— Analysis by planner’s consultant is coloured by a car mindset.
COMMENT & ANALYSIS: Last week it was claimed that the decision to reject the planned College Green Plaza was reasonable or justified — that’s not surprising from car park owners and others like them, but it was surprising coming from people who support sustainable transport and the goal of more liveable cities.
Some of them even said that they read the An Bord Pleanála planning inspector’s report, but a possible issue is that they didn’t read or pay enough attention to the Traffic and Transportation Assessment.
The inspector’s report with the backing of the consultant’s traffic report contains a huge amount of outdated thinking about how humans move in cities — for example the reports puts a heavy weight on motorised traffic but little care about cycling.
The motoring worries are in stark constraint how the planners dismissed cycling — including dismissing even the National Transport Authority when they said segregation was needed on Dame Street, and overriding the Dublin City Development requirement for contra-flow and provision to be made for the Greater Dublin Area Cycle Network (more on cycling details in another article).
The inspector’s report sounds authoritative, but the detail given in the Traffic and Transportation Assessment is often shaky at best.
One of the central reasons for rejecting the plaza by both the planning inspector and the board of An Bord Pleanála was that there were flaws in the National Transport Authority’s traffic model used to predict traffic flows after changes are made. However, the detail in the Traffic and Transportation Assessment which attacks the model is itself flawed, this includes this:
“To check further, I travelled the route on Thursday 26th April 2018 leaving Shelbourne Park at 17:52. I arrived at Heuston Station at 18:39 giving me a journey time of 47 minutes. The predicted journey time for the PM peak in the Do-Something scenario is 24.10 minutes (Table 3-10, P53 of NTA Report on RFI). The modelled journey times could not be accepted as accurate. The difference between observed journey times and those predicted by the model is extremely large, at 47 minutes pre-project as against 26 minutes post-project for PM peak (Table 4.1 Further Information Request Q No 4 page 45 and table 3-10 of NTA Report).”
Here we basically have an example of an attack on the baseline of the model times as if the model times aren’t based on an average. A model can’t do that and the model time outlined above is within the time range given by (the usually very accurate) Google Maps. There’s a major issue trying to debunk a model by using single trips taken by the author — all sorts of factors can impact on single trips and you can’t get an average from one single trip.
The traffic report further said:
“Heuston Station to Shelbourne Park was selected to represent journeys likely to be taken by someone either delivering goods or services from the general Inchicore / Ballyfermot area to the Sandymount/Irishtown area. The type of journeys I had in mind were those travelled by healthcare workers, tradespeople, delivery vehicles or people visiting friends or relatives and are instances where public transport, walking or cycling would not provide a suitable alternative means of travel.”
The author seems to think walking, cycling and public transport isn’t for visiting friends or relatives, and somehow healthcare workers also don’t use sustainable transport (the Mater hospital Smarter Travel programme starkly shows that’s not the case). And another problem is factoring in delivery vehicles at the time previously given at 17:52 — ie the middle of the evening rush hour where deliverers are not a priority, clearways are in effect etc.
A side note, here and it might only be a side note at this stage: The city is encouraging the development of last-mile delivery using cargo bicycles. Cargo bicycles are already in use by a number of local and international businesses — a growing trend not just in Dublin but around Europe. Where there are more traffic restrictions companies adapt.
The above looks fairly light on being pro-car until you keep reading — the whole picture builds the case of such. There was an attitude I could detect in the traffic report and that was confirmed near the end by this nugget:
“There are a number of traffic management schemes listed in the EIAR, but no new road space appears to be envisaged. Given the overall population projections for the Dublin Area and the projected increase of 40,000 crossings of the canal cordon in AM peak the next 6 years, it appears anomalous to expect that all increases in transportation demand can be dealt without any additional road space provision. I particularly note that in Section 2.5.5 of the NTA Report relating to the Core Radial Bus Network, reductions in road capacity within the model were predicted in areas where full bus priority could not be accommodated in reality. It is also difficult to reconcile the current (2018) accelerated house building activity with no major road infrastructure plans, given the predominance of houses being built in locations which are largely dependent on road transport.”
