Appendix C Response to Public Consultation Comments for Draft NR2040

Draft NR2040 Public Consultation

A public consultation for the Draft NR2040 strategy, and accompanying environmental reports, was launched for a period of ten weeks, from the 5th August till the 14th October 2022. The public consultation included a dedicated website (nr2040.consultation.ai), which visualised key components of the strategy and hosted links to the PDF versions of all Draft NR2040 documents. In addition, the website hosted a link to a feedback survey.

The public consultation website and survey were published through several media channels:

1 Single public notice in a national newspaper on the day of the consultation launch, as required for SEA consultation

2 Bi-weekly Tweets through the @TIITraffic tweeter feed

3 Direct notice for Local Authorities Engineers via email, along with designed flyer at the beginning of consultation period

4 Second correspondence from TII to Local Authority offices in end of September

The following section summarises key comments collected in response to the Draft NR2040 strategy and the way they are addressed in the Final NR2040 strategy.

Section 4.2 of the SEA Statement summarises key comments collected in response to the NR2040 Environmental Reports.

Comments on Draft NR2040 Strategy

Overall, 65 submissions were collected in response to the NR2040 public consultation, from the general public and organisations at both a regional and a national level.

Comments were tagged by key themes:

»Infrastructure improvement – subdivided into Active travel, Integrated transport, and Safety »Regional connectivity – subdivided into General, Figure 5.1 ‘Interurban Connectivity’, Figure 5.2

‘Dominant function of National Primary Roads, and Figure 5.3 ‘Dominant function of National Secondary Roads’ »Sustainability »Engagement with policies »Further engagement »Mobility of People and Goods in Urban Areas

Additional comments were tagged as:

»Other

Table A.4 presents key stakeholder comments, grouped by the key themes identified above, alongside TII’s response describing how the comment has affected the update of the Final NR2040 strategy.

Transport Infrastructure Ireland

Table A.4 Key Stakeholder Comments from Public Consultation on Draft NR2040, September-October 2022

Theme	Comment		TII Response
Infrastructure Improvement	Active Travel	Suggest highlighting proposed NCN and its relationship with NRN.		NR2040 addresses the NCN in Section 6.2
				Implementation Structure
				“The Decarbonisation Investment Priority … incorporates
				Integrated Mobility programme, including major projects
				such as… an Active Travel programme, which includes the
				National Cycle Network (NCN).”
				No amendment has been made to the strategy in this
				respect at this time.
		Request for increased active travel modes through the implementation and improvement of cyclist and pedestrian infrastructure.		NR2040 addresses active travel modes in Section 6.1
				Commitments, in relation to (1) Sustainability, (2)
				Movement of People, and (3) Urban Congestion:
				1. “TII will promote inter-modal solutions that maximise
				overall transport efficiency in terms of infrastructure
				and resource use. For example, facilitating safe active
				travel along national road corridors that connect with
				rail and bus stations.”
				2. “TII will consider the needs of all road users for all
				projects. On urban dual carriageways and motorways
				approaching cities, TII will work with partner agencies
				to enable public transport and high-quality active
				travel alternatives for car users.”
				3. “TII will support the provision of segregated or offline
				active travel infrastructure adjacent to national roads.”
				As well as within Section 6.2 NR2040 Implementation
				Structure
				“The Decarbonisation Investment Priority … incorporates
				Integrated Mobility programme, including major projects
				such as… an Active Travel programme”

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				One of the four investment priorities of NIFTI and NR2040
				is Decarbonisation.
				“It encompasses three investment portfolio themes:
				Integrated Mobility; Electric Vehicle Charging; and Active
				Travel.”
				No amendment has been made to the strategy in this
				respect at this time.
Infrastructure Improvement	Active Travel	Consider reprioritisation of road space in urban areas to support the implementation of Active Travel measures.		NR2040 addresses active travel, across the entire
				National Roads network, rural and urban, in:
				Section 5.1.3, as one of the Investment Portfolios under
				Decarbonisation
				“TII is committed to delivering improved active travel
				provision in all its projects…”
				As well as in Section 6.1 Commitments, in relation to
				Sustainability (1), Movement of People (2), and Urban
				Congestion (3):
				1. “TII will promote inter-modal solutions that maximise
		Request improvement of active travel modes in rural areas, as well as urban areas.
				overall transport efficiency in terms of infrastructure
				and resource use. For example, facilitating high-
				quality active travel along national road corridors that
				connect with rail and bus stations.”
				2. “TII will consider the needs of all road users for all
				projects. On urban dual carriageways and motorways
				approaching cities, TII will work with partner agencies
				to enable public transport and high-quality active
				travel alternatives for car users.”
				3. “TII will support the provision of segregated or offline
				active travel infrastructure adjacent to national roads.”

