An Bord Pleanála Ref.: HA0046 / MA0013
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; and detailed design issues having regard to relevant roads standards.
Local Authority : Kildare County Council.
Proposed scheme : M7 Osberstown Interchange and R407 Sallins Bypass scheme.
Dates of Site Inspection : 08/05/14 and 15/05/14
Date of oral hearing : 3rd , 4 th and 6th of June 2014
Inspector : John Desmond
n Bord Pleanála Page of 5 Part A
1.0 SITE DESCRIPTION 1.1 The application site, comprising those lands contained within the indicated boundary in drawings figure 1.2 ‘Proposed Scheme Layout’, of EIS Volume 3, can be best described in three sections. • The proposed Osberstown Interchange entails work along a c.1.6km length of the M7 extending west / southwest from the underbridge to the Grand Canal Naas line. The proposed interchange is located at approximately the point of an existing agricultural access overbridge. The site extends to (and includes part of) the existing roundabout on the Western Distributor Road in Millennium Park, Naas, c.250m from the existing edge of the M7 mainline and c.200m to the north of the existing edge of the mainline where it will connect to the Sallins bypass. • The proposed Sallins bypass extends for a length of c.3.65km, connecting to the M7 via the proposed Osberstown Interchange at the southern end of the scheme and to the Clane Road, at the northern end of the scheme, c.200m from the edge of the built up area of the town, although improvements will be undertaken on Clane Road up to the built up area. The route runs along the western side of Sallins town, following a path approximately parallel with the M7 mainline for c.500m before a taking sweeping 90-degree turn north, running west of the Grand Canal Naas line (Corbally), crossing the Osberstown Road L2006, the Dublin – Cork railway line, the Grand Canal Leinster line and the River Liffey before returning c.90-degrees in an easterly direction and crossing the River Liffey a second time. • The site also includes the line of a link road between the proposed bypass, from a point located approximately centrally between the Grand Canal (Leinster branch) and the River Liffey, to the junction of Clane Road (just north of Main Street) and Millbank at ‘Home Farm’. The route of the proposed link road follows the line of Millbank Road up to (approximately) the easternmost entrance to Millbank housing estate, before diverging gradually in a northwest direction, cutting over the access to the football fields (to the north), and running between and encroaching to a relatively small degree on the Castlesize housing estate to the north and the utility site (a sewage works) to the south. The route then sweeps west, south and west again over agricultural fields. The total length of the route measures c.1.25km. A revised access road is proposed for the Millbank west access and to the western end of Millbank Road.
n Bord Pleanála Page 2 of 5 2.0 PROPOSED DEVELOPMENT: 2.1 The proposed development comprises, as follows: • A grade separated junction, of typical dumbbell design, on the M7 providing connectivity between the national road network (M7) and the R407 Sallins bypass to the north and the existing local and regional road network in Naas to the south. The interchange design has capacity to cater for future traffic needs to 2030 design year. • Segregated slip lanes are proposed to the four proposed slip lanes to the interchange to facilitate free-flow movements and increased capacity at the interchange and are designed with auxiliary lanes to the motorway. • A western bypass (new R407) to Sallins extended to c.3.6km in length. The western bypass includes: o three overbridge crossings - two bridges over the River Liffey and one bridge over the Grand Canal; o two underbridges - one beneath (in a tunnel) the existing Dublin-Cork railway line and the other beneath a partly realigned section of L2030 Osberstown Road. • The southern section of the bypass is dual carriageway in design up to the junction with the proposed link road to the centre of Sallins. The northern section is single carriageway up to the Clane Road junction. • Cyclist and pedestrian facilities are proposed along the northern section of the route between the railway crossing (the road will be contained within a tunnel under the Dublin-Cork rail line 1) and the Clane Road junction. The said pedestrian and cyclist route will connect to the Canal Road on the northern side of the railway line. An additional dedicated pedestrian and cycle connect is proposed to connect the Canal Road to the existing pedestrian and cyclist facilities at Western Distributor Road, although the Canal Road falls mostly outside of the site. • A link road is proposed to connect the bypass (R407) to the centre of Sallins, which will include pedestrian and cyclist facilities in both directions. • A distributor road is proposed to connect the proposed Osberstown Interchange to the Western Distributor Road in Millennium Park, Naas.
1 Cycle/pedestrian facilities are not proposed within the proposed tunnel.
n Bord Pleanála Page of 5 • The proposed R407 Sallins bypass may facilitate an additional junction in the future to provide for a planned ‘public transport interchange’ (objective PT5 Sallins LAP). • The L2030 Osberstown Road will be partly realigned and will traverse the proposed Sallins bypass via an overbridge. • The Canal Road to the east of the proposed bypass will be partly realigned to provide a replacement junction with the L2030 Osberstown Road.
2.2 Phasing: It is possible that the interchange may be developed first and the bypass constructed at a later stage.
2.3 Road design details The design detail of the proposed Osberstown Interchange is as follows: • Dumbbell layout with two roundabouts either side of a single overbridge. • Full connectivity is proposed with two merge and two diverge slips, in addition to segregated slip roads at the top of the slips to enable traffic to avoid the roundabouts. • Slip lane with auxiliary lanes to the M7. • The cross-sections are as follows: Merge slip roads - 1.5m nearside hard-strip, 4.0m carriageway and 0.5m offside hard-strip; Diverge slip roads - 1.0m hard-strip, 2 X 3.0m carriageway and 0.5m offside hard-strip; Segregated slips – 1.5m hard-strip, 4.0m carriageway and 0.5m offside hard- strip. Auxiliary lane – 3.0m hard-shoulder and 3.5m carriageway • Slip roads to interchange are of 70kph design speed • The overbridge cross-sections are as follows: o 2 X 1.5m raised verge, 2 X 0.5m nearside hard-strip, 2 X 7m carriageway (2 X 3.5m lanes in each direction) and 1.5m central reserve – total width is 19.5. Note: table 4.2 of EIS states total width is 18.6m as the eastern verge width is totalled incorrectly as 1.1m, not 2.0m, when it includes 1.5m raised verge and 0.5m nearside hard-strip.
n Bord Pleanála Page of 5 Sallins bypass has a design speed of 85kph (posted limit of 80kph). The proposed cross-section is as follows: • Type 2 dual carriageway (between interchange and south of junction with link road) with the following cross-section: 2 X 3.0m verge inclusive of 0.5m nearside hard-strips, 2 X 7m carriageway (2 X 3.5m lanes in each direction) and 1.5m central reserve inclusive of 2 X 0.5m hardstrips – total width is 21.5. • Type 1 single carriageway (between Clane Road R407 and north of junction with link road) with the following cross-section: 2 X 3.0m, 2 X 2.5 hard-shoulders, 1 X 7.3m carriageway (2 X 3.65m lanes) – total width is 18.3. The western verge will reduced to 0.6m as per NRA DMRB TD 27/11 at the River Liffey and Grand Canal crossings. • North of the railway tunnel the eastern verge will be 4.5m to include cycle and pedestrian facilities, consisting of 1.5m segregation verge, 2.5m combined cyclist and pedestrian facility and 0.5m grass verge.
Sallins link road has a design speed of 50kph (posted limit of 50kph). The EIS submits that the design of the Sallins Link Road has been completed in accordance with the Design Manual for Urban Roads and Streets (DMURS). The proposed cross-section is as follows: • 2 X 5.5m (min) verges comprising 1.5m grass verge, 2.0m one-way cycle track, 1.8m footpath and 0.5m grass verge; 1 +7.0m carriageway (2 X 3.5m lanes) – 18.6m stated as minimum width.
Distributor link road has a design speed of 60kph (posted limit not stated) with a cross-section as follows: • 2 X 3m (min) verges, 2 X 6.5m carriageways (comprising 2 X 3.25m lanes in each direction), 2.0m (min) central reserve – 21.0m stated as minimum width.
Osberstown Road realigned section has a design speed of 70kph (80kph posted limited) with a cross section as follows: • 2 X 0.25m (min) verges, 6.0m carriageway (2 X 3.0m lanes) – 6.5m stated as minimum width
R407 Clane Road realigned section has a design speed of 70kph (posted limit not stated) with a cross section as follows: • 1.5m (min) western verge, 7.0m carriageway (2 X 3.5m) and 3.0m (min) eastern verge – 11.5m stated as minimum width.
n Bord Pleanála Page 5 of 5 Canal Road realigned section has a design speed of 60kph (posted limit not stated) with a cross section as follows: • 2 X 0.25m (min) verges, 5.0m carriageway - 5.5m stated as minimum width
The EIS indicated that the relevant design standard for the proposed M7 Osberstown Interchange and Sallins Bypass include: • NRA DMRB TD 9/12 – Road Link Design • NRA DMRB TD 27/11 Cross-Sections and Headroom • UK DMRB TD 22/06 and 2009 NRA addendum – Layout of Grade Separated Junctions • UK DMRB TD 16/06 and 2009 NRA Addendum – Geometric Design of Roundabouts • NRA DMRB IAM 03/12 – Provision for Cyclists and Pedestrians on Type 2 and Type 3 single carriageway National Roads in rural areas.
Environmental Impact Assessment The application is accompanied by an EIS.
Compulsory Purchase Order The proposed development requires land take from a number of parties. CPO issues are outside the remit of this report,
PLANNING HISTORY
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. HA0045: Concurrent application for Naas to Newbridge bypass upgrade and replacement Newhall interchange 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
n Bord Pleanála Page of 5 objectives in the Sallins LAP 2009 in addition to objectives in the Naas TDP 2005) as part of an overall development proposal. 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).
n Bord Pleanála Page 7 of 5 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 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.’
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.
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
n Bord Pleanála Page 8 of 5 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 Road (the Western Distributor Road). 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.
OBSERVATIONS FROM STATUTORY BODIES The main points of the observations received are summarised below:
An Taisce, prescribed body, 28/02/14 • Needs to be addressed on the basis of interactions and cumulative impact with N-N bypass upgrade. • No justification for separate parallel consent applications and EIS for S/O and N/N schemes which have an “immediate interface”. Board must address this as preliminary matter. • Breaches national policy ‘Smarter Travel’ - without a range of provisions to enhance and promote public transport usage and to reduce car dependence the scheme will undermine achievement of Smarter Travel targets for Naas & Sallins, make easier car access from Naas / Sallins to M7, and make car commuting to Millennium Business Park via N7 more attractive. • Non-integrated implementation of Naas Town Development Plan 2011-2017 regarding overall objectives for movement and transport (ch.7) and the parking standards applied by the Council are incompatible with achieving Smarter Travel
n Bord Pleanála Page 9 of 5 targets. E.g. of Kerry Group development (ref.13/500018) which entirely disregarded Smarter Travel and NTDP policies in the achievement of mobility targets. • Smarter Travel (2009) has entirely changed the policy considerations under which road and other transport investment must be assessed by the Bord. The interchange will have significant traffic generation impact unless active traffic management measures to enhance and provide for increased public transport, cycling and control of car use are provided for - the application fails to do so. The Board needs to ensure that any future road scheme does not increase 2009 traffic volumes or undermine national targets of reducing work related commuting by car from 65% to 45%. Can’t be justified on basis of reducing congestion as the alternative action required is reduction in traffic generation through switching to enhanced public transport services, cycling and P&R. • Fossil fuels / climate change – The EIS does not address impact of development arising from increased GHG emissions. Ireland’s economy is dependent on fossil fuels. Hirsch Report (Dept. of Energy, US, 2005) concludes that there is no ready alternative to liquid fossil fuels for private vehicle use and that replacement of stock with electric vehicles is economically and environmentally impractical. Further investment in oil dependent transport infrastructure is short-sighted, ill- conceived and an inefficient use of public funds and there is overwhelming international evidence that past trends must be not used to guide likely future outcomes. • The EIS has not considered the impact of oil dependent infrastructure in relation to GHG emission reduction targets. Ireland has signed up to the 20:20:20 EU agreement, a legally binding pledge to reduce GHG emissions by 20% below 1990 levels and to increase energy efficiency by 20% by 2020. • The proposal facilitates ease of use of all motor vehicles, will further exacerbate sprawl, fossil fuel use and emissions which the board must consider in context of Ireland’s commitment to climate change and CO2 reduction.
DoAH&G, Prescribed body, 28/02/14 • Nature conservation issues – Curragh aquifer. The Board may need to seek hydrological advice in reaching its determination. Some dewatering will occur through the development. Suggests potential for direct impacts on two nearest Natura sites (5km) with hydrological connections to the Curragh aquifer, Pollardstown Fen and Mouds Bog. • Unless there can be certainty that dewatering will not adversely affect the integrity of Pollardstown Fen cSAC the project should not proceed. Cumulative impacts on the aquifer, including from existing roads (e.g. Kildare by-pass which has monitoring in place) to be considered.
n Bord Pleanála Page of 5 • No result from bat survey included in EIS. • Otters – impact of bridge foundations on other riparian zone (10m either side). • Any mitigation measures proposed in the EIS / AA screening / NIS must form part of the construction management plan. No construction management plan is on file and it is not possible to adequately assess the impact of the project without knowing the minimum standards and mitigation measures to be contained in any CMP. • Reuse of topsoil and natural reseeding only. • Licensing agreement – derogations will be required from NPWS where necessary and should be applied for in advance of planning. • Barn owls – may be negatively impacted by road schemes through loss of nest sites and through car strikes. Roosts should be looked for in advance. • Archaeology – all measures set out under section 8.6 EIS should be carried out in full in advance of commencement of construction.
HSE, Prescribed Body, 28/02/14 (Subsequently withdrawn) • Any spillage or incident with potential to affect drinking water (River Liffey) should be immediately reported to KCC and FCC Water Services. Buffer zones from water bodies in terms of use of pesticides / herbicides should comply with that recommended on the product label and application should be postponed if significant rainfall forecast within 48 hours.
