Dart Undergound An Bord Pleanala Submission

19th August, 2010

dart underground

This is the submission that was made by Councillor Ray McAdam and I to An Bord Pleanala regarding this huge project and the impact in East Wall, North Wall and the inner city area.

Re Proposal to construct, operate, improve and maintain DART Underground railway line between Inchicore and East Wall, Dublin. Case Reference : PL29S.NA0005

Please find attached submission from Senator Paschal Donohoe and Councillor Ray McAdam to the Dart Underground Project and the specific impact of this project on the districts of East Wall and North Wall.

In introducing this we wish to emphasise the following points:-

– The current Railway Order does not recognise the residential nature of these communities. This residential dimension is explicitly recognised in the existing (and proposed) Dublin City Development Plan.

– This lack of recognition is demonstrated by the inexplicable decision to launch both tunnel boring machines (TBMs) from the East Wall area.

– This imposes an unacceptable level of burden on both of these districts. It is essential that the decision in relation to the launch of the TBMs be reversed and the level of burden be reduced through more precautionary measures and enhanced mitigation plans.

– We also want to emphasise our support for the Protect East Wall group, call for an Oral Hearing on this project and request the participation of this Group in the Oral Hearing.

– We also request our own participation in the Oral Hearing process.

This submission recognises the gain that the Dart Underground project will present to the city of Dublin. We contend that the burden of construction must be shared more equally across the entire city.

1. The need for an Oral Hearing into this project.

As this application for a Railway Order is being considered under the terms of the 2006 Strategic Infrastructure Act, the communities we represent have only had six weeks to consider the details of the documents lodged. An Oral Hearing is therefore necessary. The timeframe from when the documents were lodged to them becoming available and subsequent deadline for receipt of submissions is insufficient for detailed consideration of all the various issues of concern to the local communities. It is only through the holding of an Oral Hearing these matters and other potential difficulties will be resolved.

This is of particular importance when one considers that since the lodging of the draft Railway Order, contact numbers advertised by Irish Rail have not been manned and messages left by residents have remained unanswered. It is precisely for this reason that an Oral Hearing be held to provide a forum within which residential concerns are heard and actioned for the construction and operation phases.

Dart Underground is one of the largest infrastructural projects ever undertaken in the history of this State. Given the size of the project and the likely impact upon the communities in which the underground Dart will operate through, we would have expected a meaningful consultation between Irish Rail and all these communities. Unfortunately, the consultation undertaken by Irish Rail particularly with the community of East Wall bears little resemblance to that outlined in the Draft Railway Order. Therefore, we support the Protect East Wall group in their request for an Oral Hearing prior to any approval for a Railway Order.

We would also contend that it is necessary that East Wall and North Wall be considered as a single module during the Oral Hearing process. As these communities have been repeatedly excluded at “a stakeholder workshop”, consultation with “parties along the route” and parties “relevant to the preliminary EIS”, it is essential that the justified concerns of the residents and communities of East Wall and North Wall are adequately addressed.

2. Dublin City Development Plan recognises East Wall as a residential area – Dart Underground must do same.

This application fundamentally fails to recognise that East Wall is a residential area. The Environmental Impact Statement refers to this district as ‘industrial’. This is completely incorrect. Due to this mistake an un-acceptable amount of impacts are proposed for the East Wall district. This area consists of approximately 2,300 households with approximately 4,500 residents. The residential nature of this area is recognised in existing planning policy.

Firstly, this area is subject to an Area Action Plan. This strategy was initiated by Dublin City Council and the Docklands Development Authority in 2004 in recognition of the existing residential community and anticipated growth. This plan emphasises that:-

“The regeneration of the Docklands area, under the direction of the Authority and the City Council, now places the established residential community of East Wall in a rapidly changing economic and urban environment. From being an isolated dockland community, suffering from the decline in Port-related employment, East Wall is now at the heart of one of the fastest growing areas of Dublin city.”

Secondly, the existing and proposed Dublin City Development Plans zone the majority of land as Z1. This zoning status is to ‘To protect, provide and improve residential amenities’. This affirms the overwhelming residential nature of the East Wall district.

Due to this it is not acceptable that the current burden of impacts, as proposed by this Railway Order, be granted permission. City Development Policy recognises East Wall as a residential area. This submission asks that An Bord Pleanala also do so in their decision on the Dart Underground.

3. Re-allocate use of TBMs across the full city.

A fundamental request of this submission is to ensure that TBMs are allocated across the entire city as opposed to just the East and North Wall district. There is no justification for the allocation of all of this heavy construction work to one site. It will concentrate the burden of impacts to an unacceptable level in this area despite the fact that this district receives no particular gain from the project.

No justification for this decision is to be found in planning policy, the EIS or any statement from Iarnrod Eireann. We strongly request that it be reversed.

4. Impact of Noise on East Wall Community – Need for Strengthened Precautionary Measures and More Extensive Mitigation Plans

The East Wall Community has extensive experience of existing beside rail links and of managing upheaval during construction periods. A key concern of this submission will be the impact of noise on local residents. Experience of the work on the East Wall Railway Bridge shows that mitigation measures, of themselves, are not sufficient. The focus must be on minimising noise during the construction and operational phase. Mitigation measures must focus on the quantum of noise that is unavoidable.

