Greater Dublin Area Transport Strategy - SUBMISSION TO NATIONAL TRANSPORT AUTHORITY - LOKRA
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Greater Dublin Area Transport
Strategy
SUBMISSION TO
NATIONAL TRANSPORT AUTHORITY
Draft Transport Strategy for the Greater Dublin Area 2022 - 2042
On behalf of:
Lower Kimmage Road
Residents’ Association (LOKRA)
29th December 2021Table of Contents
Part A ........................................................................................................................................ 4
LOKRA – Introduction and Considerations on the Strategy ................................................................................................ 4
Who we are .................................................................................................................................................................... 4
Our engagement with transport issues and planning .................................................................................................... 4
Keynote issues ................................................................................................................................................................ 5
Chapter 5: Strategic aim and Objectives: ........................................................................................................................... 6
Chapter 6: Public Consultation ........................................................................................................................................... 7
Part B......................................................................................................................................... 7
Chapter 8: Planning for Sustainable Transport ................................................................................................................... 7
Car-dependant Culture................................................................................................................................................... 7
Filtered permeability ...................................................................................................................................................... 8
Urban Design and Placemaking ...................................................................................................................................... 8
The Road User Hierarchy ................................................................................................................................................ 8
Chapter 9: Integration and Inclusion .................................................................................................................................. 9
Park & Ride: .................................................................................................................................................................... 9
Enforcement of Road Traffic Laws: ................................................................................................................................ 9
Chapter 10: Walking, Accessibility and Public Realm ......................................................................................................... 9
Our experience to date ................................................................................................................................................ 10
Chapter 11: Cycling and Personal mobility devices........................................................................................................... 10
Cycling .......................................................................................................................................................................... 10
Personal Mobility Devices ............................................................................................................................................ 10
Chapter 12: Public Transport ............................................................................................................................................ 11
Bus ................................................................................................................................................................................ 11
Light Rail (LUAS & Metro) ............................................................................................................................................. 12
Chapter 14: Traffic Management and Travel Options ...................................................................................................... 12
Congestion ................................................................................................................................................................... 12
Service disruptions ....................................................................................................................................................... 13
Speed ............................................................................................................................................................................ 14
Low Traffic Neighbourhoods ........................................................................................................................................ 14
Parking.......................................................................................................................................................................... 14
Chapter 15: Freight - Delivery and servicing ..................................................................................................................... 14
Chapter 16: Climate Action Management ........................................................................................................................ 15
2What’s the best public transport solution? .................................................................................................................. 15
Some Climate relevant anomalies in public transport feasibility analysis ................................................................... 15
Getting the balance right ............................................................................................................................................. 16
Chapter 18: Environmental Assessment ........................................................................................................................... 16
Stage 1 – Route Corridor Identification, Evaluation and Selection .............................................................................. 16
Chapter 19: Next Steps ..................................................................................................................................................... 17
Phasing: ........................................................................................................................................................................ 17
Monitoring: .................................................................................................................................................................. 17
3Part A
LOKRA – Introduction and Considerations on the Strategy
LOKRA, the Lower Kimmage Residents Association welcomes the opportunity to respond to this important
consultation. We reiterate our hope that this consultation is the beginning of a process of dialogue given
that a community of interest has been constructed through the consultation process for Bus Connects and
that there will be several Dublin City Development Plans over the duration of this Strategy, against a
backdrop of the imperative of our battle for climate justice and now the declared Climate Emergency.
Therefore, an enriched implementation and leadership process which includes genuine, open community
engagement and discussion must be a part of accountability and transparency measures which underpin
the work of delivering this Strategy, because transport decisions directly impact our lives and health.
Respectfully we ask that this conversation systematically continues, and that the ambitions of citizens, the
potential of research and the realities of technological advances are not restrained by parameters of the
current vision but that space is maintained to outpace the limitations of current imagination.
This document should be considered as a companion document to the LOKRA submission to the GDATS in
January 2021, where more detail of our thoughts and ideas are expressed.
Who we are
LOKRA, represents residents of Kimmage Road Lower, in the Dublin 6W area currently zoned Z1, Z2, Z3 and
Z9. We are within 4.6 kilometres of the centre (to the GPO) and just outside the canal cordon, in a
neighbourhood that is described elsewhere by the NTA as sustainable, mixed residential, with specific areas
of conservation and archaeological interest, and small areas of mature open space.
Our engagement with transport issues and planning
LOKRA has had sustained engagement with the NTA and Dublin City Council in relation to transport and
planning and development matters (www.lokra.ie)
Kimmage Road Lower is proposed under Bus Connects to become part of CBC11 (Kimmage to City Centre),
a high-frequency public transport service route, which will predominantly service commuters from outside
our neighbourhood.
An original proposal for a four-lane superhighway was strongly rejected by our community and has
become, supported by evidence, a proposal which provides for two Bus Gates, providing bus priority, cycle
paths and altered local access, with lower speed limits and an opportunity for greater emphasis on
community life and public safety.
Residents have engaged energetically and constructively over a three year period with the NTA proposals,
because of the perceived benefits towards a healthy environment - increased health and safety through
reduced speed, a profound potential reduction in through private vehicular commuter traffic as the area is
released back to inclusive neighbourhood mobility and as the roads become safer for up to 1,600 school
children and their chaperones who will walk, cycle and scoot to school and amenities in parks and sports
facilities here and in Harold’s Cross. The proposals are not without concerns for access and egress and
protections for residents’ properties, but there is broad support for benefits as they are currently perceived.
