Submission in relation to NTA GDA Transport Strategy

9.16 Enforcement of Road Traffic Laws

The offenses listed should also include: (1) Motorists speeding - speeding in residential zones and 30/50kmph zones is particularly dangerous for other road users and creates a hostile environment for pedestrians and cyclists;  (2) Motorists failing to observe a safe distance when passing cyclists;  (3) Bicycle theft

"Cyclists travelling on footpaths or pedestrianised streets" should be removed. This typically occurs where there is no cycling infrastructure and/or roads are unsafe and is incomparable with the other offenses listed in terms of severity, threat posed, and frequency of occurrence. Also, in many countries, children under the age of 12 are allowed to cycle on footpaths.

9.14 Equality and Inclusivity Programme:  I would like to see infrastructure that supports equality and inclusivity, e.g. disability bike parking, safe, segregated cycling. 

9.15 Equality and Impact Assessment: Socio-economic status should be included too.  For many people, private cars are not affordable, as both obtaining a driving licence and a car is costly as is the annual running cost.  Reallocation of road space to walking, cycling and public transport would be supportive of the equality ambition.  

A recent EU Commission decision under its Urban Mobility Framework (UMF) recognises the primary role of cycling and other forms of active transport in moving people in cities/towns and the ECF states in its response to UMF (22 Dec 2021): “We also applaud the Commission’s emphasis on mobility as a critical aspect of social inclusion and an important determinant of human wellbeing, especially for disadvantaged groups, and that transport is an essential service in the European Pillar of Social Rights.” 

9.16 Enforcement of Traffic Laws: I am delighted to see plans to enforce traffic laws.  I would also welcome new laws that limit or dis-incentivize the size of vehicles on our roads.  I would suggest that cars should be issued with emissions stickers that indicate the size of the engine and the quantity of pollution each car emits.  Research by Irish Doctor’s for the Environment highlights the detrimental impact of cars to our health.  

France has just introduced a law requiring car ads to promote alternative modes of transport. The NTA might consider something similar.  

 Considerably improved traffic law enforcement is required. Far too many bus lanes, cycle tracks and pavements are blocked by motor vehicles with little enforcement. Blocking footpaths and cycle lanes should be treated as seriously as dangerous driving as vulnerable road users can be put at risk by illegal parking.  It may be worth considering the introduction of an online portal which would allow citizens to report illegal parking in real time to support stronger enforcement.

Better enforcement in relation to driving in excess of speed limits is required – in particular in residential areas with 30km/h speed limits which are routinely not adhered to. This can be achieved either through design and traffic management enhancements or road traffic law enforcement. Driving in excess of speed limits in residential 30kmh zones should be considered ‘dangerous driving’ as vulnerable road users are put at risk (e.g. higher risk of fatal injuries of pedestrian and cyclist are struck at speeds in excess of 30kmh).

The strategy document itself has very little detail on cycling. Cycling as well as other active modes need to be recognised as a priority for moving people in cities/towns.  

This section says nothing about a commitment specifically to safe, fully segregated, fully connected cycling infrastructure, despite highlighting the fact that the overwhelming majority want this and say it would help them to cycle more.

Throughout this section, "Cycle Network" is entirely vague - especially since it is considered to be in existence already. This section should spell out what a cycling network is. Overall, a disappointing section - to achieve aims of 51% reduction in GHG emissions, cycling should be prioritised in this strategy.

To date, little progress has to be made in relation to the prioritisation of sustainable transport modes including public transport, cycling and walking. In particular, the DDA Cycling Network Plan from 2013 has not been sufficiently addressed. The updated network plan needs to be implemented urgently to allow a greater update of cycling as an alternative to driving and in particular to allow vulnerable road users, including families and children to be comfortable to use this transport mode safely.  

Comments in relation to the GDA cycling network, which has been published alongside the NTA Transport Strategy:

There is no information what the design features of a primary, secondary or greenway are. All primary, secondary and greenways included in the cycle network plan need to be fully segregated from all vehicular traffic 24/7. Bike lanes could be segregated from traffic via removal of through-traffic on some residential roads supported by traffic management measures such as the implementation of filtered permeability (Quietways; LTNs) or through design features such as raised kerbs. Ideally the majority of bike lanes should be allowing bi-directional bike-traffic to be grouped together for added safety rather than having a single –direction bike lane next to the car / bus traffic.

By way of example, the proposed secondary cycle road leading from Palmerston Road to the Grand Canal should include bi-direction fully segregated cycles lanes along Palmerston Road and Belgrave Square, where on-street parking can be removed to facilitate the installation of a segregated cycle route leading into Mountpleasant Avenue where the road space limited and where filtered permeability can provide a safe cycling environment connecting to the Grand Canal cycleway via the proposed dedicated bicyle bridge. This safe secondary route would provide a viable alternative cycle route for less experienced cyclists away from the arterial higher traffic roads of Rathmines Road and Ranelagh Road.

The inclusion of dedicated bicycle bridges over the Grand Canal away from the main car-centric bridges is very welcome.

Without full segregation from moving traffic we cannot have a safe cycle network that would be suitable for all ages and ability (e.g. this would not deliver a network that could be used by children and families for school drop off and older residents).

The draft strategy states: “It is the intention of the NTA and the local authorities to deliver a safe, comprehensive, attractive and legible cycle network in accordance with the updated Greater Dublin Area Cycle Network”.  It is important to include a clear and ambitious timeframe for the delivery of this network.

The GDA cycling network plan also lacks language in relation to enforcing fines or other penalties for vehicles parked in bicycle lanes or in relation to specific design measures and strategies intended to prevent this.

The protection of COVID19 measures are critical. I am concerned by the statement ““It is inevitable that not all temporary measures will be retained via the formal planning process but the change in mentality as to what is possible for cycling must be harnessed and built upon over the coming years to deliver the step-change in facilities that is being demanded”.   While there has been a number of high quality schemes delivered across the region, such as along sections of the canals and on some key radial routes, the requirement to deliver a coherent network linking origins and destinations and catering for trips within communities and to schools remains. The need to deliver this comprehensive network quickly has become even more apparent during the Covid-19 pandemic.

This is a crucial issue. Dublin at present has no safe, segregated and comfortable cycling network.

There is at present no cycling "network" – existing cycle routes at the moment are completely piecemeal and disconnected. Any network must be fully connected. This needs to be built into the design. Cycling any distance in Dublin can only be done by fearless expert road users - certainly not children, the elderly, or anyone with accessibility needs.

 Measure CYC2 – Cycle Infrastructure Design:  "It is the intention of the NTA to ensure that cycle infrastructure in the GDA provides an appropriate quality of service to all users, through the implementation of the design guidance contained in the latest version of the National Cycle Manual."  The National Cycle Manual contains guidelines that are out of step with international best practice, resulting in unsafe infrastructure being implemented.  In revising the manual, the NTA must attend to the best international examples of cycle design.

11.4 Cycle infrastructure design: The lack of specific details on cycle infrastructure design is disappointing.  It is critically important that the  NTA focuses on making cycling in Dublin City safe for all as a matter of urgency.   The design of cycle tracks must be suitable for the wide range of types of bicycle, e-scooters and mobility-aids in use these days – cargobikes, handcycles, standard bicycles with big boxes on front/rear carriers, etc.

Page 97: It is unclear why 12% is considered an appropriate projected total mode share for bicycles by 2042. It would be useful to include information and evidence to support the appropriateness of this figure.  

During 2021 more than 175,000 drivers were detected committing speeding offences and more than 23,000 were found to be using a mobile phone while driving, endangering more vulnerable road users. Stronger enforcement of rules of the road are required.