This submission to An Bord Pleanála was paid for using funding donated from IrishCycle.com readers — thank you to all those who made that possable. You can find the full drawings and reports for the project at dublincity.ie.
Dear Sir / Madam,
This observation is for the ‘College Green Project – Environmental Impact Statement and Planning Submission’.
In principal, the College Green Project is to be welcomed, but the detail design is sub-standard, not compliant with the Dublin City Development Plan 2016-2022 on a number of grounds, and not compatible with local and national policy on sustainable transport. This is an observation on the project, but in the context that the design can be fixed within this process via directions issued by An Bord Pleanála to Dublin City Council (the Council).
The Dublin City Development Plan 2016-2022 (referred to hereafter as the Development Plan) states:
“With regard to the city centre, in particular, ease of access to persons of all ages and abilities is a significant indicator as to how inclusive Dublin is as a city.”
The Council’s ‘Your City – Your Space, Dublin City’s Public Realm Strategy’ (2012), states:
“Dublin City Council’s vision is for a public realm that… Is easy people of all ages or abilities to use. Universal Design Principles will be used to design create and deliver spaces that are safe, easy to navigate and can easily facilitate daily life and business.”
However, despite the above and the Development Plan looking for “facilities that are relevant and accessible to people of all ages and abilities”, the Council is planning non-segregated and non-continuous cycle lanes on Dame Street of a type where loading and unloading of goods vehicles is allowed under law, and a cycle route exposed to buses doing U-turns at the western edge of the proposed plaza – these are hardly design elements suitable for all ages and abilities. As outlined below in detail, I do not believe that cycling for suitable for all ages and abilities and the development plan objectives are being met by the Council’s plans for College Green, Dame Street, Church Lane, etc.
The development plan includes details for a reason — these are principles which should be followed, not disregarded because these were overlooked or not seen as important enough by the Council or the designers. Details of the elements of the project which are not compatible with the city development plan are outlined below.
The combined policy context incorporates the following documents:
- Dublin City Development Plan 2016-2022
- Smarter Travel
- A Sustainable Transport Future 2009-2020
- Design Manual for Urban Roads and Streets (DMURS)
- National Cycling Policy Framework
- National Cycle Manual
These include that priority and space be given to cycling above motorised transport, but this policy is not followed through on in the College Green project.
College Green, Dame Street, Church Lane and St Andrew’s Street are also part of primary cycle routes in the NTA’s Greater Dublin Area Cycle Network Plan.
Image: A section of the Greater Dublin Area Cycle Network Plan.
In the Council’s plans for the College Green project, the Environmental Impact Statement documents outlines how:
“The Proposed Project includes proposals for a two-way cycle track along the eastern and southern sides of the proposed plaza. This will connect in future to improved cycle facilities on Dame Street and Westmoreland Street providing a cohesive cycle route through the city centre. The Proposed Project will therefore greatly improve the quality of service and safety of cyclists passing through College Green.”
“The cycling provision in the Dame Street to South Great George’s Street area will likely change in the future with the completion of the Greater Dublin Area cycle network and in particular the Clonskeagh to City Centre cycle project.”
The Clonskeagh project was suspended as part of cutbacks and it is unclear when planning for it will be reactivated or when it will have a construction budget. While the Council claims that the design on Dame Street amounts to “minor works”, the drawings provided show some large footpath realignment and significance allocation of significance space to taxi ranks / loading and a turn lanes for general traffic — these are not minor changes in the context of local and national policy which puts cycling before buses, taxis, and private cars.
The current plan also only contains sub-standard cycle lanes, but the provision for cycling on Dame Street should be done properly as part of this project, and not be seen as something which can be fixed at a later date.
The current plans include non-segregated cycle lanes which are broken-lined or advisory cycles. The National Cycle Manual contains a number of images of advisory cycle lanes with the caption “Cycle lane should be wider and mandatory” or “Advisory cycle lane should be mandatory”. The Cycle Manual sees mandatory cycle lanes (ones with continuous white lines) as the perfect option over advisory cycle lanes. The manual states:
“In this manual, if cycle lanes are to be provided, the preferred option is the Mandatory Cycle Lane wherever possible.”
