Tag Archives: Submissions

All kinds of Submissions e.g. to Department of Transport, Tourism and Sport etc.

Irish Cycling Campaign Submission on Rosses Point Public Realm Project

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?

You too can be the agent of change!

Cyclist.ie Pre-Budget 2024 Submission

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:

  1. 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.
  2. Policing – We are seeking a commitment that a 50% minimum of new Garda recruits are deployed to roads and community policing. This is in the context of the rising numbers of road traffic casualties over the last two years.
  3. 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.
  4. Business focused Cargo Bike Schemes for the city centres of the five Irish cities.
  5. VRT. Review VRT levels for all sizes, weights and types of vehicles, to promote the use of greener and smaller vehicle models. Sports Utility Vehicles (SUVs) should be specifically targeted for increased VRT. This reflects the increase in road danger they create for people walking and cycling arising from the driving of larger, heavier vehicles. These vehicles now command 50% of the private car market.
  6. 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].
  7. 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.
  8. 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.
  9. 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 

References

[1] https://ecf.com/news-and-events/press-releases/cycling-organisations-achieve-important-victory-eu-consumers-reduced  

[2] https://www.epa.ie/our-services/monitoring–assessment/climate-change/ghg/latest-emissions-data/ 

[3] https://www.nationaltransport.ie/wp-content/uploads/2023/05/Inflation-Bulletin-Card.pdf 

[4] https://www.nationaltransport.ie/news/minister-ryan-welcomes-news-of-twenty-new-bike-libraries-for-dublin-primary-schools/ 

Lough Derg Greenway – Options Selection – Cyclist.ie Submission

Cyclist.ie made a submission today, Thu 12 Jan 2023, on the Options Selection Phase of the Development of the Lough Derg Greenway in County Tipperary. Information on the project can be read here https://loughderggreenway.ie/. You can read our submission below.

Note that the Options Selections Phase, in terms of its position in the sequencing of phases of the project, can be understood from the following graphic:

1 – Introduction
Cyclist.ie, the Irish Cycling Advocacy Network (ICAN), is the federation of cycling advocacy groups, greenway groups and bike festivals on the island of Ireland. We are the member for Ireland 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, climate, and environmental benefits of cycling. An Taisce is the National Trust for Ireland – https://www.antaisce.org/.   

Cyclist.ie is and An Taisce are delighted to see the planning for this greenway / high quality cycling route on the eastern shores of Lough Derg progressing.  When constructed it will hopefully form part of a lacework of cycle and walking routes around the iconic Lough Derg, which will encourage local people to travel actively more frequently, and also entice visitors to the area to experience the many attractions and activities.

We have only some general comments at this early Route Options stage, in response to the non-statutory public consultation as set out on the https://loughderggreenway.ie/ webpage. We outline these below.

2 – General Comments
2.1 Population Access
It is critical that whatever route option is chosen that the route services the largest catchment population possible, so as to ensure that it is used all year round by the local population of close to 19,000, as well as by visitors to the area. We highlight, in particular, the need to link seamlessly to schools, sports grounds, shops and employment locations. We need to nurture a culture where it is safe and easy and enjoyable to cycle to school, sports training and other destinations where distances are amenable to this.  

2.2 Constraints
As outlined in particular in Section 6 of the Feasibility & Constraints Report , there are a variety of design difficulties to be overcome in choosing the best option for this proposed greenway. National greenway design standards will limit the choices for the different route options outlined, but it is obvious that a mix of sections along the various route options will likely be the final route choice. In other words, the chosen route will likely comprise a mixture of quiet back (L) roads (with reduced speed limits – see below), of providing segregated facilities alongside any short sections of R road that are to be followed, plus elements alongside field boundaries when done in an ecologically sensitive way.