Inland Fisheries Ireland, Prescribed body, 28/02/14 • Importance of River Liffey and Naas stream for Annex listed fish. • No objection subject to 4no. conditions.
National Transport Authority, prescribed body, 28/02/14 • No objection. The facilities for cyclists and pedestrians are welcomed and their design appears at this stage to be acceptable. • It is necessary for the scheme to make adequate provision for connecting ramps from the Grand Canal Cycle Routes (Route N6 in GDA cycle network) to which the NTA would welcome liaison with the scheme designers at the detailed design stage.
OBSERVERS
Alan Lloyd, 19/02/14 • Impact of proposed canal bridge and road scheme. • Surface water drainage issues – risk to grounds water quality and to private water supply; runoff and potential flooding / collection
n Bord Pleanála Page of 5 • Dumping in local ditches and streams. • Lack of connection to services / facilities which should be provided for as part of the scheme – water supply, foul sewer connection, broadband, etc. • Slí na slainte should be extended to the southern side of the canal and connect up with Naas canal walk and Soldier’s Island – locally specific tourism issues and potential. • Improvements required to local road and to access.
Brendan Owens, Castlesize Residents Asso., 28/02/14 (subsequently withdrawn) • Loss of public open space / recreational green used and maintained by local residents. • Safety concern for children • Appropriate and secure to blend with existing hedging should be provided. • An overflow sewage tank is located behind the boundary of the proposed road (pumping station also referred to). • Queries the need for link road and considers it excessive, two points of access sufficient. • The link to the central area will not alleviate the current traffic problems but will result in it being used by traffic for Naas North, Johnstown, Kill and M7 northbound and cause a major bottleneck of traffic arriving in Sallins.
Osberstown Developments Ltd (owner of Millennium Park) c/o Gerry Prendergast, 21/02/14 In favour of proposal • Millennium park is c.160ha (140ha currently available for development) straddles the M7 between junctions 9 and 10. • 2 minutes from Sallins train station to which it has a connecting bus service. • NTDP 2011-2017 seeks to direct and encourage economic growth towards the northwest quadrant identified (since 2005) as appropriate to facilitate major new employment. • Current town development strategy founded on the Integrated Framework Plan for Land Use and Transportation (IFPLUT) for Naas 2003, based on developing a public transport corridor from an expanded town centre through the northwest quadrant (envisaged as the area in which most employment will be concentrated – 6000 employees), linking to Sallins Railway station, maximising use of public transport, sustainable modes and reduction in need to travel. • Scheme is supported by government, regional and local planning policies. • Scheme is essential and will address the inadequate connectivity between the national, regional and local road networks; the inadequate capacity of Sallins Road R407; remove regional traffic from Naas regional network and from Sallins; will facilitate planned and zoned development in the northwest quadrant of Naas;
n Bord Pleanála Page 2 of 5 facilitate the development of sustainable transport policies in the urban centres for short commutes; and would facilitate the development of a more balanced, hierarchical regional road network. • The Osberstown interchange will have a net positive traffic impact on the local road network (particularly the Western Distributor Road), releasing capacity or local trips and public transport and cycle/pedestrian infrastructure. • Will remove through traffic to M7 from Sallins, the western distributer and Monread Road.
Peter Sweetman, 28/02/14 • The proposal is an extension of the development proposed under HA0045. • Amazed that the Board accepted these applications considering the EIA Directive and the judgements of the CJEU. • Project slicing.
Mr Peter Traynor c/o John Dore, 25/02/14 • No assessment of impact on his lands in the EIS • Potential impact on greyhound enterprise (visual and noise) from proposed scheme need to be addressed and mitigated. • Possible restrictions on access to his property by high load vehicles from proposed canal bridge (alternative access blocked by low level Digby bridge. • Concern that final design for bridge may vary from the ‘specimen’ design (5.3m clearance) included in the EIS. Legally binding minimum dimensions required. • Flood risk posed by proposed attenuation pond, the issue of insurance liability and impacts on existing drainage. • Security risk to greyhounds – 2m high palisade fencing should be erected along the scheme boundary from railway bridge to the canal. • Concern about unlawful parking on the green spaces along the proposed scheme. • Queries what allowance has been made for sewage from the east towards Osberstown waste water treatment plant.
Anthony Kehoe, Michael O’Connor, Leo Heavey, Brendan Heavey, Damien Woods, Patrick Shanahan, Sean Shanahan, 26/02/14 (subsequently withdrawn) • No objection to routes or profile. • Concerned that the subject lands are referred to in the schedule as agricultural lands, whereas they are actually located within the Sallins LAP 2009 boundary zoned ‘H’ – offices, light industry and warehousing. • ARUP have undertaken to amend the schedule.
n Bord Pleanála Page of 5 • There is no reference in table 4.10 of EIS to an entrance to the subject lands which are crossed / severed by the proposed Sallins link road, unlike that proposed to be provided for the Millbank estate and other lands. • The raised elevation of Sallins link road has implications for location and arrangement of accesses, for drainage, provision of urban services and the implementation of SuDS. • Need assurance that no new risk from flood should emerge from the proposed scheme on the retained lands in terms of FRA with protection against a 1:100 year event. • The following should be provided before the scheme is approved – o Location of access to link road from subject lands o The necessary accommodation works to effect the required entrances o The conduits required to service the lands and drain the lands for surface water discharge, foul water access to mains and for power and communications o Assurances in respect of flood risk assessment and management o Proposed boundary treatment, landscaping and noise attenuation screens. • Requests clarification as to whether the attenuation area on lands purchased adjacent the Liffey can be used to provide the same facilities to the lands retained.
Anthony Neville of Briargate Developments, 27/02/14 (subsequently withdrawn) • Supports the scheme. • Having regard to the level of the proposed link road vis-à-vis his landholding, the potential landscape and visual impact on the said lands, which are variously zoned for development, ought to be considered. • Access – section 2.0 of the EIS notes that three new entrances are required for land parcels severed by the proposed scheme, but does not shown them. The same should be agreed with the landowner prior to a grant of approval. Concern regarding how the level of the road may impact on creation of new access points for future development. • Severance – The impact of severance of the subject landholding should be taken into account by the Board in its assessment of the suitability of the scheme, with a view to the impact on the lands development potential. • Accommodation works, particularly those associated with the proposed drainage system, fencing and planting. • Drainage – trusts that the design of the drainage system and attenuation pond will ensure that there is no flood risk to the subject lands and that the
n Bord Pleanála Page of 5 development potential of the lands has been taken into account in the design of same. • Fencing & planning – it is assumed that the fencing and planting will take into account the future development status of the lands and suited to a residential environment. • Lighting – the EIS provides that solid fencing is proposed where vehicle lighting could have a direct impact on residential amenity. Does this include the residential amenity of those subject undeveloped-lands zoned residential. • Noise – has the noise assessment taken account of the potential impact on those subject undeveloped-lands zoned residential, together with the 2m elevation of the proposed link road. • Duration of works – the duration of the works needs to be clarified. • Construction compound – is the size of the adjacent compound sufficient without risk of encroachment on the subject lands.
Ciaran O’Neill c/o Jordan Auctioneers, 27/02/14 (holding 106) (subsequently withdrawn) • More land than is necessary for construction of the road is being acquired. • Impact on residential amenity and impact of noise. • Inadequate detail regarding accommodation works, including boundary and replacement boundary works. • Insufficient detail regarding artificial lighting proposals on new road. • Design results in creation of open area to rear of property and no proposals made to deal with unauthorised parking.
Desmond Ward & family, Princelyn House, Osberstown, c/o Thomas Freeman Planning Consultant, 28/02/14 – Peter Sweetman representing. (subsequently withdrawn) • Concern about the alignment and impacts on his property and family life. • Project splitting – the two projects ought to be considered together having regarding the EIA Directive, Habitats Directive and to ECJ rulings. • Lack of appropriate assessment contrary to the Habitats Directive – full appropriate assessment is required for such a large projected, together with the N7/M7 upgrade having regard to the Grand Canal and River Liffey which are habitats that act as corridors for species scheduled for the Habitats Directive, including bats. • Concern over who is funding the scheme – to what extent have vested interests impacted on the proposed route, timing of project, etc.
n Bord Pleanála Page 5 of 5 • Impact on family and private life – permanent negative impact on this quiet rural location from passing traffic which will result in noise, air pollution, visual impacts, loss of privacy, etc. • Construction impacts – dust, noise, mud, etc. No details provided of when and how works will be carried out to the railway line and its environs. When and how works will be carried out to the railway line need to be provided, with confirmation that no out of hours works will be required. • Temporary access – lengthy and circuitous diversion will be required during construction which is not acceptable. • Potential for flooding acknowledged by Council Engineer, John Coppinger. Photograph of flooding of investigation boreholes attached. • Objects to the compulsory purchase of his lands. • Should the Board decide to approve the CPO and road scheme it is requested that the Council CPO the existing dwelling. Mr Ward’s mother’s house is subject of CPO, splitting the family up. This would address their concerns. • If the Council will not CPO the dwelling then the following mitigation is required – o 2.4m high wall (appropriately finished) to act as flood defence. o Installation of acoustic glass in windows and doors to ameliorate impact of traffic noise. o Construction of landscaped berms between existing lane and proposed road with proof that they would be effective. o Access to the rear of Ward’s property should be provided over lands acquired by the promoters of the scheme and to which a new access is being provided. o These works should be completed prior to commencement of scheme. • Reiterates concern about impact of night time working.
Edward O’Loughlin c/o Maguire & Asso., (site 104 - CPO) (subsequently withdrawn) • Site 104 is farmed in conjunction with lands ref.105. • Access – EIS provides for replacement access. • Cattle-shed – EIS does not provide for replacement. • There is inadequate width along the canal towpath, which is narrow, in poor condition and access to and car parking for permanently moored canal boats, to provide access for a cattle truck to the subject lands. • Sallins LAP 2009 objective for ‘footpath and cycle track’ between points X-Y will ensure that access to the subject lands is effectively closed off. • If the scheme is approved the Board should attach conditions requiring the provision of a new agricultural entrance and access via the Sallins by-pass / Sallins link road roundabout junction; and to provide a new cattle shed.
n Bord Pleanála Page of 5 Elizabeth Ward, Osberstown, c/o Pauline Foster, 25/02/14 (site 120 - CPO) (subsequently withdrawn) • Requests that the CPO of the house be completed as soon as possible and in advance of any construction to minimise impacts on her mental and physical health. • Requests that the house then be demolished and the site secured in order to prevent it becoming derelict, a dumping ground and / or attracting undesirables (it is adjacent to her son’s house).
Kieran O’Flaherty and Morgan O’Flahertyc/o Maguire & Asso. (site 102 – CPO) (subsequently withdrawn) • Devastation of their farm by bypass with profound impact on operation and viability. • Object to the provision of a footpath and cycleway on the bypass road connecting into future footpath and cycleway along the River Liffey banks. • The field severed from the rest of the farm will become inaccessible for farm machinery due to steep gradients of land. • Security and disturbance created by construction. • Requests that the bypass scheme, the CPO and the motorway scheme be refused / not confirmed by the board. • Photographs of agricultural track and ground levels, drawings of cross sections, LAP objective’s map and copy of previous submission to KCC objecting to the scheme and suggesting an alternative bypass route are attached and noted.
Pat O’Brien c/o Thomas Freeman Planning Consultant (site ref.121 CPO) (subsequently withdrawn) • Concern about the alignment and impacts on his property and family life. • Project splitting – the two projects ought to be considered together having regarding the EIA Directive, Habitats Directive and to ECJ rulings. • Lack of appropriate assessment contrary to the Habitats Directive – full appropriate assessment is required for such a large projected, together with the N7/M7 upgrade having regard to the Grand Canal and River Liffey which are habitats that act as corridors for species scheduled for the Habitats Directive, including bats. • Concern over who is funding the scheme – to what extent have vested interests impacted on the proposed route, timing of project, etc. • Impact on family and private life – permanent negative impact on this quiet rural location from passing traffic which will result in noise, air pollution, visual impacts, loss of privacy, etc.
n Bord Pleanála Page 7 of 5 • Construction impacts – dust, noise, mud, etc. No details provided of when and how works will be carried out to the railway line and its environs. When and how works will be carried out to the railway line need to be provided, with confirmation that no out of hours works will be required. • Temporary access – lengthy and circuitous diversion will be required during construction which is not acceptable. • Potential for flooding acknowledged by Council Engineer, John Coppinger. Photograph of flooding of investigation boreholes attached. • Objects to the compulsory purchase of his lands. • Should the Board decide to approve the CPO and road scheme it is requested that the Council CPO the existing dwelling. Mr O’Brien’s neighbour’s mother’s house is subject of CPO. This would address their concerns. • If the Council will not CPO the dwelling then the following mitigation is required – o 2.4m high wall (appropriately finished) to act as flood defence. o Installation of acoustic glass in windows and doors to ameliorate impact of traffic noise. o Construction of landscaped berms between existing lane and proposed road with proof that they would be effective. o Access to the rear of O’Brien’s property should be provided over lands acquired by the promoters of the scheme and to which a new access is being provided. o These works should be completed prior to commencement of scheme. • Reiterates concern about impact of night time working.
Patrick Garvey, Waterford, Osberstown, 27/02/14 and 01/04/14 (site 107) (subsequently withdrawn) • Objects to scheme • Massive effect on his property • Impact on property value – unsaleable. • Visual pollution – motorway 10m from front, rear and side of the subject property • Noise pollution – carriageway elevated above the house. Mitigation. • Light pollution • Impact on well water supply from landfill and land movements • Impact on septic tank from landfill resulting in leakage into water supply • Disruption of drainage which will divert from drainage ditches into water supply. • Access proposals are totally unacceptable. • Serious safety concerns in relation to the proposed scheme. • Inadequate boundary treatment. • Landscaping proposals are insufficient mitigation.
n Bord Pleanála Page 8 of 5 • Uncertainty - the variation in levels and road design which could arise at construction stage compared to the current proposal is too large. • Potential for structural damage during and after construction is not addressed. • Not the optimum route for road. • Inadequate catering for footpaths and cycle paths. • Does not allow for creation of sufficiently wide hard shoulder – no work is being proposed on the local road. • Dust. • Impact on amenity of garden. • Requests to see scale model of project. • Loss of sunlight. • Received legal advice that full CPO of the property should have been offered. • Adverse impact on quality of life and value of home.
