Dublin City Council has produced a design for the QBC from Amiens St., through Fairview and out along Malahide Rd. The design involves cycle lanes of sub-standard width placed often where cyclists would be at risk from doors being opened by parked cars. At junctions, it leads cyclists into increased danger by putting them to the left of left-turning traffic. At other locations, it attempts to squeeze buses past cyclists where there simply isn’t room on the carriageway.
I have made a submission to the City Council; see below. The deadline for submissions is 16th June.
Councillor David Healy
Green
Party/Comhaontas Glas
Howth ward
/ Dublin North East
www.davidhealy.com
01
8324087
54,
Páirc Éabhóra, Beann Éadair
54,
Evora Park, Howth
Comments on Malahide Road QBC proposals.
30th May 2006
By email to
qbnoffice@dublincity.ie
The following comments are submitted in response to
the public display of the proposed changes to the Malahide Road QBC
My comments focus in particular on the safety of
the proposed design for cyclists. My
comments are made as a cyclist who uses part of the route to access the city
centre myself, and as a Green Party representative for the general Dublin
North-East area for which either all of part of the route constitues the only
effective cycling access to the city centre.
Comments refer to entire route
proposal drawn up, not just that on display at the moment
The following comments refer to the design drawings
for the entire route from Amiens St. to Clare Hall, dated 18th August
2005. I understand that the drawings on
display start with North Strand/ Annesley Bridge and therefore Section 5 below
(Sheet 5 in the full set of drawings) relates to Sheet 1 in the drawings on
display. I understand also that the
design on display does not go beyond the Artane Roundabout. Section 17 (Sheet 17 in the full set of
drawings) corresponds to Sheet 13 in the display. I enclose my comment on all the elements of
the design as I feel this would be most efficient. Comments which relate only to the elements
currently on display are from Sections 5 to 17.
Generally the scheme is not good
for cyclists
I note that improving facilities for cyclists is
one of the stated objectives of the scheme.
Unfortunately it does not achieve that objective.
At the Velo-city conference last year, the flaws in
the existing design in Fairview were openly acknowledged by Dublin City Council
staff. Indeed attendees including myself
were assured that that the City Council have learnt a lot since and would not
make the same mistakes again.
Unfortunately, this appears not to be the case. The
design proposed retains almost all the defective elements of the existing
design from the Fairview/Malahide Rd. junction to Amiens St. It proposes to add many kilometres of
substandard cycle facilities to the route.
The potential exists along this route to create a
good quality route, minimising conflicts and risks for cyclists and creating a
pleasant and safe cycle facility along the route. The current design proposal does not meet
that potential and I urge the members of the City Council to require that it be
redesigned.
Section 1 Amiens St. (not in
current consultation)
1.1 Traffic lights near Foley
St.
The proposal here is to change the northbound cross
section at the traffic lights from
- Footpath 3.8m
- traffic lane 2.8m, and
- traffic lane 2.6m
to
- Footpath 2.7m,
- traffic lane 3.5m including cycle lane 1.5m, and
- traffic lane 3m
A lane of 3.5 is not wide enough to allow a wide
vehicle to safely pass a cyclist (ref pp. 62-63 of National Manual). This route has many buses and they can be
expected in this lane. Painting lanes
with inadequate widths encourages motor vehicles to pass too close to cyclists.
The traffic island could be eliminated to provide
adequate cycle lanes. If this is not
done, it would be better to mark no cycle lane than to paint lanes which
encourage passing where there is insufficient space.
1.2 What is the appropriate
cycle lane width?
The proposed design includes cycle lane on the
carriageway as low as 1.20m before the
Malahide Rd. and 1.08m on the Malahide Road.
(presumably including half of the adjacent road markings). According to the National Manual (a document
which is not without its flaws) the “absolute minimum” excluding road markings
should be 1.25m. The “preferred width … is between 1.5m and 2m. …When the
volume of cycle traffic is high, a width of 2m is recommended.”
According to the Canal cordon count (http://www.dto.ie/rumr.pdf) 215 cyclists
crossed the Canal southbound at Newcomen Bridge between 8 and 9 a.m. This is 17% of the total traffic count during
this hour. It is also the highest number
over any canal bridge during this hour. It’s
a reasonable guess that this cyclist numbers applies to the stretch between
Malahide Rd. and Connolly Station. One
could also guess that evening peak numbers, while more spread out, are similar. Logic dictates that if the reference to high
volumes of cycle traffic in the Manual mean anything, they apply to the route
between Malahide Rd and Connolly Station.