2.3 Use of L Routes and the need for lower / safer speed limits.
It is unclear from the documentation supplied as to whether some of the L routes on the different route options are proposed to be used directly without widening – with improved surfacing – or with additional width provided. Cyclist.ie advocates for the development of L routes for cycling and walking, without major upgrades, but crucially with consideration of reduced speeds and some possible design interventions, as outlined in our Rothar Roads document. 

We would argue in particular that having 80km/h as the speed limit on these back roads (some of which have grass up the centre) is totally inappropriate (even if road side separate facilities are created). We highlight here the back road shown (below) as Figure 11 of the Feasibility and Constraints report (page 33) and where the text indicates that there is “little room for widening on one side… and significant earthworks would potentially be required to widen the road to accommodate the greenway”. Cyclist.ie wishes to challenge the idea that such attractive roads with grass running up the middle (which suggests low motor traffic volumes) need to be widened in order to make them cycling friendly. The crucial intervention here is to have lower, safer speeds on these roads and with driver behaviour improved so that cyclists are “expected and respected”. The use of some type of (lateral or vertical) physical interventions to reduce speeds on these roads would seem appropriate. 

TII, in the latest update of their Rural Cycleway Design standard, endorses much of this thinking, particularly in its section 3.4, which could be utilised in developing the alignment and design of this proposed greenway.   

Screen shot from page 33 of the Feasibility and Constraints report

2.4 Landscape- and ecology friendly route design
Cyclist.ie wishes to stress the need for minimal ecological and habitat disturbance in the development of this route – and this point relates back to our previous point challenging the apparent approach of seeking to widen some extremely quiet back roads in the creation of the route. In essence, rather than seeking to create a continuous ‘greenway’ all the way around Lough Derg, it would seem more prudent to include some lengths of very quiet L-roads, where there are some motor vehicle movements (of a local access nature) but where these happen at lower / safer speeds.

2.5 Connecting to the National Cycle Network and CycleConnects routes
We are aware of the bigger picture here of the development of the NCN (by TII) and the CycleConnects Routes (by the NTA). We would urge the designers to liaise closely with both of the relevant teams here, so that the Lough Derg Greenway / Cycle Route connects seamlessly with those other national and county level cycle networks (which themselves will connect to the EuroVelo#1 and EuroVelo#2 cycle routes).

3 – Summary/Conclusion
In conclusion, Cyclist.ie and An Taisce strongly supports the creation of this greenway / cycle route, where it is done in an ecologically sensitive manner. We also endorse the use of quieter back roads – especially those with grass running up the middle – as part of the overall route, but where attention is paid to reducing the speed limits from the completely inappropriate 80km/hr existing limits. 

We would be more than happy to discuss our ideas further with the project team in due course. 

We would be grateful if you can acknowledge receipt of this submission. 

Thank you.
Damien 

Dr. Damien Ó Tuama
National Cycling Coordinator, Cyclist.ie http://cyclist.ie/ and An Taisce https://www.antaisce.org/
Vice-President, European Cyclists’ Federation (2016 – 2021) https://ecf.com/
The Tailors’ Hall
Back Lane
Dublin D08 X2A3
IrelandE:  [email protected]

CycleConnects – Cyclist.ie Submission

Cyclist.ie made the submission below to the National Transport Authority (NTA) on Friday 18 November 2022 in respect to the public consultation on “CycleConnects”. This was all about the proposed cycle networks in both rural and urban areas lying outside of the Greater Dublin Area (as shown in the light green shaded counties of the map below).

Cyclist.ie wishes to thank its many volunteers who chipped in with their local knowledge and informed reflections as the submission was being drafted – terrific team work all round. We also note the many more detailed submissions made by our local member groups in regard to county-specific proposals (which you can read here amongst
all the submissions published by the NTA).

We will be following this process closely as it moves to the next stages of development. Watch this space.   

1 – Introduction
Cyclist.ie, the Irish Cycling Advocacy Network (ICAN), is the federation of cycling advocacy groups, greenway groups and bike festivals on the island of Ireland. We are the member for Ireland 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.