Source of Noise

Noise is likely to emit from to different sources. These are:-

– General construction and operation

– Location specific work

All of this will generate a level of noise that is not acceptable for a residential community.

Sources of noise from the general construction and operation parcel include: noise from site clearing and use of TBMs and the general noise generated by the movement of trucks and vehicles through the area.

Of particular concern to this submission will be the role of blasting. The EIS notes the use of ‘high explosives’ and ‘propellants’ during construction phase but states that use will be limited and the impact will be over a short time period.

Specific sources of noise will include the construction of Operation Control Centre, new bridge and use of bridge at West Road, noise from North Wall yard, construction of ESB station at Abercorn Road, work on Sheriff Street Bridge and widened East Wall Bridge.

Role of Mitigation

Due to the variety of noise and the time duration of the construction work the Environmental Impact Statement does accept that mitigation will play an important role. There are a wide variety of proposed mitigation plans.

This is welcome but this submission does question whether an acceptance of the role of mitigation may reduce the need for precautionary measures from Iarnrod Eireann. We therefore strongly propose strengthened precautionary measures and mitigation plans that are more substantial and capable of independent review.

Recommendation – Increased precautionary measures

– That blasting should be confined to specific times of day. This period should be shorter than the proposed construction working times.

– Independent monitors should be appointed to ensure that the conditions of the Railway Order are strictly adhered to. This is vital as local authority resources may not be sufficient to monitor a project of this magnitude.

Recommendation – Strengthened mitigation plans

– Acoustic barriers must be increased in height.

– That the length of the acoustic barriers must be increased. They must surround all of the proposed works in the East Wall district.

– Acoustic barriers must be particularly strengthened on the West Road area due to the new bridge and proximity to line.

5. Vibration Impact of Dart Underground due to amount of ‘above ground work’ and lower depth of tunnelling

The impact of this project on the East Wall area during the construction phase will be unique. This is for two reasons.

Firstly, work will be taking place at a lower depth than many other parts of the city. Depth will act as an absorption measure for tunnelling work elsewhere. As operations will begin to descend at or near East Wall this absorption is denied to this district. Secondly, as two TBMs will be in operation near East Wall the vibration impact will be intensified.

There will also be a substantial vibration impact once this project is operational. The increase in train frequency will generate a higher level of vibration.

This submission points out that consideration is given to the impact of the Dart Underground works on various theatre and entertainment sites across the City. However no such consideration is afforded to a residential community such as East Wall. This lack of consideration is of particular concern in relation to vibration.

It is difficult to evaluate the strength of mitigation measures as the proposed ‘Noise and Vibration Management Plan’ does not accompany the Environmental Impact Statement. In the absence of this the only consideration afforded to the impact of vibration on local residents is to refer to the need for proactive and regular communication. Effective communication, while welcome, is not a substitute for reduced or non existent vibration.

The Property Protection Scheme will be vital for allowing residents to assess any damage caused to their property by vibration and to enable the claiming of expenses for same. Concerns exist regarding the physical area within which this scheme will be applicable.

It is also unclear why the applicant needs to specify a cap of €30,000 for expenses due to potential property damage. The proposed scheme includes measures for verifying that any damage is caused by Dart Underground works. If this is proven why should the resident potentially have to suffer any financial costs?

Recommendation – Reduced Vibrations and a Strengthened Property Protection Scheme

– That An Bord Pleanala request the publication of the ‘Noise and Vibration Management Plan’ in an Additional Information Request prior to the commencement of Oral Hearings on this project.

– That the cap on the value of expenses in the Property Protection Scheme be removed. If adequate verification measures are in place then no cap is required.

– That the area for which this scheme is applicable be increased.

– That further detail be supplied regarding how this scheme be conducted. We refer to our comments above on the need for independent monitors. A clear conflict of interest exists between the appointment of a contractor and using the same contractor to determine if any damage has been caused by their work.

6. Impact of Project on Flooding Risk for East Wall

Parts of East Wall have been severely impacted by flooding. This is compounded by the construction of East Wall on most reclaimed land. The project may lead to an alteration in the surface water levels within the district. The EIS does state that construction water will be discharged into the Liffey however the manner in which this will be done is of concern to this submission.


– That the site location be reviewed to minimise the risk of flooding in the East Wall area.

– That emergency plans be published to outline what additional resource would be made available to protect residents in case of additional flooding compounded by Dart Underground Construction works.

7. Impact of Increased Traffic levels in East Wall

Effective traffic management will be a key component in ensuring this project works smoothly and proceeds without undue disruption to the community of East Wall. However, the decision taken by Irish Rail in the draft Railway Order to base all tunnelling works in the East Wall area is a particular area of concern for this submission. We contend that as a result of this decision, there will be unacceptably high levels of construction and private vehicles coming in and out of East Wall and North Wall on a daily basis.

