We warmly welcome the NTA’s Cycle Network Plan and support its early implementation. The approach to developing the plan is methodical, clear and comprehensive, and the authors have considered a wide range of options for cycle routes. However, no network on its own will instigate the 10% National modal share target, which effectively translates into a 20% modal share target for Dublin. Cyclists will still have to share road space with motorised vehicles at local level, where urgent improvements are needed. ‘Soft’ measures must still be given high priority.

The full submission made by the cycling campaign on the NTA’s draft Cycle Network Plan for the Greater Dublin Area is available below.

• We welcome the considerable effort to improve provision for cyclists which has evidently been taken in the preparation of this document.
• The Plan is consistent across local authority and county borders, which is to be commended.
• The objective assessment of quality of cycle journeys, following on from the work done for the National Cycle Manual, is commendable. We agree with the suggested A/A+ level of service recommended for all cycle routes above 500 cyclists in peak period, and for a minimum B standard for all routes regardless of numbers. These minimum targets must be recognised into the future. We do note though some issues with regard to the basis of the Quality of Service measurement – as described below.
• The Campaign warmly welcomes the recognition given to the benefits of removing one-way street restrictions. The multi-lane, one-way ‘Formula One’ system in central Dublin is the scourge of cyclists. We are particularly happy with the recommendation for ‘provision of contra-flow cycle routes on all one way streets where these would provide for shorter cycling trip lengths’. This issue has been under ongoing discussion between Dublin Cycling Campaign and Dublin City Council and must, with the Luas works now in full swing, be acted on with urgency.
• Suggestions for permeability of some city blocks are also welcome. We note below the implications of the recent NTA proposals for general traffic management in central Dublin.
• We also welcome the exploration of alternative route options and the suggested use of public spaces, and ‘permeability’ points, to improve the cycling journey and create relatively traffic-free journey options for cyclists. This also includes the proposals for a number of bridges and/or underpasses at different locations
• The inclusion of suggested greenway routes throughout the city, e.g. the Dodder, Poddle and Tymon Park Greenways will benefit both utility and leisure cyclists.
• The measurement and prediction of cycling trips and preparation of trip model, though long overdue, is to be welcomed.
• The mentioning of a floating bridge for cyclists (page 47) shows a very welcome openness to creative ideas.

We are aware that implementation of the Cycle Network Plan falls to the local authorities, but would submit that the Authority has the expertise, and perhaps a responsibility, to prioritise the most urgent and beneficial portions of the Network.

The Cycle Network Plan’s place in NTA’s role of cycling promotion

Bearing in mind that the NTA’s own Implementation Plan allocates €65m to fund both ‘integration of all transport modes’ and ‘provision of sustainable transport’, the concern arises that the emphasis on creating physical infrastructure is too great. A clear, evidence-based ‘Hierarchy of Measures’ for promoting cycling is set out in the National Cycle Policy Framework; it places more emphasis on the likes of cycling promotion, lower speed limits, HGV strategies, road pricing or congestion charges, and cycle skills training.

The 2008 Act lists the NTA’s objective at 10 (e) of seeking ‘increased recourse to cycling and walking as means of transport’. We would contend that, while we welcome the Plan, the ‘soft’ measures advanced by the NCPF must form a large part of the work towards that objective and must not be given lower priority than engineering works. In particular we feel that the following need to be urgently addressed:

Public education on sharing road space safely and understanding the needs of other road users, including the 1.5m clearance message for motorists overtaking cyclists (see Figure 1 below). Cycle skills training for school-goers including competence in traffic environments Promotion of the benefits of cycling and increased cycling numbers for the individual and for society Enforcement of parking regulations, particularly on cycle-lanes, and greater efforts by Gardaí to prevent endangerment of cyclists by drivers of motorised vehicles. All professional drivers to undergo assessment for Certificate of Professional Competence (CPC) that deals with safe interaction with cyclists (taxi drivers must be brought into the CPC system as a matter of urgency).

While we welcome the proposals for the Cycle Network subject to these comments, we feel it must make clear its own place as part of a hierarchy of measures aimed at promoting cycling, and bring those measures to bear on each of its proposals and conclusions. We would like to see detailed cost/benefit analysis of those measures compared with the construction of physical infrastructure.

We must reiterate that no network on its own will instigate the 10% National modal share target, which effectively translates into a 20% modal share target for Dublin. Cyclists will still have to share road space with motorised vehicles at local level, where urgent improvements are needed. ‘Soft’ measures must still be given high priority.

We are disappointed that there is no specific reference in the conclusions to suggested priorities, or, at the very least, a prioritisation tool for investment. While reference can be made to the 2021 projected levels, we suggest that specific main priorities should be clearly outlined to guide decision makers.

Of critical importance to the rollout of any agreed Cycle Network are the ongoing staffing levels and the requisite funding. These need to be referenced in the study, particularly in the context of continued staff retirements and budget cuts. In the UK many cycle schemes are co-funded by the NHS, in recognition of the health benefits that cycling brings. There is a need to establish this potential funding link, here in Ireland, to support the Cycle Network rollout.