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				And in Section 6.2 Implementation Structure under the
				Decarbonisation Investment Priority which includes “an
				Active Travel programme”.
				No amendment has been made to the strategy in this
				respect at this time.
Infrastructure Improvement	Active Travel	Request reduction of urban congestion and on street parking.		NR2040 addresses urban congestion in the Demand and
				Traffic Management Portfolio under the Movement of
				People and Goods in Urban Areas Investment Priority,
				Section 5.3.2
				“TII will support travel demand management measures for
				National Roads in the five cities… TII will expand traffic
				management measures in congested
				sections of national roads to ensure optimal vehicle flow to
				minimise carbon emissions…”
				TII remit is limited to the National Roads only and does not
				generally include on-street parking.
				No amendment has been made to the strategy in this
				respect at this time.
		Request consideration of new approach to the design and / or management of some urban national roads.		NR2040 is TII’s long-term strategy for planning, operating,
				and maintaining the National Roads network. Design
				guidelines are out of scope for the strategy.
				Design guidelines are developed in the Design Manual for
				Urban Roads and Streets (DMURS, 2019) and in TII’s
				Design DN-GEO-03084 Treatment of transition zones to
				towns and villages on national roads (2021)
				DN-GEO-03084 (tiipublications.ie)
				No amendment has been made to the strategy in this
				respect at this time.

Transport Infrastructure Ireland

			TII Response
Theme	Comment
	Active	Request to re-evaluate pedestrian phase timing and duration on junction crossing national roads.		NR2040 addresses vulnerable road users’ safety in
				Section 5.1.3 Active Travel
				“TII is committed to delivering improved active travel
				provision in all its projects, such as improving the safety
				of National Roads for active travel users and reducing the
				severance caused by some National Roads in urban
				areas.
				As well as within Chapter 6. Implementation Section 6.1
	Travel	Request provision of safe crossing points for cyclists / pedestrians across the National Road Network.
				NR2040 Commitments, in relation to the movement of
				people, “TII recognises that busy urban motorways, ring
				roads and town bypasses can be hostile environments for
Infrastructure Improvement		Request development of improved pedestrian and cycle crossing along National Roads to combat existing severance and enable better integration [specific project request]		pedestrians and cyclists wishing to cross. TII will identify
				and remedy severance impacts from National Roads.”
				Specific investments are not within the NR2040’s scope
				and should be developed at a project level through
				existing processes, outlined in Section 6.3 Project
				Development Process.
				No amendment has been made to the strategy in this
				respect at this time.
	Integrated Transport	Suggest highlighting the role which the national road network can play in achieving greater inter-modality at key locations (e.g., strategic Park and Ride facilities), facilitating the use of sustainable modes of transport within urban areas.		NR2040 addresses integrated mobility Section 5.1.1
				Integrated Mobility
				“TII will contribute to integrated mobility by investing in
				measures such as Park and Ride / Share and bus
				prioritisation, where appropriate along National Roads.”
				As well as within Section 6.2 Implementation Structure, in
				relation to Decarbonisation, which “incorporates
				Integrated Mobility programme, including major projects
				such as: core bus corridors, bus and passenger facilities,
				Park & Ride and Park & Share”

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				No amendment has been made to the strategy in this
				respect at this time.
Infrastructure Improvement	Integrated Transport	Request implementation and improvement of the public transport network infrastructure.		NR2040 addresses integrated mobility in Section 5.1.1
				Integrated Mobility
				“TII will contribute to integrated mobility by investing in
				measures such as Park and Ride / Share and bus
				prioritisation, where appropriate along National Roads.”
				As well as within Section 6.1 Commitments, in relation to
				(1) Future Demographic Growth Trends, and (2)
				Movement of People:
				1. “TII will ensure that any future implementation of
				demand management proposals on the National
				Roads network aligns with the National Sustainability
				Mobility Policy as well as NIFTI Modal and Intervention
				Hierarchies.”
				2. “On urban dual carriageways and motorways
				approaching cities, TII will work with partner agencies
				to enable public transport and high-quality active
				travel alternatives for car users.”
				No amendment has been made to the strategy in this
				respect at this time.
		Request increasing Park and Ride facilities.		NR2040 addresses Park and Ride facilities in Section
				5.1.1 Integrated Mobility
				“TII will contribute to integrated mobility by investing in
				measures such as Park and Ride / Share and bus
				prioritisation, where appropriate along National Roads.”
		Support of EV charging infrastructure at Park & Ride locations served by the National Roads network		NR2040 addresses EV charging infrastructure at Park and
				Ride locations in Section 5.1.2 Electric Vehicle Charging
				“TII will work with the Department of Transport’s Zero
				Emissions Vehicles office to support the delivery of the
				national EV charging infrastructure in line with its EV

