I have made the following response to Iarnród Éireann’s public consultation on proposed new timetables.

The increase in service frequency on the Dart and other routes is very welcome. However, I am concerned about some aspects of the timetable changes proposed.

1. The timetable planning process

I asked about the use of the National Transport Authority’s transport model to evaluate this timetable change. Iarnród Éireann’s reply is that the model is used only to evaluate infrastructure changes rather than timetable changes. It is my understanding that the model includes information on interchange and intermodal trips and therefore could be used to evaluate timetable changes including the breaking of existing connections such as are proposed.

2. Interchange between rail and rail and between rail and bus

I am concerned that the timetable is not designed to facilitate interchange between rail lines or between rail and bus. The essential aspect of a quality public transport system is that it operates as a network not simply a collection of non-integrated lines.

At the moment, connections between the Howth line and the Malahide /Drogheda line are irregular, with some connections offering a reasonable interchange time and others offering a time too short or too long. Many Drogheda trains stop at Howth Junction giving access both to the Howth line and to the orbital 17a bus route which travels from Howth Junction Station across the Northside as far as Blanchardstown.

The proposed timetable has a number of negative aspects as regards interchange:

2a No interchange with Drogheda trains at Howth Junction

This proposed timetable no longer has Drogheda trains stopping at Howth Junction, meaning a trip from Donabate to Beaumont (by train and bus) or to Howth (by train) or vice versa would require two changes, not one, a significant drop in service.

2b Long waits for interchange between Howth and Malahide line trains.

The timing of trains through Howth Junction means that passengers between Howth line stations and Malahide line stations will have an interchange of 20 minutes. Such a wait in an unwelcoming station is long enough to deter many passengers. As mentioned above, it is my understanding that the NTA’s model could be used to explore how this timetabling would affect the quality of the trip for passengers and the relative desirability of public transport compared to other modes.

Irish Rail should copy the practice of other railway companies, such as the Swiss Federal Railways, who provide standard interchange times of 6 minutes for non-adjacent platforms.

3. Services to Portmarnock and Clongriffin

It is proposed that Drogheda trains will no longer stop at Portmarnock and Clongriffin. This will particularly affect peak hours with a reduction in the current frequency and the loss of some faster trains from these stations to the city centre. Given the role of Portmarnock in particular as a park and ride, some of these halts should be retained, especially at peak hours.

4. Bus timetables

Please confirm that Dublin Bus will adjust the timetables of connecting services such as the 102 and 17a to provide timely interchange with the new rail timetable.

I made the following response to the Public Consulation on Development Levies in Fingal.

1. The list of projects ​in Appendix II to be funded by the scheme should include the following:
   • Full implementation of those elements of the Greater Dublin Area cycle network which are in Fingal (https://www.nationaltransport.ie/publications/transport-planning/gda-cycle-network-plan/ );
   • Road and street redesign to to ensure compliance with the Design Manual for Urban Streets and Roads;
   • Works to improve access to and amenity at beaches.
2. ​The costs in Appendix I should be adjusted accordingly.
3. The proposal is that development contribution rates​ remain unchanged. This is predicted to lead to a shortfall of €31m or about 10%. If this happens then infrastructure which we have identified as essential will be unfunded. This is not acceptable; the Scheme should provide for full funding of the required infrastructure.​
4. Commercial/industrial and residential development are levied at different rates. When I asked why this was I was told because they require different levels of infrastructural expenditure. In fact the commercial/industrial rate is simply 78% of the residential rate for all of the types of infrastructure (transport, surface water, parks) to be funded. That this is not related to the associated infrastructure cost is demonstrated by the fact that the same surface area of development attracts different charges for provision of surface water infrastructure depending on whether its residential or commercial. At a first glance it seems daft that at a time of housing demand in Dublin and when we have large quantities of derelict/empty commercial property we would effectively subsidise commercial at the expense of the residential.Therefore the same contribution should be required for commercial/industrial and for residential.
5. Car parking is proposed to be either exempt, or in the case of ‘stand-alone commercial car parks’ levied at 50%​ (10(i)(j))​. Given that transport policy both nationally and locally seeks to achieve significant and rapid modal shift away from cars, all car parking should pay development contributions at the normal rate.

