The business group has questioned the rationale when the majority of people on board are following guidelines on facemasks.
Chief executive Richard Guiney says the numbers coming into the city are around half of what they were last year:
"The impacts on Dublin city centre are quite significant. Footfall has been rising slowly it is now in the mid to high 50 per cent rate of what it was in 2019.
"That is not enough to sustain retail and hospitality businesses and a lot of them are very vulnerable at the moment."
Dublin town also says prior to Covid two-thirds of people travelling to the city to shop or socialise used public transport to do so.
The public are now being advised not to use public transport, implying a direct link between public transport and public health.
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Office workers
They say the return of office workers in Dublin city is of vital importance to the city centre economy and they are the bedrock of custom for retail and hospitality businesses.
Mr Guiney also says with the public being discouraged from using public transport, recovery from the Covid lockdown will be made even more challenging for businesses, across all consumer facing sectors.
He added "Many businesses in Dublin city are considering permanent closure. For some this decision will be made in September, for others it will be deferred to December. The imposition of further restrictions and enhanced uncertainty regarding the future may hasten this decision.”