Seamus McCarthy c/o Maguire & Asso., 28/02/14 (site 118) • Objects to the closing of an existing agricultural entrance to the subject lands. • Provision should be made for pedestrian and vehicular entrance at the location of the proposed roundabout similar to that provided on the Naas Western Distributor having regard to the zoning of the subject lands under the Sallins LAP 2009.
Kimberley SA, James Quinn, Thomas McAndrew, Christopher O’Sullivan, Thomas English, Patrick Brady and Michael Donnelly (co-owners of Waterstown) c/o P&G Stack Solicitors (site 103) 27/02/14 (subsequently withdrawn) • Objects to the scheme on the grounds that it will interfere with the subject lands, compromise access thereto (12.3ha will be separated from the rest of the lands with no alternative access as it is bordered by the Liffey) and consequently compromise the potential for development on the lands into the future.
William Nevel & Sons Construction Ltd c/o Jordan Auctioneers (site 113) 28/02/14 (subsequently withdrawn) • KCC is acquiring more land than required. • Full planning permission exists on the subject lands for a shopping centre. • Insufficient detail provided in EIS regarding access to the lands/shopping centre development, access main services and boundary treatment works along the CPO line.
Deirdre and Martin Boran, Osberstown, c/o Moloney & Co. Solicitors (site 108), 27/02/14 and 10/03/14 (subsequently withdrawn) • Objects to CPO.
n Bord Pleanála Page 9 of 5 • Excessive land take (0.4455ha) required to facilitate realignment of Osberstown Road in the vicinity of the subject lands. • The amended road have been designed to a standard of 70kph (speed limit is maintained at 80kph) resulting in an alignment that requires excessive land take. • A design speed of 50kph would be more appropriate within the vicinity of the Leinster Aqueduct and would require less land take and less intrusive impact on the objectors’ dwellings and holding. • It would reduce the impact on the objectors’ existing entrance and may permit its retention. • The replacement of the existing ‘treed’ verge with a road structure or embankments will have a negative impact on the dwelling and holding. • The relocation of the existing entrance and drive will have a negative impact. • The scheme will have a detrimental and negative impact on the residential dwelling and lands from traffic noise impact, visual impact from elevated road, air pollution. • The bypass will do little to address the localised congestion that occurs at R407 / Osberstown junction during morning, off-peak and evening periods. • No consideration as to have the bypass will improve this traffic congestion has been considered. • Specific technical details on the extent that existing trips will transfer to the new route is required.
Kerry Group c/o Brock McClure Planning Consultants, 28/02/14 (site 109 and 128 CPO) (subsequently withdrawn) CPO • The CPO line relating to 128a.101 be amended to reflect the entirety of the permitted GTIC development ref.13/500018 and that the elements of the permitted development remain entirely within the control of the Kerry Group. • That Kerry Group’s rights at 109f.203 & 109f.202 be preserved or alternative provision be made for equivalent rights. • A condition should be attached requiring a pedestrian underpass be provided, the details of which be agreed with KCC. • A condition should be attached allowing for the construction of the interchange in a manner that would not prohibit the creation of these services in the future. EIS • Supports the proposed development • Satisfied with the EIS. • Traffic & transportation – significant traffic benefits.
n Bord Pleanála Page 2 of 5 • Provision of underpass under the proposed distributor link road is required in order to uphold Kerry Gold’s acquired right to develop and access the attenuation pond for recreational use for their employees. Condition requiring agreement with KCC for underpass. Indicative location proposed. • The Kerry Group is not agreeable to redesign / reconfiguring of the surface water attenuation ponds / swales only recently authorised by KCC in the GTIC development. • Requests the Board to attach a condition ensuring the final design detail does not impact / encroach on the permitted attenuation pond / swale. • The Kerry Group is not agreeable to redesign / reconfiguring of the parking only recently authorised by KCC in the GTIC development. • Requests the Board to attach a condition which prohibits development encroaching on the authorised parking layout to GTIC. • Climate impact assessment – o mitigation should include a dust monitoring station in vicinity of GTIC to continuously monitor PM10 to verify proper implementation of mitigation measure; o The proposed mitigation measures should also be made directly applicable for construction compounds; o The appointed contractor should be required to liaise directly with the representative of the Kerry Group as part of the preparation of the ‘Environmental Operating Plan ’ and a ‘ Construction and Demolition Waste Management Plan ’; o That mitigation measures are formally confirmed by an appropriate condition. • Drainage including Millennium Park Attenuation Pond – the Board should confirm the amendments to the attenuation pond, as described in the scheme, and that no reduction or erosion of this future amenity space occurs. • A condition should require the on-going and regular maintenance of toe drains by the council / NRA to ensure that they do not drain to the GTIC site. • Landscape / visual – condition should require the specific landscape detail to be agreed with KCC and that the proposed boundary fence in the location of GTIC swale be omitted. • M7 route widening – section 18.5 of the EIS confirms that the M7 Osberstown interchange and Sallins bypass scheme may be constructed at the same time as the proposed M7 widening scheme but not opened until the M7 widening works are completed. This has been confirmed by the project engineers. Requests that the Board confirms that both projects can take place at the same time and that the projects remain unlinked as regards their commencement, i.e. that either project can commence independently.
n Bord Pleanála Page 2 of 5 • The attached MOR report also recommends that the development taken place without impacting on the GTIC water supply and that the distance between the scheme and the GTIC should be maximised. • The MOR report also considers the traffic modelling works undertaken as part of the EIS to be satisfactory and submits that their own independent calculation correlates with the ‘ congestion reference flow ’ for the M7 presented in the EIS transport assessment so there is no argument against justification for the M7 Naas/Newbridge bypass upgrade scheme.
7.0 POLICY
7.1 Spatial Planning and Development National Spatial Strategy 2002-2020 National Development Plan 2007-2013 Regional Planning Guidelines for the Greater Dublin Area 2010-2020 Kildare County Development Plan 2011-2017 Naas Town Development Plan 2011-2017 Sallins Local Area Plan 2009
7.2 Transport & Other Planning Guidelines ‘Design Manual for Roads and Bridges ’ (NRA, various years) ‘Design Manual for Urban Roads and Streets ’ (DTTaS and DECaLG, 2013) ‘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) ‘Project Appraisal Guidelines’ (NRA, 2011) ‘Smarter Travel: A New Transport Policy for Ireland, 2009-2020 ’ (DoT & DoEHGL 2009) ‘Spatial Planning and National Roads, Guidelines for Planning Authorities ’ (NRA, 2012
n Bord Pleanála Page 22 of 5 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 2 of 5 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 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 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 provision of new interchange to the M7 at Osberstown; • The provision of a western by-pass of the R407 at Sallins to connect into M7 via the proposed interchange on the northern side of the M7, with the northern end of the by-pass connecting, via a proposed roundabout, to the Clane Road north of Castlesize, entailing two bridges over the River Liffey, a bridge over the Grand Canal, a tunnel under the Dublin-Cork railway line and the realignment of part of the R407 Clane Road, L2030 Osberstown Road (including new underbridge) and part of the L6005 Canal Road, and the junction between the two said local roads;
n Bord Pleanála Page 2 of 5 • The provision of a distributor link road to provide access between the Western Distributor Road, Millennium Park, and the M7 via the proposed interchange on the southern side of the M7; • The provision of a link road between Clane Road / Millbank junction in Sallins and the proposed by-pass.
2.0 Policy
2.1.0 Introduction 2.1.1 The scheme is submitted to be dependent on the proposed upgrade of the M7, which is subject of concurrent application HA0045 and is included within the EIS analyses as effectively the ‘baseline’ scenario or ‘do minimum’ scenario. The policy issues relating to HA0045 have been addressed in my report on that proposed development and I will not revisit them here. Rather, I will endeavour to confine my assessment to those policy documents which are relevant only to the provision of the proposed Osberstown Interchange and the proposed Sallins Bypass and related works.
2.2.0 National Spatial Strategy 2.2.1 The proposed development will facilitate greater and more direct access to zoned lands within two existing zoned urban settlements of Naas and Sallins (Naas being identified as a ‘primary development cluster’ with Newbridge and Kilcullen, with an ultimate population horizon of 40,000 (p.80)) to the national road network, thereby increasing the attractiveness of those settlements to accommodate a range of developments and facilitating consolidation of development on a ‘national transport corridor’, including a national rail line . I consider the proposed development to be consistent with the overall approach and key concepts underlying the NSS.
2.3.0 National Development Plan 2007-2013 & Infrastructure and Capital Investment Framework 2.3.1 The proposed scheme is not included in the National Development Plan 2007- 2013 (out of date but not yet superseded) but the scheme is not contrary to the provisions of same. The scheme is not included in the Infrastructural and Capital Investment Framework and is not a national road project 2. The ICIF indicates that funding for regional roads will be focused on maintenance and rehabilitation
2 Mr Thorpe, Aecom, submitted to the hearing on HA0045 (M7 upgrade scheme) that the Osberstown / Sallins scheme is not an NRA scheme and will not be funded by the NRA.
n Bord Pleanála Page 25 of 5 of the network and no funding is indicated for the development of this regional bypass (or any other regional bypass). The main focus of the ICIF ‘ is on protecting and extracting maximum value from existing assets ’ (p.16) and to ‘provide limited and targeted improvements ’ (p.17). 2.3.2 The EIS submits that the proposed scheme will help protect the value of previous investment in the M7 by relieving existing congestion in the vicinity of Naas and providing the necessary connection to employment areas and that it will enhance public transport infrastructure by providing a convenient connection from the motorway network to the existing train station and ‘park and ride’. For reasons developed later in my report, I consider the proposed scheme, taken cumulatively with the proposed M7 mainline upgrade, may actually undermine the existing investment that has been made in commuter rail services by increasing the relative attractiveness of private car for commuting, particularly in the absence of a concerted effort to provide an integrated public transport system. The proposed scheme is not supported by the ICIF and, taken cumulatively with the proposed M7 upgrade, may actually undermine the main focus of the ICIF.
2.4.0 Spatial Planning and National Roads 2.4.1 The proposed scheme is consistent with the primary purpose of the national roads network which is to provide strategic transport links between the main centres of population and employment and access to all regions (p.2). I am generally satisfied that the proposed interchange is consistent with the NRA’s policy on provision of additional interchanges (and criteria for assessing same) as set out under section 2.7 of the SPNR guidelines.
2.5.0 Regional Planning Guidelines for the GDA 2010 – 2020 2.5.1 The guidelines identify Naas as a Large Growth Town I, for which a target population of 50,000 applies (the 2009 population was estimated at 20,311 in the NTDP 2011). The guidelines emphasise the need to invest in public transport, to link population directly to large scale public transport investment and that integrated of investment in transport, particularly public transport, with housing, business and leisure development to ensure a good return on that investment by the state (p.24). New road infrastructure is included as a possible solution to local congestion, but the use of 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 are also suggested (p.59). The guidelines view public transport as the main investment priority but acknowledge that the road network will be critical in transport management for movement of buses, people and goods (p.117).
n Bord Pleanála Page 2 of 5 2.5.2 The EIS submits that the proposed development will free up congested local / regional road space to facilitate improved bus services, however the planning authority has made no progress on implementing (or investigating the implementation) the objectives of the relevant statutory development and area plans that would help realise improved public transport services on a de- congested road network 3. On balance, I consider the proposed Osberstown Interchange and the proposed Sallins Bypass, in themselves, to be consistent with the provisions of the RPGGDA.
2.6.0 Greater Dublin Area Draft Transport Strategy, 2030 Vision (NTA, 2011) 2.6.1 The strategy provides that ‘ 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 ’ and the authority will only support road improvement schemes whose primary purpose is to address accident or safety issues and that avoids inappropriately increasing capacity that may encourage longer distance car-based commuting (p.1 and 2 Ch.11). The primary purpose of the proposed scheme is to address existing congestion and accessibility issues and no clear case has been put forward that the case is warranted on safety grounds (see section 3.2.2 Safety) or no quantification of safety (that is commonly measured in reduction in road traffic accidents of different severity) has been put forward. The applicant submits that the freeing up of local and regional network road capacity will facilitate public transport (improving reliability) and access to the train station and ‘park and ride’ facility and to the proposed public transport interchange. The Planning Authority has made no progress in the implementation of objectives relating to public transport under its statutory plans, including the provision of bus priority routes, without which the potential benefits to public transport services will almost certainly remain unrealised and the available road capacity risks being absorbed by car commuters 4. 2.6.2 The strategy includes a number of proposed measures (Road 1 and 5 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,
3 I note that a Part 8 Scheme for a ‘bus hub’ at Market Square, Naas, has recently been notified to the Board and is open for consultation until 19/09/14. In addition an 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. 4 See preceding footnote.
n Bord Pleanála Page 27 of 5 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). I do not have particular concern for the proposed Osberstown Interchange and Sallins Bypass Scheme taken alone as it would improve accessibility from a designated growth area (under the NSS and the RPGGDA) to the national network which has limited capacity to accommodate additional demand. The existing capacity constraints of the M7 at peak would act as a demand management measure limiting the possible increase in car trips at commuter peak periods. 2.6.3 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. The M7/N7 and the M9 are included in Figure 11.1 along with the main national radial routes emanating from Dublin. This would suggest that the existing road capacity be managed and development of additional public transport services and rail services be encouraged the along the multimodal corridor of the M7 and Cork-Dublin railway line, rather than an automatic increase in road capacity. I consider the NTA document to be consistent with higher level national and European policy and to be logical and reasonable. 2.6.4 The applicant submits that the increased road capacity will better accommodate of public transport (bus transport) and facilitate greater reliability, but in the absence of a concerted effort by the local authority and service providers to implement integrate public transport initiatives the additional capacity will merely encourage additional and longer distance commuting by private car to Dublin, contrary to the policy of the NTA. However, I do not consider the proposed Osberstown Interchange and Sallins Bypass Scheme, in themselves, to be inconsistent with the strategy.