My response to the consultation on a Transport Strategy for the Greater Dublin Area focusses on the complete failure of the Strategy to address emissions of air pollution and greenhouse gases.

I have sent the following response to Dublin City Council’s consultation on the redesign of the junction of North Wall Quay/ East Wall Road/ Eastlink Bridge at The Point.

Executive Manager,
Planning Department,
Dublin City Council,
Block 4, Floor 3 Civic Offices,
Wood Quay,
Dublin

A chara,

I live in Howth and work in Ringsend; this is my route to work. As Councillor for Howth/ Malahide ward on Fingal County Council I also represent constituents who use this route on a daily basis.  We have an excellent coastal cycle route as far as East Point Business Park at which point the journey becomes a lot more difficult.

The scheme objectives set out in the report fail to address cyclists’ and pedestrians’ needs for safe and convenient road design and the proposal fails to adequately provide for pedestrians and cyclists as a result.

The most significant element of this is the routing of cyclists through waiting bus passengers and alighting bus passengers on each side of East Wall Road.

There are significant bus passenger numbers at this location as it is an interchange between Luas and bus services through the Port Tunnel, as well as being in the vicinity of employment and the Point Depot theatre. Buses stopping here include Swords Express, Aircoach, Airlink 747, 33x, 33d, 142, 151. The result is a high frequency of buses stopping and significant bus passenger use of the area.

However, it seems that no passenger count data has been gathered in advance of the design, or even calculations of the total frequency of buses at the bus stops in question. Traffic counts are described in the report but they appear not to include pedestrians or cyclists.

At the moment, southbound buses stop at the bus stop on East Wall Road (the one which is proposed to be retained as is). Due to the nature of the bus service, there are almost no passengers boarding here. The buses stop to allow passengers to alight. As some buses are coming from the airport, many passengers have luggage and many are in the area for the first time. There is no gap between the stopped bus and the cycle lane and the potential for conflict is obvious.

At the moment northbound cyclists either stay on the carriageway or travel across the plaza to join up with the unmarked cycle track at the junction with Sheriff Street. Bus passengers wait at the minor forest of bus signs for northbound buses. At rush hours there are normally quite a few people waiting. Before and after an event at the Point Depot, there are large crowds of pedestrians in the area.

The proposal to retain the conflict between cyclists and bus passengers on the southbound side of East Wall Road and create a similar situation on the northbound side of East Wall road is directly contrary to the guidance in the National Cycle Manual.

That guidance recommends:

• Establish likely bus patronage profile at stop in advance of design choice
• Not suitable for dense pedestrian / passenger activity

There is no indication that the likely bus patronage profile has been identified.

This is an area of dense pedestrian/passenger activity and therefore this option is not suitable.

Point Roundabout Junction

The replacement of this roundabout with a signalised junction is welcome. However, the junction design will keep the speeds of turning traffic high, fails to prioritise pedestrians and cyclists. A junction taking less space providing direct pedestrian crossings and tighter corners would be far safer.

East Link Bridge

The Eastlink bridge has been excluded from this design. This is very unfortunate. Clearly the original design of this bridge did not take into account the needs of pedestrians and cyclists. Numbers of pedestrians and cyclists using this route have increased significantly in recent years and the current highly unsatisfactory situation needs to be addressed.

The design itself is not clear on how southbound and eastbound cyclists are expected to access the East link Bridge; it seems to be directing them onto the footpath, which would be illegal. Is this the intention?

North Wall Quay

The report states that there is a two-way cycle track on the south side of North Wall Quay. It is reassuring to learn this as the road layout is confusing. It would help greatly if sections such as the one in this photo were clarified. The road markings seem to suggest westbound cyclists on the left of the cycle track should move right to be on the left of the carriageway and then back to the left of the cycle track across the path of eastbound cyclists who seem to have nowhere to go.

The proposed layout where cyclists coming off the bridge turning west will pass the end of the shared surface to join a cycle lane and then immediately turn left to cross the cycle track seems unnecessarily complicated; in addition the turning radius seems too short.