2009-07-31 QBC Consultation - Huntstown

On 31st July 2009 Dublin Cycling Campaign submitted this response to the QBN Office's public consultation on the new QBC at Huntstown Way in Blanchardstown

sites/dublincycling.com/files/users/12/2009-07-31-QBC_Consultation_Submission-Huntstown.pdf

Thanks to Colm Moore for reviewing these comments and taking photos on site. Please forward any comments you might have.

James Leahy, 31/7/09

 
1    Executive Summary
1.1    Introduction
Dublin Cycling Campaign’s comments on the consultation have been guided by the National Cycle Policy Framework (Department of Transport 2009) and Cyclist.ie’s (2008) National Cycling Promotional Policy: Achieving a Cycle Friendly Ireland. This calls for a hierarchical approach to the consideration of measures to address cycling, encompassing the classic three ‘E’s: Education, Enforcement and Engineering.
We pledge ourselves to a collaborative approach and would like to work with the QBN Office and Fingal County Council to deliver a better result for transport modes that tread lightly on the environment. We believe our experience has something to offer and we look forward to meeting with you. Doubtless there may be a small number of situations where, having worked with you, it is impossible to achieve a solution we are happy with. In such situations, should they exist, we will request detailed formal justification from the QBN Office / Fingal County Council. However, we believe this position does not take from the need to engage and exchange in the first instance.
We recognise that much has been learnt since the QBC programme began in 1997 and we notice real improvements in the design and implementation of newer QBC’s such as the Coombe Bypass and Mc Mahon Bridge. We hope that we can build on this progress through partnership with the QBN Office and Fingal County Council.
1.2    Education
•    We call for the QBN Office / Fingal County Council engineers who are designing the proposals to meet with us and cycle the routes so that we can each learn from each other’s experiences.
•    We propose that a leaflet similar to the one in Appendix ‎A5 be created jointly by all stakeholders to educate drivers and cyclists about interaction in bus/cycle lanes.
1.3    Enforcement
On completion of any proposed works we call for a multi-agency campaign of enforcement which will concentrate in particular on:
•    Speeding in the city
•    Dangerous overtaking within bus/cycle lanes
•    Illegal parking in bus lanes.
1.4    Engineering
Proposed measures to address cycling should be considered in a hierarchy as proposed in Cyclist.ie’s (2008) National Cycling Promotional Policy and Policy 2.1 of the Department of Transport’s (2009) National Cycle Policy Framework. The particular issues have been summarised according to this hierarchy below:
1.4.1    Traffic reduction
•    We strongly welcome this comprehensive reallocation of road space from general vehicle lanes to public transport and cyclists. This in itself will reduce the amount of space allocated to traffic.
•    We call on Dublin Bus and the Department of Transport to redesign Dublin Bus’s network and information and provide high quality high frequency bus services to further reduce traffic in the city.
•    We call for a multi-agency review of how taxis operate in the city. Dublin Cycling Campaign has no position on the regulation of taxis. We do however stress that the current situation whereby the city streets are clogged up with empty taxis looking for fares is untenable for all road users including taxis, buses and cyclists.
1.4.2    Traffic calming
•    We call for a 30 kmph speed limit on all these urban routes.
1.4.3    Junction treatment and traffic management
•    We welcome the removal of roundabouts and their replacement with urban style signalised junctions.
•    The design generally fails to address pedestrian and cyclist permeability at junctions.
1.4.4    Redistribution of the carriageway
•    The general concept of redistribution of space from general vehicles to bus/cycle lanes is to be commended.
•    However the practice in these proposals is completely unacceptable. A route which is currently reasonably well designed, compared to current practice, will end up with a very poor off-road cycle track leading to the “pedestrianisation” of cyclists.
•    Alternative solutions have been offered. There is a need to step back and look at the bigger picture. We are spending approximately €33 m per km to build Luas lines with almost no provision for cycling. Meanwhile we are building substandard QBC’s with substandard provision for cycling for an average of approximately €3 m per km. Both figures include infrastructure, vehicles and depots (Nix 2004) and both systems have a similar route capacity. There is space available and solutions available to design this route properly for cyclists, buses and pedestrians. We need to spend the relatively small amount of money that a proper solution would require and design it to best practice. It is a false economy to continue spending money on substandard facilities. Lastly Policy 2.7 of the National Cycle Policy Framework says that the Department of Transport (2009) will not support any further cyclists unfriendly schemes before they are designed to new guidance.
1.4.5    Cycle lanes, cycle tracks and cycle ways
•    The proposal to “pedestrianise” cyclists by putting them on badly designed off-road cycle tracks does not address safety but only serves to get cyclists out of the way of other traffic. It is unacceptable.