2.7.0 Smarter Travel 2.7.1 The EIS submits that the County Council supports an integrated sustainable multi-modal transportation strategy as reflected in the statutory plans (see p.3-6
n Bord Pleanála Page 28 of 5 and 3-7) abiding by Smarter Travel policies. The County Development Plan, the Naas Town Development Plan and the Sallins Local Area Plans include sustainable transport objectives which are consistent with Smarter Travel, but the proposed development, apart from the proposed cycle and pedestrian facilities does not include the provision or implementation of any of the relevant objectives. The argument is made that the reduction of congestion on the local and regional network (traffic is diverted to and will remain longer on the national network) will free-up road space for pedestrian and cycle facilities and offer the opportunity to improve local public transport services and connections to Sallins Train Station. There is little evidence that the Council are pursuing a strategy to improve public transport services (or to encourage service providers to do so) or infrastructure 5. 2.7.2 The Council confirmed that it has made no progress on the provision of bus priority routes in Naas, or in the provision of the public transport interchange or the park and ride facility. The Council also confirmed it had no timeline for the implementation of the street improvement scheme (improving cycle and pedestrian facilities and providing bus pull-in bays) from Sallins Main Street (junction of Millbank Road) to Naas town centre (junction of Poplar Square). Without a clear strategy and timeline to quickly implement improvements to public transport and passive transport facilities in a planned manner the available space will likely be absorbed by private cars at peak time. The potential for increase in private car traffic on the local and regional network accessing the M7 will be hugely increased by the removal of the existing capacity constraints (the stick). Therefore I don’t accept that the proposed development forms part of an integrated sustainable multi-modal transport strategy and I believe that the cumulative impact of the two schemes will be an increase of modal split in favour of the private car for commuting, contrary to government transport policy under Smarter Travel. 2.7.3 The applicant strongly argued that the proposed development will facilitate bus commuting by freeing up road space and presented letters of support from Bus Eireann and the NTA; that bus transport has advantages over rail transport in terms of its flexibility and range of routes and its lower cost; that congestion on the road network reduces reliability and speed of the bus service and its overall attractiveness as a mode; and that the proposed scheme, in itself and taken with HA0045, has the potential to facilitate improved bus services. However, without the provision of reliable and frequent services and infrastructure and demand
5 Again, I would note the recent advertising of a ‘bus hub’ Part 8 scheme for Naas and the Sallins Road scheme HA0032.
n Bord Pleanála Page 29 of 5 management on the proposed upgrade M7 mainline it is likely that the available space will be absorbed by private car commuters given the greater advantages of the car over bus public transport.
2.8.0 Kildare County Development Plan 2.8.1 The County Council’s policies, objectives and aims in respect of transportation are set out in chapter 6 of the County Development Plan 2011, which I have reviewed in detail. The provision of the proposed Osberstown Interchange is provided for expressly under objective RP 2 ‘ to facilitate provision of an additional interchange along the M7 Naas by-pass serving access to Millennium Park ’ and is consistent with 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 ’. There is no specific objective for the provision of the R407 Sallins Bypass under the County Plan, however the proposal is consistent with objective RP 16 ‘to improve and re-align where necessary the Regional roads set out in Table 6.1 ’, which includes the R407 Kilcock to Naas Ring Road via Clane Inner Relief Road. 2.8.2 The County Plan also contains objectives and policies relating to the development of or promotion of public transport and sustainable transport modes, including (objective ST 3) the implementation of quality bus networks in the county, (objective ST 4) the improvement and further development of public transport including railway stations and (objective ST 6) promoting and facilitation improvements to existing public transport links. It is also an objective (GT 7), ‘ to prepare an integrated transportation strategy for Kildare, based on sustainability and better use of resources, in consultation with the NTA (MSTACK – Movement, Sustainable Transport and Accessibility in County Kildare) ’. Little, if any progress, appears to have been made in respect of sustainable transport objectives, however the proposed interchange and bypass infrastructure would not necessarily undermine the pursuing of those objectives. 2.8.3 It is a long term objective (LT 3) ‘ to develop a public transport hub near Naas which will connect road, rail transport and public bus transport ’ and (LT 4) to investigate the upgrading or relocation of existing stations to rectify existing constraints on the network 6. This is consistent with Council policy (NR 9) ‘ to co- operate with other agencies in the provision of additional links between the national road network and public transport especially rail and bus transport including strategic park and ride facilities ’ and with objective GT 4 ‘ to prepare parking strategies and investigate the appropriate locations for vehicular, bicycle
6 There’s no specific objective to relocate Sallins Train Station under the County Plan or the Sallins LAP
n Bord Pleanála Page of 5 and park and ride facilities within the county ’. No site, or potential site(s) have been identified for a public transport hub or park and ride within the vicinity of the scheme under the County Development Plan. The EIS indicates that the proposed bypass can accommodate an additional junction to serve a future public transport interchange.
2.9.0 Naas Town Development Plan 2011 2.9.1 The proposed interchange is consistent with objective RPO 6 to facilitate provision of an additional motorway interchange along the M7 Naas Bypass subject to the agreement of the NRA, appropriately designed and scaled to provide access to the Millennium Park and the Naas Northwest Quadrant masterplan lands. The proposed connection of the proposed Sallins Bypass to the interchange is consistent with objective RPO 5 to assess the possibility of providing a link road from the bypass to the existing / planned Naas Road network in conjunction with the NRA and NTA. 2.9.2 The provision of the proposed interchange is consistent with the objectives of the plan for the development of Millennium Park and the Naas Northwest Quadrant as the main economic growth area of Naas, which has been provided for in the zoning of lands for ‘enterprise and employment’ and the Plan recognises the different factors influencing economic development and seeks to upgrade transport infrastructure, improve the inter-urban non-national road network and seek opportunities for modal change (e.g. park & ride facilities) accordingly (section 3.5, p.27). 2.9.3 According to section 7.3.1 of the NTDP the Naas Integrated Framework Plan for Land Use and Transport (2003) largely remains the preferred strategy for the future development in Naas, however the plan shows neither the proposed interchange or the proposed bypass and can be regarded as superseded by the NTDP which is the statutory plan. There are a wide range of policies and objectives relating to the promotion of sustainable transport modes and it is the overall aim of the Council to promote ease of movement within and access to Naas, by integrating sustainable land use planning with a high quality, integrated transport system, and to support improvements to the road, rail and public transport network in a manner which is consistent with proper planning and sustainable development. It is an objective (GT1) to promote and facilitate the implementation of a sustainable transport strategy for Naas and (GT2) to development Naas as a model town for sustainable transport. A number of objectives refer to the provision (or investigation of provision) of a park and ride facility in Naas (GT10, GO4, STO5 ) and to develop a quality bus network / bus priority routes (STO1 and RWO3). Based on the responses of the Council’s
n Bord Pleanála Page of 5 representatives to the hearing, the Council would appear to have made little or no progress on the objectives relating to public/sustainable transport.
2.10.0 Sallins Local Area Plan 2009 2.10.1 According to section 5.6 Transportation Infrastructure notes that congestion is a problem in town. One of the key elements of the plan is indicated as objective TR3(iv), which seeks construction of a new road from Clane road to Naas Road (Sallins bypass) and objective TR3(v), which seeks the construction of a new road from the main street to the bypass, indicated as one of the key elements of the plan. Section 7.5 suggests that the 24.1ha zoned for office, light industrial and warehousing development has remained undeveloped due to absence of the bypass that would provide easy access. The proposed bypass can therefore be seen to be consistent with the objectives of the LAP. 2.10.2 The LAP also includes a number of objectives relating to public transport infrastructure, including (PT5) to co-operate with and support public transport agencies and private stakeholders in developing a public transport interchange including expansion of bus and train station facilities on lands adjacent to the Sallins bypass route (PT6, PT7 and PT8 are also relevant to the proposed interchange 7). The plan (section 5.6) supports a strategic park and ride as part of the public transport interchange - there is no objective for a strategic park and ride under the LAP however this may be regarded as integral to the interchange. The possible location for such an interchange is constrained by, inter alia, the location of the rail line, the canal, existing development and a site area of sufficient size. No location for the proposed facility is identified under the LAP (or under any other statutory plan). The Council’s representative, Michael Kenny A/Director of Planning, indicated that no progress has been made in progressing these objectives. The EIS indicates that the proposed bypass will be able to accommodate an additional junction to access a possible public transport interchange however no location of possible or feasible sites for such a junction have been identified. The route selection process for the proposed bypass did not include the proposed public transport interchange as a constraint as no site for that facility had been identified. The location of the proposed bypass will further constrain the possible location of the future public transport interchange. 2.10.3 Conclusion - The Council’s approach to the implementation of its objectives for transport infrastructure for the Naas and Sallins conurbation, particularly those
7 There is no specific objective to relocate the existing train station, although it is (possibly) implied under PT5 and would be supported by the County Development Plan long term objective. It does appear to have been and objective under the previous plan.
n Bord Pleanála Page 2 of 5 objectives relating to public transport, has not, heretofore, been an integrated approach and is not a sustainable approach in view of its objectives for the economic and population growth for the region. However, the proposed interchange and bypass (and link road to Sallins town) are provided for under the statutory plans for the area and are generally consistent with the indicative locations identified for same.
3.0 Need for project 3.1 The need for the scheme, as set out under the EIS, can be summarised as: • Inadequate connectivity between national, regional and local road networks; • Inadequate capacity on the existing R407 Sallins Road; • Presence of regional traffic on local road network in Naas; • Presence of traffic in the urban centre of Sallins Town; • To facilitate planning and zoned development lands; Additional justification is given relating to government policy support, provision of a balanced road network and facilitating a focus on sustainable transport policies, however I do not consider these to demonstrate a ‘need’ for the development concerned, particularly as the EIS does not identify any government or regional policy that identifies the proposed infrastructure. 3.2.0 Economy 3.3.1 The EIS submits that the proposed development will facilitate an efficient integrated transport infrastructure, necessary to reduce level of congestion and allow economic growth, by providing relief to the national, regional and local road network and by improving accessibility to the public transport network and enabling the advancement of sustainable transport planning at a local level. However the scheme does not comprise or provide for an integrated transport system but a car based traffic system. 3.3.2 The EIS submits that the current lack of capacity at the interface between the regional/local traffic network and that national network leads to re-assignment of traffic along the motorway between interchanges at periods of peak flow , reducing the capacity of the existing M7 Naas bypass and that the proposed development will provide significantly more additional network improvements by providing a more balanced connectivity between national and regional road networks and will not adversely affect the carrying capacity of the M7 . This appears to conflict with the position of the applicant under HA0045 that
n Bord Pleanála Page of 5 congestion on the national network results in traffic diverting onto the local network. 3.3.3 Sections 3.2.1.2 and 3.2.1.3 suggest that there is existing congestion on Sallins Main Street at peak periods that will be immediately relieved by the proposed bypass. The EIS does not put forward a strong case for a bypass of the R407, notwithstanding the anecdotal evidence that peak hour congestion may warrant it. 3.3.4 The applicant puts forward no case for the economic costs associated with the absence of the proposed infrastructure, nor the benefits associated with the provision of same. The scheme does not actually provide for an efficient integrated transport system. The proposed development will constrain the site selection for proposal to relocate the train station, to provide a ‘park and ride’ facility and a public transport interchange and may stymie the achievement of those sustainable transport objectives as the route selection process did not take these proposals into consideration and the possible sites will necessarily be restricted to the vicinity of the railway line. The EIS acknowledges that an additional roundabout can be accommodated on the bypass to facilitate access to that facility. The location of the potential access will be further complicated by the wide variation of road levels of the proposed bypass relative to the levels of the adjoining lands. No sites have been identified, either in land use zoning, specific local objectives or otherwise, to identify a suitable location, or locations for the subject sustainable transport objectives. 3.3.5 The EIS submits that the bypass will form a natural barrier to the expansion of Sallins town and that the town will therefore be consolidated. Given the evident constraints (canal, railway line, etc.) it is likely that the proposed public transport infrastructure could only be provided outside of the bypass and outside the Sallins LAP boundary. 3.3.6 The R407, a strategically important transport corridor between Naas and Kilcock, suffers from a lack of direct connection to the national road network at the M7 corridor. The proposed development provides an opportunity to create a direct connection between the proposed R407 bypass and the M7, facilitating compliance with the principle of ordering roads in a hierarchy (national to regional, regional to local) whilst improving the access to the primary economic growth town of Naas, a Large Growth Town I and primary growth town under the RPGGDA.
