Submission of Draft County Development Plan

Uimhir Thagarta Uathúil: 
KCC-C55-330
Stádas: 
Submitted
Údar: 
Maynooth Cycling Campaign
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl
Údar: 
Maynooth Cycling Campaign

Litir Chumhdaigh

This submission is on behalf of the Maynooth Cycling Campaign.

Observations

Proposed Changes to Draft CDP Chapter 5

In contrast to agriculture and energy, transport is the area where a local authority can have the greatest impact on climate change. We welcome the support for sustainable transport including walking and cycling and the lesser role envisaged for car based travel. However, we consider that the County Development Plan should explicitly state that a significant reduction in car use is an essential requirement for a sustainable future. TII design requirements specify that planners design for increased number of vehicles in the future which is incompatible with decarbonising of transport and avoiding climate change.

 

We strongly support the concept of a 10 minute settlement although the distance covered by a 10 minutes journey by foot, by bicycle and by public transport varies significantly. Kildare towns and villages are relatively small by international standards with none having dedicated local public transport. Active travel is feasible if made attractive to people who drive their cars for short journeys.

We support the recognition that traffic congestion is reduced by more active travel rather than the traditional solution of more roads and more road space.

We welcome the (January 2029) targets for modal change. However, the targets should be broken down into individual urban areas and for rural areas county wide. Following on from the County Development Plan, the targets should also propose 2030 targets which is a key date for Ireland’s international commitment on climate action. Targets which involve a change in travel mode from private cars should also be quoted in terms of number of commuting vehicles so that Kildare’s impact on the Climate Action Plan commitment of 51% reduction in fossil fuelled vehicles can be quantified.

It is disappointing that many of the objectives and policies refer to promotion and feasibility. The plan would be more progressive and definitive if it referred to achieving and/or enabling. In particular, the statement

Kildare County Council will endeavour to deliver a reduction in private car usage broadly in line with the 51% reduction in emissions by the end of this decade …

lacks ambition and recognition of the seriousness of climate action.

In relation to car shedding and consideration of how to travel, three key moments are when people get a new job, buy a new house or have a new person in their household.

 

ADDITIONAL OBJECTIVE TM Oxxx

Encourage new employees, house buyers and parents to consider active and sustainable travel in conjunction with Kildare stakeholders.

TM O6

Support and encourage employers to develop and implement Workplace Travel Plans based on the NTA’s Workplace Travel Plans: A Guide for Implementers (2013).

Replace “Support and encourage” with “Require”.

Insert “which deliver modal change” after “implement Workplace Travel Plans”.

 

TM O7

Introduce measures to reduce traffic congestion in town centres such as pedestrianisation, pedestrian priority and/or improved pedestrian facilities, in particular increasing the number of safe crossings.

Replace “pedestrian” with “pedestrian/cyclist”

 

TM O11

Investigate the feasibility of developing high-quality, suitable, safe and

sustainable cycling pathways:

i)  from Leixlip, Maynooth and Naas into Dublin; and

ii)  between Naas and Newbridge,

ii)  Kildare town to Newbridge and westwards towards Portlaoise as far as the Kildare county boundary, and

iv)  Kildare Town to Monasterevin.

Add v)  Enfield to Edenderry disused railway line.

Add vi) Along a Kildare section of the Trans-European Transport Network (TEN-T).

 

TM O16

Ensure regular maintenance of walking and cycling routes and ensure that all roads in new developments are designed in accordance with the principles, approaches and standards contained in the Design Manual for Urban Roads and Streets 2019, the National Cycle Manual (NTA, 2011 – or the pending update) and the Draft GDA Cycle Network Plan (NTA, 2021).

Insert “including winter maintenance” after “Ensure regular maintenance”.

 

TM O19

Investigate the feasibility of dedicating a street(s) to pedestrian only activity on certain days of the week or at certain times of the day, in a pilot town during the life of this Plan.

Replace “Investigate the feasibility of dedicating a street(s) to pedestrian only activity” with “Dedicate a street(s) to pedestrian and cycling activity”.

Add “in each municipal district” after “pilot town”.

 

TM O32

Promote and encourage the use of the Toolkit for School Travel (2019) by teachers, parents and others and promote and encourage, in consultation with the Department of Education, substantial changes in relation to the items that learners are expected to bring to and from school daily to encourage more learners to cycle to school

Replace “Promote and encourage” with “Support”.

 

TM A7

Investigate the feasibility of providing a footpath connection from Maynooth to Celbridge.

Replace “footpath connection” with “a dedicated shared path”.

 

TM A13

Prepare a Cycle Network Study for each of the key towns in County Kildare consisting of the primary links identified in the NTA’s Draft Greater Dublin Area Cycle Network Plan (2021), connections between the major towns and surrounding settlements, key strategic cycle routes, greenways and local links, all in accordance with the National Cycle Manual. The study will include draft widths, level of services and identify local targets.

 

Delete the sentence commencing with “Prepare a Cycle Network Study”.

Insert “Prepare a Cycle Strategy for each of the key towns in County Kildare consisting of the primary links identified in the NTA’s Draft Greater Dublin Area Cycle Network Plan (2021), local links and links to surrounding settlements; include key strategic cycle routes, greenways connecting the major towns, all in accordance with the National Cycle Manual.”  

Replace “level of services” with “levels of service”.

 

TM A16

Provide new or upgraded lighting for all footpath and cycle track schemes subject to the consideration of ecology and impacts on wildlife. Appropriate environmental assessments will be required and may result in unlit sections which may include some parts of the county’s Greenways.

