An Bord Pleanála
Board Reference: MA0011/HA0039
Dunkettle Interchange Improvement Scheme
REPORT OF MR. D. O’CONNOR ON THE FOLLOWING ASPECTS OF THE SCHEME: -
• Transportation issues, including alternatives, prediction of traffic impacts and interaction of car base travel with public transport, cycling and walking.
• Drainage issues and associated impacts.
• Noise impacts including air quality associated with the construction and operational phases.
• Construction issues and impacts.
• Interactions of the above with other environmental issues.
______PL.MA0011 An Bord Pleanála Page 1 of 43
1.0 INTRODUCTION AND SCOPE OF REPORT
This report examines the aspects of the scheme listed above. Section 2.0 contains a description of parts of the Oral Hearing which are relevant to traffic, noise, construction and drainage.
In Section 3.0 there are lists of questions posed which require to be examined in the assessment of the scheme.
Section 4.0 is the assessment of the issues and Section 5.0 contains conclusions and recommendations.
______PL.MA0011 An Bord Pleanála Page 2 of 43
2.0 ORAL HEARING BRIEFS OF EVIDENCE AS RELATING TO THE ISSUES TO BE COVERED BY THIS REPORT
2.1 The oral hearing took place on the 14 th and 15 th December, 2012 and on 9 th January 2013 and five briefs of evidence were presented. On Day 1 of the hearing, following an introduction (pages 1-8, transcript) the brief of Mr. Alan McGinley was the first to be read into evidence. Mr. McGinley’s brief of evidence also covered the evidence prepared by Mr. Euan Barr in relation to traffic issues. The brief of evidence covered the following issues: -
• Need for the road development.
• Approach followed and choice of the preferred solution.
• Traffic and economics.
• Description of the proposed road development.
2.1.1 Background
Mr. McGinley referred to Volume 3 of the EIS and Figure 1.1.1 which indicates the location of the scheme. He described the existing Dunkettle Interchange as being a strategically important as it intersected a number of key national routes, namely: -
• M8/N8 - Dublin – Cork route.
• N25 – Cork to Waterford route.
• N40 – Southern Ring Road (through the Jack Lynch tunnel).
Mr. McGinley stated that in addition to being an intersection of the national routes, it was a key junction for traffic from the north and east travelling to the southwest to locations such as Ringaskiddy, Bandon and Kinsale. He noted the N40 Southern Ring Road facilitates the movements via junctions along its length starting at the existing Dunkettle Interchange and extending as far as the Poulavone Junction where it meets the N22.
______PL.MA0011 An Bord Pleanála Page 3 of 43
Mr. McGinley said the Kinsale Road Junction on this route had been upgraded to include a free-flow flyover in 2006 and the Bandon and Sarsfield Junctions were in the process of being upgraded to include free flow flyovers. He noted the existing interchange comprises a signalised roundabout which includes a free- flow overpass for N25 traffic from the east to Cork City and vice versa.
Mr. McGinley noted that the existing interchange includes an access point to Little Island via the R623 regional road and there was an egress from Little Island leaving directly onto the circulatory carriageway element of the interchange. He included an aerial photograph of the existing interchange which is on Page 3 of his brief of evidence.
Mr. McGinley said that approximately 700 metres to the west of the existing interchange was the Dunkettle Roundabout which is a non- signalised roundabout connecting N8 with the R639 regional road which is also known as the Glanmire Road. He noted that the Little Island junction was approximately 2.5 kilometres to the east of the Dunkettle Interchange and that this provided access to Little Island via a left in/left out arrangement for traffic travelling west along the N25 and via slip roads for traffic heading east along the N25. He referred also to a slip road which was indicated on Figure 1.1.2 of Volume 3 of the EIS which was commonly referred to as the Ibis slip as it was the location of the former Ibis Hotel and now being used as a Gaelscoil (Gaelscoil Ui Drisceoil).
Mr. McGinley said that the existing interchange was signalised in 2006 to assist in reducing congestion and it was a micro processer optimised vehicle actuation operated (MOVA) and he noted the signalisation was carried out in conjunction with the installation of additional traffic lanes at the interchange and also additional traffic lanes along the N25 between Little Island and Dunkettle.
2.1.2 Need for the proposed scheme
Mr. McGinley stated that at present the Dunkettle Interchange operates above capacity on a daily basis and he noted that in the evening or p.m. peak period, northbound traffic resulted in queues extending back into the tunnel. He included Image 1.2 on Page 4 of his Brief of Evidence indicating the queues which took place. He stated that on an average weekday morning in November 2011, queues extended
______PL.MA0011 An Bord Pleanála Page 4 of 43
approximately 600 metres on the M8 approach (to the north) and over 250 metres on the N25 approach (to the east). He said the bottleneck created by the existing interchange configuration was an impediment to the achievement of development objectives indicated or facilitated by strategic and statutory plans.
Mr. McGinley stated that improvement of the Dunkettle Interchange would optimise the benefits gained from investment elsewhere on the arterial road system including Kinsale Road, Bandon Road and Sarsfield Junctions on the N40 and that this would facilitate delivery of an element in the long term development of the Atlantic corridor.
2.1.3 Scheme Objectives
Mr. McGinley outlined nine objectives which included improvement of capacity, making best use of the existing infrastructure, separation of local traffic movement from strategic traffic and the provision of dedicated pedestrian and cycle connectivity through the junction area. He listed minimisation of impact on adjacent environmentally sensitive sites and the integration with national, regional and local policy with regard to rail links and park and ride options. He also listed an objective which was to provide planning certainty in the area by establishing the design and layout of the improvement works to the existing interchange which would enable better assessment of future planning applications in the area in the context of the proposed improvement works.
2.1.4 Process and Choice of Preferred Solution
Mr. McGinley outlined the stages of scheme development including the approach to consideration of alternatives. He said the major of constraints identified were: -
• Cork Harbour SPA.
• Dunkettle House.
• Cork – Middleton Railway Line.
• N40 – Jack Lynch Tunnel.
• Dunkettle Shore pNHA.
______PL.MA0011 An Bord Pleanála Page 5 of 43
• Construction phasing.
• Topography.
Five options were taken forward and these are referenced as being illustrated in Figures 3.1.1 to 3.1.5 of Volume 3 of the EIS. He noted that the red option was considered to be the best performing of all the options considered. He said that option did not have a direct impact on the Cork Harbour SPA or on Dunkettle House or its Demesne. He said as a result of its layout and configuration this option performed best in terms of reducing traffic congestion and improving journey times. He said the red option was taken forward to the design phase.
2.1.5 Design Phase
Mr. McGinley said that the aim of the design stage was to undertake the engineering design of elements of the red option that had the potential to influence the amount of land required to build and maintain the scheme. He said this involved significant liaison with traffic engineers to maximise the capacity available for the movements with the greatest flows and also liaison with the environmental specialists in order to avoid, remove or reduce the impact the scheme might have on the receiving environment.
2.1.6 Environmental Impact Statement
Mr. McGinley said proposed mitigation measures for impacts were incorporated into design where necessary. He said iterative assessments continued as part of the compilation of the EIS up to publication and commencement of the statutory environmental impact assessment (EIA).
2.1.7 Traffic
Mr. McGinley stated that the traffic model for the project was developed using an industry standard modelling package namely SATURN and he said the traffic model output was used within the economic assessment. He said the model replicates an average a.m., inter-peak and p.m. peak hour for a typical weekday during November 2010.
Mr. McGinley said the traffic model was developed specifically to test the impact of the proposed interchange upgrade on travel levels and traffic patterns to the main roads around Cork. He said the dominant
______PL.MA0011 An Bord Pleanála Page 6 of 43
movements subject to the highest delays at peak times were traffic through the Jack Lynch tunnel in a southbound direction in the a.m. period and from the south to east particularly in the p.m. period. He said the higher traffic volumes between east and west encounter little delay as the movement was currently grade-separated. Mr. McGinley said that the mix of goods vehicles, daily commuters, local journeys and unfamiliar drivers, combined with the signal controlled at-grade roundabout resulted in delay and journey time reliability issues. He said the situation was expected to deteriorate in future years as traffic congestion would increase with higher traffic levels.
Mr. McGinley stated that average weekday travel times from the M8 Glanmire junction to the N40 Mahon junction (south of the tunnel) would save approximately 75 hours equivalent time in the morning peak period. He said travel times from the N25 Little Island junction to the N40 Mahon junction would have an overall reduction equating to a time saving of 50 hours in the morning peak hour. He also said travel times from the N40 Mahon junction to the N25 Little Island junction would reduce with an overall journey time saving of almost 110 hours in one hour of the evening peak period.
(Mr. McGinley did not give details of any time savings on the M8/N8 flow).
2.1.8 Economics
Mr. McGinley stated that the net present value of the proposed development was €277.8 million at low growth and the benefit to cost ratio was given as 4.5 at low growth.
(The estimated cost of the scheme was given elsewhere as €89 million ).