n Bord Pleanála Page of 5 3.4.0 Common Appraisal Framework 3.4.1 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). 3.4.2 Economy conclusion – A fairly weak and unsupported case is put forward. 3.4.3 Safety – No comparison of existing road traffic accidents rates and predicted road accident rates, or the severity of road accidents are provided for the existing and proposed routes. The case put forward by the applicant is one-sided and unsubstantiated. No information is put forward to support the view that the scheme is needed on road safety grounds, or that there will be any benefit or dis- benefit arising from the scheme in this regard. 3.4.5 Environment – It is logical to assume that the rerouting of traffic to the bypass and interchange will have benefits in terms of air pollution, noise and severance. The EIS does not quantify this relative to any recognised (or unrecognised) thresholds that would support the case that the scheme is needed to address these existing impacts. For example, at what level of traffic does severance become an issue? Are local air quality standards being breached, or likely to be breached? Through-traffic will still occur, yet the benefit / improvements are not quantified. 3.4.6 Accessibility and Social Inclusion – The EIS submits that the reduced traffic in Sallins will facilitate safer travel by vulnerable road users and facilitate improved bus services by ‘making provision for those less able to afford the luxury of private cars’ (3-6). Whilst there are policies to support an integrated public transport system, almost no progress has been made in pursuing them. There is no timeline to implement a proposed street improvement scheme to the existing R407 through Sallins to Naas, and it not clear that the scheme provides any significant and consistent priority to vulnerable road users (pedestrians and cyclists). Without progress on such matters the proposed scheme will make little difference and vehicular traffic will fill the void. 3.4.7 Integration – it is submitted that the M7 Osberstown Interchange and R407 Sallins bypass scheme is necessary to allow the integrated multi-modal transport strategy to work. There is no actual formal sustainable multi-modal transport strategy under the County Development Plan, Naas Town Development Plan or Sallins LAP and the EIS refers to only a selection of policies from the plans. The proposed scheme does not provide for an integrated multi-modal transport strategy, the Local Authority has made no progress on pursuing sustainable transport objectives under the plan, has no timeline within which to pursue critical
n Bord Pleanála Page 5 of 5 objectives necessary to achieve some sort of integrated multi-modal transport system and the proposed R407 road improvement scheme, which provides for improved cycle and pedestrian facilities, has no timeline for implementation. The freeing up of congested road space at peak hour may assist cyclists and pedestrians if appropriate road-space and priority is allocated to those modes. It may also assist bus transport, but this will be of little consequence if there is no strategy to provide additional services or improved services. 3.4.8 Conclusion – In my opinion the EIS puts forward a quite a weak and unsubstantiated case for the proposed scheme. It is evident to me that the proposed interchange is required to provide more direct access from the national road network to a major strategic land-bank within the region and to accommodate for future traffic growth arising, within a settlement that is identified for significant growth under the National Spatial Strategy and the Regional Planning Guidelines for the GDA. Furthermore, the proposed interchange and bypass is needed to provide more direct access to Sallins (and Clane) from the national road network and to relieve traffic congestion on the local and regional network through Sallins Main Street and Monread Road, Naas. I therefore consider the proposed infrastructure to be justified in terms of traffic need.
4.0 Alternatives
4.1.0 ‘Do nothing’ 4.1.1 This assumes the implementation of the Naas-Newbridge M7/N7 upgrade and proposed replacement Newhall Interchange under HA0045. In the do minimum scenario congestion will remain on the regional and local route, with pressure on key Naas radial and orbital routes increasing over time, notwithstanding the implementation of other planned regional and local network improvements. There are limited additional road network improvement options available due to the constraints on and function of existing routes. The lack of capacity on the local and regional network will ultimately impact on development potential. The deliverability of public transit, street-based public transport and walking and cycling networks at local and regional levels is constrained by the limitations of the existing network as well as by existing and increasing levels of traffic congestion. Traffic volumes on the R407 will continue to increase, exacerbating severance and traffic-related environmental impacts in the urban area.
4.2.0 Public Transport Only 4.2.1 The EIS indicates that reliance on public transport would need to significantly deliver modal shift at regional and inter-urban levels in order to cater for the
n Bord Pleanála Page of 5 increase in traffic volumes that the proposed bypass achieves. The applicant submits that there is a high level of regional bus connectivity between Naas and Dublin and a good quality rail service on the same route, but that take up is constrained by accessibility and connectivity at local level due to traffic congestion. The applicant therefore does not consider a public transport only option to be a practical or deliverable option and submits that the proposed scheme will benefit public and alternative transport through facilitating (or making possible) investment at a local level in public transport, cycling and walking. There is no assessment of this alternative in terms of environmental effects as required under section 50.
4.3.0 Upgrading existing interchanges 4.3.1 This forms part of the ‘do minimum’ scenario. It is submitted that the alternative fails to address the capacity constraints on the regional and local road network on the approaches to the interchanges and elsewhere, particularly the current deficiency in the road hierarchy between R407 and M7, and would not support the continued development of public transport services (and access thereto) or the long term transport strategies of the County Council (park and ride, enhanced regional railway station). There is no assessment of this alternative in terms of environmental effects as required under section 50.
4.4.0 Alternative locations for interchange and bypass 4.4.1 A route selection exercise for the proposed R407 bypass was undertake by Fehily Timoney Gifford Ltd in 2007 and the FTG Preferred Route Corridor Report is appended to the EIS, appendix A3.1 V4. A supplementary route selection assessment was conducted by ARUP in 2013 and the Supplementary Route Selection Report is included in appendix A3.2,V4. A summary of the route option assessment is included in table 3.1 (p.3-15) of the EIS. I have reviewed both documents and I would accept that a systematic review of the potential significant environmental effect of the various combination of alternative interchange and bypass route locations has been undertaken and that the location / route selected by the applicant over the alternatives has been justified.
4.5.0 Interchange form and Road Scheme cross-section 4.5.1 The incremental assessment of the (bypass) scheme cross-section and interchange form is included as appendix A3.3, V4 of the EIS. I am satisfied that the design selected has been justified on economic and road safety grounds. The assessment of the alternatives in road cross-section and interchange form, more particularly as set out in the applicant’s EIS, does not take account of
n Bord Pleanála Page 7 of 5 environmental effects as required by section 50. However, in my opinion the proposed single lane design at the north end of the scheme and dual carriageway cross section at the southern end of the scheme results in a reasonable balance of minimising environmental effects and consideration of other factors. 4.6.0 Conclusion – On balance, notwithstanding that the EIS does not assess the alternatives in terms of environmental effects in accordance with the requirements of section 50 of the Roads Act, I am satisfied that the EIS has selected those alternatives that are both feasible to implement and that minimise environmental effects to a reasonable degree, having regard to NRA Project Appraisal Guidelines and the DTTaS Common Appraisal Framework.
5.0 Design details
5.1.0 Proposed Osberstown Interchange 5.1.1 The proposed interchange is of dumb-bell design, with two roundabouts either end of a single dual-carriageway overbridge. The interchange incorporates free- flow segregated slip lanes to / from the M7 to / from the proposed R405 Sallins bypass and to / from the proposed distributor road connecting into the Western Distributor Road in Millennium Park / Naas NWQ. Auxiliary lanes are provided to the M7 at the interchange junction. . 5.1.2 The EIS indicates that the proposed slip road cross-sections comply with NRA DMRB addendum to UK DMRB TD 22/06 and NRA DMRB TD 27/11 and are appropriate to the projected traffic volumes, and that the auxiliary lane cross section complies with NRA DMRB TD 27/11. NRA DMRB standards TD39/34 (The Design of Major Interchanges) 8, 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. The EIS refers only to TD22/06 and TD16/06, but not to TD39/34. I could find no reference to TD 16/06 under the NRA or UK DMRB standards and I assume reference to same in the EIS is merely a typo for TD16/07. It would be reasonable for the Board to assume that the final interchange design will be compliant with DMRB standards.
8 http://nrastandards.nra.ie/road-design-construction-standards/func-startdown/190
n Bord Pleanála Page 8 of 5 5.2.0 R407 Sallins Bypass 5.2.1 A Type-1 Single Carriageway is proposed for the section north of the junction with the Sallins Link Road, which is purportedly in accordance with the NRA DMRB TD 27/11 table 3 (Rural All-Purpose Roads Dimensions of Cross Section Elements). This was superseded by TD 27/14 in April of this year to include, inter alia, the requirement to provide mandatory cycle facilities in accordance with TD 300 and RCD Series 000, however the same cross-section standards apply to type 1 single (S2) carriageways with 3.0m verge and 2.5m hard shoulder either side of the 7.3m (2 X 3.65m lanes) carriageway. The revised standard includes a minimum standard for rural cycle facilities. The western verge will be reduced to 0.6m at the River Liffey and Grand Canal bridge structures in accordance with table 6 of TD27/11 (note this standard is unchanged in TD 27/14). The design speed is stated as 85kph, with a proposed posted speed limit of 80kph. 5.2.2 A Type-2 Dual Carriageway is proposed for that section south of the junction with the Sallins link road, with a total road width arising from 3.0m western verge inclusive of 0.5m nearside hardstrip, 7.0m carriageway, 1.5m central reserve inclusive of 2 X 0.5m offside hardstrip, 7.0m carriageway and 3.0m eastern verge inclusive of 0.5m hardstrip, a total of 21.5m. 5.2.3 Again, the standard applied, NRA DMRB TD 27/11, has been superseded by DMRB TD 27/14, but in the case of Type-2 Dual Carriageway there has been a material change in the cross-section of the nearside verge which increases from 3.00m to 5.00m and this would seem to increase the total cross-section of the road by 4m to 25.5m. There would appear to be no change in the required width of the hard-surfaced cross-section of the road (or bridge structures) and there is no reason to believe the additional verge width cannot be accommodated within the boundary of the scheme without material change in the environmental impacts. I would defer to the technical expertise of the applicant’s consultants I this regard
5.3.0 Sallins Link Road 5.3.1 The carriageway width is proposed at 7m for the full length of the roadway up to the junction with Clane road and the applicant submits that the road has been designed to a 50kph design speed and that the 50kph limit will apply. The width is based on the DMURS standard (see fig 4.55 DMURS) for link streets frequently used by larger vehicles. At the hearing the applicant explained that the road was considered to be likely to be frequently used by larger vehicles due to the land use zoning for the area, on the direction of the Local Authority, and therefore an increase in the standard 6.5m width (3.25m X 2) was deemed
n Bord Pleanála Page 9 of 5 warranted by the designers. The DMURS does not define ‘ frequently used ’ or ‘frequent access’ and therefore it is not possible to make a determination on this matter. 5.3.2 I would question the application of a blanket standard along the full length of the route as it will traverse four different land use zones including ‘H: office / light industry & warehousing’, ‘F: Open space and amenity (including town park objective)’, ‘B: Residential’ and ‘A: Town Centre’ without any obvious change in the design approach. Having regard to DMURS the western section of the route can be seen to be a step-down or transition zone between the bypass (85kph design speed). The roundabout junction will provide a clear marker for drivers and make them more alert to a change in the nature of the road, however the proposed road width (7m) is only slightly less than that the Type-1 single carriageway to the bypass north of the said junction, and the 7m width is the same standard as applies to Type-2 Single (S2) carriageways. DMURS suggests design approaches in such circumstances, including: • Measures that provide enclosure, such as large trees; • Applying transitional geometric measures such as the narrowing of carriageways; • Applying changes to carriageway materials. The applicant indicated that the cross section of the link road allowed for the planting of trees within the 1.5m verge located between the carriageway and the proposed cycle lane and footway and the applicant agreed to provide for such planting as part of the scheme. 5.3.3 No change in design approach is applied to the road within the town centre land use zone at Clane Road. Two issues arise in this regard. According to DMURS it would be appropriate for the link road to provide for a gateway design feature, such as the ‘ use of robust surfaces and / or change in colour…to alert drivers of change driving conditions ’ (p.81). This is particularly important as the town centre zone is almost completely undeveloped and the character of the carriageway and street structure, alone, will influence driver behaviour until an appropriate urban character develops. Such development can be expected to be facilitated by the improved connectivity of Sallins town centre to the national road network.
n Bord Pleanála Page of 5 5.3.4 More importantly, the design approach 9 to the street should change within the town centre area to reflect the different traffic priorities and the higher level of pedestrian and cyclist traffic that can be expected (and to be encourage) here when the area is developed. The town centre zone, notwithstanding its undeveloped condition, has the highest place value and therefore the design approach must provide for greater levels of connectivity, higher quality design, promote pedestrian movement and provide for a higher integration between (not segregation of) different road users. The road function (link) is moderate, therefore there is a moderate onus on the design to optimise movements of public transport and cater for pedestrian and cyclist movements. The design approach promoted under DMURS is relatively simple, being underpinned by four key design principles: • Integrated street networks; • Self-regulating streets; • Measurement of street quality is based on the quality of the pedestrian environment; • And that design be plan-led and multidisciplinary in approach; 5.3.5 The myriad of different design measures, which include, inter alia, reduced road width, varying vertical and horizontal alignment, road surfacing, varying integration (non-separation) of road users, frequency of crossings for pedestrians, integration of street furniture, are also simple to understand but may or may not be appropriate depending on the different contextual and road function factors and is open to interpretation. In my opinion, having regard to the details and principles contained within the DMURS, within the high value context of the town centre land use zone, it would be appropriate to reduce the width of the street (to 6.5m from 7m), replace the grass verge with a more urban hard- landscaping (possibly with trees) to increase the space allocated to pedestrians, integrate cyclists with the road carriageway, provide for a different road surface, and provide for frequent crossings for pedestrians, and to emphasise the change in nature of this section of road by the introduction of a gateway feature. 5.3.6 However, DMURS principle no.4 is that street design has to be plan-led and determined by a multidisciplinary team. It is therefore not feasible (or, indeed, appropriate) to address this issue by a prescriptive condition. The Board may consider it appropriate to attach a condition requiring the applicant to revisit the design of that section of road design to demonstrate clearer compliance with the
9 Note, the scale of the drawings is very small and it is not possible to discern details to any great extent. The issue of design of the link road was discussed at the hearing and the applicant did not submit that there was any different design approach along the length of the link road and no material change is evident from the drawings.
