This submission of Dublin Commuter Coalition in response to the Draft Transport Strategy for the Greater Dublin Area was sent to the National Transport Authority on 10 January 2022.
Introduction
Dublin Commuter Coalition was established in 2018 as a voluntary advocacy group for public transport users, cyclists, and pedestrians in Dublin and surrounding counties. The Coalition acts as a unifying voice for commuters in these areas so that they may express their concerns, their hopes, and their vision of a Dublin that works for all users of sustainable transport. As such, we read the Draft Transport Strategy for the Greater Dublin Area 2022-2042 with interest, and many members of the Coalition also attended the information sessions held. Unfortunately, we think that this Draft Transport Strategy is not nearly ambitious enough.
While we outline specific views on different sections below, two of the most pressing issues with the Draft Transport Strategy are the slow, unclear, or delayed timelines given for the delivery of the proposed infrastructure projects, and the removal of other crucial projects such as DART+ Tunnel and Metro South.
Dublin is a key European capital city but it suffers from decades of underinvestment in sustainable mobility. Our public transport network is well behind those of our European peers, and in the face of a climate crisis there has never been a more important time to change that. The current Draft Transport Strategy is simply not sufficient to achieve this change, and unless the Transport Strategy is made radically more ambitious, Dublin will continue to fall behind both the rest of the world and its climate targets.
We have had successive transport strategies from Transport 21 (2005), through the Greater Dublin Area Draft Transport Strategy 2011-2030 (2011), the Transport Strategy for the Greater Dublin Area 2016 – 2035 (2016), and now this. The current Draft Transport Strategy is one of the least ambitious, and marks a step down in ambition from the 2016 strategy. In particular in terms of scope and timeline, the current Draft Transport Strategy is extremely disappointing when compared to the ambition in the long-abandoned Transport 21 strategy. It is important to acknowledge that transport planning in the Greater Dublin Area has been a failure in recent decades.
Metro
MetroLink
Of all the proposed public transport projects, MetroLink is the most important. This is a landmark investment in sustainable transport infrastructure, and will set the benchmark for other major infrastructure projects in Ireland in following decades. Unfortunately, the proposed timeline for MetroLink is much too long. The timelines given in the Draft Transport Strategy lack ambition. We appreciate that the Draft Transport Strategy does not propose any extension of this timeline beyond the delays that have already happened within the project, but what is needed is positive change to accelerate the delivery of MetroLink. We would like to see a commitment and clear plans in the Transport Strategy for moving forward more quickly with MetroLink. The National Transport Authority and all other stakeholders involved need to be focused on delivering MetroLink ahead of current timing expectations, as an example of Ireland’s commitment to sustainable development, and willingness and ability to deliver world-class projects of this nature.
There have been proposals for a metro line to North Dublin and Swords (in various forms) for more than two decades, and a further, more than decade-long wait until MetroLink is opened is not acceptable. We acknowledge that a number of macroeconomic factors have disrupted these plans over the years, but now is the time to pick up the pace and see the project through to completion ahead of schedule. We call on the NTA to work with other stakeholders to investigate how the currently proposed timing for MetroLink can be accelerated. We acknowledge that this is a major project and that a timeline of years is to be expected, but there is certainly room for improvement in the current proposal.
Metro South
Metro South was included in the 2016-2035 Transport Strategy, with delivery expected ahead of the Bray, Lucan and Finglas Luas lines.[1] However, it is not included at all in the current Draft Transport Strategy, and the idea of a further metro gets barely a passing mention in a reference to “any potential future metro extensions to serve the south west, south or south east of the city region should sufficient demand arise”.[2] We acknowledge that the decision to postpone Metro South was made before the current Draft Transport Strategy. Regardless of this, Metro South needs to be re-included the Transport Strategy and prioritised by the NTA.