Mr. McGinley stated that in summary in relation to traffic that despite the recent reduction in traffic levels due to the global economic downturn, congestion continues to be an issue on the road network around Dunkettle Interchange. He said that congestion currently associated with the busiest periods would become a typical day-to-day level of operation in the future. He said the proposed interchange upgrade would be the significant benefits for local residents and road users as the stop/start driving additions would be replaced by free- flowing traffic streams. He also stated it had been demonstrated that
______PL.MA0011 An Bord Pleanála Page 7 of 43
good value for money would be achieved under all of the growth levels assessed.
2.1.9 Description of the Proposed Road Development
In Section 6 of Mr. McGinley’s brief of evidence, a description of the proposed road development is given. Mr. McGinley refers to Figure 2.1.1 in Volume 3 of the EIS which indicates the development as proposed. This figure is an aerial photograph and to see the layout in slightly more detail, it should be examined in conjunction with Figures 2.1.2 and 2.1.3 which are also in Volume 3 of the EIS.
Mr. McGinley describes the development as catering for the more local movements and this introduces a dumbbell junction arrangement which provides direct connection between Glounthaune and Little Island and also allows traffic from Glounthaune and Little Island to access the Jack Lynch tunnel, the N8/M8 motorway northbound, Cork via the N8 and also to head east via the N25. He stated that these movements are catered for in addition to the N8/M8, N25 and the N40 traffic via the Jack Lynch tunnel. He stated that the proposed development seeks to provide the largest capacity to those links with the largest traffic demand.
He describes traffic from the tunnel heading east as being a high demand link particularly in the p.m. peak and this is represented by Link A in Figure 2.1.1 (also see Figure 2.5.1).
The link between the M8 and the tunnel is important in the southerly direction in the a.m. peak and this is Link D in Figure 2.1.1 of the EIS. (Also see Figure 2.5.4 which indicates the link).
Link K in Figure 2.1.1 (also Figure 2.5.11) is the link for traffic from the east heading south through the tunnel.
Section 6.7 of the Brief of Evidence refers to the dumbbell junction arrangement to the east of the existing interchange which provides a direct link between Dunkettle and Little Island and also serves to accommodate the existing local and regional road access point. (Although not stated in the brief, this dumbbell arrangement also provides for the movement between the M8 to the N8 into Cork City and involves Link Road E (Figure 2.5.5) and Link Road M (Figure
______PL.MA0011 An Bord Pleanála Page 8 of 43
2.5.13) and also Link Road R which is the bridge at the dumbbell junction (Figure 2.5.18).
Mr. McGinley noted that the existing “Ibis slip” would be closed to traffic but Dunkettle Road could access all destinations by continuing to Burys Bridge via new links T2 and T3 and continuing to the new dumbbell arrangement via Links H. He also set out the existing accesses into and out of Little Island and into and out of Dunkettle and Glounthaune.
Section 6.14 of the brief refers to the structures and notes there are 43 major structures of various forms.
2.1.10 Pedestrian and Cyclists Facilities
Mr. McGinley refers to Figure 2.7.1 of the EIS and stated that the proposed cycling and pedestrian facility connected Little Island and Glounthaune in a north-south and vice versa direction and also connects Glounthaune to the west and east which would facilitate any future provision of pedestrian or cyclist facilities between Cork City and the east of Cork. It notes that this complies with the Blarney Local Area Plan of August 2011 in which there is an objective to provide cycle facilities to Glanmire linking the city and Little Island to facilitate commuters. It states pedestrians and cyclists can now access Little Island via Dunkettle Road and Burys Bridge or via the Glanmire Road and link T1. (See Figure 2.5.19).
In Section 6.25 of the brief Mr. McGinley referred to park and ride access and the fact that there are two potential sites, one near the former Ibis Hotel and the other in North Esk.
In relation to lighting, Mr. McGinley said the design had been carried out with each road link to the appropriate lighting class based on the character and projected traffic flow.
2.1.11 Drainage
Mr. McGinley noted that the carriageway drainage design comprised kerbs and gullies, combined kerb and drainage blocks and surface water channels. He stated that it was important to design the outfall so that the rate of discharge did not exceed that of an existing greenfield catchment area. He said this was achieved for the use of attenuation ponds at the proposed outfall locations.
______PL.MA0011 An Bord Pleanála Page 9 of 43
He noted that benefit of the attenuation ponds is that they provide a degree of protection against accidental spillage and also that constructed wetland systems had been incorporated into the proposed development in tandem with the attenuation ponds to treat the runoff at the outfall locations. He referred to Chapter 6 of the EIS for further details on this issue.
In Section 6.37 of the brief, Mr. McGinley referred to flood compensatory areas and it noted that the existing intertidal mudflats were connected both together and to the Cork Harbour estuary by a series of culverts and that a flood risk assessment in line with OPW Guidelines had been undertaken.
He stated that as areas of the existing mudflats were being lost as a result of the footprint of the proposed development, compensatory areas of flood storage had been included to compensate for those lost areas. He said they were located and sized so as to maintain the existing tidal flow regime to allow inundation of areas at similar levels in the tidal cycle by providing like for like storage as close as possible to those mudflat areas which were being lost.
Mr. McGinley said the flood risk assessment concluded that all across the study area, it was demonstrated that the proposed works do not increase the flood risk of the surrounding area, nor is the proposed development at risk of flooding.
2.1.12 Signalisation of Dunkettle Roundabout
Mr. McGinley stated that in addition to the improvement works at the existing Dunkettle Interchange, traffic signals were included on the Dunkettle Roundabout. (The Dunkettle Roundabout is on the N8, to the west of the interchange and is currently not signalised).
Mr. McGinley stated that the traffic signals would comprise signal heads on the N8 Lower Glanmire Road, the R639 Glanmire Road and on the N8 approach to the Dunkettle Roundabout from the east. He said signal heads would also be included on the circulatory carriageway of the roundabout.
______PL.MA0011 An Bord Pleanála Page 10 of 43
2.1.13 Societal Risk Assessment
Mr. McGinley noted that in AWN Consulting had completed a Societal Risk Assessment which considered impacts of major accident hazard at establishments in Little Island. Specific impacts associated with Pfizer Pharmaceuticals at Wallingstown and BASF Ireland were assessed. He noted that the assessment of individual and societal risk was completed in accordance with the methodology described in the policy and approach of the health and safety authority to COMAH Risk Based Landuse Planning of 19 th March 2010. He noted that the level of risk from major accident hazard at BASF was not significant and it was concluded that the facility did not impact on the proposed development.
He stated that in relation to Pfizer , the assessment concluded that the outer risk based land use planning zone extended to links C, J and the N25 westbound lane. He said it was concluded that the proposed scheme was acceptable in the outer zone. He stated that a societal risk assessment was completed and it was concluded that the level of societal risk of the proposed scheme was significantly lower than the societal risk acceptability criteria applied by the HSA. He said it was concluded that the level of societal risk at that proposed scheme was not significant and was acceptable.
2.1.14 Construction Phase
Mr. McGinley stated that the construction would be expected to take approximately 24 months . He noted that an environmental operating plan in accordance with NRA Guidelines would be in place before the start of construction. Specifically he noted that in relation to construction traffic management that traffic flows on the existing network must be maintained at all times and therefore it was not possible to close any element of the existing network during construction without feasible alternative diversion routes.
Mr. McGinley stated that due to the layout of the national road network and physical constraints such as the Jack Lynch Tunnel, it was not practicable to divert traffic away from the interchange during construction. He said where existing roads or slips are required to be closed to upgrade existing infrastructure, the traffic would have to be locally diverted around the works using temporary diversions in the vicinity of the work site. He noted that extensive traffic management
______PL.MA0011 An Bord Pleanála Page 11 of 43
including a lane closures, diversions and contraflows would be required to maintain traffic flow.
2.1.15 Summary of Conclusions
Mr. McGinley summarised his presentation and stated that it shows the purpose of the scheme was to facilitate strategic planning objectives. He also noted that some private and public projects had been deemed premature pending the improvement works to the Dunkettle Interchange.
He noted the provision of the dumbbell junction arrangement to the east of the main works to accommodate the more local traffic movements. He also noted the proposed dedicated pedestrian and cyclist facility.
Mr. McGinley stated the lands included in the motorway order were necessary, sufficient and suitable for the construction, operation and maintenance of the scheme and the environmental commitments proposed and which would form part of any EIA approval seek to safeguard the receiving environment from significant adverse effects.
2.2 BRIEF OF EVIDENCE OF DR. STEPHEN SMYTH, AWN CONSULTING IN RELATION TO NOISE AND VIBRATION
Dr. Smyth read his brief of evidence into the record which was based on data from the EIS. He also had an addendum to the EIS which he presented immediately after the first brief of evidence and which dealt with the impacts of more extensive use of low noise surfacing.
