion and manipulative skills may be easier to teach within a standard school PE hall setting, the stability skills benefit hugely from extra interventions such as cycling.
For many children with autism regulation of sensory inputs can be a particular challenge. They may be overloaded by noisy, busy environments. Proprioceptive (body awareness) and vestibular (balance) sensory senses can often be challenging areas too. This can lead to a more limited ability to explore their environment and, in turn, less opportunity to develop their sensory systems, resilience and relationships with peers. Children with motor difficulties require activities that challenge these systems to help them to improve and develop. They need activities that challenge balance, coordination and motor planning such as cycling to help address these sensory issues. Activities such as these have a hugely calming influence on the sensory systems of children with autism.
Social Skills Development
Social skills, difficulties with social interactions and making meaningful and lasting connections with peers is a key focus of a lot of school aged interventions. A huge aspect of the teaching of primary school aged children focuses on building and developing these skills. Children with autism have both discrete social skills teaching and social group teaching as part of their school-based interventions. Cycling to school with peers in a group or a cycle bus (a group of children cycling together in convoy to and from school under parental supervision) helps develop a sense of belonging and community with their peers that sits perfectly alongside this. The shared communal routines provide incredible benefits to their levels of social interaction, communication skills and most importantly their self-confidence.
The importance of cycling to both children’s feelings of belonging and inclusion within a group and their mental health cannot be overstated. This is especially important as children reach adolescence where interests and behaviours develop. A shared way of moving together such as cycling gives children a sense of belonging and a common interest. It also ensures that the exercise they need to help self-regulate is an enjoyable and communal experience. Having the outlet for their feelings is an especially important part of guiding children with autism through this particular phase of their lives and having a solid peer group such as a cycling group strengthens this resilience.
We know that physical activity rates decrease from childhood to adolescence. Older individuals with autism spectrum disorder (ASD) living in community settings have been observed to live very sedentary lifestyles. If children with ASD do not develop participation skills in active leisure time activities, they will most likely become increasingly sedentary with age placing them at risk of diabetes, heart disease and certain cancers. We must therefore strive to encourage physical activity for these children in our schools and communities.
Support children with autism to learn to cycle and provide the infrastructure to keep them cycling, and they will gain lifelong benefits for their physical and emotional wellbeing. Of equal importance, they will have increased opportunities for meaningful daily social interactions.
Conclusion:
We wish to thank the NCCA and its staff for what is an excellent draft specification for the new Primary Wellbeing Curriculum. We hope that you find our observations helpful and that you will consider them for inclusion in the final draft of the curriculum. If we can be of any further help please do not hesitate to contact us at any stage.
Regards,
Neasa Ní Bheilbigh – Chairperson of the Irish Cycling Campaign, (Primary Teacher – Galway)
Dave Tobin – Vice-Chair of the Irish Cycling Campaign (Primary SET – Limerick)
We made an in-depth submission on the Climate Action Plan 2024 today, calling for continued investment in active travel, quicker roll-out of urgently needed protected, connected cycle tracks.
We pointed out that it’s not only our cities that matter; our towns should be focusses of active travel too. Local Authorities each now have to make an Action Plan, and we urged the Department to keep an eye on their quality – our Navan colleagues have found serious flaws in the Meath County Council version.
And we reminded the Department of the Environment, Climate and Communications that joined-up thinking is crucial when building new rail stations, bus stops and transport hubs. More cycle parking! And less car-focussed development and giant SUVs!
Here’s the text of our full submission:
Introduction
The Irish Cycling Campaign (formerly 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. We are the Irish member of the European Cyclists’ Federation. Our vision is for an Ireland with a cycle friendly culture, where everyone has a real choice to cycle and is encouraged to experience the joy, convenience, health and environmental benefits of cycling.
We are delighted to submit our observations on this vital and necessary plan. Our comments relate generally to specific Chapters 9 (Citizen Engagement) and 15 (Transport) within the Climate Action Plan 2024.
We set out general comments initially, then our responses regarding Chapters 9 and 15 to the questions posed in the Public Consultation Summary Document (red text), finally including some brief comments on Chapters 11 and 19 regarding local authorities.
2 General Comments
The Irish Cycling Campaign welcomes the updating of the Transport Appraisal Framework (TAF) to take account of Climate Change.
We welcome the statement that interventions under the Sustainable Mobility Policy include supporting a shift to active travel and public transport, including the reallocation of road space;
We welcome the proposed publication of a Demand Management Strategy
We welcome the proposal to amend legislation to extend the remit of the NTA to the 5 cities but think this does not go far enough, Page 268 of the CAP states “This will bring a coherent approach consistent with the Climate Action Plan objectives for transport” But why aim for consistency just in the 5 cities. Should not residents of Letterkenny, Tralee, Wexford, Drogheda, Navan, Sligo, Castlebar or Portlaoise etc be treated in the same way as residents in the cities?
We are disappointed that the Citizen Engagement chapter omits mention of Environmental NGOs and of PPNs as Stakeholder groups who should be an integral part of the consultation process given their expertise and outreach into communities. PPNs are mentioned in the context of Climate Conversation workshops only and NGOs in the context of global outreach. Both groups need to be at the table.
3 Specific Comments on the Shift Sector of Chapter 15
Ref 15.2.4.1 Active Travel Infrastructure and Accessibility Work Programme
Cycle Connects and The National Cycling Network are both welcome initiatives and we recognise this vast work programme will take many years and considerable resources to implement. However, these initiatives unfortunately still leave many communities unserved by cycle infrastructure including safe routes to school. SRTS is also mentioned as a priority in this section and we strongly urge the Departments of Transport, Climate Action, and Housing to consider ways in which measures can be taken to enable all communities to avail of safe walking and cycling infrastructure including safe routes to school. Dedicated walking or cycling infrastructure should be prioritised, where possible, including cycle lanes adjoining roads, cycle paths alongside waterways and re-allocation of road space to cycling and active travel. Where this is not possible, measures such as traffic calming, reducing speed limits, and developing the Rothar Road concept should be employed.