1.3 New cycle lane at bottom of
Buckingham St.
Why is the traffic island being set back here to
curve the cycle lane away from the centre of the road? The important issue for cyclists’ safety at
this location is that they are positioned in the road where traffic waiting to
turn right into Buckingham St. will be looking for oncoming traffic. It is hard
to tell at the scale shown but it seems that the current design will have the
opposite effect.
Section 2 Amiens St./Portland
Row (not in current consultation)
2.1 Buffer shown in
cross-section
The buffer (door zone) is shown 0.6m on northbound
carriageway and 0.8 on southbound in cross-section. What is your minimum? I would have expected at
least 1m of a buffer zone on a road with such speeds and volumes, enabling the
cyclist to comfortably maintain a passing distance of 1.5m
2.2 Cycle lane placed in
door zone
However, further south there is no buffer and the
cycle lane passes directly beside parked cars.
Safe cyclists do not use the cycle lane in this area. However, inexperienced or trusting cyclists
may do so. Additionally, markings like
this result in agression to cyclists who do not use them from bus drivers, taxi
drivers and car drivers.
2.3. Cycle lane positioning
cyclists to the left of left-turning traffic
Coming into the Five Lamps junction, the cycle lane
keeps cyclists to the left of left-turning traffic. This is not safe. I would not position myself to the far left
coming into such a junction. Road
markings should encourage cyclists to occupy the lane.
Section 3 North Strand (not in
current consultation)
3.1 Width of lanes in
cross-section
Your cross-section diagram shows a bus passing a
cyclist in a 3.7m lane. p.59 of the
National Manual shows width segments. In
an area with a maximum 50km/hr the distance from a cyclist to a passing vehicle
should be at least 1.05m. Applying the
width segments to to this design, the bus, to pass safely within the lane,
would have to be a maximum width of 1.635m, which, as we know, is not the case. According to the Manual, the necessary width
for buses to pass cyclists is 4.5m. Widening
this lane to an insufficient width such as 3.7m will encourage buses to try to
get past cyclists where there isn’t space.
This increases the risk for cyclists.
3.2 Dangerous existing footpath
cycletrack
The southbound design retains the dangerous
cycletrack on the footpath north of the Canal, which requires a cyclist to come
back onto the carriageway into a traffic lane immediately before the Ossory
Road junction.
The southbound design also retains the dangerous
cycletrack on the footpath south of the Canal which brings cyclists off the
carriageway over a curb at a dangerous angle, brings the cyclist into conflict
with turning traffic at 3 locations and always has pedestrians walking on
it.
Many cyclists do not use this track because of the
additional risk. However, inexperienced
or trusting cyclists may do so. Irish
law requires that cyclists use such facilities, so cyclists are put in a
position where their safety and traffic laws conflict. Additionally, markings like this are proven
to result in agression to cyclists who do not use them from bus drivers, taxi
drivers and car drivers.
This dangerous facility needs to be redesigned.
Section 4 North Strand (not in
current consultation)
4.1 Road markings should direct
cyclists to occupy the lane
Cyclists using this section have to occupy the bus
lane. It might be appropriate for
advisory road markings to indicate this.
An assessment of such markings is at
http://www.bicycle.sfgov.org/site/uploadedfiles/dpt/bike/Bike_Plan/Shared%20Lane%20Marking%20Full%20Report-052404.pdf
Section 5 North Strand/East Wall
Road (Sheet 1 of current consultation)
5.1 Dangerous existing junction
with East Wall Road
The dangerous junction at Annesley Bridge and East
Wall Road is to remain unchanged.
Instead of dealing with the danger, cyclists who, following the design
(as they are legally obliged to do), have been thereby been put in a dangerous
position to the left of left-turning traffic are to be warned by a sign:“Cyclists
beware of HGV’s turning left to East Wall Road.”
The problem here is two-fold:
HGVs or any road user who turn left across the path
of another road user are breaking the rules of the road and thereby endangering
the other road user. Any sign should
warn them to comply with the rules before warning others of the danger they
pose.