To enable this revised proposal and accommodate the needs of commuters from elsewhere, we yield on-
road parking, consider acceptance of compromised, altered access and egress, and the potential now for a
vastly increased number of busses. In return our neighbours on some roads will share portions of
redistributed vehicular traffic which residents on Kimmage Road Lower have borne for decades.
The final statutory proposal for public consultation has not yet commenced for CBC11.
4The vague signalling of plans for the further development of certain unspecified Corridors within the
Greater Dublin Area Transport Strategy (GDATS) is at best unhelpful to the progression of this statutory
consultation. The commitment to the continued monitoring of demand is welcome and was sought but
when reviewed in tandem with a pledge to introduce higher capacity bus vehicles on ‘select appropriate
routes’ or potentially to introduce LUAS lines, on a predominantly residential road like Kimmage Road
Lower - with pinch points such as at McGowan’s Pub, the invitation to residents to sign a blank cheque is
unattractive.
From a City Development and Transport Planning perspective, the destruction of New Street and
Clanbrassil Street to Christ Church in a less enlightened age, is not a beacon calling to join all the way along
Kimmage Road Lower in like fashion to the M50, but rather a stark warning that this should never again be
done.
The Transport Framework aligns planning with transport and thus increases a vulnerability in areas adjacent
to Corridors to intensification of planning. Harold’s Cross and Kimmage Road Lower has experienced this
with an increase of population of twenty-five percent plus since 2019, sweating small areas of green space
and local amenities and creating new vulnerabilities environmentally and to sensitive ecosystems along the
Poddle river. LOKRA argues that communities provide the framework for transport. We cautiously
acknowledge statements in the Strategy that acknowledge the importance of urban centres (in our case,
including an historic village and a protected structure) being people focussed and not vehicle focussed,
including of course, public transport vehicles and the accompanying infrastructure.
The impact of zoning areas for the city on those areas such as Kimmage Road Lower which falls just outside
the canal cordon is heavily impacted by decisions for entry within the canal cordon. While there are
investment and business opportunities, ours will be the parking drop-zone if it becomes prohibitive for
private commuters to enter the cordon. Attention and care is required of residential needs within such
transport planning.
Keynote issues
• The timing of this public consultation and structure of the provision of feedback is difficult and
antithetical to genuine community engagement on a vital issue that impacts health and livelihood.
• The document identifies many welcome, long overdue short-term gains, presumably for quick
implementation, and for which the necessary cultural buy-in and ground- work has already been
prepared, e.g. speed reduction and consistency measures taking account of neighbourhoods such
as ours where up to 1600 children will attend local schools any one of which is at any point, within
a maximum of ten-fifteen minutes’ walk from any part of Kimmage Road Lower.
• However, there are also signals of a profound lack of responsiveness to the concerns of
communities - not just in refusing to acknowledge proposals, or to defend their dismissal, but
further in not countering with alternatives that meets concerns and acknowledges common
ground. Communities close to city, just outside the canal cordon, want our road surfaces back for
healthy living and community life. We believe that the technology is there and that financially this
is a matter of choices.
• LOKRA calls strongly for a set of guiding principles from which we may evaluate decisions and
proposals; these should include healthy city indicators such as those used in London. For example -
the GDTAS will
o prioritise the needs of healthy communities in land use for all transport infrastructure
o prioritise sustainability and climate action gain in all transport procurement
o foster just transition and real transport choice for everyone in transport planning
o lead inclusive conversations and research about transport, communities, health, society and
economic success building on engagement to date
o develop and promote healthy city transport indicators and publish evaluations against them
5• There is a concern that the Strategy lacks ambition for long-term solutions and will not provide the
necessary steppingstones for a future-proofed integrated transport system that properly
acknowledges the historicity and value of our city. This raises the very real concern about the
allocation of budget and commitment at government level to resolving the cities transport
challenges. The Strategy should be clearly accompanied by a multiannual budget to deliver
significant projects according to clear principles.
o Given the reality of a Climate Emergency, the Strategy does not signal a strong response nor an
enabling for citizens to meet that emergency in the necessary choices that we must make for
mobility in the context of a healthy city.
o There is a lack of incentivisation for modal shift from cars, electric or otherwise, to other forms of
transport. This is reflected in a weak consideration of congestion mitigation and solution
measures, the absence of appropriate Bus & Bike Park-and-Ride facilities (at community level and
further afield), and limited vision for micro-mobility which assumes an able-bodied user only and
does not exploit even current technologies in an inclusive and imaginative way.
o Public realm design and transportation design and infrastructure are inseparable and cannot be
utilitarian, one-size-fits-all, in a historic city of unique character. Equally given the Climate
Emergency, transport planning must be accompanied at every step by biodiversity and greening
infrastructure. Our healthy city and community must be front and central in all transport
planning.
o Underground Transport (Metro) must be urgently and actively considered for the Southwest
quadrant which cannot remain the sole quadrant with all transport options occurring above
ground. A population of 125,000 between the Red and Green Luas lines (approx. the same size as
Cork city), deserve equal consideration and our roads for filtered permeability, for living and
community life. LOKRA supports an appropriately evaluated Metro South West solution as a
companion to bus services and alternative proposals suitable to narrow residential historic roads.