Cyclist.ie welcomes the publication of the draft Cycle Connects proposals available at https://consult.nationaltransport.ie/en/consultation/cycleconnects and we are happy to provide feedback at this stage. We note and welcome the extended deadline of 18 November (moved from 11 Nov last week).

Our submission here concentrates on providing feedback on the principles and standards underpinning the development of the cycle network and, crucially, interrogating the meaning of what is proposed as a cycle network, rather than location specific feedback. We also comment on the ongoing planning of the National Cycle Network (NCN), and the relationship between both projects.  Additionally, many of our member groups are making their own separate submissions in regard to the proposals and these will provide more location specific feedback. 

2 General Comments
We welcome the commitment in the CycleConnects document ‘to enable and promote higher levels of sustainable transport and are therefore tasked with increasing active travel mode shares – supporting new cyclists, those transitioning from other non-sustainable modes and improving conditions for existing cyclists’.  It is an important and welcome restatement of government policy in this area.  

2.1 Cycle Connects and the National Cycle Network (NCN)
We note the reference in the CycleConnects report to the regular collaboration with the TII team working on the NCN.  This is good to hear, although we are disappointed that the publication of the NCN final report has been delayed beyond its original date, and thus makes comparison for us, as advocates, more difficult.  Much of our (Cyclist.ie’s) comments in our detailed  submission on the NCN, delivered earlier this year, can be applied to the development of CycleConnects. Of necessity there is some repetition. In essence all of the points raised in Section 2 of our NCN submission are also germane to the development of CycleConnects and we ask the CycleConnects team to examine that submission and to consider its recommendations.

2.2 Who are the target users for each route type?
We would like to see an explicit statement in all of the documentation (both the overarching and the county level documentation) indicating who the target users of the routes will be – ie. for:
– urban primary routes
– urban secondary routes
– greenways
– inter-urban routes
This appears to be missing in the documentation. Without having a clear sense of who exactly the routes are being/will be designed for, the concepts remain too vague, and the meanings of the lines on the map remain too nebulous. This makes the consultation more difficult to respond to.

We would like to see a crystal clear statement about the target users for each of the route types being set out, to include consideration of the following cohorts (at a minimum):
– parents with children on bikes / trikes (including cargo bikes) and/or riding alongside parents
– primary school children cycling to school, sports grounds, local shops and other destinations (on their own)
– secondary school children cycling to school, sports grounds, local shops and other destinations (on their own)
– those commuting to work and other ‘utility journeys’
– those using non-standard bikes such as trikes, handcycles, mobility aids and trishaws
– recreational cyclists 
– touring cyclists

Without the above being thought through, we would be concerned that future decisions about route alignments and infrastructure types and standards end up being made with ambiguous and perhaps conflicting senses of who the target users will be – and this could lead to routes of sub-optimal quality being advanced.   

2.3 Urban Cycle Networks
It is critical that any proposed urban cycle networks are given protection in local development plans into the future, to preserve potential alignments.  Ideally the core networks need to ensure that there are permeability links into and from them to ensure maximal usage of the network, by surrounding populations.

In the ‘Route Development Methodology’ section of the main report , while ‘services’ are generally referenced in ‘Link Selection’ there is no explicit designation for bus or train stations, which will be a critical part of any developed network, as transport hubs . We want to see these destinations identified clearly on the Cycle Connects maps because inter-modal trips involving bikes and trains/buses will be critical as we seek to reduce the number of car journeys.  

While we note the point stated in the FAQ doc that “no  cycle  infrastructure  has  been  considered  as  part  of  the  development  of  these  routes”, we would like to stress at this point the need for 30km/h to be considered as the default urban speed limit in each of the urban areas intersected by the network.  There is a need to make towns and cities cycle friendly for all ages and abilities. The default 30km/h speed limit is widely recognised as the far safer vehicle speed limit to achieve that target (see https://www.love30.ie/ and other sources).

