CTTC submission on Greater Dublin Area Draft Transport Strategy 2013 – 2018

Submission by the


Coach Tourism and Transport Council of Ireland




The National Transport Authority

On the

 Greater Dublin Area


Draft Transport Strategy 2013 – 2018


1.      Background to the CTTC


The Coach Tourism and Transport Council of Ireland (CTTC) is the representative organisation for Ireland’s coach touring companies, and private coach and bus operators. All of our members are family-owned companies with a combined fleet of over 1,000 coaches, and we employ over 2,000 people directly. The CTTC believe that cost effective and efficient transport is a key component in promoting the economic wellbeing of the GDA which is of vital importance to the wider national economy.


The distribution of population is a critical factor in determining travel behaviour particularly in relation to key services such as work, education, and retail and leisure outlets. There has been a significant increase in population since 2006 in the commuter belt outside of Dublin city particularly in Fingal, Kildare, and Meath and there must be significant improvement in bus service provision in these peri-urban and semi-rural fringes of the GDA to satisfy the public transport needs where there is greater employment concentration.


Private operators while currently operating quality services in these areas are uniquely placed to improve the transport services in a cost efficient manner. The protection of existing PSO services is stifling any innovation which might be forthcoming from the Private Sector in provision of Express type services from various parts of the City along busy commuter corridors.


2.      Infrastructural Investment Programme issues identified


1.         Coach Parking within the city

The CTTC believe that a well planned investment framework is essential to ensure the objectives of the plan. In the region of €245 million will be spent on bus infra-structure during the life of the plan to improve bus stops, journey times, accessibility, integrated ticketing and general integration of service providers.


While this investment is welcome the plan fails to address the issue of coach parking in the city.


During the plans preparation there was limited consultation with private bus operators on the issue of coach parking in Dublin city. There is a proposal for a coach parking facility close to Dublin City Centre, however there is no timeline or costing for its provision nor is there any proposal for consultation and dialog with the relevant stakeholders. We strongly believe this major infrastructural barrier to the provision of a bus service to the city needs to be clearly addressed with locations, timelines and indicative budgets. The current text is aspirational and provides no commitment to deliver in the short to medium term. We request that this matter is clearly addressed in the final plan.


2.         Luas line disruption to Coach parking

Work on the Luas Cross City will have major implications for coach operators with the loss of Coach parking in Marlborough St. and Nassau St, yet the plan does not address this issue. An alternative coach parking area needs to be identified and secured for this purpose prior to works commencing. We again would ask for this matter to be addressesed in the final draft of the plan.


3.         Cruise Ship tourists coach parking and access


One of the key objectives of the plan is to sustain and promote economic grow within Dublin City and its immediate hinterland. Coach Tourism is a proven economic driver and income generator. In conjunction with daily tours operated by private operators to various tourist attractions within the city there are at present in the region of 80 to 90 cruise ships docking in Dublin Port on an annual basis, each cruise ship is serviced by up to 20 coaches transporting patrons (total in excess of 1000passengers) to Dublin City centre generating significant income to business’s.  


At present there is no officially designated collection/dropping off point for these passengers and the current point of disembarkation at Kildare St will be unavailable due to traffic management changes as a result of the new Luas line. It is essential that part of the €245 million budget for bus infra-structure is set aside for a central coach park within the city centre and the project is time lined. There is also a requirement for provision to be made for dedicated Coach set down areas at key tourist attractions such as the Book of Kells, Sports stadiums and concert venues.


4.         Bus contraction and fleet replacement

The report does not address the issue of bus usage contraction between 2006 and 2001 in respect of work trips despite the fact the fact that motor car usage remained almost static.


The report suggests that continued investment in new fleet, bus-stops and corridors will reverse the trend but we think this is highly questionable.

An independent review is required to identify the root cause of this contraction, and to differentiate between profitable and non profitable PSO routes. We would suggest that a major capital investment in the public transport bus fleet is not the answer.

5.         Bus Rapid Transit Proposals

The use of high quality bus bases transport systems has significant merit in that it delivers fast, comfortable and cost effective urban mobility through the provision of segregated right-of-way infrastructure, rapid and frequent operations delivering optimum customer service and satisfaction. The report states that there is a very significant saving to the state as they do not require the large investment in infrastructure compared to a light rail system and there is also the benefit of quicker implementation. We would strongly suggest that this initiative is unnecessary given the existence of rapid and efficient commercial services which operate at no cost to the State. BRT’s will be expensive despite being more cost-effective than light rail.

In view of the fact that private operators are providing high quality, cost efficient services without state subsidisation in some of the proposed areas under consideration there is an urgent requirement for private operators to be involved in this proposal as their participation could generate significant saving to the state and provide them with opportunities for business expansion.


3.      Conclusion

The CTTC welcome the publication of this draft Strategy. While comprehensive in nature the strategy focuses and is based on a system and structure of state subsidisation which could be argued is outdated and no longer sustainable in the current economic climate.


This document does not set out any meaningful role for private operators in subsidized services as provided under the 2008 Act. It sets out a programme of bus and other investment to 2018 which takes no account of any possible route tendering .It states that the bus fleet is too old and needs to be renewed to an average age of 7 years. That is laudable if no other option is available but it is our contention that private sector investment would be forthcoming if the NTA provides the right environment through competitive tendering. Issues such as service quality, branding, RTPI, bus-stops and emissions could all be dealt if a fair and thorough tendering process is initiated.


There is a need for incremental change, routes in the GDA need to be tendered out on a phased basis to private operators who have a proven track record in quality service delivery by doing so significant cost saving to the exchequer and the tax payer could be achieved.


The CTTC is committed to working with the NTA and other stakeholders to achieve a fully integrated and world class transport infrastructure in the Greater Dublin area, and we welcome the opportunity to constructively contribute to the implementation of the strategy.

© 2019 Coach Tourism and Transport Council of Ireland
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