Limerick Cycling Campaign, along with Limerick Pedestrian Network, Limerick Chapter of the Georgian Society and Limerick Cycle Bus have compiled a list of five core deficiencies in the current draft of the Limerick Shannon Metropolitan Area Transport Strategy (LSMATS), and the actions needed before productive consultation can proceed. Below is our open letter. See the PDF of this open letter which also includes referenced appendices.
Minister Eamon Ryan
Ms. Anne Graham
Chief Executive Officer
National Transport Authority
28th October 2020
RE: Limerick Shannon Metropolitan Area Transport Strategy – Open Letter
Dear Minister Ryan and Ms. Graham
Advocacy groups including the Limerick Cycling Campaign, Limerick Pedestrian Network, Limerick Cycle Bus and the Limerick Chapter of the Irish Georgian Society are calling today for a review of the draft Limerick Shannon Metropolitan Area Transport Strategy (LSMATS).
Collectively we are requesting that the NTA and the Minister for Transport pause the current process to :
- align LSMATS with the climate and active travel commitments made in the current Programme For Government, the Living With Covid Plan, the Climate Action Plan, and the National Planning Framework.
- bring an updated draft of LSMATS forward for a subsequent round of public consultation that allows for meaningful stakeholder and public engagement.
We believe the current draft of this document lacks integrity and credibility, does nothing for Limerick in 2020 and will struggle to deliver for Limerick and the Shannon region over the next twenty years. LSMATS is the oversight document that establishes the transport ambition in the region for the years ahead. This strategy document will be a reference point for active travel planning in the region until 2040 and we cannot stand over the abject lack of care and attention given to such a task, when transport impacts so heavily on every facet of our society.
LSMATS is being presented as a non-statutory document. However, it will be adopted into the Limerick City and Council Development Plan 2022-2028, which will give it statutory status. The ambitions set out in LSMATS (or lack thereof) will be locked into the city at least for the lifetime of the Development Plan. Furthermore, when we have made this point previously, we are guided to an Implementation Plan – that we cannot see or consult on.
Five Core deficiencies in the current strategy and the actions needed before productive consultation can proceed
1. Ground the Strategy with Real Targets
LSMATS in its current guise has no targets. Without targets, how is success or failure measured? It makes it difficult to suitably direct resources efficiently and apply oversight to monitor delivery. The proposed implementation table is inadequate. There are no significant projects scheduled for completion in the city within the next 10 years. Almost all projects are scheduled to take 20 years to complete. This needs to be addressed.
The addition of clearly defined key performance indicators KPIs that are aligned with project objectives will help focus efforts on choosing the correct methods that will deliver results. Targets should be set for;
- Infrastructure delivery targets (project stages timeframe)
- Modal Shift (specific targets for Education Journeys, work journeys, leisure journeys along with journey lengths)
- Health and Inclusion parameters
- Carbon Mitigation Targets (clear targets should be set in line with the Climate action plan objectives and programme for government commitments – see Appendix 1.2 of the PDF letter)
- and other indicators of delivery on defined objectives.
Targets should align with independently monitored checkpoint reviews carried out at 2-year intervals for the duration of the strategy. These checkpoint stages will allow for a review, report and alignment or discontinuation of successful and unsuccessful methodologies employed to deliver on the strategies objectives.
2. Engage in Meaningful Public Consultation
Public consultation on LSMATS by the NTA and LCCC has been negligible. It falls short in every way of public sector guidelines (DPER 2016). No public meetings were held, and groups like ours which engaged proactively (see Appendix 2 of PDF letter) were given little assurance of our submissions making any difference to the draft. All political parties in Limerick have voiced serious concerns about the document and have asked for the consultation process to be paused or repeated, to no avail. We call for a robust and meaningful consultation process. This needs to be held after this round of submissions are taken into account by the NTA and LCCC and an amended version of the draft is made public. There is further detail about this group’s engagement activity and the consultation process in Appendix 2 of PDF letter.
3. Update and Correct the Faulty Modelling
This is a process led document rather than a vision led document. It relies heavily on a data model to predict future car-based transport demand. We have assessed the modelling and found it to be of poor quality, It is based on many false assumptions while utilising out of date data. Future modelling should refine the options for meeting transport demand while meeting our carbon reduction commitments, including growing trends in Micro-Mobility (electric bikes and scooters). The modelling should play a supporting role to the overall transport vision, it should not define the vision.