2.4 Investment Prioritisation
As the CycleConnects project moves to the next phases of its development, we would like to stress the need for the following principle to be adopted when figuring out how route investments will be prioritised – particularly given that we are probably going to end up with several thousands of kms of lines on maps by the end of the route identification phase. We would like to see a prioritisation given to making investments on the basis of the number of people living within, say, 5km of their most common destinations – and then on the basis of the number of people living within, say, 10km of their most common destinations (this longer distance can be very easily done on e-bikes which are a growing part of the cycling market). 

Drawing on some of the analysis conducted as part of the (2007) Strategy for the Development of Irish Cycle Tourism, what often happens with Irish towns is that there is ribbon development extending out from the villages and towns in all directions – not just one direction, linking to other villages (which might be a good distance away) – which means that interventions to improve the quality of provision for cyclists needs to be concentrated on all roads extending from these villages.  Therefore, one might end up with slightly wider local networks (extending into rural areas), which themselves are linked to the county cycle networks.

2.5 County Cycle Networks
We commend the detailed exploration of initial potential cycle networks, and the opportunity to comment on them.  In the FAQ document, under the section called “How have the rural routes been selected”, the following text is provided:
It has generally been found that rural regional roads tend to connect more smaller towns and villages than National 100kph roads which will miss many of these towns. The exception to this is when a 100kph National Road is present with a wide hard shoulder and thus the potential for cyclist infrastructure, and potentially is located along the TII National Cycle Network’.

However, we introduce a cautionary note on the above statement as follows:

(i) Many rural regional roads carry far higher traffic volumes than the local roads, and often at much higher speeds. They are also not particularly pleasant places to cycle on, and are not suitable for less experienced and/or younger cyclists.

(ii) While some N roads do indeed have wide hard shoulders on them, it does not follow that they may be suitable as designated safe cycling routes. The experience of cycling directly alongside motor vehicles (including HGVs etc) travelling at or close to 100km/h is frightening, and generally to be avoided.  Additionally, Cyclist.ie wishes to emphasise that the so-called ‘greyway’ solution is certainly not a fit answer to this issue – See our website piece.  The consultants and future designers need to be especially aware of the limitations of providing formal cycle routes on N-roads, as well as recognising the (apparent) positives.

(iii) Cyclist.ie would ideally like to see a much greater use of the local road network (i.e. non- R or N roads) in the development of the county cycle networks – but these roads need to be re-examined so that “cyclists are expected and respected” as set out in our Rural Cycling Vision.  And as these local roads move closer to towns and villages (and hence have higher traffic volumes), then special attention needs to be given to intervening more radically in terms of reallocating space for people on bikes and bringing speeds right down.  Some design issues for these roads are dealt with in the latest update of the TII Rural Cycleway Design, Section 3.4.  

Cyclist.ie would like to see the locations of all schools shown on the county level maps, not just on the urban maps. 

2.6 Standards
While not specifically referred to in the main CycleConnects Summary report, we note the reference to the National Cycle Manual under the ‘segregation’ FAQ.  It states that the ‘National Cycle Manual and other cycle design guidance’ will be utilised to ‘inform infrastructure upgrades’.  We would like to see all reference documents utilised for cycle design purposes clearly identified as part of this project, for the guidance of designers in the development of these networks.

3 – Conclusion / Summary
Cyclist.ie warmly welcomes this first phase of the initiative on the development of local cycle networks across the country, which we fully support, and we look forward to feeding into the actual development of the proposed routes.  We want to see these routes developing quickly and being used by local communities.  Our local member groups are submitting detailed comments on specific local county networks.

As outlined above, and in our previous submission on the National Cycle Network, we want to see:
– Prioritisation of route development to ensure highest potential usage by the local populations
– Inclusion of bus and train stations (and Transport Hubs) and Schools/Colleges on all network maps, both urban and rural
– Clear linkage with final NCN alignments
– Clarity on target group users for the networks
– Greater consideration of L road usage as part of the networks (along with a re-examination of speed limits on those roads)
– An abandonment of the original concept for ‘Greyways’ on National or Regional Roads.
– Listing and Application of the Design Standards to be applied

Cyclist.ie is happy at any stage to engage directly with the NTA in the furtherance of this important project, as part of sustainable transport in Ireland.