We welcome the recognition that the growing number of electric bicycles (E Bikes) means positive changes to the potential for modal shift become viable, but safe routes are the other essential requirement for this to happen.
BusConnects
We welcome the CAP’s support for the BusConnects scheme, particularly the 50% increase in services proposed in Cork. The BusConnects corridors, if constructed as planned, will provide a step-change in the quality and extent of cycle infrastructure, while improving walking facilities significantly (e.g. crossings across all arms of a crossroads, rather than 2 or 3 out of 4). A protected, connected cycle network – as planned by BusConnects for inner Dublin, for instance – has the potential to encourage a rapid and significant growth in cycle traffic: a step-change which could potentially become a tipping point in transforming Ireland’s transport culture.
Rapid social acceptance of cycling as a normal, daily travel mode is possible, in the same manner as attitudes to plastic bag use and workplace smoking changed rapidly, given rapid roll-out of infrastructure and good leadership. The communications and storytelling approach outlined in the CCCC and Chapter 9 will assist this cultural change. Ongoing social and behavioural research is crucial.
Opposition to BusConnects, often rooted in misinformation and micro-local concerns and sometimes touted by elected representatives, must be addressed and confronted by the NTA and local authorities, now that several of the required planning permissions have been granted and construction is imminent. The strengthened social contract dealt with in Chapter 9 is critical. Loss of street-side parking privileges, for example,, balanced against the common good of on-time bus services, must be put into accurate perspective.
However our reviews of BusConnects corridor plans, in the process of making many submissions during the various consultation phases, show that BusConnects infrastructure plans require improvements:
Cycle tracks often too narrow;
Junction designs (conflicts between motor vehicles and people on bicycles are made more likely than necessary by the designs/ traffic light phasing);
Compromise of designs for public and active travel at many locations, in order to maintain car traffic flows;
Failure to account for the real potential health benefits of modal shift, e.g. by using World Health Organisations’ HEAT methodology.
These issues must be addressed in detailed design. Thus, we would submit that the CAP should specifically endorse the standards set out in the National Cycle Design Manual, over and above the mention on p. 272.
Additionally, CAP should recommend revision of Transport Appraisal Frameworks e.g. National Investment Framework for Transport Infrastructure, to include HEAT or equal methodology: Human health impacts of transport are not only from vibration/ pollution/ access to services (as appraised in current practice) but also – and far more significantly – from access to or preclusion from active travel. Active travel facilitated by good cycle tracks, quality walking environments and linkages with public transport, can engender daily, habitual physical activity. Significant mental and physical benefits are known to result. Conversely projects that facilitate or enable motor dependence often worsen the environment for walking and cycling, thus denying opportunities for exercise. CAP is in a position to leverage health benefits for GHG abatement by addressing how projects are appraised and prioritised.
Ref 15.2.4.2: Major Public Transport Infrastructure Programme:
” Public transport projects will ensure quality active travel access and cycle parking for passengers”.
We suggest that this measure should not just apply to major new projects but to smaller projects such as bus shelters and include retrofitting of existing infrastructure. Connecting Ireland does not appear to be incorporating cycle parking in its enhanced services.
Rail
Facilities for combining bicycle/wheelchair/pram users and train travel should be improved through lifts at train stations which are long enough for non-standard bicycles and mobility aids, or providing other means for these vehicles to easily change platforms. Latency in lift capacity, i.e. additional provision to cater for breakdowns, should be built into station design.
Cycle parking at stations must be in compliance with development plan requirements and best practice. Neither Dublin MetroLink nor Dart + West projects, for example, have been designed with adequate cycle parking spaces, compared to local authority standards. Inadequate cargo bike/ disability trike/ non-standard cycle provision is shown on plans.
When procuring train carriages and buses, design of the train carriage or bus should include space which can be used by bicycles/wheelchairs/prams or seated passengers through fold-up/down seats, and straps for securing the bicycle when the seats are folded up. Embarking or disembarking with a bicycle/ wheelchair/ pram should be facilitated by ensuring there is not a large step up/down to embark/disembark.
If bicycles are allowed on particular train carriages within a train but not other carriages, this should be very clearly marked on the side of the relevant carriages so cyclists can easily find the carriage to enter.
Bus and bike
For buses, a rack on the back of the bus, or space in the hold of the bus, can be alternatives.
Secure parking facilities for bicycles, and availability of public shared bicycle schemes at train stations and bus stops, should be prioritised. A mix of parking provision is necessary, in some cases a simple Sheffield stand may suffice, in others more secure supervised indoor parking or secure bicycle cages/lockers may be necessary
Consistency of access for all wheeled modes to all public transport should be built into the Plan.
For overseas travel via ferry, cyclists should be offered the same choice of ferry routes and timetable as motorists are offered, and the same or lower prices based on the lower weight involved.
Omission from Shift Proposals: Transport and Sustainable Tourism
The preceding comments on integrating cycling with public transport were focussed on the needs of people who cycle for transport but could equally be applied to Cycling Tourism. We are surprised that the only reference to the promotion of Sustainable Tourism in the main CAP24 doc or in the Annex of Actions occurs in the chapter on a Just Transition for the Midlands. A major focus on the Midlands is entirely justified given the job losses arising from the cessation of exploitation of the bogs for production of electricity and fuel. Actions such as regenerative tourism, the development of walking and cycling trails and the decarbonisation of the bus fleet are laudable and welcome.
However, we would like to propose that the Departments of Climate and Transport engage with the Department of Tourism and with Local Authorities and bring the same imaginative thinking on regenerative tourism to bear on sustainable transport projects countrywide. We have already seen a significant expansion in rural bus services and we have seen many walking and cycling trails developed under ORIS, Community Recognition and other funding streams. What we have not seen is some joined up thinking and effective marketing to encourage tourists to avail of these new services and to access local walking routes.
The Midlands undoubtedly attracts fewer tourists than the Wild Atlantic Way but much of the tourism to the WAW is car and coach intensive and causes congestion on narrow roads.
We think a section on regenerative tourism on a national footing would be a worthwhile addition to the CAP. The aim should be to highlight and promote routes and itineraries which integrate different modes of transport, walking, cycling, train, bus. Maximum use should be made of the expanding network of Greenways.