• Clarification must be given immediately, in advance of the final statutory consultation for Bus
Corridors to An Bord Pleanala on the likely Corridors to be assigned for LUAS as signalled in the
Strategy. LOKRA would hold the view, notwithstanding the potential development of rail
technology in a twenty-year period, that our narrow residential historic road would not sustain a
LUAS line, (given that such a solution was rejected by expert review in 2008 and 2016), nor would
it be consistent with road user hierarchy, and the filtered permeability that our neighbourhood and
1,600 school going children will require. We are concerned that the bona fides of our community
engagement with Bus Connects is undermined by this potential inference of using Kimmage Road
Lower to provide light rail. A comprehensive statement is required for our community.
• Residents on Kimmage Road Lower sacrifice a great deal for mobility, including of adjacent roads
and commuters from other areas. Neighbours share parking spaces with us in as much as is
permissible. In our neighbourhood, we are part of the community, far greater than any transit
corridor.
The Transport Framework acknowledges planning aggrandisement associated with Transport Corridors.
This would be of concern to our community and neighbourhood, given our existing density.
Chapter 5: Strategic aim and Objectives:
• LOKRA notes that a core aim of this strategy is to provide a long-term strategic planning
framework for the integrated development of transport infrastructure and services in the Greater
Dublin Area (GDA)
• It is our assessment that the focus in this document is on pragmatic short and medium term aims
and objectives but falls short on Vision or Future-Proof planning, which given the lead time to
delivery on many projects (eg. Metro, active community engagement with cutting edge emergent
6transport research and piloting), need to be planned for and initiated in the timeframe leading up
to 2042.
• LOKRA has previously argued for a principles-led approach putting citizens and communities at the
heart of developments impacting quality of life, and against which plans, initiatives engagements
can be evaluated.
• It is noted that the Dublin Southwest Study, similarly lacks a value-based analysis, which in the
context of climate change and forward looking urban renewal puts communities first, should be
core elements of any cost / benefit exercise on decision making in relation to Public Transport
mode provision into the future such as Metro
• This strategy should build the foundation for a future proofed, integrated transport system serving
citizens and communities in an ancient but evolving city and not just a system for the short /
medium term.
Chapter 6: Public Consultation
• While acknowledging the limitations imposed by Covid-19 on public consultations, mechanisms
need to be in place for proper engagement with communities which goes beyond short,
explanatory webinars.
• The Strategy must be principles and value-led, in ways that sensitively acknowledge the desires and
needs of communities, and the importance of our heritage and historic villages and that commit to
working with them collaboratively and accountably
• The tight deadline for this submission, extensive document reading required and proximity to
Christmas, combined with communities’ own challenges in engagement prohibits a comprehensive
response to the Strategy.
Part B
Chapter 8: Planning for Sustainable Transport
Car-dependant Culture
o The strategy goal is for 50% of journeys to be by private car. In our opinion this is too
unambitious.
o LOKRA residents have direct experience of that which the Strategy notes, that ‘an overly car-
dependent culture results in congestion, air pollution, community severance and unattractive
urban environments including poor walking, cycling and living’ environments.
o Experiencing as we do the high volume of private vehicular commuters from outside our
neighbourhood, more broadly from the Dublin Southwest area, and looking to the Strategy for
incentives to change commuting patterns, LOKRA sees little in the Strategy to encourage
motorists to embrace the required modal shift to public transport and the subsequent potential
advantages that would follow from such a shift.
o The strategy outcomes (Section 17) stand no chance of being realised if the strategy fails to
reduce our reliance on the private car in the short to medium term. (see also LOKRA response to
Sections 9 / 10 / 12 and 14)
o LOKRA submissions to the NTA propose a range of short- and medium-term solutions including
micro-mobility provision adjacent to Bus Corridors, which acknowledge the choice and
independence factor for many commuters. Car dependency is reduced by the provision of
affordable and accessible choice that meets just transition metrics, but also by a transformative
approach to urban villages and environments, the acknowledgement of road space as belonging
primarily to communities. Government Policy must prioritise community life as the heartbeat of
road use and ownership and affordable public transport over an increase in congestion that is a
replication of a multiplicity of electric cars.
7Filtered permeability
o LOKRA strongly supports the concept of filtered permeability through neighbourhoods, to
increase social interactions, and facilitate more activity in our public realm (parks, amenities) and
maximise the potential for walking and cycling, particularly as 1,600 children and their
chaperones access our four local schools that lie within ten minutes from the heart of our road.
Kimmage Road Lower residents have sacrificed greatly for the benefit of private vehicular
motorists from other neighbourhoods, in the personal direct experience of congestion, quality of
air and environmental impact and speed and safety risks.
