28th May 2021

Transport Policy Submission

This week, Key Town and Regional Growth centres throughout the country, including Ennis, came together to create a  group Public Transport Submission, available to read below.

Town Chambers Public Transport submission.

Submitted to the Department of Transport on the National Investment Framework for Transport in Ireland

May 2021


Chambers Ireland is the State’s largest business representative network, as an all-island organisation with a unique geographical reach; our members are the Chambers of commerce in the cities and towns throughout the country. Each of our member chambers are central to their local business community and all seek to promote thriving local economies that can support sustainable cities and communities.


Amongst our network of members are our ‘Town Chambers’ grouping who represent Key Town and Regional Growth centres throughout the country. Under the National Planning Framework these larger regional towns have population growth targets of 30-40%. These members, as part of our network all signed a pledge in September 2019 to support the Sustainable Development Goals as a framework to identify policy priorities and communicate our recommendations with a focus on five of the goals in particular to promote decent work and economic growth, sustainable cities and communities, advancements in gender equality, and progress in climate action.[1] 


On behalf of the larger Regional Towns in Ireland we are delighted to contribute to this national policy review, and are grateful to the Department and the Minister for having the foresight to instigate it.


Transport is perhaps the most important of state policy, all activities within the state, be they business, personal, private or otherwise, are contingent upon the appropriate transport infrastructure being in place to facilitate them. Following the introduction is our response to the questions presented in the public consultation survey.



Efficient, Inclusive and Sustainable transport infrastructure is vital to the development of Ireland, and the provision of a universal approach to public transportation sufficient to meet the demands, both current and future, of our Regional Towns is inherent to this.


Resource-efficient, balanced urban living is necessary for the creation of sustainable communities, whether that be local active travel supporting infrastructure, interconnected rural transport, inter-urban connections, or a blend of pedestrian and vehicle friendly road infrastructure.


Better investment in our transport infrastructure supports quality-of-life, environmental goals and the economic competitiveness of our larger regional towns in Ireland. Our member chambers are united in the vision of an Ireland where localities are transformed to become more person focused and getting the active transport infrastructure right is fundamental to that.


Our urban areas need to move towards locally active travel nodes, with efficient and affordable public transport linkages between urban nodes. This is as true for our towns and in particular the Key Towns and Regional Growth Centres, just as it is for our larger cities and MASP regions. Access to our towns and cities is becoming less dependent on private vehicles, however the lack of viable consistent alternatives is prohibiting this.


Each of our member Chambers is central to their local business community and all seek to promote thriving local economies that can support sustainable communities. Because of this deep sense of place is so fundamental to the identity of each and every Chamber they, perhaps more than any group, understand both the national/regional importance of inter-urban connectivity, and also how the intra-urban transport environment impacts upon their local economy.


The undersigned Chambers have the view that sustainable public transport is critical to the future economic wellbeing of our larger towns and believe it, and there is an inherent need to establish a universal standard of public bus infrastructure in each of the larger towns in Ireland, with an immediate need to invest into a sustainable fleet to encourage an inclusive modal shift to public transport in these towns that enables each of these larger regional towns achieve a 10minute town standard.


Consultation Questions

Section 2: Supporting the Project Ireland 2040 Vision

The National Planning Framework has established a clear direction for the sustainable development of Irish society in the coming decades, as articulated by its ten National Strategic Outcomes. How can transport investment support this vision?

Transport is the foundation of our society and Chambers Ireland have consistently argued[2] for greater and better investment in our transport infrastructure not only because of the quality-of-life benefits, but also for the economic competitiveness benefits, and the environmental benefits.


Unless we get transport right, we will get nothing else right. Most importantly we will not be successful in having our economy transition to carbon neutrality. Unless we transform how we move, how we live, and the economy that underpins our communities we will fail to develop into a sustainable society.

In the coming decades, there must be increased and sustained investment to deliver a safe and sustainable transport network which supports prosperous communities, promotes balanced regional development and helps to realise our climate change goals.

A focused plan is required for our regional urban areas, however we need to establish a baseline standard for urban public transport that enables the expected population growth. Access to our towns will become less dependent on private vehicles like cars, but only if viable alternatives are in place to enable this to happen.

It is essential that future investment in transport projects/infrastructure must meet at least one, or more, of the National Strategic Outcomes (NSOs). The more that a project can meet of the ten strategic outcomes, the better. We are also pleased to learn that for the occasions when a certain type of investment performs strongly against one NSO but negatively against another, these negative considerations will be balanced through a new strategic assessment stage in the project lifecycle.


Section 3: Delivering the National Strategic Outcomes

How can transport investment support the delivery of compact growth in our towns and cities in the coming years?

