Martin Roundabout Upgrade

Here’s our submission on the Martin Roundabout (Galway Clinic Roundabout) Upgrade Statutory Public Consultation which took place in Summer 2019. This project has been funded by the Urban Regeneration and Development Fund – over €2m. of tax-payer’s money, so we want to be sure it achieves its stated goals of “provision of public transport priority measures, provision of cycling facilities and associated pedestrian enhancements and traffic calming measures.

In short, while removal of the roundabout was a positive step, given the nature of the motor traffic volume and speed at this location, the initial proposals need to be improved quite a lot to make this a cycling and walking friendly junction. There is also huge potential to provide and link with cycling and walking facilities in the periphery of the junction as part of these works, but this seems to have been overlooked.

We’re awaiting the details of the next design stage and will hope to input on further designs details as they emerge.

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Cycling is Normal: Make it Better and Safer

More and more cyclists are on our roads, choosing a faster, cheaper and independent transport option for moving through our cities and towns. The upswing of more people cycling are reduced congestion, cleaner air, and healthier people. Over half of short journeys (less than 2km) are by car in Ireland. We want more people to feel better and safer about switching to bikes. We have 10 Asks for our general election candidates. Here’s our summary.

1 CYCLING NEEDS TO BE A NORMAL EVERYDAY ACTIVITY

Cycling is a critical part of the transport equation in combating Climate Change.  We need everyday cycling to be better and safer, more convenient, and easier. Hopping on your bike should be a more attractive option for the so-called first-mile and last-mile journeys.

No more slashing of funding or paltry rises: major investment is needed to shift people away from car dependency, especially for short journeys under 5km.  This means greater investment in cycling infrastructure and promotion. 

We need our next Government to allocate a minimum 10% of Transport Funding to cycling immediately, as promised under the National Climate Action Plan.  Currently, cycling is allocated a tiny 2% of our transport spend.

We do not need to reinvent the wheel. Bike safety is highest in countries and cities where bike use is high and people cycling have interconnected networks of segregated routes. Seville, Leeds, Manchester show it is possible to apply the lessons of the Netherlands and Denmark.

2 ELIMINATE THE NEED FOR CYCLE BUSES – BUILD SAFE  SEGREGATED NETWORKS

Manifestos that mention school cycle buses should make us weep with rage. There should be no need for parents and adults to marshal kids to school on bikes, forming human shields between small soft bodies and big, motorised, metal boxes. Cycle buses must not become the norm.

What we need are safe routes to schools and throughout populated areas: networks of segregated cycle paths along roads; safe junction design with priority signalling for people on bikes; and quiet routes through permeable neighbourhoods. This applies to county towns and villages as much as our cities.

Let’s get designing and building.

3 FIT FOR PURPOSE PLANNING, POLICY AND POLICING

The 3 Ps of Planning, Policy and Policing seem a little dry at first glance – but these are the actions that make the good things happen.

Planning  – Building safer cycling infrastructure should be guided by our National Cycle Manual. This design guidance needs urgent updating to upgrade our standards and bring us into line with best international practice.

Policy – We need joined-up thinking for everyday cycling across the myriad of Departments: Transport Tourism and Sport, Health, Environment/Housing, Education, and Justice. We need a resourced National Cycling Office, preferably within the Department of Transport, Tourism and Sport, to coordinate policy, and ensure action.

Policing – We have road traffic legislation that considers people who cycle and walk, but enforcement needs greater priority. People who cycle are frustrated and frightened by illegal parking in cycle lanes and dangerous overtaking. The Garda need to learn from their UK counterparts.

IT’S AS EASY AS ABC

Increasing cycling numbers in Ireland will cut congestion, improve public health, and reduce pollution.

To get more people cycling, we need to make it an easier and safer choice. Let’s have real Cycle Networks, Safe School Routes, and coordinated Planning, Policy and Policing that protects us.

It’s as easy as ABC: Allocate 10% of transport funding to cycling; Build safer infrastructure, and everyone will Cycle more.

WRITER
Martina Callanan, project manager, is the representative of Galway Cycling Campaign on Cyclist.ie, the Irish Cycling Advocacy Network.

ABOUT US
Galway Cycling Campaign is the voice of everyday cyclists in Galway. We want to make Galway cycling-friendly. 

Cyclist.ie, the Irish Cycling Advocacy Network (ICAN) is the federation of Cycling Advocacy Groups Greenway Groups and Bike Festivals on the island of Ireland. We are the Irish member of the European Cyclists’ Federation

Our vision is that cycling will be a normal part of transport and everyday life in Ireland.  Cycling is a vital part of building  healthier and less polluted communities. Check out our 10 Election Asks.