Urban Design and Placemaking
o LOKRA strongly supports badly needed improvements in Urban Design and Placemaking for
Kimmage Road Lower, as described in this document as:
a. the process of creating quality places that people want to live, work, invest and spend time
in
b. better street design in urban areas, including the presence of active street frontages
c. creating a built environment that responds more sympathetically to the distinctive natures
of the individual communities and places
d. fosters greater biodiversity in urban areas
o LOKRA is active with the HCVCC in HXGrow, (an award-winning community biodiversity initiative),
the Harold’s Cross Tidy Towns, the community Volunteering Initiative; the LOKRA submission to
the DCC Development Plan (Pre-draft) 2022 – 2028 (www.lokra.ie) focused strongly on
placemaking, informed by residents need and opportunities as perceived at the time of writing.
o However, we are mindful of the challenges of budget in a post COVID recovery economy; the
proposals for public realm implicit in the original CBC11 (Kimmage to City Centre) proposals have
been trimmed in part arising from conflicting interests of business which disappointingly do not
align with the ambitions of residents for community-oriented nodes which are likely to yield
greater returns, but also because budgets have been trimmed. Therefore we urge clarity
regarding what budget has been committed to placemaking in the context of the Transport
Strategy and how is it weighted against engineering works? How will placemaking
infrastructure be developed in consultation with DCC, and who will be ultimately responsible
for development and maintenance?
o The DCC Development Plan (Draft) 2022 – 2028, proposes to open up riverways and walkways
and to monitor sensitive riparian environments. CBC11 will run closely beside the Poddle river.
Yet we note that it is possible that a LUAS will also in time be proposed to run on Kimmage Road
Lower, on this environmentally sensitive, narrow, residential, historic road. Clearly this is a cause
for great concern in a community that has deep commitment to heritage and environmental
issues. Please see www.lokra.ie for previous submissions.
o LOKRA contests that urban realm design including for the sensitive integration of transport
related infrastructure and furnishings in many historic villages and roadways should reflect and
celebrate heritage and identity. There are arguments for consistency. The best designers should
be involved in placemaking initiatives and co-construction with communities, with priority given
to the residents who actually experience the impact daily, and whose investment in their homes
is a lifelong commitment.
The Road User Hierarchy
o The availability of usable open space - and respect for historic villages such as Harold’s Cross
(including Harold’s Cross West) and acknowledged important ‘ribbon roads’ such as Kimmage
Road Lower - is protected where transport solutions that are respectful of scale and
infrastructure. Large capacity buses and or LUAS lines on Kimmage Road Lower does not respect
road user hierarchy. The development of METRO Southwest however would.
8o Furthermore, it would release additional useable road space back to communities and increase
capacity, complement existing bus services and respect the scale and density of housing provision
and a population which has already increased by 25% in the last two years. It would enable
CBC11 to operate as designed with Bus Gates and provide protection for the 1600 children
commuting on foot, by bike and scooter with their chaperones to the four schools within easy
reach of Kimmage Road Lower.
Chapter 9: Integration and Inclusion
Park & Ride:
o A core focus asserted in this document (Strategic Challenges – Part A) is to reduce car trips with
an additional 500,000 non-car journeys targeted by 2035. LOKRA supports the assertion that
‘Park & Ride can intercept car trips where people are reliant on private car at an early point in
their journey’ ‘– Reduces carbon emissions and congestion’ and has noted this consistently in
submissions re Bus Connects since the earliest consultations.
o Park & Ride must support all Bus Corridors, including CBC11. This is particularly important given
the high dependency on cars in the SW district of the city. If Park & Ride is not affordable and
attractive and convenient beside a good bus service or alternative, those who chose cars will
simply stay in cars.
o Furthermore Park & Ride must in view of adapting car parking regulations within the DCC
Development Plan (Draft) 2022 - 2028 provide imaginatively for (preferably underground)
municipal community parking as is the practice in EU cities.
o We note with concern that the nearest proposed Bus Park & Ride facility to Dublin South West / F
Spine / CBC11 is at Kill, Co. Kildare. There is a lack of imagination and future planning in not trying
to capture even some of the 70,000 car journeys that use the M50 on a daily basis and encourage
a modal shift to public transport, by providing strategic Bus Park & Ride closer to the M50 and
the N81. (eg. at Spawell).
Affordable and appropriately located bus and bike Park & Ride must be urgently provided as
outlined above, as an immediate enabler of Bus Connects and future light rail (Metro or LUAS)
Enforcement of Road Traffic Laws:
o LOKRA suggests that the Strategy lacks sufficient essential detail and an implementation plan in
relation to enforcement of road traffic laws.
o This section of the document makes very general statements on the critical issue of enforcement:
…comprehensive enforcement of road traffic laws, including exploring innovative new
methods…, LOKRA has previously requested clarity on the specific detail as to who will have
overall responsibility / governance (NTA / Gardai / TII) for enforcement and for information on
the range of methods that may be in place to ensure the success of any future transport plan,
including the enablement of Bus Gates.
o Signage and large-scale public information should be available from a distance on all motorways
to and from all exits on the M50 regarding changes to Core Bus Corridors, Bus Gates, Penalties,
Park & Ride and subsequent alternative traffic distribution arrangements.
o In the context of LUAS, we are concerned that the only reference to improving security on the
LUAS network will be ‘subject to funding’ – with clearly no budgetary consideration in the
strategy. This aspirational statement is not only disappointing, but alarming.
Chapter 10: Walking, Accessibility and Public Realm
o LOKRA is pleased to note that the Strategy sets out that the Quality of Public Realm is ‘an
indicator of the social, cultural and environmental health of an area. Ensuring that urban centres
are people focussed and not vehicle focussed is an objective of national, regional and local
planning policies.’
9o A key tenet of this strategy document is that public realm ‘should not be compromised by the
design of transport environment or vehicles’ - This statement of course includes Public Transport
Vehicles that should be chosen with consideration for the character of our road which partially
echoes the Poddle river in form, its residential status, camber and width, heritage and history.