Colm Ryder
Cyclist.ie Infrastructure Coordinator
[email protected]
https://cyclist.ie/ 

Naas to Kill Cycle Scheme – Cyclist.ie Submission

On 19 October 2022, Cyclist.ie made a submission on proposals for the “Naas to Kill” Cycle Scheme, as developed by Kildare County Council. 

This is a proposed 4.4km high-quality cycle route connecting Naas and Kill via Johnstown Village. 

In general Cyclist.ie warmly welcomes this proposed scheme from the outskirts of Naas to the village of Kill, a route that has the potential to be transformative, and opens up safe and relatively pleasant cycling and walking along this route.




However, we particularly urge consideration of the following items in drawing up the final scheme:

● Narrowing of the main carriageway through both villages to encourage lower vehicle speeds, and enable a better quality and continuous cycle track.
● Consideration of the addition of Zebra/Wombat crossings in further locations in both villages.
● Reduction of the posted speed limit from 50kph to 30kph in the villages of Johnstown and Kill in line with current guidelines.
● Remove all the unsightly railings from outside Saplings Special school.
● Upgrade the cycle route from the Dublin Roundabout to Naas Town Centre, in line with a previous Part 8, to ensure that there is a complete safe route from Naas Town Centre to Kill Village.

Cyclist.ie’s submission can be read in full here.

The submission of Naas Cycling Campaign, a new member group of Cyclist.ie, can be read here

And the formal planning application documents from Kildare County Council can be viewed here.

Radical Changes to Transport MUST Be Part of the Next Programme for Government

The election is over but a new government has not yet formed. The arrival of COVID 19 has added to the challenge of negotiations for a new Programme for Government, but at the same time we cannot stand still on other issues.  During the election, Cyclist.ie, the Irish Cycling Advocacy Network, urged parties to implement two key transport policies  – 1) the rebalancing of Land Transport funding to allocate more to cycling  and 2) the provision of high quality cycling infrastructure. 

We accept that in the short term that the government is facing substantially increased expenditure to deal with Covid-19 and its consequences and a reduction in the capital budget is inevitable. However, we are looking for a rebalance of the transport capital budget and would  stress that investment in cycling represents very good value for money – the best return on investment for any transport intervention. The need for an appropriate level of funding and high quality infrastructure will continue long into the future if Ireland is to achieve government goals on road safety, climate action, congestion, the environment and health.

From election manifestos, all political parties accept the need for increased everyday cycling, while most accept the need for increased funding to 10% of the Land Transport budget, which in 2020 would amount to €182M. In the first 8 months of last year, the Minister for Transport spent approximately €2M or  0.11% of his annual Land Transport budget on cycling from his Walking /Cycling allocation – the principal area of expenditure for everyday cycling. Gerry Dornan, Vice Chair of Cyclist.ie stated “We accept that an immediate increase to 10% by the Minister for Transport is not practical in 2020 or 2021, but it is realistic to ramp up investment to 10% within three or four years and that is the benchmark by which we will judge the next government”.

A revision to the Strategic Framework Investment in Land Transport (SFILT) is essential. The original SFILT was developed in 2015 and fails to take into account increasing congestion, chronic health issues, air and noise pollution.  A suite of some twenty background papers informed the SFILT process but most were related to existing high car dependency and failed to give any serious consideration to increased active travel. 

The second issue which the incoming government  must address is the quality of infrastructure. Last year, international attendees at the Velo-City cycling conference  in Dublin were shocked at the poor quality of Irish cycling infrastructure. In order to attract people out of cars, high quality segregated infrastructure is essential. 