4. Acknowledge the Role of Transport in City Placemaking, Health and Regeneration
A high-level vision for the future of Limerick must be a guiding principle of the transport strategy, where public health, transport inclusion, place-making, heritage protection and liveability form key areas for discussion and consultation. The strategy shows little regard for the Georgian heritage of our city centre. It shows little regard for the challenges our city faces and the hollowing out of the city core that is taking place at pace. It does not sufficiently tie in with the local authority’s analysis that identifies transport exclusion in the four main Regeneration areas. There is no accessibility planning underpinning this document or reference to actions that build up accessibility in communities where the local authority has readily identified social, physical and economic isolation. See Appendix 4.2 of PDF letter.
5. Align the Strategy with National Climate Action Policy & The Programme for Government
This strategy is based on increasing emissions until 2040. There are no targets for reduced emissions or sufficiently specific plans for how to reduce transport emissions. There was no process for carbon proofing this strategy on a systematic basis, to pivot to a near zero carbon investment strategy. In short this strategy is not climate action plan compliant. We are asking that LSMATS clearly sets out year on year targets on how it will align with the deliverables as set out in the Climate Action Plan, the Programme for Government and our international carbon reduction commitments.
Overwhelming cross-party support for a pause, redraft and re-consult
One singular positive we can see from the NTA’s poor handling of the LSMATS process is that it has united Limerick voices like nothing else has before.
Every political party elected to Limerick Council has come out in opposition to this poor draft strategy. Local metropolitan councillors from Fianna Fail, Fine Gael, Labour, Sinn Fein and the Green Party have put out a range of statements decrying its lack of vision and ambition.
Kieran O’Donnell TD, the chair of the Oireachtas Committee on Transport and Brian Leddin TD, the chair of the Oireachtas Committee on Climate are both calling for a pause and update to LSMATS. Sinn Fein’s Maurice Quinlivan TD and Senator Paul Gavan say it doesn’t even meet the minimum expectations of what LSMATS should deliver.
Stakeholder groups involved, from active travel groups such as the Irish Pedestrian Network and Limerick Cycling Campaign to business groups such as Limerick Chamber are united against the current plan. The Limerick Chamber of Commerce, which represents over 400 businesses in the region have called for the process to pause to allow for additional layers of stakeholder and public engagement to be added.
Public reps, alongside advocacy groups, have called on Minister Ryan and the NTA to review the document and take time to put together a strategy document that adequately meets the needs of the Limerick – Shannon Metropolitan Area over the next twenty years.
The lack of consultation with the wider public is very disappointing. Limerick’s Public Participation Network has had no contact from the NTA. We have had no consultation events from the NTA that were open to the general public. Whole sectors and communities have been completely excluded from any involvement in this process. The entire consultation and draft has shown itself to be out of touch with Limerick’s needs, it’s people and it’s public representatives.
LSMATS is the key to meaningfully achieving modal shift in our city, supporting a city core that’s on its knees due to what the strategy correctly refers to as “a legacy of car dependency, which has contributed to a wide range of economic, environmental and social issues including longer commutes, declining urban centres, poor public health, reduced air quality and noise pollution.”
We all stand united in the promise Limerick has. We’re proud of our city and believe in its immense potential to lead. Unfortunately, a Dublin-led process has ignored Limerick voices and expertise leading to what amounts to a low effort draft strategy that is completely out of touch with the needs of our city.
Consultation on LSMATS must be paused immediately. Submissions gathered to date should be folded into a new draft that better reflects the needs of Limerick people and the responsibilities of the NTA and Limerick Council under the Programme for Government and the Climate Action Plan. A revised draft should then be returned to the general public for a new round of consultation. Unlike the current consultation process, any future public consultation needs to be open, extensive, meaningful, inclusive of all voices and meet communities where they are.
To move to a final strategy document at this stage would be to ignore that Limerick has spoken with a singular united voice and said:
Limerick deserves better.
Limerick Cycling Campaign – Conor Buckely, David Tobin, Bruce Harper
Limerick Pedestrian Network – Madeleine Lyes
Limerick Chapter of the Georgian Society – Ailish Drake
Limerick Cycle Bus – Anne Cronin