Dublin 7 Sustainable Energy Communities - comment on the strategy specific to Cabra, Phibsborough, Stoneybatter and Dublin's inner city

Uimhir Thagarta Uathúil: 
NTA-C5-799
Stádas: 
Submitted
Údar: 
Dublin 7 Urban Action Group
Líon na ndoiciméad faoi cheangal: 
0
Údar: 
Dublin 7 Urban Action Group

Tuairimí

3. Strategy Challenges

3.6. Transformation of the Urban Environment

Car travel, and the reduction of it,  is still the central objective of the strategy - the focus needs to change. It should be made clear that car travel is a deprioritised mode and that inconveniencing private car traffic is something that needs to be done. The end goal is, of course, modal shift to active and public transport modes. Therefore, let the objective be to prioritise the modes we want to see on our streets - it is the congestion in public transport that needs to be addressed. 

The focus is clear throughout the document: for example, when it comes to modal shift, it is stated that car use needs to be reduced. This is far from enough - private cars need to be the very last mode of transport facilitated.

8. Planning for Sustainable Transport

8.9 Urban design and placemaking

Glad to see the NTA has highlighted the importance of biodiversity. We need as much greening of the GDA as possible to respond to the biodiversity crisis. It is however, completely insufficient. Plans to reduce car speeds to facilitate placemaking is fine but is not close to what is necessary: the city and its urban villages are traffic sewers and if the NTA is serious about urban design and placemaking, it has to reallocate space away from the private car and enable one-way systems all within the canals for trees to be planted, concreted areas to be transformed into green spaces, to prepare the city for floods and soaring temperatures (a tree planted street is on average 4 degrees cooler than a concreted one - within the canals, the tree cover is particularly poor).

 

PLAN 14 Reallocation of Road Space: “The NTA, in conjunction with the local authorities, will seek the reallocation of road space in Dublin City Centre, Metropolitan towns and villages, and towns and villages across the GDA to prioritise walking, cycling and public transport use and prioritise the placemaking functions of the urban street network.”

This is very important and is a welcome point, but it is not backed up by the BusConnects project in the Phibsborough and Church street area for example, where the already heavily concreted streets will be made available exclusively to motorised passing traffic, with the removal of the segregated cycle lane and the impossibility to increase footpath width. 

 

9. Integration and Inclusion

9.16 Enforcement of Road Traffic Laws

"Cyclists travelling on footpaths or pedestrianised streets" should be removed. People on bikes do not pose any threat, and when offered suitable infrastructure, do not cycle on paths. Moreover, pedestrianised streets should be open to people on bikes, with pedestrians prioritised, like it is done abroad (Seville would be a prime example of mixed streets, with injunctions for cyclists to leave priority to people on foot.

 

The NTA also needs to ensure that there will be enforcement on its bus lanes - the entire success of BusConnects depends on it.

 

9.8 Behavioural change

This needs to be revised. What definition of behaviour change is referred to? Campaigns are grand, but behavioural change will come once the reallocation of space has happened. See Covid 19 impact - when the streets are quiet, people cycle. You have the power to make streets quiet - one way streets, filtered permeability, road design. This is what people want from you, not dozens of campaigns. Promoting behaviour change without building infrastructure to support the behaviour desired, is ineffective. 

 

10. Walking, Accessibility and Public Realm

10.6 Pedestrian Crossings: 

"As such, the time spent waiting for the pedestrian phase may also need to be reduced (...) and a balance is required to ensure the needs of all modes are met." This is quite a revealing sentence. If we are serious about climate change and the impact of car traffic on our quality of life, we cannot talk about a balance. Private cars need to be deprioritised and inconvenienced. People on foot need to have priority - there is no balance to be sought here, but a voluntary move to take cars away and to make them as unpleasant to use in the city as possible, except for professionals and people with reduced mobility.

 

11: Cycling and Personal Mobility Devices

11.1 introduction

There are no clear measures and objectives in place for this entire section, despite cycling being one of the main tools we have in cities to decarbonise transport. 

"It is the intention of the NTA and the local authorities to deliver a safe, comprehensive, fully connected, attractive and legible cycle network in accordance with the updated Greater Dublin Area Cycle Network”. 

If we look at the maps provided with the documents, it seems the connected aspect of the network is not taken seriously (see notes on maps below), as some parts of the same road start with being primary and end up being secondary (with no explanation of what is primary and secondary). If we want people to replace car trips with bicycle trips, the network needs to be connected and safe, i.e. cycle lanes that can be used by children, people with disabilities, elderly people and nervous cyclists. As it is, the ‘network’ is haphazard, and the cycle lanes are of different widths, meaning cyclists may have to get into general traffic during their trip. 

“69% would find more cycle tracks along roads, physically separated from traffic and pedestrians useful to help them cycle more."

“84% of residents also support building more physically separated on-road cycle tracks, even when this would mean less space for other road traffic."

The difference between wanting to cycle and cycling is infrastructure - despite knowing this and having a vast majority of people expressing their desire to cycle, there is no commitment anywhere in the document to safe, fully segregated, fully connected cycling infrastructure in Dublin and no number attached to it. How many km? How many segregated? What width? 