Secondly, cyclists are in a position to be hit by
such HGVs if they occupy the road position which they are instructed to take by
the cycle lane marking. The design here
is one which consciously puts cyclists in danger and then attempts to warn them
of the danger!
The reasonable solutions are as follows:
- Ban left-hand turns at this junction (and redesign the junction in
order to prevent/impede illegal turns.)
- Direct the cyclist to occupy the lane with markings as referred to at
4.1 above
Section 6 Annesley Bridge
Road/Fairview (Sheet 2 of consultation)
This is appalling.
6.1 Seriously inadequate cycle
lane in door zone
The cross-section shows a cycle lane (at 1.20m below
“absolute minimum width” and far below the recommended 2m) in the door zone of
parked cars.
6.2 Substandard cycletrack
against railing with substandard footpath
The design also retains the 1.05 cycletrack on the
footpath on the other side of the road. According
to the National Manual, a one-way track off the carriageway should be given a
width from 1.75m for a peak hour cycle traffic volume of up to 150, a width of
2.5m for 150 to 750 cyclists and 3.5m for over 750 cyclists.
According to the Canal cordon count (http://www.dto.ie/rumr.pdf) 215 cyclists
crossed the Canal southbound at Newcomen Bridge between 8 and 9 a.m.; it’s a safe estimate that cyclist numbers
along Annesley Bridge Road are similar.
Therefore the width should be 2.5m
This track of sub-standard width is marked to the
left of the pedestrian area of the footpath.
There is a cycletrack of substandard width directly beside a
railing. The National Manual requist
that the edge of the cycletrack should be >0.5m from objects such as
lamp-posts etc. and >0.75m from solid walls.
Unsurprisingly the pedestrians do not remain in
their minimal 1.05m allocation and walk on the entire footpath. Additionally, cars park on this footpath,
probably in part because of the difficulty in crossing the road on foot.
The cyclist facilities along here are entirely
inadequate. An aware cyclist would not
use them as they are more risky than using the rest of the carriageway.
The obvious solution is to remove one of the two
northbound general traffic lanes to provide cycle facilities of adquate width
on both sides of the road.
Section 7 Fairview (Sheet 3 of
consultation)
7.1 Seriously inadequate cycle
lane in door zone
The same considerations apply as for Section
6. The cross-section shockingly shows a
1.25m cycle lane in the door zone of a parked car with a bus passing the
cyclist on a 2.3m bus lane. The bus in
the diagram is wider than the bus lane.
How can a design like this be put on public display?
7.2 Unnegotiable angles
The only additional element here are the sharp
angles on the footpath cycletrack westbound. These contravene the absolute
minimum curve radius of 4m in the National Manual.
At this location there are two northbound and two
southbound general traffic lanes in addition to the bus lanes. This 6-lane road completely severs Fairview
Park from its hinterland making a dangerous environment for pedestrians. It would make sense to take this an
opportunity to reduce the impact of
traffic on this area and facilitate it’s rejuvenation and improvement.
Section 8 Fairview /Malahide
Road (Sheet 4 of consultation)
8.1 What happens to the existing
straight-ahead cycle lane?
The design is not clear as to what is intended for
the straight ahead eastbound cycle lane at the junction of Marino Road and
Malahide Road.
Section 9 Malahide Road (Sheet 5
of consultation)
9.1 Road markings should direct
cyclists to occupy the lane
Given the carriageway width,
there is no room for overtaking of a cyclist within the lane. Markings as referred to in 4.1 above should
be considered.
Section 10 Malahide
Road/Griffith Avenue (Sheet 6 of consultation)
10.1 Cycle lane positioning
cyclists to the left of left-turning traffic
Travelling northbound at the Griffith
Avenue/Malahide Road junction, there is a bus lane marked for straight ahead, a
left turning traffic lane to the left of it and a cycle lane to the left of
that. Is this for cyclists travelling
straight ahead? The sign coming into
this junction instructs road users that the left lane is for turning left only
and makes no reference to the cycle lane which is to be marked.
Cyclists travelling north on Malahide Road turning
onto Griffith Avenue should be facilitated with a cyclelane thorugh the
original alignment of Griffith Avenue.
