Key considerations
Climate
While the 2021 Climate Act sets a legally binding target of 51% reduction in emissions this decade, we believe this should be regarded as the floor of our ambition, rather than the ceiling. Transport has a critical role to play, particularly in Dublin where there are more alternatives to the private car available. Investments in public transport infrastructure necessarily take time to yield benefits and given the increasing urgency of our climate response, we must look to bring these investments forward so that they their impact on reducing emissions begins sooner and last longer.
We believe 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.
Furthermore, while the strategy states: “Fundamental changes are required in the area of transport over the next decade. Central to those changes will be the need to increase the proportion of travel by sustainable modes and reduce the level of usage of petrol/diesel powered vehicles”, the strategy overall does not appear to take into account the specific need to halve emissions by 2030. The 2022 to 2030 phase of the strategy is not nearly ambitious enough; and many key projects are not earmarked for delivery until 2040 or beyond.
The strategy further states: “This Transport Strategy is also based on national policies on sustainability including those set out in climate action and low carbon legislation, and in climate action plans”, BUT the timeline has too many projects earmarked for delivery decades from now, and crucially with the last decade before Ireland reaches net zero, allowing no time for behaviour change and / or unforeseen delays. For Dublin to play do its fair share in reducing transport emissions, it simply has to happen faster. Additionally:
- The plan needs to be updated to reference the Climate Action Plan 2021, the New National Development Plan 2021 to 2030 and Housing for All.
- Clear modal shift targets need to be set out as part of the plan if we are to reach our climate emissions targets for 2030 and 2050.
- A core focus of the strategy must be on the reallocation of road space to walking, cycling, e mobility and public transport, with specific targets set out.
- The strategy must set out a very clear roadmap as to how this plan will help to reach our 2030 and 2050 climate targets, and set out a year by year path to decarbonisation. The decade ahead is critical and the success or otherwise of the measures in this strategy must be assessed on a continual basis if they are to achieve the desired results. This must be done with a willingness to alter the plan if we fall behind on our path to decarbonisation.
- Another flaw in the strategy is that it only counts emissions at the tailpipe rather than accounting for the total emissions involved in the construction and end of life of the vehicles.
Covid 19
It is vital that the NTA considers the profound impact that the Covid-19 crisis has had on our lives, our communities and how we live and work. While might well see a return to full-capacity on our public transport infrastructure one day, some societal shifts are likely to have longer-lasting impacts on how and when we travel into the city centre.
The overarching design of this strategy is predicated on the need to move large numbers of people quickly and efficiently from an outer radius of Dublin into the city centre, but it’s important to note that the shift to remote working will become permanent for many workers, and so too will the move to online retail.
We also must acknowledge that a connected city requires a network of transport options that move people around as well as to the city. It is a stated objective of the plan that it achieves “Connected Communities and Better Quality of Life - To enhance the health and quality of life of our society by improving connectivity between people and places, delivering safe and integrated transport options, and increasing opportunities for walking and cycling.
However, it doesn’t seem to acknowledge the need for communities and suburbs to connect to other communities and suburbs. Our city centre may well need to recalibrate to adapt to changing patterns, and so too this strategy should be future-proofed to reflect the latest information available on travel and lifestyle patterns – particularly with regard to census information.