The manual states that cycle lanes “are only effective when unhindered by parking and loading activity”. The manual goes on to describe how set down and loading is allowed in advisory cycle lanes:
“Advisory Cycle Lanes are marked by a broken white line which allows motorised traffic to enter or cross the lane. They are used where a Mandatory Cycle Lane leaves insufficient residual road space for traffic, and at junctions where traffic needs to turn across the cycle lane. Parking is not permitted on advisory cycle lanes other than for set down and loading. Advisory cycle lanes are 24 hour unless time plated.”
There is no possible reason for the cycle lanes along the length of the section of Dame Street covered in the EIS to be advisory for their full length.
The Cycle Manual has fairly high requirements (in terms of speed and/or traffic flow) for segregation and it has little about segregation in urban centres. However, for good planning we should look at the range of documents — the Development Plan states that:
“It is an Objective of Dublin City Council…To improve existing cycleways and bicycle priority measures throughout the city, and to create guarded cycle lanes, where appropriate and feasible” [MTO10]
The term “guarded cycle lanes” effectively is what most people refer to as protected or segregated cycle lanes or paths.
Dame Street already has thousands of people who cycle the street daily and the planned cross-city cycle route upgrades will lead to an increase in the numbers cycling. The street will also retain buses, taxis, vans and trucks for deliveries and private motorists accessing car parks. It is appropriate for safety and desirability of people of “all ages and abilities” to segregate cycling from motorised traffic.
It is also feasible to have segregation of cycling — the street has been de-prioritised as a through traffic route and the prioritisation of public transport in nearby areas will mean lower traffic levels across the city centre. The prioritisation of public transport includes the prioritisation of buses on the quays and Parliament Street, and buses and trams between Westmoreland Street and Dawson Street etc — there is no question that capacity for private traffic will be reduced. In such a case, buses, taxis and private motorists should not mix as much as is practicable and cycling should be prioritised in line with local and national policy.
Giving dedicated space to cycling is key to prioritising it and making cycling a safe and attractive option for all ages and abilities.
If some or most of the taxi and loading space planned for Dame Street is shifted to the side streets around the old Central Bank building (even if the DublinBikes station in turn needs to be relocated), and/or if the eastbound Dame Street general traffic lane and right hand turning lane beside it are merged, it would provide space on Dame Street for segregation, including island bus stops (also known as ‘bus stop bypasses’).
Irish planners may argue that island bus stops are not appropriate for busy central areas. However, this can mainly be put down to a lack of experience in providing high-quality cycle route which are in line with policy. Such island stops are provided at bus, BRT, and tram stops across the Netherlands and at bus stops on the second generation of London’s Cycle Superhighways which are segregated from traffic.
An island bus stop is even possible on what is viewed to be “the busiest cycleway in the Netherlands” with on average 32,000 cyclists per day in the city of Utrecht on Vredenburg beside its main bus corridor (source: https://bicycledutch.wordpress.com/2017/06/06/the-busiest-cycleway-in-the-netherlands/)
Note: The image includes a two-way cycle path. The suggestion is that Dame Street could accommodate smaller single-directional cycle paths on both side of the road. As all buses will be turning around, bus stops are only needed on one side of the street.
Cycle path junction with north-south pedestrian flow
The design of the two-way cycle route turn where it crosses the pedestrian flow to-from Grafton Street was always going to be one of the hardest movement elements of the project to design so that conflict is minimised, the current design includes an unrealistically sharp turn (highlighted above in red) which will add to any potential conflict. In particular, the design is unfair on southbound pedestrians, who will need to look for cyclists and emergency vehicles (which won’t necessarily be operating with lights and sirens) that are behind them, as opposed to being to their side.
While European cycling expert’s advice to the Council (attached) agreed that there had to be a mixing area, the current design of such will be poor for all users.
An alternative must be looked at. The below image is just a very rough outline of one possible design solution: with the black lines representing tactical kerbs and the green areas representing possible low-level planting to dissuading both cyclists and pedestrians from taking short cuts. It could be designed in a way which also allows for the planned emergency access.
In the interest of safety and conflict reduction, the board must direct the Council to redesign the mixing area between the two-way cycle route and the pedestrian flow to/from Grafton Street. This is of vital importance — if this junction does not work a large percentage of cyclists are likely to detour across the main plaza area.