For illustrative purposes we will look at an example from County Clare. At the moment it is difficult for someone based in Ennis to plan a day out in North Clare to visit some of the sights and get reliable information on bus stop locations and timetables as well as walking routes and cycling options. For example it is possible to take the bus from Ennis to the start of a walking trail, complete a walk on that trail in one direction and link up with a bus back at the end of this trail but information on the bus services is not integrated, eg 350 bus from Ennis to Fanore, walk to Ballyvaughan,local link bus from Ballyvaughan to Ennistymon and 350 from Ennistymon back to Ennis.
The TFI Live app could be an amazing resource if it was populated with all the Local Link information and if it was marketed effectively. All popular visitor destinations whether Walks, OPW sites, Historic Houses and Castles, Farm Attractions should be requested to display options for access by Sustainable Transport where such is possible. Bus companies should make their timetables widely available.
4 Responses to Summary Document Questions
1. What do you think are the key challenges/risks to delivering the measures/actions set out in the Plan?
We agree with the statement in the Climate Plan (p247) which follows on the acknowledgement that transport emissions increased in 2021 and 2022 that “Decoupling the direct correlation between transport emissions and wider social and economic activity thus forms the fundamental challenge for the sector” Decoupling is extra challenging at a time when the population is increasing.
The shortage of student accommodation means that many 3rd Level students must commute long distances daily
Construction inflation is a major issue for delivery of transport projects.
If we are to meet our 2030 targets we need people to switch modes now, but many major public transport and active travel projects are still at the early planning stages
There is a sense in which some Local Authorities are citing National Policy re Sustainable Transport but not treating the necessary implementation plans with sufficient urgency. Local Authorities have now completed their own Climate Action Plans and submitted them to the DECC but there appears to be huge variance in the sustainable transport measures and targets (e.g. Meath, as noted above).
With respect to Active Travel, the original announcement in January 2021 about the setting up of Active Travel Teams stated “The new staff will be dedicated to delivering and promoting active travel in Ireland and will work across design, communication/community liaison and construction oversight functions.”However, outside of the cities, as far as the Irish Cycling Campaign can ascertain, Active Travel Teams comprise almost exclusively engineers with some technicians or administration personnel. This means that the teams do not have the expertise for the essential work of communicating with communities and “selling” sustainable schemes. It also means schemes may not be optimal in terms of enhancing liveability. Our experience is that Local Authorities are still falling back on online consultations as their main means of community engagement and this is unlikely to result in community buy-in.
2. Are there additional supporting actions that could be taken in 2024 to address or mitigate any identified challenges or risks to implementation?
Inflation proofing: It may not happen in 2024 but it is essential that the next PfG introduces a clause that funding for sustainable and active travel will be capped as a percentage of each year’s land transport budget and not as is currently the case as a % of the budget for the first year the current government takes office, as happened in 2020. €350 m annually represented exponential progress at the time but unfortunately it was insufficient to absorb shocks like the Pandemic and the War in Ukraine.
Active Travel Teams: We urge the Government to recognise that while engineers are essential for the delivery of AT schemes, engineer only teams lack some of the skills needed for successful roll-out and ‘selling’ of active travel projects. Areas outside the cities need multi-disciplinary teams just as much as their city counterparts. Clearly it would not be feasible to appoint large teams to each county but architects, planners, public liaison officers, could be shared between counties, possibly via the existing local Regional Design Offices. There are already many examples of local authority shared services and there are cooperation mechanisms in place via the Regional Assemblies.
Now that the Department should have received copies of their LACAPs from every Local Authority we suggest it would be a useful exercise to highlight examples of best practice of SMART measures and ask the more progressive authorities to share their thinking via CPD, podcasts, social media etc. It would be important to have a variety of exemplars that could be replicated by smaller, as well as larger, better resourced, areas.
Inclusion of the Irish Cycling Campaign in the relevant sections of the Annex of Actions and Citizen engagement as a key stakeholder in supporting the design and delivery of Active Travel infrastructure and a key facilitator of encouraging modal shift to cycling.
Irish Cycling Campaign should be included as a key stakeholder in the National Dialogue on Climate Action.and the National Climate Stakeholder Forum. According to Chapter 9, the Forum comprises Government, Departments, Local Authorities, Public Sector Bodies, national organisations, academics, representative bodies, voluntary organisations, and community groups but the Irish Cycling Campaign has not been invited in its own right.
Here is why the Irish Cycling Campaign should be added:
Electrification of the private car fleet is invested with doing a lot of the heavy lifting in meeting emissions targets but it is unlikely they will be met by 2030.
Major Public Transport projects, while welcome and necessary, will not be complete by 2030 either.
It is more important than ever that Active Travel is prioritised and the roll-out of infrastructure is accelerated. Funding of projects and of well resourced Active Travel Teams is essential but it would be foolish to discount the experience of people such as the advocate members of the Irish Cycling Campaign, who already engage with local and national officials, and in the everyday cycling to school, college, work, leisure activities that the Climate Plan and the Sustainable Mobility Policy wish to expand.
3. Do you have any specific suggestions on how the implementation of measures/actions in the Plan should take account of the four principles of Ireland’s Just Transition Policy Framework (as set out in Chapter 7 of Climate Action Plan 2024)?
The Just Transition section of the Transport Chapter already recognises the need to tweak the balance of avoid/ shift/ improve depending on the capacity of communities to absorb the proposed changes.
4. Are there any specific improvements that could be applied to the Plan in general, or to specific measures/actions or chapters in the Plan?
Annex of Actions (p67) SHIFT Public Transport Services and Escort to Education Journeys: TR/24/16/TG Connecting Ireland In our view this excellent initiative merits a further degree of joined up thinking. Connecting Ireland has already made phenomenal progress in providing bus services in rural areas. It is truly remarkable that communities who had only one daily bus service now have up to 9 services including early morning and late night services. In other areas hourly bus services have become half hourly again with early and late services. Increased services and reduced fares are game-changers. The plan is only at the half-way stage so progress in rolling out services will continue. However in our view two further changes should be implemented at the same time as services are being improved.