Cyclists travelling north through the junction
should occupy the centre of the bus lane and the bus lane should be marked as
such with markings such as those referred to in 4.1 above. Alternatively a cycle lane of appropriate
width could be placed to the left of the bus lane. Cyclists coming from Brian Road need to be
facilitated in joining whichever straight-ahead lane is provided for cyclists.
10.2 Advanced Stop Lines
All arms of this junction should be provided with
advanced stop lines for cyclists (ASLs).
10.3 Inadequate cycle lane width
In the cross-section, the existing northbound cyclelane at 1.15m are
below the minimum width. There is plenty of room on the northbound carriageway
to increase this about 2m which would be more appropriate given the large
numbers of buses on this route and the
speeds on the road.
Section 11. Malahide Road,
Clontarf Golf Club (Sheet 7 of consultation)
11.1 Inadequate cycle lane width
These cyclelanes are substandard width and should
all be increased to 2m. At the cross
section location, there is sufficient space for 2m +3m +3m. If more space is needed it can be taken from
the traffic island.
Section 12. Malahide Road/Donnycarney Road (Sheet 8 of
consultation)
12.1 Inadequate cycle lane width
As for Section 11.
The cross-section northbound proposes a 2.65m bus lane beside a 1.25m
cycle lane. This would bring a bus
travelling at speed far too close to a cyclist.
The cycle lane should be increased to 2m.
Travelling southbound, the bus lane is to be widened
from the current width but the cycle lane is kept at an inadequate 1.25m
width. The cycle lane should be
increased to 2m. Space can be taken from
the bus or general traffic lanes for this.
Section 13 Malahide Road /
Collins Avenue (Sheet 9 of consultation)
13. 1 Inadequate joint bus and cycle lane
The cross section shows a joint bus and cycle lane
of 3.5m including a cycle lane allocation of 1.25m. As discussed in 3.1 above, this is not a safe
design for cyclists and is worse than the inadequate current situation. It is not possible for a bus to safely pass a
cyclist in this design.
A design of 3.5m is shown in the National Manual
for a shared lane (no separate cycle lane is marked in it) with the condition
that bus speeds should be <30km/hr
and bus and bicycle volumes should be low: “This design can only be used
on roads where buses and cycle traffic have a minor function”. These conditions
do not apply here. 4.5m are
required here.
Note that no separate cycle lane is marked within
the 3.5m lane in the Manual. Marking a
separate inadequate cycle lane within the bus lane will encourage bus drivers
to try to pass cyclists where there isn’t room to safely pass. It makes an inadequate design worse. Where there isn’t room to pass, road markings
should direct cyclists to occupy the lane as in 4.1 above.
One option here is to take more space from the
footpath.
Another is to only have a bus lane north bound.
Another option within the proposed carriageway
width would be to provide an adequate 2m cycle lane northbound /uphill to
facilitate buses passing cyclists who will be travelling more slowly in this
direction, and providing a joint bus/cycle lane southbound/downhill where
cyclists’ speed is closer to that of buses.
13.2 Road markings should direct
cyclists
Coming northbound into the junction of Malahide Rd.
and Collins Ave., cyclists should be guided to occupy the straight-ahead lane
by markings such as those referred to in 4.1 above. Alternatively a cycle lane of appropriate
width could be placed to the left of the bus lane.
13.3 Is it really necessary to
have 4 north bound lanes?
Widening the northbound entry to this junction will
make it harder for cyclists to turn right here.
13.4 Advanced Stop Lines
At the junction of Malahide Rd. and Collins Ave.,
there should be ASLs on all arms.
Section 14 Malahide Road (Sheet
10 of consultation)
14.1 Inadequate joint bus and
cycle lane
As for point 13.1 above.
Section 15 Malahide
Road/Killester Avenue Junction (Sheet 11 of consultation)
15.1 Inadequate joint bus and
cycle lane
As for point 13.1 above
Section 16 Malahide Road/
Kilmore Road Junction (Sheet 12 of consultation)
16.1 Inadequate cycle lane width
It is proposed to retain the existing substandard
cyclelane of 1.1m in order to facilitate the southbound buslane. This brings unacceptable risks to cyclists. There
is not room for a bus lane on the current carriageway nor on the proposed
slightly wider carriageway. It would be
more appropriate to provide a 2m cycle lane and a 3m general traffic lane in
either direction. The traffic lights at
Kilmore Road could be use to give priority to buses leaving the junction and
similar priority could be given southbound say at the junction with Daneli Road.