Seville was able to provide a cycle network and increase cycling significantly to 8% in just five years – the same period of office as an incoming Irish government. In the last five years, there has been little progress in Irish cities. Cyclists in Galway and Cork are frustrated and alarmed by their respective Metropolitan Area Transport Strategies while Limerick cyclists have little confidence in efforts to date at urban improvement by their local authority. The Strategies pay lip service to prioritising cycling and instead reflect the road-centric policies of the SFILT. In particular, traffic models are constructed on the basis that traffic levels will increase, with the inevitable “conclusion” that more roads are needed. The increases are large enough to justify “one more lane” but less than actual increases which would cause politicians to question the viability of schemes in terms of sustainability and value for money. 

Furthermore, the lack of vision on cycling by Irish local authorities is clearly demonstrated by several Dutch cities having current cycling levels in excess of 40% of journeys, whereas by 2039-2040 the predicted level of cycling in Galway city centre is just 6% and in Cork is 4%.

Cyclist.ie believes that the Department of Transport should require Directors of Services for Transport to be appointed as Cycling Officers with responsibility for change in transport mode for their authority and for publishing annual progress reports. 

The challenges to the next Irish government are unprecedented. It MUST introduce radical change to the way transport is managed in order to create a resilient mobility system and one that is consistent with nurturing active and healthy travel habits.

Submission on Policing Priorities 2020

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 a registered Charity and are also the Irish member of the European Cyclists’ Federation.  Our vision is that cycling will be a normal part of transport and everyday life in Ireland.

Cyclist.ie, is delighted to make this brief submission to feed into Policing Priorities for 2020, and we note the commitments made in Policing Plan 2019.

We note and appreciate the Roads Policing Key Performance Indicators, the high level objective of Protecting People, and Garda Commissioner Drew Harris’ commitment in the foreword to keeping people safe and protecting the most vulnerable. We especially welcome the section in  Policing Priorities 2019 which includes Policing our Roads and Safeguarding Road Users. Cyclist.ie suggests two further additions to Policing Priorities 2020: 1) Dangerous Overtaking and 2) Obstruction of Cycle Lanes 

Both of which would help to improve the safety of people who cycle.

The background to our comments is the trend of increasing cyclist fatalities on the roads. The graph below shows that this trend has been generally upward since 2011.   

Together with this trend in cyclist fatalities, we note the very worrying trend of high levels of serious injuries to vulnerable road users in urban areas, as outlined in the joint RSA/Garda press release of 28th November

The excerpted graph below, from the above report, illustrates the seriousness of this growing trend

We would hope that these latest figures will spur the Garda Traffic Division to greater efforts to protect vulnerable road users in urban areas in particular.  And, in the case of cyclists this can be done by increased enforcement levels, based on the new ‘Safe Overtaking of Cyclists’ legislation as well as tackling illegal parking in cycle lanes, on double yellow lines, and illegal use of bus lanes by private vehicles.  We note also from the latest figures released by the RSA that approximately three cyclists per week suffer life changing injuries.

Periodically, Cyclist.ie meets with senior officers of An Garda Roads Policing Unit, and RSA, to discuss items of mutual interest. The most recent meeting – jointly with the Road Safety Authority – was on 27th August 2019 when the Garda delegation was led by Chief Superintendent Paul Cleary. The discussions that day included Dangerous Overtaking, and Obstruction of Cycle Lanes. 

Dangerous Overtaking of Cyclists

Cyclist.ie has campaigned in support of legislative changes and more effective enforcement of road safety legislation. We are pleased that the Minister for Transport, Tourism and Sport and the Minister for Justice have successfully introduced new penalties for the Dangerous Overtaking of Cyclists.  We look forward to new initiatives by the Garda Roads Policing Unit in 2020 to support the introduction of this legislation, and to protect vulnerable road users.