There needs to be a major acceleration in the programme for the provision of bus shelters in both rural and urban areas. From the emissions reduction point of view Connecting Ireland will only be successful if it brings about a modal shift. Current bus users will appreciate the lower fares and extra services but in terms of achieving the substantial reduction in kilometres driven mandated by the Climate Action Plan, people who currently choose to drive need to be persuaded to take the bus instead. For example, surveys undertaken by Sligo PPN and Sligo Comhairle na nÓg cite the lack of bus shelters as a major deterrent to choosing to travel by bus.
The second related issue is that the take-up of bus services is hugely dependent on their perceived reliability. Two issues related to reliability, i.e. a shortage of drivers and a shortage of buses are being addressed. However a third issue; the extension of the LA winter gritting programme to cover routes used by local link services requires DECC and DT to liaise with DEHLG, and of course will require a larger winter maintenance budget. The very nature of Local Link services means they use Local Roads for part of their routes and these roads are currently not included in the winter maintenance programme. Gritted roads means that on days when there is frost the service is often cancelled or curtailed, and this unreliable. This leaves people unable to get to work or to appointments and is the last thing that should be happening if the policy is to encourage a move from car-dependency to sustainable transport. Gritting of roads used by Local Link services could be regarded as a just transition measure.
Active Travel: TR/24/15(TF) SMP Pathfinder: Accelerate implementation of Safe Routes to School Programme: It is welcome that it is planned to identify additional phase 3 schools and bring them into the SRTS Programme but a more basic step also needs to be taken. The CAP makes reference to whole of government collaboration and in Chapter19 to the essential role of Local Authorities in achieving our emissions reduction targets. In this context it is almost incredible to read on https://irishcycle.com/ this morning about a brand-new school which the Department of Education and Mayo County Council has allowed to be built without provision being made for active travel access. https://irishcycle.com/2024/04/04/a-new-school-at-the-edge-of-town-is-opening-on-an-80km-h-road-with-no-footpath-or-crossing/. SRTS involves retrofitting walking and cycling infrastructure at existing schools. The idea that in 2024 one is permitted to build a new school and retrofit active travel at some later date is unacceptable.
Smart, Shared and Integrated Mobility: TR/24/17(TF)Development and publication of Policy Statement on Mobility Hubs
15.2.4.4 (p277) of the Plan is about mobility hubs. It states, ” it is intended that the NTA will go to tender in 2024 for the staged commencement of services across the 5 Cities.” and also, “Policy underpinning the approach to shared mobility and mobility hubs on a national basis will be advanced in 2024 with plans to develop a Policy Statement on Mobility Hubs in the third quarter of 2024”.
Proposals for mobility hubs already feature in some draft town transport plans as part of County Development Plans so it is important they are not seen as merely being for cities. Pilot hubs need to be established in urban centres of different population sizes.
TR/24/18(TF) Rollout of expanded Regional Bike sharing schemes in Limerick, Cork, Waterford and Galway, including enhanced e-bike provision. This is a welcome development but our understanding is there are problems with the maintenance of the current fixed station bike-share schemes in the regional cities, so merely adding a greater variety of bikes without ensuring the stations and bikes are well maintained will not lead to greater take-up. In some of our cities, one-way systems make bike routes circuitous and unattractive so local authorities need to be encouraged to provide for more contra-flow routes.
5 Chapter 19: Local Authorities Climate Action Plans (LACAPs): Need for Enhanced Guidance:
5.1Consistency of Guidance and Assessment While we welcome the statement that “A monitoring and reporting system for the LACAPs will be developed and best practice examples of LACAPs will be identified and disseminated across the sector through peer-to-peer engagement”, we are concerned that the statement, “Local authorities can take their own approach to the style and structure of the LACAP but it must be aligned with the key principles set out in the statutory guidelines; ambitious, action-focused, evidence-based, participative and transparent” has led to inconsistencies across the system and less than robust targets for sustainable transport.
The current guidelines for Local Authorities are vaguely-worded and contain optional phrasing such as “should” and “could”. In practice, this allows for unsatisfactory plans by Local Authorities, as the guidelines can be argued to have been followed. We would like to see more specific guidance so that local authority plans can be objectively assessed as having met or not met the guidelines.
An example of the outcome of this is that our Meath sub-group, Navan Cycling Initiative, have found the Meath County Council Climate Action Plan to have very few measurable and scheduled targets for the development of active travel, for instance having no annual targets for rapid-build cycle infrastructure, and no specified, measurable, timed actions set out regarding speed limit reductions.
We note that one of the actions listed in the Citizen Engagement chapter of the CAP is “Delivering robust systems to measure climate action at all levels”.
Measurement of climate action through citizen engagement will only be possible if measurement metrics are in place to start with. Having read the transport section of several LACAPs we note a distinct absence of robust measure/monitoring systems for active travel in many of them.
5.2Clarify Consequences for Local Authorities for failure to meet Targets While the emissions targets are statutory, the consequences for Local Authorities failing to meet these targets are entirely unclear. The targets are therefore being prioritised alongside every other KPI (e.g. NOAC KPIs). Clarifying consequences if any will allow Local Authorities to prioritise appropriately.
6 Spatial and planning policy (Chapter 11):
Local authorities are continuing to permit low-density and one-off, car-dependent housing developments on the periphery of towns and cities. Such planning denies access to healthy active travel.
We would support accessible, medium-density, mixed use neighbourhoods and the 15-minute city concept. We support Chapter 11’s section 2.3 and its reference to the National Planning Framework, particularly National Policy Objective 53, in seeking to minimise car-dependent new housing. We submit that the Climate Action Plan 2024 should include an Action strengthening its support for this Objective and highlighting its importance.