Section 17 Malahide Road, Artane
Roundabout (Sheet 13 of consultation)
17.1 Removal of roundabout
welcome
The removal of the roundabout at this location is
most welcome. The design seems to be a
considerable improvement on the current situation.
17.2 Width of cycle lanes
The cycle lanes on the road sections need to be of
a decent width considering the speeds of traffic in this area. The National Manual recommends that the cycle
lanes approaching the jucntion should be 1.75 to 2m. If road space is tight, this can be taken
from central islands and traffic hatching on all arms.
17.2 Straight-ahead cycle lane
starting to the left of a left-turning lane
The cycle lane coming into the junction on Ardlea
Road should start from the main lane on the carriageway not from within a
left-turning lane as shown.
17.3 Cyclist traffic lights
There is no indication on the design as to the
locations of the traffic lights. This would be an appropriate location for
cyclist specific traffic lights at a lower level. To discourage motorists from encroaching onto
the ASLs the main lights should be targetted at the motorists’ stop line.
17.4 Bus stop missing?
Is there to be no southbound bus stop at this
junction?
17.5 Left-turning filter lane
The left-turning filter lane southbound into the
junction is very long. What are the
consequences for cyclists using the cycle lane of motorists having the
opportunity to cross their path over a longer stretch like this and
additionally of having motorists joining the filter lane behind them then
passing them to the right potentially at speed?
Section 18 Malahide Road (not in
current consultation)
18.1 An opportunity for a
quality cycle facility
The problems with inadequate width for cyclists
being passed by buses referred to in 13.1 apply here.
There is an opportunity to do something quite
pleasant here.
On this road section it would be appropriate to
provide a segregated cycle facility. The
necessary road space can be taken from the central median.
The cross section could be
- 2m cycle track,
- 1.5m grass verge including trees
- 3m bus lane
- 3m general traffic lane
- 3m general traffic lane (other direction)
- 3m bus lane
- 1.5m grass verge including trees
- 2m cycle track
This is only 0.85m wider between existing grass
verges than the current design. That
small amount of space could be taken from the existing verges to provide this
quality facility.
The bus stops could, with appropriate curves, be on
the new grass verge outside the cycle track. This design would of course
require that cyclists are brought safely back onto the carriageway at relevant
junctions (on adjacent sheets) to prevent conflict with turning traffic. Unless this can be done safely and
effectively then segregation should not be pursued.
Section 19 Malahide Road (not in
current consultation)
19.1 Opportunity for quality
cycle facility continues.
Most of the same considerations apply as to Section
18. Here again we have inadequate,
sub-standard and dangerous widths being proposed for cyclists (1.08m cycle lane
beside 3m bus lane). There is even more
space in the central media here available for a pleasant segregated design as
in 18.1 and it could be easily implemented within the current
carriageway+median width.
The junction with St. Brendan’s Drive and Coolock
Village would need to be designed carefully to bring the cyclists from the
segregated facility onto the carriageway in order to negotiate the junction
safely. Alternatively or as part of
this, traffic lights might be appropriate here.
Additionally, cyclists will have to be brought onto
the carriageway before the Tonlegee Rd. junction, or the junction redesigned
with cyclist phases in the traffic lights.
Section 20 Malahide Road/ Oscar
Traynor Road (not in current consultation)
20.1 Opportunity for quality cycle facility
continues.
The road section south of the junction is wide and
north of the junction is wide again.
(For the first time, the design shows cycle lanes of minimum
widths.) Here again there is an opportunity
for a pleasant segregated design as described under 18.1 above
20.2 Advanced Stop Lines
At the junction with Tonlegee Rd. ASLs should be
provided on all arms.
20.3 Conflict between cyclists
and left-turning traffic.
On three of the entrances to the junction there is
a risk to cyclists of being crossed by left-turning traffic. This risk needs to be recognised and designed
for. Markings as referred to in 4.1
above should be considered. Another possible
response is for the curb radius of the filter lane to be be low enough to
prevent a fast turn across the cycle lane.
Section 21 Malahide
Road/Greencastle Road junction (not in current consultation)
21.1 Opportunity for quality
cycle facility continues.