2.2.1 Introduction and Methodology
Dr. Smyth stated that AWN Consulting Limited had conducted an assessment as part of the noise and vibration chapter for Dunkettle Interchange Improvement Scheme EIS and the phases of the assessment included: -
• Detailed baseline noise survey.
• Assessment of the impacts.
______PL.MA0011 An Bord Pleanála Page 12 of 43
• A recommendation of the mitigation measures necessary.
Dr. Smyth said the baseline survey took account of the NRA 2004 Guidance Document entitled Guidelines for the Treatment of Noise and Vibration on National Road Schemes. He said there was a total of nine attended and two unattended 24-hour locations which were monitored during October 2011. He said measured noise levels were in the range
of 55 – 63 dB L den at the monitoring locations. He said noise levels were found to be dominated by existing road traffic. He said the highest noise levels were recorded along the N8 between the Dunkettle Roundabout and the Dunkettle Interchange at properties which directly fronted the road.
Dr. Smyth described the prediction methodology and noted that a total of 43 receiver locations, representing 23 sensitive locations were assessed. He referred to Figure 9.1.2 of Volume 3 of the EIS for indication of the receiver locations.
Dr. Smyth described the design goals and the assessment results and referred to Table 9.4 of Chapter 9 of Volume 2 of the main report of the EIS. It concluded that in the design year mitigation was deemed necessary at six properties: -
• Gaelscoil Uí Drisceoil, receivers R004d, R004e and R004F.
• Residential property at North Esk – receiver R021a.
• Residential properties at Tower Hill – receivers R007, R008 and R012.
• Dunkettle House – receiver R023a.
Dr. Smyth described the operational phase mitigation measures and the extent of the load noise surfacing proposed. (This would be superseded by the additional report which indicates that low-noise surfacing would be provided on all links).
In Section 3.3.2 of the brief of evidence, Dr. Smyth describes assessment of construction noise and the construction phase mitigation measures are given in Section 3.3.3.
______PL.MA0011 An Bord Pleanála Page 13 of 43
In relation to vibration, Dr. Smyth said the most significant source of vibration would likely be piling works during construction. He said considering the distance of the piling works from the nearby buildings, vibration levels would be expected to be well below the level at which structure or even cosmetic damage would occur.
Dr. Smyth referred to the submissions and responses and responded to a question as to whether measured noise levels would be greater in winter when the foliage in the trees were less. He said that would not be case as trees nor their foliage do not offer any significant levels of noise reduction. He said that noise levels would be likely to be higher when there is foliage present on trees due to a degree of wind generated noise. He referred to survey location S09 which had been described as Tower Hill in Table 9.1 of the EIS. He noted that submissions were received stating that it was misleading and not an accurate description of the location. (Drawing 9.1.2 of Volume 3 is relevant in this regard).
In Section 4.2 of the brief of evidence, Dr. Smyth referred to the Cork County Council Noise Action Plan of 2008 . He referred to a priority area N25 – 4 in the Noise Action Plan but stated it was important to note that the noise in the Glaunthaune area is to a large degree dominated by the noise generated on the N25 mainline east of the Dunkettle Interchange and is therefore outside the scope of the scheme to provide mitigation in this area.
Dr. Smyth stated that following the implementation of the recommendation and mitigation measures in the EIS for the scheme, noise levels at the majority of receivers closest to the interchange would be in the worst-case design year predicted to reduce when compared to the do-minimum scenario for the same year.
In relation to construction noise management, Dr. Smyth noted a submission had been received requesting that all measures of mitigation be implemented. He noted the submission also requested that continuous noise monitoring be conducted at noise sensitive locations during the construction of the scheme. He said in response to that the mitigation measures set out in the EIS would form part of the contract documents for the scheme. He said the contractor would be required to conduct a noise and vibration impact assessment for specific phases of works and would be required to prepare a construction noise and vibration management plan to minimise the
______PL.MA0011 An Bord Pleanála Page 14 of 43
potential for noise disturbance as a result of the works. He said that would involve liaising with the local authority and any affected residents during the works.
2.2.2 Supplementary Brief of Dr. Stephen Smyth
Dr. Smyth read an addendum to the EIS into the record and this detailed the extended use of low noise surfacing now proposed. He said a low noise road surface was defined as a surface that could provide a minimum noise reduction of 3.5 dB (A) when compared to a standard hot rolled asphalt road surface (HRA). He said the addendum to the EIS had considered the use of low noise road surface on all links which formed part of the scheme as an enhanced noise mitigation measure. In the brief of evidence Table 1 gives the predicted noise level at receiver reference numbers R0012, R038. This table shows that do-minimum predicted noise level for the design year of 2031 and the do-something noise level. In almost all the cases, the do-minimum level is higher than the do-something level with the exception of receptor R012 in the vicinity of Factory Hill where an increase is predicted. Dr. Smyth said that with the use of a low noise road surface on all links the combined expected maximum traffic noise level from the proposed road scheme would be less than or equal to the NRA design
goal of 60 Db L den at 40 of the 59 receiver locations. He said of the remaining 19 locations, 16 would show either no change or a reduction in noise levels in the range of 1 to 5 dB and three locations show a slight increase in noise levels when compared to the do-minimum scenario. These locations were given as R036 – R038 (to the east of the scheme – see drawing 32102600/SK/68 which accompanied Dr. Smyth’s addendum guidance).
Dr. Smyth said that additional mitigation in the form of roadside barriers was further investigated and the locations where roadside barriers were considered to be feasible were given in Figure 2 at the back of the brief of evidence. He said Table 2 listed the predicted noise levels at the receiver locations for the scenario where roadside barriers and low- noise road surfaces are used in combination.
Dr. Smyth said with reference to Table 2, it was found that at the majority of assessment locations, the addition of roadside barriers to the scheme mitigation provides minimal benefit. He said the addition of noise barriers as shown in Figure 2 was found to reduce traffic noise levels by the order of 1 dB beyond that achieved with the use of the
______PL.MA0011 An Bord Pleanála Page 15 of 43
low-noise road surface alone. He said the exception of that was the provision of a 2.5 metre high noise barrier along the roadside edge of the western edge of a link U , between chainages 0 and 450 (this is the link between the N8 Glanmire and the M8 heading north).
Dr. Smyth said that generally small noise reduction offered by noise barriers was due to: -
• Barrier only provides mitigation to the nearest carriageway whereas there are generally numerous links contributing to the overall noise level in this instance.
• There is considerable distance between the roadside edge and the majority of noise sensitive location.
• There is a significant change in elevation between the roadside edge and the nearest noise sensitive location.
In conclusion, Dr. Smyth said the use of a low noise road surface on all links of the proposed scheme along with a 2.5 metre high noise barrier to the western edge of link U would reduce the do-something
noise levels in the design year to less than or equal to 60 dB L den at 42 of 59 receiver locations. He said of the remaining 17 locations, 14 are predicted to experience no change in noise levels or a reduction in the range of 1 – 4 dB. He said the remaining three locations show a slight increase of the order 1 dB which he described as not being significant.
2.3 BRIEF OF EVIDENCE OF DR. STEPHEN MILLS, ENVIRONMENTAL CONSULTANT ON HYDROLOGY AND WATER QUALITY ASSESSMENT
The portions of the brief of evidence covering baseline environment and the water quality are covered in the Inspector’s Report. This report (following) relates to the drainage and construction aspects.
2.3.1 Drainage Details
Dr. Mills noted that the carriageway runoff from the existing interchange is discharged untreated through a series of kerbs and gullies to the Jack Lynch Tunnel Intertidal Mudflat (WF2) via three outfalls which flow into Lough Mahon or into the North Esk Intertidal Mudflat West (WF3) on outgoing or incoming tides. He noted the impermeable area
______PL.MA0011 An Bord Pleanála Page 16 of 43
currently draining is approximately 4 hectares which equates to a 1 in 50 year runoff of approximately 585 litres per second. (Reference Figure 5.1.1 in Volume 3 of EIS).
Dr. Mills stated that the drainage for the proposed development was divided into four networks each which had a distinct outfall point. He referred to consultation with the NPWS which resulted in the proposal of a three-stage attenuation system being adopted: -
• Oil/petrol interceptor. • Initial attenuation pond. • Constructed wetland.
Dr. Mills said that the entire impermeable area being drained by the proposed development is approximately 9 hectares which includes the 4 hectares of the existing impermeable area. He said this would equate to a total runoff for the 1 in 50 year storm event of 1,400 litres per second but when attenuated, the flow would be less than 140 litres per second of which 70 litres per second would equate to discharges via the new attenuation measures.
Dr. Mills pointed out the discharge figures did not account for the carriageway runoff from the N25 east and the N8 west of the existing interchange.
2.3.2 Construction Phase Impacts
Dr. Mills noted the potential for pollution of surface water features during construction and he listed the sources including construction adjacent to watercourses, excavation, stockpiling of materials, accidental spillage and plant and vehicle washing. He said that in line with the NRA Guidance that watercourses in the study area and adjacent to it were examined: -
• North Esk Intertidal Mudflats (WF3 & WF4). • The Jack Lynch Intertidal Mudflat Area (WF2). • Pfizer Intertidal Mudflats (WF5 & WF6). • Lough Mahon.