“Road transport” and “road capacity” here is to be read as motorised private road transport (ie mainly car traffic). The concern about buses expressed here is that the planned infrastructure upgrade of the bus network would result in “reductions in road capacity”. This is old-school engineering thinking — in cities we should look at people moving capacity:
As we have previously reported, the data for Dublin shows that the number of car users, which includes an estimate of drivers and passengers combined, crossing into the canals has decreased 15,156 people in 10 years and down 27,812 since 1997. At the same time the number of commuters overall across all modes combined has increased from 180,000 in 1997 to nearly 211,500 commuters.
For a former planner inspector hired as a consultant to suggest the city try to reverse this trend of not providing for new car traffic by some new major road building is not just strange but worrying as it goes against both national and local policy and the trends for more sustainable and liveable cities.
What has happened in Dublin is traffic evaporation at work — there’s now fewer cars but more commuters. There’s also more people living in the city centre and that number is going to climb higher too. But the traffic report was dismissive of traffic evaporation:
“The M50 was expanded to cater for existing congestion and provide for further traffic growth. The term ‘traffic evaporation’ was referred to on a number of occasions at the Hearing. While it is questionable if the concept of traffic evaporation is strictly appropriate in the case of College Green, the M50 is a prime candidate for the inverse effect, namely causing or facilitating ‘induced demand’…”
The problem here is that the author does not just rant about the well-established effect of car traffic evaporation he also got induced demand wrong. Induced demand in general terms is that as supply increases, more of a good is consumed — in road terms it basically means “that increasing roadway capacity encourages more people to drive, thus failing to improve congestion”. Citylab.com and Wired.com both explain it quite well in detail — it’s shown in academic studies and proven to happen over and over around the world.
The author expects more car capacity and he doesn’t understand induced demand. He then goes on further to state:
“My first inclination was to see the M50 not having a linkage with College Green. However, when one looks at journey planner apps one finds regularly that journeys which look like they should go through the city are routed via the M50. One recent search just after the PM peak showed Raheny Village to Heuston Station via M50 as 27 kms taking 30 minutes while a route using
Matt Talbot Bridge and the south quays showed 11 kms and 33 minutes. A second example, off peak showed Terenure to Ballymun Garda Station at 25.5kms and 27 minutes via M50 or 11.2 kms and 33 minutes via Church Street. That the M50 is even considered as an alternative or competing route in either example above should be of concern given that the M50 represents more than a doubling of the distance travelled and includes a toll.”
This pretty typically happens in cities all around the world which have ring roads and more so for those who have reallocated space inside their ring roads to make them more liveable places which are more effective at carrying more people by sustainable and active transport. But — the author claimed — we also can’t compare Dublin to other cities:
The problem with comparisons with other cities is that it is necessary to examine all aspects of the facilities being compared. In this respect I would consider the best example to take would be that of Oslo City Hall Square. This large square was pedestrianised in the 1990’s but that was not done until after the completion of the Festning Tunnel in 1990. Wikipedia states this tunnel runs under the City Hall Square and is 1.8 kms long with a total of 6 lanes.
Such tunnel building is often cited when relocating of street space is discussed, but it is rare for sustainable cities to be still planning such tunnels today — the thinking has generally moved on.
Utrecht are now reducing road capacity for cars and providing no alternatives besides the already congested ring road motorway. Amsterdam provided a car tunnel under an expanded section of its central train station but more recently it has chosen to cut off other east-west traffic routes in the city centre with no alternative driving options (for the record, the city’s new metro line serves a different direction, north-south).
The traffic reports notes large roads besides Copenhagen’s town hall square which was used as an example. Dublin City Council and the NTA would do well to stop referencing Copenhagen so much — Dublin’s road network or more so the problems with space and the issues of relocating space are more comparable to that to cities like Amsterdam or Utrecht. Museumplein in Amsterdam or similar spaces in the Netherlands would have been better examples.
Paris is doing a similar reallocation of space and there is no sign that it is adding to its underground public transport at any kind of similar capacity, and even Paris suffers from people saying public transport isn’t good enough in my area yet. Paris is doing that to some of its bigger roads. Meanwhile, Utrecht has fewer big roads and it is cutting space for cars on them — more space for greenery, walking, cycling and generally people.
Like Dublin, these cities have achieved and are expecting more modal change from cars to walking, cycling and public transport.