Our experience to date
o LOKRA’s experience with Public Realm enhancement with the NTA and Bus Connects for CBC11
has been somewhat disappointing. Initial potentially transformative proposals have been diluted,
in part arising from resistance from business owners concerns for parking, at a key node on the
road. An additional aesthetic benefit whereby tree planting would have travelled around a very
run-down junction has been removed, much to residents’ disappointment. Public realm
enhancement remains limited further down Kimmage Road Lower on CBC11 and also at Harold’s
Cross.
o If the Strategy adopted a principle of high-quality value added public realm and unique design
that prioritised residential placemaking and community building, aligned with a value of
inclusion, then every action under this element of the Strategy would deliver with ambition and
imagination. (see also LOKRA response to Section 8 – Planning for Sustainable Transport)
Improved Public Realm greatly facilitates the future viability of local communities, climate action goals
and support the health and well-being of citizens with the reduction of air pollution and road speeds
Chapter 11: Cycling and Personal mobility devices
Cycling
LOKRA welcomes the initiatives proposed in the document for improved cycle facilities, including
the safe route to school initiative as outlined in the section on Traffic Management (Chapter 14), in
the GDATS document. As a community wherein 1,600 children and their chaperones will travel to
schools within at most fifteen minutes of the centre point of Kimmage Road Lower on foot or by
bike, scooter etc, safe school zones along our road and neighbourhood, with safe access across our
road to our parks and businesses is vital. The concept of ‘filtered permeability’ matters for
residential areas like Kimmage Road Lower.
Personal Mobility Devices
o Along with Park & Ride, further supports of modal transfer in the future include the full suite of
imaginative and cutting-edge micro-mobility devices, including mobility chairs, e-scooters, cargo-
bikes, double e-buggies etc.
o LOKRA believes this section of the document demonstrates a very narrow focus and vision on
future transport and mobility requirements, particularly locally based micro-mobility.
o Mobility devices listed are predominantly used by able bodied individuals
o The provision in communities of public micro-mobility schemes should meet whole-of-
neighbourhood needs, particularly of cohorts who are less physically able and or who require
care or supports. Diversity begets stability.
o Micro-mobility means: e- charge points for e.g. bicycle/scooter, but also e-mobility chairs at
micro-mobility points for mobility impaired people/small scale e-carriers for clubs with
equipment transport needs for clubs/schools/equipment and for small groups of children to
amenities, including to schools from designated pick up points.
o Cohort specific mobility devices and access schemes need to be designed and made available
within and proximate to areas designated as Bus Corridors, based on needs, key services,
amenities and requirements, particularly enabling the success of Bus Gates.
o Cohort based mobility need studies would be helpful, particularly for older communities - for
example within LOKRA, some of our residents have difficulty getting glass to bottle banks, or
getting shopping back home, while enjoying the walk to the shops. We believe that there are
solutions locally for this in the context of a sensitive public transport micro strategy.
10o Smart transport meeting whole-of-community needs would locate these along Bus Corridors,
outside Bus Gates, and in adjacent roads addressing some anxieties for traffic redistribution, and
supporting greater local mobility, respecting the desire for independent travel that characterises
car as the preferred mode of travel for some.
o This is really important in preventing the polarisation in urban communities of fit and healthy
people who can cycle and walk distances, in unhelpful debates with those who feel that their
private car is their only realistic transport choice to meet their needs. Lives are complex.
Chapter 12: Public Transport
Bus
The NTA has acknowledged in this GDATS that bus capacity will not be sufficient on its own to serve
the needs of the growing population in Dublin Southwest even in the short to medium term.
o LOKRA accepts that buses form a vital part of our existing public transport infrastructure and
should continue to do so.
o The LOKRA community broadly supported the last Bus Connects proposals for CBC11 with its
promise of a cleaner, quieter, safer road and the subsequent anticipation of a better living
environment for residents, because of reduced private vehicular traffic.
o The proposal in this strategy, for a significantly increased bus capacity fleet (bi-articulated buses
up to 25 metres long), transitioning to LUAS in the medium term, potentially along CBC11 raises a
number of significant concerns (see also LOKRA response to Chapter 8 – Planning for
Sustainable Transport)
o We note in the strategy, that this will depend on the operating environment, including street
widths, and it would be onto select appropriate Bus Corridors. LOKRA urgently requires
clarification on the assessment and selection process of appropriate corridors and if CBC11 itself
is deemed to be one, given its configuration as a largely narrow winding residential road.
o The GDATS states: BusConnects Core Bus Corridors will provide the basis of the higher capacity
intervention, with combined services, including combined light rail/bus services, potentially
operating on the particular corridor. However, in some cases alternative alignments may be
identified following assessment studies. LOKRA needs to understand how / if this applies to
CBC11 and Kimmage Road Lower.
o In terms of the Orbital network, we note that the GDATS refers to high frequency orbital buses,
with no mention or timeline for Public Consultation on Orbital Corridors. Has this concept been
dropped by the NTA? Is it anticipated that high frequency orbital buses, may also transition to
high-capacity buses and ultimately LUAS lines as proposed for eg, CBC11?
o LOKRA would contend that the nature of some roads in the area (eg. Kimmage Road Lower,
Kimmage Road Lower to Harolds Cross Road at McGowan’s Pub, Clareville Road, Kenilworth to
Grosvenor Road), encompassing narrow, winding sections of road and tight turns, make high-
capacity bus and LUAS solutions impossible without demolition of historic/period homes and / or
significant land take, again on heritage sites and areas of archaeological interest close to
protected structures in the case of Kimmage Road Lower. An underground Metro is the only high-
capacity sustainable long-term solution if homes, businesses and communities in this area are to
survive.
o LOKRA is concerned that the bona fides of the Bus Connects community engagement is
undermined by the potential to use this Corridor to provide light rail. Accepting that light
rail/LUAS may look very differently in two decades time, none the less, our heritage is such that
our homes have stood for over one hundred and twenty years. There is concern that Bus
Connects is a socialisation process, in fact in the longer term for a destructive process that is at
odds with community value, heritage and placemaking. Alternatives are possible with greater
community gain.