Replace “upgraded” with “dynamic”.

 

ADDITIONAL ACTION  TM Axxx

Design separate facilities for pedestrians, cyclists and vehicle drivers unless vehicle speeds and levels of activity are low. If numbers are high, shared space will result in a poor level of service for all.

 

TM O58

Secure the implementation and maintain corridors free from development to facilitate future roads, cycle facilities and other transport infrastructure improvement identified within this Plan (Tables 5.4 & 5.5) and Local Area Plans. The further progression of the road projects is subject to assessment against the ‘Principles of Road Development’ criteria set out in Section 13.2 of the Draft Transport Strategy for the Greater Dublin Area 2022-2042. Where the road project is an orbital road around a town centre, the development must be accompanied by enhanced public transport, cycling and pedestrian facilities in the relevant centre, as required by Section 13.5 o

Insert “the National Investment Framework for Transport in Ireland (NIFTI)” between “subject to assessment against” and the “Principles of Road Development”.

 

TM O71

Support and facilitate enhanced orbital movement between the N3, the N4 and N7 national roads, by the widening of existing roads and/or the development of new road links, for the purpose of providing resilience to the operation of the M50 and incorporating provision for sustainable transport as provided for in the NTAs Draft Transport Strategy for the Greater Dublin Area 2022-2042 and the Regional Spatial and Economic Strategy

Delete this Objective as it is incompatible with government Climate Change objectives.

 

TM O85

Progress the regional roads identified for improvement as set out in Table 5.5 subject to funding.

Add “During the life of this Plan, select a (section of) regional road linking two urban settlements in each of the municipal districts and investigate the feasibility of providing a segregated shared path adjoining it.”

Comment - Table 5.5 includes 44 regional roads virtually every regional road in the county. This is in addition to some 20 priority road projects listed in Table 5.4 (Section 5.1 Roads and Street Network).

 

TM O98

Set and apply speed limits taking into account the function of the road or street, the characteristics of the surrounding area, the design of the street environment and the presence of vulnerable users. The speed limits shall be in accordance with the Road Traffic Act 2004 (as amended) and shall be subject to the requirements of the Guidelines for Setting and Managing Speed Limits in Ireland (2015).

Insert “potential” before “vulnerable road users”.

Replace “shall be subject to the requirements of the Guidelines for Setting and Managing Speed Limits in Ireland (2015)” with “in accordance with the Stockholm Declaration”.

ADDITIONAL OBJECTIVE - TM Oxxx

Reduce motorised traffic in town centres where alternative routes exist so as to promote walking and cycling in the interests of road safety.

TM O107

Seek to reduce the level of on-street parking with a view to the reallocation of the roadspace to sustainable modes and to investigate the feasibility of delivering parking on suitable backland sites that would not jeopardise the vitality and vibrancy of the relevant town/village centre.

Replace “Seek to reduce” with “Reduce”.

Travel Mode Targets

The travel mode share targets quoted in the CDP are incorrect as they amount to 115% and 130% instead of 100%.

Mode of Travel

Travel To Work* (2016 - Assumed 2021)

Travel to Work Target 2029 in CDP

Travel to Work Target 2029 Proposed

Walking

6%

20%

20%

Cycling

1%

10%

10%

Bus

5%

13%

10%

Train

5%

14%

10%

Car share

4%

8%

8%

Car

74%

50%

42%

TOTAL

95%

115%

100%

       

* Table 5.1 Draft CDP

     

Mode of Travel

Travel To Education* (2016 - Assumed 2021)

Travel to Education Target 2029 in CDP

Travel to Education Target 2029 Proposed

Walking

28%

50%

35%

Cycling

2%

15%

10%

Bus

20%

25%

25%

Train

 

 

 

Car share

 

 

 

Car

50%

40%

30%

TOTAL

100%

130%

100%

       

* Table 5.2 Draft CDP

     

Proposed Changes to Draft CDP Chapter 15

The specification for cycle parking at primary and secondary schools is adequate for 2029 targets but woefully inadequate for 2050 requirements. To cater for cycle parking in 2050, new schools planned during the period 2024-29 should ensure that they identify and keep free from development sufficient space for at minimum twice the level of parking specified above.

Proposed Changes to Draft CDP Chapter 16

Monitoring and reporting are an essential element of management ensuring that development is in accordance with what is intended. Our opinion of the appendix which runs to nearly 120 pages is that it fails to measure the key metrics and fails to inform the general public of a is trying to achieve and why, and which the general public can read and understand.

 

The Council MUST radically reorder this Appendix starting with items to be reported annually, through to items which have to be reported after 5 years ie at the end of the Plan's life.

 

In relation to transportation, there are two key performance indicators:

·Travel modal split, and

·Reduction in carbon emissions.

If these performance indicators perform as intended, much of transport objectives and actions will be successfully implemented. If they fail to be implemented, management must redouble efforts to achieve their implementation.

In  measure these performances, it is necessary to

1)    Measure travel mode split on an annual basis, and

2)    Estimate the impact of emission reduction of active travel schemes and the impact of emission increase of non-active travel transport projects at the design and post-construction stage.

Performance indicators which are measured annually, will of course also be reviewed after two years in accordance with the statutory requirements but statutory requirements do not preclude them from being measured more often if they are critical.

Faisnéis

Uimhir Thagarta Uathúil: 
KCC-C55-330
Stádas: 
Submitted
Líon na ndoiciméad faoi cheangal: 
0
Teorainneacha Gafa ar an léarscáil: 
Níl