n Bord Pleanála Page of 5 design principles of DMURS having regard to the site’s high ‘place context value’ and providing for an integrated design to the entirety of that section of street rather than merely to one side (north side) of the street. 5.3.5 Another design issue of concern relates to the elevated nature of much of the link road. According to the cross-section / elevation details submitted to the hearing 10 , the road will be elevated c.12m above current ground level at the junction (ch.0+00) with the proposed bypass, drops down approximately 3m above ground level 300m east of the junction and then continues at a level between 3-2m above ground level for c.500m before meeting existing ground level another c.100m east at the proposed junction with Millbank Estate. The high level of the proposed link road at the western end is determined by the level of the Sallins Bypass, which is determined by the bridge crossings of the canal and the River Liffey. In response to questioning at the hearing Ms Eileen McCarthy, on behalf of the applicant, submitted that this was necessary to accommodate the bridging of the abandoned canal and for drainage reasons (at ch.0+300) - I would accept this. It can be seen from the spot levels (section drawing no.CSK-150) that the existing ground levels along the route, between the abandoned canal and the Millbank Estate junction, vary in an uneven manner, whereas the road level drops by c.1.28m generally in an even manner 11 . It would therefore not be feasible to require that the finished surface level not exceed the existing ground level by a set amount (or range) as the said levels are not consistent. Rather the finished level of future development of the adjoining lands adjacent the route will have to be designed to address the proposed roadway. 5.3.5 The applicant’s position, as put forward by Ms McCarthy, is that the link road will be able to accommodate access (in the form of a limited number of access road junctions) from the adjoining zoned lands and that the lands could be developed up to the road (up to where exactly is unclear). She also indicated that direct access would not be permissible. It would appears to me that the design of the road does not consider, in an integrated plan-led approach, the land uses and the nature, design and layout of development that are to be accommodated along the link road. It appears to me that the road is designed as a frontage free elevated distributor road that severs the lands either side, with little or no though to future access or crossing points (for example to the proposed town park), or at what point along the route frontage development will be appropriate (for example at the office development area, at the residential zone or the town centre). In this regard the DMURS advises that ‘ Designers should seek to promote active street
10 Drawing CSK-150 ‘Sallins Link Road Plan & Profile Sheet 1 of 1. 11 The proposed road surface actually undulates slightly between those two points.
n Bord Pleanála Page 2 of 5 edges on all streets within cities, towns and villages ’ (p.72). Without provision for these elements and proper integrated plan-led consideration of this link road, which will transition between place contexts of increasing value from west to east, integrated and co-ordinated development will not occur. I am therefore satisfied that the proposed link road does not comply with the requirements of the DMURS. I would advise the Senior Inspector that should she consider making a favourable recommendation on the proposed scheme, the issue of link roads compliance with DMURS should be addressed by condition.
5.4.0 Distributor Link Road 5.4.1 DMURS is also relevant to the proposed distributor link road within the proposed developing urban area of the Naas NWQ and Millennium Park. Given the ‘ low ’ place context value (a little above that of industrial estate), there is less need to provide for connectivity, to provide for higher quality design, to promote pedestrian movements or to integrate different road users. In addition, the ‘moderate ’ road movement function (in reality I would consider it to be closer to ‘high ’ given the function of connecting the national network to the regional network) means that the design must optimise movements of public transport and cater for pedestrian and cyclist movement and may cater for higher volume of traffic. Given the function of the road, the high level of traffic it is intended to carry, the absence of pedestrian facilities across the proposed interchange (and, it is reasonable to assume, the lack of need for same) pedestrian facilities would not be appropriate. As a viable and reasonable alternative reasonable cyclist route is proposed between the Western Distributor Road and the proposed Sallins Bypass (north of the rail tunnel), I would accept that cyclist facilities are not required (and are not appropriate) on the proposed distributor link. Separate public transport facilities would also seem to be currently unnecessary, although this might be something that could be explored by the authority and provided at a later date, if necessary. 5.4.2 The proposed distributor link road is a transition zone between the high speed motorway network and the regional / local network within a developing urban area. I do not agree with the applicant’s position (in response to questioning at the hearing) that the roundabout junction would sufficiently slow down approaching traffic. The existing roundabout includes segregated free-flow left- hand slip lanes for traffic entering / exiting the proposed distributor road, reducing the necessity for traffic to slow on approach to the junction. I would consider the provision of large street side tree planting along the proposed distributor road approaching the junction to be an appropriate design element to signal the transitional function of the route, which should help reduce traffic speed and improve road safety in this area based on the principles under the DMURS. As
n Bord Pleanála Page of 5 no footpaths or cycleways are proposed and there are significant lands either side of the proposed route, there would appear to be no reason this planting could not be provided. The nature and location of the planting could be agreed by condition. 5.4.3 Junction – I am concerned about the impact of the proposed distributor link road and Western Distributor Road junction in terms of its impact on pedestrians and cyclists travelling west-east on the northern side of the Western Distributor Road. The DMURS discourages the use of large roundabouts (radii >7.5m) in urban areas due to the difficulties posed to pedestrians and cycles by roundabouts. It also strongly discourages the incorporation left-turn slip lanes at junction for the same reason. In this case the roundabout junction is very large and includes segregated free-flow left-hand slips to the northern arm of the roundabout junction. Whilst cycle lanes and footways are provided on the approaches to the junction, the junction will present a difficult barrier to east-west pedestrian / cycle traffic along the northern side of the Western Distributor Road. 5.5.4 The roundabout is already in situ, constructed as part of the Western Distributor Road, but the junction with the proposed distributor link road, including the segregated free-flow left-hand slips fall within the boundary of the scheme. Where such junctions already exist, the DMURS encourages their replacement with signalised junctions, or to retrofit them to be more compact and/or pedestrian and cycle friendly, as appropriate, where any major upgrade works are proposed (p.105 The DMURS). It is vital that east-west pedestrian traffic be accommodated across the said junction. Having regard to the moderate context- value of the area (a developing business park and mixed use area to accommodate the expansion of Naas) and to the high level function of the subject roads, the DMURS would not rule out a roundabout, but the size and design of a roundabout suitable to appropriately accommodate pedestrian and cycle traffic is unlikely to be of sufficient capacity to accommodate future vehicular traffic. As the capacity of roundabouts are generally lower than that of signalised junctions (p.105, The DMURS), it would be appropriate to replace the existing roundabout junction with a signalised junction of a design suitable to accommodate pedestrian and cycle traffic, or to retrofit the junction to be more compact and/or pedestrian and cycle friendly, as appropriate, in accordance with Government design policy. I would advise the Senior Inspector that should she make a favourable recommendation to the Board, it would be appropriate to address this issue by condition.
n Bord Pleanála Page of 5 5.6.0 Other 5.6.1 The proposed scheme entails modifications, alteration or realignment of part of the Canal Road, the Osberstown Road and the Clane Road. Given the nature, character and speed limit of those roads the proposed design, in terms of carriageway width and verges appear reasonable.
5.7.0 Conclusion 5.7.1 The design of the proposed Osberstown Interchange and R407 Sallins Bypass appear to be designed to NRA DMRB standards, except for verge width to the southern dual carriageway section which is substandard the 5m width required by DMRB TD 27/14 adopted in April 2014, replacing TD 27/11 to which standard the road has been designed. The design of the proposed amendments to the Osberstown Road, the Canal Road and the Clane Road all appear to be reasonable. 5.7.2 I am satisfied that large street side tree planting should be provided along the proposed distributor road approaching the junction with the Western Distributor Road as a design element to signal the transitional function of the route and help reduce traffic speed and improve road safety in this area based on the principles under the DMURS. I am also satisfied that the existing roundabout junction should be replaced with a traffic controlled cross junction with provision for pedestrian and cycle facilities, or to retrofit the junction to be more compact and/or pedestrian and cycle friendly, as appropriate, having regard to the requirements of DMURS. These issues can be addressed by condition. 5.7.2 I am satisfied that the Sallins Link road has not been designed in accordance with the principles of the DMURS, having regard to the intended road function and the place value context of the lands through which it will traverse, and that it has not been planned in an integrated manner taking account of the future access requirements and frontage development having regard to the land use zoning objectives pertaining to lands along the proposed route. This is particularly pressing at the eastern end of the route on lands zoned town centre under the Local Area plan. I would advise that the design, including the road width, and the nature of pedestrian and cyclist facilities (segregated versus integrated) and the presence of grass verges be re-examined having regard to the changing place context value along the full length of the proposed link road between the proposed R407 Sallins Bypass and Clane Road (existing R407) 12 . This issue could be appropriately addressed by condition. It may be useful for
12 The small scale of the drawings make it difficult to discern the detailed features of the road way, including where grass verges are proposed.
n Bord Pleanála Page 5 of 5 the applicant to identify suitable locations for access roads onto the link and suitable locations for frontage direct access development along the route, in order to inform the design of the route having regard to the changing place context value there-along. This would be a more integrated approach to planning of the route, but it is not necessary to require this detail by condition.
6.0 Traffic and transport impact
6.1.0 Impact on M7 6.1.1 According to table 5.5 of EIS, the proposed scheme will result in an increase of AADT on the M7 of between 12% (west of proposed junction) and 8% (east of proposed interchange) in 2015 and between 9% (west of interchange) and 11% (east of interchange) in 2030 13 . From table 5.6 of the EIS, the predicted increase in AADT translates to a maximum increase of 10% AM peak and 7% PM peak two-way traffic in 2015 and 8% AM peak and 6% in PM peak two-way traffic in 2030 (west of the interchange in each case). The highest increase (per traffic direction) would be an 18.6% increase in westbound traffic, west of the proposed interchange, in the AM peak in 2015 (from 2150 vehicles to 2550). The highest traffic volume with the scheme is predicted to be east of the interchange in the westbound direction in the PM peak in 2030, with 4,800veh/hr and that in the AM peak eastbound traffic flow will be 4,650veh/hr. It should be noted that the actual capacity of the upgraded M7 (three lanes) is estimate at 4800veh/hr in the EIS to HA00454 14 and therefore it would appear that the combined impact of the proposed Osberstown / Sallins scheme will result in the M7 operating at or close to capacity at peak hour. 6.1.2 The increase in mainline traffic in the ‘do something’ scenario is significant. The EIS explains that the increase results from the redistribution of regional traffic on the network through the provision of a more direct route to Naas NWQ and to R407 Clane Road, allowing that traffic to remain on the motorway for longer 15 and therefore to have less of an impact on local road network, which is an objective of the scheme. This is a logical explanation and the result is generally acceptable and consistent with the NRA Spatial Planning Guidelines. 6.1.3 It is the applicant’s position that the proposed increased capacity of the M7 (under HA0045) in advance of the proposed scheme will ensure that the increased traffic demand can be catered for. According to EIS HA0045, the M7
13 The predicted increase from the cumulative impact of the Naas-Newbridge (HA0045) and Osberstown-Sallins (HA0046) schemes in the EIS to the former scheme is 13% and 15% in 2030. 14 Table 4-1, p.6 of ‘Technical Note 10’ received 20/05/14. 15 It will also allow traffic to come off earlier as evidenced by the 2% decrease in westbound traffic west of the interchange in 2030, resulting from traffic departing the M7 at the proposed interchange rather than at Newhall.
n Bord Pleanála Page of 5 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; that the proposed Osberstown Interchange and Sallins bypass is predicted to increase the traffic demand on the M7 by between 8-10% (due to the diversion of traffic), leading to increased congestion and further delays on the M7 at peak periods; that the proposed Osberstown-Sallins Scheme would lead to increased congestion and further delays on the M7 at peak and is dependent on the completion of the upgrade of the M7 16 (section 18.5, EIS HA0045). 6.1.4 Having regard to the details submitted to HA0045 (Naas/Newbridge/Newhall Scheme), I am not satisfied that it has been demonstrated that this section of motorway is (on average) operating at / in excess of capacity at peak, except between Newhall and Great Connell junctions. Based on NRA ATC data for the M7 2010, which contrasts with the applicant’s survey data and capacity assessment to EIS HA0045, there may be some capacity available on the section between Newhall and Maudlins where the proposed Osberstown Interchange is to be located - between c.300PCU and 500PCU west/southbound in the PM peak and up to 230PCU in the AM peak east/northbound. Based on table 5.6 of the EIS it would appear that the traffic flow arising from the proposed interchange and bypass would absorb this capacity. Furthermore, in the future year scenarios (EIS HA0045) this section of the M7 is estimated to be operating well in excess of capacity. It can therefore be reasonably concluded that the proposed Osberstown Interchange and Sallins Bypass is dependent on the proposed upgrade of the M7. 6.1.3 The EIS indicates that based on NRA DMRB TD 9/12, the theoretical capacity AADT of the M7 Naas Bypass is 55,500 vehicles (for a wide motorway cross section), above which congestion can be expected, however actual capacity is dependent on a number of factors, including the proportion of peak hour traffic. The CRF (Congestion Reference Flow) value for the road link (from UK DMRB TD 46/97) i.e., the flow at which the carriageway is likely to be ‘congested’ in the peak periods on an average day (where hourly traffic demand exceeds maximum sustainable hourly throughput) is critical. The minimum desirable CRF AADT for a 2-lane motorway standard roadway is 65,000 two-way flow, with links achieving a value above this indicative of acceptable driving conditions. The EIS submits that the CRF value in 2006 was 89,000 AADT but that it dropped to 61,000 AADT in 2012 reflecting the increase in peak commuter period traffic volumes, confirming the necessity to upgrade the M7 Naas Bypass to dual-three lane
16 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 7 of 5 standard in advance of the Osberstown Interchange and R407 Sallins Bypass Scheme. I have reviewed TD 46/97 and note the formula for calculating the CRF, however the full data to make that calculation is not on file or available on the NRA website and the EIS does not include the details of its calculation. The Senior Inspector may consider it reasonable to accept this calculation at face value. 6.1.4 The information on file indicates that the proposed development will result in very significant journey time reductions and journey speed improvements at AM and PM peak 2030 along a number of routes. These statistics appear to relate to trips taking place predominantly on the local and regional network, although commencing on the M7 /N7 mainline in an interchange. It is unclear whether the statistics relate to the average journey or these routes, or to the cumulative savings / improvements of all journeys (I could not find it explained in the EIS or in the Traffic Model Report contained in Volume 4 of the EIS). The details of the modelling exercise are not contained within the EIS or its appendices, however, it can reasonably be assumed that the proposed scheme will improve traffic flow and hence reduced journey times and improve journey speed on the local and regional road network as strategic traffic will be accommodated more directly and for longer on the national road network.
