GREEN PARTY/Comhaontas Glas

CONTRIBUTION to PUBLIC CONSULTATION

on the Proposals Contained in

The NTA’s Fingal/North Transport Study Appraisal Report, November 2014

19th January, 2015

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The Green Party would like to thank the National Transport Authority for the opportunity to comment on the proposals of the Fingal/North Dublin Transport Study.

Key Points

• This submission is based substantially on the Green Party’s Transport Policy1, notably the principles of minimising greenhouse gas emissions, of climate change and of social justice (provision of a quality system for all). • The study is welcome insofar as it recognises a need for a high quality public transport system to support, within the area in question, a modal shift from private vehicles to public transport and the substantial projected increase in population. • However, the approach taken in studying the Swords-City Centre corridor in isolation from the general issue of is limited as it precludes recognition of the need for a comprehensive transport network of orbital and radial routes, such as illustrated in the Aris- Leahy “Dublin Transport Map” 2. • The Study should recognise the global context of climate change and the urgent need to reduce carbon emissions. • As well as considering conventional measures of technical feasibility, cost and travel time savings, all proposals should be appraised on the basis of o high level of service in terms of reliability, frequency and comfort; o emissions reductions; o ability to cater for expected population increases in the study area; o impact on the public realm and streetscape; o integration with existing transport systems; o safety for vulnerable road users. • On the basis of the information available, the Green Party considers that LR7/‘optimised’ Metro North is the scheme which currently best fulfils these criteria.

Schemes proposed: criticisms and areas for further analysis

Given the preliminary stage of technical and economic analysis, it is premature to make categorical statements about the best transport system for the area in question. The section below outlines criticisms and areas where further analysis is required for the six schemes identified as feasible in the study. The proposals are discussed here in the order in which they are presented in the study.

HR2: Rail link Swords - Clongriffin • It serves a very limited new catchment due to the low level of development between the airport and Clongriffin.

1 The Green Party (2013). Transport Policy. Available at: http://www.greenparty.ie/assets/docs/Green%20Party%20Transport%20Policy.pdf

2 http://www.venetikidis.com/ArisV/DUBLIN_TRANSPORT_MAP.html

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• The lack of capacity on the Northern line between Clongriffin and Connolly is a major disadvantage. HR2 is contingent on the progress of the Dart Underground/Expansion project, whose status is currently uncertain. • As acknowledged in the study, even if the Dart Expansion project were to go ahead, it is not clear whether there would be sufficient capacity on the line both for a new airline service and commuter and mainline rail services. • The Dart Underground project is discussed in further detail on pg.5 of this submission.

HR8: Rail link Drumcondra-Swords • There is again a high level of uncertainty about the capacity of the Western rail line. • The cost of this option is extremely high with low benefits in comparison to other options.

LR3: Swords-Cabra • LUAS is a proven technology in Ireland with a high level of public support. • The cost of this option is not prohibitive.

• Whether the maximum possible capacity on this line could cater for greater demand due to population increases in the North Dublin area should be examined. • The travel time for this option is poor. • Further analysis should investigate how this could be improved, for example by ensuring priority for LUAS at all road junctions. • Also, the current route alignment under Glasnevin Cemetery means a significant catchment is excluded. • The possibility of adding an underground station to serve Glasnevin/Drumcondra should be explored. • Further analysis should clarify whether the addition of services to Swords on the Cross City line would negatively affect the frequently of services to Broombridge.

LR7: ‘Optimised’ Metro North • On the basis of the information available, this option currently best fulfils the criteria for a large scale public transport system serving the North Dublin corridor. • It has sufficient capacity to cater for greater demand as a result of population increases. • It provides a high level of service particularly in terms of travel time. • Underground rail in the city centre is favourable in terms of minimising impacts on the streetscape. • According to the research conducted by Caulfield et al. 3, the Metro would cause the greatest reduction in private transport trips of all options on this corridor. • There has been substantial prior investment in planning and pre-development. • Although the cost is high, the Metro fulfils the need for long term planning and strategic investment in public transport in Dublin.

Criticisms and suggestions for further analysis of the Metro proposal • Further development of this option should involve exploring all possible measures to minimise impacts on St. Stephen’s Green. • Underground transport systems have a significant environmental impact during construction. • Later stages of analysis should explore means to further reduce costs. • This could include limiting the distance travelled underground to the core city centre.

