Submission on Greater Dublin Area Transport Strategy

Thu, Jan 20, 2022

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The NTA put their draft Greater Dublin Area Transport Strategy out to consultation over Winter 2022. There are many aspects of the strategy to be welcomed, including a shift from congestion management focus to emissions reduction focus. However, overall the strategy remain under ambitious in the context of the climate crisis and the travel needs of Dubliners. Below is my submission, in collaboration with Councillor Darcy Lonergan and Deputy Neasa Hourigan.

Submission on Greater Dublin Area Transport Strategy

Dear Sir/Madam,

We would like to make the following observations and raise various concerns regarding the NTA Greater Dublin Area transport strategy. There are several aspects of the strategy which should be warmly welcomed but overall the strategy lacks the urgency or ambition that we need to see in Dublin over the coming decades.

Climate Target

The 2021 Climate Act sets a legally binding target of 51% reduction in emissions. This should be regarded as the floor of our ambition, rather than the ceiling of it – particularly in Dublin where there are greater alternatives available to the private car. 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.

Path to Decarbonisation

The transport strategy needs to set out a year by year path to decarbonization. It may prove dangerous to wait until the decade is over to measure the success or otherwise of the measures against what is envisioned. It is important for public accountability and for all the stakeholder bodies to be able to monitor the success of the plan on an ongoing basis. And the NTA should aim to alter the plan if it emerges that we are not on our predicted course for decarbonisation.

Vehicular emissions lifecycle

A limitation of the plan is that it only counts emissions at the tailpipe rather than the total emissions involved in the construction and end of life of the vehicles. Electric vehicles, while still much lower emitters than petrol or diesel vehicles, are emissions intensive to produce and dispose of. But these emissions are not counted in a tailpipe calculation. Externalising emissions counting onto other regions and sectors does little to reduce our overall footprint in a global system of climate change. The plan should demonstrate, at a minimum, an awareness of this limitation and be clear that all alternatives to EVs are preferred and EVs should be regarded as the last alternative.

Demand Management

The demand management tools to be considered by this strategy will have a very significant impact on people’s lives and how they travel and yet they are entirely unelaborated in this document. The demand management strategy should be published and put out for public consultation to gather feedback. The ambition of the demand management strategy should be to find mechanisms that are as equitable as possible and maximise the benefits to communities who currently experience restricted mobility by the current transport system e.g. changing the roadscapes to provide one way systems and increase cycling and walking provisions in areas where there are currently few public transport option. For those who are entirely dependent on cars for transport, supports should be identified to ensure they are not unfairly penalised.

Road/street space reallocation should also be examined and modelled by the NTA. It can serve a dual purpose as both discouraging journeys by private car and supporting and making safer journeys by bike or walking, which will particularly benefit those who do not have access to a car or who are not able to drive. Therefore as a demand management strategy, road/street space reallocation is likely to be one of the more progressive options available.


The timelines for many of the big infrastructure projects envisioned by the plan are far too long. The political landscape, realities of the climate emergency and priorities of the general public will change significantly over the decade or so between when projects initially go out for consultation and when they are implemented. Timeframes need to be condensed to reflect the urgency of climate action. Delays to announced timelines also need to be avoided.

Big projects need expanded design teams in order to ensure that the timelines are accelerated as much as possible. We have previously seen significant delays on the design phase of projects. We cannot afford these to be repeated in these projects if the 2030 targets for emission reductions are to be reached.

Accelerated timelines are also necessary for the success of demand management strategies. There will be a limit to how many journeys can be displaced from private cars if there are not sufficient alternatives available to absorb these journeys.

In particular the Finglas Luas could and should be brought on stream quicker. With an expanded design team and tendering taking place in parallel with the design and planning phase the project should be deliverable in advance of 2030.

The current system of evaluating projects according to a business case is ill-equipped to reflect the climate crisis and adding to the timeline for delivery. An alternative system of proofing, prioritising and accelerating projects according to their ability to deliver on urgent emissions mitigation measures is needed.