So, it’s in this kind of mindset the report should be read when it states:
“As Parliament Street featured prominently during the Hearing, I looked at the traffic predictions for the immediate area. The prediction for Parliament Street shows a reduction in AADT for the north end of the street to 2,830 from 7,165 as per Table 6.3, EIAR. Given that between 700 and 1500 additional buses will use the street it would appear that general traffic of the order of 5,000 AADT will be displaced from Parliament Street under the scheme as all non-public transport will be banned from 7:00 am to 7:00 pm. To put this figure in context, there is at least one completed motorway section in Ireland where AADT figures of 6,000 were estimated at approval stage. The question arising from the 5,000 AADT drop in traffic is where that traffic will relocate.”
The same thing will happen as has happened when the city had the introduction of Grafton Street pedestrianisation, bus lanes, Luas, the College Green Bus Gate, etc etc — that is to say, there was car traffic evaporation.
Worryingly the author says that “there would be concern that there could be negative impacts on Capel Street, from where much of the displaced traffic would appear to emanate” — this shows a lack of understanding that little traffic actually emanates from Capel Street, the street is not a main road, thus it is effectually a city centre rat run with very little of the traffic using the street having any business on the street.
There was also concern expressed that footpaths on the quays could not accommodate the extra bus stops — there are two presumptions that seem to be at play: (1) that the quays would be the only bus stops people who currently use College Green / Dame Street would switch to as to get to College Green — this is deeply flawed as many bus users coming from different directions would likely disembark before coming to the quays (ie at Dame Street beside City Hall, at George’s Street, etc), and (2) that footpaths cannot be widened when the realty is footpaths can be widened and decluttered (and still provide for buses and the Liffey Cycle Route). It was within the planner’s powers to make wider footpaths a condition of the project.
The An Bord Pleanála inspector’s recommendation and board’s direction — as we reported here — is all coloured by the transport analysts which is old-school thinking which dismisses basics in sustainable and active transport planning.
The possible traffic impacts of the proposed development was the first point given by the inspector and the board for the rejection, this was dressed up as a traffic modelling issue when no model can give the details and certainly the planners were looking for.
The flawed thinking about the impact on buses only came second and the impact on pedestrians on the quays came third, when it was solvable and should have been balanced with the overall massive positives for pedestrians.
Dublin City Council could have been clearer on a number of issues but the main reason that College Green was not approved was flawed thinking from planners and the board of An Bord Pleanála — thinking which would put a stop not to just the plaza but any changes like it which might have knock-on impacts. Combined, the planners and board failed on their lack of understanding of how sustainable cities look to move people not car traffic, how traffic works, how models work and how change has happened. They have also failed to have vision.
If the city or any city followed An Bord Pleanála’s thinking there would be never any progress on plazas, bus lanes, tram lines or cycle routes. Cities would be paralysed and forced to stick to the status quo.
Subscription drive update: IrishCycle.com reached its target of 270 subscribers by the end of August -- thank you to all who have helped! Our new target is to have 300 subscribers by the end of 2022 -- originally this was hoped to be exceeded by the first year of running the site full time (end of October).
If you can help push IrishCycle.com above 300 subscribers, please subscribe today for €5 or more. If you have already done so -- thank you!
Please remember, every month there's a natural drop-off in subscriptions due to people getting new cards, cards stolen, Revolut not topped up etc.
IrishCycle.com is a reader-funded journalism publication. Effectively it's an online newspaper covering news and analyses of cycling and related issues, including cycle route designs, legal changes, and pollical and cultural issues.
There are examples, big and small, which show that the reader-funded or listener-funding model can work to support journalism -- from the Dublin Inquirer and The Guardian to many podcasts. To make it work for IrishCycle.com, it just needs enough people like you to believe!
Monthly subscriptions will give IrishCycle.com's journalism a dependable base of support. But please don't take free access for granted. Last year IrishCycle.com had an average of 15,800 readers per month and we know our readers include people who cycle and those who don't, politicians, officials and campaigners.
I know only a small percentage of readers will see the value of keeping this open enough to subscribe, that's the reality of the reader-funded model. But more support is needed to keep this show on the road.
The funding drive was started in November 2021 and, as of the start of June 2022, 250 readers have kindly become monthly subscribers -- thank you very much to all that have!
But currently, it's only around 1.6% of readers who subscribe. So, if you can, please join them and subscribe today via ko-fi.com/irishcycle/tiers