11Light Rail (LUAS & Metro)
o LOKRA supports the use of LUAS light rail where it is an appropriately located, medium capacity
support in an integrated public transport system. It has proven to be very successful in many of
the locations it serves currently – the majority of which are located along previous rail
infrastructure or wide commuter roads.
o It is difficult to understand how the alternative of a future-proofed, medium to long term Metro
Southwest solution was not even considered in the GDATS Dublin South West document as part
of the differential analysis for the region.
o 4,000 submissions were received to the previous consultation on the Draft GDATS, where one of
the main issues raised was a proposal for Metro for Dublin SouthWest.
o The main explanation given is one of cost but this is difficult to accept as no appropriate cost
benefit analysis has ever been carried out on an underground Metro solution servicing the
catchment area between the RED and GREEN Luas lines, including the major population,
educational, medical and commercial centre of Tallaght.
o Such a cost benefit analysis should also include appropriate Car and Bike Park &Ride facilities to
allow longer distance commuters access the public transport system (optimising demand) at a
distance from the city that would significantly reduce suburban and city congestion.
o While there is an outline proposal for a metro line to Knocklyon / Ballycullen post 2042, the
MSWG continue to point out the deficit of any kind of rail service or Park & Ride facility for the
triangle between the LUAS red and GREEN lines in this region, with absolutely no support to
encourage private car modal shift from commuters on the M81 or M50.
o While an on-road LUAS expansion may appear to be a more cost effective and viable option in
the short term, it will do nothing to future-proof public transport for the city.
o It also risks creating permanent legacy hard infrastructure, that potentially interferes with or
inhibits the development of healthy and viable city suburbs, which is a core element in best
practice urban planning and intrinsic to the DCC Development Plan (Draft) 2022-2028
o It is a major concern that there is the potential plan to literally divide Kimmage Road Lower so
that the simple daily tasks of meeting our neighbours, going to Church, to Mount Argus Park or
shops becomes an impossibility. It is a spectre that weighs heavily.
o The GDATS states that Post 2042: The alignments and details of proposed transport projects …
are indicative only and are subject to further development as the design and planning processes
for individual projects progress.
LOKRA must have a clear indication of the options / alternatives for the provision of LUAS
services for our area proposed in this document, prior to the commencement of the statutory
consultation for CBC11 for An Bord Pleanala
o It is stated that light rail produces significant positive impacts on their urban environments
through which they pass. LOKRA contests that such positive impacts must be published as they
apply to the context of the narrow residential road which is Kimmage Road Lower. This must be
done prior to the statutory consultation for CBC11 to An Bord Pleanala.
An underground Metro service should be the backbone of any integrated, multi-modal, transport system
that should aim to free up precious and already seriously limited road space for flexible public transport
options (such as bus and shared modes of transport), cyclists, pedestrians and support the creation of
healthy urban living and working environment
Chapter 14: Traffic Management and Travel Options
Congestion
One of the main aims of traffic management is: to ensure public transport is not adversely affected by
private car traffic, and that the impacts of traffic congestion can be minimised.
o Dublin is already widely acknowledges as being one of the most congested cities in Europe.
12o With a relatively modest target of a reduction in private car use over the lifetime of this strategy
to 2042, other measures will be required to address this problem.
o It must not be forgotten that on-street public transport vehicles are also contributors to
congestion on our narrow city and suburban streets. This is most clearly demonstrated in the city
centre where tram bunching and inefficiency that happens regularly with existing services – and
this in spite of the fact that the private car has already limited access to the area.
o It is the responsibility of this strategy to address this issue and mitigate for any future potential
congestion in this regard.
o The NTA, in conjunction with TII and the local authorities: will explore how best to manage the
road and street network, with enhanced priority for trams. But studies have not yet been made
available to the public, if they have been carried out to see the viability of tram / bus etc
interactions, which will be increasingly important if/as additional LUAS lines are added
LOKRA would contend that any such exploration should be completed and reported on before any
suggestion of additional high capacity on-road public transport such as extra LUAS lines are ‘cast in
stone’ by statutory process
We strongly request the re-consideration of more underground Metro solutions for the city as the only
real way of permanently alleviating this problem and for making bus services more effective and
efficient.
o Congestion will occur as people will not always choose public transport and indeed it will not
always realistically meet need. Much mention is made of zoning, congestion charges within the
canal cordon, and of prioritisation at traffic lights to facilitate movement.
Congestion needs monitoring, including in cycle lanes and paths as micro-mobility choices and options
grow, provision and adequacy may need adjustment. Similarly with traffic light changes and adjustments in
order to maintain movement. It may be necessary to encourage cars to switch off when idling.
