Submission made to Galway City Council on their draft Public Realm Strategy.Galway-Cycling-Campaign-Submission-Galway-Public-Realm-Strategy-Sep-2019
Data has been collated by members of the Galway Cycling Campaign, and can be contributed to by members of the public, by leaving a comment below ⇓ or emailing firstname.lastname@example.org.
If possible, provide the following information:
- Type of bike parking? Is it a Wheel Gripper, Sheffield Stand, Sheffield Toaster Stand.
- Exact location.
- The number of spaces/stands provided.
- Is it covered or not? Does it have shelter from the elements.
- A picture would be great. It can give so much information.
Please also let us know if bike parking is removed from or upgraded at any location.
Please allow a while for map to load…
Explanation: what’s all this?
As part of Census 2016 everyone in Ireland on Census night had where they live along with the location of their workplace, school or college recorded and processed. These data, along with people’s primary mode of transport (and other demographics) have been made publicly available on a neighbourhood-level.
Here we have mapped these data at a neighbourhood level in and around Galway City. This shows each area by the levels at which people begin their trip by bike to work or education (by origin). This can be displayed as the total number or as the percentage in a neighbourhood. We also show areas which are the destination of peoples journey to work or education by similar summaries.
Other data include the total numbers of people travelling from an area to work, school or college, or travelling to an area. The percentage of households which have access to a car/van, can also be displayed.
Each location is clickable with more information, including the proportions of “Active transport” (walking and cycling) and “Private transport” (driving or being driven in a car/van/other private vehicle).
Example of how to read the map
In this example we choose checkbox
- ‘Cycling to destination (%),
- In the resulting map can see that area marked 2 is the darkest shade.
- This means that Salthill Village has the highest percentage of all trips to Salthill by Bike in Galway City.
- This does not mean that Salthill has greater numbers cycling to it as a destination compared with Galway City Centre, it just means as a percentage of all trips it has a greater proportion relative to other modes.
- The elipse shape(marked in light yellow) shows Galway Golf Club Course. So pretty obvious no Galway Golf Club Golfers take the Cargo Bike to the Golf Club :¬)
Your journey, your story?
What about where you live or where you work or go to school? Are they cycling hot-spots or cycling deserts? Let us know what it is like to cycle your daily journey in the comments, or get in touch via email (email@example.com) and maybe we could profile your neighbourhood? Could the cycling infrastructure be improved (yes, of course it’s Galway!) and if so how?
On your bike
Free social leisure rides for adults of all ages. Looking for a reason to get back on your bike? Here’s your opportunity. Follow your leader, meet new people, get some exercise and socialise in a small, local group.
Sign up to Galway events, led by Dan Clabby:
- Huntsman to Oranmore and back (Friday evening) (26/07/2019) 17:00pm
- Huntsman to Oranmore and back (Sunday) (28/07/2019) 12:00noon
- Huntsman to Oranmore and back (bank holiday monday) (05/08/2019) 12:00noon
These will start at ‘Hunstman’ via Lakeshore dr, Dun na mara dr, Hawthorn dr (stop a few seconds for sea view), Fucsia dr, Ballyloughane rd, Murrough ave, Lurgan pk, Lois an uisce, Murrough dr. Stopping for halfway refreshment break at Galway Crystal (or Norios if evening event) … Continuing on Rosshill rd, Old Dublin rd, Coast rd R338 hard shoulder, and all the way through Oranmore main st. to ‘Brazzco coffee’ above Lidl (or BASILICO if evening event) for a light snack before returning to Hunstman by the same route.
More trips will added over the coming months.