2.3.3 Operational Phase Impacts
______PL.MA0011 An Bord Pleanála Page 17 of 43
Dr. Mills said pollutants such as oils and hydrocarbons from fuel combustion and salts or herbicides would be deposited on the road surfaces. He said the impact would depend on the volume and type of traffic using on the road, the provision of pollution control measures and the sensitivity of the receiving watercourse. He referred to the Highways Agency Water Runoff Assessment Tool which was used to assess the impacts from acute and chronic pollution on Lough Mahon. He said the probability of accidental spillage had been calculated for each link and he referred to the EIS in Volume 2 and Table 6.17 for a full summary of impacts on water quality for each waterbody during construction and operation.
2.3.4 Construction Phase Mitigation
Dr. Mills outlined the mitigation measures which would include measures to prevent the release of sediment and to minimise the displacement and subsequent erosion and release of soft sediment, particularly from WF6, WF5, WF7 and WF4. These also included provision of measures to handle, store and reuse material removed from the intertidal mudflats where feasible. He also noted provision of measures to minimise any runoff into the Jack Lynch Tidal Polder (WF1) by diverting temporary draining into WF2 instead. He said sediment and materials from Pfizer Intertidal Mudflat West and East would be retained and re-used within flood compensation intertidal areas.
Dr. Smyth referred to the submission of the Inland Fisheries Ireland which required control measures for water quality monitoring and culverting of the freshwater stream (water feature 10). He said the primary concerns of the IFI concerning infilling of intertidal habitat and potential of pollution had been fully identified and addressed within the EIS with appropriate mitigation set out. Dr. Mills said with implementation of the mitigation strategy it was assessed that all residual impacts in those areas had been reduced to being imperceptible.
2.4 SUBMISSION BY CORK COUNTY COUNCIL (DAY 2, TRANSCRIPT, PAGES 13-25)
The content of the submission by the officials from Cork County Council are noted insofar as they are seen to concern transportation
______PL.MA0011 An Bord Pleanála Page 18 of 43
issues and the linking of transport capacity with land use policy and planning generally.
2.4.1 Submission of Mr. O’Keeffe, County Engineer
Mr. O’Keeffe said the scheme would improve connectivity to a number of areas. He said it had positive benefits both for walking and for cycling and benefits for the N28 impacting on a strategic employment zone at Ringaskiddy. He stated there were positive benefits for commuter traffic coming in and out of city and more importantly, benefits for strategic traffic. He said (transcript, page 21) it was a vital part of the Atlantic Corridor as it was a vital link between Waterford, Cork and Limerick so that the scheme was essential both nationally and in Cork.
Mr. O’Keeffe said that the Noise Action Plan was commissioned in 2007 and that the mapping was based on computer generated noise contours from the 2007 traffic flows. He said a review of the noise action plan was underway and noise mapping had been prepared for both roads and bridges, as well as roads which exceed 6 million vehicles per annum and also roads exceeding 3 million vehicles per annum and the agglomerations of Cork City and its environs.
2.4.2 Submission of Mr. Hind, Senior Planner
Mr. Hind said that the scheme should have capacity to operate efficiently and effectively in the future and it was a vital thing for the growth of the Cork area in general. He referred to Ringaskiddy and said it was the preferred location for the relocation of the Port of Cork from the city. This would facilitate the development of the city into the area occupied by the Port. He said this was a vital plan for Cork that would be facilitated by the interchange. Mr. Hind also referred to the airport which had also a significant level of business development which requires an airport location. He said into the future the County Council had proposals for progressing jointly with UCC and CIT and landowners for his Science Park development at Curragheen to the immediate southwest of the city.
Mr. Hind said that the key growth area in East Cork incorporated the settlements of Carrigtwohill, Little Island, Middleton and Cove. He said the population projected for that corridor was 70,000 persons.
______PL.MA0011 An Bord Pleanála Page 19 of 43
Mr. Hind noted the single access currently available to Little Island and the single directional link between Little Island and the tunnel.
He said that at Little Island, the public transport was dependent on the railway and while this has improved over the years, the configuration of the station and the access to the main important areas of Little Island is still difficult. He said out of scheme they hoped would come a second station namely a park and ride station and he confirmed that there were two potential sites possible. Mr. Hind also said the scheme would encourage greater walking and cycling.
Mr. Hind said that the 70,000 population prediction for the East Cork area was in line with the South West Regional Planning Guidelines. Mr. Hind stated that when the figures were compared, the CASP area was slightly ahead of the target population in the South West Regional Planning Guidelines. He said other things being equal, the recession had not dented the ability of the CASP area to achieve the targets. He said the growth in the Middleton Electoral Area was a very significant part of that effort.
In response to a question from the Inspector, Mr. Hind stated that in relation to the Dunkettle House area, a substantial part of it had been zoned for over a decade but development has not been authorised. He said it was the Council’s view that they want to see the land developed and that the Glanmire area, as a settlement close to Cork that is an established transport corridor to Cork, has a contribution to make in the overall growth to the Cork region. He said they did not see the scheme as a limiting factor as this proposal has been part of established planning framework of Cork before the scheme was conceived and as presented by the NRA. He said the Council were intending to prepare a Local Area Plan for the development of the Glanmire land and this plan would be prepared while working with the NRA and the NTA.
2.5 RESPONSE IN RELATION TO NOISE ISSUES BY DR. SMYTH (Transcript, Day 2, Pages 26-41)
Dr. Smyth stated that in response to the noise mitigation levels, the proposal was now to use a low noise road surfacing throughout the scheme. He said it was also proposed to use a barrier on the western extent of the scheme as it joins the N8 as there was property quite close to the road. He said the reason that barrier were not being used
______PL.MA0011 An Bord Pleanála Page 20 of 43
in other locations was the difference in elevation between the main road link and the residential properties particularly in the Glounthaune area. He said the low noise surface is the preferred approach because it mitigates not only the receiver closest to the road, but also receivers at a greater distance from the road. He said it was not within the remit of the scheme to extend along the N25 to the east as the scheme boundary prevented that. This affected parts of Little Island.
Dr. Smyth explained the analysis of the noise measurements to
determine the L den value which was the criteria defined by the European Noise Directive.
Dr. Smyth said that the survey took into account primary noise sources and he said that topography and reflections were all taken into account as part of the model. He said it was a detailed three-dimensional model with ground contour information provided from the Ordnance Survey and he said it also took into account the elevation of the existing and proposed roads in terms of overbridges and junctions. He said low noise surfacing was one that provided a noise reduction of 3.5 decibels when compared with a standard or hot-rolled asphalt surface.
Dr. Smyth said that in relation to perceived noise levels, there would be a positive impact on the noise environment in the area, but he said that locations closest to the interchange would see the biggest benefit. Dr. Smyth stated that this was because they were in control of where they could apply the low noise surface in that area. He said depending on the location, they were predicting a noise reduction of up to 8 decibels which would be approaching a halving of the loudness. He said that did depend on the location.
In relation to specific questions raised on Day 1 of the hearing, Dr. Smyth stated that baseline noise levels were used to determine the existing noise environment. He stated that the design goals prior to 2004 were less onerous than currently.
In relation to future traffic levels, he stated that the noise model used the high growth traffic figures and he said also as a rule noise levels were not particularly sensitive to changes in traffic volumes. He said traffic volumes would have to double to see a 3 decibel increase in the noise levels. He said there was not a huge sensitivity there between traffic volumes and noise. He said there were differences between the criteria used in the EPA Licensed sites and in the guidelines, it
______PL.MA0011 An Bord Pleanála Page 21 of 43
specifically stated that these were not to be used in other situations. He stated that the NRA Guidelines were the most appropriate for the current situation.
In relation to construction phase impacts with particular reference to the North Esk community, he said there would be some disruption during the construction phase and this would also generate some additional noise. He said there could be some night-time work to railway structures which were located to the northwest of the North Esk community. He said these would be expected to only last for a number of nights throughout the duration of the entire project.
Dr. Smyth said unfortunately the NRA were committed to providing noise mitigation only within the road corridor so mitigation such as double glazing of windows was not something that could be offered.
In relation to alteration of speed limits, Dr. Smyth said the 120 kph limit was moved where it currently stands within the scheme to the end of the scheme (to the east). He said the estimation was that there could be about 1.5 decibel reductions for every 20 kph change in the speed limit. He said they tended not to use speed as a mitigation measure because it is not particularly reliable.
In relation to whether properties at elevated sites would experience higher noise levels, Dr. Smyth stated that these properties could be more exposed and would not benefit from attenuation that maybe lower properties would do coming from absorption due to the ground or other obstacles in the way between the road and the receiver itself.
