28th May 2021Eamon RYAN TDMinister for Transport,Minister for the Environment, Climate and CommunicationsBy email: transport2040@transport.gov.ieRe. National Investment Framework for Transport in Ireland (NIFTI)Dear Mr. Ryan,I am writing to you in response to your department’s public consultation on the draft National Investment Framework for Transport in Ireland (NIFTI) and in my capacity as Dublin’s MEP and a member of the European Parliament’s TRAN committee. I would firstly like to thank you for the opportunity to consult you on this very important topic.The NIFTI should aim to support zero-emission mobility in Ireland, aiming for the complete decarbonisation of the sector. Additionally, transport needs to be inherently aligned with wider spatial planning priorities and policies. The focus should be on investing in new active and public transport networks in order to align with these mentioned priorities. Transit-Oriented Development (TOD) should be developed and encouraged within the framework in order to facilitate sustainable as well as accessible, reliable and efficient travel. To this end, I would advise for the development of specific multi-level governance organisation, which can consider interlinked spatial and transport considerations, researching and proposing substantive interventions. However, while acknowledging the positive potentials TOD presents, I must advise that any consideration of TOD must acknowledge its potential effects on house-prices and overall (in) affordability of affected areas. This necessarily requires consideration of mitigating policies and interventions.The priority for decarbonisation should also include considerations for the reduction of the significant negative externalities of our transport system (accidents, biodiversity loss, congestion, emissions, air and noise pollution, well-to-wheel emissions, etc.) to ensure that the full and true price of transport on our environment and society is fully taken into account in investment interventions. New projects should be balanced against a checklist of the negative externalities produced, whereby projects that significantly increase negative externalities over the short-, medium- and long-term should not be funded.I acknowledge and appreciate the modality hierarchy present in the framework, namely its focus on active and public transport. However, as a national framework for transport investment, I have some concerns regarding your investment priorities and intervention hierarchy. I agree that the maintenance and modernisation of the existing infrastructure is necessary, but the development of a multimodal transport system should be the essential objective, and this should be reflected in this framework and the intervention hierarchy overall. When maintaining transport infrastructure, the needs of society and the environment must be central.Up to 69% of the steady state expenditure in your department (€1.178bn) goes towards road infrastructure. This situation inherently favours private car travel. This is why adequate consideration needs to be given to “induced demand” in order to avoid creating demand for unsustainable transport modes[1]. Maintenance and new interventions, as defined in your framework, and specifically in relation to the road network, could increase demand and congestion on our roads and therefore result in an increase of the negative externalities and investment requirements to meet this demand. Excessive focus on roads and the corresponding increase in demand for car travel, as well as increases in congestion, air pollution, and noise pollution and so on, would not mean prioritising the needs of all in society.It is necessary for policy to focus on making sustainable alternatives to driving cheaper. This relates to my previous point that asks you to ensure that the negative externalities caused by all transport modes, but especially private car travel, are thoroughly considered within the framework, its priorities and intervention hierarchy. We need to make public transport cheaper and more extensive, as public transport is a public good, and should not be viewed only through the lens of profitability.My thanks for the good work that you and your department have carried out to date.Warmest regards,Ciarán CUFFEGreen MEP for Dublin A link to the submission can be found here.