Substandard cycle lanes are again proposed in the
cross-section.
The segregated design suggested under 18.1 above would
fit here without difficulty well.
Alternatively, taking a small bit of space from the
central median would allow decent cycle lanes to be provided on the
carriageway.
21.2 Conflict between cyclists
and left-turning traffic.
The junction with Greencastle Road needs to be
considered carefully. The proposal to cut away the curb and facilitate a faster
left turn onto Greencastle Road across a marked cycle lane is worrying,
especially as buses make this turn. There
should be clear facilities for cyclists travelling straight ahead. Markings as referred to in 4.1 above should
be considered.
Section 22 Malahide Rd., Newtown
cottages (not in current consultation)
22.1 Opportunity for quality
cycle facility continues.
Substandard cycle lanes are again proposed in the
cross-section
The segregated design suggested under 18.1 above
would fit here without difficulty well.
The only caveat is that the presence of driveways would require that
traffic turning across the path of cyclists coming either onto or off the
carriageway would need to be made very aware they are crossing another’s right
of way. Appropriate verge widths would
help to address this as would surfacing and signs.
Alternatively, taking a small bit of space from the
central median would allow decent cycle lanes to be provided on the
carriageway.
Section 23 Malahide Road/
Newtown Road (not in current consultation)
23.1 Opportunity for quality cycle facility
continues.
Substandard cycle lanes are again proposed in the
cross-section.
The segregated design suggested under 18.1 above
would fit here without difficulty well.
Alternatively, taking a small bit of space from the
central median would allow decent cycle lanes to be provided on the
carriageway.
23.2 Left-turning filter lane
The same question arises in relation to the junction
with Newtown Road as in 17.5 above.
Section 24 Malahide
Road/Priorswood Road (not in current consultation)
24.1 Replace roundabout with
traffic lights
This roundabout should be replaced with a normal traffic
lights controlled crossroads.
The proposed roundabout design is a disaster for
cyclists. There are shart right angled
turns on the cycle track, which it is not physically possible to negotiate by
bicycle. Cyclists coming from Priorswood
Road to Blunden Drive will have to cross 4 sets of traffic lights. They will also have to negotiate 6 impossible
sharp right-angled turns. As with other
similar designs in Dublin, most cyclists will not use it and remain on the
carriageway, dealing with a dangerous roundabout.
The proposed design is also a major inconvenience
for pedestrians, taking them well out of their way in negotiating the junction. It is not appropriate for a built-up area
where official policy is to encourage and facilitate walking and cycling.
This should be replaced with a traffic lights
controlled crossroads as with the Artane Roundabout.
Section 25 Malahide Road, Grove
Lane (not in current consultation)
25.1 Opportunity for quality cycle facility
continues.
Substandard cycle lanes are again proposed in the
cross-section.
The segregated design suggested under 18.1 above
would fit here without difficulty well. Alternatively,
the central median could be retained as is and the necessary space obtained by
only providing one general traffic lane in each direction, giving the following
cross-section:
- 2m cycle track,
- 1.8m grass verge including trees
- 3.5m bus lane
- 3m general traffic lane
- 8.85m median
- 3m general traffic lane
- 3.5m bus lane
- 1.8m grass verge including trees
- 2m cycle track
Alternatively, taking a small bit of space from the
central median or the verges on either side would allow decent 2m cycle lanes
to be provided on the carriageway.
Section 26 Malahide Road / Clare
Hall shops (not in current consultation)
26.1 Opportunity for quality cycle facility
continues.
Substandard cycle lanes are again proposed in the
cross-section.
Either of the segregated designs suggested under 18.1
or 25.1 above would fit here without difficulty. This would require a redesign of the junction
with the Clare Hall shopping centre access, which would not be particularly
difficult with cyclists’ traffic lights.
Alternatively, taking a small bit of space from the
central median or the verges on either side would allow decent cycle lanes to
be provided on the carriageway.
Section 27 Malahide Road / N32
(not in current consultation)
27.1 Cycle lane positioning
cyclists to the left of left-turning traffic
The northbound cycle lane leaves the cyclist on the
left edge of the left-turning lane, bringing her /him directly into conflict
with left-turning traffic if (s)he is travelling straight ahead. This is unacceptable.
