The Prague ring road received an EIA assessment in the north. What were our comments?

Last year, AutoMat submitted comments on the part of the northern Prague ring road between Ruzyně and Ďáblice (SOKP 518 and 519) as part of the EIA procedure. We now present a summary of their settlement and the terms outlined in the consent opinion.

Dealing with comments from city districts, associations, and the public is a standard part of the EIA (Environmental Impact Assessment) process, which ended for these parts of the Prague Ring Road this September. It also defines the conditions for the implementation of the plan.

Our comments mainly related to traffic induction, the regional variant of the ring road, and the bicycle transport solution. We expected the issued assessment to set the conditions for accompanying measures and solutions for bicycle transport in a comprehensive manner and in accordance with the Prague bicycle route system and the standards for bicycle routes.

In the assessment, cycle transport is addressed as part of the following condition:

As part of the follow-up project documentation from the point of view of recreational use of the territory, ensuring appropriate passage through the affected territory and the availability of all divided plots, ensure the implementation of bicycle transport following the city-wide system of bicycle routes CT A 0 hl. city ​​of Prague and the cycle general of the Central Bohemian Region in detail of specific localities and affected routes.

An integral part of the follow-up project documentation will be the Landscape-Urbanistic and Architectural Study D0 518 and D0 519 (JK ARCHITEKTI, s.r.o., 2022), from which some suggestions and recommendations can be derived that may be related to the plan D0 518, 519 Ruzyně – Březiněves and which will be examined and consulted with the concerned municipalities.

However, the mentioned circular cycle route A 0 does not address cross-links. There is a risk that the insufficient solution of cycle routes from the EIA management documentation will fix a bad state and it will not be possible to add adequate cycle routes.

Another problem is the mentioned landscape-urban study. This was not part of the documents for the EIA management and its availability is somewhat problematic. Section 518 (west of the Vltava) is referred to at least by the Prague-Suchdol Municipal Council. The study does not include all sections of city-wide cycle routes, some future and part of other routes of the city-wide system are designed as unpaved, which is not sufficient, especially for the superior route. In section 519, we assume similar deficiencies.

In the report, the responsibility for cycle routes is somewhat alibistily transferred from the state to the city and city districts, so that they “additionally” solve cycle transport even where their establishment is prompted by an investment. We consider it crucial to solve bicycle transport together with the circuit, as a fixed part of the transport system, not as a recreational accessory. Unfortunately, the conditions imposed by the EIA assessment are weak in this regard in our view.

A regional option is not on the table

V našich připomínkách jsme také požadovali prověřit variantu alternativní (regionální) trasy okruhu, který by vedl dále od města ve Středočeském kraji. Vypořádání nepočítá s regionální variantou s vysvětlením, že je regionální trasa méně příznivá z hlediska ovlivnění obyvatel znečištěním ovzduší, hlukovou zátěží a větším záborem bonitně cenné půdy. Takové zdůvodnění nicméně dlouhodobě zpochybňuje spolek Rozumná doprava, který se o regionální variantu zasazuje. Řadu negativních dopadů obnáší i současný záměr, který navíc prochází Přírodním parkem Drahaň-Troja.

In our comments, we also requested to examine the option of an alternative (regional) circuit route that would lead further from the city in the Central Bohemian Region. The settlement does not take into account the regional variant, explaining that the regional route is less favorable in terms of impacting residents with air pollution, noise pollution, and a greater occupation of valuable land. However, such justification has long been questioned by the Rozumná doprava association, which advocates for a regional option. The current project, which also passes through the Drahaň-Troja Nature Park, also has many negative impacts.

Thus, the assessment does not allow comparing multiple solutions and finding a compromise in terms of impact on the landscape, land occupation, population burden, and traffic induction towards the city. The goal of environmental impact assessment should be to find the form of the plan that will have the least negative impacts, not whether one pre-selected option will undergo a deterioration that is declared to be bearable.

Even from the analyzes used to promote the construction, it follows that instead of protecting the city, the circuit routed in this way will lead to an increase in the traffic load in the north of Prague.

Even the city did not fully comply with the demands

The capital also submitted its comments, specifically the deputy mayor for the environment. The city demanded, “to deal with bicycle transport following the city-wide system of bicycle routes of the Capital City of Prague and the bicycle general of the Central Bohemian Region in sufficient detail, and to design individual buildings by the valid Active Mobility Standards approved by the HMP Council in August 2022.”

Město jmenovalo řadu konkrétních opatření, zejména zklidnění vybraných ulic, doplnění cyklostezek a buspruhů podél páteřních komunikací a koordinaci záměru s plánovanými tramvajovými tratěmi do Suchdola a do Zdib. Samostatná příloha byla věnována požadavkům na detailní řešení cyklodopravy v jednotlivých úsecích.

The city named several concrete measures, in particular the calming of selected streets, the addition of cycle paths and bus lanes along the backbone roads, and the coordination of the plan with the planned tram lines to Suchdol and Zdib. A separate appendix was devoted to the requirements for a detailed solution for bicycle transport in individual sections.

The settlement of these comments is largely offset by the argument that cycle paths and similar projects are the responsibility of the city and not the state. Apart from the condition for the implementation of the A0 circular route, specific requirements for bicycle transport are not taken into account in the conditions. The tug of war over what is still in the hands of the state and what is already in the hands of the city is counterproductive for such an important building. Continuity of all types of transport and all the consequences connected with it should be dealt with comprehensively.

How do we proceed now? We will monitor the situation, as the current conclusions do not look very favorable, and we will express our opinion in subsequent proceedings. At the same time, we will urge the administration of the capital to negotiate routes according to the city-wide system and accompanying measures for the affected city districts. We will ask the developer of the assessment to explain how he will take the requested routes into account.

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