7 Summary/Conclusion
In summary; the Irish Cycling Campaign welcomes many aspects of CAP 24 and is cognisant of the work being undertaken by both the Department of Environment Climate and Communications and the Department of Transport to move us from car dependency and high emissions to a more sustainable means of transport with reduced emissions. We are happy with the Sustainable Mobility Policy, the proposed Demand Management Strategy, the Avoid Shift Improve approach, the expansion of Bike Share schemes, the concept of Mobility Hubs and the proposals for a Citizen Engagement strategy. We welcome Cycle Connects and the National Cycling Network Plans.
We feel the Plan would be improved by having a more robust integrated strategy for multi-modal transport, by accelerating the roll-out of the bus shelter programme and by expanding the Local Authority Winter Maintenance Programme to include bus routes served by Local Link.
In recognition of the volume of carbon emissions generated by the tourism sector and mindful of the benefits of sustainable tourism to rural communities, we would like to see a section on Transport and Tourism added to the Plan
We are concerned that the Department’s current strategy for engagement with stakeholders excludes groups such as the Irish Cycling Campaign and does not include environmental NGOs such as An Taisce or PPNs except in a minor way. We would like to see this change.
We are also concerned with the variation we have observed in LA CAPs re the measurement and monitoring of sustainable transport targets and feel guidance for LAs needs to be more robust.
We are disappointed no start date is mentioned for the commencement of the proposed Smart and Sustainable Mobility Accelerator Project. This project featured in CAP23 but appears not to be on target. Meanwhile LAs are going ahead with projects without the relevant training.
We strongly urge the creation of Regional Active Travel Teams so as to incorporate the genuine multi-disciplinary skills that are available to larger city teams.
Earlier today (Fri 05 April 2024), Irish Cycling Campaign made a submission in response to the Department of Transport’s consultation on the Review of the Road Safety Authority. You can read a copy of it below.
We wish to thank all of our fabulous volunteers who contributed to this submission. We sincerely hope that it helps to reshape the institutional context which has a huge bearing on the real and perceived safety of those who travel on foot, by bike and indeed by any other mode of transport.
Introduction
We in the Irish Cycling Campaign are a network of knowledgeable and passionate cycling advocates from across urban and rural Ireland. We are the member for Ireland of the European Cyclists’ Federation (https://ecf.com/) and also a member of the Irish Environmental Network (https://ien.ie/).
We know that cycling is part of the solution to many of society’s problems, from health to the environment to the economy. We have a vision for Ireland where everyone has the opportunity to cycle safely to the shops, to school, to workplaces regardless of their age or ability. Our expertise in research, policy, transport planning, infrastructure design, event management and behaviour change means we are the trusted voice on everyday cycling in Ireland.
The Department of Transport (‘the Department’) is currently undertaking a review of Ireland’s Road Safety Authority (RSA) via an independent third party, Indecon International Consultants. We set out our views below in the form of responses to the seven online questions posed by the Department on the downloadable public survey.
Executive Summary
We welcome the opportunity to make this submission. In short, we have serious concerns about the performance of the RSA:
Institutional and financial adherence to car dominance
Cultural blindness to the needs of vulnerable road users
Failure to advocate for better road designs and effective enforcement
Silence on the rapid growth of ever larger and more dangerous private motor vehicles (SUVs)
Views on Services Provided by the RSA
Q 1. The RSA currently provide a range of services and functions, including Driver Testing and Licencing, NCT and CVRT Vehicle Testing, road safety advice, road safety promotional and media campaigns, and road safety education programmes, as well as working with other stakeholders to enhance road safety enforcement and inputs to road safety legislation. What do you believe to be the most important of these services and functions? And are there any other services or functions which the RSA should be undertaking that they are not undertaking currently?
We believe that any authority concerned with road safety in Ireland must carry out all those functions. However, the current dominance by private car use (whether EV or ICE) leads to poorer safety outcomes, compared to a holistic approach to road use (and transport generally) that tackles car dominance and unrestrained driving.
We see a crying need to shift Ireland’s road use and culture to one that is both safe and healthy, and one that prioritises vulnerable road users (as required by the Department’s own guidance and investment frameworks). Thus the education, promotional and legislative functions must take priority. We believe any effective road safety authority will also have an active role in enforcement of traffic legislation, and in advocacy for better roads, cycleways and walkways.
Implementing road safety measures can be unpopular and is often faced with local and political opposition, especially when it involves prioritising road users who are not driving. It should be a core function of the Road Safety Authority (RSA) to dispel misinformation and clearly educate the public in relation to the importance and benefits of reduced speed limits and the infrastructure that improves road safety.
Data:
High quality research and data is needed to lead road safety interventions. The RSA should be bringing together multidisciplinary research teams in universities to carry out comprehensive research and data analysis. Such teams would include behavioural scientists, experts in public health and epidemiology, statisticians and engineers.
The absence of any road traffic collision data made publicly available for researchers and public engagement, is a major deficiency in one of the core roles of the RSA.
By contrast, such data is not only available in the UK in machine-readable format amenable for analysis, but is also collated and presented for better public information with dashboards and interactive maps. See for example the following:
Arguments about GDPR preventing the release of these data in Ireland do not appear to hold much water, since other European jurisdictions are subject to the same regulations.
We note that a road traffic collision map was previously available on the RSA website, covering collisions until 2016. Although limited in its function, it had a role in road safety audits and could be used for simple research, public information and advocacy purposes. This map was removed in late 2020, and on November 30th 2020, the following statement appeared on the RSA’s website:
“Access to road safety data”
We are in the process of reviewing our road traffic collision (RTC) data sharing policies and procedures. Record-level RTC data can’t be shared until this review is complete.”
After more than 3 years, there appears to have been no visible progress on this issue. This is an obvious concern for all stakeholders. The impression given (whether true or not) is that this is not a priority for the RSA, or that there is something to conceal in these data. We would strongly argue that the RSA follows the example from other states in making the data available and useable.
Q 2. Do you have any other views on the focus and balance of the Road Safety Authority’s functions, between the driver and vehicles testing and licensing services it delivers to the public, on the one hand, and the road safety policy, promotion, education, and research functions it undertakes, on the other? (See:Role of the RSA)
Decoupling of Services:
We propose a re-evaluation of the RSA’s structure to potentially decouple those two roles. Whether intentional or not, the RSA’s approach to road safety is extremely motor-centric. We expand on this below.