Mr. Tyrell (Factory Hill Residents and Others) raised the question of polygon N25-4 mentioned in the Cork County Council Noise Action Plan and where there were 420 residents living. He stated that when it was proposed to spend €89 million for the whole scheme, what they were looking for was that the low noise surfacing be continued a bit outside the scheme. He asked that it be included as far as the Little Island overpass and the barriers also. He said they should be given higher barriers than those in the noise study and while he noted that it only gave one decibel reduction at a 3 metre barrier, perhaps a 6 metre barrier would give more. He noted that the speed limit had been increased from 100 to 120 kph on the section of the N25 which goes below where he was living. The residents would say they had noticed
______PL.MA0011 An Bord Pleanála Page 22 of 43
very little difference in the traffic movement and it went to 120 kph, so maybe thought should be given to bring it back to 100 kph again.
Mr. Pearse asked for clarification in relation to double glazing (North Esk community). Drawing No. 9.1.2 of Volume 3 of the EIS was referred to. Mr. Pearse stated that if one spoke about the road corridor that he had roads on both sides of his premises and therefore suggested he was within the road corridor. Dr. Smyth said that the corridor was the CPO line itself which defines the land been taken. Dr. Smyth stated there could be no barrier proposed at that location because there was a line of sight issue.
Mr. Sinnott (Dunkettle) stated that the sound attenuation surface slightly up the M8 would possibly lessen the effect of sound for him if they were not going to put up barriers.
In reply to questions raised on Day 1 of the hearing, Dr. Smyth stated
that the query that Receptor R012 would have a level of 55 dBL den in a do-minimum situation and yet 58 dBL den in a do-something situation had been looked at. He said this was to do with the location of the property relevant to other properties around it. Dr. Smyth said there was a type of noise shadow cast behind one or other residences and the new scheme was reducing the noise shadow in the way the new links were to be constructed so there would be a slight increase. He said it was still within the NRA Guidelines of 60 dB. He confirmed it was not a typographical error, as most of the remaining receptors showed a reduction rather than an increase in predicted noise levels.
Dr. Smyth confirmed that the original submission only identified seven links for low noise surfacing but now they were putting in more mitigation.
2.5 (CONT.) RESPONSE TO QUESTIONS ON TRAFFIC ISSUES: - (Transcript, Day 2, Pages 42-53)
Mr. Euan Barr gave details of the responses to questions raised in relation to development growth forecasts which were raised by Mr. D. O’Connor at Day 1 of the hearing. The response is included as a separate document and is also in the transcript from Page 43 – Page 46 of Day 2.
______PL.MA0011 An Bord Pleanála Page 23 of 43
In summary Mr. Barr stated that traffic forecasts were developed in accordance with the NRA Project Appraisal Guidelines (PAG) Unit 5.4 and uses growth forecasts from the National Traffic Model (NTM). He said it also took account of national transport policies including the Smarter Travel 2009. Mr. Barr gave a number of references for population growth statistics including the CSO figures and also the CASP Update of 2008. On Table 1 of the submission he indicated a total CASP region population of 488,000 based on the CASP Update of 2008 with the NTM forecasts ranging from 391,982 for a low growth scenario to 496,856 for a high growth scenario in the year 2025. Mr. Barr stated that the current M8/N8 through to Dunkettle would be about 18,000 AADT. He said by 2016, an increase of the order of 11% would be expected and of 28% by 2031. This would raise this traffic flow to 23,500 AADT.
Mr. Barr said regarding the N25, the current AADT traffic levels were approximately 51,000 vehicles per day. He said there would be a 20% increase by 2031. He said approach from the Jack Lynch Tunnel had current traffic levels of just below 60,000 vehicles per day . Mr. Barr stated that the flows to the west were approximately 40,000 vehicles per day and he illustrated these on Figure 2 which he concluded with his supplementary presentation.
In response to further questions from Mr. O’Connor, Mr. Barr put the threshold for congestion at approximately 75,000 AADT at which stage one would potentially be looking at congestion issues occurring at a.m. and p.m. peaks. It was agreed that the existing Dunkettle roundabout was a constraint and it appeared that it would need to be signalised whether or not a scheme took place.
Mr. Barr confirmed that the new route from the M8 to the N8 into Cork would be approximately 1.3 kilometres longer than it is in the existing situation. He said in 2016 although it was longer, it would be slightly quicker by a few seconds than the do-minimum situation.
Mr. Barr said the most likely link to come under pressure in a high growth scenario would be Link K which is the link between the N25 and the Jack Lynch Tunnel heading south for the a.m. peak. He said the analysis indicated that the link would keep moving which was different than the current configuration at the roundabout which would potentially completely gridlock.
______PL.MA0011 An Bord Pleanála Page 24 of 43
Mr. Barr said the maximum journey times were up at about 23 minutes from the existing Little Island interchange through from Mahon under the do-minimum situation. Under the scheme, Mr. Barr said this would only get up to a maximum of 8 minutes even with potential pressure on Link K.
2.6 SUBMISSION BY THE NATIONAL TRANSPORT AUTHORITY: - (Transcript, Day 2, Pages 76-80)
Mr. Shinquin, National Transport Authority, outlined the functions of the authority and the relationship it had with planning. He said through their various funding arrangements, they would influence and facilitate the integration of land use and transport planning at all levels. He said this would be to ensure that the many planning decisions that are made would be made with a view to the transport implications of those decisions and to work with local authorities in the making of development plans and local area plans. He also said the NTA would influence anything from the location of development to its density, mix of uses, support of the transport infrastructure and public transport services.
Mr. Shinquin referred to the Cork area and the southwest region and the Regional Planning Guidelines. He said there was also a Regional Cities Fund and at the moment a five-year transport development programme was being prepared for both city and county councils. He referred to traffic management measures, walking and cycling networks, investment and public transport facilities and services.
Mr. Shinquin said the NTA would be of the view that any upgrade of the national road network would be something which should primarily facilitate strategic traffic. He stated there were some strategic employment locations identified including Little Island, Ringaskiddy, the airport and locations west of the city. He said there were a number of objectives to improve public transport services and to work towards better connectivity and the Prime Modal Shift away from almost complete car dependency. He said the underpinning of the NRA analyses is that they would be catering for both substantial growth both in population and employment across the metropolitan area.
Mr. Shinquin said on that basis the NRA argument was that the capacity was required to meet future demand. He said that would obviously increase the volume of traffic which the N40, N22 and N25
______PL.MA0011 An Bord Pleanála Page 25 of 43
and other routes would be able to handle in future years. He referred further to public transport accessibility and its development as a viable alternative car based trips. He also referred to necessary transport management measures on the national road network. He said the NTA would be supportive of the scheme but in the context he had just described.
2.7 SUBMISSION BY MR. STEPHEN PEARSE
Mr. Pearse said he was a resident of the North Esk area where there are about 10 houses. Mr. Pearse raised a concern about flooding and stated that there had been a considerable increase in water logging since the tunnel opened. He referred to link G and he said he believed that it had to do with a development that happened in Eastgate that water had been pushed down towards them and that land was owned by the County Council had been left completely water logged. He said that of two front gardens, the second front garden had now become water logged were asking that it be looked at again in terms of levels.
Mr. Pearse also stated they had concerns about the on-going levels of noise. He said the noise was a constant drone and that the readings were very close to the design goal of 60 decibels. He said his question was would these rise again and he noted that the NRA level was higher than the EPA levels of 45dB for night time and 55dB for daytime.
Mr. Pearse said the area owned by the County Council in the vicinity of North Esk had not been maintained and was used for dumping gravel, sand and storage of porta cabins.
Mr. Pearse asked would there be compensation in the form of (double) glazing, as the noise levels were unacceptable. He said the houses were built in the late 1700s.
By way of clarification on area (Page 38/39, Transcript, Day 1) Mr. McGinley stated that the intertidal area in the vicinity of the houses involved loss of a particular area and a compensatory area was being provided. He said the model showed that during a spring tide a moderate flooding of the garden or allotment would occur and that would be consistent with the model. He said what they were trying to do with the scheme is to retain the existing regime in the area. He said there would be a small reduction in flood levels in that area as a result
______PL.MA0011 An Bord Pleanála Page 26 of 43
of the proposal, but it did not have a negative impact in terms of ecology.
2.8 Construction Impacts
Mr. McGinley stated in his brief of evidence that the construction period would be 24 weeks. Clarification on construction sequence was sought and this was submitted and presented at the adjourned oral hearing on the 9 th January 2013. It is titled Oral Hearing – Drawing Issue. This drawing indicates the mitigation measures during construction in response to the requirements and questions raised by the NPWS.
The latter part of this set of drawings concerns the phasing of the works and this covers the sequence which has been broken into eight separate phases. The various drawings indicate the works to be carried out and these are referenced also in the drawing. Works range from the preliminary installation of culverts and diversion of watermains (Phase 1). The creation of compensatory areas, construction of temporary diversion, installation of new culverts, construction of works including structures, temporary traffic lights, partial road closures and commissioning of new sections. In all, 34 separate activities are indicated.