 

11.2 

 

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”. 

 

Again, there is no figure attached to any of this, nor any budget. The graph following the paragraph shows a 12% the projected total mode share for bicycles by 2042, or 14% in the metropolitan area - where are those 12% and 14% coming from? Why is it lower than the 20% modal shift dublin City Council had set for 2020 in its development plan? How do we measure success?  Why is it so unambitious?

This is even more concerning that the legal objective is now to reduce GHG emissions by 51% across all sectors - we are not given any goal on transport, subdivided by mode. At European level, this has been understood and the mobility package in the TEN-T legislation considers cycling as the backbone of urban mobility - the NTA has not made cycling their priority yet.

11.3 GDA Cycle Network - comments on page 7 of the plan Mapset

Please note that we assume that primary road means this road will be considered as a main cycling route, secondary as a potential cycling route, as there is no explanation or clear legend on how to read the documents. With that in mind, we suggest a number of changes:

 

Capel Street and environs:

 

Remove the secondary cycle route from Capel Street. The overwhelming success of the summer pedestrianisation trials shows that Capel Street will be best used as a pedestrianised street, not as a through-route for motor vehicles or even bicycles. The high concentration of bars and restaurants leave outdoor space at a premium and using it as a through route is a poor use of the space. You shouldn’t run a cycle route down the street any more than you would on Grafton Street.

 

Instead, we suggest that you upgrade Jervis Street / Swift Row & Eustace Street (Temple Bar) to a primary route, and add a new walking & cycling bridge on the Liffey connecting the two. This is a better location for a bridge than the proposed bridge connecting Fishamble Street to Arran Street. There is a shortage of cycling crossing points in Dublin’s core, whereas there are several existing road bridges around the Dublin 7 and 8 area that the Fishamble St bridge is proposed for that can be retrofitted to include better cycling. A bridge at Jervis St / Eustace St (Eustace St would be need to be resurfaced and converted in bicycle-only street with widened footpaths) would be closer to key destinations such as Henry St and the new bicycle parking facility at Jervis St, and would connect to a dedicated cycle route on the north side rather than residential back streets, and would provides a direct route from a natural desire line between Parnell Street to the cycle route on College Green, and to the George’s St. 

 

LUAS / Finglas area greenway

We suggest extending the greenway that currently ends at Fassaugh Road. It could continue alongside the LUAS track, all the way to connect up to the plaza at Broadstone / TU Dublin. This would be a complex project that requiring engineering works and land acquisitions, but would be an enormously beneficial amenity for the area and is worth pursuing as a long-term goal.

 

Other comments:

 

  • Discontinuous from Botanic avenue to Church st : if we want this to be a main artery, a continuous, straight, primary road from Finglas to the city centre would make sense. Coupled with Luas Finglas, this would reduce motorised traffic from that heavily congested artery. Going further, this could be continued past the Liffey and by making Usher's quay a primary route continuous to reach Patrick st (which is marked as primary), you could create a North to South route from Finglas to Portobello
  • The Royal Canal Bank cannot become a primary cycle route despite the ambition for BusConnects - there is not enough width to accommodate a large flow of people, and plans for bridges over the canal and underneath the Blacquiere bridge have not been published yet. This corner (Royal Canal Bank / NCR) is also going for redevelopment,
  • with 100 apartments and 450 cycle parking. For this new community to be able to cycle safely and straight into the city, the Phibsborough road needs to be the first choice. The Canal Greenway would be great for leisure cycling and family cycling but should not be considered as a main artery.
  • Unless Whitworth road is made into a one way road, there is simply not enough space to make it an orbital route
  • Instead, make the whole North Circular road into primary or orbital road - that would allow people living in Stoneybatter and Phibsborough to access the Phoenix Park by bicycle and could be connected to the Canal Greenway off North Strand, creating a continuous cycling route from Heuston to Grand Canal Dock with very little effort but reallocation of space. The Mater Hospital being one of the main employers in the Phibsborough area, this could encourage a lot of commuters to switch to bicycles or public transport
  • Upgrade the rest of George’s St/Aungier St/Camden St to primary to provide a continuous north-south primary route through the heart of the city
  • Upgrade Dorset Street to Primary and King St North to Primary orbital
  • Add a secondary route connecting Stoneybatter to the North Circular Road Phoenix Park gate. Suggested route via Arbour Hill, up through the residential streets and through O’Devaney Gardens
  • Upgrade East Wall Road to primary to connect the coastal routes north and south of the city

11.4 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 do not fit with international best practice, which is counter productive, a waste of money, and potentially dangerous. In revising the manual, the NTA must attend to the best international examples of cycle design, and not try to reinvent the wheel such as with junctions, which the NTA seems to be opposed to for no good reason: https://irishcycle.com/2021/03/09/dublin-style/

Dublin is also covered in substandard cycle lanes, which are not wide enough for cargo bikes, or for 2 people cycling alongside - if we want to make cycling attractive, we need to make it as comfortable and social as driving a car, where two people can talk while the vehicle moves. Some of them are too narrow for cargo bikes, trikes or for people to cycle beside their child - a minimum width needs to be respected throughout. 