Sign up to participate
Find out more…
Background: the Greenway controversy and the new strategy
The recent conduct of various “Greenway” projects by the Department of Transport, Tourism and Sport has been extremely controversial and has generated unneeded conflict. In Galway, the main source of the difficulty has been a switch by state actors to treating greenway provision as exclusively involving the construction of new roads, mainly through working farms. This is either new roads along disturbed ground such as the long abandoned and now privately owned Clifden railway alignments. Alternatively, in East Galway the proposed new roads are to be constructed along new alignments through open farmland. Previously there had been an acceptance that in accordance with national policy, minor country lanes could also form part of greenway networks. Predictably this “build new roads” approach has generated serious conflict and acrimony. Out of this acrimony “Galway Cycling Solutions” was formed as a coalition of cycling and landowner interests. In January 2017 a delegation from Galway Cycling Solutions and farm organisations met Minister Shane Ross and Junior Minister Patrick O’Donovan to raise concerns. The delegation was informed a new process was to be developed. A consultation on a new Greenway Strategy was announced in May 2017 and received detailed submissions from interested parties around the country including the Galway Cycling Campaign. In July 2018 the Government published the resulting Greenway strategy document. In September 2018, this was followed with a €53 million funding call. If the Greenway Strategy had been circulated as a draft for discussion it would be a welcome step forward. As it stands the final document is flawed, seems to promise more conflict with landowners and the proposed strategy seems to be inherently unlawful under EU and national law.
The strategy document does make an attempt to appear reasonable and to take into account various issues that were raised during the strategy consultation.
- There is talk of consultation with stakeholders – although there are apparent problems that are outside the scope of this article.
- Issues for farmers are acknowledged such as avoiding severance and following boundaries instead of splitting fields, a need for accommodation works and to maintain access for motor vehicles on sections of greenway
- The authors acknowledge the Eurovelo guidelines and the use of low traffic roads (but the discussion is misinformed)
- The discredited NRA National Cycle Network scoping study is dropped (which is good, but what is replacing it – a greenway system of new roads – is not adequate)
Picture: Section of the old Clifden road near Derryneen, In 2012 the county council accepted that this could be used as part of the western section of the Clifden Greenway. Then something seems to have changed and minor country lanes became unacceptable to the council for subsequent greenway proposals.
A continued focus on building new roads
A central problem remains an apparent focus on the construction of new roads. In the published strategy the authors use the words like “built” or “construct” where a credible and environmentally defensible strategy document would use words like “designate”, “adapt”, “create”, “provide” or “develop”.
Page 6: Objectives First paragraph: “The objective of this Strategy is to assist in the strategic development of nationally and regionally significant Greenways in appropriate locations constructed to an appropriate standard in …”
Page 7: What is a Greenway? third paragraph: “Greenways funded under this Strategy will be built following …”
Page 13: Public Consultation Process, third paragraph: “… the plan to construct a Greenway will intensify the use of that land and … “
Page 13: Land Access for Greenways: “… there are significant amounts of land in State ownership around the country that are suitable for the construction of Greenways or sections of Greenways …“
Page 14: Permissive Access, second paragraph: “… with the sponsoring agency or local authority that has paid for the development and construction.”
Page 14 Land purchase: “… it is anticipated that voluntary agreements would be entered into to sell the small sections of land required to construct the Greenway…”
Page 14 Accommodation Works: “It is recognised that a proposal to construct a Greenway route through or adjacent to private land …”
Page 16 Impact on Agriculture and Rural Areas; fifth paragraph: “While there are risks associated with any construction near farm-holdings, the development of a Greenway …”
Page 18 Greenways and the Environment: “Greenways must be planned and constructed in compliance with the requirements of Irish and European law including, but not limited to, EU Directive 2014/52/EU.”