Notwithstanding growth in remote working and post lock down re-opening, traffic on Kimmage Road Lower
remains high and speed with it. (https://bit.ly/lokra25, https://bit.ly/lokra26)
o None-the-less, congestion is a daily reality for residents.
o Awareness needs to be raised that our choices make us the congestion, that we (and on-street
public transport) are the traffic, and most particularly that a hybrid or electric car of bus, may still
be a car or bus in traffic causing congestion, just as much as a polluting one.
o To reduce congestion, a multiplicity of measures are required - reduce cost of public transport,
extend the network, including of an underground, and promote awareness of it - set metrics and
publish them, hours lost, particles released etc.
o Public information and education is low and something of a niche /polarised conversation. To
enable a strategy to be successful and to provide for supports for climate change measures, this
really has to change. There are many remarkable and convincing studies in relation to transport
which are pertinent to urban and historic districts like Kimmage Road Lower. These need to be
discussed.
Service disruptions
All on-street public transport services are subject to Service Disruptions such as:
o Motorists crashing into level crossing or trams
o adverse weather conditions
o road traffic collisions.
o extreme weather events, such as flooding
The consequences of such disruptions can have serious impact on the efficiency and provision of public
transport. One of the best ways to build resilience into the system is to diversify and provide every possible
mode of public transport including Metro on a strategic city wide basis.
13Speed
o LOKRA strongly supports the reduction of speed limits in residential urban neighbourhoods
making our streets cleaner, quieter and safer places, consistently for everyone. Please see LOKRA
submission to DCC Special Speed Limit By-Laws 2020 (Covid-19) (www.lokra.ie)
o Kimmage Road Lower has four schools within immediate short walking distance of our homes,
providing for 1600 children. Mount Argus Church, a site of national pilgrimage to the only Saint
buried in Ireland as well as a protected structure in it’s own right, is frequented by daily
worshippers, not all of whom are able bodied. The reduction of speed is essential for the safety
of our residents and those who visit the services and amenities close by.
Low Traffic Neighbourhoods
o LOKRA supports the initiative to develop broad Low Traffic Neighbourhoods and would like to see
an evaluation of its viability for the neighbourhood including Kimmage Road Lower.
o Bus Connects proposals were perceived as a potential benefit in this regard as there would be a
general reduction in inbound traffic across the neighbourhood making it safer in particular for the
1600 children and their chaperones attending schools in our direct reach.
o The promised reduction in direct traffic because of proposed bus gates depending on operation
hours, brings benefits to the entire neighbourhood including in a reduction of reduced speeding
vehicles (current Telraam data (https://bit.ly/lokra25, https://bit.ly/lokra26), suggests that over
8% of cars in daylight hours exceed 70kmph as they approach a dangerous bend on the road).
o However, the potential for redistributed traffic once experienced entirely on Kimmage Road
Lower is cause for concern, here commuters are less enabled or inclined to choose alternatives to
private vehicular transport for the multiplicity of reasons there may be. (see also LOKRA
response to - Chapter 10: Walking, Accessibility and Public Realm)
Parking
o Reduced parking provision
The strategy proposes that new residential developments in places like Kimmage Road Lower would
have provision for at most 1.5 parking spaces per unit. It is not enough however, for the strategy to
just mention the associated risk of the potential for overspill into adjacent areas. It should contain
concrete proposals as to how overspill can be prevented.
o On-Street parking
In-garden / off-street parking is not an option for several residents on Kimmage Road Lower who
can only park on the road. On-street parking is possible for limited times and with very limited
opportunities. Residents here have sacrificed much for the benefit of other car users in their
neighbourhood and all of us, for commuters from elsewhere.
It is not good enough for the strategy to simply state that local authorities should review/reallocate
such parking without providing guidance on how the "loss" can be mitigated - e.g. local authority to
provide alternative of municipal ‘community’ parking for affected residents within a specified
distance etc.
While car usage may vary and indeed change, assumptions cannot be made about residents’
capacity or requirements in different zones of the city.
Chapter 15: Freight - Delivery and servicing
With the experience of the pandemic, an increase in on-line shopping is likely to remain a feature of
daily life and will result in a matching increase in freight delivery.
• While it is critical to continue the filtering of HGVs away from city and urban areas as much as
possible, new opportunities present themselves to enable more streamlined and green solutions to
delivery and servicing in the city and suburbs. While the examples included in the strategy lack
14detail and specific proposals, LOKRA welcomes the change in direction to more sustainable
solutions such as:
o Reduction in ‘last mile’ trips - Urban or micro-consolidation centres
o Increased use of cargo bikes for delivery in Dublin City Centre
o Out-of-hours delivery – low noise (EV) vehicles
o Smaller and non-motorised vehicles – more street space to pedestrians and cyclists
o Consideration of the Utrecht Cargohopper and Gothenburg’s Stadleveransen city deliver systems
– minimising empty return trips
o Local click and collect – stations / PARK & RIDE / residential developments
The needs of SMEs and retail operations for delivery should also be explored with a view to the
establishment of co-operative logistical hubs to service deliveries across neighbourhoods using micro
mobility devices. E-cargo delivery bikes could then be used from logistical delivery services for local
businesses from local distribution points as we shop locally in the 15-minute city concept.