6.2.0 Junction capacity 6.2.1 The applicant’s modelling of the proposed Osberstown Interchange using VISSIM micro-simulation traffic modelling software demonstrates that there will be sufficient capacity available at the roundabout approaches and slip lane merges to cater for the projected traffic flows without any impact to ‘through traffic’ on the M7 mainline. I consider this is reasonable. I am a little concerned that the model will not have taken into account the impact of the provision of the proposed infrastructure on the development potential and, hence, the true potential of traffic generation, in the ‘do-something’ / ‘with development’ scenario. However given the apparently high-capacity design of the proposed interchange (with segregated slips and auxiliary lanes), the low delays and queues predicted on the M7 off-slips, and the location of two existing interchanges in relatively close proximity serving Sallins and Naas (Maudlins and Newhall), I do not consider it likely that the capacity of the proposed interchange is such as to result in any impact on ‘through traffic’ on the M7 mainline. 6.2.2 The EIS assessed the potential impact on other junctions in the vicinity, including the Distributor Link Road and the Western Distributor Road junction, the Sallins bypass and Clane Road junction, the Sallins Link Road and Clane Road junction, and the Sallins Bypass and Sallins Link Road junction. The analysis indicates
n Bord Pleanála Page 8 of 5 that the junctions would operate within capacity in the ‘do something’ scenario in 2030.
6.3.0 Impact on public transport 6.3.1 The EIS submits that the proposed scheme will have positive impacts on public transport in the short term by improving journey times and reliability for public transport services, including increased accessibility and connectivity with Sallins Train Station, through reduced traffic volumes on the local and regional network. I would accept that this is a plausible positive impact, however without the provision of improved public transport services to provide an alternative to private car for local trips within Naas an Sallins, and the implementation of demand management measures to restrict car usage on the network, it is likely that the freed-up capacity on the currently congested local and regional network will be absorbed by private cars either through diverted, delayed or induced trips. In this regard the Naas Town Development Plan 2011 (p.73) recognises the high rate commuting to work (75%) 17 and to school (54%) by car. The proposed scheme therefore offers the opportunity of a positive impact on public transport, but without proper planning this opportunity may be lost. 6.3.2 The EIS submits that in the longer term the proposed scheme will enable the Local Authority’s strategic public transport objective including facilitating an enhanced Public Transport Interchange and a strategic ‘park and ride’ adjacent the railway and accessed off the proposed Sallins bypass. The EIS indicates that the proposed bypass can accommodate another roundabout junction but does not indicate where. The options for locating same are very limited given the road’s varying horizontal alignment and the location of the railway and the situation is not helped by the failure of the County Development Plan or the Sallins Local Area Plan to zone a site to accommodate the proposed facility. The EIS indicates that the route selection did not include the potential location of the stated public transport facilities as a determining factor in the route selection process for this reason. This can hardly be considered unreasonable. Rather the route of the bypass, assuming it is authorised by the Board, will be one of the determining factors in the future selecting of a location of the proposed stated public transport facilities. 6.3.3 The EIS does not take account, or provide a proper analysis of the potential adverse impacts on the full transport network including each of the relevant transport modes due to the change in relative costs and benefits between public transport and private car arising from the scheme taken cumulatively with the
17 The applicant put this figure at 67% at the hearing.
n Bord Pleanála Page 9 of 5 Naas / Newbridge Bypass and Newhall Scheme. Reduced congestion on the M7 mainline and improved access to the mainline from the two proposed interchanges will make commuting by private car more attractive relative to rail and bus services, thereby potentially reducing the numbers of rail and bus commuters. A reduction in the number of bus and rail users will make bus and rail alternatives less viable, possibly necessitating an increase in fares and / or a reduction in services, thereby making those services even less attractive and undermining existing and ongoing government investment in those services. A thorough assessment of the impact on public transport would be appropriate in view of Government transport policy as set out under Smarter Travel. 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.
6.4.0 Impacts on cyclists and pedestrians 6.4.1 The EIS submits that the proposed scheme will have a positive impact on the pedestrian and cyclist environment. An alternative cycle and pedestrian route is proposed north and south of the M7 by connecting the existing routes along the Western Distributor Route (Cycle Route N6) to the Canal Road (green way Route K13) and, in turn, connecting the Canal route to the R407 Sallins Bypass north of the rail underbridge. The bypass incorporates an amenity cycle track and footway on the Sallins Town side of the bypass (and on the proposed Sallins bypass link road) and makes provision for a future connection to future cycle network and pedestrian routes along the Canal (Cycle Route K10). 6.4.2 In addition, the pedestrian and cyclist environment will benefit from reduced traffic levels, including a reduction in severance on Sallins Main Street and the opportunity to enhance pedestrian and cyclist facilities. Subsequent to the lodging of this application the Planning Authority has submitted an application for EIS Screening in respect of a proposed road improvement scheme for the R407 between Naas Town Centre up to the proposed junction between Clane Road and the Sallins bypass Link Road (ref.noHA0032), which provides for improved
n Bord Pleanála Page 5 of 5 pedestrian and cyclist facilities. The Council’s response to questioning at the hearing revealed that it has no timeline for implementation of the subject scheme.
6.4.3 In addition, I have concern about the potentially significant adverse impact of traffic accessing/egressing the proposed Distributor Link Road (between the proposed interchange and the Western Distributor Road) on cyclist and pedestrian traffic using the cycle lanes and footways on the Western Distributor Road. Due to the design of the existing roundabout (with segregated free-flow left-hand lanes) and the level of traffic, the link road junction will present a very difficult (and dangerous) obstacle for pedestrian and cyclists to traverse, particularly at peak time. I have addressed this issue under ‘Design Details’, above.
6.5.0 Network statistics 6.5.1 The comparative network statistic for the different design year scenarios are provided under section 5.6 of the Traffic Model Report (appendix A5.1, Book 2, Vol.4 of the EIS). The statistics relate to total vehicular kilometres, total network travel time (hours), average speed and average trip length for the AM peak, inter peak and PM peak hours, but not for the annual average daily traffic. 6.5.2 In general the traffic modelling found that the ‘do something’ scenarios 18 resulted in a reduction in the total number of vehicular kilometres travelled, a reduction in the total network travel time, an increase in average network speed and a slight reduction (or no change) in average trip length over the respective design year ‘do-minimum’ scenario. The benefits (in terms of reduced network time and increased speed) were found to be more pronounced in the ‘do something 2’ scenario (i.e. with both interchange and bypass) than in the ‘do something 1’ scenario (the interchange alone). I would caution that these statistics do not relate to the average annual daily traffic but to peak hours only. More importantly, the statistics are based on a model that takes no account of the potential for induced traffic and takes no account of the differences in demographic and employment growth (arising from differences in development potential) and, hence, traffic growth that are likely to arise from the provision of the subject infrastructure. 6.5.3 One of the government’s key targets under Smarter Travel Transport Policy is that the total kilometres travelled by the car fleet in 2020 will not increase significantly from current total car kilometres. The EIS reports that the development will result in a reduction in the total number of vehicles travelled which would clearly suggest that the scheme supports government policy.
18 ‘Do something 1’ interchange alone; ‘do something 2’ interchange and bypass.
n Bord Pleanála Page 5 of 5 However, it is my understanding that the total vehicular kilometres travelled relate only to traffic within the LAM boundary for trips that originate and/or finish within the LAM. It does not include through traffic trips and it is unclear whether it includes that portion of LAM trips that take place outside of the cordon. The projected reduction in total vehicular kilometres is misleading and, in particular, does not take account of the potential for increased commuting trips (and lengths of same) using the upgraded M7. This concern relates primarily to the proposed upgrade of the M7 rather than to the proposed interchange and proposed Sallins Bypass.
6.7.0 Induced traffic 6.7.1 I have addressed the issue of ‘induced traffic’ in detail in my assessment on the concurrent application for the proposed M7 Naas-Newbridge Upgrade and replacement Newhall Interchange Scheme (HA0045). 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. 6.7.2 The baseline traffic information demonstrates that the traffic on the mainline is highly congested at peak and that trips on the mainline are temporally diverted to avoid congestion (as evidenced by extended peaks0700-0900 AM peak and 1600-1900 PM). The mainline upgrade will greatly increase peak hour capacity on the mainline motorway and will result in contraction of the extended peak hours to fill the increased mainline capacity. The proposed Osberstown Interchange and Sallins bypass (and replacement Newhall Interchange) will greatly improve ease of access onto and off of the upgraded mainline M7 from Newbridge, Naas and Sallins and therefore will also be likely to result in induced traffic. 6.7.2 Downstream capacity constraints on the N7 and on the M50 may impact the overall level of induced traffic that would occur on the upgraded section of road.
n Bord Pleanála Page 52 of 5 This effect is complicated by the dispersed destination of M7 traffic (according to Mr Sheils of Aecom 19 , 60% of N7 traffic diverts before the M50 ring). The predicted AADT at N7 east of the Johnstown Interchange is 84,550 in 2030 (table 5-8, TMR) in each scenario. NRA DMRB TD 9/12 does not provide an indicative capacity for three-lane carriageways (55,000 AADT is the corresponding figure for two-lane motorway) and the EISs to this and the concurrent applicant (HA0045) do not state the predicted AADT capacity of the proposed upgraded three lane motorway. 6.7.3 The EIS to the Naas/Newbridge/Newhall Scheme (HA0045) indicates that spare capacity of 600veh/hr eastbound and 400veh/hr westbound would be available in 2030 with the proposed M7 upgrade in the AM and PM peak, respectively (total three lane capacity of 4,800veh/hr without traffic management). The EIS to the Osberstown/Sallins Scheme indicates that the available capacity westbound in the PM peak will be absorbed by the cumulative development of the M7 and Osberstown/Sallins schemes (4,800veh/hr), and that available capacity will be approached eastbound in the AM peak with 4.650veh/hr by 2030, without taking account of the potential for induced traffic.
6.8.0 Development potential 6.8.1 Access to Sallins and Naas and Newbridge from the two existing interchanges is constrained, congested and circuitous. The replacement Newhall Interchange and proposed Osberstown Interchange will provide two high-capacity interchanges opening up far more direct access routes major lands zoned for development (including, in particular, Millennium Park / Naas NWQ, but also in Newbridge, Sallins and Clane) thereby increasing the development potential of those lands 20 . It is not unreasonable, therefore, to assume that the demographic and employment growth factors would be significantly different in the ‘do something’ scenario in the absence of current infrastructural constraints. As a consequence the traffic generating potential of the LAM lands could be expected to be greater. There is nothing to suggest that the applicant’s traffic assessment took into account the differing development potentials between the ‘do minimum’ and ‘do something’ scenarios.
6.9.0 Conclusion
19 Response to cross-questioning on HA0045. 20 For example, section 7.5 of the Sallins LAP 2009 suggests that no development had taken place on the 24.1ha area zoned for ‘office, light industry & warehousing’ and office development due to the absence of the bypass access. The vastly improved accessibility facilitated under the proposed scheme can therefore be expected to have a significant impact on development potential
n Bord Pleanála Page 5 of 5 6.9.1 On balance I am satisfied that the proposed Osberstown interchange and Sallins bypass will not, in themselves, result in significant adverse impacts on traffic and the road environment and appreciable improvements can be expected through Sallins Main Street and Monread Road, Naas through the diversion of existing traffic onto the M7 and away from those routes. I am not satisfied that the differing development potentials arising from the increased accessibility between the ‘do minimum’ and ‘do something’ scenarios has been factored into the traffic modelling and the applicant’s assessment of environmental impacts, but the lands concerned are zoned for such development and the settlements concerned are identified for significant growth in regional planning documents. It is the cumulative impact of the said improved accessibility, combined with the increased capacity of the M7 mainline under HA0045 that generates significant potential to increase traffic on the mainline, and on the network generally, through induced traffic (temporally diverted traffic, new traffic and traffic diverting from different modes) and to increase total vehicular kilometres travelled, perhaps significantly. 6.9.2 In the absence of the proposed M7 upgrade the existing capacity constraints would be expected to limit traffic growth, however the applicant has submitted a strong argument, supported by the traffic analysis data, that the proposed Osberstown Interchange and Sallins Bypass Scheme cannot be accommodated without the prior completion of the proposed M7 Naas / Newbridge Bypass Upgrade Scheme. Based on the information available to me, I would accept the applicant’s position in this regard.
6.9.0 Traffic impact - without Sallins bypass 6.9.1 The Traffic Model details provide the projected traffic along 72no. links in the ‘do min’ scenario and in the ‘do some 1’ (i.e. only interchange) scenario and the ‘do some 2’ (interchange and bypass) scenario for the future design years 2015 and 2030. Section 20.4 addresses the potential environmental impacts of the interim scheme (i.e. the Osberstown Interchange minus the bypass), however details are provided only for 45 of the 72 links. The EIS assessment of the interim scheme is cursory. It reports that the interim scheme results in a higher increase in traffic on the Western Distributor Road between R407 Sallins Road and the Distributor Link Road connecting to the interchange and that traffic volumes on the M7 approach to the M7 Osberstown Interchange are lower that with the addition of the Sallins bypass. The proposed interchange and the Western Distributor Road roundabout are predicted to operate well within capacity. 6.9.2 The EIS indicates that the proposed development will have a positive impact on public transport in terms of reducing traffic volumes on the local and regional
n Bord Pleanála Page 5 of 5 road network. Whilst this may be true of some links, the traffic through Sallins will increase over the ‘do min’ and ‘do some 2’ scenarios, thereby making access to the train station more difficult for all transport modes. In addition, the interim scheme will not facilitate the achievement of public / sustainable transport objectives under the Kildare County Development Plan and Sallins LAP. 6.9.3 The adverse impact on public and alternative transport modes is therefore likely to increase modal share of the private car above that considered in the transport model 21 , with consequential increased adverse impacts in terms of traffic congestion, emissions, etc. The significance of this impact is difficult to quantify, but an increase in traffic on the local and regional network would clearly undermine the justification for the scheme which is the removal of such traffic and thereby facilitating the development of sustainable transport modes in accordance with government policy under Smarter Travel. 6.9.4 Section 20.4 addresses the environmental impacts of the interim scheme, however these are generally outside the remit of my assessment. I would note, in particular, that (section 20.4.5.2) it does not take account of the increasing severance impact on Sallins town centre arising from increase in traffic in the interim scheme. The reduction in community severance within Sallins (Main Street) is one of the main reasons used by the applicant to justify the scheme in the ‘do something 2’ scenario. Severance and other adverse environmental impacts will therefore increase in Sallins and on the Main Street, but only by 3% over the ‘do minimum’ scenario 202022 . The increase in traffic levels on Main Street in the ‘do something 1’ over the ‘do something 2’ (interchange and bypass) will be 52% in 2015 and 63% in 2030. 6.9.5 I would therefore strongly advise the Senior Inspector that the two pieces of infrastructure be constructed and commissioned as a single project in order to ensure the positive environmental impacts envisaged by the scheme, including the facilitation of public and alternative transport modes, are attained and / or can be facilitated.