Page 20 Page title “Post construction”
Page 23 Other Cycling and Outdoor Recreation Infrastructure: First paragraph: “Whilst this Strategy concerns the construction of strategic Greenways there …”
The authors do acknowledge the Eurovelo guidelines and the use of low traffic roads. However, the authors appear to frame this as something that is mainly suitable for experienced cyclists which suggests the authors have an incorrect understanding of cycling policy and cycle route provision. As our submission pointed out, there are numerous locations across Europe where low-traffic roads provide a family friendly and child friendly cycling environment serving inexperienced cyclists. Furthermore the use of low-traffic roads is a key component in Objective 3 “Provide designated rural signed cycle networks” of the 2009 National Cycle Policy Framework. The Greenway Strategy does not seem to mention the National Cycle Policy Framework at all – which many might find very curious omission. Instead the published strategy seems to frame low traffic roads only as a way of linking the new roads constructed as “greenways” to other destinations or as an alternative network for “experienced” cyclists. The discussion of low traffic roads is passive and mentions traffic calming and speed limits but not the active creation of low-traffic environments. (The traffic calming methods mentioned “road narrowing, chicanes” are often hostile to cyclists and therefore do not inspire confidence in the understanding of the strategy authors). In relation to the new roads that are to be built under the strategy, the authors acknowledge that limited access for motorised vehicles will need to be maintained for landowners and maintenance vehicles. However, this seems to be only by way of responding to farmers concerns. The opposite to this, that restricting motor vehicle access to existing roads is a standard way to create a greenway experience, is not discussed. Like the discredited National Cycle Network Scoping study the latest Greenway Strategy document reads like something that was put together by roads engineers for the purpose of justifying particular types of roads works. It seems that the main goal is to spend significant funds on building new rural roads rather than being focused on delivering our national cycling infrastructure in the fastest, most sustainable and most resource efficient manner. At the July launch of the strategy, and in a subsequent funding call the Minister for Transport, Tourism and Sport, Shane Ross and Minister of State for Tourism and Sport Brendan Griffin stated that the strategy is backed by a fund of €53m for the years 2019 to 2021
The legal situation: EU Directive 2014/52/EU
On page 18 the strategy authors specifically reference EU Directive 2014/52/EU. Directive 2014/52/EU is the latest version of directive 2011/92/EU “on the assessment of the effects of certain public and private projects on the environment”. The objective of the directives is not merely to ensure projects are carried out in a manner that protects the environment. But to ensure that “Effects on the environment should be taken into account at the earliest possible stage in all the technical planning and decision-making processes”. Any project may have an environmental impact purely through the manner in which it consumes resources. There is also an associated EU communication “COM(2011) 571 final Roadmap to a Resource Efficient Europe” which commits to the efficient use of resources and to the principles of sustainable development. (See below for relevant sections). These directives are transposed into Irish law under regulations such as the European Union (Planning and Development)(Environmental Impact Assessment) Regulations 2018 (S.I. No. 296 of 2018).
As adopted into Irish practice and Irish planning law, there is a requirement for a developer to commission an Environmental Impact Assessment Report (EIAR) as part of the planning process. This report must include an assessment of reasonable alternatives that achieve the goal of the project. The environmental impacts of these alternatives must be compared. The intent is that a project with the least impact and most sustainable use of resources can be found. An EIAR is a key part of the planning process for projects such as new roads. When the National Planning Board “An Bord Pleanála” holds a hearing on a project is perhaps better thought of as being a hearing into the EIAR report rather than simply the project in isolation.
Conclusion: the 2018 Greenway Strategy is contrary to EU and national law.
The published Greenway Strategy does not reflect key areas raised during the consultation process. The latest Greenway Strategy document is focused on constructing new build roads as “greenways”. It acknowledges that motor vehicle access might be permitted to these greenways but not the opposite; that restricting motor vehicle access is an effective, established, way of creating a greenway-like experience on existing local roads. For local roads the strategy merely refers to traffic calming rather than roads management or traffic restriction and diversion. The document acknowledges that low traffic local roads have a role in cycling networks but frames this merely providing links to the greenways (new rural roads) constructed under this strategy.
Therefore the apparent effect of the Greenway Strategy is to direct local authorities to propose schemes that involve building new roads through lands as a direct alternative to adapting existing features that already have an established value as cycling infrastructure. In effect this seems to be an instruction to propose projects that have higher environmental and resource impacts as an alternative to those that have lower impacts.
This suggests that the Greenway Strategy is contrary to EU law on environmental protection and for many locations planning applications framed on the basis of the Greenway Strategy will be inherently unlawful under EU directives on the environment and hence unlawful under the Irish planning regulations.