We also acknowledge the proposed upgrades to the Luas Green line (Measure LRT8 in the Draft Transport Strategy) as an alternative to reaching a metro standard, however these are not a sufficient substitute for Metro South. Projects of this kind do not get cheaper over time. This has been clearly demonstrated by the rising cost of MetroLink. Even if it is included in the Transport Strategy, it will be many years before Metro South is operational. Treating this as a potential future project “should sufficient demand arise” ignores the reality that the Green Luas is already under pressure, and that fast, efficient public transport measures naturally increase demand in the areas they serve. In addition, the high volume of housing being developed at Cherrywood, Sandyford, and elsewhere on the Luas Green line will only lead to increased demand in coming years (likely on a much shorter timeline than the delivery of Metro South). If Metro South is not included in the Transport Strategy now, it is inevitable that demand will outstrip the capacity of the network before the project is even close to completion. Given the existing Luas Green line infrastructure which can be updated to Metro standard, Metro South is a highly cost-effective measure to provide much-needed world-class public transport infrastructure to Dublin. In addition, there will no doubt be efficiencies in progressing Metro South at the same time as MetroLink.
Luas
The proposed timing for all the Luas projects is disappointing and unambitious. The 2016-2035 Transport Strategy envisaged the Finglas, Poolbeg, and Bray Luas projects being completed by 2035.[3] That was already not ambitious enough in our view. The current Draft Transport Strategy contemplates completion of these projects by 2042, which is a step backwards and is not in keeping with the Government’s stated transport- and climate change-related priorities. At a minimum, we ask that all of these projects are delivered by the timelines proposed in 2016 (i.e. by 2035). We do, however, think that there is significant potential for them to be delivered soon.
Luas Finglas
This is a short and simple extension in the context of much more complicated Luas extension projects that have been completed in Dublin since 2004. There’s no reason why it couldn’t be finished before 2030. We acknowledge that this is being progressed with the recent publication of the Preferred Route, and we ask that this work continue on a more ambitious timescale as the design process is now expected to take almost four years.
Luas Lucan
The Draft Transport Strategy acknowledges that a Luas connection to Lucan is needed. This project will require extensive design and planning, and should be progressed as quickly as possible. We ask that the Transport Strategy commit to holding a public consultation in early 2022, and that clear timelines for the delivery of this Luas connection are included in the Transport Strategy.
Luas Bray
Similarly, we would like to see planning and design for this short extension begin as soon as possible. This project was also already planned to be finished by 2035 in the 2016 Transport Strategy and any delays to that timeline would be unacceptable.
Luas Poolbeg
The 2016-2035 Transport Strategy envisaged the Luas Poolbeg extension being completed by 2035.[4] In contrast, the current Draft Transport Strategy does not commit to this project at all, indicating that “it may be necessary to consider delivering Luas to this area during the later periods of the Transport Strategy.”[5] We believe that it is necessary not only to consider this project, but also to implement it before 2035 as originally planned. This is a short extension to an existing line which will bring high-quality public transport to the high-density Poolbeg Strategic Development Zone (SDZ) and its environs. The Luas Poolbeg extension should be progressed now and delivered before the SDZ is finished. We ask that specific timelines for the implementation and completion of this project be included in the Transport Strategy, and that the completion be no later than the previous timeline of 2035.
Other Luas lines
The Draft Transport Strategy envisages 8 further Luas lines or extensions to be delivered after 2042. Given how long projects of this kind take and the desperate need for a more robust light rail system in Dublin, we call for the Transport Strategy to commit to progressing all 8 lines or extensions by 2042. In particular, we ask that the NTA progress the following Luas projects with a matter of urgency:
City Centre to Clongriffin
City Centre to Blanchardstown;
Green Line Reconfiguration to provide the following lines:
City Centre to Bray via UCD and Sandyford; and
Sandyford to City Centre
In our view these projects are the most important and readily achievable of the 8 listed post-2042 Luas projects listed in the Draft Transport Strategy, and should be moved forward in the Transport Strategy.
Orbital Luas
The Draft Transport Strategy does not commit to an orbital Luas, leaving this to be “monitored as part of the periodic review of the Transport Strategy”.[6] We call for orbital Luas to be prioritised as part of the Transport Strategy, to increase connectedness between the outer areas of Dublin and between the proposed additional Luas routes/extensions. The orbital Luas should be developed from the work that was done on the historically proposed Metro West between 2001 and 2008.[7]
Heavy Rail
DART+ Tunnel
The need to create a new cross-city rail corridor was identified at least fifty years ago. More recently, DART Underground was a key project under Transport 21 and the 2011 and 2016 Greater Dublin Area Transport Strategies. Dublin’s population and transport demand has continued to increase since and the need for such a rail link serving popular destinations in the city centre is higher than ever. We strongly dispute the modelling which claims that DART+ Tunnel would only attract a small number of new public transport. Furthermore, the ease and convenience that DART+ Tunnel would provide would improve the journeys and livelihoods of tens of thousands of existing public transport users every day. It is unfathomable that the NTA would seek to shelve such an important project for another 20 years.