Sustainable transport infrastructure is vital to creating efficient, inclusive, quality, densified urban living which is necessary for the creation of sustainable urban areas and communities. We must connect the link required between Rural Transport and Regional Town Intra-Urban needs. The development of one without the other breaks the chain that will be required to connect rural communities and the large regional towns that service their hinterland and therefore reinforce the need for private vehicles to access our larger towns.


Towns in excess of 10,000 population already play an important role as key hubs for the rural areas they service. The NPF estimates an increase of one million people in the population in the next twenty years. Where this population lives and works will be a key factor in how Ireland develops, socially and economically, and the NPF has set the objective of accommodating 50% in towns and rural areas. The provision of appropriate transport infrastructure will play a crucial enabling role in the delivery of this objective and supporting quality of life for all Ireland’s inhabitants.


Making our regional urban areas attractive and accessible places will support the denser populations that the NPF projects (30-40% pop. increase) them to be able to meet. This will require significant additional investment in transport networks, particularly public and active transport networks. Our existing urban transport networks are to an inconsistent standard throughout our Regional Towns, operating on often out-dated and inaccessible fleet supported by out-dated locally enacted licences, and in almost all circumstance inadequately servicing the full extent of their current town’s needs, never mind their future needs.


For Key Towns and Regional Growth Areas where there is an existing bus service, these services often serve routes which are no longer optimal, often ignoring, or underserving, key developments such as third level centres of education, new industrial and retail parks, or recently developed housing. Often the service is infrequent or irregular, and the quality and accessibility of the vehicles undermines the environmental benefits of public transport, while also excluding members of the public; people with additional needs, children, the elderly, people with buggies are often excluded from using these services. To complement the other elements of NIFTI it is important that in Key Towns and Regional Growth Centres there is a standardised, consistent, rational, reasonable, and efficient public transport alternative to using private vehicles.

In order for this public transport to be effective, and for active transport to become the primary mode of travel for our daily needs, we must fully embrace the ten-minute town concept proposed for example in the Southern Regional Assembly Report, enhancing both quality of life and sustainability. Good public transport is essential to realise the vision of 10-minute towns across Ireland. While this report sampled the towns of Carlow, Tralee and Ennis; and significantly underlined the inconsistency in approach to the provision of public transport (bus services) within these towns, this report is a-typical of similar sized towns throughout Ireland in excess of 10,000 in population.


This report observed “that bus services tend to only cover specific corridors, as seen in the location of bus stops in the three towns. Therefore, the lack of bus service coverage limits the demand for residents to take public transport, as it would generally cater for residents who are within a 10-minute walk to the bus stop(s).”


The welcomed densification of Ireland’s Key Towns and Regional Growth Centres cities will place additional strain on inconsistent urban transport networks in these towns. For the NPF spatial goals to be delivered, it is therefore essential that a consistent and planned approach to the provision of public transport is provided for these regional urban areas. This will mean establishing through the NTA a minimum standard of sustainable urban bus service, that is supported to provide for not only the current demand, but also the future population growth demand of these urban areas, thus increasing public transport capacity and usage as a viable alternative to private car use as much as possible.


Outside of the major cities, the vibrancy of these towns must be supported as attractive places to live and work. This will mean ensuring reliable access to services and amenities, particularly for communities that are highly dependent on a small number of regionally important transport links. Given that public transport in many of these towns is largely inadequate, a key focus will be meeting maintenance requirements for existing infrastructure to provide a guaranteed level of connectivity to centres of scale. This must be supplemented by the targeted provision of new infrastructure and services where necessary.


When it comes to encouraging compact growth, the success of NIFTI is interdependent on the success of the NPF. On the one hand, to make our urban areas attractive places to live and work, transport policy and the transport network need to address urban congestion and provide affordable, comprehensive, frequent and reliable public transport and active travel options. On the other hand, given that the viability of many public transport solutions is contingent on the population density of a given area, the planning regime needs to successfully encourage urban development and densification and discourage sprawl.

For urbanisation and the delivery of compact growth in our towns in the coming years to be successful we need to have efficient, reliable, and safe transport in our urban areas.




How can transport investment enhance regional accessibility in the coming years?

The absence of local and regional public transports forces people to rely on private vehicles as their primary means of transportation, increasing congestion, which creates pressure for increased road capacity. This increased capacity impels housing development ever further from the urban cores.


At the inter-village and inter-town level, where possible, dedicated routes for active travel should feed into Local Public Transport Hubs in the centre of our larger towns, which connect people to the Town Urban Bus in a Hub and Spoke Model of transportation. Within those urban areas our towns need to place active travel first in how they adapt to the changing climate and economic pressures.

While we have made significant progress in building a national road network and through URDF funding we have invested significantly in the development of our town centres, we cannot expect people who live in the periphery of our regional towns to abandon the car entirely, without providing an alternative. We have not sufficiently integrated public transport infrastructure in our town revitalisation projects, and it is very much an afterthought in active travel and mobility measures in many urban areas. This must be urgently addressed with transport-oriented development at the core of town planning.