References and background reading
S.I. No. 296 of 2018 – European Union (Planning and Development)(Environmental Impact Assessment) Regulations 2018
The 2018 Guidelines for Planning Authorities and An Bord Pleanála on carrying out Environmental Impact Assessment state as follows:
Reasonable Alternatives: 4.12. The Directive requires that information provided by the developer in an EIAR shall include a description of the reasonable alternatives studied by the developer. These are reasonable alternatives which are relevant to the project and its specific characteristics. The developer must also indicate the main reasons for the option chosen taking into account the effects of the project on the environment.
(7) Over the last decade, environmental issues, such as resource efficiency and sustainability, biodiversity protection, climate change, and risks of accidents and disasters, have become more important in policy making. They should therefore also constitute important elements in assessment and decision-making processes.
(8) In its Communication of 20 September 2011 entitled ‘Roadmap to a Resource Efficient Europe’, the Commission committed itself to including broader resource efficiency and sustainability considerations in the context of the revision of Directive 2011/92/EU.
3.1. Sustainable consumption and production 3.1.1. Improving products and changing consumption patterns Changing the consumption patterns of private and public purchasers will help drive resource efficiency and can also frequently generate direct net cost savings. In turn it can help increase demand for more resource efficient services and products. Accurate information, based on the life-cycle impacts and costs of resource use, is needed to help guide consumption decisions.
5.3. Ensuring efficient mobility A modern, resource efficient mobility system, serving both passengers and freight can contribute significantly to competitiveness and sustainability. The Transport White Paper24 puts forward a wide range of options for pursing the required holistic transport policy.
Milestone: By 2020 overall efficiency in the transport sector will deliver greater value with optimal use of resources like raw materials, energy, and land, and reduced impacts on climate change, air pollution, noise, health, accidents, biodiversity and ecosystem degradation.
Coke zero controversy continues as Council, Coca-Cola and NTA uses new bike scheme station as another opportunity to treat Galway people on bikes with disdain
The Cycle Campaign originally welcomed the news that a public bike scheme was coming to Galway – the expected implementation of the Jacobs report promised to be a step change for cycling in Galway with one-way streets finally reverting to two-way use for cyclists. Instead The Coke-zero bike scheme has not brought a universally happy time for cycling. In a move that seemed calculated to cause offence, and succeeded in that apparent aim, already scarce bike parking was removed to make way for public bike stations. Bike stations that were to replace car parking were dropped. One-way street restrictions continue to be applied to cyclists in a snub of the legal changes brought in by Galway TD (and Minister of State) Bobby Molloy in 1998. On Lough Atalia Road some time in early 2018, apparently in conjunction with the construction of badly needed new bikeshare station at the playground, road signs went up “banning” cycling on the seaside path.
Clearly unless legally permitted it is an offence to cycle on a footpath (or footway in the traffic regulations). However should it be illegal to cycle on this particular path at Lough Atalia? First off shared use paths (pedestrian/cyclist) along roads can be problematic and in our culture are seen as something to be avoided. At Lough Atalia the seaside path itself is quite wide and much of the pedestrian traffic seems to stay on the city side of the road thus reducing potential conflicts. Also with a coastal path like Lough Atalia most pedestrians are moving along the path on a linear track – there are few crossing movements – so a type of conflict that arises at other locations is rarely present. Many otherwise confident road cyclists were in the habit of switching to the path if going or coming to Renmore. Lough Atalia Road itself is not a nice place to cycle – it is the main access route for the docks – but is possibly slightly better than some alternatives (Sean Mulvoy Rd beats it in the nastiness stakes for people trying to cycle to the east of the city)
Figure: picture of one of the new signs on the Lough Atalia Path. At this point the path is 2.9m wide
The use of roadside cycle paths or “cycle tracks” can also be problematic for people on bikes when it comes to junctions particularly if the junction treatments ignore the presence of cyclists and try to maintain convenience for motorists. Two-way cycle paths or paths that attract two-way use can be particularly problematic with the “wrong-way” cyclists at much higher risk of collision with turning motor vehicles. One exception to this rule however is if you are following a feature such as a river bank, canal tow path or a coastal route. These types of route have reduced junction conflicts and are ideal for two-way use. One successful example in Ireland is the Grand Canal cycle path in Dublin which has traffic lights for the cyclists where it meets roads crossing the canal. In Galway there are limited sections of coastal cycle path at South Park and behind the Golf Club between Black rock and Gentian Hill. One section of de-facto coastal cycle path was the seaside path at Lough Atalia which connects with paths leading to Lakeshore drive in Renmore and is a handy low-traffic route into the city from Renmore/Mervue and the GMIT (or vice versa).
