Core Bus Corridors Public Consultation Stage 1 Phase 3
Here follows the submission we made on the Third phase of the Core Bus Corridors Project, May 31st 2019
This has been submitted as part of Phase 3 but, unless otherwise stated, the following can be considered as network wide and applied to all of the proposed corridors.
Dublin Commuter Coalition is a group advocating for public transport users, cyclists and pedestrians in the Greater Dublin Area. We represent hundreds of people who have joined
our campaign to advocate for better public transport, cycling and pedestrian infrastructure.
We are in favour of BusConnects as a project to vastly improve the bus network in Dublin and the allocation of widespread cycling infrastructure throughout the city.
What follows are some of the issues we have with the Bus Connects proposals.
The Hierarchy of Road Use
We follow the hierarchy of road use, which advises that in the allocation of space in the public realm, consideration should be given in the following order:
Able Bodied Pedestrians
Cyclists and Scooters
Private Hire and Delivery Vehicles
Private Motor Vehicles
In this vein, throughout the entire BusConnects project, footpaths and cycle paths should be the priority in the allocation of road space. Following this, allocation given to bus lanes or other bus priority measures with general traffic lanes being provided where possible after the other elements have been provided. This hierarchy, more than any other area, should be aggressively followed in the city centre where the overwhelming majority of movements are made on foot, by bike or by public transport. Maintaining dual lanes in one direction for general traffic at the expense of wide footpaths, wide cycle lanes and public transport infrastructure is unacceptable. The plans available from BusConnects seem to aim to maintain as much of the current road layout as possible, adding bus lanes and then squeezing in footpaths and cycle lanes. This is a backwards approach and more courage is needed in removing space for private motor vehicles where keeping them impacts adversely on the majority of other users of the public realm.
Road Widening and Tree Felling
Where required there may be no question that roads require widening and tree felling. Dublin Commuter Coalition fundamentally believes that the issue of Compulsory Purchase Orders on gardens and private lands is an issue for the landowner and the NTA and is none of our business. However, as discussed previously, we fundamentally disagree with widening roads to maintain access for the private motor vehicle when other solutions exist, including bus gates, local access roads and one way systems. These proposals should be used before the use of road widening is implemented.
The felling of trees, especially mature trees should be avoided at all costs. But, again, attempts to keep trees by squeezing space for pedestrians and cyclists is a backwards approach. Pedestrians and cyclists deserve more space than currently and attempts to further reduce their allocation of road space should be harshly rejected, the first casualty should always be the private motor vehicle.
The Bus Connects Information Documents state that a Tree Replanting Scheme will follow any tree felling, we would advise that in the detailed design stage plans that include the allocation of trees be protected as unquestionable elements of the design as, as we have seen from Molesworth Street in the city centre the actual number of trees planted was much lower than originally allocated.
Parking Spaces and Loading Bays
To maintain accessibility for people with reduced mobility or reduced sight, buses must be able to merge with the kerb to allow the safe and consistent deployment of the wheelchair ramp and to give people with reduced sight the confidence to board a bus without having to step onto the road.
Parking spaces and loading bays being placed ahead of Bus Stops creates a limitation for buses to merge with the kerb effectively. Buses must be given adequate space in the lead up to a bus stop to allow the bus to merge. Parking and loading bays should only be positioned immediately after the bus stop area.
Floating Bus Stops
Dublin Commuter Coalition respects the need for people with reduced mobility and sight to be able to use footpaths without the need to share space with cyclists and/or cars. The use of floating bus stops is important to remove cyclists from the highway when a bus stops. However, every effort must be made to show a clear distinction between the footpath and cyclepath, this carries for the entire network but particularly where pedestrians must cross a cycle path. Coloured tarmac should be used to show the distinction and priority must remain with the pedestrian. Adequate signage should not only be provided but designed to an extremely high quality where there is no ambiguity as to who must yield and who has right of way. Green barriers made of plants may be an idea to clearly show where the crossing should be made. Leading to a heightened awareness for both the pedestrian and the cyclist.
Floating Bus Stops wherever possible
In situations where there is no room for a dedicated cycle path and car traffic cannot be removed, where possible floating bus stops should still be provided for cyclists using bus lanes. The locations of bus stops along routes should tie into this consideration, a rare wide section of an otherwise narrow road is the ideal location for a bus stop to be located, for the sake of pedestrians waiting for the bus, pedestrians passing the bus stop (eliminating the need to navigate a large crowd) and for the sake of cyclist safety.
Detouring cyclists away from the direct route for the benefit of public transport or private cars goes against the Hierarchy of Road Use.
We fundamentally disagree with any attempt at any point on the Network that cyclists should be detoured to remain safe. We believe that the detour should be for cars as, as mechanically propelled vehicles with near unlimited freedom of mobility, the inconvenience for them is minimal. Car traffic should be removed as a first step. Not cyclists.
However, where a route is not feasible or safe for cyclists and there is no way to remove car traffic, the detoured routes down “quiet roads” must be upgraded to make it safe for cyclists of all abilities. Filtering should be used to make sure these roads are truly quiet and not merely a road not as busy as the main routes into the city. The current provisions for the cycling detour around Phibsborough do not even as much as show road resurfacing on the local surfaces in Royal Canal Bank. When this route then meets the North Circular Road, cyclists must then use the footpath and pelican crossing to move across the road to the continuation of their detour along Royal Canal Park. We would propose a diagonal separated intersection with the same level of importance as the cars using the North Circular Road and a pedestrian crossing over same. As we understand, commitment has been made for an underpass of this road. We would encourage that too.