Culture and norms around driving instruction and testing
Respect for people cycling and understanding of cyclist behaviour needs to be prioritised in the driver training curriculum. We are concerned that some Driving Instructors have difficulty observing rules that are there to protect people walking and cycling, such as parking in cycle lanes and footpaths, even when engaged in training novice drivers.
There seems to be no understanding, for example, of the role played by bike-boxes with their advanced stop-lines among the ADIs. Drivers regularly invade these safety features, so it is clear that their importance is not covered by instructors or testers.
The test must be reformed so that there is a vulnerable road user category added with mandatory questions posed in the on-line assessment; in addition, we would urge that a mandatory requirement be introduced into the training and testing of professional drivers that involves safe interaction with bike users, where the novice or a driver undergoing annual CPC assessment must ride a bicycle in traffic in an urban area to have experiential awareness of extreme vulnerability.
The medical fitness to drive assessment requires reform
GPs need to carry out a thorough investigation beyond focusing on blood pressure and eyesight. The exam should include checking peripheral vision or ability to rotate the head in a horizontal plane. This latter function is of critical importance in keeping bike users safe on our roads – drivers are failing to turn their heads in order to look properly so it is our view that many may not actually do this due to age related cervical vertebra mobility issues.
Taxi drivers must be subject to mandatory CPC
The exclusion of taxi drivers from mandatory CPC assessment is unacceptable. They drive as a profession and therefore must be treated as a professional driver. Sharing bus lanes with bike users carries additional responsibility and awareness.
Views on the approach to funding of the RSA
Q 3. The RSA’s functions and operations are mostly self-funded, from the fees it charges for the provision of services, including driver licensing and testing, and passenger and commercial vehicle roadworthiness testing services (the NCT and Commercial Vehicle Roadworthiness Testing), with little direct Exchequer/public funding received. What are your views on this self-funding model rather than an exchequer funded model or a mixed funding model?
The Irish Cycling Campaign fundamentally opposes the current self-funding model of the RSA, which relies heavily on the growth of private car ownership and use. This model creates a conflict of interest, as the RSA’s financial well-being is directly tied to the proliferation of vehicles and increased vehicle-kilometres travelled (VKT) on our roads. We strongly advocate for an exchequer-funded model to ensure the RSA’s independence and ability to take necessary actions to enhance road safety for all users.
It is deeply inappropriate for the RSA to use motor industry sponsors in road safety campaigns.
Views on the future of the RSA
Q 4. Do you have any views on the future role of the Road Safety Authority?
We have set out our views on future funding models, and on the cultural norms of the Authority. We would submit that there are other changes that would potentially be useful and effective.
Different indicators of success
The current mission of the RSA is “to save lives and prevent injuries by reducing the number and severity of collisions on the road.”
The statistics on death and injury should not be the only indicator of how safe our roads are. Another important key performance indicator which should be applied is the number of people walking and cycling on our roads. The number of children walking and cycling to school has plummeted in the past 30 years as the number of car journeys has soared. Parents no longer feel safe letting their children commute by bike or even playing outside in many places.
Counting not just victims by mode of transport but the perpetrators of road violence:
Since the primary hazardous exposure on roads and streets in Ireland is driving, reducing the total number of kilometres driven nationally by enabling more walking, cycling or public transport journeys will itself make roads safer.
This has the effect of signalling to the public that the RSA only engages or values input from such “paying users” of its services.
Future Board Make-up / Expertise
In the make-up of the RSA board, we see a need for much wider ranges of expertise than are currently represented.
Such expertise might include, for example, vulnerable road user requirements, public health, health effects of sedentary lifestyles, of climate change, or of air/ noise pollution, and hazard and risk assessment in road use. There also appears to be an absence of non-drivers on the board. It is essential that road safety is approached representing the experience of people who do not use a car.
We are unaware of specialist sub-committees of the board, who may have expertise in the various relevant fields (e.g. public health, air pollution, social change). We would urge consideration of the establishment of such sub-committees, which might provide useful input to Board decision-making.
Q 5. Do you think there are any functions currently undertaken by the RSA that would be better delivered by another body/agency or any functions completed by others that would be better undertaken by the RSA?
Road Safety Commissioner
As outlined in Q.2 above, the two main functions of the RSA conflict with each other, and there is a strong argument for separating them. The appointment of a suitably empowered and resourced Road Safety Commissioner, working either in parallel or as an overarching authority above the RSA, should be considered. Such a Commissioner would take a broader view of road safety, particularly drawing out the implications of the existing Road Safety Strategy Safe System Priority Area Six, which
‘…involves promoting these safer modes, such as public bus and train, and providing safer environments for healthier modes, such as walking and cycling.’
Strong advocacy for reduction in car use across society is the ultimate outcome of this Priority Area. Switching travel mode from private car to public and active travel is the ultimate road safety tactic, and should be a central task of any authority concerned with road safety.
Engagement with the RSA
Q6. Please indicate any involvement you may have with the work of the organisation and your views on their road safety information campaigns, education work or other services.
The Irish Cycling Campaign meets regularly with RSA officials to advocate for safer cycling and measures to control poor driver behaviour. Under its former name, Cyclist.ie, and under sub-groups such as Dublin Cycling Campaign, the organisation has engaged with RSA since its inception.
Hierarchy of Controls
The Vision Zero approach refers to a hierarchy of controls. The Authority have noted in their own document “Guidelines for Improving Road Safety Around Your School” (2021), that personal protective equipment (hi-vis) is the last level of control (p15, Fig 3).
The RSA should allocate funding to all levels in the hierarchy, with proportionally more to earlier levels – i.e. Elimination, Substitution. This is not to say that no funds should be allocated for hi-vis, but that funds for hi-vis should be lower than all other measures. Currently huge emphasis is placed on the wearing of hi-vis clothing. The emphasis on hi-vis has also meant that the message that it is a legal requirement to have bike lights in hours of darkness has been lost, with many people now cycling with hi-vis vests, but without lights.