There are particular areas of concern with the Traffic Impact Assessment and the proposed mitigation measures that require further examination before a Railway Order is granted.

While traffic management plans have been outlined in the Environmental Impact Statement, there is a significant lack of detail in what has been provided to date by Iarnrod Eireann. This submission calls into question the claim in the draft Railway Order that the mitigation measures due to be put in place are “expected to fully address the anticipated transportation impacts” caused by construction work in East Wall.

Other outstanding issues of concern relate to the management of commercial vehicle movement through East Wall in order to avoid queues. These issues include:
– How will such movement work and what priority will be provided to the movement of local vehicles in the area?
– What will be the level of on-site parking for construction staff?
– The EIS claims that workers will travel predominantly to the area via public transport, how can this be guaranteed?
– Local residents are fearful that their on-street parking will be lost due to the inevitable influx of privately owned vehicles of construction staff.

Despite attempts to address local concerns about increased levels of traffic during morning peak hours, particularly along Sherriff Street, more effective management plans are required for non-peak hours. It would appear that during non-peak times substantial heavy traffic volumes can be expected in an area that normally does not experience such large traffic flows. Such volumes of traffic would have been necessary had tunnelling works were split evenly between Inchicore and East Wall.

The Environmental Impact Statement also makes reference to the need for road possession in East Wall. However, there is a lack of detail as to what roads will be taken into possession by Iarnrod Eireann throughout the construction phase and what level of access will be provided to local people during this time.

Recommendation – Effective Traffic Management Plans
– That An Bord Pleanala directs that an independent review of the traffic impact assessment take place.
– Resulting from this review, detailed scheme traffic management plans should be put in place and form part of any approved Railway Order.
– Limit the operation of commercial vehicles to between 7am and 7pm, Monday to Friday & 7am to 3pm, Saturdays and Sundays in the East Wall and North Wall area.
– No commercial vehicles carrying spoil to use Sherriff Street Lower as a route away from the site.

8. Impact of proposed DART Underground on North Wall

The scale of the proposed DART Underground and the associated construction works will also have a substantial impact upon communities in North Wall as well. The Environmental Impact Statement which accompanied the draft Railway Order highlighted a number of proposed works along or near Abercorn Road, Irvine Terrace and Church Street East. Residents on these streets have spoken to us about the worries they have about such plans.

The issues that we have highlighted below will have an immense impact upon this small, close-knit community. We would also argue that although we have not examined the impact of vibrations, noise and water in these areas of concern, we would urge An Bord Pleanala to consider the potential impact of each on these matters.

Significant concern exists regarding the proposal to construct an ESB substation at the junction of Abercorn Road and Sherriff Street Upper. Areas of concern include the proposed height of the building compared with homes in the area, the location of the substation, particularly its proximity to a residential area and the visual intrusion this facility will be. Further issues concerning nearby residents would be the noise emanating from the centre, electro-magnetic emissions as well as the associated traffic problems – both during construction and when operational.

There is reference to the provision of a Recharge Well at the rear of homes on Abercorn Road without any clear explanation as to why it is necessary, what the impact of it is and why is it so close to these houses? More information must be made available about this Well.

The proposal to allow for vehicular access to Irish Rail lands behind these homes will see up to “57 and 47 entering and exiting vehicles during the morning peak hour” traffic. This would mark a substantial increase in the number of vehicles using what is normally a quiet and residential road. The Traffic and Transportation chapter outlines that between 6 and 8 trucks will use similar access points in various areas along the route every hour. However, it does not adequately address whether the access point at 1 Abercorn Road will see such volumes of construction traffic. Of particular concern to this submission is whether HGVs will be allowed to use this entrance.

Another source of concern to residents in the Abercorn Road area is the proposed location of temporary two story office blocks. Such office use would occupy the footprint and height of approximately 9 terraced two story houses. We argue that the location of these office blocks in close proximity to an established residential area is inappropriate. These buildings would negatively impact homes through over-shadowing, a loss of privacy as well as the visual intrusiveness of their construction. There would be other associated problems with the construction of these blocks including an increase in noise pollution from congregating construction workers and the parking of their private vehicles.

According to the plans submitted by Irish Rail, it would seek to have on-street parking removed on Sherriff Street Upper. No reference has been made in the draft Railway Order as to whether any on-street parking will be lost on Abercorn Road, Church Road East and Irvine Terrace.


– This submission supports the request of the local community that An Bord Pleanala considers proposing the re-locating the substation to Docklands Station.

– To request that An Bord Pleanala examine in detail what is the Recharge Well – why it is needed and why is it located so close to a residential area?

– To urge An Bord Pleanala to refuse permission for temporary office blocks to close to this residential area on the grounds of loss of privacy, height, over-shadowing and being visually intrusive.

– To support the request of local residents that no on-street parking be removed on Abercorn Road, Church Road East and Irvine Terrace and that this is included in any Railway Order approved by An Bord Pleanala.

– To state that any approved Railway Order needs to contain a detailed a traffic management plan for Sherriff Street Upper and Abercorn Road.