Transport Infrastructure Ireland

			TII Response
Theme	Comment
	Integrated Transport			Charging Infrastructure strategy, currently under
				development.”
				Specific investments are out of scope for the strategy
				and should be developed at a project level through
				existing processes, outlined in Section 6.3 Project
				Development Process.
				No amendment has been made to the strategy in this
				respect at this time.
Infrastructure Improvement		In reference to the Rail Freight 2040 strategy, there are no proposed rail links to Rosslare Port.		NR2040 is TII’s long-term strategy for planning, operating,
				and maintaining the National Roads network, under the
				remit of TII.
				The Rail Freight 2040 strategy is under the remit of
				Iarnród Éireann and as such out of scope for the current
				strategy.
				No amendment has been made to the strategy in this
				respect at this time.
	Safety	Need for safer and more accessible roads by increasing signage, speed cameras, safety training / road education, road maintenance / upgrades, better adaption to extreme weather conditions caused by climate change, lower traffic speeds (including speed limits).		NR2040 addresses (1) Road Safety, (2) Asset
				Management & Network Operations and (3) Resilience &
				Climate Adaptation in Chapter 5. Investment Priorities
				and Portfolios, as three portfolios under the Protection
				and Renewal Investment Priority:
				1. “TII will deliver on its actions in the Road Safety
				Strategy (2021-2030) and collaborate with partners
				to deliver on supporting actions… TII will target
				investment on sections of national roads with the
				highest risk of fatal or serious injury…TII’s road safety
				programme will focus on achieving safe roadsides
				and a safe environment for vulnerable road users in
				line with the safe systems approach.”

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				2. “A key priority for TII is to maintain the existing
				National Roads network to a robust and safe
				standard”
				3. “There is need to ensure the road network is resilient
				to the effects of climate change…TII is continually
				maintaining and renewing road pavements and road
				assets such as signage, crash barriers and noise
				barriers. Adaptation to climate change is included in
				drainage designs by strengthening bridges and
				raising of roads…”
				No amendment has been made to the strategy in this
				respect at this time.
Infrastructure Improvement	Safety	Traffic noise can be a serious environmental and health issue for residents that are adjacent to high-speed roads. It is considered that the strategy should be supportive of measures to reduce the noise impact of existing roads on residential communities, particularly in the context of larger towns and cities.		NR2040 addresses road related noise in Section 5.2.3
				Resilience and Climate Adaptation “TII is continually
				maintaining and renewing road pavements and road
				assets such as signage, crash barriers and noise barriers”
				and in Section 6.1 Commitments, in relation to
				Sustainability “In line with its legislative remit, TII will work
				with relevant bodies to support measures to reduce air
				quality and noise impacts from road transport.”
				No amendment has been made to the strategy in this
				respect at this time.
		Request more investment in effective traffic calming on national roads in smaller towns and villages that have not been bypassed.		NR2040 is TII’s long-term strategy for planning, operating,
				and maintaining the National Roads network.
				In Section 6.1 Commitments, in relation to the movement
				of people, “TII recognises that busy urban motorways,
				ring roads and town bypasses can be hostile
				environments for pedestrians and cyclists wishing to
				cross. TII will identify and remedy severance impacts from
				National Roads”.

Transport Infrastructure Ireland

					TII Response
Theme	Comment
Infrastructure Improvement	Safety					Specific investments are not within NR2040’s scope and
						should be developed at a project level through existing
						processes, outlined in Section 6.3 Project Development
						Process.
						No amendment has been made to the strategy in this
						respect at this time.
Regional Connectivity	General	Consider the upgrade of national roads in the [specific Region] as a priority.				NR2040 does not suggest prioritisation of interventions
						or corridors, apart from NIFTI’s Investment Priorities and
						its Modal and Intervention Hierarchies.
			Request recognition of the strategic			Enhanced Regional and Rural Connectivity is one of
			importance of [specific Region].			NR2040’s four Investment Priorities, as developed in
		There is a need for positive discrimination when considering investment decisions relating to [specific Region].	There is a need for positive discrimination			Section 5.4 “The enhanced regional and rural
			when considering investment decisions			connectivity investment priority encapsulates the social
			relating to [specific Region].			and economic importance of the National Roads network,
						in supporting and balancing the regional cities, key
						settlements, and rural areas’ prosperity and growth,
						towards achieving Project Ireland 2040 goals”
						No amendment has been made to the strategy in this
						respect at this time.
		Request continued investment in the national road network between [specific areas] to maximise economic benefits.				NR2040 is TII’s long-term strategy for planning, operating,
						and maintaining the National Roads network.
						Specific investments are not within NR2040’s scope and
						should be developed at a project level through existing
						processes, outlined in Section 6.3 Project Development
						Process.
						No amendment has been made to the strategy in this
						respect at this time.