11.5 Cycle Parking

 

There is no mapping of secure cycle parking anywhere in the document, or any number identified (it just mentions ‘ more bike parking’). This is a very vague goal for something that could be crucial for the city, as a lot of people fear their bike will be stolen if they cycle. Identifying locations for safe cycle parking is necessary and should be included in the document, including adapted bikes, cargo bikes and electric bikes. On those, it would be essential to have protected, camera enforced safe parking so that longer bicycle trips (over 10km) can be encouraged. 

 

11.7 Bikes on Public Transport

"As such, all Irish Rail services using newly procured fleet, including new DART fleet, will accommodate a minimum of 4 bicycles per train, in addition to an unlimited number of folding bikes." If we really want to encourage multi modal shift (i.e. train + bike for commuting or for greenways), we need to increase this and have 4 bicycles / carriage and not by train. 

The NTA states the Luas is “unsuited for carriage of standard bicycles on board”. There is no explanation on why that is? These trams are the same design as the ones used in Strasbourg, and the city of Strasbourg has dedicated spaces in their trams for bikes. 

 

13. Road

13.2 Principles for Road Development

 

MEASURE ROAD1

 

“5. That where a road scheme comprises an urban bypass, measures must be proposed and implemented to reallocate road space within the bypassed area to sustainable transport and/or public realm improvements;”

This statement should be strengthened. It is well established that bypasses which do not actively prevent through-traffic on the bypassed street simply increase the overall road capacity and lead to more congestion. Therefore, this point should be amended to require that bypassed routes in villages, towns and cities are made impermeable to motor vehicles (except in certain circumstances, e.g. bus gates for public transport) as a condition of the construction of the bypass.

 

13.3.2 National Roads Projects

 

If the primary objective/function in relation to national roads is to protect the role of strategic traffic, then road-pricing and public transport upgrades should be the measures prioritised to reduce congestion and improve the flow of strategic traffic. 

 

There is an ongoing trend of pushing through road upgrades under the guise of sustainable transport that needs to end (e.g. Snugborough Road upgrade). There is general agreement in the literature that to reduce the modal share of cars, a carrot AND stick approach must be taken; a carrot-only or ‘one for everybody in the audience’ type approach whereby extra lanes are slipped in alongside bus lanes does not work. Modal shift will not be achieved as long as the attractiveness of driving remains untouched.

 

A case in point: section 13.5, MEASURE ROAD 9 - Regional and Local Roads Policy states:

 

“Enhance orbital movement between the N3, the N4 and N7 national roads, by the widening of existing roads and/or the development of new road links, for the purpose of providing resilience to the operation of the M50 and incorporating provision for sustainable transport;”

 

Will these new roads have bus gates so that they can only be used for public transport and local trips? If so, there doesn’t seem to be any mention of it. Otherwise, these roads will increase car-use, congestion, car-dependency and emissions; business as usual rebranded with terms like ‘enhance’ (increase capacity), ‘provide resilience’ (increase congestion), and co-opting the language of sustainability.

 

 

17. Strategy Outcomes

17.2.6 Noise

The number of goods vehicles travelling in the GDA is expected to increase as a result of growth over the period of the strategy. While this may lead to some localised impacts in terms of increased noise, it is forecast – in line with policies and objectives related to the management of Heavy Goods Vehicles – that these adverse effects would arise primarily on the national and strategic road network, rather than on local roads and as such, would not lead to a significant increase in the population exposure to high noise levels’. 

This is an extraordinary statement. Many people live by major roads, including people living within the canals. The communities in the Dublin 7 areas live by primary / national roads - Phibsborough road, Botanic, North Circular road, Cabra road, Manor st etc. People living along these main arteries (in their 10s of thousands) are impacted very adversely by heavy traffic already, and are exposed to noise levels 5 times the recommended WHO levels every day, 20 hours + a day. How many people is acceptable for the NTA to expose to even higher levels of noise? Has the NTA studied the effects of high levels of noise on people? The latest studies show a direct link between noise and hypertension, heart disease, dementia etc. There is no

number attached to how many people will be affected, just a generalisation. This is unacceptable, and metrics around noise need to be attached, and the goal to radically diminish those. If people live beside roads, it is the NTA’s responsibility to ensure noise + air pollution are dealt with by ensuring traffic levels go down - people’s health should not be treated as collateral damage. 
 

17.2.7 Mode Share

We would humbly suggest that the mode share targets, which include a reduction of car use of 9.1% across the GDA region and 10.5% for Dublin Metro, are not compatible with national climate emissions targets. Achieving modal shift in the more peripheral regions of the GDA is a daunting challenge, so the targets for Dublin Metro need to be much greater to compensate.

Targeting an 18% reduction on 2016 levels in commuter vehicle kilometres also seems like an extremely unambitious target given the changes to remote-working that are already baked in since then.

 

Faisnéis

Uimhir Thagarta Uathúil: 
NTA-C5-799
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
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