Cycling UK Response to the NI Active Travel Delivery Plan

As is always best, lets start with the positives, of which there are several.  Firstly, the fact that we now have a plan, on paper, with maps showing progress over time is fantastic, its the first time people across NI can say there is a coherent proposition for active travel outside the Belfast area. Secondly, the Department should be commended for the sheer number of engagement events they held across the country, both online and in person - including engaging directly with IMTAC (The Inclusive Mobility and Transport Advisory Committee) and the Active Travel All Party Group at Stormont. In terms of the plan itself, the rhetoric on prioritising 'schools, town centres and transport hubs' is hard to argue with, and the 'people centred..accessible to all' design principles focusing on 'high quality infrastructure...with safety at its heart' gets a double thumbs up from us.

Several criticisms of the development plan

We do have several criticisms however, with the development of this plan. Our major concern is based around the number of separate schemes the plan proposes - 42 settlements across Northern Ireland. Given the inability to deliver any major active travel projects in Belfast over the past few decades, it is hard to see high quality networks being developed with the jam being spread so thinly. We think there has been a failure in the development of the plans to conduct an analysis of where investment should be focused to get more people cycling. There is obviously a need to address regional imbalances in NI, but within these regions the Department needs to be laser focused on schemes in areas where they will really get people cycling i.e. places with higher populations, transport hubs and an existing cycling culture. We want to see a handful of high quality schemes which deliver a shift in transport, rather than isolated schemes diluted across the country. Representatives should be able to look at schemes in areas outside their own, see the benefits and call for them to be delivered in for their constituents. This will not happen if roads are dug up, lives disrupted and there is no significant benefit seen.

Our other major criticism is the lack of early engagement with groups like Cycling UK, Sustrans and Cycling Ulster. These organisations are engaged with local people who cycle every single day, we have a strong grasp of what it takes to change the culture of transport and travel and we would have been an invaluable part of the plan development process. Several issues with the plan could have been addressed before the scheme was published. A stakeholder group has been promised by the Department for several years, and the shortfalls of this plan highlight its importance.

We don't criticise for the sake of it, we desperately want investment in active travel to deliver change across Northern Ireland, we know the difference it can make to our lives, from our independence to health, and the economy. We hope that DfI consider all the feedback received and make changes to the delivery plan, if we can show successful schemes it will breed an appetite to enable active travel everywhere.

Our response to the consultation

Positives 

• Good to see a plan considering active travel progression in urban areas outside of Belfast.
• Prioritisation of connections to local schools, public transport and town centres.
• Focus on ‘people centred…accessible’ places and ‘high quality infrastructure’ is welcome given the low quality, driver focused infrastructure currently in place.
• The comprehensive range of locations for engagement events was welcome.

Negatives 

• Attendance at many of the engagement events was poor and local representatives largely failed to engage.  Several events could have been announced with more prior notice, and it would be good to see DfI engage with specific councillors in order to engage the local politicians.
• No analysis of propensity to cycle conducted for the 42 areas across Northern Ireland.
• Failure to do a cost-benefit analysis of investing in the various settlements.
• Benefit-cost ratio must be developed for active travel routes much like in the All-Ireland Rail Review.
• The aim of the Climate Act is ultimately to achieve a reduction in carbon emissions, which includes enabling more people to walk and cycle, not simply spending 10% of the transport budget.
• There needs to be more focus and stronger reasoning on the likelihood of modal shift through this investment.
• Spreading the investment across NI due to political diplomacy will lead to an ineffective network of disconnected routes with low levels of use.  The Department has a duty to communicate reasoning behind prioritising certain areas over others in order to ensure a high return on investment.
• Considering the difficulties in delivering the Belfast Cycle Network over several decades (i.e. the consultation process, local resistance, and staff recruitment), spreading limited funding across 42 schemes in separate towns is unlikely to lead to high quality and well used schemes.
• Within the 42 schemes there is a lack of ambition; very few will develop routes that connect well within the towns and cities over the next 10 years.
• There has been little thought given to existing routes e.g. through parks, which could connect with new infrastructure.
• There is a strong likelihood that the patchwork of schemes, which will require disruption to residents and drivers, will lead to more animosity towards active travel if the resulting routes are not well used.
• Lack of detailed design guidance.   The Department used ‘LTN 1/20’ as their guidance until 2024 when it switched to ‘Cycling by Design’.  It is difficult to understand why Northern Ireland would require its own version of design guidance given the comprehensive existing guidance documents which we are able to use.
• The plans for the two most populous cities, Derry-Londonderry and Bangor, do not follow the stated prioritisation assessment framework.  These cities routes focus on ring roads rather than getting people into town centres, transport hubs or schools, where they would achieve higher use.
• Atkins consultants have stated that the routes in the delivery plan do cover schools if you consider a “400-500m radius. This approach fails to acknowledge that if users don’t feel safe all the way to their destination, they will not cycle.  You cannot call a cycle route ‘high quality infrastructure’ when it only gets within a ½ km walk of a destination. 