Figure: The new bike share station. There is a playground to the left. Apparently bike share users and children are expected to cycle on the main road, which is also the main traffic access route to the Galway Docks.
What does design guidance say?
So what does design guidance say about using a path like this as a cycle route or a connection in a cycle route? The NTA publishes a cycle manual that has some problems but is an obvious reference (the NTA are part funding and overseeing the scheme). Working off their “width calculator” we can get a figure of 3m for a two-way road side cycle track. Transport Infrastructure Ireland also publish a manual for rural cycle ways. For low volume cycleways this has a desirable minimum width of 3.0m but provides “steps” down of 2m and 1.75.
Figure: Extracts from NTA (top) and TII (bottom) guidance on width for cycle facilities
In the UK Local Transport Note 02/08 “Cycling Infrastructure design” has this to say for roadside shared use.
8.5.3 Where there is no segregation between pedestrians and cyclists, a route width of 3 metres should generally be regarded as the minimum acceptable, although in areas with few cyclists or pedestrians a narrower route might suffice.
In the Irish NTA cycle manual there is also diagram that shows 4m for two-way roadside cycle tracks – 2m in each direction so lets treat this as a target level of service.
Figure: Extract from NTA cycle manual
How wide is the actual seaside path at Lough Atalia?
At the playground/bikeshare station where we find one of the “no cycling” signs, the path is 2.9m wide. For a long section it narrows to 2.7m and at one point there is a small parking bay where the effective width is 86cm (the width needed for a door into a wheelchair accessible toilet is 90cm). Down near the Galmont (ex-Radisson) hotel the path is 3m wide before the road splits into stacking lanes for the traffic lights at Fairgreen road. At the pedestrian crossing the width is 1.97m.
Figure: The Lough Atalia Path, at this point the path is 2.7m wide it varies from 3m to 2.9m with one pinch point at a parking bay.
Figure: The parking bay pinch point – the path here is 86cm. The strategic value of this feature is open to question.
The City Development plan 2017-2023 already shows an indicative cycle corridor going around Lough Atalia. Casual observers who perceive the Lough Atalia path to be already “ok” or “nearly ok” for two-way cycling/shared use could feel that they have support from official guidance. It is also clear that very little work would be needed to make the route conform to “best practice” with 2m lanes in each direction. Theoretically add a 1.3m concrete strip and the job would be done. There is clearly land available for this option. (There would still need to be an assumption that faster “roadies” would use the road and any seaside path would not be convenient for people aiming to cycle to Moneenageisha and on to the Monivea road/Ballybrit.)
Despite this, in apparent defiance of available design guidance, and while putting in a bike share station, the City Council, Coca-Cola and the NTA between them decided to formally ban bike share users and other people on bikes from using a very obvious and established feature for accessing the city. As with other council activities associated with the Coke-zero scheme the reaction has been seething anger from many regular users of the route.
Doing something about it.
The Galway Cycling Campaign is forming a specific action group to look at the issue of a coastal cycling route from Oranmore to Barna. If this is an issue that affects you then why not become a member and get involved?
- NTA Cycle manual https://www.cyclemanual.ie
- Rural Cycleway Design (Offline) TII Publication Number: DN-GEO-03047 Date: April 2017
- Local Transport Note 02/08 Cycling Infrastructure Design