In doing so, regional accessibility will dramatically open up as people move to new areas that are easily commutable. This will have positive knock-on effects for regions across Ireland in the coming years as flexible and remote working become the norm and the need to reside in the main cities near employment centres lessens. This will also be a positive knock-on effect for many businesses that are based outside of large urban areas, bringing increased investment to regional and rural areas.


Investment in transport will play a key enabling role in the achievement of Strengthening Rural Economies and Communities (NSO 3), aiming to ensure that our regional towns are attractive places to live, capable of supporting vibrant local communities and become economic drivers for the rural regions they support.


How can transport investment strengthen rural economies and communities in the coming years?

To support the continued vibrancy of rural Ireland, rural areas must be attractive places to live and work and must be supported by larger towns that serve as local regional drivers. This will mean ensuring reliable access to services and amenities, particularly for communities that are highly dependent on private vehicles.


While headline projects such as BusConnects, Luas extensions, and the Dart Expansion plan are vital to the growth of our cities, our larger regional towns need a similar focus with a similar headline project that will provide a transformative sustainable urban bus system across regional economic driver towns across Ireland. Our member Chambers are united in the vision of an Ireland where localities are transformed to become more people-focused and getting the active transport infrastructure right is fundamental to that.


To support the livelihoods of people in rural communities, the planning and design process needs to be focused around transport networks, including public and active transport links. Sufficient infrastructure is required to enable inhabitants in rural parts of the country to go about their daily commute or errands to key towns, sustainability and safety, without the need to always use a car is a minimum requirement.


Furthermore, transport should be accessible and affordable to all. The most appropriate modern transport fleet determined by land use planning, geography, density of a location, urban and rural scale and future growth potential should be determined. We need to take this opportunity to emphasise the principal requirement for the provision of a smart, integrated, accessible, affordable and clean technology public bus service for these regional urban areas.


How can transport investment deliver sustainable mobility and encourage modal shift in the coming years?

In the absence of appropriate public transport options people are forced to use private vehicles, this is not solely an issue for our larger city regions, but also for the Key and Regional Growth towns throughout Ireland.


There is a strong relationship between the mode of transport that people take and the time it takes them to make that journey. Modal change will be achieved if people can access reliable, integrated and efficient public transport and active transport infrastructure to commute to work and access the wider urban environs.


With that in mind, 10-Minute towns are the ideal that transport policy should centre around for all our larger regional urban areas. Interconnected bicycle routes and pedestrian-permeable streets all expand the area which is accessible within those ten minutes. Conversely hostile transport architecture narrows that range, and forces people to rely on private transport. Within towns we already see significant strides being made to support people friendly streets, however the periphery of those areas are cluttered with traffic and over-subscribed parking areas because of the lack of viable public transportation.

How can transport investment help us to transition to a low carbon and climate resilient society in the coming years?

Our current national transport infrastructure facilitates the development of sprawl. If we are to shift our society towards a sustainable economic trajectory where regional locations are viable, it will be transportation and accessibility that will be the enabler.


Transport infrastructure needs to prioritise access to town centres and areas which are already developed and improve public transport connections to the periphery of our towns and surrounding rural areas so that private vehicles no longer become the sole option. In terms of reducing environmental impact, the most effective way of reducing transportation’s toll on the environment is to ensure that transport options which do not require the use of private vehicles are the easiest, quickest, and safest means of transit. Creating neighbourhoods that are porous to pedestrians, that are linked through energy efficient modes of mass transport to other porous neighbourhoods will be essential to transforming our relationship with our environment.


There are huge economic gains to such a strategy. In 2019, the AA estimated that the burden of car ownership for a typical Irish household is almost €11,000[3] whereas for Copenhagen households, of those who have a cargo bike, 30% of households have been able to replace their car with the bike. This massively expands discretionary income for those households, which are also households that are primed for spending their income closer to home.


A national strategy focused on delivering a standard of public bus infrastructure within our larger towns is needed, one that is centrally co-ordinated, and will interact with at a high level with our Local Authorities, Stakeholders and Operators.  One that will deliver a service for current and plan for future growth needs.


Section 4: Transport Investment

What challenges and opportunities exist with regard to decarbonising the transport sector?

Critical to our country’s economic development will be the maintenance and creation of sustainable communities in the journey towards our collective 2030 and 2050 climate targets. At the highest level this will require massive decarbonisation of our transport systems – which in practical terms will involve the vast bulk of our urban transport shifting towards active and public forms of transport.


The principle means of reducing congestion is to have more people using modes of transport that do not suffer from congestion and ensuring that people who use private vehicles that are prone to causing congestion have viable mass transport options. The challenges associated with this include the speedy rollout of active travel infrastructure universally across larger regional towns across the country; funding this rollout; and engaging the businesses and local communities to switch to more sustainable travel choices.