Navan Rail Line
The commitment to rebuild the Navan rail line is one of the few positives in the Draft Transport Strategy. We strongly reccomend that the NTA choose Option B from the Navan Rail Assessment Report due to its higher catchment area in the Dunshaughlin area and the opportunities it creates for population growth in Dunshaughlin.
However, once again, we are disappointed with the lack of a detailed timeline for construction. Planning for this much needed line to serve Navan and Dunshaughlin should begin as soon as possible. The Navan Rail Assessment Report supports our view that this project can be delivered by 2029 and we strongly believe that the NTA should aim for a 2029 opening. It is also essential to commit to all new commuter lines such as this being electrified from the beginning.
Electrification
It is a non-negotiable that Ireland’s railways have to be completely decarbonised before 2050. While pathways to decarbonisation using hydrogen may exist, there is already an internationally tried-and-tested method of decarbonisation: electrification. Over the last century, Ireland has been a laggard when it comes to electrification of railway lines as demonstrated by the fact that Ireland has the smallest electrified rail network in Europe. Therefore, it’s disappointing to not see a wider plan to electrify all railways in the GDA in this Draft Transport Strategy.
Based on the Draft Transport Strategy, by 2042, the following sections of rail in and around the Greater Dublin Area will remain unelectrified:
Wicklow to Arklow
Naas & Sallins to Monastrevin
Waterford line
Kilcock to Kinnegad
M3 Parkway to Navan
This amounts to almost half of the rail network in the GDA. This low level of electrification proposed by 2042 in the Draft Transport Strategy is at odds with the fact that Dublin-Cork and all the other intercity lines will have to be electrified before 2050. Expansion of electrification in the Greater Dublin Area before 2042 will serve as a starting point for the wider electrification of the rail network. Going forward, we believe that there is a need to disassociate electrification with the DART brand and progress electrification independently of DART to all corners of the GDA.
New Stations
New stations identified in the Draft Transport Strategy must be planned as possible and built in parallel to planned line upgrade related projects such as DART+ West and DART+ South West. The opportunity to deliver Kylemore and Cabra stations alongside DART+ South West was squandered and resulted in an unnecessary loss of trust in the project. Designing and building stations separately after line upgrades is neither efficient nor conducive to gaining local support. We would like to see clearer plans and timelines for building new stations in the final Transport Strategy.
Integration and Inclusion
Children
We were surprised to see that the needs of children are barely addressed in this Draft Transport Strategy, given that they constitute a sizeable proportion of the population of Dublin and have to commute to and from school and recreational activities each day. Because their minds and bodies are still developing, they are disproportionately affected by the car-centric environment of the city. Recent research suggests that they are likely to have worse mental and physical health when exposed to car exhaust and other air pollution.[8] To better address the needs of children, we suggest that the Transport Strategy should include 1) a commitment to work towards a default 30 km/h speed limit for all urban areas in the GDA, 2) clear and detailed plans for how and when safe, segregated cycle lanes to and from all schools in the city will be built, 3) a plan for how the NTA will work with An Garda Síochána to ameliorate the serious problem in this city of parking on footpaths, and 4) a commitment to directly include children and adolescents in all future transport planning, including transport planning boards.
Inclusive Infrastructure
There are three substantive inclusion issues that we would like to see more clearly addressed in the Transport Strategy: 1) safe segregated cycle lane and cycle parking provision, 2) footpath parking, and 3) footpath clutter.
Cycle lane and parking provision
Disabled road users may be using cargo, three-wheel, or other bikes and need space in the cycle lanes to use these. Further, both national and international evidence point to women and children’s hesitancy in cycling outside of segregated bike lanes.[9] We therefore recommend that the Transport Strategy include a commitment to building all future cycle lanes to be 2.5m wide, in line with international best practice, and where possible to having those lanes be segregated. We would also like to see a commitment to building more bike parking spaces, and for those spaces to de facto include parking for multiple types of bicycles.