Road Safety and Children
We urge the organisation to shift its focus away from victim-blaming campaigns centred on the wearing of high-visibility clothing. Is it an appropriate use of resources to be distributing 40,000 hi-vis vests to pre-school and school children annually, while there is little intervention to deal with driver behaviour around schools, sports grounds and playgrounds? It is an erroneous message to give children the impression that hi-vis will protect them. The responsibility for road safety lies with adults driving ever large motor vehicles recklessly and flouting road traffic laws – and not with small children.
Children lack the capacity to be responsible for road safety and must absolutely not be held accountable or held to blame. Children have the right to play, they have the right to be safe outside. Our car culture has negated this right. Driving is a privilege and it is viewed in Irish society as an entitlement. Driving has removed safe places for children to play outside.
The RSA education programme to primary school students is actively disempowering in that it creates a sense of danger around walking and cycling outdoors. It perpetuates the removal of this freedom. The driver is 100% responsible for a child’s safety. These RSA primary school campaigns are public health campaigns around a group of people who do not drive. In short, the RSA is failing children.
Much of the “Guidelines for Improving Road Safety Around Your School” document is commendable, as it follows the Hierarchy of Controls, but it places the onus on already overburdened school management to create and implement a road safety plan.
Most schools do not have the capacity to implement and sustain such a plan and certainly do not have the power or authority to enforce the main elements that would actually have an impact on road safety around schools.
We need to see a move away from spending on PPE and hi-vis for small children and, instead, see a reprioritisation of the education message in primary schools from children to parents and other drivers.
We would recommend education nights by RSA educators and partners (AGS, etc) delivered to parents facilitated by school management and parents associations.
Additionally the RSA need to measure modal shift to walking, wheeling and cycling as one of their metrics to measure a successful safe school environment.
30kph Campaign
While we commend the RSA for its recent positive 30kph speed limit campaign (along with the campaign to urge drivers to allow sufficient space when overtaking people on bicycles), the Authority has failed to persuade An Garda Síochána to enforce 30kph limits. Furthermore, it is vital that traffic calming infrastructure is rolled-out quickly to ensure average traffic speeds are compliant with the posted speed limit. This involves engaging proactively with each of our 31 Local Authorities.
Where traffic calming is ineffective or absent, there must be active enforcement. Without enforcement, people do not observe these limits as outlined in the RSA’s own Free Speed Survey 2018, which show that 98% of drivers speeding on urban national roads with 30kph limits, and 70% of drivers speeding in residential 30kph streets – (Appendix I, page 11, of FREE SPEED STUDY Survey Report 2018 | RSA
We also note that the Free Speed Survey in 2021 does not contain data on 30kph zones – Free Speed Survey 2021 | RSA.
It is critical that the RSA continue to gather data on compliance in 30kph areas, call for enforcement in 30kph zones, and advocate the use of static speed cameras where AGS or Go Safe vans cannot provide enforcement.
A 2022 AECOM/ TII report pointed out the higher GHG emissions from ICE cars travelling at less than their optimally efficient speeds of 50 – 90 kpm. But it is important that, in urban and built-up areas, road safety is prioritised over minor possible savings in fuel efficiency. We would support the report’s recommendation for there to be a focus on the reduction of congestion in urban areas, and we maintain that this is best achieved through the allocation of road space to public transport and active travel. This would also improve road safety, if accompanied by measures to improve pedestrian and cycling infrastructure.
The apparent absence of the RSA in policy discussions about speed limits on the national road network means that economic and GHG mitigation considerations have, in some cases, trumped the most obvious road safety benefits of reducing traffic speeds – and we are thinking here in particular of cases where schools are located right next to N-roads.
Call for effective and widespread enforcement in regard to conditions for people on foot / on bike
There needs to be an education and enforcement campaign with regard to motor vehicles parking on footpaths and cycle-lanes / cycle-tracks. This behaviour has become habitual, especially in residential areas. It creates hazards for vulnerable road users, especially those walking and cycling with children, elderly people and those with vision or mobility impairments.
Schools around the country have tried to educate and inform parents around illegal parking but to no avail. Safe Routes to school is progressing far too slowly to have the required impact on driver behaviour. In the interim, we need enforcement and RSA has not effectively advocated or demanded it.
Supporting implementation of road safety interventions:Advocate for infrastructure:
For many years the RSA have shown their support for investment in motorways and road upgrades to improve road safety outcomes. The RSA’s voice has been and is generally completely absent in educating the public on the positive road safety impacts arising from the reallocation of road space to modes other than private motor vehicles. This would include traffic calming measures such as junction redesign, road narrowing, and infrastructure to create a safe environment for people walking and cycling, segregated cycle paths, continuous raised footpaths across junctions and pedestrian and zebra crossings.
Providing public transport alternatives to driving also reduces the risk of people opting to drink/drug drive.
False equivalence
The RSA must improve the language they use around people walking and cycling. The “Be Safe, Be seen” messaging is jarring, especially when so many collisions are due to drivers’ failing to observe. People cycling have a legal requirement to have front and rear lights in hours of darkness. People are clearly visible in daylight hours but they cannot make themselves seen by drivers who are distracted or failing to observe.
People cycling do not pose the same risk as people driving cars. The weight and speed of a motor vehicle means the driver bears far more responsibility when sharing the road with others.
Sports Utility Vehicles / SUVs
The striking difference in the mass, momentum and kinetic energy of motor vehicles versus people on (10-20kg) bicycles, is accentuated further by the disturbing growth of ever larger Sports Utility Vehicles (SUVs) on our roads and streets. According to a recently published research paper:
New cars in Europe are getting 1 cm wider every two years, on average. That’s according to research by Transport & Environment (T&E) which says the trend will continue due to the rising sales of SUVs – unless lawmakers take action. Around half of new cars sold are already too wide for the minimum on-street parking space in many countries. https://www.transportenvironment.org/discover/cars-are-getting-1-cm-wider-every-two-years-research/ The RSA has been silent on the frightening phenomenon whereby almost two out of every three cars sold in Ireland are of SUV body types (https://www.ft.com/content/fba7a808-e03e-40c6-9795-38c05abc844a). The trend towards wider vehicles is reducing the road space available for other vehicles and people on bikes (as shown in the image below), while parked cars are further encroaching on footpaths. The wider designs have also enabled the height of vehicles to be further raised, despite crash data showing that a 10 cm increase in the height of vehicle fronts carries a 30% higher risk of fatalities in collisions with pedestrians and cyclists.