What challenges and opportunities exist with regard to improving mobility for people and goods in urban areas?

Parking Charges:

  • There is a capital costs of creating more people friendly streets and much of this work is underway in many of the larger towns throughout Ireland with the support of URDF funding and Local Authority investment. In many instances this capital works will lead to a reduction in car-parking spaces and therefore the associated local authority car parking charges, which will impact upon local authority balance sheets. While over a medium-term period, revenues will likely fall (the business rates revaluation process occurs over at least a 5-year cycle). The funding model for these mobility improvements will need to consider these effects and the incentives which may slow, or even stall, improvements at the local level. An associated key challenge will be to ensure that the electricity network operates reliably for all users as EV numbers increase, which will include work to modify local electricity distribution networks. Without incentives such as smart charging, users are unlikely to charge their vehicles at off-peak times. – A reduction of parking charges income for Local Authorities, through a shift to public transportation, can be counter-balanced through income generated through a share in the provision of public bus services and electric charging points.


  • Long commutes are detrimental to quality of life. This creates lost opportunities for everyone caught in this traffic and creates inflexibility in the workforce. The opportunity lies in the regional towns which are generally more compact, which means walking and cycling are practical ways of getting around. In the long-run the benefits of people-friendly streets that promote the utilisation of public transport in combination with active transport networks and technologies create a healthier urban environment, reduce CO2 emissions, encourages resilient local economies, and makes for a more efficient use of finite land resources – in the short-run, the reprioritisation of resources will be zero-sum.


What challenges and opportunities exist with regard to enhancing regional and rural connectivity, including to our ports and airports?

  • Rural areas present a significant challenge to transport planning, but also opportunities to increase levels of FDI in regions across Ireland that will need it in the post-pandemic recovery.

Better connectivity is critical to ensuring good accessibility for these communities, which they need to thrive. However, providing a transport service that meets the accessibility needs of all regional and rural users and businesses alike is a major challenge, given the range of different needs and the barriers to providing a reliable, cost-effective transport system. Limited public transport and declining local services are major factors behind this relatively poor accessibility in many areas and help to explain the car-dependent behaviour often found in these areas.


Section 5: Further Comments

Do you have any further comments to make on the National Investment Framework for Transport in Ireland?

There is an inherent need for a headline project specifically to initiate a uniform standard of quality Town Urban Bus in our larger regional towns sufficient to provide a viable alternative to private transport. This sustains the vitality of our towns and future growth of our regional urban areas.


A hap-hazard and often antiquated approach to public transport provision restricts the growth of many regional towns. The following final conclusions from this grouping of Chambers representing regional towns throughout Ireland provides some clear recommendations for policymakers:


  1. Plan and set a standard for Regional Town public transport (Town Urban Bus), rather than un-coordinated one-off local projects. This will maximise the value for money and efficiency of government goals. Establishing and then investing in a clear baseline standard for each Key Town and Regional Growth centres (towns in excess of 10,000 population that are targeted for growth) will improve outcomes and provide for more planned population growth in our regional towns.
  2. A Hub and Spoke Model for Larger Towns. At the inter-village and inter-town level, where possible, dedicated routes for rural active travel should feed into Local Public Transport Hubs in the centre of our larger towns, which connect people to the Town Urban Bus in a Hub and Spoke Model of transportation.
  3. Support the long-term national vision and goals for Regional Towns but being mindful of diverse local priorities. This will allow for future population growth targets to be planned rather than responded to. Assess and engage with the existing operators of public bus services in each town and establish a future focused service level agreement (SLA) for route provision and minimum fleet infrastructure in each town.
  4. Invest in the future – Invest into sustainable fleet, public service obligation levies for future growth focused route provision, integrated booking technology, and public engagement campaigns to encourage an inclusive modal shift to public transport in these towns.
  5. People Friendly Towns. As our towns become more people orientated, transport infrastructure must provide viable alternatives. Getting our transportation infrastructure right is a prerequisite to making our town and city centres vibrant again. Focus on how best to optimise the whole system to enable each of these larger regional towns achieve a 10minute town standard.
  6. Our transport infrastructure has to support the aims of the Climate Action Plan. Decarbonising transport must involve prioritising no-carbon active transport options.


It is essential that the Department takes a national view to enable the growth of the larger regional towns and invest into enabling infrastructure that achieves at least a minimum standard for public transport. We will not be successful in providing opportunities for population and employment growth if we hinder the accessibility of our larger regional towns.



Issued on Behalf of Regional Town Chambers in the Chamber’s Ireland Network:




[1] The Chambers Ireland SDGs. Available at:

[2] Chambers Ireland Submission on the National Development Plan Review to Renew Consultation – February 2021


This website uses cookies to enhance your browsing experience. By using this site you agree to our Cookie Policy Ok