Fine Gael made a submission on the planning process for Metro North this Monday morning through an oral presentation by Councillor Ray McAdam. This is available below.
“My name is Ray McAdam and I am the Fine Gael Councillor representing the North Inner City. I will making this presentation on behalf of myself and my Fine Gael colleagues in Dublin Central Senator Paschal Donohoe and Councillor Mary O’Shea.
There is no doubt that the Metro North will create massive benefits for the city of Dublin and the residents living along its route. Improving our transport infrastructure must be a key consideration as the city expands. The largest infrastructural project in our nation’s history, the sheer scale of the development requires that extra consideration be given at planning stage to reducing the impact on local residents as far as is possible. With this in mind there are a number of areas which we feel should be re-examined before the Railway Order is granted.
Traffic Management
Effective traffic management will be a key component in ensuring the Metro North works proceed smoothly and without undue disruption to local residents. While traffic management plans have been outlined in the Environmental Impact Statement (EIS), ‘Scheme Traffic Management Plans’ developed in consultation with key stakeholders are needed for a detailed, local level, assessment.
We are concerned also that the routes for construction traffic outlined have not adequately considered the commuter traffic which uses those same routes and the need to provide alternative routes or other mitigation measures.
There is also a need for a major incident traffic management plan, to specify how emergency vehicles will access the ventilation shaft and stations along the route should an accident occur in the tunnels. Details like this are too important to be left to chance.
Surface Water Management
The recent flooding across the country has highlighted the necessity of proper consideration of surface water management at planning stage. Residents have voiced significant concerns over the inadequacy of the current surface water management plans. There is already flooding in the area from Homefarm to Millmount and across the river to Botanic Road and there has been no attempt within the plans to address this.
The lack of detail within the EIS in relation to surface water management is especially perplexing given the flooding that has occurred in the past along the proposed route for the Metro North. The statement of the EIS that water will be discharged to foul or storm drains if there is capacity does not adequately address this issue, as the capacity of such drains has not been investigated to date. The same holds true for plans to discharge water to surface water bodies if available, but these too have been neither named nor investigated.
Furthermore, the surface water management plan within the EIS assesses the Griffith Avenue site as a tillage farm, with the RPA stating it intends to reinstate the land to tillage use to preserve the soil profile when construction is completed. This takes no account of the large development Dublin City University (DCU) is planning for this site.
We believe that a comprehensive surface water management plan is an essential element of such a large-scale development. A flood risk assessment needs to be carried out and mitigation measures put in place.
Working Hours
The works on the Metro North will necessarily cause huge disruption to local residents. Because of this, we stress that the hours of work in residential areas much be agreed and made a condition of the Railway Order.
With the exception of concrete pours, the EIS assesses all other works as daytime works. In light of this, there should be clarification of what other works, if any, should be done at night and an explanation given as to why this should be the case.
The RPA statement concerning night-time noise levels gives some cause for concern as it is stated that noise should not exceed 40dBLAmax, ‘except in cases where there are no complaints’. This appears to place the onus on individual residents to complain rather than having a policy of minimal disruption at night time. We feel works at night should be minimized and the issue of what and how frequently night works can be carried out should be addressed in the Railway Order.
Mitigation Measures
A number of areas which will require mitigation measures have not been dealt with adequately to date. The security of residents, especially the elderly in the area will be compromised as vibrations produced by tunnelling are likely to set off car and property alarms. No evaluation of what steps can be taken to reduce this interference was made in the EIS.
Changes in the quality of local air also need to be addressed. Residents within the 150m boundary face a range of increased costs as the dust produced will necessitate increased window, road and gully cleaning and residents will not be able to hang their washing outside to dry. Because of this, we believe the question of mitigation measures with regards air quality needs to be addressed.
Utility Diversions
Further afield, the lack of an economic assessment on the impact of Metro North to city centre businesses is an issue deserving of attention. Many local families rely on such businesses for their livelihoods and given that some of the city centre works are expected to last up to 64 weeks the RPA’s assessment that there will be a ‘temporary impact on adjacent businesses’ is simply inadequate.
Local businesses need accurate information so they may make assess the disruption in trade they will face and plan accordingly. An assessment of whether maintenance and upgrade works of utilities can also take place at this time by the RPA and Dublin City Council would allow future disruption to these city centre businesses to be minimised.
Access
Concerns over the lack of access to information have been voiced by many residents. We note that the Independent Expert’s GWP has suggested some additional guidance could be provided to increase the accessibility of the EIS to a non-technical readership.
The lack of either transcripts or webcasting of the oral hearings limits the ability of local residents to become informed participants as is their democratic right.
On a purely practical note, the evacuation plans for local schools and residences in the case of emergency, during both the building and operational phases of Metro North, need to be published and assessed. Residents have a right to know that their safety and that of their children will not be jeopardised by the works.
Local Issues
A number of local issues have also been brought to our attention by residents and we would like to highlight these below:
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There has been no assessment of vehicular or pedestrian traffic management around the ventilation shaft on Millbourne Avenue, despite assurances by the RPA that the ventilation shaft would be assessed in the same manner as the stations. We believe such an assessment must be made before the Railway Order is granted.
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Clarification must be provided as to pedestrian management at Drumcondra Station, where there are already a large number of users of the mainline rail station.
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It is acknowledged within the EIS that parking on Griffith Avenue will be reduced due to the works, but no mitigation measures have been offered to residents. Furthermore, the issue of where construction workers are to park also needs to be addressed.
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Millmount Avenue has been identified as the preferred route for construction traffic, which will force children on their way to school to negotiate heavy construction traffic as they will have to cross the site exit.
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A maintenance proposal and plans for traffic management during maintenance periods should be a requirement of the Railway Order as soil settlement during the construction of Metro North may necessitate road maintenance along Griffith Avenue.
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It is not clear where water collected at the pumping station in the ventilation shaft is to be pumped to. This should be clearly identified.
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Provisions should be put in place to ensure testing of the ventilation fans does not occur at night or at the weekends as there will be significant noise levels.
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Houses surrounding the Ventilation Shaft, where the noise level will increase significantly at night, and Drumcondra Station, which will be subjected to very high noise levels should be provided with sound proofing. No mitigation measures are currently in place.
We hope that An Bord Pleanala will actively consider these and other submissions so that this important project can go ahead with the right conditions attached. We feel these proposed measures will strengthen the Railway Order and that the concerns and questions raised by local people will be adequately addressed.”