3 Caulfield B., Bailey, D. and Mullarkey, S. (2013) Using data envelopment analysis as a public transport project appraisal tool. Transport Policy. 29, 74-85.

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• Further analysis should explore the possibility of an at-grade alignment through the airport as suggested for HR8. • The at-grade section could be extended further south towards the city centre than is currently proposed. • An underground rail system of this nature must be accompanied by complementary measures to ensure resulting available road space does not result in increased car use. • The removal of the Lower O’Connell St. Station should be reconsidered as this is an important point of interconnection with the Luas .

BRT option: • The BRT option has a favourable cost compared to others. • It has the potential to be developed into a comprehensive network, for example as suggested in the Aris- Leahy “Dublin Transport Map” referred to at ² above. • It has potential benefits in terms of reducing the road space available to private cars. • BRT is regarded as an unproven technology in Ireland. • A system with levels of service, in terms of capacity, comfort, travel time and reliability, equivalent or greater than is required in order to cause significant modal shift. • The ‘semi-open’ type network suggested for Dublin in the NTA’s Dublin BRT Core Network Report 4 will not deliver such levels of service as it does not sufficiently prioritise BRT over other road users in terms of levels of segregation. • These conclusions are supported by the Institution for Transport Development and Policy’s “BRT Standard” report 5 .

C1: Combination Option • This option requires a transfer from passengers travelling from City centre – Swords by heavy rail. This will seriously undermine its attractiveness to passengers. • Capacity on the LUAS line from Airport-Swords would need to be sufficient for additional passengers transferring from the Clongriffin-Airport route. • Otherwise refer to observations on HR2 and LR3.

Other issues to be considered

1. Carbon emissions reductions and social gains

One of the principal objectives of the system should be reducing overall carbon emissions from transport. As such it is necessary to consider the number of private vehicle trips removed as a primary benefit of investment in public transport. In addition, it is also necessary to consider the relative energy efficiency and social gains of public transport systems. This should be an aspect of option appraisal. The Green Party strongly supports the implementation of public transport systems that utilise low emissions technology such as electric, hybrid or biogas power.

2. Timeframe for implementation and expected population increases

4 National Transport Authority (2012). Core Network Dublin

5 Institution for Transport and Development Policy (2014). The BRT Standard. Available at: https://www.itdp.org/wp-content/uploads/2014/07/BRT-Standard-20141.pdf

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The Green Party considers that the timeframe for implementation of the study must be reduced. The implementation of some of the proposals is not foreseen before 2035. There is an urgent need for the provision of high quality public transport in this area in the short to medium term for all the reasons that we support public transport, including reducing congestion and emissions.

Furthermore, where future housing development is located should be governed not just by current and expected increases in population, but by public transport routes and hubs. It is also possible to promote high density development around public transport stations in planning policy. Increased capacity as a result of such development should be considered in the appraisal of options.

3. The Dart Expansion/Underground Project

The Dart Expansion/Underground Project is referenced throughout the study report in which context its progress is regarded as uncertain. More recently, according to the draft ‘Strategic Framework for Land Transport’ the Dart Expansion project has been indefinitely postponed. the status of the Dart Underground/Expansion is a vital consideration in the appraisal of options in the current study. It is inappropriate, for example, that HR2 and C1 propose to utilise railway capacity which may not eventually materialise. Dart Underground is also an essential point of integration with the proposed Metro North route alignment.

The Green Party strongly supports the DART Underground project. The economic benefits were clearly demonstrated in the 2010 'Business Case' report.6 In addition, the DART Underground corresponds to the need to maximise the value of existing infrastructure and form a coherent public transport network to a greater extent than the projects currently proposed in the North Dublin Study.

4. Complementary public transport schemes

The prospect of increased investment in public transport in the area in question is welcome. However, in the absence of a coherent strategy for the entire Dublin region, the approach of the study is limited by isolating the North Dublin area from the wider issue of transport in Dublin. This issue must be considered in a more integrated manner.

Such an approach fails to consider the need for orbital routes which connect suburban areas. A wide variety of research (e.g. Murphy and Killen 7) has demonstrated that Dublin is characterised by diffuse patterns of employment and, as a result, typically non-radial commuting patterns. As such, it is necessary to cater for this demand by implementing a comprehensive integrated public transport network, for example as suggested in the Aris-Leahy Map (referenced above). Although conceptual in nature, the outline plan illustrates the potential effectiveness of such a network.