Footpath parking
Footpath parking disproportionality impacts physically disabled and visually impaired people, who may be prevented from even being able to walk outside their home by inconsiderately parked cars. Carers of children and of those with physical disabilities requiring a wheelchair are being pushed to drive because often it is not possible for them to push a pram or a wheelchair on the footpaths in Dublin. We reiterate here that the Transport Strategy needs to include a commitment to working with other agencies to meaningfully address this problem.
Clutter
Footpaths often feature a dizzying array of signs, poles, and boxes. This disproportionately impacts those with mental and physical disabilities, who may be unable to process the sheer volume of information (largely repetitive and unnecessary in the first place) provided on signs, or whose access to areas may be hindered because of these obstructions. While some infrastructure of course cannot be removed, much of it could be. We call for the Transport Strategy to include a definition of when signage should be used; a specific statement that any new street clutter should not be allowed to impede the flow of traffic on footpaths; and a timeline for the removal of any street clutter which does not meet the definition of a necessary sign and/or which impedes the flow of traffic.
Walking, Accessibility and Public Realm
Footpath Parking
Enforcement of footpath parking is outside the scope of enforcement for the NTA, but we believe that the Transport Strategy should include a statement indicating that footpath parking is a problem which needs to be addressed in Dublin, and providing a plan for how the NTA will work to address this.
Placemaking
The inclusion of placemaking in the Draft Transport Strategy is welcome. We would like to see clearer plans in the Transport Strategy for pedestrianisation of streets within the city and the creation of plazas as public amenities.
Cycling and Personal Mobility Vehicles
Road User Hierarchy
We strongly endorse reallocation of road space to active modes of transport, including cycling. While we are heartened to see that the Draft Transport Strategy includes a discussion of the Road User Hierarchy, we believe that this needs to be strengthened. It is not enough to say that “the design, planning and funding of transport schemes in the GDA, will be guided by the priority afforded to each mode in the Road User Hierarchy”; it is critical to that the Transport Strategy commit that there will be no design, planning, or funding which is not directly underpinned by this hierarchy.
Cohesion
Currently the cycle lane provision appears to be ad hoc and many key routes are unconnected; a detailed plan for future provision is needed. The existing Greater Dublin Area Cycle Network Plan is now nine years old and has delivered very little. This failure can largely be attributed to a lack of pre-defined targets or any sort of timeline. It’s disappointing to see a similar approach taken in the new Dublin Area Cycle Network Plan.
We would like to see specific plans for a safe, integrated, segregated cycling network across the Greater Dublin Area included in the Transport Strategy. This should include maps and timelines of specifically where cycle routes are planned and when they will be delivered, with provision for further cycling infrastructure to be added in addition to the Cycle Network Plan as the need and opportunity arises.
Cross-Liffey Cycle routes
We would like to highlight the removal of a proposed walking/cycling bridge as an extremely retrograde step. There is no walking/cycling bridge between Chapelizod & Lucan, which forces people into cars, causing traffic for everyone. We think renovation of the Farmleigh bridge is of strategic importance, and would like to see the route west of the M50 bridge reinstated.
 |  |  |
Previous plan had a walking/cycling bridge here, just west of M50 road bridge. We request this bridge be reinstated into the plan. | In the new plan, this has sadly been removed. This is a lost opportunity. | Having no walking/cycling options between two of the most populated areas in Dublin is a huge mistake. This increases traffic onto the M50. |
Luas Finglas cycle route
The new Greater Dublin Area Cycle Network Plan omits the Luas Finglas cycle route proposed by TII in the emerging preferred route in 2020. It seems the removal of this cycle route from the preferred route was due to it not being in the Cycle Network Plan. We strongly believe that this is a mistake and should be rectified before the project progresses further. The Cycle Network Plan should not serve to limit the provision of other future cycling infrastructure when opportunities to provide them arises. In this case, the NTA should take the opportunity provided by the Luas Finglas project to include the route in the Cycle Network Plan and aim to construct a high-quality walking and cycling route parallel to the Finglas Luas line.