The work involved is similar to that which was required on the upgrading of the junctions on the M50 in the Dublin area, in that traffic must be accommodated on an on-going basis and there is very little scope even short-term road closures.
The drawings submitted to the adjourned hearing on the 9 th January 2013 are considered to adequately indicate how the scheme can be constructed while accommodating all the major traffic flows.
Also at the adjourned hearing, a drawing reference 32102600/SK/061 was submitted and that drawing indicated the route of the proposed cycle way from the Dunkettle Roundabout past Burys Bridge and across the N25 to Little Island.
______PL.MA0011 An Bord Pleanála Page 27 of 43
2.9 SUBMISSIONS WITH IMPLICATIONS FOR TRAFFIC ISSUES
A number of submissions were received from statutory bodies and evidence was given at the oral hearing from some of these bodies.
2.9.1 Port of Cork
The Port of Cork made a written submission on the 13 th September 2012 in respect of the development. It referred to the objective of achieving planning certainty. He said this particularly important to the Port of Cork in light of the strategic infrastructure development of a container terminal at Ringaskiddy which was refused under planning reference PL 04.PA0003 on the grounds that the proposal would result in much of the port-related traffic traversing the city road network and would impact on the carrying capacity of strategic interchanges and also the Jack Lynch tunnel and that the proposed development would exacerbate serious traffic congestion at a number of interchanges.
The submission states the company reviewed its strategic Development Plan and was now in a position to submit a revised proposal which, it was hoped, would address the Board’s concerns. It stated that the proposed improvement of the Dunkettle Interchange was welcomed, not only because of the improvement of journey times to the Jack Lynch Tunnel and the interchange, but also because the scheme was based on the fundamental principle of making separate provision for strategic and local traffic. The submission states that the benefits of the investment in the Dunkettle Interchange would not be fully achieved until strategic traffic was also prioritised along the M28 and Bloomfield Interchange.
The submission stated that it was important that proposal for strategic road infrastructure should demonstrate not only that there is a lack of conflict with planning policy, but also that they support in a proactive way the other strategic infrastructural objectives of the policy framework. The submission makes reference to the suitability of Ringaskiddy as the location for the majority of new port development and significant planning gains which would arise from the relocation of port operations from the city quays and Tivoli.
______PL.MA0011 An Bord Pleanála Page 28 of 43
The submission states that An Bord Pleanála assessment of the Dunkettle Project should have regard not just to the Blarney Local Area Plan but also to adjacent Local Area Plans which would generate strategic traffic through the interchange. It notes the Carrigaline Electoral Area Local Area Plan identifies Ringaskiddy as the preferred location for container services. Specific objective DB-02 undertakes to facilitate the relocation of the Port of Cork’s container and bulk goods facilities to Ringaskiddy.
The submission stated that in Section 3.3 of the EIS the effectiveness of Intelligent Transport Systems (ITS) was considered. It states that the analysis of the ITS measures demonstrated no reduction in congestion at the existing Dunkettle Interchange, they would ask the Board to consider whether ITS might have a role to play in ensuring that the benefits of the proposed investment at Dunkettle are secured for a strategic port traffic.
2.9.2 Submission of the National Transport Authority
Mr. Eoin Shinquin made a verbal submission at the hearing on Day 2 (Transcript, Day 2, Pages 76-80)
Mr. Shinquin set out the functions of the National Transport Authority as they related to Dublin and the country as a whole. He said it could be broadly divided on the basis of the various investment programmes, funding instruments and the regulation of transport service provision and investment in the provision of public transport services. He stated that they generally worked with local authorities, regional authorities and in that way they directed the spending of investment through various funding instruments. He said this was to influence and facilitate the integration of land use and transport planning at all levels. He explained that this was to ensure that the many planning decisions that are made would be made with a view to the transport implications of those decisions. He said they sought to work with local authorities at the earliest possible stage to influence elements such as the location of the development, mix of uses and public transport infrastructure and public transport services.
Mr. Shinquin referred to the Regional City’s Fund and the South West Regional Planning Guidelines. He stated that a five-year transport development programme was being prepared for both the city and County Councils. He said this would be underpinned by the objective
______PL.MA0011 An Bord Pleanála Page 29 of 43
of integrating land use and transport planning and would comprise the development of traffic management measures, walking and cycling networks, investment in public transport facilities and various transport demand monitoring measures.
In principle Mr. Shinquin said that any proposal to upgrade the national road network should primarily facilitate strategic traffic. He said in Cork there were a number of strategic employment locations which had been identified in the CASP Plan also. He noted the areas as being Little Island, Ringaskiddy, the airport, and locations west of the city and within the city boundary itself.
Mr. Shinquin said there were a number of objectives to improve public transport including better connectivity by public transport to strategic employment locations. He said that in time they would hope would deliver a modal shift away from almost complete car dependency towards the use of public transport. Mr. Shinquin concluded that the NTA were supportive of the scheme, but in the context in which he had described.
2.9.3 Submission of Cork County Council
The submission made by Cork County Council was by Mr. Andrew Hind, Senior Planner and Mr. Noel O’Keeffe, County Engineer.
The submissions by Mr. Hind and Mr. O’Keeffe are detailed in the report on the oral hearing and this was from Day 2 of the hearing, Pages 13-25.
The key elements of the submission by Mr. Hind related to the extent of the envisaged development which included the East Cork area, Dunkettle House, the relocation of the Port of Cork to Ringaskiddy, business and other development in the area of the airport and a science park development at Curragheen which he stated was at the immediate southwest of the city.
Mr. O’Keeffe made specific reference to the Atlantic Corridor and its importance.
______PL.MA0011 An Bord Pleanála Page 30 of 43
3.0 QUESTIONS PUT DURING THE HEARING BY MR. D. O’CONNOR
3.1 Questions on Day 1 of the Hearing, (Pages 23 – 30)
In reply to a question on the construction of the mudflats , Ms. Cawley stated that some mudflat areas would be permanently lost and to compensate for that they were creating fresh areas. She said it was important that the mud would be taken from the existing intertidal mudflats to the new areas, because the existing muds have all the nurturate communities. She said sewage outfalls upstream could be quite beneficial for nurturate communities and birds so it is very important as a food resource for birds so that the issue of a sewage outfall would not be negative.
Questions were put in relation to traffic and the first question was how the 2031 Traffic Projection was arrived at and was this based on traffic growths or were there very specific inputs from land use potential?
Mr. Euan Barr stated he was Technical Director with Jacobs and was the Traffic and Economics Lead in relation to the scheme. He said they had taken the NRA’s Project Appraisal Guidelines as an initial set of forecasts from the National Traffic Model to give a set of growth movements. He said that the model was supplemented with making sure that they took the actual distribution of the growth projected in the national model based on where the CASP update model actually seems to allocate the growth within smaller zone size locations.
(CASP is the Cork Area Strategic Plan which has an update year of 2020). Mr. Barr stated that the model year was slightly different in that it was five years beyond at 2025.
Other questions put for which replies were prepared for Day 2 were as follows: -
• Due to the constrained nature of the site and in particular the Jack Lynch Tunnel, was it possible to assign the right amount of development to the scheme and a request was made for traffic model outputs to help examine the predictions.
• The description of the scheme that the traffic would be free-flowing “as far as practicable”. The link that is not free-flowing is the one
______PL.MA0011 An Bord Pleanála Page 31 of 43
coming from the north to the west. A question was put as to how much longer the particular route would be in the future than it is at present. (The history of the Dunkettle Interchange and the additional use of traffic lights within the relatively short time were noted in this respect).
• What impact would altering speed limits on the N25 have on noise factors? It was noted that the speed limit on the N25 is 120 kph east of Little Island and from there it dropped to the west to 100 kph and further on to 80 kph.
• In response to questions raised by some objectors, would the noise expert reply as to the impact of noise when the elevation of the receptor is significantly higher than the location of which the noise is generated?
3.2 Questions arising from data submitted
On Day 3 of the Hearing (adjourned date of 9/1/13) the locations of the nearest permanent traffic counters were indicated on a map.
This indicated that counters N08-4b & 5 were on the M8 towards Watergrasshill. It is noted from the NRA Website that AADT for 2012 was 19,819 for counter 4b near the interchange and this was down 1.6% on 2011 which was the peak year.
The counter on the N8 (N08-4G) is between the Dunkettle Interchange and Dunkettle Roundabout and had a 2012 AADT of 37,758, down 3.8% on 2011. The peak year was 2007 at 43,022 AADT.
The N25 counter west of Little Island was 48,019 in 2012, down 2.9% on 2011. The peak year was 2008 with 51,514 AADT.
The above figures were not brought up or discussed at the oral hearing but the drop of approximately 13% from peak needs to be taken into account in the assessment.
A further question arises as to whether a counter on the N40 in the vicinity of the Tunnel is required for any on-going assessment.