Figure from the Transport and Environment report, link above.
From an emissions perspective, Prof Brian Caulfield, regarded as one of the leading authorities in transport emissions in Ireland, and someone who has conducted extensive research on decarbonising transport, said SUVs need phasing out (https://www.irishexaminer.com/news/spotlight/arid-41132380.html) – but from a road danger perspective, SUVs are contributing to a more hostile and hazardous road and street environment for everyone else in their vicinity.
The RSA, or a replacement road safety organisation, needs to engage with the latest research on this topic, step up and advocate strongly on this topic.
Other Comments
Q7. Finally, please provide any other comments which you feel may be of relevance to this review of the RSA.
In summary, we need an expedited, national motor traffic reduction plan and a paradigm shift in how we think about road danger. We need to stop diverting ourselves from the real issue – which is the physical presence, destructive and violent potential of ever larger forms of private individualised mobility.
We again thank the Department and Indecon for their attention to our submission.
Our newly inaugurated Irish Cycling Campaign (formerly Cyclist.ie) has made its first formal planning related submission to Sligo County Council, together with our member group Sligo Cycling Campaign. And what better place to start than the lovely seaside town of Rosses Point west of Sligo Town. Note that the image above shows a present view of the Rosses Point coastal road.
The Rosses Point Public Realm Enhancement project is a scheme aimed at providing improved walking and cycling facilities along the main coastal road in Rosses Point. Interestingly, this project is funded from the Rural Regeneration Development Fund (RRDF) and not through available Active Travel funding. Last year’s active travel funding allocated a separate €70,000 for footpaths in the village itself. This was out of a total active travel allocation of €3 million for the county of Sligo for 2023.
Both Sligo Cycling Campaign and the Irish Cycling Campaign were supportive of the project, which Sligo Cycling Campaign views as the beginning/end of a Sligo Coastal Mobility Route from Rosses Point to Strandhill. We both made a number of suggestions for proposed improvements. Our submissions can be read HERE (for the ICC one) and HERE (for the Sligo CC one). Our main points related to:
Compliance with the Cycling Design Manual
Speed limit reduction to 30kph
Consistent narrowing of the main carriageway to help reduce speeds
Controlled pedestrian and bike crossings
Consistent bike track width
Junction design improvement
Bus Stop shelter provision
More inclusive bike parking
Sligo Cycling Campaign members try out a potential Coastal Mobility Route to Rosses Point
We would be hopeful that Sligo County Council will take our considered points on board, and we look forward to the building of the proposed scheme sometime soon.
These two submissions are the first of many that will be submitted in the coming year by the Irish Cycling Campaign and its members across the country. We will continue to make these submissions to Local Authorities and national bodies, to ensure that proposed active travel schemes are planned and built to a high standard. Last year alone in 2023, as Cyclist.ie, we made over 50 submissions on Active Travel projects nationwide!
If you would like to support us in this valuable work in making Ireland better and safer for cycling and walking why not join Irish Cycling Campaign, or consider making a donation – or even better, get involved in our work through our many local groups?
Cyclist.ie delivered its Pre-Budget 2024 Submission to the Department of Finance (Minister Michael McGrath) and the Department of Education (Minister Norma Foley) earlier today, 28 August 2023.
You can read it in full as a PDF here or in the body text further below.
A big thanks to our hard-working Executive Committee and wider team for preparing the submission. This behind-the-scenes work is but a small part of our broader advocacy efforts to put cycling and walking to the fore in government policy, practice and investment decisions.
Aggressively Promote Climate Change Requirements Increase Level of Transport Capital Funding Allocated to Creating High Quality Conditions for Cycling and Walking Countrywide
1 – Introduction Cyclist.ie – the Irish Cycling Advocacy Network, is the umbrella body of cycling advocacy groups in Ireland (https://cyclist.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). Three 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 and safe 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 2023, 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:
Infrastructure – Urgent need to further increase funding for high quality Active Travel scheme. Increase to €1B over the final two years of the current government term.
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.
Bike to Work Scheme reconstituted. Move away from the PAYE 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.
Business focused Cargo Bike Schemes for the city centres of the five Irish cities.
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 50% of the private car market.
VAT. Zero rate VAT on bicycle repairs and businesses – to promote the circular economy, create jobs in the green economy, and make cycling more affordable for people of all incomes [1].
Safe Routes to School Funding increased with the outcome of the removal of all school motor traffic from all urban and suburban schools by September 2024.
Bike Parking and Bike Scheme Investment – Large indoor and supervised bike parks at all major city bus and train stations. Covered outdoor bike parking at medium sized transport hubs.
Education & Training – Funding to establish cycle training as part of the primary school curriculum
Further detail on the above items is provided on pages 3-5 below.
3 – Further Details
Walking and Cycling Infrastructure While Cyclist.ie 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 report on our emissions targets, they noted that transport was a key problem area that saw emissions increase by 6% despite the significant increase in electric motor vehicles [2].
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 projects [3]. 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 2023 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 remaining two years of this government. The allocation of €1B 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.
Policing 2023 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 is 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 can borrow them over the school term to trial what bike would allow them to make the switch from the car [4]. 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 they make funding available to all schools at both primary and secondary level to enable projects like this to take place.
Business Focused Cargo Bike Schemes Cyclist.ie 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 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 bicycle repairs and businesses – 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 a goal of the removal of car traffic from the internal roads and front of school streets of all urban and suburban schools by September 2024.
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 huge success in empowering and enabling children to cycle safely, but we need to see proper investment to ensure every child leaves primary school with an adequate level of cycle training.
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 sincerely,
Neasa Bheilbigh Chairperson Cyclist.ie – the Irish Cycling Advocacy Network