Transport Infrastructure Ireland

					TII Response
Theme	Comment
		Consider the re-classification of strategic regional roads as national routes.				TII analysis for NR2040 could inform decisions regarding
						reclassification from Regional to National and vice versa.
						Roads reclassification is a matter for the Minister, as laid
						out in the Roads Act, 1993 (as amended), Part II33, and is
						not within TII’s remit.
						No amendment has been made to the strategy in this
						respect at this time.
	General		Request consideration of how potential		TII’s investment priorities as developed through NR2040 will remain relevant for links that may be defined as part of the National Roads network in the future. No amendment has been made to the strategy in this respect at this time.	TII’s investment priorities as developed through NR2040
			new links on the NRN be accommodated			will remain relevant for links that may be defined as part of
			and implications on investment priorities.			the National Roads network in the future.
Regional Connectivity			Suggested that NR2040 should consider
			how potential new links on the National			No amendment has been made to the strategy in this
			Roads network would be accommodated			respect at this time.
			and how these would affect TII’s
			investment priorities. Potential new links
			could include [specific corridors].
	Figure 5.1 Interurban Connectivity	Ambiguity as to the meaning of section 5.4 - Does a corridor where interventions support the NPF/NIFTI 90kph average inter-urban speed target have a higher ranking than Lifeline/Arterial Roads.	Ambiguity as to the meaning of section			NR2040 does not suggest a ranking of interventions,
			5.4 - Does a corridor where interventions			apart from NIFTI’s Investment Priorities and its Modal and
			support the NPF/NIFTI 90kph average			Intervention Hierarchies.
			inter-urban speed target have a higher
			ranking than Lifeline/Arterial Roads.			No amendment has been made to the strategy in this
						respect at this time.
			Requests to include [specific corridors] in		Analysis has been re-examined and no amendment has been made to the identified corridors in Figure 5.1 at this time.	Analysis has been re-examined and no amendment has
			Figure 5.1 as corridors where			been made to the identified corridors in Figure 5.1 at this
			interventions support NPF/ NIFTI 90kph			time.
			target
			Request more detailed information (with			TII’s National Roads Indicators report provides annual
			regular updates) regarding current			updates on the performance and use of the National
			average speeds on national roads be			Roads network.
			made available.

33 The Government of Ireland, Roads Act, 1993 (as amended)

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				No amendment has been made to the strategy in this
				respect at this time.
Regional	Figure 5.2 Dominant Function of National Primary Roads	Request [specific routes] be identified as an ‘International Connectivity’ route or as a ‘Regional Connectivity’ route.		The strategy has been updated to represent Ireland West
				International Airport (Knock Airport) for international
				connectivity in Figure 5.2
				No further amendment has been made to the identified
				corridors in Figure 5.2 at this time.
Connectivity	Figure 5.3 Dominant Function of National Secondary Roads	Requests for [specific] amendments to Figure 5.3		The strategy has been updated to represent sections of
				the N56 as Collector and Arterial Routes, instead of
				Lifeline Routes.
				No further amendments have been made to the identified
				corridors in Figure 5.3 at this time.
		Consider applying a separate funding mechanism to life-line routes, given their key strategic importance.		NR2040 has established a separate funding mechanism
				for National Secondary roads, elaborated in Section 6.2
				NR2040 Implementation Structure and illustrated in
				Figure 6.1.
				No amendment has been made to the strategy in this
				respect at this time.
Sustainability		Need to reduce vehicle use.		NR2040 supports a shift to more sustainable modes of
				transport including public transport and active travel
		Promote zero emission / alternative fuel vehicles.		modes and promotes decarbonisation as one of the
				investment priorities.
				No amendment has been made to the strategy in this
				respect at this time.
		Request quantitative terms of how NR2040 will contribute to the decarbonisation of the transport sector.		TII’s National Roads Indicators report provides annual
				updates on the performance and use of the National
				Roads network including Emissions.