______PL.MA0011 An Bord Pleanála Page 32 of 43
4.0 ASSESSMENT
The proposal is assessed in this report in relation to a number of headings which relate to transportation, noise, drainage and construction and the interaction of these impacts. The need for a scheme from a transportation point of view is also assessed.
4.1 Need for the Scheme
The current Dunkettle interchange has evolved over the last 15 years and currently comprises two major routes namely the M8 – N40 routes running north to south which intersects with the N25/N8 running east to west and also comprises a number of local roads which have significant traffic flows in their own right. Areas in the vicinity of the interchange are Glanmire, Glounthaune and Little Island.
The Jack Lynch tunnel was completed in May of 1999 and was reported to have approximately 40,000 vehicles per day using it in 2005. It has a height restriction of 4.6 metres which is lower than that on the main national road network (Dublin Port Tunnel is 4.65 metres height). The tunnel has required night time closure for maintenance from time to time and in the latter part of 2012 work had to be carried out to bring the tunnel into line with the requirements of the EU Directive 2004/54/EC which required additional fire safety measures. The need for this upgrade was not unique to the Jack Lynch tunnel and such upgrade works were also required in many tunnels in Europe and specifically on the M25 tunnel in London. The tunnel closures in recent times have been based on closing the tunnel to traffic from the hours of 21:15 to 07:00.
The M8 motorway leads from the Dunkettle Interchange to Naas where it becomes the N8 and the section between Cork and Fermoy has been open for over 5 years. The N25 Waterford to Cork section has been the subject of major upgrade works in the past 15 years and is dual carriageway from Cork City towards east Cork.
The circulatory roundabout which currently makes up the Dunkettle interchange, was signalised in 2006 to provide additional capacity and improve traffic flows.
Currently as described at the oral hearing there are peak hour queues which form on the N25 turning towards the tunnel and on the M8 heading south, both in the a.m. peak and there is evidence of queuing,
______PL.MA0011 An Bord Pleanála Page 33 of 43
sometimes back into the tunnel, for south to east-bound traffic in the p.m. peak period. The date given for this observation was November 2011 and current delays may in fact be less.
Preliminary to the consideration of the alternatives which were examined, it is necessary to pose the question as to whether the current problems could be addressed with measures that did not require the construction of major infrastructure. In this regard Volume 2 of the EIS is considered relevant and in particular Section 3.2 which is a consideration of a do-nothing and do-minimum alternatives. In Page 31 of Volume 2 of the EIS Table 3.1 gives 9 objectives and a do- nothing alternative is considered which is shown not to satisfy any of the objectives.
The do-minimum alternative which was examined looks at what would happen if any committed improvements were included. Those are schemes which have been progressed through the planning stage and are either under construction or are programmed into capital expenditure budget. The do-minimum alternative included the grade separation at the Sarsfield Road roundabout and Bandon Road roundabout on the N40 and associated works. The conclusion in the EIS is that the do-minimum alternative would not have any impact or would not satisfy the objectives listed. In fact it could be stated that the improvement of other parts of the N40 which is listed in the do- minimum scenario, would attract higher level of traffic onto the N40 generally and could have a negative impact on the Dunkettle interchange as currently configured.
In Section 3.3 the EIS considers traffic management alternatives which included measures involving access control, incident detection and variable mandatory speed limits and also tolling. The conclusion reached in the EIS was that traffic management alternatives would not satisfy the scheme objectives and it was concluded that the only remaining alternatives to be considered were those associated with direct infrastructural improvements.
The EIS does not consider how effective improved public transport links and initiatives could reduce overall traffic and if these could be successful in achieving significant modal shift, what the timespan would be. From the evidence at the hearing and the information contained in the EIS, it is reasonable to conclude that while the impact of public transport initiatives including park and ride options and a new
______PL.MA0011 An Bord Pleanála Page 34 of 43
station on the Cork-Middleton rail line in the vicinity of North Esk would assist in reducing traffic and achieving some modal shift, the extent of such traffic reduction would not be such as to render the need for major infrastructure works unnecessary.
With regard to the lower traffic volumes recorded in 2012than in previous years and the likelihood that the peak traffic year is more than 10% higher than current levels, it is still evident that congestion does occur, but to a lesser extent.
It is my opinion therefore that the EIS concludes correctly on page 32 of Volume 2 that there is a need for a solution to the current problem by way of provision of direct infrastructural improvements.
Before referring to the five different options considered in the EIS, the point made at the oral hearing in relation to having a second access from the N25 to the Little Island industrial area is considered very relevant and the point made that the second access is very important from a safety consideration, given the nature of the development in Little Island.
4.2 Alternatives Examined
The EIS sets out the alternatives examined which were the following:-
• Blue option Figure 3.1.1 and 3.2.1 of Volume 3 of the EIS. This option involves an additional roundabout on the N8 between Dunkettle roundabout and the Dunkettle interchange and significant earthworks adjacent to the Dunkettle House. There is also a relatively tight loop to allow traffic movement from the tunnel going east onto the N25.
• Brown option showing on Figure 3.1.2 and Figure 3.2.2. This option is characterised by a greater number of loops and the EIS notes that while only one railway bridge was required, a significant number of other bridges would be required.
• Orange option – Figure 3.1.3 and Figure 3.2.3 in Volume 3 of the EIS. This option features two loops north of the existing interchange and it is stated by the EIS to be similar to the brown option except it uses a larger loop for traffic exiting the tunnel and heading east.
______PL.MA0011 An Bord Pleanála Page 35 of 43
• Purple option – Figure 3.1.4 and Figure 3.2.4. This option accommodates the main south to east traffic movement (in both directions) without loops or roundabouts and the other movements are then accommodated with loops. Of particular note is the access from the M8 from the north to the N40 Jack Lynch tunnel which would be by way of elongated loop to the south of the existing interchange. This option includes a dumbbell junction to give a second access to Little Island and includes a spur heading south through this area.
• Red option – Figure 3.1.5 and Figure 3.2.5 of Volume 3 of the EIS. This is the chosen option . This also has the dumbbell junction given access to Little Island. It provides for direct flow of the N25 east to west with a larger radius loop from the tunnel to the N25 east. It also provides for access from the M8 to the tunnel. The main feature of this arrangement is the fact that there is a 1.3 kilometre extra distance to be travelled accessing the N8 west from the M8 and also there is a requirement to negotiate two roundabouts at the dumbbell arrangement at Little Island.
The EIS shows a framework matrix in Table 3.2 on Page 35 which indicates the preferences for the red option and the reasons for this choice are set out on Page 35. Advantages given included not impacting on the Cork Harbour SPA or directly on Dunkettle House or its demesne. The EIS states that as a result of its layout and configuration, it performed best in terms of reducing traffic congestion and improving journey times. It states it was also favoured along with a brown option in terms of safety.
The alternatives considered are described in the EIS and the rationale is given for the choice of alternatives.
4.3 Adequacy of Proposed Scheme in terms of Traffic and Transportation
The EIS sets out in both Chapter 1 and Chapter 2 of Volume 2 of what are the nine objectives of the Scheme as follows:-
1. Improve capacity through the interchange.
2. Make best use of the infrastructure to minimise the impact of the scheme.
______PL.MA0011 An Bord Pleanála Page 36 of 43
3. Separate local traffic movements from strategic traffic.
4. Provide separate clearly designated lanes with minimal weaving.
5. Provide a dedicated pedestrian and cycle connectivity through the junction.
6. Minimise impacts on adjacent environmentally sensitive sites.
7. Integrate with national, regional and local policy.
8. Provide consideration of access to a future railway station and associated park and ride facilities.
9. Provide a planning certainty in the area by establishing the design and layout of the improvement works to the existing interchange, thereby enabling better assessment of future planning applications in the area in the context of the proposed improvement works.
10. Of the above, I consider that Objectives Nos. 1 and 9 require further examination to understand what is being sought.
In relation to Objective 1 namely the improvement at capacity and the reduction of congestion, it is considered necessary to look at this objective as requiring any improved capacity to be fit for purpose or adequate for the likely eventualities in relation to traffic and transportation issues which would arise between the construction of the scheme and the design year. To this end, it is not satisfactory, given the constraints in the area which will be examined later, to refer solely to improvement of capacity.
In relation to Objective 9, it is considered that the adoption of a specific layout and design would not of itself give planning certainty unless it is possible to quantify or at least estimate the different traffic flows which would be generated by the different proposed major planning applications.
It is considered that Objectives 2-8 are capable of being met by the current proposal.
What marks out the Dunkettle interchange as unique, are a number of constraints, some of which do not appear to be amenable to being overcome, should the proposed scheme develop difficulties in the future. The constraints listed in the EIS are as follows:-
______PL.MA0011 An Bord Pleanála Page 37 of 43
• Cork Harbour SPA
• Dunkettle House
• Cork – Middleton Railway Line
• N40 Jack Lynch Tunnel
• Dunkettle Shore Proposed NHA
• Construction Phasing
• Topography
Of the above the N40 Jack Lynch tunnel is considered the most critical aspect in relation to future capacity and the need to link the current proposal with land use policies and proposed or anticipated population increases.