Ultimately, if cyclists MUST be detoured they should be afforded expansive and high quality infrastructure beyond simply telling them to follow signs down a smaller road.
Cycling Infrastructure beyond Finglas Village
Bus Connects is marketed as a Bus Lane and Cycle Lane improvement scheme. The scheme is the perfect opportunity to expand cycling infrastructure across the entire city. However, in some instances cycling is simply ignored. From Finglas Village to Charlestown, the end of the proposed corridor, the bus lanes continue on the bypass but cycling infrastructure is nowhere to be found. Even an effort to suggest an alternative quietway, as is present in the rest of the plan, is not made. As mentioned previously, quietways should not merely be suggestions to use other roads to avoid narrow roads to the benefit of motorised traffic, but given due upgrades to make them suitable to cycling. But the decision to simply disregard cyclists who live north of Finglas Village is unacceptable. There is ample space for the provision of a bidirectional cycle path through Mellowes Park. This corridor should be re-examined to see how cycling can be accommodated between Charlestown and Finglas Village
Fully Segregated Junctions
Areas designated as “shared space” where cyclists and pedestrians are forced to mix is unacceptable. Cyclists on the footpath present a danger to pedestrians, particularly vulnerable pedestrians, including children, the elderly and people with reduced sight or mobility.
Every possible measure should be made to make sure that shared space is not something that will be present on the finished network, whether that is taking space from bus lanes or car traffic. Asking pedestrians to share space with cyclists, unless grade separated or barriered off, is unacceptably unsafe. Dutch Style junctions that follow the National Cycle Manual are always going to be the appropriate solution, anything else is another attempt to appease the private motor vehicle at the expense of other vulnerable road users.
Bus Stop Design
The Bus Stop box on the road should be placed in such a way that the Bus Stop Flag is at the head of the box, or so that the far end of the bus shelter aligns with the end of the box. Further, drivers should be trained to align the front of the bus with the front of this box as much as is possible. This will enable bus users to position themselves where the door is due to open, allowing queuing systems to make sense. So that when users queue at the stop, the person at the front can board first, instead of the door opening in the middle of the queue, creating a crush. Bus Stops should include markers to show where users should queue from. This will enable quicker boarding, leading to better journey times.
Many instances on the network show Bus Lanes becoming filter lanes for left turns or cycle lanes being jettisoned to accommodate right turn lanes. Filter lanes encourage car use by providing more space to increase the mobility of the car user to the detriment of other road users. From a traffic planning standpoint they make sense but should not be used where space is limited. All traffic should remain in the lane it is given and wait until the car ahead has made its turn. If this wait time becomes unwieldy, the turn should be banned.
Further, where a bus lane crosses a junction, the head of the lane is turned into filter left turn lane. This leads to cars entering the bus lane 100s of meters ahead of where the road markings permit them. Therefore it is suggested that bus lanes be bollarded off at the approach to a left turn filter lane, to stop cars using them before they are permitted.
Road Colour Design
The preliminary maps for BusConnects show the Bus Lanes in blue. This is done to distinguish them from traffic lanes. But in practice bus lanes and traffic lanes are the same colour. Cycle lanes sometimes are and sometimes aren’t differentiated by colour. This leads to pedestrians wandering into them as an extension of the footpath, and leads to cars creeping into them as an extension of the road.
We believe cycle lanes and bus lanes should be coloured if possible to instill in the public's eye their complete distinction from regular traffic lanes and footpaths. This is especially necessary at complex junctions like Hart’s Corner where bus lanes start and stop a lot. A distinct coloured road surface would leave little ambiguity as to the appropriate lane for traffic to be in as they navigate a junction.
We understand the complexities that go into the management of traffic, buses, cyclists and pedestrians at complex junctions. However, in the city centre, we believe that just as much effort should be made to encourage people to walk part of their journey and one of the biggest barriers to comfortable walking is the expectation to wait several times on islands in the middle of traffic to be able to complete a crossing of a junction.
Wherever possible junctions should encourage simultaneous phasing for pedestrians, include diagonal crossings, discourage the use of pedestrian islands and include pedestrian crossings on all arms of the junction. For example, although this phase of the consultation has been completed, the junction of Drumcondra Road Upper, Swords Road and Griffith Avenue is a 4 arm junction with pedestrian crossing provision only present on 3 of the arms. Each arm has an island, splitting the crossing into two phases. So if someone is walking on the southern side of Griffith Avenue looking to cross the junction and continue to the southern side of Griffith Avenue, pedestrian infrastructure asks that they make 6 crossings and wait for 6 light changes to safely cross the road. This is a barrier to walking and cannot be allowed in the design of junctions and pedestrian crossings.
In the city centre, the number of pedestrians vastly eclipses the number of cars, therefore every provision should be given to moving as many pedestrians as possible as quickly as possible through the city centre. We believe this is possible with increased diagonal crossings and simultaneous signalling and removing necessary stoppages in crossing a junction by providing islands.
Use of Bus Lanes by Taxis
Bus Lanes are by definition to be used by buses to maximise the number of people that can be moved. Allowing taxis to use these lanes goes against this idea. Taxis using lanes at peak times can create queues at junctions that are just as long as the private car lane.
Whether it’s peak time bans or bans within the Canal Cordon, something must be done to remove the number of single occupancy vehicles from bus lanes
DUBLIN COMMUTER COALITION