Transport Infrastructure Ireland

					TII Response
Theme	Comment
						No amendment has been made to the strategy in this
						respect at this time.
		Suggested that NR2040 takes account of upcoming and future requirements in relation to a net zero-carbon transport future in developing infrastructure projects.				NR2040 is in line with the National Policies, reviewed in
						Chapter 2 Policy Context, and sets Decarbonisation as an
						Investment Priority, in Section 5.1, and includes TII’s
						commitment, in Section 6.1, to appraise all National Road
						projects “in the context of compliance with Ireland’s
						climate change targets, in line with the Governments
						Climate Action Plan, NIFTI and in accordance with the
						Department of Transport’s Common Appraisal
						Framework.”
						No amendment has been made to the strategy in this
						respect at this time.
Sustainability		Consider recognising to a greater extent, the impacts of transport on air quality and noise, as well as clarifying TII’s role in environmental noise management.				The strategy has been updated in Section 3.4 to provide
						further detail on the impacts of transport on air quality
						and noise.
						TII’s legislative remit is set down in the Roads Act 1993 (as
						amended), referenced in Section 1.
						No amendment has been made to the strategy in this
						respect at this time.
			Consider including a target for reducing			NR2040 is a high-level strategy. The commitments will
			the population exposed to environmental			influence projects on an ongoing basis. Continued noise
			noise from national roads in the strategy			monitoring and environmental impact assessments are an
			commitments and outlining specific			integral part of the project development and appraisal
			environmental objectives covering			process and will inform impacts including those related to
			environmental noise, noise action plans,			noise.
			mitigations, and support for Local			No amendment has been made to the strategy in this
			Authorities.			respect at this time.

Transport Infrastructure Ireland

					TII Response
Theme	Comment
Sustainability		Consider reviewing the effects of climate adaptation and resilience to a greater extent.				NR2040 addresses climate adaptation and resilience in
						Section 3.3. In addition, TII’s Climate Adaptation Strategy
						2022 includes further detail on the matter.
						No amendment has been made to the strategy in this
						respect at this time.
Engagement with policies			Supportive of National Roads 2040, in		-
			providing a clear context for the national
			road network as it relates to key areas of
			Government policy, including the National
			Planning Framework, the National
			Development Plan and the Climate Action
			Plan
		Consider highlighting the potential for greater alignment between National Road Network planning and National Ports Policy.	Consider highlighting the potential for			The strategy has been updated to include review of the
			greater alignment between National Road			‘National Ports Policy’ in Section 2.9 and mentions that
			Network planning and National Ports			‘Integration between planning and policy for ports with
			Policy.			that of the transport system should be of high priority. TII
						recognises the potential for greater alignment between
						planning and policy for Ports with that of the National
						Roads network.
						No amendment has been made to the strategy in this
						respect at this time.
		Consider engaging with and responding to the 2022 OECD report entitled Redesigning Ireland’s Transport for Net Zero: Towards Systems that Work for People and the Planet.				The strategy has been updated to include review of the
						OECD report ‘Redesigning Ireland’s Transport for Net
						Zero: Towards Systems that Work for People and the
						Planet’ in Section 2.8 and mentions that ‘The NR2040
						strategy has been developed in accordance with the
						OECD recommendations presented above and
						recognises the issues of increasing car use and
						emissions. TII widely supports the mitigations measures
						that should be put in place to reduce these emissions
						and improve the well-being of Irish citizens, which have

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				been broadly responded to and recognised by the
				NR2040 investment priorities and commitments.’
Engagement with Policies		Request clarity on how the NR2040 and its investment priorities will align with the aim of the Government’s Climate Action Plan.		Decarbonisation is one of NR2040’s four investment
				priorities, elaborated in Section 5.1.
				It encompasses three investment portfolio themes:
				Integrated Mobility; Electric Vehicle Charging; and Active
				Travel. These are meant to promote reduction of road
				transport emissions and promote achievement of Climate
				Action Goals.
				In addition, Section 6.1 Commitments, details seven TII
				commitments for addressing the strategic long-term
				issue of Decarbonisation, including ‘National Road
				projects will be appraised in the context of compliance
				with Ireland’s climate change targets, in line with the
				Governments Climate Action Plan, NIFTI and in
				accordance with the Department of Transport’s Common
				Appraisal Framework. Predicted changes and/or targets
				associated with the levels of usage of each mode (e.g.,
				bicycle, car, public transport, truck, van) will inform this.’
				No amendment has been made to the strategy in this
				respect at this time.
		Consider the National Policy Objectives (NPOs) as well as the National Strategic Outcomes (NSOs).		NIFTI translated the National Planning Framework (project
				Ireland 2040), including its National Policy Objectives
				(NPOs), to a transport investment context and NR2040 in
				turn further develops NIFTI in the context of the National
				Roads network, as illustrated in Figure 2.1.
				NR2040 aligns with NPO2c where any interventions to
				improve regional connectivity will be developed in
				accordance with the NIFTI Investment Priorities and the
				Modal and Intervention Hierarchies.

Transport Infrastructure Ireland

			TII Response
Theme	Comment
				NPO2c states:
				“Accessibility from the north-west of Ireland and between
				centres of scale separate from Dublin will be significantly
				improved, focused on cities and larger regionally
				distributed centres and on key east-west and north-south
				routes.”
				No amendment has been made to the strategy in this
				respect at this time.
Engagement with Policies		Suggest regarding to the Avoid-Shift- Improve framework in the Final Strategy.		The strategy has been updated in Section 2.2 with the
				review of the Climate Action Plan 2023 which, amongst
				others, refers to the Avoid-Shift-Improve framework.
				Additionally, the strategy was amended to incorporate
				Appendix B Assessment of Alternatives Summary,
				including reference to the Avoid-Shift-Improve
				framework.
				In Chapter 7 of the SEA environmental report, the Avoid-
				Shift-Improve framework is addressed.
		The balance of priorities between achieving NIFTI Intervention Hierarchy and the NDP commitments and NSO of regional and rural connectivity is unclear.		NIFTI translated the Project Ireland 2040 NSOs to a
				transport investment context and NR2040 in turn further
				develops NIFTI in the context of the National Roads
				network, as illustrated in Figure 2.1.
				No amendment has been made to the strategy in this
				respect at this time.

Transport Infrastructure Ireland

			TII Response
Theme	Comment
		Current form of strategy is not consistent with the Regional Spatial and Economic Strategy (RSES) for the [specific region].		NR2040 is consistent with NIFTI, developing it in the
				context of the National Roads network, as illustrated in
				Figure 2.1.
				NIFTI Chapter 1 Overview, Section 1.4 Strategic
				Investment Framework for Land Transport outlines that:34
				“Future transport investment projects and
				programmes as identified in investment
Engagement with Policies		Consider amending the Strategy to clearly reflect the regional accessibility ambitions of the National Planning Framework, and the RSES for the [specific region].		strategies – whether they are developed by the
				NTA in the case of public transport, TII in the
				case of the National Roads network, or Local
				Authorities in the case of regional and local roads
				and other projects of a local nature – will have to
				demonstrate their fit with NIFTI and, by extension,
				with the NPF and NSOs.”
				NR2040 addresses the importance of regional
				accessibility, as highlighted by the NPF, in Section 5.4.1.2
				Regional Connectivity
				“Both the NPF and NIFTI indicate the importance of
				maintaining and improving accessibility to and between
				the more peripheral areas of the state…Any interventions
				brought forward will be developed in accordance with the
				NIFTI Investment Priorities and the Modal and
				Intervention Hierarchies.”
				No amendment has been made to the strategy in this
				respect at this time.
		Development plans should be consistent with RPOs and RSES.		Development plans are the responsibility of Local
				Authorities and should be consistent with RPOs and
				RSES.

34 Government of Ireland, National Investment Framework for Transport in Ireland (2021)

Transport Infrastructure Ireland

							TII Response
Theme		Comment
								NR2040 is TII’s long-term strategy for planning, operating,
								and maintaining the National Roads network.
								No amendment has been made to the strategy in this
								respect at this time.
Engagement with Policies				Consider addressing commitments in the NPF and the Regional Strategies.				The strategy has been updated to include in Section 6.5
								Collaboration,
								“It is important that future transport investment is
								coordinated and integrated with other sectors including
								land-use planning to avoid the case of urban sprawl and
								promote NSOs such as compact urban growth.”
					Consider aligning the strategy		The strategy has been updated to include Section 7 Monitoring Framework, including reference to the SEA Environmental Monitoring.
					implementation, monitoring and reporting
					with the environmental monitoring
					required under the SEA legislation, and as
					set out in the SEA ER.
Further Engagement					Request further engagement to clarify		The Draft NR2040 strategy was presented to Local Authorities in the TII Conference in Sligo in October 2022, with an invitation for open discussion.
					comments submitted and understand
					TII’s intentions regarding its priorities and
					funding of interventions before NR2040 is
					finalised.
				Request for further training for local authorities to become familiar with the content of the strategy and to translate its objectives into specific plans.	Request for further training for local			NR2040 provides guidance as to the Project
					authorities to become familiar with the			Development Process in Section 6.3.
					content of the strategy and to translate its
					objectives into specific plans.			The Draft NR2040 strategy was also presented to Local
								Authorities in the TII Conference in Sligo in October 2022.
								The slide deck presented was provided to all participants
								and will also be hosted on the nr2040.consultation.ai
								website alongside the Final Strategy and accompanying
								environmental reports.
	Mobility of People and Goods in Urban				Consider placing a critical emphasis on			Two of the four investment priorities of NIFTI and NR2040
	Areas				the need to safeguard the primary			are Protection & Renewal and the Movement of People