Mode Share

The modelling of mode share is unambitious for what can be achieved by appropriate cycling and walking interventions. Cycling has the capacity to carry a significantly greater proportion of journeys – particularly in the urban parts of the Greater Dublin Area. Interventions to support safer cycling, reallocation of road space and access to e-bikes and other appropriate bikes have been shown to radically increase the proportion of people cycling in other European cities. The NTA modelling should look at what role ebikes can play in supporting longer commutes and other longer journeys and should work with local authorities and public bodies to ensure that appropriate infrastructure is in place to support people to use these vehicles e.g. appropriate storage and charging facilities and lifts that accommodate bikes at Dart and train stations. If utilized effectively in the Greater Dublin Area they are likely to prove effective mobility aids and capable of displacing journeys that would not be reachable by regular pedal bikes.

Further e-scooters and appropriate interventions to support them should be considered. It is concerning if the majority of journeys by e-scooter are likely to be displaced from other sustainable transport means e.g. walking and cycling. But they offer significant potential for last-mile commuting and multi-modal travel so interventions around train and bus hubs in particular should be explored.

While cycling has gained popularity in net figures over recent decades it has decreased in use among women, children and older people. This particularly contrasts with countries where safe and segregated cycling infrastructure is provided. This demonstrates the capacity for cycling to carry many more journeys if safe infrastructure is provided and the needs of women, children and older people in particular are catered for.

Working with Local Authorities and the Department of Transport

The success and timely delivery of this plan requires that the Department of Transport and all local authorities share a vision for radical reduction of carbon emissions and a refocus of transport away from private cars and towards more sustainable means of transport over the coming decade. Particularly in relation to the roll out of active travel infrastructure and some demand management measures e.g. parking charges, local authorities will play a crucial role. Delineation of responsibilities between local authorities and the NTA must be made clearer. It is important that local authorities are empowered rather than undermined in the process by having clarity regarding respective responsibilities in relation to emissions reduction measures from the outset of the plan.

Local authorities can also play a significant role in providing measures to complement demand management e.g. providing people with greater access to bikes and e-bikes, providing people with reward schemes for choosing more sustainable means etc.

The Department of Transport should also reform mileage payment schemes to reward commuters and workers who choose walking and cycling over driving. These incentivising tools should be supported by the NTA and factored into modelling.

Pedestrian improvements

We welcome the suggested measures around walking including in particular:

Such changes will be welcomed by footpath users and in particular more vulnerable footpath users. We note that many of these changes will be implemented “in conjunction” or “in cooperation” with local authorities. We hope that the NTA will take a lead role in driving these changes. Too often pedestrian improvements are far from the top of local authorities priorities. We also note the point about street clutter caused by, for example, private cars and outdoor seating. While private businesses and individuals do generate obstructions on the footpaths, obstructions generated by state and semi state bodies are often numerous. We feel that the these bodies should focus on:

Planning beyond 2030

We can be sure that the climate crisis will be an ongoing challenge for Ireland to respond to over many decades ahead and that provision of adequate public transport will be an essential aspect of how we need to address this. While the immediate focus is on the ambition regarding emissions reductions leading up to 2030, planning for post 2030 must begin immediately so that projects such as the Luas Poolbeg can be delivered as soon as possible.

The NTA should seek to increase its staff complement and support the relevant staff in local authorities on a long-term basis to ensure there is a consistently rolling over body of work being done to bring new projects on stream and reach as many communities as possible to address their diverse needs.

Equality and Inclusion

The inclusion of an equality assessment in this draft strategy is very welcome and demonstrates progress towards greater understanding of the existing inequities in transport systems. Women, older people, children, ethnic minorities and people with disabilities tend to experience greater disadvantage in access and safety in the current transport system. These groups will, on balance, benefit the most from expanded sustainable transport options, but it is important that careful attention is given to their particular patterns of travel, priorities and needs as planning for a “default male commuter” has previously resulted in a further marginalisation of these groups. As already noted there has been a reduction in the number of women, children and older people cycling since the 1980s, despite an overall increase - so specific targets should be assigned to increasing the modal share of these groups and all interventions gender and age proofed. It is also important that the emphasis is moved away from the minority of journeys which are for the purpose of commuting towards providing sustainable options for shopping, caring, community based and leisure journeys too. This would reflect the change from a transport strategy focused on reducing congestion to one focused on reducing emissions and improving equality.

You can view the full draft strategy here: