An Bord Pleanála Ref.: HA0045 / MA0012
An Bord Pleanála
ASSISTING INSPECTOR’S REPORT TO SENIOR INSPECTOR
NATURE AND PURPOSE OF REPORT: To inform the report of the Board’s Senior Inspector on traffic and transport issues arising, including the adequacy of baseline information, the assessment of the likely impacts on traffic and transportation and the appropriateness and validity of traffic modelling; the need for the scheme having regard to policy provision, the strategic function of the road and road safety; the alternatives investigated and detailed design issues having regard to relevant roads standards.
Local Authority : Kildare County Council.
Proposed scheme : Naas to Newbridge bypass upgrade and replacement Newhall interchange scheme.
Dates of Site Inspection : 29/04/14, 08/05/14 and 15/05/14;
Date of oral hearing : 23/05/14, 16/05/14 and 06/06/14
Inspector : John Desmond
n Bord Pleanála Page of 7 Part A
1.0 SITE DESCRIPTION 1.1 The application site, comprising those lands contained within the indicated boundary as ‘ lands made available ’ in drawings figure 4.2 to figure .4.10, inclusive, of EIS Volume 3, encompasses approximately 13.6km length of the M7 / N7, extending between junction 8 Johnstown Interchange, to the east/north, and junction 11 Great Connell, between M7/M9, to the west/south. 1.2 The site encompasses junction 11 Great Connell; c.1km of the R445 (Newbridge to Naas road) including its over-bridge of the M7; junction 10 Newhall Interchange, including its over-bridge of the M7, two direct M7 off- slips and one direct M7 merge lane; an indirect M7 merge lane from the Newhall Interchange via the Bundle of Sticks roundabout on R445/L2030, including an intervening section of Due Way Road (local road, unnumbered); a section of unnamed / unnumbered local road (from the direction of Newtown townland) connecting at the junction of the local road (from Bundle of Sticks) and the M7 Newhall westbound merge. The site also encompasses junction 9 Maudlins Interchange between the M7 and R445 (Naas to Dublin and Johnstown); the R445 between the Maudlins Interchange roundabout and the M7 westbound off-slip roundabout, and a c.200m section of the L2014 to Johnstown. For clarity, junction 8 Johnstown Interchange does not fall within the boundary to the road scheme. 1.3 A grass median with hawthorn hedgerow runs along almost the entirety of the subject length of the M7 / N7. The EIS indicates that the width of the median varies from 12-15m wide between J11 and J10 and is c.8m between J10 and J9. 1.4 Junction 11 Great Connell Interchange is not a full interchange and only facilitates access from the M9 to the M7 in the eastbound direction and access from the M7 in the westbound direction to the M9 southbound (the M9 commences at junction 12). There is no access from the M9 to the M7 westbound and no access from the M7 eastbound to the M9. The merge from the M9 to the M7 has two lanes extending up c.1km in length. 1.5 Junction 10 Newhall Interchange is not a full interchange, although it facilitates full interchangeability indirectly. It allows direct egress from and access to the M7 in the eastbound direction and also allows direct egress from the M7 from the westbound lane. Access to the M7 westbound is facilitated indirectly via the junction of the R445 and the L2030 at the Bundle of Sticks roundabout and Due Way Road. The design of the interchange is a one-sided dumbbell (northern side), with the M7 off-slip and merge slip meeting the L2030 at a relatively small roundabout which also accommodates access to the M7 Business Park. The M7 westbound off-slip terminates at the
n Bord Pleanála Page of 7 priority junction with the L2030. The Bundle of Sticks roundabout acts as a default southern side to the dumbbell junction. The interchange acts as a western / southern interchange serving Naas and as a northern / eastern interchange serving Newbridge. 1.6 Junction 9 Maudlins Interchange is a J-type interchange with a roundabout on the southern side. It accommodates full interchangeability. 1.7 The western distributor road (also known as the Naas Orbital route 1) runs approximately parallel to the M7 between the Bundle of Sticks Roundabout and Sallins Road, with the route continuing north to Junction 9, Maudlins Interchange, as Monread Road. The WDR is the principle traffic route through Millennium Park and effectively forms an inner bypass to Naas. It is designated as a local road.
2.0 PROPOSED DEVELOPMENT: 2.1 The proposed development comprises, as follows: • The widening from two to three lanes of the M7 between junction 11 Great Connell (M7/M9 merge) and Junction 9 Maudlins, over a length of c.13km, including:
o Consequential minor reconfiguration of the section of dual 3-lane all- purpose road between junction 9 Maudlins and junction 8 Johnstown which currently includes a lane gain/drop as the road passes through Maudlins interchange, following the existing alignment;
o Constructed within the existing grass median;
o Drainage works provided within grass verges and 5 new attenuation ponds alongside motorway (chainage 4+400 to 4+800; 6+500 to 6+700; 7+700 to 7+900; and 11+400 to 11+500 approximately) some requiring new land-take;
• Closure of motorway slips to the existing junction 10 Newhall Interchange.
• Construction of a new dumbbell interchange (new junction 10) with existing R445 Naas-Newbridge Road 700m south of existing junction 10, with two new roundabouts on R445, one either side of existing motorway bridge (ch 6+700);
• Local reconfiguration of the merge and diverge tapers at junction 11 Great Connell to effect a lane gain/drop;
• Local reconfiguration of eastbound merge and westbound diverge tapers at junction 9 Maudlins to eliminate current lane gain / drop arrangement;
1 For consistency, I will refer to this route only as the Western Distributor Route or the WDR.
n Bord Pleanála Page 3 of 7 • Due Way road, currently acting as a local access road and a M7 merge slip will be locally realigned to the south of the new Newhall interchange to provide for local access only and omitting the M7 merge slip and a new roundabout will be provided to maintain access to the surrounding lands.
2.2 Road design details The proposed M7 upgrade road cross-section is as follows: • 3.0m hard-shoulder, 3no.X 3.5m traffic lanes; median hard-strip 1.0m required by TD27 resulting in 14.5m each side. Existing is 3m, 3no.X 3.65m; 1m = 11.3m. Additional hard-surface required is 3.2m per carriageway.
• A concrete barrier will be provided for each carriageway with (leaving space in-between) except between ch 13+670 and Ch 14+300 due to level difference to be retained by concrete barriers.
• Existing speed limits (120kph between J11 and J9 and 100kph between J9 and J8) to be retained.
3.0 Environmental Impact Assessment 3.1 The application is accompanied by an EIS.
4.0 Compulsory Purchase Order 4.1 The proposed development requires land take from the following parties:
5.0 PLANNING HISTORY 5.1 Road schemes - HD0032: Application for Local Authority Road Development EIS Direction in respect of the proposed upgrade of existing pedestrian, cycle and vulnerable road user facilities along the R407 Sallins Road, from Naas to Sallins Village. DECISION DUE 23/09/14. HA0046: Concurrent application for M7 Osberstown Interchange and R407 Sallins Bypass scheme. DECISION PENDING. HA0018: The Local Authority Road Development Application was lodged by Kildare County Council on 04/11/08. The Board decided on 26/02/10 to REFUSE TO APPROVE the proposed M7 Osberstown Interchange motorway scheme. The main reason for refusal can be summarised as concern over project splitting of projects requiring EIA, with consideration of the proposed Osberstown interchange premature in the absence of the concurrent consideration of the Sallins bypass (having regard to the objectives in the Sallins LAP 2009 in addition to objectives in the Naas TDP 2005) as part of an overall development proposal.
n Bord Pleanála Page of 7 The Board’s reasons and considerations included reference to the Sallins LAP 2009 objectives to provide for a new interchange to relieve congestion on the other two interchanges and provide additional connectivity to the local, regional and national network; to facilitate improved public transport services included n/s public transport link across the M7 motorway link between Sallins and Naas in accordance with CDP 2005 objectives; and the achievement of the SLAP 2009 objective for a public transport interchange connecting the M7 and the railway. TR4(iv) and PT5 of Sallins LAP; sections 4.2.7 objective M25c and 4.2.3 of the NTDP 2011. A submission received from NRA (23/12/09) indicated no objection in principle and stated that ‘ the authority is conscious of the significance attached by the County Council and the Town Council to the Osberstown Interchange as an integral element of an overall transport plan for the area which seeks, inter alia, to improve regional transport linkages to a new and expanded Naas and Sallins Train Station, provide an extensive park and ride facility to serve the Naas and Sallins station and to create regional/local bus/rail interchange facilities . The successful implementation of this strategy would, in the local authorities [sic] view, facilitate a transfer of car-based commuter traffic off the M7 to rail These objectives strongly influenced the Authority’s position on the Council’s proposal for the M7 interchange.” …The Authority recognises that the Newhall Interchange will require upgrading in the future; the proposed Osberstown interchange is likely to result in some deferment of this requirement. It is the Authority’s intention to upgrade the Naas bypass motorway to three lanes in the future. The present interchange proposal, as designed, will not impact on the ability of the Authority to undertake such upgrade works. The Authority will not be contributing to the cost of the proposed interchange…” HA0008: The application for the Local Authority Road Development, referred to as the N7 Newlands Cross Junction Improvement Scheme, was 17/12/07. The Board decided (06/06/08) to APPROVE WITH CONDITIONS (generally standard type and entailing minor modifications) ER2018: The application for EIS Road Approval was lodged by South Dublin County Council on 16/01/03 for the N7 Rathcoole to Kildare County boundary road improvement scheme. The Board decided (21/07/03) to APPROVE WITHOUT MODIFICATIONS. ER2008 : The application for EIS Road approval was lodged by Kildare County Council on 17/01/01 for the N7 Naas Road Widening and Interchange Scheme. The Board decided (09/08/02) to APPROVE WITH MODIFICATIONS (generally minor, relating to noise mitigation measures). ER2034: The application for EIS Road approval was lodged by Dun Laoghaire County Council on 23/09/04 for the upgrade of existing M50 motorway in Dublin entitled “M50 Motorway Upgrade Scheme 2004”. The scheme comprises the addition of a third lane in each direction on the M50 over a distance of 31kilometres between the M1 and Sandyford together with the provision of auxiliary weaving lanes
n Bord Pleanála Page of 7 between the M1 and Scholarstown, generally within the existing motorway boundaries. Modifications to ten interchanges will provide full or partial free flow for the principal turning movements and the Westlink toll plaza will be upgraded to a fully electronic free flow facility. The Board decided (29/04/05) to APPROVE WITH MODIFICATIONS . Condition no.7 attached by the Board is of particular note: ‘A scheme of specific demand management measures for the M50 motorway corridor shall be published by the relevant road authorities not later than three years after the M50 Motorway Upgrade Scheme has been completed. Reason: To protect the traffic capacity provided by the M50 Motorway Upgrade Scheme over its design life.’
5.2 Other Schemes – Part 8 :
No reference number. Part 8 Scheme advertised for ‘Bus Hub’ at Market Square, Naas, comprising provision of bus parking and bus shelters on either side of the street at Market Square, with improvements to the public realm, footways, upgrade of pedestrian crossings, cycle stands, realigned parking and taxi rank. The public consultation period closes on 19 th September 2014.
No reference number. Part 8 Scheme advertised for the upgrade of the R407 Sallins Road Osberstown Roundabout, Naas. The public consultation period closes on 19th September 2014.
5.3 Relevant Planning Applications Reg.ref.13/500018: Permission GRANTED by Kildare County Council Planning Authority for A Global Technology and Innovation Centre of c.24,968-sq.m over 4 storeys with both open and enclosed plant areas at roof level, in 5 interconnected blocks comprising a mixture of office accommodation, customer areas, meeting rooms, office and staff facility accommodation, delivery point and general service yard, research and development areas, technology development areas and storage facilities: Block A provides office floor space of c. 5,892-sq.m gross floor area over 4 storeys plus plant at roof level, Block B provides reception area, office and office support floor space of c. 3,346-sq.m gross floor area over 4 storeys, Block C provides office, office support, laboratory and laboratory support and research floor space of c. 9,412-sq.m gross floor area over 4 storeys plus plant at roof level, Block C1 provides goods handling, service and maintenance, and plant floor space of c. 509-sq.m gross floor area over a single storey, Block D provides research and development and plant and maintenance access floor space of c. 5,758-sq.m gross floor area over two storeys plus plant at roof level; c, 784 parking spaces (c.1 per 32- sq.m), c. 100 bicycle parking spaces, etc., on a site area of c. 12.19 ha. Access to the development is proposed to the southeast (employees) via the District Distributor Road permitted under 07/500040 and to the east (visitors) off the Millennium Link
n Bord Pleanála Page 6 of 7 Road (the WDR). Permission is sought to amend the development granted under Planning Register Reference 07/500040 in order to facilitate the proposed access arrangements. The site is located within Millennium Park and is bounded generally by the M7 to the northwest and the Western Distributor Road to the southeast, the proposed Distributor Link Road to the northeast. The proposed Osberstown Interchange (HA0046) is located to the north / northeast and the site boundary of same encroaches slightly thereon. The implementation of this permission supersedes previously authorised development on this site under reg.ref.07/500040 (distributor road system implemented) and reg.ref.08/500065 (6-storey office building). Reg.ref.06/500189: Permission GRANTED (25/06/07) by KCC to Gerry Prendergast / ReNAASance Medica Ltd for a private day hospital within a 4-storey over-basement building. Extension of permission was granted (reg.ref.12/500046) and the permission will expire 26/07/17. The site is located within Millennium Park to the south of (and accessing onto) the roundabout to which the proposed Osberstown Interchange link road will connect into the Western Distributor Road.
6.0 OBSERVATIONS FROM STATUTORY BODIES The main points of the observations received are summarised below:
An Taisce (21/02/13) • Will encourage commuter travel by private car in contravention of Government policy in Smarter Travel • EIS doesn’t address additional traffic generated by switch from public transport to private car into the future, particularly so for Newbridge traffic. • No consideration of alternative scenario of strengthening public transport to alleviate congestion. • Smarter Travel has entirely changed the considerations under which road and other transport investment must be assessed by the Board which must ensure that any future road scheme (i) does not increase 2009 traffic volumes and (ii) does not undermine national target to reduce work related commuting by car from 65% to 45%. • The scheme cannot be justified by the argument of reducing congestion – alternative action required to reduce traffic generation on M7 through public transport and cycling promotion. • 5 goals of Smarter Travel – i) reduce overall travel demand; ii) maximise efficiency of transport network; iii) reduce reliance of fossil fuels; iv) reduce transport emissions; v) improve accessibility to Transport. • 5 overriding policy objectives – i) future pop employment growth to take place in sustainable compact forms to reduce need to travel for employment / services; ii) car commuting to drop from 65% to 45%; iii) cycling, walking and public transport to account for 55% of commuter work journeys by 2020; iv) total km
n Bord Pleanála Page 7 of 7 travelled by car fleet not to increase significantly; v) reduction of GHG emissions from 2005 figure to be achieved for transport sector. • The applicant should have overall objective of reducing traffic demand through creation of walkable settlement patterns and include detailed policies on walking and cycling and reducing car use. Does not align with NTA policy on regional transport strategies regarding rail infrastructure and bus services. • The Board is requested to consider the impacts of the project on potential for achieving Smarter Travel targets in mid-east and midlands region and nationally in its carrying out of EIA. • No evaluation of the impact of dispersed settlement on the current road has been carried out in the EIS. The proposal will facilitate ease of use in commuter travel feeding into Dublin and further exacerbate suburban and rural sprawl. Board should consider the downstream impacts this road project will have on future spatial settlement and land-use patterns. • Fossil fuel & climate change – public investment in oil dependent infrastructure is short-sighted (peak oil, rising prices); fossil fuel reserves must be left in ground as there is no safe level of emissions. • Ireland bound to reduce GHG emissions by 20% on 2005 level. EPA projects exceedences. No co-ordinated concerted effort to reduce emissions. Further infrastructure investment in roads to serve energy inefficient and emission generating private motorised vehicles is untenable, will shape society & economy around oil-based transport and increase exposure to oil price inflation. • Board requested to have regard to – Intergovernmental Panel on Climate Change (2013); A Baseline Assessment of Ireland’s Oil Dependence (Forfas 2006); Tipping Point (Feasta, 2010); Sustainable Energy Security (White Paper, 2010); The Oil Crunch (UK Task Force); Growth Isn’t Possible (2010); • The EIS has not fully considered the impact of oil dependent infrastructure in increasing capacity for generation of GHG emissions. • The Board should consider the impact of the project on the future of Ireland’s commitments in climate change and requirement to reduce carbon. • Noise – EIS indicates that noise levels are already above noise design goal for new roads. Scheme can only exacerbate this.
DAU DoEH&G ( 20/02/13) • All mitigation measures detailed in s.13.7.1 should be carried out in full in advance of commencement of development & overseen by a Project Archaeologist.
HSE (21/02/13) (subsequently withdrawn): • Use of pesticides – buffer zone from water-bodies should be as per that specified on pesticide label not a standard 2m.
n Bord Pleanála Page 8 of 7 Inland Fisheries (21/02/13): • No objection – All works to be subject to Construction Management Plan and Environmental Operating Plan which should identify potential impacts and mitigating measures and provide a mechanism for ensuring compliance with environmental legislation. • Comply with mitigation measures detailed in chapters 7, 9 & 20 EIS. • All in-stream works to be completed May – September and then in-line with an agreed Method Statement. • Detailed design of culvert design for Ladytown Stream and R445 to be agreed with IFI in advance – general principle acceptable.
IAA – no observations
National Transport Authority (21/02/13) • No objection in principle to M7 upgrade. • Cycle Network Plan for the Greater Dublin Area – R445 Newbridge / Naas is rural cycle route K15 connect route N1 in Naas to NB1 in Newbridge. At detailed design stage appropriate facilities should be included at the proposed Newhall junction layout to facilitate safe cycle usage across the junction including roundabouts and connecting links. NTA would welcome liaison with scheme designers. • A number of bus services between N/N and on the N7 route stop within the vicinity of the proposed junction. At detailed design stage a review of adjacent or potential bus stop locations is required together with an examination of likely necessary pedestrian links and that appropriate provision for safe bus stopping facilities and safe pedestrian links and crossing points within the extents of the scheme are provided at detailed design stage.
OBJECTIONS TO THE EIS ONLY The main points of the objections received are summarised below:
Annett & Ciaran Parker; Grainne & Michael Forde • Extension of noise attenuation barrier >500m east of NSR R16 to mitigate noise on that dwelling. • Survey underestimates impact as wind speed and direction not taken into account – dry calm day. Prevailing wind will increase noise levels above those predicted.
• WHO – impact of noise on children. L night level of 40dB(A) recommended outside bedrooms to prevent adverse health effects (WHO Regional Office for Europe, Data and Statistics 2014) whereas 54dB and 55dB predicted for 2015 and 2030.
n Bord Pleanála Page 9 of 7 Mr Fintan Flood (c/o Vincent JP Farry & Co. Ltd) • No objection in principle but inadequate attention paid to the effects associated with the replacement of junction 10 on M7 with new access and egress arrangement. • Will focus on existing junction already suffering considerable congestion which the circuitous nature of the replacement arrangements is likely to exacerbate. • EIS confesses that the motorway project will exacerbate congestion on local network (operating already in excess of design capacity) – shouldn’t be endorsed in advance of changes to remedy same. Concerns R445 & L2030 (Rathangan Road). Short distance and long distance commuters use this route & M7 resulting in near gridlock at peak. • The traffic problems on R445 / L2030 exist independently of cars leaving the M7. R445 is already clogged with local traffic in the PM peak and cannot absorb additional flows, rather than the flows exiting the M7 being the problem. • The scheme will required M7 bound Rathangan traffic to divert through the congested bundle of sticks roundabout. Likely that such traffic will instead divert to R445 via Floods Cross along rural road [L2031], a substandard rural route. • The improvement of traffic flows on M7 would be at expense of conditions on local road and encourage some drivers to use the national road for short trips. • NB of L2030 which carries a greater volume of traffic than many regional routes. NB of population within hinterlands Of N/N/R & the large commuter population. • Junction 10 facilitates short-distance and longer-distance trips. • Mitigation required to address this – roundabout at Flood’s Cross, upgrading of L2031 between L2030 & R445 and provision of roundabout to R445 junction with L2031.
Harry & Maura Coyle (c/o Maguire & Associates) Newhall, Naas (subsequently withdrawn), • Proximity of contractor’s compound to dwelling- no alternative location examined in EIS. • Impact of night time working • Excessive noise levels – rerouting of heavy vehicles to both sides of dwelling. • Duration of contract 28-34 months • Impact on family’s mental health • Inadequate vehicular and pedestrian access. Dangerous and non-compliant with ‘Recommendations for Site Development Works for Housing Areas’ (DoE&LG 1998). Health and safety issue. Services access problems. • Underestimation of traffic in the area leading to inadequate assessment of impact on residential property in relation to material assets, noise, air quality & traffic. • No assessment of human beings in EIS
n Bord Pleanála Page of 7 • Mental anxiety and stress over time. • Sleep deprivation. • Noise amplified by reflection off large building. • Raises issue of request to rezone of lands. • Map 4/9 (fig 13.4) of roundabout is incorrect. • Inadequate description of development in notices, no site notices indicated. • Locating of interchange further west no investigated as alternative. • Traffic analysis significant underestimation of flow – Trafficwise for Brendan and Gertie Coyle forecast increase in flows on R445 and M7. Impacts on objectors therefore underestimated & mitigation may be inadequate. Appendix A shows traffic to increase by more than 50% but this is not reflected in the EIS. • Impact on material assets inadequate – impacts on residential amenities of the dwellings will be significant during construction and devastated on completion but were not assessed, only impact on lands used for equine. From Table 11.6 EIS baseline rating of lands should be high not medium and impact significant. • Impact of loss of amenity not recognised or analysed under Human Beings. Profound cumulative impacts on quality of life and mental health. • EIS acknowledges the cumulative visual and landscape impact on the domestic environment of the Coyle’s houses over two decades but only minimalist mitigation proposed. Proper landscaping, planting, banking of solid and higher noise barriers required. • Mitigation is totally inadequate to alleviate noise. Location of noise survey point S03e underestimates baseline noise and the cumulative noise impacts. • Air quality and climate – the residents will have to move out during construction. • Cumulative impacts - inadequate baseline analysis of the existing situation (noise & air quality) leading to inaccurate conclusions in EIS. • If permitted the following conditions should apply – i) relocation of contractor’s compound; ii) no night time working within vicinity; iii) noise mitigation measures to be agreed with the Coyles and completed prior to commencement; iv) revised access road and cycleway to Coyles completed prior to commencement; v) all proposed works to be agreed with Coyles prior to commencement.
Joe & Karen Evans (19/02/14) 1158 Osberstown Cottages, Naas (subsequently withdrawn) • Low hedge at rear of property should be replaced by wall to mitigate impact of water collection and storage area. • Impact – results in unacceptable overlooking and loss of privacy. • Impact – access to site from M7 will result in loss of security. • Impact – represents an unacceptable risk to their children. • Impact – increase in rodent population and influx of same to their property.
n Bord Pleanála Page of 7 Kerry Group Services International c/o Brock McClure 21/02/14 • Welcomes the development and has no issue with components of the scheme. • Development permitted under reg.ref.13/500018 is under construction creating 800 permanent jobs and 300 construction jobs on site within Millennium Park within vicinity of the scheme (owns land proximate to Osberstown attenuation pond also). • Scheme has potential to fulfil key policy objectives for Naas and act as catalyst for development in Millennium Park. • Concern about commencement, timing and progression of project in relation to the concurrent Sallins by-pass and Osberstown Interchange. • Sallins / Osberstown scheme has 18 month construction timeframe and commencement date of 2015. • The M7 Naas / Newbridge upgrade is to be constructed in advance of the Sallins / Osberstown scheme, has a construction timeframe of 28-34 months with a likely earliest commencement date of January 2015 and completion date of May 2017. • The earliest Osberstown Interchange commencement and completion dates would be June 2017 and October 2018 respectively. • Section 18.5 of the EIS indicates that the S/O would increase traffic on M7 by 8-10%, leading to congestion and further delays and it is therefore dependent on completion of the N/N M7 widening scheme and may not be constructed but not opened until the widening works of M7 are competed. • A situation whereby the O/S scheme does not commence until the M7 upgrade has been completed is untenable to the Kerry Group. They welcome that the schemes can be constructed concurrently and request that the projects remained independent in terms of their timing of commencement.
Mary Coyle, Newhall, Naas c/o Maguire & Associates 18/02/14 (subsequently withdrawn) • Air pollution, noise pollution, disruption of family life from construction works, disruption of services/utilities and grandchild’s studying, disruption of horses, stress, flooding from surface water runoff and value of home decimated by the road developments surrounding the property. • Proximity of contractor’s compound • Night time working • Excessive noise • Duration of construction works (28-34 months) • Impact on mental health • Inadequate vehicular and pedestrian access • Underestimating traffic levels and consequently inadequate assessment of impact un terms of Material Assets, Noise, Air quality and traffic. • No assessment of Human Beings.
n Bord Pleanála Page of 7 • Noise amplified by reflection off large building. • Raises issue of request to rezone of lands. • Map 4/9 (fig 13.4) of roundabout is incorrect. • Inadequate description of development in notices, no site notices indicated. • Locating of interchange further west no investigated as alternative. • Traffic analysis significant underestimation of flow – Trafficwise for Brendan & Gertie Coyle forecast increase in flows on R445 & M7. Impacts on objectors therefore underestimated & mitigation may be inadequate. Appendix A shows traffic to increase by more than 50% but this is not reflected in the EIS. • Impact on material assets inadequate – impacts on residential amenities of the dwellings will be significant during construction and devastated on completion but were not assessed, only impact on lands used for equine. From Table 11.6 EIS baseline rating of lands should be high not medium and impact significant. • Impact of loss of amenity not recognised or analysed under Human Beings. Profound cumulative impacts on quality of life and mental health. • EIS acknowledges the cumulative visual and landscape impact on the domestic environment of the Coyle’s houses over two decades but only minimalist mitigation proposed. Proper landscaping, planting, banking of solid and higher noise barriers required. • Mitigation is totally inadequate to alleviate noise. Location of noise survey point S03e underestimates baseline noise and the cumulative noise impacts. • Air quality and climate – the residents will have to move out during construction. • Cumulative impacts - inadequate baseline analysis of the existing situation (noise & air quality) leading to inaccurate conclusions in EIS. • If permitted the following conditions should apply – i) relocation of contractor’s compound; ii) no night time working within vicinity; iii) noise mitigation measures to be agreed with the Coyles and completed prior to commencement; iv) revised access road and cycleway to Coyles completed prior to commencement; v) all proposed works to be agreed with Coyles prior to commencement.
Old Abbey Residents Association c/o Mark Stopes (subsequently withdrawn) • Objects to the provision of a 3 rd lane to the M7 and to the ancillary works. • Increased impact of noise on this estate located within 200m of the M7 during operation and from construction. • M7 identified in the Kildare County Noise Action Plan 2013 under the Environmental Regulations 2006 which gave effect to EU Directive 2002/49/EC. Old Abbey Manor was identified as affected. • The primary objection of the NAP is to prevent future noise problems and the second is to improve the noise environment of those affected. Any strategic development should consider the NAP recommendations in accordance with the Directive.
n Bord Pleanála Page 3 of 7 • Reg.ref.03/2515 conditioned the erection of a noise barrier along the M7 approximately between chain 0 – 600 of proposed scheme but not erected (enforcement 05/02/2010). • The unremedied breach of planning, if not rectified, will lead to further degradation of noise environment. • Does not recognise NAP recommendations and further action is required to manage the additional noise generated. • If proposals agreed with Willie Hannigan and Stephen Cunningham 21/01/14 are actioned this will allow the objections to be removed.
Orla & Trevor Nuzum, Roseanne & Vincent Butler, Mary & PJ Breen and Marie & Padraig Gibbons of Caragh Road, Naas, 21/02/14 (subsequently withdrawn) • Impact of noise on the 5 properties. • Existing significant impact may become intolerable with 3 rd lane upgrade. • Nuzum’s house was not included in the noise assessment readings. • Requests that the noise attenuation barrier be extend up to Ch. 8850 at minimum and increased to 2.5m in line with other sections of road. • Would like clarity on nature of acoustic barrier design – absorptive or reflective and performance rating? • No objection to upgrade in principle.
OBJECTIONS TO THE EIS AND CPO
Brendan & Carol Carton, Lewistown, Naas (18/02/14) • Extreme upset at having their names published in the Leinster Leader in the CPO scheme. • Attached map of area concerning CPO. • The EIS has understated the forecast increase in traffic flows and consequentially the impact on the property of noise and vibration arising from traffic flows are underestimated. • No noise measurement taken from their property. • The noise barriers will be totally inadequate to reduce the impacts. • Should permission be granted conditions should require provision of additional noise barriers including insulation of house with treble glazing; provision of earthen mound along edge of M7; no night time working to be allowed within the vicinity; and provision of additional landscaping of the site (in context of location of house beside the Herbertstown Branch of the Grand Canal.
Brendan & Gertie Coyle, Newhall, Naas (18/02/14) (subsequently withdrawn) • Cumulative impacts of successive road schemes on mental health / anxiety. • Destruction / dispersal of original farm holding.
n Bord Pleanála Page of 7 • Cumulative noise and lighting impacts and impacts on residential amenities. • Impact of construction works plus night time working – 28-34 months. • Inadequate vehicular / pedestrian access. • Impact of night time working on horses. • Inadequate assessment of impact on material assets, noise, air & traffic on their property. • Location of contractors' compound. • No assessment of Human Beings. • Letter to Joe Kelly NRD Office regarding noise issue at Coyles. • List of Coyles’ objections – noise, property devaluation, major drainage problems, emergency access impossible, dust during construction, night working, traffic pollution, no pedestrian access / footpaths, tonal disruption (7 generations of family have lived here). • Since 1990’s no mitigation measures have been carried out to mitigate impacts of M7. • Drainage / flooding of Coyles’ lands – photos (flooding & waterlogging) and map attached and noted. Problems arise from previous road schemes due to poor construction, non-accordance with good engineering practice and inadequate supervision. No drainage provided to N/N road but flows onto Coyles’ lands; water flows across N/N road leading to flooding on road (traffic hazard – some mitigation carried out); poor restoration of field (1) now waterlogged; blockage of drainage channels leading to flooding of field (2); drainage channel should have been provided under M7 to drain lands (points A-B); flooding from Rathangan Road due to inadequate gullies; impacts on equine use. • Vehicular / Pedestrian access – no footpaths / cycleways / public lighting to Coyles ‘ housing estate ’. Refuse collections via R445. Access provided as part of previous road upgrade scheme is extremely dangerous to egress. Does not comply with ‘Recommendations for Site Development works’ (DoE&LG 1998). • Photo survey of houses concerned attached. • The lands should be zoned industrial the same as the surrounding lands. • No proposals included to achieve the stated objective ‘ to better facilitate cyclists and pedestrians at the Newhall Interchange ’, • Inadequate description of proposed development in newspaper notice 20/12/13. No indication of site notices. • Alternatives – why was the option to relocate the interchange / junction 10 further west not examined where no house / amenities would be interfered with. Proposal has maximum impact on Coyles. • Alternatives – No alternative location considered for construction compound. • Traffic analysis – R445 & M7 traffic forecasts significantly underestimated (agent predicts 50% increase on R445) & therefore the impacts are also and the mitigation consequently insignificant.
n Bord Pleanála Page of 7 • Material assets – EIS conclusion that no direct impacts will occur on any residential property assets from M7 widening is not convincing. No consideration of impact of Newhall Interchange & etc. No analysis included on impact on Coyles’ residential properties from construction and operations or taking account of impact on same from cumulative impacts over 30 years. • Material assets – use of ‘medium’ rating for equine use as baseline criteria is inappropriate and distorts significance of impact in the EIS. • Material assets – no analysis carried out on residential properties (rated high) in the EIS. • Human beings – impact on Coyle’s residential amenities have been completely ignored. Positive impact on most HBs but not on Coyles which will be profound and catastrophic. • Landscape and visual impact – section 14.8.2 of EIS states ‘ the cumulative effects [on the Coyles’ properties] of the proposed development with previous development of the motorway and environs should be recognised. ’ Yet only minimalistic mitigation measures proposed. Proposed landscaping (soil banking and noise barriers) and planting required as buffer. • Noise and vibration – 3 rd party consultant’s report (Karl Searson CE) submits that Coyles’ properties are blighted and mitigation is totally inadequate. Baseline station S03e location understates noise. Does not address the cumulative impact of noise on these properties over last 20 years or propose mitigation and therefore EIS is inadequate. • Noise and vibration – EIS does not address noise impact on horses. • Air quality and climate – TMS ltd report • Cumulative impacts – impacts (flooding, traffic, noise & air quality) on Coyles completely ignored & mitigation measure totally inadequate. Inadequate baseline assessment. • If permitted the following conditions should apply – i) relocation of contractor’s compound; ii) no night time working within vicinity; iii) noise mitigation measures to be agreed with the Coyles and completed prior to commencement; iv) revised access road and cycleway to Coyles completed prior to commencement; v) all proposed works to be agreed with Coyles prior to commencement.
Trafficwise Report – Julian Keenan • Addresses EIS’s assessment of traffic, associated direct effects from increased traffic flows and other effects dependent on traffic flow data and forecasting. • The detail provided in the EIS is not commensurate with the Institute of Highways and Transportation ‘Guidelines for Traffic Impact Assessment ’ (1994). Insufficient data or references to enable the reader to follow all stages and come up with similar results. • Baseline data given as 2012 but M7 traffic count data for Naas Bypass not available on the website. No details of the NRA counters, such as the unique
n Bord Pleanála Page 6 of 7 reference numbers are provided. Unreasonable not to provide same. Impossible for third parties to check the accuracy of the TA without this data. • Data collection - Base manual / automatic surveys carried out in February – not a neutral month for traffic data – flows are low and not representative (this is supported by NRA online data - .10% below 85 th percentile value used in TAs & 5% below AA traffic). The NRA’s PAG (p.30) also show that Feb/Jan have lowest traffic flows. • No supporting information in EIS that baseline data was adjusted or factored to account for shortfall between data and representative traffic flows. Baseline inaccurate then forecast will magnify inaccuracies increasing with length of forecast. • Reported results – 6.4.2 states ‘ the PAG specifies that the proposed scheme should be assessed using three future traffic growth scenario, namely NRA low, medium and high growth.’ The EIS reports that assessments have been carried out for all 3 but presents only medium on the basis that it “ represents a central forecast of future growth ”. Maguire claims that the this is false and that the medium growth rate is come 25-30% lower than the average between the high and low growth scenarios. • Based on PAG it is reasonable to expect that all three scenarios should be presented and results considered and discussed within the EIS report. The EIS fails to consider the environmental impact of the low and high growth scenarios throughout, including on noise and vibration impacts but only the medium GR which is less than the average or central forecast.
Base traffic model & traffic flow forecast - • Table 6.3 opening year scenario for R445 (west of Newhall) is 17,050s based on estimated of AADT derived from peak and inter-peak traffic flows using an equation that it not justified and which cannot be verified independently and is not the standardised method set out in PAG (unit 16.2 ‘expansion factors for short period counts’). • Traffic count figures from KCC show 14,870 vehicles on R445 12-hour. Use of PAG expansion factors (unit 16.2) results AADT of 19,387. • Insufficient information on model to allow reader to follow and check each step. The agent has conducted a simple local traffic reassignment exercise to demonstrate that without traffic growth traffic on R445 would increase from 14,870 to 24,618 a 65% increase. Expanded to AADT the same proportional increase would result. Table 6.3 predicts increase from 17,550 to 21,800 or only 24% [2015 do min to do something scenarios], some 40% lower than results from the simple reassignment exercise. • Para.2.4.10, table 6.3 – traffic flow at link 4 and link 7 should be the same for the opening year as the flow can be expect to continue as far as the relocated Newhall. This is generally the forecast scenario.
n Bord Pleanála Page 7 of 7 • Link 4 increase by 14,050 AADT. Appendix B fig.2 shows 5068 12-hr diverted due to new interchange in 2012 with no growth factor. Allowing for PAG expansion factor an AADT of 6,600 arises and therefore practically half of the forecast increase in M7 traffic can be attributed to simple reassignment of traffic. • NRA AADT for link 4 is 58,250 in 2015 (do something) which is significantly lower than 2013 NRA recorded AADT of 61,798 for this location. Suggests that below average base flows evident in February 2012 carried through to forecasts. Lower forecasts than would be expected given that the EIS suggests that M7 will become more attractive to motorists using alternative routes. • The high growth rate forecasts (appended to submission) for link 7 (without scheme) and link 4 (with scheme) for 2015 are less than the current traffic flow on the M7 for this location which confirms that the EIS significantly underestimates the traffic flows likely to prevail with / without the scheme. • Conclusions – forecast traffic to R445 & M7 adjacent client’s property is significantly understated and consequently the environmental impacts are also and the mitigation inadequate. No noise mitigation proposed for R445 where traffic to increase by 50% through reassignment not reflected in the TA. Should the Board grant permission appropriate mitigation measures to front and rear commensurate with the impact should be provided.
• Fanning French ‘Material Assets Report’ • Searson Associates - Noise Report - Noted • Coughlan White & Partners - Noted
OBJECTIONS RELATING PRIMARILY TO CPO ISSUES Mrs Catherine Morrin, Ladytown (subsequently withdrawn). Mr Edward Kinirons of Ladytown Stud, Naas (c/o Murphy Design & Building Solutions) (subsequently withdrawn). Gerald Kehoe, Osberstown (c/o Clarke & Company) (subsequently withdrawn). Dr John Kehoe, Osberstown – c/o Clarke & Company (subsequently withdrawn). Origin Enterprises Ltd (lands SE of Newhall) – c/o Reddy Architects (subsequently withdrawn).
7.0 POLICY
7.1 Spatial Planning and Development National Spatial Strategy 2002-2020 National Development Plan 2007-2013
n Bord Pleanála Page 8 of 7 Regional Planning Guidelines for the Greater Dublin Area 2010-2020 Kildare County Development Plan 2011-2017 Naas Town Development Plan 2011-2017 Newbridge Local Area Plan 2013
7.2 Transport & Other Planning Guidelines ‘Department of Transport – Statement of Strategy’ (2011-2014) (DTTaS, 2011) ‘Design Manual for Roads and Bridges ’ (NRA, various years) ‘EIA of National Road Scheme – A Practical Guide ’ (NRA, 2008) ‘EU Directive 2008/96/EC on Road Infrastructure Safety Management ’ (European Commission, 19/11/08). ‘Greater Dublin Area Draft Transport Strategy 2011-2030, 2030 Vision ’ (NTA, 2013) ‘Infrastructure and Capital Investment 2012-16: Medium Term Exchequer Framework ’ (DTTaS, 2012) ‘Integrated Implementation Plan for the Greater Dublin Area 2013-2018 ’ (NTA, 2013) ‘Guidelines on a Common Appraisal Framework for Transport Projects and Programmes ’ (Department of Transport, 2009) ‘M50 Demand Management Report ’ (NRA, April 2014) ‘National Transport Model, Model Validation Report ’ (NRA, August 2011) ‘New EU transport infrastructure policy – background’ (European Commission - MEMO/13/897, 17/10/2013), http://europa.eu/rapid/press-release_MEMO-13- 897_en.htm ‘Project Appraisal Guidelines’ (NRA, 2011) ‘Road Safety Strategy 2013-2020 ’ (RSA, 2013) ‘Smarter Travel: A New Transport Policy for Ireland, 2009-2020 ’ (DoT & DoEHGL 2009) ‘Spatial Planning and National Roads, Guidelines for Planning Authorities ’ (NRA, 2012 ‘The Core Network Corridors, Trans-European Transport Network 2013 ’ (European Commission) http://www.tentdays2013.eu/Doc/b1_2013_brochure_lowres.pdf ‘Transport Research and Information note: A Study of Lane Capacity in the Greater Dublin Area ’ (NRA, February 2012) ‘UK Transport Analysis Guidance: Guidance for Technical Project Managers ’ (January 2014)
n Bord Pleanála Page 9 of 7 7.3 Oral Hearing An oral hearing was held in respect of the proposed development application. I have not included a summary of the hearing but refer to issues and details raised at the hearing in my assessment, as necessary. A summary is provided in the Senior Inspectors report and a recording of the hearing is attached to the file.
n Bord Pleanála Page of 7 Part B
ASSESSMENT
Having inspected the site and reviewed the file documents, I consider that the issues raised by this appeal can be assessed under the following broad headings:
1.0 Introduction and brief of assessment 2.0 Policy 3.0 Need for project 4.0 Alternatives 5.0 Design details 6.0 Traffic and transport impacts 7.0 Traffic modelling 8.0 Conclusions and recommendations
1.0 Introduction
1.1 The purpose of this report is to inform the assessment of the Senior Planning Inspector, Mairead Kenny, on traffic and transport issues arising, including the adequacy of baseline information, the assessment of the likely impacts on traffic and transportation and the appropriateness and validity of traffic modelling; the need for the scheme having regard to policy provision, the strategic function of the road and road safety; the alternatives investigated and detailed design issues having regard to relevant roads standards. 1.2 A detailed description of the proposed development is set out under Part A section 2.0, above, but the development can generally be summarised as follows: • The upgrading of the existing M7 motorway from two lanes to three lanes between junction 11, Great Connell Interchange (junction with M9 to Waterford), up to and including junction 9, Maudlins Interchange (junction with R445 Dublin Road, Naas north), to connect with the existing three lane section of the N7 between Maudlins and the Johnstown Interchange (junction 8). • The closure of the existing junction 10 Newhall Interchange with the L2030 Rathangan Road, Naas southwest, and the provision of a replacement interchange with the existing R445 Newbridge Road, c.700m west.
n Bord Pleanála Page of 7 2.0 Policy
2.1.0 EU context 2.1.1 It is submitted that the proposed scheme has been designed as part of the fulfilment of the delivery of the strategic motorway improvement infrastructure identified in national, regional and local planning strategies and in government initiatives including Transport 21 and Smarter Travel. 2.1.2 The applicant places the M7 and the proposed scheme within a European context, explaining that the M7 forms part of the European priority access route no.13 2 (between Cork-Dublin-Belfast) within the Trans-European Transport Network (TEN-T) and informed the hearing that EU financing for transport infrastructure has been tripled to €26bn for 2014-2020. The Cork- Dublin-Belfast road route is an important route at Irish and EU levels, however European policy on the TEN-T network is more complex than the support of road building projects. ‘TEN-T is an essential tool for transport policy to meet the overall target to reduce by 60% emissions from transport by 2050… At its heart the TEN-T network is a multimodal transport network, facilitating a substantial the [sic] shift of passengers and freight from road to rail and other transport modes… To [qualify for EU money all TEN-T projects] must meet all the requirements, in terms of planning and sustainability set out under EU environmental legislation’ 3. Mr Simon Clear indicated that individual upgrading schemes are being introduced to target the most significant congestion, safety and environmental issues along the length of the road link, but the subject scheme is not included in the list of TEN-T projects the EU intends to part-fund up to 2020. The only TEN-T projects in Ireland concern the Cork-Dublin-Belfast rail (DART interconnector (studies and work) and the Core Network sea ports of Dublin and Cork (capacity studies))4. ’
2.2.0 National Spatial Strategy 2.2.1 The applicant submits that the proposed scheme supports the National Spatial Strategy 5, which indicated that ‘ building on the completion of the radial routes to and from Dublin, Ireland’s road network, public transport system and international access points, such as ports and airports, will remain key components around which development will need to be structured ’ (P.24, NSS). As the radial motorways between Dublin and the provincial cities have been completed, the objectives of the NSS, in respect of the development of the motorway network, can be seen to have been achieved. The NSS did,
2 I could not locate this reference however it would appear to refer to the road route only. 3 http://europa.eu/rapid/press-release_MEMO-13-897_en.htm (p.7) 4 ‘ The Core Network Corridors, Trans-European Transport Network 2013 ’ (European Commission) http://www.tentdays2013.eu/Doc/b1_2013_brochure_lowres.pdf 5 I would accept the applicant’s position that the NSS remains still official policy until the review of the strategy has been completed.
n Bord Pleanála Page of 7 raise concern that the form of development, ‘improved roads, relatively low road fuel prices, higher car ownership and availability and use of certain commuter train services have created an increasingly dispersed form of growth in the GDA and beyond’ (NSS p.22). The proposed scheme will increase the carrying capacity of the motorway network within the GDA and may increase the potential for dispersed growth within the GDA region and, in particular, accommodate most distant commuter traffic on the strategic road network. The highly peaked pattern of traffic on this route (see Traffic Model Report) is indicative of a high proportion of commuter traffic and it is only at peak times that traffic on the route is congested. The scheme is designed to accommodate peak hour traffic which is primarily car commuter generated rather than strategic intercity traffic and the Board may therefore consider it inconsistent with the NSS.
2.3.0 Infrastructure and Capital Investment Framework 2.3.1 It is submitted that the proposed scheme is consistent with the main priorities of the government’s ‘ Infrastructure and Capital Investment 2012-2016: Medium Term Exchequer Framework which include’6: • Ensuring adequate maintenance of the National Road network in order to protect the value of previous investments; • Targeting the improvement of specific road segments where there is clear economic justification The applicant makes the case that the M7 upgrade works are required to protect (through alleviation of congestion and improving connectivity within the vicinity of Naas) the value of the investment of previous development and the improvement of the national road network; and that the upgrade of the section of the M7 is a targeted improvement initiative. At the hearing the applicant 7 submitted that the cost benefit analysis demonstrated clear economic justification for the proposed scheme with a cost benefit ratio of 6.5 (the high ratio results from the low land costs as the land required is almost entirely within the applicant’s ownership). In addition the applicant highlighted that the scheme is a targeted improvement of a congested section of two-lane motorway which is a bottleneck between four lanes of motorway (M7 and M9) converging at Great Connell junction 11 and a three lane national road at Maudlins junction 9. 2.3.2 The Framework provides for ‘ targeting improvements of specific road segments ’ in its identification of the N11 and N17 road schemes as its priorities 8. No reference is made to any proposed upgrade of the M7 and,
6 P.6, Brief of Evidence, Simon Clear. 7 Mr Thorpe at c.11.31AM on day two of the hearing in response to questioning by An Taisce (Dr Brown). 8 Specified on page 14 of the framework within the context of the main priorities.
n Bord Pleanála Page 3 of 7 indeed, the opening paragraph on ‘The Road Network’ states ‘ The opening of the final phase of the M7 Dublin to Limerick route…brought the completion of the motorway network linking Dublin to each of the main regional centres and the Board with Northern Ireland ’ (p.13), which would seem draw a line under the investment demands for the main motorway routes. The bulk of investment in roads is to be directed to road maintenance and for the first time the government proposes investing more in new public transport than in new road projects (p.16). There is nothing in the framework document that suggests that this scheme was included as a consideration.
2.4.0 National Development Plan 2007-2013 2.4.1 The EIS refers to the ‘The National Development Plan 2006-2013 and implies, rather that explicitly states that the proposed M7 upgrade work is consistent therewith (it is submitted, the plan places particular focus on investment on road routes that link the Gateways 9). The Transport 21 investment programme forms the central part of the NDP, with €13bn investment in public transport provided to achieve the objective to encourage a switch from car use to public transport, particularly within the Dublin Region. The NDP recognised that ‘ It is not … sustainable to promote road and car transport as the major long-term mode of passenger transport, especially in urban area. The growth in population and in employment, in tandem with the environmental imperative to reduce carbon emissions, requires a major modal switch in passenger transport from car to public transport. This underlines the importance of the investment in transport for environmental sustainability. Whilst the environmental benefits from a major switch to public transport are clear, the major investment in roads will also improve traffic flows, reduce congestion and thus result in lower rates of traffic related emissions’ (p.131). 2.4.2 The NDP 2007 allowed for €17.6bn investment for the upgrading of and building of new national and non-national roads, which included the completion by 2010 of the major inter-urban routes linking Dublin with Belfast, Cork, Galway, Limerick and Waterford. This has been achieved. The further upgrade of the M7 was not identified for investment under the NDP or under Transport 21. The plan is no longer in date but it has not yet been superseded by a new national development plan.
2.5.0 Smarter Travel - 2.5.1. The Government’s medium term transport policy is set out under policy document ‘ Smarter Travel: A Sustainable Transport Future 2009-2020 ’. The key goals of government transport policy can be summarised as follows: • Improve quality of life and accessibility to transport for all;
9 p.2/7 of EIS
n Bord Pleanála Page of 7 • Improve economic competitiveness through maximised efficiency of the transport system and alleviated congestion and infrastructural bottlenecks; • Minimise environmental impact of transport by reducing localised air pollutants and greenhouse gas emissions; • Reduce overall travel demand and commuting distances travelled by private car; • Improve energy supply security through reduced dependency on fossil fuels. 2.5.2 Smarter Travel includes ambitious but necessary key targets against which to measure the success of the policy, however it makes clear that these targets are set in the context of specific population and economic growth projections 10 and that the targets will have to be adjusted as the actual growth figures emerge with time. Notwithstanding that we are halfway through the policy period and economic growth has been poorer than anticipated, there is no indication that the government has issued revised targets to date. The key targets/aims can be summarised as follows: 1. Work-related car commuting to reduce from 65% to 45%, equivalent to 500,000 – 600,000 commuters (200,000 of which were existing car drivers in 2009); 2. Car drivers will be accommodated on other modes – walking, cycling, public transport – or by e-working, to account for 55% of commuters; 3. Total car kilometres will not increase significantly from 2009 level to 2020; 4. Road freight sector to become more energy efficient to reduce GHG emissions; 5. Real reductions on current transport emissions will be achieved falling
possibly by between 4Mt to 8Mt CO 2 equivalents, with transport to make a meaningful contribution to Ireland’s commitments under EU effort-sharing for climate change. 2.5.3 The applicant submit that the proposed scheme aligns with key goal number two 11 in that it would maximise the efficiency of the transport system, alleviate congestion and remove an infrastructural bottleneck. The applicant does not give an indication as to how the scheme will contribute to key goal numbers one, two, three or five. It is further submitted that the policy document recognises that roads will continue to be the main source of transport for
10 The document refers to the ESRI estimated growth scenario of 5.1m population by 2020 and an average annual growth rate of 3%, which were revised down to 4.8m population for 2020 and an economic decline in 2008 and 2009 with a gradual return to growth rate of 3.5% by 2012 (p.27). 11 Note, the targets are listed in the order of listing in Smarter Travel but that document does not indicate that the list is set out in order of priority or that any goal is of greater or lesser priority than any other.
n Bord Pleanála Page of 7 people and goods and focuses on the need to improve the efficiency of motorised transport in order to limit the development of traffic jams and the associated negative consequences for fuel consumption and emissions and, therefore, investment in roads will remain an important element of sustainable travel to 2020 in the relieving of congestion problems. This may be taken to imply that the proposed scheme would contribute to the achievement of key goals numbers four and five. 2.5.4 The proposed scheme will increase CO2 emissions by 0.005% and 0.007% of Ireland’s Kyoto 12 target in 2015 and 2030, respectively. The total combined annual GHG emissions generated by this section of road will represent only 0.19% of the Kyoto limit compared to 0.186% without the development (see table 16.15 of the EIS) and the EIS considers the impact to be insignificant 13 . The emissions are based on the traffic levels produced in the applicant’s traffic model and does not take account of the potential for ‘ induced ’ traffic which may be engendered by significant improvements in road capacity (this is addressed in more detail later in this report) whereby the level of traffic expands to fill the available road capacity. If the applicant has underestimated the likely level of traffic then the potential growth in GHG emissions will be greater than predicted. In addition, it is my understanding that the emissions excludes that part of the trip taking place outside the LAM cordon and it is not clear that through trips on the M7 (without origin or destination within the LAM) area captured in the emissions calculation. 2.5.5 The applicant argues that reduced congestion will enable freer flow and, therefore, improved reliability and punctuality of bus transport, making it more attractive to commuters; and that, taken with the Osberstown interchange and Sallins bypass, it will make Sallins train station more accessible and free up space for pedestrians and cyclists in Sallins and Naas, which would aid the achievement of key goals numbers one, two and five. The applicant also submitted that the change in modal split in favour of non-car transport will be achieved in the centre of Dublin (inside the M50 ring) with increased residential densities and improved public transport and sustainable transport infrastructure improvements, implying that modal change will be less important in the hinterland areas. Whilst there is clear logic to this argument, the M7 runs adjacent to the one of the (if not the) most developed commuter and intercity railway lines in the state for which there are high 14 level and
12 62.8MT 13 EPA ‘Ireland’s GHG Emissions 2012’ – ‘ Between 1990 and 2012, Transport shows the greatest overall increase at 113%. However, transport emissions have decreased for five consecutive years and are now 24.8% below peak levels in 2007. This is primarily due to the economic downturn. The increase up to 2007 can be attributed to general economic prosperity, increasing population with a high reliance on private car travel as well as rapidly increasing road freight transport. The annual rate of decrease is slowing with 3.5% decrease in 2012 compared to an average annual reduction of 6.0% over the period 2008-2011. ’ 14 The EU TEN-T investment in the underground DART interconnector will facilitate DART to run on the Kildare line.
n Bord Pleanála Page 6 of 7 local 15 level objectives to further develop and improve the commuter rail service. It is obvious that commuter traffic generated along this TEN-T rail between the growing and consolidating urban settlements of Naas / Sallins and Newbridge and Dublin will also need to be skewed strongly in favour of public transport in order to compensate for development in much of the rest of the state which is dispersed, low-density and impractical to service by public transport. A strong case could be made that a higher modal split target (for alternative transport modes in commuting) than the national average target under Smarter Travel should apply to settlements such as Naas/Sallins/Newbridge given their location on the rail and road transport corridor to compensate for the car based, dispersed settlement pattern dominating much of the state. 2.5.6 None of the Local Authority’s main objectives regarding public transport infrastructure are being pursued as part of, or in tandem with the proposed scheme and the applicant indicated that there has been no progress at County or local level in respect of these policies 16 and there is no evidence that the County Council is pursuing the advancement of alternative modes at a local or regional level with any vigour, notwithstanding that some elements, such as the objective to provide QBCs for the conurbation, are largely within the local authority’s own control. I note, however, that a Part 8 Scheme for a ‘bus hub’ at Market Square, Naas, has been notified to the Board and is open for consultation until 19/09/14 and that the pursuit of such facilities is positive. 2.5.7 The applicant poured cold water on the importance of the rail service as an alternative to road-bus transport due to the fixed location of the stations and the distance of same from the origin and destination of many trips. Much was made of the Minister for Transport’s recent speech (made at the Transport Ireland Conference 2014) focus on the benefits of bus transport as an alternative to rail and the applicant submitted that the proposed scheme will facilitate better and more reliable bus transport. However the Minister’s speech was referring to existing and aspirational routes that were not economically viable rather than to the Kildare rail line, which forms part of the European TEN-T core network, the upgrading of which has been and continues to be part funded by the EU, including the DART interconnector which will join the Kildare and Belfast lines. The objectives for the development of rail services, including the connecting of the Kildare and
15 The KCDP and NTDP and the Sallins LAP contain objectives to develop a public transport interchange, a park and ride and provide bus priority network. 16 Whilst the County Council has submitted an application for EIA screening direction to the Board (ref.HD0032) in respect of a proposed road improvement scheme (the scheme includes the provision of altered pedestrian and cycle routes / infrastructure and altered junctions, has been advanced to the Board by the County Council) the planning authority were unable to provide the Board with any indication of when it is intended to implement the proposed scheme other than it would consider this issue when the Board had made a decision on that application. I would also have reservations about many of the details of the scheme in terms of compliance with the spirit and detail of the Design Manual for Urban Roads and Streets (2013).
n Bord Pleanála Page 7 of 7 Belfast lines through the Phoenix Park rail tunnel, thereby ensuring that commuters can access the commercial core of Dublin without the need for transferring to bus or tram at Heuston, is an objective and an identified area for investment under the NTA’s Integrated Investment Plan 2013-2018. The concurrent proposed Sallins bypass scheme actually provides for the upgrading of the Kildare line from two to four lines between Dublin and Kildare (at the requirement of Irish Rail) notwithstanding that the applicant was not able to identify where this upgrade (beyond Hazelhatch) is included in any policy document. The potential for the proposed road upgrade scheme to undermine the viability of the Kildare rail line and therefore undermine the significant public investment that has been and continues to be invested in that line, at national and EU level, is therefore a significant issue for consideration under this scheme and yet it was not considered under the EIS in terms of material assets or elsewhere in that document. 2.5.8 The proposed development, which comprises the continuation of a policy of building roads to accommodate car traffic growth (the predict and provide approach) will not contribute to the achievement of a reduction of 4MT to 8MT in CO2 emissions in accordance with EU agreements and having regard to projected population and economic growth envisaged in 2009 under Smarter Travel. That the EIS predicts growth in GHG emission (4% greater with the development in 2030) would appear to be contrary to ST. According to the Traffic Modelling Report (table 5-20) the proposed scheme will increase the total vehicular kilometres in the AM, Inter and PM peak hours in the do something scenarios for 2015 and 2030, but only by less than 1%, except in the 2030 PM peak where an increase of c.1.2% is predicted. This would appear quite insignificant, however the EIS does not provide details of total growth in AADT and, more importantly, the growth in vehicular kilometres only refers to trips within the Local Area Model and therefore does not provide any indication longer distance commuting passing through the LAM and does not take account of that part of the journey taking place outside the LAM cordon. The EIS therefore underrepresents the impact of the proposed development on total vehicular kilometres generated by traffic facilitated by the proposed infrastructure. In addition the model does not take account of the potential for induced traffic. The proposed scheme is therefore likely to result in much more significant growth in total vehicular kilometres than is presented in the TMR and it would therefore militate against the achievement of key target number three. 2.5.9 I consider a point raised by An Taisce (Dr Brown) at the hearing to be particularly pertinent to the Board’s consideration of the scheme in view of Smarter Travel - if the Government’s targets for modal split under Smarter Travel are achieved then there will not be the demand for the road scheme and undermines the applicant’s justification for the scheme.
n Bord Pleanála Page 8 of 7 2.6.0 DTTaS Statement of Strategy 2.6.1 It is the applicant’s position that the proposed M7 upgrade will support the key transport strategies of the Department (that are targeted to deliver on the commitments in the Programme for Government). The proposed scheme is not inconsistent with the strategy ‘ to implement improvements where funding is available ’, or with its commitment, ‘ to where possible, to deliver network improvements in support of competitiveness and economic recovery’, however the department’s ‘primary focus…[is] on maintaining the existing network ’. Priority for the proposed scheme cannot be inferred from the Department’s objectives set out for ‘ land transport ’, and the performance indicators for the ‘ land transport ’ objectives make no reference to the proposed M7 upgrade scheme. In contrast it makes provision for the proposed M11 Rathnew / Arklow scheme and the N7 Newlands Cross scheme on pages 12-16 of the strategy. 2.6.2 The proposed upgrade scheme is not included in the Department’s Strategy, but a case has been made by the applicant that the scheme is consistent with the Department’s commitment to deliver network improvements in support of competiveness and economic recovery. In this regard I note that the proposed Osberstown Interchange (and Sallins bypass), subject of concurrent approval application HA0046, is purported to be dependent on the capacity improvements provided by the upgrade of the M7. The said proposed interchange will facilitate direct access to Millennium Park and to the wider Naas Northwest Quadrant area, which can be expected to be a significant economic driver for the region in the coming decades (consistent with high level policy documents) and therefore an argument can be made that the proposed scheme is consistent with the statement of strategy.
2.7.0 Spatial Planning and National Roads, Guidelines for Planning Authorities (2012) 2.7.1 The guidance states ‘The primary purpose of the national road network is to provide strategic transport links between the main centres of population and employment…and to provide access to all regions ’ (p.2). The proposed upgrade works will assist this purpose, increasing the capacity between Dublin and the provincial cities, and improving access to the northern side of Newbridge via the proposed replacement interchange. The traffic that will be served by the proposed scheme falls within the broad definition of ‘ strategic traffic ’ under the guidelines. There is nothing to suggest that the proposed upgrade from two to three lanes is inconsistent with the guidance document. The guidance document adopts a 20 year design horizon for capacity design
n Bord Pleanála Page 9 of 7 and there is every indication that the proposed upgrade of this section of the M7 is compliant in this regard 17 . 2.7.2 The NRA’s policy on the provision of additional interchanges or enhancements is set out under section 2.7. The NRA accepts that in certain circumstances additional junctions or the enhancement of existing junctions may become necessary to service development needs of strategic or national importance, subject to compliance with nine criteria set out on pages 14 and 15 of the document 18 . The applicant does not explicitly address the criteria in a single section of the EIS or other document on file, but I am satisfied that the applicant has addressed the majority of the criteria throughout the body of the EIS and that the proposed upgrade would service the development needs of strategic or national importance. There are, however, three criteria for which compliance it unclear. 2.7.3 It is not clear that the applicant has demonstrated that all other options for serving development needs and, in particular, that the regional and local roads network and the use of public transport solutions have been examined and exploited to the fullest extent practical. It is apparent that the existing Newhall Interchange is operating in excess of capacity at peak and poses a danger to road safety by queuing of traffic back onto the mainline M7. I accept that there are very limited realistic options to address this through use of the local and regional road network and that this may not actually be desirable in the context as the proposed traffic to be served is strategic traffic. The applicant submits that the proposed scheme will facilitate the implementation of public transport solutions through the making available of road capacity for bus transport and, in this regard and there are letters of support from Bus Eireann and the NTA. 2.7.4 The guidance also requires it to be demonstrated ‘ that the proposed development will not give rise to an undesirable precedent for further traffic generating development at or in the vicinity of the proposed development ’, however it is my conclusion that this requirement does not relate to ‘ capacity enhancements ’ at junctions but to development proposals in the vicinity of junctions. The zoned lands within the vicinity of the Newhall junction and the wider region are identified in the EIS and the Traffic Modelling Report and the traffic impact of potential future development has been considered and was interrogated during the hearing. The proposed development is for capacity enhancements that will accommodate traffic generally and not for a specific traffic generating development and it cannot therefore set precedent for further traffic generating development.
17 The EIS indicates that the original Naas bypass was constructed in 1985, has exceeded its design life, that the Newbridge bypass was constructed in 1994 and has also reached the end of its design life and that neither section has subsequently been subject of a significant upgrade. 18 These are appended to this report.
n Bord Pleanála Page 3 of 7 2.7.5 No ‘ details of the…proposed demand management measures ’ are provided. It would appear evident that this requirement of the guidance document relates to development within the vicinity of junctions rather than to enhancement works to the national road. Demand management will therefore be relevant only to future development within the vicinity. 2.7.6 Given the obvious shortcomings in the design of the existing interchange, its inadequate capacity, the obvious congestion problems arising thereat and the unsatisfactory and circuitous connectivity provided by the interchange to the Newbridge Road R445 (the interchange is the de facto northern interchange for Newbridge as well as the southern interchange for Naas), I am satisfied that it meets the criteria for a replacement interchange under the guidelines. The proposed M7 Naas/Newbridge Bypass Upgrade and replacement Newhall Interchange Scheme is not inconsistent with the Spatial Planning and National Roads Guidelines 2012.
2.8.0 Greater Dublin Area Draft Transport Strategy 2030 Vision (NTA, 2011) 2.8.1 The EIS fails to have regard to critical elements of the NTA’s strategy for roads as set out under chapter 11 of the document. In particular, the strategy states: ‘in providing a sustainable transport system capable of meeting the needs of the region, it is essential that an appropriate balance is achieved between the allocation of road space to the motor car and the prioritisation of road space for pedestrians, cyclists, public transport, and freight movement. … Accordingly, further road development in the GDA in the period of the Strategy will be limited to cases that are justified on a basis other than simply providing road capacity ’ … The specific principles that will underpin decisions in relation to the development of roads schemes in the Greater Dublin Area are set down in “Measure ROA D 1”’ (ch.11 p.1). 2.8.2 The strategy also states that the NTA: will support road improvements schemes whose primary purpose is to address accident or safety issues, providing such schemes are designed to an appropriate standard and avoid inappropriately increasing capacity that may encourage longer distance car-based commuting ’.(ch.11 p.2). 2.8.3 The Board will be aware that the NTA submitted a letter of support for the proposed scheme. The applicant has made the case the scheme is warranted on grounds of traffic safety. I would accept that the existing Newhall Interchange poses a traffic hazard as its design and the arrangement of junctions in the immediate vicinity result in diverging traffic queuing on the
n Bord Pleanála Page 3 of 7 off-ramps backing up onto the hard shoulders of the M7 mainline at peak times. The replacement of the interchange would therefore appear justified. I am not satisfied that the applicant has demonstrated that the upgrade of the mainline is justified in terms of road safety and the applicant admitted at the hearing that this is secondary to the primary purpose of the scheme to reduce congestion. Rather the scheme presents real potential to encourage longer distance car-based commuting through the increased capacity on this section of road contrary to the NTA draft strategy. The NTA raised no concern in this regard and did not attend the hearing. 2.8.4 The strategy includes a number of proposed measures (1, 5 and 10 are most relevant) relating to road development, including measure 1 which requires, including, inter alia, that road development must satisfy that alternative solutions such as traffic or demand management cannot satisfactorily address the issues of concern; that the proposed road scheme will not give rise to a significant or unsustainable level of car trips; and that the scheme is consistent with the strategy and with Smarter Travel. It further states that ‘In delivering the strategy, it will be important to consider how policy and infrastructure measures should interact – e.g. how far demand management should be applied on a corridor before infrastructure proposals are brought forward; and what should be done following enhancements to ensure that new car trips (”generated traffic”) do not emerge to occupy road space freed up by transfer to other modes as a result of the scheme delivered’ (Ch.12, p.32). 2.8.5 It is also the NTA’s strategy, under measure Road 5 to identify the network (referring to Figure 11.1) of roads essential for strategic traffic outside of the M50 in its Strategic Management Plan and to seek the management of this network to, inter alia, protect person-trip capacity, operate it at its maximum efficiency having regard to the balance to be achieved across the various modes, provide reliable journey times and network resilience, provide priority for higher modes where needed and to expand the use of Intelligent Transport Systems to enhance operational efficiency. 19 The M7/N7 and the M9 are included in Figure 11.1 along with the main national radial routes emanating from Dublin. 2.8.6 Having regard to measures Road 1 and Road 5, it is my interpretation that the draft strategy does not automatically support the provision of additional capacity to this mainline section of the M7 for private car transport, but rather
19 Note, the predecessor the NTA’s draft strategy, the DTO’s Platform for Change (November 2001) also envisaged the implementation of demand management, with ‘strategic, but limited, improvements to the road network which will be managed in a way which does not encourage peak hour car commuting’ (p.8, Summary Report), traffic management policies to optimise road use and improvements across a range of public transport modes and sustainable modes (p.8, Summary Report). The strategy applied to the transport corridor to Naas as far as Kildare. It can therefore be seen that the policies now being pursued by the NTA and being pushed at national level through Smarter Travel are a continuation and sanctioning at the highest level of such policies
n Bord Pleanála Page 3 of 7 would pursue the management of existing road capacity, encourage the development of additional public transport services and rail services along the multimodal corridor of the M7 and Cork-Dublin railway line. I consider this to be consistent with higher level national and European policy and to be logical and reasonable. The applicant submits that the additional road capacity will enable public transport, in the form of bus transport, to be better accommodated and to become more reliable. However there are no proposals to restrict any additional road space to use for public transport only and no strategy to provide for improved bus services. Therefore it is almost certain that the additional capacity will merely encourage additional and longer distance commuting by private car to Dublin, contrary to the policy of the NTA.
2.9.0 NTA Integrated Implementation Plan 2013-2018 2.9.1 The applicant quotes a selection of the objectives of the NTA IIP, however the applicant fails to set out that those objectives are set out in the context of the negative impacts of road congestion and the positive effects of an integrated public transport system. Having regard to the context of those objectives, I would not agree with the applicant’s submission that the proposed upgrade of the M7 mainline, by reason of its potential to provide an improvement to congestion along the M7, at peak periods, is compatible with those objectives 2.9.2 In respect of national roads and motorways, the plan recognises that the strategic transport function should be maintained by limiting the extent of development that would give rise to the generation of local car-based traffic on the national road network. This objective relates to the control of development (in terms of location, nature and scale) and hence the growth in traffic accessing onto the network (predict and manage approach) rather than a policy in favour of continuing to expand the motorway network to accommodate growth in traffic (traditional predict and provide). 2.9.3 In this regard the plan informs that whilst the numbers in employment within the GDA dropped 6% between 2006-2011, with consequential drop in trips to work, the modal share of car for such trips has increased. Over the same period car ownership rates have continued to increase, with some counties approaching saturation levels (Kildare County rate is indicated the region of 520 per 1000 persons 20 ). 2.9.4 The main objective of the Integrated Implementation Plan ‘ is to encourage the continuation of modal shift to cycling, walking and public transport. ’ The applicant has not demonstrated that the proposed development would be consistent with the said objective and there is a real risk that the proposed development will result in the growth in commuter traffic on this route due to
20 Figure 5, p.13.
n Bord Pleanála Page 33 of 7 ‘induced traffic ’ (i.e. the notion that car traffic grows to fill the available capacity at peak), particularly from more distant locations as the existing bottleneck will facilitate free flowing car travel through this section. The traffic model used by the applicant cannot take account of induced traffic.
210.0 Regional Planning Guidelines for the GDA 2010 – 2020 2.10.1 The applicant submits that the proposed development is consistent with the RPGGDA 2010, however the RPGs emphasize, time and again, the need to invest in public transport, to link population growth directly to large-scale public transport investment and that integration of investment in transport, particularly public transport, with housing, business and leisure development is needed to ensure good return on that investment by the state (p.24). The possible solutions to address local congestion in the GDA do include new road infrastructure to relieve constrains, it also suggested the use of more sophisticated traffic management to maximise the use of existing road infrastructure, travel demand management and the development and promotion of public transport alternatives to road usage (p.59). Although the proposed upgrade scheme is not ruled out by the guidelines, at the time or writing the completion of the major inter urban motorway routes in 2010 (completed) was anticipated, not the further upgrade of the M7 to three lanes, and the guidelines focus on public transport as the main transport deficiency in the region. 2.10.2 The only regional scale road routes then under consideration by the Department of Transport were the Leinster Outer Orbital Route and the Eastern bypass. The guidelines highlighted concern that the LOOR may have the potential to undermine the core consolidating strategy of the guidelines (p.119, section 6.3.2). It is possible that the proposed upgrade scheme would have similar potential to undermine the core consolidating strategy by encouraging and facilitating more distant car commuting. The guidelines acknowledge (p.117) that public transport is the main investment priority in the GDA but that the road network will be critical in transport management, the movement of buses, people and goods. Whilst the applicant submits that the proposed development will free up congested road space to accommodate improved bus services, there is no evidence that bus services improvements are proposed by Bus Eireann or other operators to take advantage of the increased road capacity. There is no evidence of are no proposals to provide dedicated space to bus services either along the proposed scheme or between the scheme and bus corridors within Dublin.
2.11.0 County & Local Planning Policy 2.11.1 It is the aim of the Council ‘ to promote ease of movement within and access to County Kildare, by integrating sustainable land use planning with a high
n Bord Pleanála Page 3 of 7 quality, integrated transport system; to support improvements to the road, rail and public transport network, together with cycleway and pedestrian facilities ’ (p.94). In my opinion the plan misrepresents Smarter Travel, emphasizing the need to continue investment but implying that public transport, walking and cycling is secondary and failing to acknowledge the key goals and key targets / aims of Government policy. 2.11.2 The policies under the County Plan are favourable, if somewhat vague and/or long term in nature, toward alternative transport modes and the integration land use and transport planning. In contrast the policies for road development are far more specific. Even where the Council has included specific objectives in pursuit of sustainable travel, such as objective GT7, to prepare an integrated transportation strategy for the county based on sustainability and better use of resources in consultation with the NTA (based on MSTACK – movement sustainable transport and accessibility in County Kildare), or objective ST3 to implement quality bus networks, or objective ST4 to secure the improvement and further development of the public transport system, including railway stations in the county; the planning authority confirmed at the hearing that no progress has been made to date, nor is there any evidence that the planning authority has pursued these objectives with any vigour. 2.11.3 It is Council policy (NR 2) ‘ to upgrade and improve the national road network in accordance with national transport policy, in co-operation with the National Roads Authority, the Department of Transport and the NTA ’, however as noted above there is no national transport policy to upgrade this section of road. The County Plan includes as an objective the (RT 1) the development of a third lane in both directions on the M7/N7, including the improvement of interchanges as need arises; an objective (RT3) the identification of the location of a future improvement / upgrade for junction 10 Newhall; and an objective (RT4) to investigate the feasibility of an interchange to serve the eastern side of Newbridge. The proposed scheme would achieve these three objectives. No progress has been made in the development of a transport interchange for road, rail and public bus as proposed under long term objective LT3, or in the investigation of the provision of new railway stations or the upgrade/relocation of railway stations within the county.
2.12.0 Naas Town Development Plan 2011-2017 2.12.1 It is the aim of the County Council ‘ to promote ease of movement within and access to Naas, by integrating sustainable land use planning with a high quality, integrated transport system; to support improvements to the road, rail and public transport network together with cycleway and pedestrian facilities and to provide for new and improved transport facilities within Naas in a manner which is consistent with proper planning and sustainable development ’ (p.70).
n Bord Pleanála Page 3 of 7 2.12.2 The NTDP acknowledges that the high rate of car ownership in Naas may be indicative of commuting patterns and that a substantial number of residents commute to work outside the town. It provides for a better overview of Smarter Travel than the County Plan, but omits a crucial key goal, that is ‘ to reduce overall travel demand and commuting distances by private car .’ Given that Naas is a significant commuter base for Dublin (p.15) and that its high rate of car ownership in Naas is likely to be reflective of the commuting patterns of the settlement (p.70), it is critical that the Development Plan have due regard to the key goals of Government transport policy. Similar to the County Plan, the Town Plan has had no obvious regard to the key targets / aims under Smarter Travel and the national targets pertaining to Smarter Travel are not way translated to the County or, indeed, the local level. 2.12.3 The NTDP strategy for movement and transport (p.72) seeks to improve the safety, capacity and efficiency of an integrated transportation infrastructure in Naas in accordance with national, regional, county and local policy. The Council seeks to promote sustainable transport by influencing sustainable options by working closely with relevant organisations in improving public transport facilities and promoting opportunities for alternative transportation (p.73), this is reflected in Council’s policies for movement and transport and for traffic, public transport (TM1, TM2, TM3) and for sustainable modes (G08). GO8: To increase the level of access within Naas to a choice of transport modes and, in particular, to promote forms of development that reduce dependence on private car transport. 2.12.4 There are no objectives for upgrade the M7 from two to three lanes within its town boundary, however the proposed upgrade would not necessarily be inconsistent with the NTDP.
2.13.0 Policy conclusion : 2.13.1 The proposed upgrade of this section of motorway is not identified under any policy document at EU, National or regional level. The objectives of the National Development Plan 2000 pertaining to the development of the major inter urban motorway routes to a level of service C can be seen to have been achieved with the completion of the M7 Dublin to Limerick motorway in 2010, notwithstanding that the level of service on the section of M7 between Great Connell and Johnstown has subsequently declined as the completion of the network has brought significant traffic level to converge on this section of road arriving from the M7 (Limerick), M8 (Cork) and M9 (Waterford / Kilkenny). 2.13.2 The peakedness of traffic patterns on this stretch of road is indicative of a high level of commuting by private car. According to the NRA’s ‘ Spatial Planning and the National Road Network Guidelines ’ the purpose of the national and motorway network is to provide for strategic transport links between the main centres of population and employment. The NRA’s definition of strategic
n Bord Pleanála Page 36 of 7 traffic does not exclude commuter traffic. The Board should consider whether it is reasonable to permit an increase in capacity of this strategic route having regard to the high level of strategic traffic using the route in view of National and EU level transport policy. 2.13.3 Transport policy at EU and national level has evolved significantly over the last 20 years in response to traffic congestion, the deterioration in the quality of urban environments, and climate change and international obligations on the reduction of GHG emissions. It now places considerable focus on the growth of sustainable and alternative modes. EU transport policy has been translated into national transport policy under Smarter Travel. In my opinion, the proposed upgrade of the M7 mainline is contrary to and will militate against the achievement of the key targets of Smarter Travel for year 2020 which relate to modal split, total car kilometres and GHG emissions, directly, by providing for an increase in modal split for private car through provision of additional capacity on the network (and making it more attractive and more cost effective) and, indirectly, by reducing the numbers using alternative public transport modes, thereby making existing and proposed public transport (rail, in particular) less economically viable, with consequential risk of a deterioration in those services and a reinforced negative circle of decline. 2.13.4 In my professional opinion, the proposed upgrade of the M7 mainline is inconsistent with the NTA’s ‘GDA Draft Transport Strategy Vision 2030’ regarding the provision of additional road capacity, demand management, the interaction of infrastructure measures and impact on modal split and it is also contrary to the main objective of the NTA’s Integrated Implementation Plan 2012-2018 ‘ to encourage the continuation of modal shift to cycling, walking and public transport’ . I also consider the proposed scheme to be generally contrary to the provisions of the Regional Planning Guidelines for the GDA regarding transport infrastructure and services. However, it must be acknowledged that the NTA raised no objection to the proposed scheme in its submissions to the application and the Department of Transport Trade and Sport has submitted no observations. 2.13.5 The proposed development is wholly supported by unambiguous roads objectives under the County Development Plan. It is for the Board to decide whether the County Development Plan has had sufficient regard to government policy in its inclusion of the said objectives in the development plan.
3.0 Need for project
3.1.0 Significance 3.1.1 The section of road forms part of one of nine core road routes (the Trans European Road Network or TERN) forming part of the core section of the
n Bord Pleanála Page 37 of 7 Trans European Transport Network (TEN-T) which is proposed to be completed by 2030. It is also one of the busiest sections of the main major inter urban routes in the state.
3.2.0 Age of road 3.2.1 The Naas bypass was built in 1983 and has not subsequently been subject of any carriageway capacity alterations. The NRA road schemes have a 20 year design horizon and this section of road has reached its capacity horizon and its predicted design life and requires review. The Newbridge bypass was constructed in 1994 and can therefore also be assumed to be approaching time for review. The design of this section of road provided for the future upgrade of the route to three lanes through the inclusion of a wide central margin, which is an example of long term infrastructure planning.
3.3.0 Capacity 3.3.1 M7 Mainline - The main argument put forward for the scheme is on grounds of inadequate capacity to meet current and future demand at peak times. The completion of the M7 to Limerick, the M8 to Cork, the M9 to Kilkenny and Waterford have increased capacity on network and facilitated increased access to this section of the M7 between its junction with the M8 (and also from its junction with the M9 at Great Connell, junction 11) to the M50. As a consequence this section of the M7 is one of the busiest and most important sections of motorway in the state. The increase in capacity and traffic movement arising from the extended motorway system has exposed the restrictions in the capacity of this section and provides justification for the proposed scheme in the interests of service, safety, economy and environmental pollution. However, according the applicant’s submission to the hearing, the principle argument for the proposed motorway upgrade is on grounds of existing capacity constraint. 3.3.2 The capacity constraints are evident from congestion on this section of road. It is submitted (and was evident on inspecting the site) that congestion is particularly evident on the westbound carriageway during the evening traffic peak, with queues extending back to the Johnstown Interchange (junction 8) and traffic flow effected as far back as Rathcoole. This arises from the lane drop from three lanes to two at Maudlins, creating a bottleneck for westbound traffic. It is submitted that the congestion results in traffic diverting from the national road network to the regional / local network at Kill or Johnstown interchanges to access Naas. Congestion at Newhall Interchange, junction 10, results in traffic queuing to exit the westbound off slip extending, at times, back onto the M7 carriageway hard-shoulder, raising serious safety concerns. Congestion is also evident eastbound on the M7 in the AM peak at the M7/M9 merge, where four lanes converge to two. Traffic exiting the eastbound off- slip at Newhall can extend back onto the M7 carriageway hard-shoulder,
n Bord Pleanála Page 38 of 7 again raising serious safety concerns. Traffic speeds are reduced between Johnstown and Great Connell interchanges at peak times. 3.3.3 The issue of M7 road capacity is set out under section 3.4.1 of the EIS. The applicant submits that the Annual Average Daily Traffic (AADT) flow on this section of the M7, 60,374 AADT 2010 between Newhall and Maudlins 21 , exceeds the 55,000 AADT capacity for a dual two-lane motorway for Level of Service D (LOS D 22 ) under NRA guidance; that, AM and PM peak traffic exceeds the practical capacity of the motorway, resulting in reduced speed, increased journey times and an increased risk of accidents (further exacerbated by queuing at the Newhall Interchange exit ramps) which equates to a poor level of service (LOS E) that does not meet the minimum target of LOS C under the National Development Plan 2000-2006 23 . 3.3.4 For clarity, the concept of Level of Service rating comes from the US Highway Capacity Manual. The levels of service relevant to this assessment are defined, according to the NRA’s ‘Study of Lane Capacity’, as follows: ‘LOS C provides for flow speeds at or near the free-flow speeds of the motorway. Freedom to manoeuvre with the traffic stream is noticeably restricted, and lane changes require more care and vigilance on the part of the driver. Minor incidents may still be absorbed, but the local deterioration in service will be substantial. Queues may be expected to form behind any significant blockage. LOS D is the level at which speeds begin to decline slightly with increasing flows and density begins to increase somewhat more quickly. Freedom to manoeuvre within the traffic stream is more noticeably limited, and the driver experiences reduced physical and psychological comfort levels. Even minor incidents can be expected to create queuing, because the traffic stream has little space to absorb disruptions. At the highest density value, LOS E describes operation at capacity. Operations of this level are volatile, because there are virtually no useable gaps in the traffic stream. Vehicles are closely spaced leaving little room to manoeuvre within the traffic stream, at speeds that still exceed 80kph. Any disruption to the traffic stream, such as vehicles entering from a ramp or a vehicle changing lanes, can establish a disruption wave that propagates throughout the upstream traffic flow. At capacity, the traffic stream has no ability to dissipate even the most minor disruption, and any incident can be expected to
21 58,172 between Great Connell and Newhall. Figures from p.3/6 of EIS. The applicant estimates a figure of 59,591 AADT from the traffic surveys in April 2012 and this figure is included in the EIS for Osberstown/Sallins Scheme HA0046 on table 5.1 p.5-5. 22 NRA level of service scale A-F with A being best and F worst. 23 Note, this target did not carry forward into the NDP 2007.
n Bord Pleanála Page 39 of 7 produce a serious breakdown with extensive queuing. Manoeuvrability within the traffic stream is extremely limited, and the level of physical and psychological comfort afforded the driver is poor’ LOS F describes breakdown in vehicular flow. Such conditions generally exist within queues forming behind breakdown points.’ 24 3.3.5 Based on NRA permanent traffic count data the applicant demonstrates that the traffic profile on this section of road is very peaky. Traffic surveys conducted in April 2012 found the motorway to carrying 4,012PCU/hr 25 in the westbound direction at PM peak (between Newhall and Great Connell Interchanges) and 3,658PCU/hr in the eastbound direction at AM peak (between Newhall and Maudlins). This is excess of the practical capacity of the motorway, which is estimated by the NRA to be between 3,400- 3,600PCU/hr 26 (two-lanes), where practical capacity is that point at which flow breakdown can start to occur (without traffic management). 3.3.6 It is not possible for me to confirm the applicant’s survey figures. These would appear to be based on the ‘origin-destination’ surveys conducted between April 17 th and 19 th in 2012 as no other surveys are referred to for April 2012 under section 2.3 ‘Data Collection’ in the applicant’s Traffic Model Report (received 16/05/14). Based on NRA permanent traffic-counter data for the same section of road, the motorway was operating at 3,691PCU/hr 27 westbound in the PM peak (compared to 4,012PCU/hr) and 3,367PCU/hr 28 eastbound in the AM peak (3,658PCU/hr) in 2010 (the nearest available comparable NRA data). The NRA’s data contrasts significantly with the applicant’s survey data. Whilst the NRA data would confirm that the M7 westbound carriageway was, on average, operating in excess of capacity in the PM peak in 2010, between Newhall and Great Connell Junctions, it would suggest that the eastbound carriageway was operating below capacity between Newhall and Maudlins Junctions. The NRA data also reports that the M7 southbound (westbound) carriageway carried, on average, 3123PCU 29 in the PM peak between Maudlins and Newhall Junctions in 2010, which is well below capacity and contrasts significantly with the applicant’s figures 30 .
24 P.24 ‘A Study of Lane Capacity in the Greater Dublin Area,’ (NRA, 2014) 25 PCU or passenger car units where larger vehicles are converted to passenger car equivalents by use of a multiplying factor. Car = 1PCU; bus = 2PCU, etc. Use of veh/hr does not differentiate between vehicle types. 26 Or 1,700-1,800 per lane. P.26, ‘Transport Research & Information Note: A Study of Lane Capacity in the Greater Dublin Area’, (NRA, February, 2012). 27 NRA ATC no.M07-35 Lewistown. Total of 3418veh/hr, 4%HGV (136.72no.). PCU factor of 3 applied to HGV traffic, as per table 3.1 of EIS HA0045, results in 410PCU. Total of 3691PCU. 28 NRA ATC no.M07-36 Naas Bypass. Total of 3006veh/hr, 6%HGV (180.36no.). 180 X 3PCU factor = 540PCU. Total 3,367PCU. 29 NRA ATC M07-36 Naas Bypass. 2892 veh/hr in the PM peak (4% HGV 30 Note: This data relates to the M7 section between Maudlins and Newhall, whereas the applicant’s data relates to that section between Newhall and Maudlins.
n Bord Pleanála Page of 7 3.3.7 The NRA traffic count data would therefore seem to cast some doubt on the applicant’s figures. The NRA data can be considered more representative as it is based on much longer survey periods (345 days for Lewistown M07-35 and 186 for Naas Bypass M0-36), compared to the applicant’s three day O-D survey. It should be noted that the applicant applied a factor of 3PCU for HGV traffic and, for consistency of comparison, I did likewise in my calculations. This is a high factor and may overstate traffic demand 31 . I was unable to locate NRA (or UK equivalent) guidance on application of PCU factors for vehicle type at time of writing, however, for comparison, I note that the Transport for London’s ‘ Traffic Modelling Guidelines (Version 3.0) ’ applied a factor of only 2.3. 3.3.8 The applicant submitted a future capacity assessment (‘ Technical Note 10 ’) on 20/05/14. It predicts that eastbound flows in the AM peak will increase from 3,100veh/hr 32 in 2014 to 4000veh/hr in 2030 without the development (‘do-min’ scenario) but that this will increase to 4,200veh/hr in the ‘do- something’ scenario. The applicant’s data therefore confirms that the current AM peak eastbound traffic is not yet at capacity of 3,200veh/hr 33 , but is predicted to grow to exceed existing capacity by 800veh/hr by 2030 in the ‘do- min’ scenario. The westbound flow in the PM peak is predicted to increase from 3,600veh/hr in 2014 to 4000veh/hr in 2030 in the ‘do-min’ scenario, rising to 4,400veh/hr in the ‘do-something’ scenario. This would indicate that the current westbound PM traffic flow exceeds capacity by 400veh/hr and will exceed capacity by 800veh/hr by 2030. Whilst there is some uncertainty regarding the current peak hour traffic demand on this section of the M7, the future traffic flow demand at peak times on the motorway are predicted to be well in excess of the capacity of the existing two lane carriageway of 3,200veh/hr. The proposed scheme will increase the capacity of the motorway to 4,800veh/hr (5,200PCU/hr) in both directions, providing spare capacity in the ‘do something’ scenario of 600veh/hr eastbound in the AM peak and of 400veh/hr westbound in the PM peak in 2030. 3.3.9 Conclusion – The information submitted by the applicant indicates that the subject section of M7 motorway is currently operating at, or in excess of capacity at peak hour. The most recent available NRA traffic count data (2010) would indicate that the motorway is, on average, operating below capacity at peak hour, except between Newhall and Great Connell westbound in the PM peak. However, I would accept, based on the information available, that traffic growth on the mainline will result in traffic demand well in excess of
31 This will also depend on the percentage of HGV traffic it applies to. This is not stated. 32 Note, for clarity this is vehicles per hour, not PCU/hr. 33 The figures provided in the EIS, TMR and Technical Note 10 vary between PCU/hr and veh/hr. To calculate the estimated lane capacity for veh/hr for a single lane I divided the three-lane capacity figure of 4,800 (stated in table 4-1 of Technical Note 10) by 3 (1,600veh/hr) and multiplied by 2 to get a figure of 3,200veh/hr for the existing dual lane carriageway. The NRA’s study only provides an estimate of capacity in PCU/hr.
n Bord Pleanála Page of 7 the capacity for a two-lane motorway at peak hour by 2030 on the subject section of M7. 3.3.5 Great Connell & Maudlins - The large number of vehicles merging at Great Connell interchange (1000 from the M9 and 2000 on the M7) leads to flow breakdown and safety concern. As a short term measure a ghost island has been introduced to spread merge manoeuvres and improve safety but the addition of a third lane is necessary to provide the required additional capacity (lane gain) in the east bound direction to allow traffic from the M9 access the M7 safely and to reduce flow breakdown at this location. The disruption of the traffic stream from merging traffic or weaving between lanes can result in a disruption wave (shockwave) propagating through upstream traffic causing queuing, delays and increased likelihood of rear-end shunts. The capacity issues at Maudlins and Great Connell are directly related to the lack of capacity of the mainline, which implies that those issues would be resolved by increasing the capacity of the mainline. 3.3.6 Newhall Interchange - Congestion at the Newhall interchange results from the high traffic flows accessing the junction and the design of interchange in terms of the close proximity of the individual junctions (M7 business park roundabout, the M7 westbound off-ramp priority junction and the Bundle of Sticks roundabout) making up the interchange. The applicant submitted a copy of the junction analyses 34 prior to the hearing at the request of the Board (see Technical Note 10). The micro-simulation modelling indicated that the westbound off-ramp priority junction operated well in excess of capacity in 2012 in the PM peak (RFC of 1.18) and at capacity at the AM peak (right turn only) with significant queuing. As the Picady modelling does not take account of the queuing backing up from the Bundle of Sticks onto the overbridge, possibly preventing egress from the M7 off-ramp, it does not fully reflect the traffic situation. 3.3.7 The ‘do-nothing’ 2030 future scenario predicts that the junction will be operating at up to twice its capacity in the AM peak with queues extending up to 262 vehicles. Although such a scenario is hardly credible (traffic would divert its route, time of arrival or destination), it does highlight the existing capacity constraints evident at the interchange. The Arcady assessment of the Bundle of Sticks indicated that it is currently operating at over capacity, even when taken in isolation from traffic queues from the B&Q roundabout on the R445 which further limits traffic through put in the direction of Naas. Technical Note 10 indicates that the micro-simulation of the M7 Business Park roundabout found extensive queuing on the M7 eastbound off ramp and on the Rathangan Road in the AM peak, with traffic queues exacerbated in the
34 The Picady model was used to assess the westbound off-ramp priority junction. Arcady was used to assess the two roundabouts and was also used to inform the capacity assessment of the westbound off-ramp junction.
n Bord Pleanála Page of 7 2020 scenario. The report does not state that Newhall is operating, or will operate at / in excess of capacity in the current or future scenario and the modelling results are not included in the body of the report or in the appendices. 3.3.8 On inspecting the site at the AM peak, extensive queuing was evident on the eastbound off-ramp backing up to the mainline, although I can’t say for definite that it extended onto the mainline or hard shoulder. The EIS indicates that although the provision of the proposed Osberstown Interchange would address the current capacity issues at Newhall, the traffic modelling shows that the issue would arise again due to traffic growth and that the relocated interchange is required to significantly increase the junction capacity and to ensure that congestion on the local road network does not affect the motorway.
3.4.0 Road safety 3.4.1 The primary need for the scheme is to provide a road link that can provide the required capacity to cater for the anticipated future year flows and to improve safety. The RSA Road Safety Strategy 2013-2020 places emphasis on value for money road improvements that enhance the safety of the road network as a whole, including national roads in the context of EU Directive 2008/96. In terms of road safety, this section of road has a high proportion of accidents (38%) resulting from rear end shunts (from EIS). The applicant tabulates the accident statistics for this section of road between 2002-2011, however the details are not provided in the context of the accident rate on the overall motorway network and no strong argument is set out in terms of road safety in my opinion. 3.4.2 The details of the road safety assessment are included in the cost benefit analysis document submitted to the hearing on 26/05/14. It purports to show that the implementation of the proposed scheme would result in ‘ discounted accident benefits ’ of €15.725m (at 2009 prices) over the 30 year period to 2045. Mr Philip Shiels of Aecom presented, in his brief of evidence that the scheme would result in a reduction, over the 30 year period, of 11 fatalities and 23 serious injuries. I am not convinced by the applicant’s calculations, in particular the decision to split the scheme into two sections in the calculation of the accident rate per million vehicular kilometres, but the cost savings over the 30 year period appears minimal at c.1.6%. I would expect that the increased road capacity would facilitate greater speeds and that therefore whilst there might be a reduction in the overall accident rate due to decreased density of traffic, the severity of RTAs would be expected to increase as more traffic would be travelling at higher speeds. The applicants set out no reasoned argument to counter this but rather submitted that the main reason for the scheme was to address congestion and not on traffic safety grounds.
n Bord Pleanála Page 3 of 7 The road safety assessment did not comprise a predicted effectiveness assessment of the proposed scheme in terms of the achievement of a target accident rate to a particular stated statistical value of certainty, but merely assumed that the road accident rate for this section of road would revert to the average accident rate for the motorway system. I would therefore question the value of the applicant’s submission in this regard. 3.4.3 The EIS refers to the requirements of the EU Directive on Road Infrastructure Safety Management in terms of road safety in support of the proposed scheme. The said Directive requires that the motorway system be ranked in sections in terms of road accidents and that safety measures be implemented for those sections of motorway in order of priority – i.e. the worse performing sections are addressed first. The applicant was not aware whether such a ranking system had yet been implemented by the NRA. There is no evidence that the subject section of road is the least safe section of the motorway network and requires upgrading as a priority in terms of road safety having regard to the Directive. Furthermore, there is no evidence that a Road Safety Audit and a Road Safety Impact Assessment have been conducted for the proposed scheme. A RSA and a RSIA is required under SI 472 of 2011 (arising from EU Directive on Road Infrastructure Safety Management) to be conducted for all major road schemes on the TERN at the initial planning stage prior to approval of the scheme. In the absence of these assessments the applicant’s assumption that the road traffic accident rate would converge with the average rate for motorways is unsupported.
3.5.0 Guidelines on a Common Appraisal Framework for Transport Projects and Programmes (CAF) 3.5.1 The EIS addresses the objectives of the scheme under economy, safety, environment, accessibility and social inclusion, and integration as per the requirements of the Department of Transport’s ‘ Guidelines on a Common Appraisal Framework for Transport Projects and Proposals ’ (2009). • Economy – It is the objective to reduce journey times, accident costs and improve journey time reliability on a key national corridor. • Safety – The high proportion of rear-end shunts road traffic accidents are reflective of the congestion network. It is the objective to comply with EU Directive 2008/96/EC on Road Infrastructure Safety Management of TERN, to reduce the frequency of collisions and the severity of accidents on this section of the M7.
• Environment – It is the objective to reduce CO 2 and particulate emissions through a reduction in fuel consumption and to reduce noise emissions associated with turbulent traffic flow on the mainline and with queuing at Newhall.
n Bord Pleanála Page of 7 • Accessibility and social inclusion – To improve road-based public transport journey time and journey reliability, to better facilitate cyclists and pedestrians at Newhall interchange and to achieve national and local planning objectives. • Integration – To integrate with recent investments in the N7 road widening scheme, the current Newlands Cross Upgrade and the Major Inter Urban corridors (M7, M8 and M9), providing a consistent quality road between the M50 and Cork as part of the TEN-T North Sea – Mediterranean Corridor. 3.5.2 The applicant submits that the benefits of the proposed scheme in terms of economy, safety, environment, accessibility and social inclusion and integration will be significantly positive and long term.
3.5.0 Conclusions on need for project 3.6.1 I am satisfied that the applicant has demonstrated that there is need, on grounds of capacity constraints, peak traffic levels and resultant congestion and consequential road safety risk, for the proposed replacement Newhall Interchange. 3.6.2 I am not satisfied that the applicant has demonstrated that the proposed upgrade of the M7 mainline is a priority, or indeed necessary, on road safety grounds, particularly as the most significant safety concern would appear to be resolved with the replacement of the existing interchange. It can also be expected that the removal of traffic queues back onto the M7 mainline from the existing Newhall interchange will also improve traffic flow on the mainline as vehicles will not need to slow in caution. 3.6.3 The merging of the two motorways at Great Connell junction 11 does appear to present a capacity issue. The NRA has undertaken road improvement works at the junction, comprising the lengthening of the merge slips and the provision of ghost islands at the merge, but these have not resolved the issue. The traffic modelling suggests that this issue will become more pressing with future traffic growth on the M9. In response to questioning the applicant submitted that the further upgrading of the junction (or of the mainline in the vicinity of the junctions) was not a realistic option. I am not convinced that merging problems cannot further improved through redesign of the junction and the merge slips, however if the issue boils down to inadequate capacity of the M7 mainline to cater for the total quantity of peak traffic then no amount of rejigging off the junction will resolve the issue, in which case the Board may consider that the applicant has demonstrated need for the project on grounds of capacity. 3.6.4 The converging of three lanes (N7) to two lanes (M7) at Maudlins junction 9, coupled with the merging of traffic at the Maudlins on-ramp presents a
n Bord Pleanála Page of 7 capacity problem on the M7 mainline westbound at PM peak due to the sheer quantity of outbound vehicles. The continuation of three lanes along the mainline westbound would appear to be justified in terms of need. There is no issue eastbound through the junction as two lanes of the M7 merge into three lanes at the N7. However, the details submitted by the applicant would strongly indicate that the M7 mainline operates at / in excess of capacity at peak eastbound in the AM and westbound in the PM. 3.6.5 I consider that that the applicant has demonstrated that there is need for the project in terms of providing adequate capacity in the network to provide a reasonable level of service having regard to existing and predicted peak hour traffic.
4.0 Alternatives 4.1.0 The EIS clarifies that section 50 of the Roads Act requires that the EIS shall contain ‘ an outline of the main alternatives studied by the road authority concerned and an indication of the main reasons for its choice, taking into account the environmental effects ’ (p.5/1). The alternatives examined in the EIS and the main reasons for the discounting of same are set out below, first for the proposed mainline upgrade and then for the replacement interchange.
M7 upgrade - 4.2.0 Do nothing 4.2.1 The expected increase in traffic would lead to increased congestion and delays to the network, with traffic diverting from the motorway with knock on congestion in the towns of Naas and Newbridge in particular. I am highly sceptical that any significant traffic diversion from the M7 through the towns on Naas and Newbridge would occur unless the M7 reached virtual standstill due to congestion given that traffic through the towns would be impeded by traffic lights, speed limits and growing priority to sustainable modes of transport. With the growth in congestion on the network it is likely that trips will also divert to alternative and sustainable modes, that trips will divert in terms of time of travel - there is evidence that this is occurring already, with extended peaks (0700-0900) in the AM and PM (1600-1900) or that trips will not take place at all. Once the network has reached practical capacity (such as at peak times) it will not be possible for traffic to increase further, although the AADT may continue to increase if traffic grows outside of the periods where practical capacity occurs. As the network will not be operating at practical capacity outside of the peak periods, additional capacity will not be required to accommodate growth of traffic outside of the peak periods. 4.2.2 I do not consider the EIS to have taken into account the full extent of the environmental effects of the ‘do nothing’ scenario, including possible positive effects. The impacts of this scenario in terms of GHG emissions, impact on
n Bord Pleanála Page 6 of 7 amenities and material assets (viability of public transport modes and associated infrastructure) is far from black and white. 4.2.3 The PAG (unit 4.0) advises that the ‘do minimum’ alternative include those transportation facilities and services that are either committed or planned within the appraisal period, but that it otherwise assumes no other investment in the transport network (other than regular maintenance) during the appraisal period beyond that being considered as par to the scheme under the appraisal. Investment is proposed on the railway network under the TEN-T, comprising the DART underground interconnector between the Dublin-Cork and Dublin-Belfast lines, which will facilitate the extension of DART services to the Kildare line (to Hazelhatch). The implications, in terms of the capacity and quality of commuter rail services are not explored in the EIS in the ‘Do minimum’ scenario and this may be considered contrary to the PAG. The use of a ‘regional travel demand forecasting model’, as advised by the PAG 35 may throw further light on the transport implications of rail infrastructure investment in the different scenarios for the future years.
4.3.0 Hard shoulder running 4.3.1 It is submitted that hard-shoulder running would require the strengthening of the hard-shoulder and the provision of a temporary additional lane (for Newbridge section of M7 only) and the provision, long term, of additional electronic equipment, monitoring and communication, the cost of which would be extremely expensive compared to the construction of a permanent third lane in this context. From the UK experience the applicant estimates the costs at €5.8m to €7m per kilometre (this works out as €79m to €95m over the 13.6km) which results in the approach generally only being considered where space is restricted and land at a premium. It is also suggested that the long term safety of hard shoulder running is also in question, specifically regarding the absence of a hard shoulder to accommodate access for emergency vehicles in the event of an accident. At the hearing the applicant clarified that it was the on-going costs of operating and managing a hard shoulder running operating system (including monitoring and incident response unit) that is the issue. 4.3.2 The EIS examines hard shoulder running as an isolated option separate from an overall demand management approach when in reality it would form part of an overall integrated approach with a suite of traffic control measures including variable speed limits 36 , and ramp metering 37 . I note that it is a
35 Unit 4.0, para.2.4. 36 This refers to variable speed limits that allow speed limits to be dynamically (i.e. they change in real time as necessary) set to suit traffic conditions, so that flow is maintained, avoiding stop-start conditions that arise from driver behaviour when congestion limits speeds below the road’s usual limit; 37 Ramp Metering refers to the control of access onto a dual carriageway or motorway corridor, through the provision of traffic lights on the entry slip road which respond to the traffic conditions on the corridor.
n Bord Pleanála Page 7 of 7 proposed measure (TM1) under the ‘Greater Dublin Area Draft Transport Strategy 2011-2030 ’ (chapter 11, p.13-14) to evaluate the feasibility and benefit of implementing such measures within the GDA. The applicant refers to only one scheme in the UK, that of the M42 38 . There are now a range of schemes in the UK and in other countries to which the applicant may have referred and compared in terms of costs, challenges and benefits in order to provide a more informed basis for the decision. The applicant does not reference from where the figures for cost of implementation of hard shoulder running are taken, what these costs include and whether all these costs would apply in this instance. 4.3.3 The major failing of the applicant’s assessment regarding hard shoulder running is that it does not at all take into account the environmental effects (positive or negative) of the implementation of that option as it is required to do under section 50 of the Roads Act, but rather the assessment is based only on the financial cost of implementation and unsupported (and unquantified) suggestions of adverse impact on road safety. The applicant does not refer to what approaches are taken to improve road safety within such schemes, or the positive impacts on road safety that may well arise from the implementation of an integrated suite of traffic management measures within such schemes. 4.3.4 It can reasonably be assumed that the use of hard shoulder running, particularly in association with the aforementioned other traffic management measures, would not, unlike the provision of an additional lane, result in ‘generated traffic’ (trips diverted in time, route or destination) and / or ‘induced traffic ’ (shift in travel modes to, new trips and longer trips on the M7)39 , or that the level of same would be much lower. The dis-benefits associated with an increase in traffic would be less. As hard shoulder running necessarily forms part of a managed motorway or active traffic management scheme which includes use of variable speed limits, the existing adverse impacts in terms of GHG emissions and air pollution, in particular, would be mitigated by an overall scheme for hard shoulder running that would include. The benefits would include a reduced impact on downstream traffic movement and potential for congestion on the N7 and on the M50 as increased peak hour flows would not feed onto the network due to the restricting impact of the ‘bottleneck ’ on this section of the M7. This would increase the likelihood of space being retained for on road public transport (the bus fleet), making the use of same more desirable. As a consequence the retention of the existing capacity restriction on the M7 at this location may actually have a positive impact on GHG emissions on the wider network.
38 The M42 system is termed Active Traffic Management. 39 ‘Generated Traffic and Induced Traffic, Implications for Transport Planning’ (Todd Litman of the Victoria Transport Institute, April 2014), at http://www.vtpi.org/gentraf.pdf
n Bord Pleanála Page 8 of 7 4.4.0 Demand management 4.4.1 The EIS accepts that the implementation of demand management measures, which influence travel behaviour through restrictions on private travel and car ownership and the provision of alternative travel modes result in a more efficient transport system, improved environmental conditions and improvement in road safety as well as revenue generation. It lists a wide range of traffic demand measures (physical measures such as traffic calming, road space reduction, parking control, etc.) and fiscal measures (such as parking charges, road user charging, public transport subsidies, etc. 40 ). The EIS correctly points out that to be effective a bundle of demand management measures should be implemented to develop appropriate schemes that satisfy local objectives, solve local transport problems and which are politically and publicly feasible. However the EIS examines the implementation of only a single measure, a fiscal measure comprising road tolling. 4.4.2 The applicant discounts any consideration of the demand management option on the basis that there is no viable alternative route for M7 traffic if the route were to be tolled. I do not accept the applicant’s reason for not considering demand management measures as an alternative. The implementation of demand management measures would in no way oblige or imply that this section of the M7 (or any road) be tolled as road charging / tolling is merely one option out of a range of physical and fiscal measures. The retention of the existing M7/N7 at two lanes is effectively a demand management measure, imposing an effective cap on the quantity of traffic that can pass through at times when practical capacity occurs (peak traffic times), whereas the provision of a third lane would constitute demand accommodation (predict and provide approach 41 ). 4.4.3 The applicant submits that where demand management is implemented the existence of an alternative route would be prudent. Whilst the demand measure the applicant is referring to is specifically tolling, it is unclear whether the applicant is suggesting that a viable alternative route should be available in all cases where demand management measures are proposed. Clearly the provision of a viable alternative route would not be ‘demand management’ on the road network as it would only serve to divert traffic onto alternative road routes. The only instances in which I would expect transport planners to divert road trips between routes through demand management would be to in order to ensure that only local trips traverse local access roads and to prevent rat-running. This clearly would not apply here, except where the local authority felt it necessary to reduce the attractiveness of the western
40 Note that some fiscal measures can only be, and have been, implemented at a national level, such as fuel taxes, vehicles excise duty and public transport subsidies. 41 Predict and provide – where road infrastructure capacity is provided to accommodate future growth scenario.
n Bord Pleanála Page 9 of 7 distributor road in Naas, or the Osberstown Road to the north, as a rat-run in the event of congestion on the M7. 4.4.4 Sections 4.7 to 4.10 of the PAG address the assessment of traffic management alternatives. It includes local road safety improvements; fiscal or traffic control measures to manage traffic demand; public transport priority, capacity and / or public transport services; corridor / area-wide improvements to pedestrian / cycling provision; ITS to improve reliability, safety and operating capacity within its definition of traffic management alternatives. The PAG indicates that the traffic management alternative deserves significant attention in its definition and refinement with identification of an optimum mix of actions and that this may necessitate a number of iterations to determine the appropriate ‘best fit’ traffic management solutions using the existing infrastructure and that it may be appropriate to consider different traffic management combination solutions as alternatives. Similarly, the ‘Common Appraisal Framework’ also requires that the analysis of proposed projects gives explicit consideration to traffic management approach. 4.4.5 The NRA’s own research 42 has indicated that demand management (predict and manage) approach had the potential to reduce traffic levels on the M50 by 20%.43 In comparison to the M50 the M7/N7 corridor runs between discrete settlements (Dublin, Naas/Sallins, Newbridge and beyond) and can easily facilitate bus transport between to/from Dublin and Naas / Sallins / Newbridge, in addition to a high (and increasing) capacity main rail line which provide feasible alternatives to travel by private car and therefore a comparable (or superior) reduction in traffic levels would not appear to be an unrealistic prospect using a co-ordinated approach. In its submission to HA0018 (previously proposed Osberstown Interchange) in 2009, the NRA noted and did not contradict the local authority’s position that the successful implementation of the Council’s plan to ‘ improve regional transport linkages to a new and expanded Naas and Sallins Train Station 44 , provide an extensive park and ride facility to serve the Naas and Sallins Train Station and to create regional / local bus / rail interchange facilities… would… facilitate a transfer of traffic off the M7 to rail ’. 4.4.6 The main alternative examined by the applicant was not demand management measure per se but a road tolling option45 . In my opinion, the
42 ‘M50 Demand Management Report’ (NRA, April 2014). 43 It indicates that a lane flow of 1,500veh/r will tend to operate at a level of service of LOS D, but that under turbulent conditions flow can quickly deteriorate to LOS F at the same traffic flow. It further indicates that a robust traffic control strategy can increase the traffic flow associated with the upper limit of LOS E from 1,500veh/hr to 2,100veh/hr. 44 There is no specific objective to relocate Sallins train station under the current Sallins LAP 2009, although the Kildare County Development Plan 2011 includes an objective to this effect for the relocation / upgrade of rail stations in general. 45 The NRA M50 study looked at five types of demand management measures: Fiscal measures (specifically variable distance tolling); Intelligent Transport Systems / Traffic Control (specifically variable speed limits and
n Bord Pleanála Page of 7 reason for not pursuing this option (lack of an alternative route) did not take account of (or attempt to quantify) the environmental effects (positive or negative) as is required under section 50 of the Roads Act, although the reason for not tolling the road is not unreasonable and the said alternative may be considered not to be a feasible option at this point in time. The broader range of demand management measures, which could include variable speed limits and ramp meters, in addition to shoulder running may or should have been examined as an alternative in the context of their environmental impacts. 4.4.7 The Board will be aware that it attached a condition to its approval for the M50 upgrade (ER0034) in 2005 that required the NRA to publish a scheme of specific demand management measures for the M50 motorway corridor. The NRA published its scheme in 2014 with the caveat that any decision to implement the demand management measures is a decision of Government. It can be expected that any decision to implement demand management measures on the M7/N7 would also be a decision of Government and would necessarily have to be implemented in an integrated and coherent manner across the network.
4.5.0 Construction of an additional lane 4.5.1 The benefits of this alternative over the others is that it will accommodate the predicted increase in traffic over the coming years without any additional land take. The future provision of the additional lane was envisaged and provided for in the original scheme in the provision of a wide central median and therefore can be seen as an example of long term transport infrastructure planning. As with the hard shoulder running alternative, the environmental impacts are indicated as not significant, with minor improvement in terms of the attenuation and treatment of surface water runoff. This does not take account of potential for ‘induced’ traffic or the implications for development potential and overall growth in traffic demand within the region and further afield through commuting. 4.5.2 I would acknowledge the suggestion put forward by Mr Sweetman to the hearing that, due to the higher peak hour traffic on the westbound carriageway where the 3 lane N7 feeds into the 2 lane M7 (at Maudlins Interchange) there was an economic case for a third lane in the westbound direction, but not in the eastbound direction where the 2 lanes of the M7 open out to three lanes at the N7. This was not an alternative examined by the applicant and was not pursued at the hearing beyond Mr Sweetman’s submission. I do not know whether it is a feasible or appropriate to apply
incident detection); Information (roadside and internet based real time information); Smarter Travel (area based travel planning aligned with Local Authority integrated land use transport planning); Network Control (use of single traffic control centre to manage all operational functions of the national roads network).
n Bord Pleanála Page of 7 different design standards on different carriageways to the same stretch of motorway, but anecdotally it would not appear to be common. 4.5.3 Other design approaches to increasing capacity, particularly at the interchanges, such as the provision of a third lane along limited stretches of the motorway (e.g., additional lengths to merge / diverge slips at the M7/M9 junction and / or other interchanges) were also not examined as alternatives in the EIS. In response to questioning on this issue Mr Thorpe indicated that the resulting motorway would not be a coherent system and would be confusing for motorists. Another option that would appear to be feasible, the widening of the M7 to three lanes up to the proposed Osberstown Interchange (this may address the capacity concerns on the M7 arising from the proposed interchange under HA0046), was not examined in the EIS and was not questioned at the hearing. However, it would be unreasonable to expect the applicant to examine each of the various combinations that could be implemented in respect of the road widening.
4.6.0 Conclusion on alternatives to mainline upgrade 4.6.1 In my opinion the EIS does not comply with the requirements of section 50 of the Roads Act as it did not adequately take into account the environmental effects of the main alternatives studied in reaching a decision on its choice between the alternatives and, furthermore, it did not examine a realistic comprehensive alternative to the scheme selected in terms of hard shoulder running and demand management but rather presented two oversimplified alternatives in the form of simple hard shoulder running and road tolling. The failure to openly consider the advantages and disadvantages of other realistic alternatives to this scheme, including in view of the probable environmental impacts of the different alternatives is, in my view, a serious failing of the EIS that undermines the Board’s making of a decision on the proposed scheme in a fully informed manner. 4.6.2 The NRA’s own EIA guidelines ‘ EIA of National Road Scheme – A Practical Guide ’ (2008) in respect of the examination of alternatives emphasize that ‘ the avoidance of significant environmental impacts through the consideration of alternatives is a fundamental principle of EIA ’ (p.23). The guidance document is focussed on new road schemes where the issue of alternative route selection and alternative designs are at issue and the document offers no guidance outside of that scope. Whilst the alternatives presented by the applicant had merit and some basis in reality, the approach taken by the applicant to the implementation of same was not realistic and therefore the environmental impacts and feasibility of same was not examined realistically. 4.6.3 The CAF requires that, in appraising strategies (e.g. to combat urban congestion), it is necessary to include some options that broadly achieve the same impact on congestion. This is similarly a requirement under unit 4.0 of
n Bord Pleanála Page of 7 the PAG (section 3 ‘Requirements of Scheme Alternatives’). It is debatable whether the applicant has done that in the options presented in the EIS. An Taisce criticised the EIS for not including public transport improvements at an alternative to the scheme. The CAF does not exclude the NRA having to consider options that fall outside its remit, but it suggest that where overall transport planning has resulted in a programme of projects for each of the major modes, appraisal of the project within its modal programme (the National Roads Programme) may occur without reference to other modal options (p.8) 46 . As the proposed project does not form part of any official programme of projects 47 it would seem to follow that the scheme appraisal should have considered modal options outside its remit. This was not done and, notwithstanding the difficulties facing the applicant in addressing this alternative in a realistic manner, within the context of Smarter Travel (as set out above) and my assessment of traffic modelling, below, the Board may consider this to be a significant omission and failing of the EIS regarding the proposed M7 mainline upgrade. 4.6.4 In response to concerns about this issue raised at the hearing by An Taisce, the applicant (Mr McGrath) submitted that the EIS only had to consider the environmental effects of the main alternatives studied and that the inclusion of an alternative in the EIS did not mean it was a main alternative. I would differ in opinion to the applicant in this regard.
4.7.0 Junction 10 Newhall Alternatives 4.7.1 The junction has been found to be operating above capacity due to its, perhaps, somewhat unorthodox design, which incorporates a number of different junctions and the high traffic flows which lead to blocking back from one junction to another. A ‘do nothing’ alternative was not examined presumably because it was deemed not viable in the context, however a broad range of alternatives were examined in the EIS and the main reasons for the discounting of same are set out below • Option 1 - Signalising of the existing junction with traffic signals optimised to provide for the most efficient movement of traffic through the junction. • Option 2 - Increased stacking on the M7 off-slips / diverge lanes which would be re-demarcated to provide for two lanes, with the westbound approach on the M7 re-demarcated to provide additional length to the diverge lane in lieu of hard shoulder. • Option 3 - New off-slips to the R445, the existing off-slips would be removed and new off slips provided to the R445 either side of the existing
46 This is repeated under section 4.7 of the PAG Unit 4.0. 47 In contrast the rail line is subject of an official programme for upgrade under Transport 21 and under the TEN-T with the DART underground interconnector.
n Bord Pleanála Page 3 of 7 underbridge, but the existing off-slips / merge lanes onto the M7 would be retained. • Option 4 - New eastbound off-slip to R445 & new westbound off-slip to Western Distributor Road – The existing west and eastbound off-slips would be removed. The eastbound off slip would be relocated to the R445 and the westbound off-slip relocated to the WDR via new land take to access an existing roundabout. • Options 5 - New off-slips to and new merge slip eastbound from the R445, with existing westbound merge slip retained. • Option 5a - New off-slip and merge slip from / to the M7 eastbound only to the R445 – existing eastbound diverge removed. Existing westbound off- slip and merge slip retained. • Option 6 - Existing on-slips and diverge slips to Newhall Interchange removed and replaced by new off-slips and merge slips directly between the M7 and the R445. 4.7.2 The alternative selected was chosen on the basis that the first two options still resulted in traffic queuing back onto the M7. Options 3-5A inclusive were all discounted as there were significant safety concerns regarding the available sight distance of the existing eastbound merge slip (on-ramp) from Newhall which was retained in each of those scenarios and due to the fact that a lot of development has taken place adjacent that ramp. The construction of the new Newhall Interchange is purported to provide a significant improvement in capacity. 4.7.3 The applicant’s selection of the chosen alternative junction design has had no reference to the environmental effects of the different alternatives, contrary to the requirements of section 50 of the Roads Act. This is a critical issue in this case as the potential for what may be considered significant permanent adverse impacts on local receptors (namely the impact on the landholdings of the extended Coyle family adjacent the existing and proposed interchanges) varies quite appreciably between the scenarios. Options 3, 5 and 6 entailing significant land-take from that family’s landholding and the different alternatives result in different traffic flows routing around the said properties which are contained entirely between the M7, the interchange (inclusive of the L2030 and the Bundle of Sticks) and the R445. In addition, options 5 and 5A, written off due to issues with retention of the existing eastbound on-ramp / merge slip, would not actually appear to necessitate the retention of the said on-ramp as a new one was proposed from the R445, and the consideration of alternatives in the design of the proposed interchange was not exhaustive. For example, on deciding that the alternative chosen was to be a new interchange, there was no consideration of alternative design approaches to the new interchange, such as alternative design and layouts to the on-ramps
n Bord Pleanála Page of 7 and off-slips having regard to the environmental effects of same, particularly with regard to the impact on sensitive properties in the vicinity.
5.0 Design details 5.1 The proposed upgrade to the M7/N7 mainline provides an additional lane mostly contained within the existing grass margin. The resulting motorway cross section will be of 14.5m paved width, comprising 3.0m hard shoulder, three traffic lanes of 3.5m each, a median hardstrip of 1.0m to comply with NRA DMRB standard TD27 48 . TD27 gives details of the cross-sections and headroom clearances to be used for all-purpose roads and motorways (urban and rural), both on open roads and at structures and sets out fixed values for cross-section standards for (rural motorways, table 2) standard motorway (D2M), wide motorway (D2M) and wide motorway (D2M) with provision for extra lane. I have tabulated the relevant standards in table 1, below, for the information of the Board.
Table 1 – Rural Motorway cross section standard (extracted from table 2 of NRA DMRB TD27) in comparison to proposed cross section Mainline road Nearside Carriage- Implied Offside Central type hard way (fixed) lane width hard strip reserve shoulder standard 49 (fixed) (min) (fixed) Standard 2.50m 7.00m 3.50m 1.00m 2.60m 50 motorway (D2M) Wide 3.00m 7.50m 3.75m 1.00m 9.00m Motorway (D2M) Wide 3.00m 7.50m 3.75m 1.00m 16.00m Motorway (D2M) (with provision for extra lane Proposed 3.0m 10.50m 3.50m 1.0m Varies section between c.3.60m and c.10.60m (my estimate)
48 Adopted April 2014. The standards for hard shoulder, carriageway width, hard strip and central reserve have not altered from the standards of November 2011 or December 2007. 49 This is not stated under TD27, but may be assumed if each lane is to be equal in width. 50 The actual width has to be determined with reference to type of safety barrier (TD19 refers).
n Bord Pleanála Page of 7 5.2 Central reserve standards are minimum standards, with any reduction a deemed a departure from the standard. Hard shoulder, carriageway and hard strip dimensions are fixed values, with any increase or reduction of these elements deemed a departure from the standard. DMRB allows that in exceptional circumstances the NRA may agree to a departure from standards where the standard is not realistically achievable, the proposals for which must be submitted by the design organisation to the NRA for formal approval to be received before incorporation into a design layout.
5.3 Nowhere in the EIS or in the application does it state whether the proposed motorway is a standard motorway or a wide motorway. There is no indication on file that the proposed design includes a departure from TD27. In table 1, below, I have set the standards incorporated in the proposed scheme design in the context of the TD27 standards, with shading to highlight with which standards the proposed design would seem to (most) comply where relevant to my assessment. The standards for hard shoulder and carriageway widths are fixed standards and for central reserve width are minimum standards, with different standards applicable in each case between a standard motorway and a wide motorway. It can be seen that the proposed design accords with the fixed standard for a standard motorway (D2M) in terms of carriageway lane width. It exceeds the fixed standard for hard shoulder width applicable to a standard motorway (D2M) and meets that for a wide motorway. The EIS indicates that the existing hard shoulder is 3.0m in width.
5.4 The proposed cross-section shown in figure 4.15 of volume 3 of the EIS indicates a typical central reserve of 4.30m. The EIS (para.4.2.1, p.4/6) indicates that the existing central varies from 12-15m between J11 and J10 and is in the region of 8m between J10 and J9. The proposed scheme will create an additional 6.4m (3.2m per carriageway) hard surface. It follows that the proposed central reserve width (which includes the hard strip widths either site in accordance with the DMRB definition) will therefore be c.3.6m between J9 and J10, and range from c.7.6m to 10.6m between J10 and J11, and therefore would appear to exceed the minimum standard for standard motorway (D2M) along its whole length and to exceed the minimum standard for a wide motorway (D2M) in parts.
5.5 There is no explanation given for the application of an apparent mix of standards applied to the proposed scheme, or reference to any departure from the standards authorised by the NRA. The critical issue is the width of the hard shoulder which exceeds the fixed standard for a standard motorway (the carriageway width complies with the fixed standard for a standard motorway and the central reserve appears to exceed the minimum standard for a standard motorway). I note that the existing hard shoulder measures 3.0m, constructed prior to the introduction of TD27 in December 2007 and it
n Bord Pleanála Page 6 of 7 can be assumed that this is in compliance to the standards applicable at the time of construction. Without any explanation of the increased hard shoulder width, or proof of authorisation of departure from the standards from the NRA, it would appear that the increased hard shoulder width is non-compliant with the appropriate standard and unnecessarily increases the impact of the proposed scheme on the environment through increase in hard surface paving along the length of the proposed development. The Board may be mindful to rely on the design expertise of the applicant in this instance. 5.6 Interchange design – The proposed replacement Newhall Interchange is of dumb-bell design, incorporating free-flow segregated slip lanes to / from the M7 to / from R445 in the direction of Newbridge. No segregated slip lanes are provided to / from the M7 to / from R445 in the direction of Naas, although the detail of the westbound M7 off-slip is unclear. 5.7 The EIS does not state to which standard(s) the proposed replacement interchange has been designed to comply. NRA DMRB standards TD39/34 (The Design of Major Interchanges), TD22/06 (Layout of Grade Separated Junctions) and TD16/07 (Geometric Design of Roundabouts) made the UK’s Highway Agency’s DMRB standards of the same titles applicable to Ireland and these would appear to be the main relevant standards. TD39/34 recognises the dumb-bell design as one of the most common type of interchanges in the UK and it is evidently a common interchange design on Irish motorways. It would be reasonable for the Board to assume that the final interchange design will be compliant with DMRB standards. 5.8 The NTA’s ‘Draft GDA Cycle Network Plan ’ (August, 2013) identifies the R445 51 as part of the proposed K15 rural cycle route between Naas and Newbridge, which will continue on to Kildare town on the R413. This route will interface with the proposed (part existing) urban routes within Naas, the Na6 (Millennium Park – Monread Road) and the Na1 (Kill – Johnstown – Dublin Road – Main Street - Newbridge Road) and with the NB1 (R445 Naas Road – Main Street Newbridge – Standhouse Road) in Newbridge. The proposed design of the interchange takes no obvious account of the infrastructure required to accommodate cyclists. In its submission of 21/02/13, the NTA indicated that it had no objection to the proposed upgrade of the M7 but submitted that at detailed design stage appropriate facilities should be included at the proposed Newhall junction layout to facilitate safe cycle usage across the junction including roundabouts and connecting links and that it would welcome liaison with scheme designers. The NTA also submitted that at detailed design stage a review of adjacent or potential bus stop locations is required, together with an examination of likely necessary pedestrian links, and that appropriate provision for safe bus stopping facilities and safe
51 Incorrectly referred to as R405, but correctly identified on the accompanying maps.
n Bord Pleanála Page 7 of 7 pedestrian links and crossing points within the extents of the scheme are provided at detailed design stage. 5.9 Subsequently, on 14/05/13, a copy of correspondence between Kildare NRO and the NTA was received by the Board from the NTA. The letter included from Kildare NRO (30/04/14) confirmed that KCC and their designers will liaise with the NTA at detailed design stage to address, to the satisfaction of the Authority, all issues raised in their submission. The cover letter from the NTA indicated that the Authority was satisfied that the Local Authority would be able to address their concerns at detailed design stage. It is reasonable to accept that the design issues of concern at / within the vicinity of the proposed interchange can be satisfactorily resolved between the Local Authority and the NTA. The applicant suggested to the hearing that cycle (and pedestrian) traffic could be rerouted to the existing Newhall Interchange bridge, rather than over the proposed new interchange. The suggested route would increase the length of cycle trips between Newbridge and Naas and make them less direct and therefore provide a disincentive to cyclists using the NTA’s proposed cycle route. There is no evidence that the NTA would be agreeable to this approach and the permitting of the proposed scheme should not prejudice.
6.0 Traffic & transport impacts : 6.1 Chapter 6 of the EIS provides an analysis of the potential impact of traffic on the road network as proposed to be altered. It is based on the Traffic Modelling Report (TMR) and informed by the M7 Interchanges Capacity Assessment (Technical Note 1), submitted to the Board on 16/05/14, which I have reviewed in detail, including the appendices to same. As noted above, the M7/N7 is operating close to, or above, capacity at peak times, resulting in congestion, reduced speeds, breakdown in traffic flow and consequential safety concerns, with the subject mainline operating at a Level of Service E. The Newhall interchange suffers congestion at peak hour, with traffic queues extending back onto the M7 mainline posing significant safety concern. 6.2 The EIS concludes that proposed upgrade of the M7/N7 mainline will lead to a reduction in congestion on the M7 mainline and a reduction in travel times between the Johnstown interchange and the M7/M9 interchange at Great Connell at peak hour (average saving of 6 minutes per vehicle along the length of the scheme in 2030 between the ‘do minimum’ and ‘do something’ scenarios). Tables 5-10 and 5-12 of the Traffic Model Report indicate that total vehicular kilometres will be higher in the ‘do something’ scenario in the AM and PM peak in 2015 and in 2030 than they would be in the ‘do minimum’ scenario although this is in the order of 1% or less and therefore cannot be
n Bord Pleanála Page 8 of 7 regarded as significant and to conflict with a key target of Smarter Travel 52 . However the figures for total vehicular kilometres should be treated with caution as the LAM only takes account of the kilometres travelled within the cordon, only related to peak hours and not AADT and, in addition, appears to exclude through trips on the M7 that have neither origin nor destination within the LAM 53 . The actual increase in vehicular kilometres travelled due to the proposed scheme would therefore be greater than that indicated, possibly significantly so. 6.3 The proposed relocated Newhall interchange will reduce congestion and result in significant improvement in safety issues associated with traffic queuing on the off-ramps of the existing interchange. No adverse impacts on traffic flow are predicted. The predicted 5% increase in traffic flow at the Maudlins Interchange will be accommodated within the existing capacity of the interchange by the provision of the additional lane on the mainline. 6.4 The cumulative impact on traffic from the proposed Naas / Newbridge bypass and Newhall Interchange scheme coupled with the proposed concurrent Osberstown Interchange and Sallins bypass scheme (ref.HA0046) are assessed under section 18.5 of the EIS. It compares the modelled results for the do-min scenario (i.e. the existing road network) 2030 with the do- something scenario (for the two combined schemes) for 2030. The key results are an increase in traffic on the M7 mainline between M7/M9 and Maudlins resulting from the diversion of traffic accessing Naas and/or Sallins away from Newhall and Maudlins interchanges and to the Osberstown Interchange. The increase in AADT is 13% west of Osberstown and 15% east of Osberstown 54 , ‘ as a result of the additional capacity of the M7 55 and vehicles remaining on the M7 to access Naas and Sallins via the proposed interchange ’ (p.18/4). Interestingly, the impact of the latter scheme in the absence of the proposed upgrade ‘ would increase demand on the M7 mainline by between 8-10%’. The M7 mainline is operating in excess of 2000PCU at peak hours, whereas average lane capacity is estimated by the NRA to be c.1750 PCU/l/hr. It is the position of the applicant that the proposed Osberstown-Sallins Scheme would lead to increased congestion and further delays on the M7 at peak is dependent on the completion of the upgrade of the M7 56 .
52 A key target of Smarter Travel is that total vehicular kilometres travelled by car does not increase significantly. 53 This is not entirely clear. 54 The figures for cumulative impact in the Osberstown / Sallins Scheme EIS are 9% and 11%, respectively. 55 Underlining is my emphasis. 56 The EIS to HA0018 (previous application for Osberstown Interchange) in 2008 recognised that there would be a need to increase mainline capacity on the M7 to three lanes beyond 2010 and by 2025 but submitted that the proposed Osberstown Interchange would help alleviate this by diverting traffic onto the local network from the M7 (sections 5.7.4 and 5.7.5).
n Bord Pleanála Page 9 of 7 6.5 The Newhall interchange would experience a decrease of 37% in traffic exiting the eastbound off ramp and a decrease of 42% at the westbound on- ramp. The Maudlins Interchange would experience a reduction of 24% at the westbound off-ramp and a decrease of 22% at the eastbound on ramp. The EIS also examined how the existing Newhall Interchange would operate with the proposed Osberstown Interchange in place. It found that whilst queuing would be reduced in the 2015 and 2030 scenarios, significant queuing would still occur and indicating that the replacement Newhall Interchange is necessary even with the proposed Osberstown Interchange in place. 6.6 The EIS (and the TMR) does not, however, provide an analysis of the potential impact on the full transport network, including each of the relevant transport modes. This is a critical issue and a significant failing of the EIS given the stated policies of the government under ‘Smarter Travel’ (2009) and its commitments under EU climate change agreements, which favour and require a change in modal split in favour of public transport and other sustainable transport modes. Furthermore, it is also contrary to the Department of Transport’s ‘Common Appraisal Framework’ which indicates that cross modal impacts need to be considered in the appraisal of road projects (p.8). The potential impacts on other transport modes is particularly relevant to material assets, as the road development may undermine the feasibility of existing rail and bus networks and its associated infrastructure through a reduction in its customer base, resulting in a deterioration in the frequency and / or quality of services that can feasibly be provided. 6.7 There are very few references to bus and rail services in the EIS other than a statement that ‘ motorways are also very important public transport corridors for public bus and coach services ’ (p.2/2 and p.3/1), and an excerpt from the RPGGDA regarding the inability of the rail network alone to deliver future transport demands and the critical role of the road network to transport management and the efficient movement of buses, people, etc., although the road and rail networks detailed in the National Spatial Strategy are provided. At the hearing the applicant submitted that the provision of additional road capacity will facilitate bus transport and emphasized the importance road- based public transport. The applicant drew the Board’s attention to the support of Bus Eireann for the proposed development and referred to the Minister for Transport’s statement on rail and bus transport at the Transport Ireland Conference 2014 which indicated that the focus on public transport would be on bus services rather than rail. However, as noted above, the Minister’s speech was referring to existing and aspirational routes that were not economically viable rather than to the Kildare rail line, which forms part of the European TEN-T core network, the upgrading of which has been and continues to be part funded by the EU, including the DART interconnector which will join the Kildare and Belfast lines (it is also identified area for investment under the NTA’s Integrated Investment Plan 2013-2018). The
n Bord Pleanála Page 6 of 7 applicant was unable to identify any proposed bus service enhancements proposed along the subject route and the local authority has not made any progress on its objectives pertaining to bus priority routes within Naas under the NTDP, or pertaining to the development of a public transport interchange in Sallins under the Sallins LAP 2009 and the Kildare CDP 2011. 6.8 In a closely related matter, the applicant’s traffic modelling and analysis failed to take account of the potential for the scheme to generate ‘induced traffic’. Induced traffic includes: i) the diversion of existing traffic on the network in terms of time of travel; ii) the attraction of additional (new) traffic onto the network due to the availability of additional capacity on the network. Additional or new traffic may comprise entirely new trips that would not otherwise have taken place, however the new trips may also occur as a result of the diversion of existing trips from other modes, such as from public transport, onto the road network as new (induced) traffic. This may occur where the relative advantages / disadvantages of road versus rail, for example change, due to increased capacity on the road network that allows for improved road journey times. 6.9 In addition, the failure of the applicant to take account of the potential for induced traffic arising from the proposed scheme undermines the predicted environmental effects in respect of climate change (GHG emissions), local air quality and noise and vibration. The predictions are based on the achieving of free flowing traffic and the absence of the existing congestion and stop-start traffic which results in reduced GHG emissions per vehicle and improved local and global air quality (per unit traffic), and consequently improved residential amenity. These positive impacts may quickly dissipate, with the environmental impacts rebalancing to negative due to the additional vehicles and the re-emergence of interrupted flow / flow breakdown. 6.10 Induced traffic is a significant concern in transport planning. The issue is raised in the NTA’s ‘Draft GDA Transport Strategy and Vision’ (2013) (ch.12/32) which, in respect of the implementation of the strategy, raises the question of ‘ how far demand management should be applied on a corridor before infrastructure proposals are brought forward; and what should be done following enhancements to ensure that new car trips (“generated traffic ”) do not emerge to occupy road space freed up by transfer to other modes as a result of the scheme delivered ’. 6.11 The NRA’s own ‘National Transport Model, Model Validation Report ’ (August, 2011) attempted to assess the impact of ‘induced demand’ on existing motorway routes by comparing the model output with its own estimate of induced traffic from other available data. It estimated that 45% of traffic on
n Bord Pleanála Page 6 of 7 the M6 was from induced demand, compared to 32% based on the NRA’s own data (p.29, NTptM, 2012, NRA). The UK’s ‘Transport Analysis Guidance: Guidance for the Technical Project Manager’ considers the issue at length and advises that ‘ the potential impact of induced traffic should be recognised and it is highly recommended to scope the need for a demand model at an early stage ’ (p.17, January, 2014), and that ‘ All assessments of Government- funded investments in transport schemes need to consider the effects of variable demand (and the resultant induced or suppressed traffic) on the justification for intervention ’ (p.29). 6.12 The failure of the EIS and the applicant’s traffic modelling and analysis to take account of the potential impact on alternative modes and the potential for induced traffic is a serious omission in view of EU and national level policies (Smarter Travel) and objectives in terms of the promotion of alternative and sustainable travel modes as part of the strategy to meet objectives and commitments on Climate Change and a reduction in greenhouse gas emissions. It is also a significant omission in view of the designation of the Cork-Dublin-Belfast rail line as part of the Core Trans European Transport Network (TEN-T) and the provision of part-funding of the DART underground interconnector under the TEN-T which will enable the DART service to be extended to the Kildare rail line. The failure to take due account of the potential impact on alternative modes and the potential for induced traffic undermines the assessment of the potential impact on climate (through GHG emissions), local air quality and noise and vibration arising from traffic on the M7/N7. I therefore consider the EIS to be deficient and contrary to the requirements of the EIA Directive. 6.13 In addition, the traffic model does not appear to take account of the differing potential for development growth between the ‘do minimum’ versus the ‘do something’ scenarios. Growth in traffic is the same in both scenarios. The main argument for the proposed project is that the existing infrastructure is deficient and a constraint on traffic flows. In the short term the proposed replacement Newhall Interchange will facilitate greater accessibility to northeast Newbridge, including Togher Business Park, and to west Naas, including more direct (though not direct) access to Millennium Park and the Naas Northwest Quadrant area. This will facilitate and may stimulate development within those areas, with consequential impacts on traffic demand and flows on the network, even if total level of development within the LAM were to remain constant between the two scenarios. The impacts of this are not evident in the TMR or in the EIS. 6.14 Conclusion – The Environmental Impact Statement is deficient in its consideration of the potential for environmental impacts arising from the scheme, particularly in respect of the impact on material assets (alternative transport mode infrastructure), climate and local air quality (additional GHG
n Bord Pleanála Page 6 of 7 and other air emissions from induced traffic and future congestion), noise and vibration (additional noise and vibration arising from induced traffic) due to its failure to take due account of impacts on potential consequential changes to modal split and the potential for induced traffic and the impact of development potential.