Transport Infrastructure Ireland

					TII Response
Theme	Comment
		functions of the national road network in catering for strategic movement, through the protection and optimisation of existing assets. This is of particular importance in relation to the movement of freight and access to international gateways.				and Goods in Urban Areas. NR2040 addresses freight
						movement in Section 5.3.2 Movement of Goods
						“TII will work with the Department of Transport and partner
						agencies to explore traffic and demand management
						measures to improve the journey time reliability required
						for the efficient movement of imports and exports.”
						As well as within Section 6.1 NR2040 Commitments, in
						relation to the Movement of Goods & Services
						“TII will provide/consider prioritisation measures such as
						dedicated freight lanes where such prioritisation results in
						greater transport efficiency.”
						No amendment has been made to the strategy in this
						respect at this time.
Mobility of People and Goods in Urban Areas		Consider highlighting the important role of the national road network in the provision of bus-based public transport services, both within urban areas and for inter-urban movements, through the application of appropriate design interventions, traffic management and demand management measures.				One of the four investment priorities of NIFTI and NR2040
						is the Movement of People and Goods in Urban Areas.
						TII recognises the importance of the National Roads
						network in catering for public transport and in Section 6.1
						commits to future actions to support the movement of
						people including ‘Connecting Ireland and prioritisation
						measures such as dedicated bus lanes where such
						prioritisation results in greater transport efficiency.’
						No amendment has been made to the strategy in this
						respect at this time.
		Urban Traffic Demand Measures should also consider rationalising tolling arrangements.				The strategy has been updated to include a reference to
						TII’s BRUCE project in Chapter 3. Long Term Strategic
						Issues for National Roads- Section 3.10 Asset
						Management and Operations
			Consider improving road access to			NR2040 addresses International Connectivity in Section
			[specific] ports			5.4.1.3 International Connectivity and identifies National

Transport Infrastructure Ireland

					TII Response
Theme	Comment
						Primary Roads with an International Connectivity
						predominant function as illustrated in Figure 5.2.
						No amendment has been made to the strategy in this
						respect at this time.
			Supportive of measures that will improve		-
			visitor access to the county through Cork,
			Shannon, and Kerry Regional airports via
			national roads.
Mobility of People and Goods in Urban Areas		Consider optimised vehicle flow on sections of the National Roads network [specific section mentioned] for the benefit of all users.	Consider optimised vehicle flow on			NR2040 addresses optimised vehicle flow in Section
			sections of the National Roads network			5.3.3 Demand and Traffic Management
			[specific section mentioned] for the			“TII will support travel demand management measures for
			benefit of all users.			National Roads… and implement other government policy
						on demand management on national roads… TII will
						expand traffic management measures in congested
						sections of national roads to ensure optimal vehicle flow
						to minimise carbon emissions, particularly from freight.”
						As well as within Section 6.1 NR2040 Commitments in
						relation to Urban Congestion
						“TII will promote traffic management interventions that
						help optimise traffic movement on urban National Roads.
						No amendment has been made to the strategy in this
						respect at this time.
Other		Consider applying a weighting to the investment priorities, that will compensate for infrastructural deficiencies.				NR2040 does not suggest a weighting of investment
						priorities, apart from NIFTI’s Investment Priorities and its
						Modal and Intervention Hierarchies.
						No amendment has been made to the strategy in this
						respect at this time.

Transport Infrastructure Ireland

			TII Response
Theme	Comment
		Consider including a clear acknowledgement of the pronounced and widening gap in the key indicators of economic performance and prosperity and outline how enhanced Road connectivity is one key factor towards addressing the pronounced legacy of under investment in multiple modes across [specific region].		Project Ireland 2040 provides the National Planning
				Framework (NPF) for enhancing regional development.
				The NPF provides three Regional Assemblies to
				“co-ordinate, promote and support the strategic planning
				and sustainable development of the regions.”
				Whilst Project Ireland 2040 provides the framework for
				regional development, NR2040 will support Project Ireland
				2040 in a transport context.
				No amendment has been made to the strategy in this
				respect at this time.
Other		Consider amending the Strategy to reflect the All-Island Dimension of Planning and Road Infrastructure		TII considers the NR2040 maps to represent the All-
				Island dimension of planning and road infrastructure as
				presented in the Draft Strategy published for public
				consultation.
				No amendment has been made to the maps in this
				respect at this time.
		Consider codifying the commitments made in the Strategy, which will help assess the commitments against the Strategic Environmental Objectives of the SEA.		NR2040 is a high-level strategy. The commitments will
				influence projects on an ongoing basis.
				No amendment has been made to the strategy in this
				respect at this time.
		Consider providing more focus on the Integrated Mobility, Electric Vehicle Charging and Active Travel goals (part of the Decarbonisation Investment Priority) for counties of a rural and peninsular nature.		Section 5.1. Decarbonisation encompasses three
				investment portfolio themes: Integrated Mobility; Electric
				Vehicle Charging; and Active Travel.
				For Integrated Mobility,
				“TII will contribute to integrated mobility by investing in
				measures such as Park and Ride, Park and Share and bus
				prioritisation, where appropriate along National Roads.”