Galway Bike Parking Map

This is our Galway City Bike Parking Map, showing location, type and number of spaces of all publicly available bike parking.

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 info@galwaycycling.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.

Government’s new €53 million Greenway Strategy appears to be inherently unlawful

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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

Strategy Launch 20 July 2018 Ministers Launch the Strategy for the future development of National and Regional Greenways

Ross and Griffin issue call for €53 million funding for Nationwide Greenways

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.

Directive 2014/52/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014

(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.

COM(2011) 571 final Roadmap to a Resource Efficient Europe

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: City council sparks anger with cycling “ban” at Lough Atalia

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.

 

Conclusion

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?

 

Sources

  • 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

South Kerry Greenway: Council planning application to An Bord Pleanála does not comply with EU Environmental Impact Directives

Final_GCC_logo_7_06_2010Campaign submission argues planning board should reject application and order new Environmental Impact Assessment Report.

In August Kerry County council made an application to An Bord Pleanála for the so called South Kerry Greenway running roughly parallel to the N70 national route for 30km between Glenbeigh and Cahersiveen/Reenard on the Iveragh peninsula.  To achieve their proposed design, the county council propose to acquire by compulsory purchase order (CPO) sections of the abandoned Valentia railway.  This railway was abandoned in 1960, the rail lines lifted within two years, and much of the land sold or transferred back to the farmers along the route.  The misguided and unhelpful conduct of some recent “greenway” projects by local authorities has been hugely damaging to the brand of cycling and created needless acrimony between farming and cycling interests. The South Kerry scheme could set a positive or negative national precedent.  If conducted incorrectly, it could set the national farming community in opposition to greenway projects for a generation. The Galway Cycling Campaign wishes to avoid this outcome and has made a submission to An Bord Pleanála.

A central problem identified with the Kerry County Council planning application is an apparent failure to comply with EU directives on environmental impact assessment. 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.

In the Environmental Impact Assessment Report (EIAR) the alternatives given are as follows –

  1. On-Road Route Option – construct a roadside cycle track within the N70 – which will involve significant engineering works
  2. Abandoned Railway Line Route Option – much of which is in private ownership and which will involve significant engineering works
  3. New Greenfield Route Option – which will involve significant engineering works
  4. Do-Nothing Route Option

The published EIAR does not appear to include commonly accepted alternatives recommended by the applicable policy frameworks. The EIAR consultants make no apparent mention of using minor country lanes or boreens. This option if available could involve little engineering and would be less environmentally damaging than any of the proposed works in the EIAR.

The guiding policy source in this instance is the 2009 National Cycle Policy Framework (NCPF).  Under Ministerial Circular PSSP 8 – 2010 the NCPF is a national policy under the terms of section 9(6) of the Planning and Development act regarding development plans.  Objective 3 of the NCPF provides for a national cycle network that may include greenways and disused railway corridors but also makes extensive use of minor roads.    The NCPF references the 2007 Fáilte Ireland Cycling Strategy, which proposed an Irish Cycle Network using “the network of country lanes and roads throughout the country. These roads have been chosen where traffic levels are light and lanes have a line of green grass up the centre“.

We find no discussion of this option – even to dismiss it – in the EIAR.

Other countries make extensive use of minor country lanes to provide long distance cycling routes.  The South Kerry Greenway is supposed to be a component in EuroVelo 1 the Atlantic Coast Route.  We have discussed the Eurovelo guidelines previously in relation to the problematic Dublin Galway Greenway proposals. Tourist cycling routes should be kept well away from heavy traffic but they do not need to be completely traffic-free. Across Europe cycling tourists and family groups make extensive use of low-traffic roads as part of local and national cycle networks.

This model is not simply a matter of passively finding roads that match the criteria. Local authorities will actively manage minor rural roads to reduce and divert inappropriate motor traffic and provide for walking and cycling.  There is no legal impediment to doing the same thing in Kerry.

The ordnance survey map shows a range of minor roads on the Iveragh Peninsula that might form part of the proposed route.  Possible options can also be found using Google Streetview.    CPO is an intervention that is not be treated lightly and the requirements of natural justice must be seen to be followed.  If the use of obvious alternatives is not dealt with in the current EIAR then it will have to be dealt with at any oral hearing.  Any such discussion at an oral hearing may be incomplete and will happen without formal prior consultation with affected parties along the alternative routes.  This reinforces the need to reject the current application and require a new EIAR that reflects the relevant EU and state policies.

Google street view screen grab showing a country lane near Glenbeigh and running towards Cahersiveen

Google street view screen grab showing a country lane on the route between Mountain Stage and Cahersiveen.  Local farmer on his bike courtesy of Google street view.