Recommendations 

• In the early stages of any active travel delivery plan there needs to be a strong focus on 3-5 schemes which develop routes in places where they will achieve the highest modal shift. These initial schemes should be located in the most densely populated areas, which have higher propensity to cycle.  Otherwise, numerous but poorly considered schemes in the wrong places will be of low quality and fail to attract people out of their cars. The complaint the Department should be striving for should be ‘why don’t we have a scheme as good as ‘X’ in our area’ rather than ‘yet again the Department has wasted time and money and disrupted lives for a cycle lane no one uses’.
• Early-stage priority routes should be developed in conjunction with councils and concentrated in areas where they will lead to the greatest shift in journeys to active travel.
• The 3 obvious places for initial schemes are Derry-Londonderry and Bangor, given their population densities and transport hubs, and Craigavon, given its existing ‘Black Paths’ network and the higher number of people who currently walk and cycle in the area already.
• Within these urban areas there should be one section of cycling infrastructure built to a high specification together with traffic calming measures and speed limit reductions on surrounding streets. This is likely to show quick results which can be learned from, shared and repeated across other urban areas, in turn creating a willingness from local politicians and residents to put up with disruption and possible loss of space for cars, as they will see the positive impact a high-quality scheme can bring.
• In these areas councils should be engaged to make decisions on which schemes should be the priority, thus giving local representatives and residents a say and a sense of ownership of the schemes.
• Before schemes are delivered it is imperative that data gathering takes place to set out the base level for active travel journeys so ‘before and after’ comparisons can be made. Public ‘cycle counters’ have been used across the UK and provide fun and live public engagement with active travel journeys for locals.
• Beyond these 3 areas a detailed modal shift analysis should be conducted for the 10 most populated areas of NI, employing similar metrics to the Department for Transport-funded Propensity to Cycle Tool developed by Leeds University. The Department should fund a version of the tool to be used in Northern Ireland, the only UK nation which does not have its own version. Further, more ambitious plans should be based on results from the resulting benefit-cost ratio.
• Lack of local input and local understanding.  While we congratulate the Department on the range of places where engagement events were held, it was clear that many were barely attended, and local representatives in several locations were unaware or uninterested.  The plan shows very clearly the need for the Department to establish the long promised Steering Group made up of representative bodies and local cycle representatives. Many of the major issues with the plan could have been avoided with early engagement on this level.
• Any NI-wide plan to increase active travel needs to consider lower cost measures to increase both safety and the perception of safety for people walking, wheeling and cycling.  In the short term there needs to be a greater focus on wide ranging speed reduction measures such as the 20mph default rollout in Wales which has reduced KSIs on these roads by around 100 people in its first year. The NI Highway Code also needs to be updated in line with the 2022 changes to the GB code which protect people travelling actively through the Hierarchy of Road Users and the new junction priority rules. 

Low level recommendations 

Given the delivery of high-quality active travel infrastructure will be relatively new to Northern Ireland, there is an opportunity to create unique features on these routes.  Ideas from both within Northern Ireland and beyond offered below: 

• Artwork in underpasses/tunnels much like the Yorkgate Underpass in Belfast.
• Clock/temperature sculptures.
• Cycle counters.
• Angled bins for easier deposits from those cycling.

• Information signs which provide travel time to top destinations by cycling/walking rather than distance. These should also include names of places which you can get to by walking and cycling e.g. supermarkets, schools, parks, leisure centres, transport hubs, and town centres. The more awareness people have about how realistic active travel is for the places they want to get to, the more likely they will be to try it out.