Transport Infrastructure Ireland

			TII Response
Theme	Comment
Other				As well as “Improving connections to major public
				transport hubs”.
				TII is committed in supporting the Department for
				Transport and will “support the delivery of the national EV
				charging infrastructure in line with its EV Charging
				Infrastructure strategy, currently under development.”
				TII will continue to deliver active travel projects, such as
				improving the safety of National Roads for active travel
				users and reducing the severance caused by some
				National Roads in urban areas.
				TII are currently developing Greenway schemes in rural
				areas. Section 5.1.3 Active Travel of the NR2040
				addresses the NCN and Greenway network
				“TII will collaborate with other stakeholders to implement
				the National Cycle Network plan to cater for more active
				trips and expand the Greenway network nationwide, on
				behalf of the Department of Transport.”
				No amendment has been made to the strategy in this
				respect at this time.
		Consider the rapid evolving nature of EVs as a strategic issue and driver-assist technology, have the potential to impact on the operating capacity of national roads. Therefore, consider potential long- term implications for traffic on the national road networks from evolving vehicle design (including the design of road infrastructure both urban and inter- urban).		NR2040 has and will continue to consider technological
				change as set out in Section 3.9
				“TII is committed to the facilitation of Connected Driving
				on National Roads in collaboration with key stakeholders.”
				As well as within Section 5.1.2 Electric Vehicle Charging
				“TII will work with the Department of Transport’s Zero
				Emissions Vehicles office to support the delivery of the
				national EV charging infrastructure in line with its EV
				Charging Infrastructure strategy, currently under
				development.”

Transport Infrastructure Ireland

			TII Response
Theme	Comment
			No amendment has been made to the strategy in this respect at this time.
		Consider whether and how the interface of the national road network with relevant regional and local roads could be better be addressed at a strategic level to 2040 to help achieve the vision and objectives of TII for the national road network.		TII is cognisant that the National Road Network is not
				considered in isolation to local and regional solutions. TII
				supports holistic regional transport solutions and will
				continue to work in partnership with local authorities and
				the NTA to develop improvements at a local and regional
				level.
				No amendment has been made to the strategy in this
				respect at this time.
Other		Provide more emphasis on the implications of the development of multimodal autonomous freight movement.		NR2040 has considered multimodal freight in Section 3.7
				“Integration of road and rail freight is supported by TII and
				is important for reducing freight related congestion and
				emissions on National Roads.”
				Moving forward, TII will continue to work with the
				Department of Transport to consider opportunities for
				utilising the rail network for freight movements.
				NR2040 also considers Technological Change in Section
				3.9
				“TII is committed to the facilitation of Connected Driving
				on National Roads in collaboration with key stakeholders.”
				As part of NR2040, the development of autonomous
				vehicles will be monitored on a regular basis. The
				potential implications of autonomous freight movements
				will be considered in terms of possible interventions
				required on the National Road network.

Transport Infrastructure Ireland

			TII Response
Theme	Comment
Other				No amendment has been made to the strategy in this
				respect at this time.

Transport Infrastructure Ireland

y p

Theme	Comment		TII Response
Infrastructure Improvement	Active Travel	Suggest highlighting proposed NCN and its relationship with NRN.		NR2040 addresses the NCN in Section 6.2
				Implementation Structure
				“The Decarbonisation Investment Priority … incorporates
				Integrated Mobility programme, including major projects
				such as… an Active Travel programme, which includes the
				National Cycle Network (NCN).”
				No amendment has been made to the strategy in this
				respect at this time.
		Request for increased active travel modes through the implementation and improvement of cyclist and pedestrian infrastructure.		NR2040 addresses active travel modes in Section 6.1
				Commitments, in relation to (1) Sustainability, (2)
				Movement of People, and (3) Urban Congestion:
				1. “TII will promote inter-modal solutions that maximise
				overall transport efficiency in terms of infrastructure
				and resource use. For example, facilitating safe active
				travel along national road corridors that connect with
				rail and bus stations.”
				2. “TII will consider the needs of all road users for all
				projects. On urban dual carriageways and motorways
				approaching cities, TII will work with partner agencies
				to enable public transport and high-quality active
				travel alternatives for car users.”
				3. “TII will support the provision of segregated or offline
				active travel infrastructure adjacent to national roads.”
				As well as within Section 6.2 NR2040 Implementation
				Structure
				“The Decarbonisation Investment Priority … incorporates
				Integrated Mobility programme, including major projects
				such as… an Active Travel programme”