Obstruction of Cycle Tracks

A second  area of concern is drivers who obstruct cycle tracks by parking on them, thereby forcing cyclists either onto the footpath or into general traffic lanes. We welcome the provision of an email address for Cyclist.ie to report such instances and propose to follow up on this in this New Year. We note that on 23rd June last, Minister Flanagan tweeted that “Cycle lanes must be kept clear for cyclists only. Gardaí and local authorities must act to enforce the law.”

We would also welcome increased policing of the offences referred to above, namely; parking on double yellow lines, and illegal use of bus lanes by private vehicles.  The publication of regular (quarterly?) bulletins on the number of Fixed Charge Penalty Notices (FCPN) issued would be a progressive step in indicating how all of these issues are being progressed.

As enforcement is a key factor in ensuring that cyclists are not endangered by such practices, a commitment in terms of targets and resources is essential to ensure that the targets in question are met. As a step towards this end, Cyclist.ie urges the Garda Commissioner to include these areas in the Policing Priorities of the national Policing Plan 2020.

We note that the Police Authority also has input into the national policing priorities and that the priorities in turn inform and are reflected in the priorities of Divisional Policing Plans and the Joint Policing Committees. Highlighting these areas by prioritising them would send a clear message to members of the force, to politicians and to the general public that they are no longer acceptable.

Cyclist.ie is happy to engage with members of the Roads Policing Unit at any stage, on any of the above issues.

Submissions on New Sustainable Mobility Policy

Cyclist.ie made four detailed submissions today (28th of February 2020) in regard to the Department of Transport, Tourism and Sport (DTTAS)’s Review of Sustainable Mobility Policy. Our submissions covered Active Travel, Climate, Congestion and a Summary paper

In our submissions, we pointed out that the Irish modal share data speak for themselves: a car dependence of 74%; a public transport share of a mere 6%; 15% travelling on foot; and just 2% cycling. Immediate and radical action is required to address the failure to improve this balance over the last half-century. For comparison, the modal share for cycling for all trips in The Netherlands is approx 25% and for trips under 7.5km is approx 33%. 

We believe that the government needs to invest far more seriously in active travel – and to de-prioritise investment in the unsustainable modes – in order to achieve an increase in active travel in all parts of Ireland: urban, suburban and rural area. There is a need for greater recognition of the potential of walking and cycling to achieve carbon abatement targets and recognition of the many wider benefits increased cycling offers. 

A sincere thanks to our volunteers – and, in particular, the members of the Cyclist.ie Executive Committee – in drafting these submissions. 

Government Consultation on Sustainable Mobility

Friday 28th Feb is the closing date for making submissions on the government’s sustainable mobility policy (SMP). This covers public transport (urban and rural) and active travel (i.e. walking and cycling). Details of the process including background papers can be read here

We urge all of our members and fans to send in submissions to the Department of Transport, Tourism and Sport (DTTAS) stressing the need for a radical change in policy – to be emailed to [email protected] by 17:30 this Friday 28th Feb. You can use the material in the two links below, and add in your own observations also.

If you are under pressure and have time only for a super short submission, we suggest you stress the following points in your submission (with subject title – Public Consultation on a Review of Sustainable Mobility Policy) and reword/edit in your own style as appropriate