Large-scale public transport infrastructure must be complemented by investment in cycling and walking infrastructure and local bus services for shorter trips.

6 http://www.irishrail.ie/media/dart_underground_business_case1.pdf?v=grhdepa

7 Murphy, E. and Killen, J.E. (2011) Commuting economy: An alternative approach for assessing regional commuting efficiency. Urban Studies. 48, 1255-1272.

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Finally, to promote interconnection with the whole North Dublin region, the possibility of extending the system to meet the existing Northern rail line at Donabate should be explored.

5. Promoting public transport integration

In addition to the development of individual public transport systems or the longer term objective of a comprehensive network, other measures to increase the attractiveness of the existing infrastructure should be introduced. These include:

5.1. An integrated ticketing system whereby payment is not fragmented between modes should be considered. Other cities have successfully introduced ticketing schemes which involve payment on a distance-based or time-based model. The possibility of including the Dublin Bikes in an integrated system should be investigated.

5.2. Transfer/Interchange Facilities The development of waiting facilities at points of transfer within public transport journeys has been neglected and is a major disincentive to public transport use. All options in this study involve interconnections with other forms of public transport. It is necessary to provide waiting facilities with high standards of design as well as adequate seating and shelter.

5.3. Public Transport Pricing The attractiveness of public transport should be increased by ensuring fares are reasonable. Although outside the remit of this study, this can be achieved by increasing subventions available to public transport providers. It is noteworthy that in the past year, while public transport users have suffered increasing fares, motorists have benefitted from reduced costs due to petrol price decreases, while continuing to disproportionately contribute to harmful carbon emissions as well as the other negative externalities of private transport.

6. Airport and general transport needs

Air transport is a substantial contributor to total carbon emissions. While the airport is an important economic centre and requires a public transport link, its importance should not be overestimated in the appraisal of investment. The study conflates the question of transport to the airport with the needs of the general public in the North Dublin area. A public transport system to serve the North Dublin region must facilitate diffuse trips and include the most extensive catchments possible.

Transport Policy Process

1. Democratic deficit

While the Green Party is pleased to be invited to contribute to this debate, it is evident that there is a remaining democratic deficit in the making of transport policy, given that no regional elected body has formal influence over the outcomes. Generally there is a need for greater regional democratic oversight of transport policy.

The Green Party has previously proposed the establishment of the position of directly elected Mayor of Dublin with responsibility for transport policy. Such a position would make a significant positive contribution in this regard.

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To gain further public input into this debate, the Green Party conducted an online survey to represent public views on this issue. The results are briefly discussed below.

2. Integration of transport and development planning

There is a clear need to integrate the processes of the planning authorities with the NTA in order to ensure that adequate sustainable transport options are provided in all cases. The current practice of separating the bodies involved is inappropriate and results in disjointed outcomes.

Survey results

In order to inform the party’s response to the NTA’s call for submissions, an online survey canvassed opinions among the public. The survey was completed by a total of 56 individuals, not limited to those in the study corridor. Although not representative in a scientific sense, it gave a wide range of views on the issues at stake. It was noteworthy that there was majority support for five of the six options proposed, reflecting the level of need for major public transport investment in the study area irrespective of type.

Regarding the study proposals, there was a clear preference among respondents for a scheme that serves the maximum catchment not currently benefitting from high quality public transport. The level of service, in terms of travel time and reliability, was perceived as being of particular importance. The responses indicated that the BRT option is relatively less popular as it is not perceived as being capable of delivering on these requirements. There was concern that additional road based transport would increase pressure on limited available road space and pose a safety risk to cyclists and pedestrians.

Based on the survey results, there is a clear preference for a rail-based public transport system. Both the LUAS and other international examples of underground rail systems are regarded as examples which could be emulated in Dublin. In terms of specific proposals, LR3/LUAS was regarded positively by the majority of respondents and was the second most popular proposal. LR7/Metro was regarded positively by a large majority (66%) and was perceived as very good by the largest proportion of respondents (38%).

Notably, over half of respondents commented on the need for complementary investment in infrastructure for pedestrians and cyclists in addition to large-scale infrastructure. A large proportion cited the Netherlands and as positive examples in terms of promoting cycling. This result supports the points made previously about a wide range of measures being needed to encourage a switch to sustainable transport.

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