Bus
Orbital Bus Corridors
We welcome the larger orbital bus corridor network proposed in the Draft Transpor Strategy but would like to stress that their success relies heavily on the level of priority available. We’re also pleased to see the rollout of the orbital routes beginning this month. Considering the fact that there is currently little bus priority on these orbital roads compared to the existing radial roads where QBCs were constructed in the early 2000s, it’s vital that bus priority measures are introduced along these corridors at the earliest opportunity to make orbital bus journeys faster and more reliable.
City Centre Bus Priority
There is a need to increase the level of bus priority available at key city centre streets such as Gardiner Street, Tara Street, Westland Row etc. that do not form part of the Core Bus Corridors project but are critical to the bus network.
Regional Core Bus Corridors
While we support the Regional Core Bus Corridors project, we would like to ensure that these bus corridors are not built through further road widening of dual carriageways and motorways. There is sufficient space available on most of these roads to reallocate road space from private cars towards regional buses.
Traffic Management and Travel Options
We support the introduction of default 30km/h speed limits on urban areas in the GDA and would like to see the NTA work with local authorities across the GDA on its implementation. This approach would make arterial roads with higher speed limits the exception to the rule and would eliminate a lot of street clutter by removing the need for repetitive 30 km/h signs.
Climate Action Management
It is important to note here that while the Climate Action Plan aims to reduce Irish transport emissions by 42-50% by 2030, the bulk of this will have to be carried by reductions in urban transport which will mostly be in the Greater Dublin Area. Therefore, the transport emissions reductions required in the Greater Dublin Area by 2030 will need to be far in excess of 50%. By aiming for a simple 51% reduction in the GDA by 2030, the Draft Transport Strategy is fails to set a suitable target required to achieve a 51% reduction in transport emissions nationwide. It is hard to see how this Draft Transport Strategy could achieve the emissions aims of the Climate Action Plan.
The Draft Transport Strategy states that to achieve a 51% reduction by 2030, a reduction from 3.2 MtCO2eq to 1.6 MtCO2eq would be required. It also recognises that this Draft Transport Strategy is not going to be able to achieve that. It is anticipated that the “likely emissions outturn for the GDA in 2030 will be approximately 2.0 MtCO2eq”. However, the Draft Transport Strategy seems to suggest that the bulk of those reductions will come from the hardly credible plan to increase the number of electric vehicles in the State to 936,000 vehicles by 2030. The Draft Transport Strategy should explicitly state which policy changes are leading to the anticipated 1.2 MtCO2eq reduction in emissions.
Conclusion
As stated repeatedly in our submission, we think the timeline for delivery of projects in the Draft Transport Strategy is far too vague and, where is clear, it seriously lacks ambition. The postponing of a large number of projects until after 2035 (and even after 2042 in many cases) is not acceptable and is not in line with the climate action commitments made by the government.
Even without considering the climate, from a quality-of-life perspective Dublin needs to see bold investment to create a world-class public transport and active travel network to reduce car dependency, air pollution, inactivity and car dominance in our public realm. When the climate crisis is also taken into account, it is clear that there is no room for decades-long delays and non-committal language – we need to see action taken and infrastructure put in place on a much shorter timescale.
We thank the NTA for its work on the Draft Transport Strategy so far, and we look forward to seeing more boldness and ambition in the final Transport Strategy.
Footnotes
2016-2035 Transport Strategy, Section 5.12.
Draft Transport Strategy, Section 12.3.2.
2016-2035 Transport Strategy, Section 5.12.
2016-2035 Transport Strategy, Section 5.12.
Draft Transport Strategy, Section 12.3.7.
Draft Transport Strategy, Section 12.3.9.
See for example Railway Procurement Agency Metro West Outline Business Case dated December 2008.
Braga A, Saldiva P, Pereira L, Menezes J, Conceição G, Lin C, Zanobetti A, Schwartz J and Dockery D 2001 Health effects of air pollution exposure on children and adolescents in São Paulo, Brazil Pediatric Pulmonology 31 106-113.
Monsere C, McNeil N and Dill J 2012 Multiuser Perspectives on Separated, On-Street Bicycle Infrastructure Transportation Research Record: Journal of the Transportation Research Board 2314 22-30.