  1. The balance of investment between active travel and public transport on the one hand, and carbon intensive modes on the other hand needs to change radically in favour of the former. Our position is that, once essential maintenance is provided for, and existing contracts honoured, there should be zero allowance for growth in car-based modes and the budget needs to be allocated to walking, cycling and public transport.
  2. Road space needs to be reallocated to allow a shift to more efficient modes of travel by installing high quality segregated cycling infrastructure and improved facilities for pedestrians on both urban and rural roads. A special emphasis needs to be given to making junctions safe for all ages and abilities – in too many cycle schemes over the last 20 years, improvements were made to the links, but not to the junctions themselves (the location of many collisions). 
  3. Secure and high quality cycle parking facilities need to be provided at all public transport stops, stations and interchanges to facilitate intermodal journeys. In the case of major stations (such as Plunkett in Waterford, Kent in Cork, Colbert in Limerick, Céannt in Galway, and Heuston, Connolly and Bus Áras in Dublin), there is a need to provide high capacity state-of-the-art cycle parking facilities as can be found in cities such as Utrecht and Malmo. 
  4. Create immediate ‘Quick Build’ projects in the interim to improve the cycling experience, while waiting for the major projects to be completed.
  5. Create an institutional structure to coordinate and oversee the implementation of all active travel measures. We would maintain that the structures recommended in Chapter 06 of the 2009 National Cycle Policy Framework (NCPF) are still broadly relevant. A major weakness with the implementation of the NCPF over the last decade was the lack of advancement of critically important actions such as 17.2 (establishment of a National Advisory Forum) and 17.4 (Creation of a Network of Cycling Experts). Compared to the institutional structures created to look after the roll out of Ireland’s motorway network, the structures created to coordinate cycling interventions were not in the same league. 

Cyclist.ie Calls for a VeloRution!

Cyclist.ie’s vision is that cycling will be a normal part of transport and everyday life in Ireland.  Cycling is a vital part of building healthier and less polluted communities. Check out our 10 Election Asks HERE, but we boil them down to three kernel points below.

  1. CYCLING NEEDS TO BE A NORMAL EVERYDAY ACTIVITY

Cycling is a critical part of the transport equation in combating Climate Change.  We need everyday cycling to be better and safer, more convenient, and easier. Hopping on your bike should be a more attractive option for the so-called first-mile and last-mile journeys.

No more slashing of funding or paltry rises: major investment is needed to shift people away from car dependency, especially for short journeys under 5km.  This means greater investment in cycling infrastructure and promotion.

We need our next Government to allocate a minimum 10% of Transport Funding to cycling immediately, as promised under the National Climate Action Plan.  Currently, cycling is allocated a tiny 2% of our transport spend.

We do not need to reinvent the wheel. Bike safety is highest in countries and cities where bike use is high and people cycling have interconnected networks of segregated routes (e.g. Netherlands, Denmark, Bristol, Manchester).

2.ELIMINATE THE NEED FOR CYCLE BUSES – BUILD SAFE  SEGREGATED NETWORKS

Manifestos that mention school cycle buses should make us weep with rage. There should be no need for parents and adults to marshal kids to school on bikes, forming human shields between small soft bodies and big, motorised, metal boxes. Cycle buses must not become the norm.

What we need are safe routes to schools and throughout populated areas: networks of segregated cycle paths along roads; safe junction design with priority signalling for people on bikes; and quiet routes through permeable neighbourhoods.

Let’s get designing and building!

3. FIT FOR PURPOSE PLANNING, POLICY AND POLICING

The 3 Ps of Planning, Policy and Policing seem a little dry at first glance – but these are the actions that make the good things happen.

Planning  – Building safer cycling infrastructure should be guided by our National Cycle Manual. This design guidance needs urgent updating to upgrade our standards and bring us into line with best international practice.

Policy – We need joined-up thinking for everyday cycling across the myriad of Departments: Transport Tourism and Sport, Health, Environment/Housing, Education, and Justice. We need a resourced National Cycling Office, preferably within the Department of Transport, Tourism and Sport, to coordinate policy, and ensure action.

Policing – We have road traffic legislation that considers people who cycle and walk, but enforcement needs greater priority. People who cycle are frustrated and frightened by illegal parking in cycle lanes and dangerous overtaking.The Garda need to learn from their UK counterparts.

CONCLUSION

Increasing cycling numbers in Ireland will cut congestion, improve public health, and reduce pollution.

To get more people cycling, we need to make it an easier and safer choice. Let’s have real Cycle Networks, Safe School Routes, and coordinated Planning, Policy and Policing that protects us.

It’s as easy as ABC: Allocate 10% of transport funding to cycling; Build safer infrastructure, and everyone will Cycle more.