7.0 Traffic modelling : 7.1.0 Traffic model 7.1.1 The details of the traffic analysis contained in chapter 6 of the EIS summarise the details provided in the Traffic Modelling Report (TMR) which was submitted to the Board by the applicant on 16/05/14. The model used was a traffic assignment (fixed demand) model using VISUM (V.12.00-06). It was used to create a local area model (LAM) with a defined cordon set within the NRA’s National Traffic Model. The TMR explains that the National Traffic Model is a strategic (macroscopic) traffic model developed using the transport modelling software VISUM, which covers that entire national and regional road network, is used by the NRA as a tool in the appraisal of potential road schemes, land use and policy changes. The NTM divides the country into 874no. zones. The growth factor attributes set for each zone determine the traffic generating power and the traffic growth for that zone in the low, medium and high growth scenarios up to year 2040. Any local area model set within the NTM is constrained to the NTM traffic growth scenarios pertaining to the zones. 7.1.2 The NRA’s Project Appraisal Guidelines (unit 5.2 ‘Construction of Transport Models’) provides guidance on the appropriateness of use of the different categories of traffic / transport models available (see also scoping criteria under table 5.2.1, p.13). Assignment models, such as that, used by the applicant, can only consider the reassignment of (fixed demand) vehicular traffic on the road network. Variable demand models, on the other hand, include consideration of demand responses (Trip Generation, Distribution and Mode Share). Unlike assignment models, the PAG advises that variable demand models are appropriate where schemes will generate traffic impact, will lead to large reductions in journey time; where induction or suppression of traffic is anticipated, will increase competition with public transport and in major urban areas where congestion will exist. As set out in previous sections of this report, there are legitimate concerns regarding the potential for the proposed scheme to induce traffic and to increase competition with public transport modes and therefore a variable demand model may be considered the appropriate model under the PAG criteria. 7.1.3 The issue of induced traffic and competition with public transport routes was discussed at length at the hearing HA0045 and in response to questioning by An Taisce and by the Inspector. A review of the traffic totals for the 40 links
n Bord Pleanála Page 63 of 7 included in the LAM shows a c.6% increase in total traffic between the ‘do- something’ versus the ‘do-minimum’ scenarios. The applicant confirmed that the traffic model does not take account of induced traffic and only takes account of traffic diverting its route. I can only conclude that the c.6% increase in traffic results from traffic diverting onto one or other of the 40no. links from other routes not included as a link within the model LAM, rather than induced traffic. 7.1.4 The applicant explained to the hearing that a variable demand model was not used as there was no national variable demand model available at the time of developing the LAM; the NRA’s National Transport Model (a VDM) can only model the current year scenario and therefore cannot assess schemes, such as this subject scheme. The National Transport Model is currently being upgraded and within the next few months will be able to assess future year modal split 57 . The applicant’s traffic model consultant (Mr Philip Shiels) offered no other justification of the use of the assignment model, but he confirmed that he considered the model fit for purpose and compliant with the requirements of the PAG model selection criteria under Unit 5.2 58 . 7.1.5 As noted above, the NRA’s data suggests that the introduction of motorway routes have resulted in induced traffic in the region of 32% AADT (M1 and M6, NTptM). I am not in a position to estimate what increase in the level of traffic AADT the introduction of a third lane on this section of the M7/N7 might induce. It will depend in part on existing latent traffic demand, i.e. trips that are diverted in time and mode or that do not take place due to existing congestion and the future congestion that would otherwise take place. The baseline traffic survey details demonstrate that there is significant temporal diversion of traffic at peak hours, with peak spreading at AM (two hours) and PM (possibly three hours). It is likely that the increased capacity will induce some existing traffic to divert to the peak hour and also induce existing (and future potential) trips to divert from other modes to the M7/N7 by private car. The attractiveness of this route will be further enhanced by the completion / commissioning of the Newlands Cross grade separated interchange. It follows that the available road capacity may well be absorbed in a short period of time. The issue of induced traffic at peak times is critical to the traffic impact arising from the proposed development and its impact will extend over the entire commuter belt using the M7, not just within the Local Area Model zone.
7.2.0 Baseline data 7.2.1 The issue of whether the baseline data was representative was raised in submissions to the application and was discussed during the course of the
57 Inspector’s questioning of Mr Philip Sheils of Aecom, 11.18 – 11.32am 06/06/14 (HA0046 Osberstown/Sallins Scheme hearing) 58 In response to questioning at oral hearing HA0046.
n Bord Pleanála Page 6 of 7 hearing. Mr Shiels stood over the use of traffic count data from February and from Monday which he indicated was in accordance with the NRA’s PAG. I am aware that UK guidance advises that traffic count data avoid certain months (December, January, February, August) and weekdays (Monday and Friday) as unrepresentative and there is a risk that the traffic count data does underrepresent the baseline situation and therefore the future year scenarios. The PAG does not advise against the undertaking of counts in certain months or on certain weekdays and therefore, excepting the issue of the appropriateness (or not) of the transport model used by the applicant, I am generally satisfied that the model has generally been informed by appropriate baseline data and has been calibrated and validated in accordance with the NRA’s Project Appraisal Guidelines (2011). 7.2.2 The failure of the applicant to conduct roadside interview surveys as part of the Origin-Destination surveys is a significant omission from the methodology employed. According to the PAG (U.5.1 pr.3.19) the purpose of the OD surveys ‘is to obtain a sample of the population in the study who are travelling along relevant routes / corridors and obtain detailed information about the nature of their trip.’ The absence of information on ‘trip purpose’, actual O-D (trip length) and vehicle occupancy results in a lack of understanding of the determinants of traffic generation in the within the study area, the potential for growth and undermines the model and the results it produced. For example road side surveys may reveal whether or what proportion of trips are currently being undertaken outside of peak due to existing congestion, or of car sharing, representing a latent demand for car trips within peak (i.e., it may provide a better indication of the potential for induced traffic). In response to questioning at the hearing the applicant submitted that RSI surveys could not be conducted as it was not permissible to stop vehicles on the motorway. However at least one of OD locations was situated on a local road (L2030) and the OD survey locations could have been chosen to facilitate at least some additional RSI surveys.
7.3.0 Development and traffic growth 7.3.1 The growth in traffic within the NTM and the LAM is the same with or without the provision of the infrastructure proposed as the overall level of development within the individual zones of the LAM are constrained to the NTM’s medium growth scenario 59 . I don’t consider this to be realistic. The argument for the proposed project is that the existing infrastructure is a bottleneck. It can be assumed that the existing infrastructure has acted (and will continue to act) as a constraint on development in the region and that once these constraints are removed development potential will be released. It follows that the LAM’s medium traffic growth scenario is incorrect either in the
59 The growth factors are based on CSO population and employment projections.
n Bord Pleanála Page 6 of 7 ‘do minimum’ scenario or in the ‘do something’ scenario but that it cannot hold true for both scenarios. 7.3.2 The proposed development can be expected to have significant implications for the future development of the north-eastern side of Newbridge, including the Newbridge Industrial Estate and the Tougher Business Park, as it will provide direct and high capacity access between the R445 (Newbridge Road) and M7. It will also facilitate much improved accessibility to the west side of Naas including (indirectly) to Millennium Park and the Naas Northwest Quadrant area 60 . The traffic modelling was informed by a background exercise on ‘future development potential’ for the Naas zone (504). This determined where future development would likely take place and the NTM’s medium growth scenario was apportioned to the various subzones within Naas, accordingly. This would appear to provide some realism to the distribution of traffic demand across zone 504, but it does not provide for a different level of development and traffic demand between the ‘do minimum’ and ‘do something’ scenarios in the future design years across the zone. No such exercise was undertaken for Newbridge and the forecast growth (from the NTM) was distributed evenly across the disaggregated zones (no bias towards the north/eastern side of the settlement closer to the proposed infrastructure). I don’t consider that to be realistic. In 2015 the ‘do something’ scenario results in an increase of c.17% in the AADT over the ‘do min’ scenario on the R445 Newbridge Road (c.16% in 2030)61 , without any consideration of the potential impact on development potential and the consequence of same on traffic generation. The increase will be more pronounced at peak traffic times. 7.3.3 I am not satisfied that the traffic modelling used by the applicant takes due account of the different development potential within the LAM between the ‘do minimum’ and ‘do something’ scenarios, which would have consequential impacts on traffic generation and traffic flows within the LAM. This is of greater concern in terms of the cumulative impact with the proposed Osberstown and Sallins Scheme, rather than to the case at hand. 7.3.4 Smarter travel - Mr Shiels of Aecom submitted to the hearing that the National Traffic Model takes account of the government’s transport policy under Smarter Travel and constrains potential traffic growth through the limiting of growth in car ownership to a cap of 2.1m cars (referred by Mr Sheils as a target under Smarter Travel 62 . He confirmed that the NTM does not
60 The concurrent application for the Osberstown Interchange (and Sallins bypass) under HA0046 is likely to be of even greater significance in terms of impact on growth potential as it will facilitate direct access to the strategic landbank at Millennium Park / Naas NWQ. I address this in greater detail in my report to HA0046. 61 Tables 5-8 and 5-9 of the TMR, comparing link 5 ‘do min’ and link 36 ‘do something’ - 17,550 and 20,550 in 2015; 19,650 and 22,700 in 2030. 62 I have reviewed the National Traffic Model Validation Report (March, 2009) as contained in Unit 20.3 of the PAG, to better understand the assumptions upon which it is based. It makes no reference to Smarter Travel or
n Bord Pleanála Page 66 of 7 explicitly take account of the modal share targets under Smarter Travel (i.e. the reduction in commuting trips by car from 65% to 45% by 2020) which will relate particularly to traffic peak hours. The Smarter Travel, document does not set a target to limit growth in car ownership but indicates that ‘if we continue with current policies’ car ownership growth could grow to beyond European levels from c.1.8m to almost 2.5m. 7.3.5 It would appear that the NTM, in selecting a figure of car ownership at 2.1m, provides for a mean level of growth in car ownership levels. I was unable to confirm these details or other assumptions impacting on traffic growth in the NTM online. Given that Aecom and Roughan & O’Donovan were involved in the making of the NTM, the Board may consider it reasonable to accept Mr Shiels’s submission at face-value. The applicant did not specify whether the 2.1m car ownership limit applies up to 2020 (the Smarter Travel target year), the 2030 future year scenario, or 2045 (the NTM final year scenario). It cannot apply to each of those future year scenarios given future population and economic growth likely over the period to 2045 and given that Smarter Travel applies up to 2020, it is reasonable to assume that the limit to car ownership growth applied only to that year. The situation after 2020 is unclear. 7.3.6 Mr Thorpe of Roughan & O’Donovan submitted that the approach taken by the NRA in its NTM represents a sea-change in its approach to traffic growth - there is no longer to be an assumption of continued, almost unrestrained car growth (as there was in NRA’s Future Year Forecasts 2002-2040 (2003)). I would accept that this is the case and that it is a more reasonable approach. It is not obvious how the existing car ownership levels within and without the LAM change over time and vary between the zones of the NTM and LAM or how this impacts on private car mode share, however the Board may consider it appropriate to accept it at face value.
7.3.7 Alternative modes – The planning authority revealed that little, if any progress has been made to date in respect of the objectives and policies pertaining to improvements to public transport for the Naas and Sallins area. In particular, no progress has been made regarding sustainable transport objectives for the provision of a public transport interchange, a park and ride facility and no progress has been made on the development of bus priority routes in the town which are provided for under the Sallins LAP 2009, the Naas TDP 2011 and / or the Kildare CDP 2011. In reality, the provision or
to a limit to car growth, nor does it refer to a target limit to total car ownership or vehicle licenses which would support Mr Shiels’s submission. However, as this is a validation report and compares the modelled situation with the then current traffic situation, future traffic growth determining factors would not be relevant to that report. Such details may likely to be contained elsewhere in another report pertaining to the NTM. The authors include Aecom and Roughan & O’Donovan, the consultants representing the applicant at the hearing.
n Bord Pleanála Page 67 of 7 failure to provide the said infrastructure has significant implications for modal split and traffic generation. 7.3.8 The LAM cannot and does not take account of modal split across the different modes, rather it can only include assumptions on traffic (i.e. car and HGV trips) generation and traffic growth based on population and economic growth factors. Neither the NTM nor the LAM take account of the Smarter Travel modal split commuter targets (i.e. the reduction in commuting trips by car from 65% to 45% by 2020) and they do not take account of the planning authority’s objectives for sustainable transport infrastructure. The absence of the aforementioned infrastructure therefore appears to have no implications for modal split and traffic generation within the LAM. In reality the additional increased capacity of, and improved access to, the M7 will increase the attractiveness of the private car over alternative modes and increase its modal share. This effect will be even more pronounced in the absence of progress in improvements in public transport modes in accordance with objectives under the statutory plans and will result in development within the region being car-based in nature.
8.0 Conclusion and recommendations : 8.1 This section of motorway is part of the strategic road network and part of the core Trans European Road Network (TERN) and Trans European Transport Network (TEN-T). The proposed upgrade of this section of motorway is not identified under any policy document at EU, National or regional level. 8.2 The route is congested and provides a low level of service at peak times and the Senior Inspector should consider whether it is reasonable to permit an increase in capacity of this strategic route having regard to the high level of strategic traffic (which includes commuter traffic according to the NRA definition) using the route in view of National and EU level transport policy. ‘Smarter Travel ’ sets out the government’s transport policy and translates EU transport policy at a national level having regard to GHG emissions reduction commitments. I would advise the Senior Inspector that the proposed upgrade of the M7 is contrary to and will militate against the achievement of the key targets of Smarter Travel for year 2020 which relate to modal split, total car kilometres and GHG emissions, directly, by providing for an increase in modal split for private car through provision of additional capacity on the network (and making it more attractive and more cost effective) and, indirectly, by reducing the numbers using alternative public transport modes, thereby making existing and proposed public transport (rail, in particular) less economically viable, with consequential risk of a deterioration in those services and a reinforced negative circle of decline. The scheme comprises a continuation of the ‘predict and provide’ approach to road traffic planning, which is not sustainable beyond a certain point – a certain level of road
n Bord Pleanála Page 68 of 7 capacity is obviously essential - but where this point lies is subjective. The NRA’s own research has indicated that demand management (the predict and manage) approach had the potential to reduce traffic levels on the M50 by 20% and the Senior Inspector may consider it would be appropriate to advise the Board that the demand management approach, integrated with a co- ordinated public transport (bus and rail) improvements along this transport corridor (a core section of the Trans-European Transport Network), be investigated for M7/N7 prior to a final decision being made on the application. 8.3 I would accept that the proposed upgrade of this section of the M7 to three lanes can be considered a long-term objective in that provision for a 3 rd lane was made in the original motorways scheme through the inclusion of a large central reservation. The NRA signalled its future intention to upgrade the said road to three lanes in its submission to application HA0018 (Osberstown Interchange Scheme 2008) in 2009. In addition, the Department of Transport, Tourism and Sport has submitted no objection to the proposed upgrade and the National Transport Authority raised no objection in its submission on file. I am satisfied that the applicant has demonstrated that there is a need for the proposed upgrade of the M7 and for the proposed replacement Newhall Interchange on grounds of future capacity need, but I am not convinced by the applicant’s submission that the upgrade of the mainline is required on safety grounds. It is indicated that the mainline upgrade is prerequisite for the implementation of the proposed Osberstown Interchange and Sallins Bypass due to the capacity constraints on the mainline. 8.4 Whilst the proposed replacement Newhall Interchange will increase access to the M7 mainline from Naas and Newbridge, the existing capacity constraints on the M7 mainline will limit the potential for traffic growth to arise during peak hour in the direction of Dublin. Accordingly I do not consider that the provision of same would be contrary to Smarter Travel and I am satisfied that it is accords with the provisions of the NRA’s Spatial Planning and National Roads Guidelines. I would agree that the replacement interchange is warranted on safety grounds. 8.5 In my opinion the applicant’s EIS does not comply with the requirements of section 50 of the Roads Act as it did not adequately take into account the environmental effects of the main alternatives studied in reaching a decision on its choice between the alternatives and, furthermore, it did not examine realistic comprehensive alternatives to the scheme selected in terms of hard shoulder running and demand management, in accordance with the NRA’s PAG and the DTTaS’s CAF, but rather presented two oversimplified alternatives in the form of simple hard shoulder running and road tolling. I consider this to be a serious failing that undermines the Board’s making of an informed decision on the proposed scheme. I would have similar concern
n Bord Pleanála Page 69 of 7 regarding the approach of the EIS to the consideration of alternatives to the proposed replacement Newhall Interchange. 8.6 I have no concern regarding the intended design of the proposed M7 upgrade, having regard to DMRB standards. I do not consider it desirable to leave the final design detail of the proposed Newhall Interchange for agreement between the applicant and the NTA regarding the facilitating of cyclists and pedestrians on the R445, particularly as the applicant is suggesting the rerouting of the cycle link via the Rathangan Road and the NTA’s submission does not indicate that this would be acceptable to them. It would not be unreasonable for the Board to allow this issue to be agreed between the two parties. 8.7 I consider the EIS to be deficient in its consideration of traffic and transport impacts, particularly in respect of the impact on material assets (alternative transport mode infrastructure), climate and local air quality (additional GHG and other air emissions from induced traffic and future congestion), noise and vibration (additional noise and vibration arising from induced traffic) due to its failure to take due account of impacts on potential consequential changes to modal split and the potential for induced traffic. These impacts have the potential to be significant, adverse and long term. 8.8 I am not satisfied that the traffic model (an assignment model) used was appropriate given the nature of the scheme, the location and nature of the infrastructure concerned and the presence of competing public transport infrastructure, having regard to the criteria for selecting traffic/transport models under the NRA’s PAG. The PAG advises that variable demand models are appropriate where schemes will generate traffic impact, will lead to large reductions in journey time; where induction or suppression of traffic is anticipated, will increase competition with public transport and in major urban areas where congestion will exist, all of which are factors arising from the proposed upgrade of the M7 mainline. The applicant’s traffic analysis (included in the EIS) and the assessment of environmental impacts are based on the findings of an inappropriate traffic model, the results of which I do not believe can be relied upon for the subject scheme under consideration. It follows that the applicant’s conclusions regarding traffic impact and environmental impacts cannot be relied upon. 8.9 My concerns regarding the traffic model used are compounded by concerns regarding the baseline assumptions in the National Transport Model that constrain the applicant’s Local Area Model that, in particular, prohibit it from assessing the traffic impact of development that would be facilitated by the development of the infrastructure concerned and that would effectively remove a current bottleneck to development potential within the Naas / Newbridge region.
n Bord Pleanála Page 7 of 7 8.10 Accordingly, I would advise the Senior Planning Inspector that a favourable recommendation on the proposed M7 Naas-Newbridge Bypass would be inappropriate, and that it may be appropriate to advise that the applicant be requested to investigate the resolution of the M7N7 capacity constraints through the implementation of an appropriate range of demand management measures and co-ordinated public transport improvements along this transport corridor, notwithstanding that the implementation of same will ultimately be a decision of Government. A favourable recommendation on the proposed replacement Newhall Interchange would be appropriate.
______John Desmond Inspectorate 12/08/14
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