Subvention for local businesses as early adopters must be promoted and rewarded; Dun Laoghaire-
Rathdown County Council has managed a successful campaign with business, but there needs to be traction
within this area. To LOKRA’s knowledge, there is one business operating with a cargo delivery-bike in the
immediate neighbourhood.
Chapter 16: Climate Action Management
What’s the best public transport solution?
The only acceptable public transport solutions are those that acknowledge and prioritise the Climate
Emergency, with the centrality of local community life.
The key to climate action management in the context of transport is the reduction of private car use
and dependency and associated traffic congestion, to achieve greenhouse gas emission targets.
Effective public transport requires optimal use of on-street space, but with the priority given to the
walking, cycling, micro-mobility and community first.
An underground Metro system supported by an on-street flexible bus service and existing and
appropriately sited future LUAS infrastructure (e.g. on green field sites) appears to be the best way to
achieve this.
An underground Metro service for Dublin South West would:
o Restore precious and very limited road space to communities and active transport modes
o Allow for optimal pedestrian, cycle and bus infrastructure configurations
o Help achieve Placemaking objectives and support the development of 15-minute neighbourhoods
o Help minimise air and noise pollution in residential urban areas
o Significantly reduce congestion by providing an off-road, rapid alternative for the commuting
public, whether electric or otherwise.
o Support community integration rather than community severance
o Allow more surface area to be re-configured from hard landscaping in favour of increasing
mitigating environmental infrastructures such as pocket parks, pocket forests, green dwell zones
o Help increase bio-diversity in line with Climate Action Goals
Some Climate relevant anomalies in public transport feasibility analysis
To date, feasibility studies for a Metro service for Dublin south West have:
o Not included Carbon emission or Air Quality / Population Health parameters in any Cost / Benefit
analysis
o Completely ignored Tallaght as a major attractor, with an already over-subscribed LUAS Red Line,
hospital, university, commercial centres and significant and growing population. This will further
limit the incentive for modal shift from the private car to public transport for this area.
15o Insisted on retaining Charlemont as the most appropriate interchange hub for LUAS (potentially 2
lines, a future Metro line, car, bike and pedestrians), despite its extremely constricted location
and multi-level interchange requirements. This in the context of the abandonment of the LUAS to
Metro upgrade originally proposed, and St. Stephen’s Green / City Centre already well
established as a key transport interchange hub.
Getting the balance right
o Transport services in themselves, do not bring with them services, amenities, green spaces,
balanced housing development, or a just perception of a community.
o Kimmage Road Lower has long suffered from being perceived primarily as a ‘through road’ rather
than the vibrant living, breathing local community it is.
o Public transport systems and infrastructure must respect and be part of the change in this
perception and not exacerbate it.
o Where communities are established as in Kimmage Road Lower, community needs should lead
development and inform infrastructure planning.
LOKRA is disappointed to see no mention of complementary climate mitigating measures such as
greening infrastructure & biodiversity enhancement in the strategy
Chapter 18: Environmental Assessment
Stage 1 – Route Corridor Identification, Evaluation and Selection
According to the GDATS, The following Corridor and Route Selection Process will be undertaken for
relevant new infrastructure:
o Environmental constraints (including those identified
in Section 4 of the SEA Environmental Report) and opportunities (such as existing linear
infrastructure) will assist in the identification of possible route corridor options;
o Potentially feasible corridors within which infrastructure could be accommodated will be
identified and these corridors assessed. The selection of the preferred route corridor will avoid
constraints and meet opportunities to the optimum extent, as advised by relevant specialists;
and
o In addition to the constraints identified above, site-specific field data may be required to identify
the most appropriate corridors.
LOKRA would like clarification as to whether this applies to the final outcome of the An Bord Pleanala for
Bus Connects CBC11 (pending), and / or only new infrastructure planned subsequently for CBC11 and / or
other areas
Clarification is essential prior to the progression of any proposal to An Bord Pleanala for Bus Connects
(CBC11 - pending) regarding any outline or new infrastructure that may be under consideration in
relation to:
o Potential use of long high-capacity buses on Kimmage Road Lower
o Potential to establish light rail /LUAS on Kimmage Road Lower
o Plans for formal continued community engagement in monitoring the implementation and
impact of Bus Connects and CBC11 should it proceed
16Clarification is essential as to what is envisaged where it is written that the ‘selection of preferred routes
will avoid constraints’, and that ‘in addition to environmental considerations, the identification of route
corridors and the refinement of the route lines is likely to be informed by other considerations’.
LOKRA must understand the implications of this prior to engaging with further statutory consultation in
relation to CBC11
Chapter 19: Next Steps
Phasing:
o LOKRA is perplexed and disappointed to see no reference whatever to Park & Ride in Figure 19.1
of the document, in spite of the acknowledgement of its key role in facilitating modal shift to
public transport.
o We would like to know the time-frame for implementation of the limited proposed Park & Ride
facilities.
Monitoring:
o LOKRA notes that there is no reference to community engagement in the monitoring process for
the strategy roll-out and evaluation and would like to see this included as a vital measure of
success or failure particularly in relation to public transport impact on residents.
o Public education, engagement and information about essential research and cutting-edge ideas is
essential in order to drive support and respectful understanding of the diversity of perspectives
in relation to transport needs and demands. All communities should be engaged. A network of
those impacted has been painfully constructed arising from Bus Connects consultations. This
relationship should be democratically built upon and extended.
It is the function of transport strategies and infrastructure to serve people and populations
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