The NTA has applied for planning permission for the Bus Connects Kimmage to City Centre scheme. The deadline for submissions in the 12 September 2023 and the Bord’s reference number is 317660. Dublin Cycling Campaign will be making a submission and is supportive of the scheme, though we will be making a number of suggestions for improvement. We urge you to contact your local politicians and residents associations to let them know you support the scheme and to make a submission if there are issues that particularly affect you. The main points in our submission are listed below:

Welcome Elements of the Scheme

We are supportive on the scheme and believe it will bring about significant improvements in bus travel and walking and cycling facilities.

We particularly welcome a number of the modified elements of the proposed scheme, which were raised in previous submissions, including:

• Provision of cycling facilities along the main CBC corridor
• The introduction of a bus gate at peak times from the KCR to Harolds Cross, to improve bus journey times
• Provision of new canal bridges at Emmet Bridge to provide additional space for pedestrians and cyclists;
• New bus stop by-passes along sections of Kimmage Road Lower, Harolds Cross Road and Clanbrassil Street
• Construction of new retaining wall at Emmet Bridge/ Clanbrassil Street to provide for adequate width;
• Provision of segregated cycle tracks along Harolds Cross Road;
• Addition of a quiet way along the Poddle and through Mount Argus;
• Retention and enhancement of cycling facilities on Clanbrassil Street;

Elements of the Scheme for Consideration

The points listed below relate to the overall characteristics of the scheme which we believe need to be addressed during the detailed design and construction phases.

Quality of Cycling Facilities

We are disappointed to see low-quality intermittent cycle lanes shown on the Lower Kimmage Road, with the parallel cycle route being circuitous, with a very narrow bottleneck entering Mount Argus while sharing with pedestrians.

While the scheme increases the total cycling facilities from 2.8 km to 4 km, of this 2 km consists of the existing advisory cycles lanes. And along two sections of Lower Kimmage Road the advisory cycle lanes will be removed and replaced by formal car parking spaces. At the moment parking is not allowed in the inbound cycle lane from 7-10am, and the outbound cycle lane from 16:00-19:00. Outside of these hours the cycle lanes are frequently used for parking. This will put cyclists in danger of “dooring” and force them into the bus lanes.

This does not appear to be consistent with the scheme goal to:

“Enhance the potential for cycling by providing safe infrastructure for cycling, segregated from general traffic wherever practicable;.”

Neither will it encourage “Interested but Concerned” cyclists or parents with children to cycle along this route. We suggest the scheme would be improved by upgrading the advisory cycle lanes to segregated cycle tracks.

Bus Gate Operating Hours

The proposed operating hours of the bus gate are 8:00-10:00 and 16:00-20:00 Monday to Sunday. This does not align with school closing times, so children who might cycle to school (with or without parents) will be forced to mix with traffic on the way home.

We suggest that the bus gate should operate during the time periods when children are travelling to and from school.

Cycle Track Widths

Throughout the scheme we see a variation in the proposed widths of the cycle tracks with some as narrow as 1.2m and most at 1.5m. As per the current National Cycling Manual (NCM) guidelines we would expect that all cycle tracks be a minimum of 2.0 m. At this width this allows overtaking of regular cycles and also will accommodate larger cycles such as tricycles and cargo bikes.

In most cases there is space to increase the width of the cycle tracks, by reducing traffic lane or footpath width and it is not clear why the narrow cycle tracks were included in the design. We also believe that any cycle track proposed to be constructed at less than 2.0 m is not being built for the envisaged future capacity. As the evolution of e-mobility including e-bikes continues to unfold, the infrastructure being put in place should have the capacity to cope with increased demand, and as such the width of the cycle tracks should be maximised to accommodate this modal shift.

Quiet Street Treatment

The scheme includes two ‘Quiet Streets’ routes: the Poddle Way, and east of Kimmage Road Lower on Derravaragh Road. We welcome these routes and the additional traffic restrictions. The utilisation of filtered permeability, such as on Derravaragh Road, is a welcome approach. The engineering solution of bicycle gates will negate the possibility of ‘rat-running’, will improve traffic calming in the area, and improve the environs for residents. To ensure the concept of a ‘Quiet Street’ is deployed and successful we propose that engineering designs are utilised to reduce the width and speed of the carriageway to make it a safe and comfortable route for cyclists as well as denoting that cyclists should have priority. The Dutch guidance for such a street (as per CROW Design Manual for Bicycle Traffic) outlines some of the following implementations and considerations:

• The colour of surfacing red (to make cycle route recognisable)
• No marking on the carriageway
• Width of vehicle path 4.5m
• Safe for cyclists
• Comfortable for cyclists
• Clear to motorists that there is a cycle route

For the entire Bus Connects program we would suggest that Quiet streets are given a distinct uniform surfacing to denote their purpose. In addition we would suggest that parking is limited and when provided is designed in such a way to protect the cyclist. Interventions such as build-outs could be used to further cultivate a ‘Quiet Street’ environment.

Speed Limits

We welcome the introduction of a 30 km/hr speed limit along a 2 km stretch of this scheme. It is not clear from a legislative perspective how this will be executed given speed limit changes are currently under the remit of local authorities.

Compliance with speed limits in Ireland is poor. The RSA ‘Driver Attitude & Behaviour Survey 2021’ found that 57% of motorists admit to exceeding 50 km/h speed limits by up to 10 km/h. The survey didn’t ask motorists if they comply with 30 km/h speed limits, but it is evident that compliance is even worse for 30 km/h speed limits. We therefore request that driver behaviour with respect to speed limits is cultivated through engineering design and supported by automated speed cameras.