Thank you for inviting An Taisce to comment on the Draft Integrated Implementation Plan 2013-2018. We have the following comments to make on the document to the National Transport Authority (NTA).

General Comments

The plan in its entirety does not meet the statutory obligations of the NTA, does not comply with EU legal obligations or government policy on Smarter Travel. It is entirely deficient in defining overarching targets and objectives on reducing climate and air pollution emissions, reducing car dependence, achieving land use planning integration and enhancing safety. Chapter 3 Transport Challenges and Objectives fails to refer to or address the policies and provisions of Department of Transport’s policy, Smarter Travel: A Sustainable Transport Future – A New Transport Policy for Ireland 2009-2020:

More specifically, the plan fails to provide the required targets for:

 Reduction of greenhouse gas emissions to meet Ireland’s EU 2020 obligation.

 Reduction of mode share for workplace travel from 65% to 45% nationally required in Department of Transport’s policy, Smarter Travel: A Sustainable Transport Future – A New Transport Policy for Ireland 2009-2020.

 Specific quantified and timetabled measures for safety and sustainable transport.

Imagine If: The Health Service Executive hospital provision plan did not set out waiting times for key medical procedures like hip replacement. The Department of Education plan for education investment did not provide targets for class sizes or pupil teacher ratios. Such plans or strategies would be deemed not fit for purpose.

There is an inexplicable failure to include fiscal measures as part of the scope of the implementation plan. This would include levying of charges on different categories of parking with immediate focus on retail locations providing free or low cost parking such as Liffey Valley Shopping Centre - imposing of a levy on such parking both to incentivise mode change and fund sustainable travel. No consideration is given to using toll adjustments for traffic management.

The lack of targets and fiscal measures is combined with poor integration of land use and transport in the Greater Dublin Area. This constitutes a major regulatory failure with incalculable future costs in greenhouse gas emissions, inefficient land use and urban sprawl, social and economic cost in excessive or inefficient travel times and undermining of the strategic benefit of public transport and cycling infrastructure investment.

Over the previous decade, successive Chairpersons and Board Members of the Dublin Transport Office failed to exercise their prescribed body function in making submissions and taking appeals to An Bord Pleanala on car based developments contravening the Dublin Transport Office ‘Platform for Change’ strategy.

The NTA since it was constituted with enhanced legal powers and continued the legal remit of the Dublin Transport Office has been entirely ineffective in exercising its prescribed functions for major car based developments in the Greater Dublin Area over the last year.

The objectives and overall investment programme are not reconciled with and directly contradicted by the National Roads Authority proposal to wide a section of the M7 between Newbridge and Naas which would filter extra traffic into the greater Dublin area, exacerbate car based sprawl and undermine strategic transport objective.

No green house gas reduction and fuel efficiency targets are set for bus fleet renewal. The main public transport investment proposed in the strategy is the three Bus Rapid Transit routes are not timetabled. The plan is seriously deficient in safety enhancement and targeting of accident black spot and risk areas particularly in interface junctions between HGVs, cyclists and school travel routes. Regulation of HGV movement is not addressed. No evaluation is made on the efficacy of current toll management on sustainable transport in the Greater Dublin Area and the safety risk of caused by M3 toll evasion on the N2 via Slane. Our specific comments and recommendations on the content of the draft document are as follows:

1 Introduction and Background

1.2 Content of an Implementation Plan

2 Travel in the Greater Dublin Area

3 Transport Challenges and Objectives

4 Scope of the implementation Plan

5 Overall Infrastructure Investment Programme

6 Bus Investment

7 Light Rail investment

8 Heavy Rail

9 Integration Measures and Sustainable Transport Investment

9.4 Cycling/Walking

9.5 Traffic Management

10 An Integrated Service Plan

11 Integration and Accessibility

12 Integration of Land Use and Transport

Download the submission here.