Lack of clarity of cycle route around plaza area
Around the plaza and the bus turning circle area (where high-quality paving is planned from building to building), the Council seems to be planning a cycle route only defined by small bicycle logos and no colour or line difference between both the roadway and pedestrian sections of the plaza.
The Council’s report on transport states that “The proposals include a dedicated two-way cycle track on the eastern and southern sides of the plaza”, but there is no defined cycle track shown in planning drawings of that area, only a cycle route across an area of the same surface design and colour as the plaza and roadway at the bus turning circle.
Advocates for those with sight impairments demand that there be an appropriate division between pedestrian and cycling areas. Ideally, this should be achieved with a low kerb and a contrasting surface colour. An alternative would be using strong lines of street furniture and trees with limited gaps.
The lack of clarity of the cycle route in this area will make it harder for pedestrians and motorists to see the cycle route and this will lead to increased levels of conflict. The board should direct the Council to at the very least to enlarge the bicycle logos to the size of standard cycle lane bicycle logos, and to re-examine the colour and pattern of the cycle route. Areas that will have bus operations should strongly contrast with the pedestrian and cycling areas.
Bus turning area
Around the plaza and the bus turning areas, the cycle route will be mostly set between the lines of trees and footpaths, however, at the bus turning area people cycling will be exposed to buses turning and drivers dealing with blind spots.
While the side street access requirements might disallow full segregation, segregation is possible on the turning circle from the top right to bottom left hand corners of the above image. The board should instruct the Council to segregate cycling from turning buses.
Bicycle parking around plaza
The Council has outlined in recent reports how there is a major shortage of bicycle parking in the city centre, in the plan for this project, however, the plaza project only includes an increase of 6 bicycle spaces, for a total of 32 cycle parking spaces in the plaza area.
On the below drawing includes I have highlighted planned bicycle parking racks (in yellow circles) and potential locations for extra parking spaces (in red Xs): It is clear that more than double the amount of bicycle racks can be provided without impacting on pedestrian flows, bus flows, emergency flows, seating areas or event area etc.
The Development Plan states that it is an objective that:
“MTO13: In accordance with cycle routes identified in the National Transport Authority’s Greater Dublin Area Cycle Network Plan (i) To improve permeability for cyclists by reducing speed limits to 30kph and allowing contraflow cycling on all single lane one way streets, and to provide a segregated contraflow cycle lane on all one way streets with two or more lanes, except where engineering report demonstrates risk is too high.”
However, the plans which were put on display by the Council includes no contra-flow access on on-way side streets north or south off Dame Street.
Church Lane and St Andrew’s Street, on the south side of Dame Street, are part of the Primary Route 11 to Ranelagh in the Greater Dublin Area Cycle Network Plan. Not only is there no contra-flow on Church Lane, but there also appears to be no route for people cycling from Church Lane and wanting to turn left into the two-way cycle route at the edge of the plaza.
A “balancing of requirements” or other reasoning for no contra-flow may be argued for the other side streets, but given that Church Lane and St Andrew’s Street are both part of a primary cycle route, two-way cycling must be provided. There is no reason to leave this to a later date and the Council’s plan of establishing a loading bay on Church Lane will hinder the in the provision of following the Development Plan and the Greater Dublin Area Cycle Network.
Further, as Church Lane is quite very steep, it should be considered as to whether it is suitable of not for a loading area. Trolleys, etc. will be difficult to unload and are at risk of rolling down the hill.
This project should also be used to upgrade the existing contra-flow cycle lane on St Andrew’s Street (which is known for chronic illegal parking and loading) to become a segregated contra-flow cycle lane, by way of bollards, flexi-bollards or a high kerb, which would only need bollards at either end.
For the above reasons, the board should instruct the Council that the planned loading bay on Church Lane should be removed and the space relocated to a segregated contra-flow cycle lane and wider footpaths, and that the St Andrew’s Street contra-flow cycle lane be upgraded to segregated contra-flow cycle lane.
Access from Dame Street to/from Nassau Street
Cycling access from Dame Street to/from Nassau Street needs to be designed for to avoid users unnecessarily entering the busiest areas or making risky movements.
