INTRODUCTION

We are writing to you on behalf of the Fingal Cycling Campaign a subgroup of the Dublin Cycling Campaign which has been advocating for improved cycling infrastructure for Dublin for 26 years and a registered charity #20102029. Dublin Cycling Campaign is a member of Cyclist.ie (www.cyclist.ie), the Irish Cycling Advocacy Network, is the network in Ireland of Cycle Campaign, Bike Festival, and Greenway Groups, and is the Irish member of the European Cyclists’ Federation (www.ecf.com). We want to make Fingal a safe and friendly place for everyone, of all ages, to cycle and walk. Dublin and Fingal Cycling Campaign welcome Fingal County Council’s intent to improve walking and cycling infrastructure

We would hope that Irish Rail takes into consideration our recommendations as suggested below. As referenced in the consultation documents Option 2, Option 4 & 4a, Option 4 & 4b and Option 6 go forward to Phase 2. We will concentrate on Option 2, 4, 4a and 4b only

**GENERAL COMMENTS ** There are pros and cons for use of either an underpass or a bridge. Fingal Cycling Campaign is recommending an underpass is the preferred option. The benefits of an underpass are that it’s protected from the elements such as wind and rain and cyclists don’t have to deal with incline to cycle over the royal canal. The descent should also benefit cyclists in building momentum coming from south to North and overcoming the incline on the North side of the canal. There is a shorter descent from North to South and a 450 meter incline. This will be important and so the gradient should be less than 1:20 (1:5 and even 1:3.5). We have referenced both the Irish guidelines which are limited in their scope for design standards in APPENDIX I and Dutch design standards which have more comprehensive examples in dealing with similar complex junctions in APPENDIX II. We would recommend Irish Rail consider the best practice and design standards from the Dutch design standards as they are the leaders in cycling infrastructure design.

The main issues with design of tunnels/underpass and bridges for cyclists and pedestrians are Lighting gradients (<1:20) Safety (especially at night time for women) Line of sight Segregation Noise
Priority CCTV Passive surveillance Active surveillance by An Garda Siochana

**SPECIFIC COMMENTS **

Fingal Cycling Campaign supports Option 2 in combination with either Option 4a or Option 4b in order to support cycling and walking of all ages and abilities. Option 2 and 4a underpasses supports cycling and walking for people who are less abled to deal with the incline crossing the cycling and walking bridge as shown in 4b. The issue of safety, especially women and girls, will not use an unsafe location. We can see this already from the new section of the Royal Canal (near Guild Street/Newcomen Bridge) and at sections along the Grand Canal (near Bluebell/Inchicore) Option 2 will have a segregated cycle lane and it will be sharing the space in the underpass which can make it very loud in the underpass. Will there be options to reduce noise in the underpass as it is quite a long section of the underpass? Option 2 has 4 junctions with large entrance and egress points along its route so cyclists will lose priority and they will have to deal with crossing dangerous junctions moving in and out into the main lane of traffic. Will there be Toucan crossing at these junctions along the route of Option 2? This will make this option less attractive for cycling and walking. This is why we are requesting a separation of cycling and walking from Option 2. It is unlikely that Option 4a is compatible with Option 2 so we would defer to Option 2 in combination with Option 4? Is there a possibility of doing an improved design? . There is no mention of the incline and decline gradients on approach and exit to Option 2. The CROW design standards ( https://crowplatform.com/ ) recommends a gradient of less than 1:20. There should be a right first time approach to this design and a great opportunity to design a good tunnel in Ireland for cyclists and pedestrians. It was disappointing to see that the pedestrian and cycle counts were only done on one day on 5th February 2019 compared to three weeks of surveys for vehicle traffic. Could this have biased Irish Rail view on how many cyclists and pedestrians are using these level crossing and therefore not provided for high quality designs. See Appendix III It will be important to have a high quality crossing for pedestrians and cyclists in order to connect to the Phoenix Park from the Royal canal and the new Hamilton way that is currently out to consultation now. https://www.dunsink.dias.ie/hamiltonway/ See Appendix IV with image of proposed greenway The NTA have also mentioned (Page 29/144) in their report that that Option 2 will result in increases in journey times and travel distances for people living and working in the Ashtown Village/Scribblestown Road or Ashtown Road/Mill Lane areas could be significant. Given the local severance that will be caused, the provision of a pedestrian bridge over the rail line should be examined if the level crossing is to be closed. In Utrecht, Netherlands there are examples of combined traffic and cycle underpasses that the cycle track doesn’t go as far down as the traffic lane. People on bikes aren’t as tall as buses/HGVs and don’t need the same clearance. It means that the ramps on either side can be less steep, which makes it easier to cycle through. Could this be considered for Option 2 as it will remove the issue with gradients on both North and South sides of the underpass. Example in attached submission.

Please also refer to Cllr David Healy from Fingal County Council study tour of the Netherlands. He references some good examples of underpass design standards

http://davidhealy.dublin13.com/wp-content/uploads/2017/09/Report-from-Ve…

**CONCLUSION **

Fingal Cycling Campaign welcomes the DART+ West plans. We are excited to see the plans put forward by Irish Rail. We have some concerns around the design standards that will be used. The current Irish design standards are not of a high quality and lack detail. We would recommend Irish rail take on board our points referenced and refer to the Dutch design standards for best practice that will help cycling for all ages and abilities. If a totally separate cycling and pedestrian underpass is not possible such as Option 4a we would suggest that Option 2 is altered to take into account a cycle lane that can be modified to remove any gradient issues with Option 2. We look forward to working with you on the other level crossing west of Ashtown.

See Irish Rail website for more details: https://www.irishrail.ie/about-us/iarnrod-eireann-projects-and-investmen…