In addition to the constraints listed in the EIS, I consider that the N8 heading west through the Dunkettle roundabout towards Cork City is a further constraint in that this route would not be capable of significant improvements and also there is no obvious parallel route possible in the corridor between the Dunkettle roundabout and the city. It is noted that the current Cork North Ring Road which leaves the Glanmire Road at the Silversprings Hotel joins the N20 at Blackpool and has over 16 sets of traffic lights in that stretch of road.
Dealing firstly with the Cork North Ring Road, in the longer term, the potential construction of a route between the N20 south of Blarney and the N8 north of the Glanmire Junction is noted.
In the event of a direct link being provided between the N20 and the M8 to the north of Cork, this would potentially reduce pressure on the traffic route from Dunkettle into Cork City on the route of the old N8.
In relation to the Jack Lynch tunnel a number of specific issues are considered relevant:-
1. The tunnel has a height of 4.6 metres and as such cannot cater for some high vehicles and this factor could be relevant in relation to the development of Newport facilities in Ringaskiddy.
______PL.MA0011 An Bord Pleanála Page 38 of 43
2. Closures for maintenance and upgrade works have been necessary in the past. The most recent closures relate to upgrading of the tunnel to comply with new EU Fire and Safety Regulations and have resulted in overnight closures. It would be particularly important that sufficient capacity remains in the alternative route for the off-peak periods involved. This could not happen if in fact the normal flow or traffic demand in the tunnel was such that even the night time flows could not be accommodated on the alternative routes through the city.
3. The undesirability of queuing within the tunnel. It is noted that at present, in the p.m. peak that queuing within the tunnel occurs for northbound traffic. It is considered that a greater factor of safety or ratio of capacity to traffic flow is maintained for a tunnel as queuing within the tunnel should be avoided in the future.
4. The upper capacity of the tunnel was given at the oral hearing of being approximately 75,000 AADT. The 2016 traffic estimate in the EIS were medium growth was given as 62,700 AADT while for high growth, the document submitted at the oral hearing gives a figure for the year 2031 of 76,400 AADT. A question is therefore posed as to whether the projected traffic for the design year of 2031 is in fact above capacity, noting also that this is a tunnel rather than a dual carriageway in the open air.
While some of the above issues pose serious questions as to the adequacy of the proposal to meet the objectives, this item will be revisited in the section of the report dealing with recommendations.
The absence of an automatic on-line traffic counter on the N40, particularly in the vicinity of the tunnel, makes assessment more difficult. The question posed by the quite large drop in traffic volumes on some commuter routes in the area since 2007 (e.g. N22 Ballincollig and N25 east) needs to be taken into any on-going appraisal.
The drop in traffic since 2007 could be arising from lower employment but it could reflect changes in car usage. These functions could benefit from further study if more accurate predictions relating to the traffic implications of major planning proposals are to be achieved.
______PL.MA0011 An Bord Pleanála Page 39 of 43
5.5 Noise Issues
Noise issues were raised by residents in the vicinity of the proposed interchange, principally in Dunkettle, Glounthaune and North Esk. There is also a potential issue with noise in relation to wildlife which were raised by Dr. Good of the NPWS. The issues raised by Dr. Good relate mainly to the construction phase.
It was stated at the oral hearing that a major part of the noise generation comes from the N25 and it has noted that the speed limit for much of the area of the junction is 100 kph rising to 120 kph to the east and dropping to 80 kph to the west. The original proposal was to provide low noise surfacing to seven links on the scheme and at the oral hearing proposals were brought forward to use a low-noise surfacing on the entire scheme. The evidence given at the oral hearing explained the effect of low noise surfacing and the limitations on the use of barriers in some instances. Provided the mitigation measures of using a low-noise surfacing throughout the scheme coupled with the barriers which are proposed are carried out, it is considered that from a noise perspective the proposal is satisfactory. It is noted that in relation to construction issues, undertakings have been given to the NPWS in relation to noise and vibration impacts.
4.6 Drainage
It is noted that the current interchange and roadway do not have attenuation and the evidence at the oral hearing was that the 4 hectares of impermeable area currently discharging would have a 1 and 50 year run-off of approximately 585 litres per second. The drainage arrangements are in Figures 2.8.1 and 2.8.2 of Volume 3 of the EIS.
It is noted that the proposed drainage involves attenuation areas and the use of oil/petrol interceptors and constructed wetlands. The evidence at the oral hearing and in the EIS indicates that the proposed development would have 9 hectares of impermeable area which would include the 4 hectares currently discharging. The evidence is that there would be a total run-off for the 1 in 50 year storm event of 1,400 litres per second but when attenuated the flow would be less than 140 litres per second of which it states 70 litres per second would equate to
______PL.MA0011 An Bord Pleanála Page 40 of 43
discharges via the new attenuation measures. The proposals in relation to road drainage are considered satisfactory.
4.7 Assessment of submissions by the Port of Cork, the NTA and Cork County Council
In relation to the Port of Cork submission, it is clear that there is a very significant level of development envisaged which would generate high levels of traffic. The submission includes the proposition that the area vacated by the current port activities, would be redeveloped and this also would have significant traffic and transportation implications. It is noted that the submission makes reference to the use of intelligent transport systems to help monitor the effectiveness of the proposed infrastructure being proposed for the Dunkettle Interchange. The submission does not make reference to the height of Jack Lynch Tunnel, but presumably this has been addressed in its planning application and revised report.
In relation to the submission of the National Transport Authority, the linking of land use planning and transportation is referred to a number of times. This issue is considered at the core of the proposal. While the submission implies that transportation impacts should be at the heart of all significant land use planning decisions, this is not spelt out at any stage, and a submission does indicate broad support for all the measures and planning objectives that were listed by Cork County Council.
The County Council submission lists a number of strategic areas which are seen as objectives for development and are listed as objectives in the various local area plans. A number of these developments have been refused on the grounds of prematurity, pending resolution of the difficulties at the Dunkettle Interchange. Given the scale of some of the developments, the question has to arise as to whether the infrastructure being proposed at present would be sufficient for the generated traffic and transportation requirements to the design year of 2031.
In this case reference must be made to page 36 of Volume 2 of the EIS where the CASP total population in 2006 is given as 377,596 with the projected population for 2020 at 488,000 for the year 2020. This population figure approximates to the high growth scenario given in the supplementary evidence at the oral hearing on Day 2 on the 15 th
______PL.MA0011 An Bord Pleanála Page 41 of 43
November 2012. The concern is that the traffic flow projected for the Jack Lynch Tunnel in the supplementary information was of the order of 76,000 vehicles per day, while also at the oral hearing, the NRA stated that congestion could occur on an on-going basis with an AADT of 75,000.
Mr. O’Keeffe referred to the strategic importance of the junction as being part of the Atlantic Corridor. The Atlantic Corridor has been listed as including the routes of Limerick to Cork and Cork to Waterford. The route would therefore include the Cork North Ring Road as currently configured from Blackpool to the Silver Springs Hotel which is very congested. The improvement which would accrue to the N25 through the revised Dunkettle Interchange would appear to be quite marginal. Therefore it is difficult to see the overall strategic importance of the Dunkettle Interchange as a significant part of the Atlantic Corridor. In this respect what is reasonable to state that if the outer ring road between the N20 and M8 was completed, then the proposals for the Dunkettle Interchange would have a beneficial effect in that the free-flow arrangements between the M8 and N25 as proposed are quite satisfactory.
5.0 RECOMMENDATIONS
Having regard to the constraints imposed particularly by the Jack Lynch Tunnel and also the route of the N8 from Dunkettle to the city, it is essential that strategic land use planning decisions be made in such a way that any permissions granted would not cause the capacity of the proposed interchange to be exceeded. It is understood that studies have been undertaken and are being undertaken in the Cork area in relation to achieving reduction in commuter traffic which if successful would reduce long-term traffic demand.
Therefore it is recommended that if permission is granted for the interchange, that the proposers be required to upgrade the regional traffic model on a two-yearly basis and that at each review, in addition to measuring the traffic flows and validating the model, specific inputs for all planning permissions granted would be included in the model. It is recommended that no planning permissions with significant transportation impacts be granted when the capacity of the most critical element in the interchange, namely the Jack Lynch Tunnel, is at 90% of the level at which on-going congestion would occur.
______PL.MA0011 An Bord Pleanála Page 42 of 43
The implication of such a condition would be that if 90% of the capacity of the tunnel was committed, then further permissions should not be granted until or unless further traffic management measures and modal shift were shown to have taken place which would release more capacity in the tunnel.
It is also recommended that a permanent traffic counter be provided on the N40 close to the Jack Lynch Tunnel and that the on-going monitoring would take particular note of the traffic flows on this route.
______Daniel O’Connor Part Time Consultant
______PL.MA0011 An Bord Pleanála Page 43 of 43