The board should direct the Council to provide for cyclists coming from Dame Street and turning right onto Grafton Street (and vice versa), OR provide clear routing and signage via St Andrew Street / Church Lane and Suffolk Street in both directions. The latter would reduce the flow of cyclists in the busiest area and reduce conflict.
Bank of Ireland front access
Retaining regular motorised vehicular access to the front door of Bank of Ireland is undesirable and a potential safety concern. The safety issues arising include conflict with pedestrians, conflict with cycling and possibly allowing greater access to the plaza for both unaware motorists or a terrorist driving a car or truck. Potential counter measures could include bollards of the style used at the Dame Street side of the Central Bank Plaza. Provision would need to be made for parade and maintenance access in the form of retractable bollards.
At the construction phase, the plan states: “Vehicles (other than bicycles) will be excluded from east-west transit through College Green at the beginning of the construction stage and will not return after construction is finished.” It states that “a minimum 20m wide pedestrian / cycle zone will be maintained”.
Segregation of walking and cycling is needed at construction phase. In the city of Utrecht temporary cycle paths have been maintained across construction areas around its central station area redevelopment, a far more complex project than the College Green Plaza. I would ask that the board set down a requirement that walking and cycling will be given their own space (separate from each other) at the construction phase.
The proposal for Luas Line F is for a route from Lucan via Thomas Street and Dame Street to College Green, connecting with the under-construction Luas Cross City at the northern end of Grafton Street. Line F is necessary to allow increased access into the city centre from the west of the city, as a back-up for the existing Red Line and as a contingency in the case that DART Underground isn’t or can’t be built. In the context of the loss of through buses on College Green, and the consequent emphasis on the O’Connell Bridge – Hackett Bridge – Abbey Street node as a potential choke point, it is important that space be set aside at College Green for a potential tram line. In the context of the Council’s proposals, there is a need to ensure surface levels are consistent with any prospective tram line.
As trams operate on tracks, their alignments are much narrower and their swept paths more precisely defined than an equivalent capacity road. In many locations across Europe, trams operate through otherwise pedestrianised streets and plazas without material levels of conflict.
As trams would only operate on the plaza every few minutes, they wouldn’t have the detrimental effect that current traffic levels have.
In summary and for the reasons outlined above, I would ask An Bord Pleanála to instruct the Council to:
- Redesign the cycle lanes on Dame Street between Anglesea Street and Temple Lane South so that the project complies with objective MTO10 the Development Plan, the National Cycle Manual, and other policies.
- In the interest of safety and conflict reduction, redesign the mixing area between the two-way cycle route and the pedestrian flow to/from Grafton Street.
- At the very least to enlarge the bicycle logos to the size of standard cycle lane bicycle logos around the plaza and bus turning circle area, and to re-examine the colour and pattern of the cycle route.
- Segregate cycling from turning buses at the bus turning circle.
- Remove the planned loading bay on Church Lane and relocated the space to a segregated contra-flow cycle lane and wider footpaths, and that the St Andrew’s Street contra-flow cycle lane be upgraded to segregated contra-flow cycle lane
- Provide for cyclists coming from Dame Street and turning right onto Grafton Street (and vice versa), OR provide clear routing and signage via St Andrew Street / Church Lane and Suffolk Street in both directions. The latter would reduce the flow of cyclists in the busiest area and reduce conflict.
- Give walking and cycling their own space (separate from each other) at the construction phase.
- Ensure surface levels are consistent with any prospective tram line.
I would like to thank you for considering my points.
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Great submission but will designers pay any attention to your recommendations and observations?
We are for ever wasting out time with these! Direct Action and/or a legal challenge is what will change provision for the least polluting and super healthy travel mode.
Well done Cian. A lot of work went into that.
Unfortunately we have a situation in this country where we have to cross our fingers and hope that they take notice. What a crappy situation to be in when we have to hope that best practiced will be followed, and that the designers and planners will bother to follow the clear guidelines set out in both the national cycle manual and the City’s own published development plan.
Great submission. While I agree that direct action and legal routes may be more effective in getting results in the short to medium term, there is still a clear need to clearly lay out the reasons for our objections in a precise and comprehensive manner in order keep applying pressure that is backed up by rational analysis, to keep track of our position on each project as it proceeds and to be able to clearly articulate an alternative approach to engineering-minded officials when the time comes. So well done and keep up the good work.