Climate Target
The 2021 Climate Act sets a legally binding target of 51% reduction in emissions. This should be regarded as the floor of our ambition, rather than the ceiling of it – particularly in Dublin where there are greater alternatives available to the private car. There is an overreliance on demand management strategies to bridge the gap to a 51% reduction in emissions in the transport sector. These measures will have a limited impact on emissions if there is not the capacity to absorb journeys onto alternative, sustainable means of transport. Large scale infrastructure projects need to be brought on stream as quickly as possible to ensure there is capacity for displaced car journeys. Supports and incentives also need to be identified to encourage people to use active travel means wherever possible.
Path to Decarbonisation
The transport strategy needs to set out a year by year path to decarbonization. It may prove dangerous to wait until the decade is over to measure the success or otherwise of the measures against what is envisioned. It is important for public accountability and for all the stakeholder bodies to be able to monitor the success of the plan on an ongoing basis. And the NTA should aim to alter the plan if it emerges that we are not on our predicted course for decarbonisation.
Vehicular emissions lifecycle
A limitation of the plan is that it only counts emissions at the tailpipe rather than the total emissions involved in the construction and end of life of the vehicles. Electric vehicles, while still much lower emitters than petrol or diesel vehicles, are emissions intensive to produce and dispose of. But these emissions are not counted in a tailpipe calculation. Externalising emissions counting onto other regions and sectors does little to reduce our overall footprint in a global system of climate change. The plan should demonstrate, at a minimum, an awareness of this limitation and be clear that all alternatives to EVs are preferred and EVs should be regarded as the last alternative.
Demand Management
The demand management tools to be considered by this strategy will have a very significant impact on people's lives and how they travel and yet they are entirely unelaborated in this document. The demand management strategy should be published and put out for public consultation to gather feedback. The ambition of the demand management strategy should be to find mechanisms that are as equitable as possible and maximise the benefits to communities who currently experience restricted mobility by the current transport system e.g. changing the roadscapes to provide one way systems and increase cycling and walking provisions in areas where there are currently few public transport option. For those who are entirely dependent on cars for transport, supports should be identified to ensure they are not unfairly penalised.
Road/street space reallocation should also be examined and modelled by the NTA. It can serve a dual purpose as both discouraging journeys by private car and supporting and making safer journeys by bike or walking, which will particularly benefit those who do not have access to a car or who are not able to drive. Therefore as a demand management strategy, road/street space reallocation is likely to be one of the more progressive options available.
Working with Local Authorities and the Department of Transport
The success and timely delivery of this plan requires that the Department of Transport and all local authorities share a vision for radical reduction of carbon emissions and a refocus of transport away from private cars and towards more sustainable means of transport over the coming decade. Particularly in relation to the roll out of active travel infrastructure and some demand management measures e.g. parking charges, local authorities will play a crucial role. Delineation of responsibilities between local authorities and the NTA must be made clearer. It is important that local authorities are empowered rather than undermined in the process by having clarity regarding respective responsibilities in relation to emissions reduction measures from the outset of the plan.
Local authorities can also play a significant role in providing measures to complement demand management e.g. providing people with greater access to bikes and e-bikes, providing people with reward schemes for choosing more sustainable means etc.
The Department of Transport should also reform mileage payment schemes to reward commuters and workers who choose walking and cycling over driving. These incentivising tools should be supported by the NTA and factored into modelling.
Planning beyond 2030
We can be sure that the climate crisis will be an ongoing challenge for Ireland to respond to over many decades ahead and that provision of adequate public transport will be an essential aspect of how we need to address this. While the immediate focus is on the ambition regarding emissions reductions leading up to 2030, planning for post 2030 must begin immediately so that projects such as the Luas Poolbeg can be delivered as soon as possible.
The NTA should seek to increase its staff complement and support the relevant staff in local authorities on a long-term basis to ensure there is a consistently rolling over body of work being done to bring new projects on stream and reach as many communities as possible to address their diverse needs