6.10.0 Cumulative traffic impacts 6.10.1 Section 20.3 of the EIS submits that the concurrently proposed upgrade of the M7/N7 mainline forms part of the baseline ‘do-minimum’ scenario, as it is required to be developed in advance of the proposed new interchange and bypass, and is automatically included in the ‘do something’ scenario. On this
21 Note, the traffic model used by the applicant cannot actually take account of modal split. 22 By 3.7% in 2015 and 4.7% in 2030.
n Bord Pleanála Page 55 of 5 basis the cumulative impacts have been addressed under the relevant chapter of the EIS. This is reasonable.
6.11.0 Construction traffic impacts 6.11.1 The potential impacts from construction traffic are detailed in section 4.4.11 and section 5.6 of the EIS. It is the strategy to direct construction vehicles away from the local road network and that they will be required to use designated primary national and regional routes to access the site. Use of local roads will only be used where no alternative construction route options are available, which is reasonable. It is envisaged by the applicant that access for the delivery for the majority of site materials will be via the Western Distributor Road, the M7 and Clane Road R407. 6.11.2 It will be necessary to use the local road network to access the area north of the railway and south of the canal for the purpose of constructing the foundations to the temporary supports to the railway track, but trucks will exit the site onto the local road south of the railway, travel under the existing railway tunnel and then re-enter the site immediately north of the railway line. Once the supports are in place the tunnel will be constructed under the railway line and there will be no requirement to use the local road. Due to the height restrictions on the existing tunnel only smaller trucks and machinery will be able to take this route. 6.11.3 Construction traffic will travel via Clane Road and Millbank Road along the route of the proposed link road to construction section 4 (central section) of the proposed bypass. I assume that this will entail the routing of traffic from the M7 via the Western Distributor Road and then via Sallins Main Street as there is no obvious northern route. Without knowing the location of the quarry pits serving the proposed development, it is not possible to determine the traffic route, an issue that was addressed in some detail in questioning at the hearing. No definite location of the quarries to be used was given. The total number of HGV movements estimated to be generated by the construction of sections 4-6 of the scheme is 91,600, amounting to c.235 movements per day. If access is restricted to regional or higher order roads, then this traffic will have to pass through either Sallins Main Street (south of Millbank Road) or Clane and Prosperous (assuming Allen quarry is used – it was identified as a possible supplier by the applicant at the hearing). This equates to a 21% increase in HGV AADT. This would be a significant impact, particularly where that traffic travels within residential areas. However, the impact would be of temporary duration and therefore, in my view, acceptable. It may be possible to mitigate the impact by splitting traffic routes, possibly on a 50:50 ratio, to avoid the full impact of traffic being concentrated on a single route. It may be appropriate to address this issued by way of condition.
n Bord Pleanála Page 5 of 5 7.0 Traffic modelling
7.1.0 Traffic model 7.1.1 The details of the traffic analysis contained in chapter 5 of the EIS are a summary of the details provided in the Traffic Modelling Report (TMR) contained in appendix A.5.1, Vol.4, Book 2 of the EIS. The EIS indicates that the model used was that model developed by AECOM for the M7 Naas to Newbridge Bypass Upgrade Scheme (concurrent application for EIS approval HA0045), but was subjected to increased refinement to reflect some of the existing and future zoned land uses with the Naas and Sallins Hinterland based on the Development Plans. From the details on application HA0045, the model used is a traffic assignment (fixed demand) model using VISUM. It was used to create a local area model (LAM) with a defined cordon set within the NRA’s National Traffic Model. 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 and 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. 7.1.3 There are legitimate concerns regarding the potential for the proposed M7 Upgrade Scheme (see my assessment report to HA0045) 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. The increased accessibility to the national network from Sallins and Naas and the wider area arising from the proposed Osberstown Interchange and Sallins Road
n Bord Pleanála Page 57 of 5 scheme will also have potential to induce traffic and to increase competition with the public transport network, but I consider this of concern only in terms of cumulative impact with the proposed M7 upgrade. A variable demand model may be considered the appropriate model under the PAG criteria. 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) only became available subsequently. 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 section 5.2. 7.1.4 The issue of induced traffic is primarily of concern relating to the proposed Upgrade of the M7 Naas-Newbridge Bypass upgrade to three lanes and not in respect of the proposed Osberstown Interchange and Sallins Bypass infrastructure.
7.2.0 Development growth 7.2.1 The growth in traffic within the NTM and the LAM is the same with or without the provision of the infrastructure proposed. This is not realistic but arises due to the nature of the model used. The absence of proposed infrastructure (such as the Sallins Bypass) has been recognised as a constraint on development of zoned lands and it is reasonable to assume that once these constraints are removed development potential will be released. It follows that either the NTM’s medium traffic growth scenario is incorrect in the ‘do minimum’ scenario or in the ‘do something’ scenario but that it cannot hold true for both scenarios. 7.2.2 Given the identification of Naas as a large growth town 1 under the RPGGDA, the primary importance of Naas as the economic driver of the region under the County Development Plan and the zoning of the Naas Northwest Quadrant and Millennium Park as a major economic driver for the Naas region under the NTDP, the opening up of access to this area through the proposed Osberstown Interchange (in addition to the opening up of access to zoned lands in Sallins) is likely to have significant implications for the development potential of the area and, in turn, the traffic generating potential of the area. The cumulative impact of the two schemes does not take this potential growth into consideration 23 . The findings of the Naas Growth exercise contained in appendix G to the TMR (appendix A5.1 of Vol.4, Book 2 of the EIS) were not used to inform the actual traffic growth for the 2030 scenario, rather they were used to inform the
23 The proposed replacement Newhall Interchange will also have significant implications for development potential at Togher Business Park and north / east Newbridge.
n Bord Pleanála Page 58 of 5 percentage distribution of future traffic growth (i.e. the NTM medium growth scenario) within the subzones within Naas NTM zone (zone 504). Whilst the methodology used in the exercise appears, in general, to be reasonable and valid for the purpose used, it also serves to demonstrate the significant growth potential of the area which has not and cannot be taken into account in the applicant’s traffic model and, in my opinion, undermines the applicant’s traffic model. 7.2.3 The applicant’s growth forecast assumes the construction of 2,720 dwellings by 2030, compared to the NTDP target of 3,610 by 2017. Assuming the resolution of the Osberstown WWTP capacity issue, the NTDP target will surely be achieved (and possibly exceeded) by 2030 and therefore the applicant’s assumption for dwellings is an underestimate. In contrast, the study’s assumptions for economic and employment growth (build out of 80% of lands) is not 7.2.3 The study assumed an 80% build out of the employment related zoned lands (total 83ha) by 2030. Given the nature of the infrastructure proposed, the nature and location of the concurrent proposal for a new motorway interchange at Millennium Park within the Northwest Quadrant Area under HA0046 and the overall economic strategy for Naas under the NTDP to direct and encourage economic growth toward areas zoned for employment uses, particularly towards the NNWQ area, it would seem probable, assuming a continued upturn in the national economy to 2030, that a high proportion of development will occur. Significant economic development of Naas is envisaged under the RPGGDA, nonetheless an 80% build out of the total employment zoned lands by 2030 is unlikely to be a realistic outcome by 2030. 7.2.5 In response to questioning by the inspector under HA0046, Mr Kenny, Acting Director of Planning, would not comment on pre-planning consultations for Millennium Park and the Northwest Quadrant Area as he considered them confidential. He, also, would give no indication as to whether there was a feeling of pent up demand for the development of that area and what level of development he might expect to be forthcoming in the near / medium future. 7.2.6 Mr Kennedy, Planning Consultant with RPS, submitted that the future development of the NNWQ area would be nothing like the density of development that was envisaged under the NNWQ Masterplan given the changed economic circumstances. The low density layout and comparatively low plot ratio of the permitted Kerry Group Ltd development (reg.ref.13/500018) would support this. The NTDP allows for a range of plot ratio standards from 2.0 to 0.25 depending on the site location (from town centre to outer suburban remote from public transport), from which I would expect the plot ratio of
n Bord Pleanála Page 59 of 5 development within the Millennium Park will vary between 0.25 and 0.5. The applicant based the development growth for employment lands on a plot ratio of 0.25. Compared to the plot ratio of about 0.2 at permitted the Kerry Group Ltd technology and innovation centre development, the assumption of a 0.25 is not unreasonable. 7.2.7 Conclusion Development Growth – The applicant’s ‘future growth’ study demonstrates that there is potential for residential development growth (and, hence, traffic generation growth) far in excess of that taken into account in the applicant’s LAM, but I would expect that the level of commercial development assumed in the applicant’s exercise is highly unlikely to approach anywhere near the 80% built out by 2030 assumed in the applicant’s ‘future growth’ exercise. As indicated above, the development growth potential will necessarily be materially different in the ‘do minimum’ and ‘do something’ scenarios for the future design years. There is no information on the development growth factors included for in the NTM / LAM (derived from CSO POWCAR data) and therefore it is not possible for me to determine whether the growth potential is overestimated in the ‘do minimum’ scenario or underestimated in the ‘do something’ scenario.
7.3.0 Traffic growth 7.3.1 General – Traffic growth was determined by CSO population and employment projections and car ownership growth. I have already addressed the issue of whether the development growth included in the model is realistic in respect of the ‘do minimum’ and ‘do something’ scenarios. These concerns carry forth directly to traffic growth which is also the same in both scenarios. 7.3.2 The ‘future growth’ exercise was used to determine the allocation of traffic demand on the network between the sub-zones to Naas 504 zone. Based on the information available to me I have concluded that the potential for residential development is likely to exceed the future growth assumed in the study, whereas the employment development is likely to be far lower. The total level of traffic generated by residential development will likely be greater than predicted and the total level of traffic generated by employment development will be less. The imbalance in residential versus employment development will result in different potential for local traffic generation, linked trips (22.5%) and reverse commuting than has been assumed in the LAM. It is not clear how significant this will be to the traffic modelling. 7.3.3 Having regard to the TRICS Good Practice Guide 2012, I do not consider the applicant’s use of TRICs in the ‘future growth’ exercise to be correct in respect of how it was applied to employment development. The applicant included sites, such as Burton Hall in Leopardstown and Taney Drive in Dundrum which are not
n Bord Pleanála Page of 5 comparable to the Millennium Park / Naas NWQ in that they are easily accessible by Luas and bus as well as on foot and bicycle and therefore will not generate a similar proportion of car trips as development in Millennium Park. I suspect that the sites at Cardiff, Caerphilly and Edinburgh may be similarly unsuitable. the correct approach would have been to use the total number of trips generated per m2 floor area at those sites to calculate an average for total trips (all modes) per floor area at within the Naas employment zone and then apply a realistic modal split for Naas to that figure to calculate the generation of car trips per floor area. The applicants approach will have resulted in a lower car trip generation than would otherwise have been the case. 7.3.4 Mr Shiels of Aecom submitted to the hearing that the trip rates in the ‘future growth’ exercise did not feed directly into the LAM, as traffic growth is determined by the NTM for each zone. Rather it was used to allocate the proportion of in-out trips generated within the subzones to 504. This would appear to be reasonable, however I would caution that the car trips under table 4.3 of the ‘future growth’ study (appendix G of the TRM) should be taken as under-representing the potential for traffic generation for enterprise and employment within the zone. 7.3.5 Smarter travel - The National Traffic Model 24 takes account of the government’s transport policy under Smarter Travel and limits potential traffic growth through the limiting of growth in car ownership to a cap of 2.1m cars, but does not 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). 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. 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. 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) but it can be assumed that it applies to the Smarter Travel target year 2020. The situation regarding car ownership rates between 2020 and design year 2030 was not stated. 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)). The new approach is more realistic.
24 Mr Sheils indicated that the National Transport Model, a national variable demand model, does take account of Smarter Travel modal split targets but cannot currently be used to model future year scenarios.
n Bord Pleanála Page of 5 7.3.7 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 new train station and 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 failure to provide the said infrastructure has significant implications for modal split and traffic generation, and more so with the increased capacity to accommodate private cars on the M7 mainline and on the network generally and the resulting development will of necessity be more car dependent. In view of this, it would be unrealistic for the LAM to have included a reduction in modal share of cars for peak hour commuting traffic and the incorporation of a cap of car ownership at a moderate level would, on the face of it, appear to be more reasonable. 7.3.8 Conclusion – Having regard to the issues outlined above in respect of induced traffic (at and upstream of the proposed M7 Bypass upgrade) and development growth (within Naas), it would seem likely that traffic growth will have more significant potential than has been taken account of in the applicant’s traffic analysis and EIS. The impacts on the nation, regional and local roads will therefore be greater, the positive impacts less significant and the adverse traffic impacts more significant than have been predicted.
8.0 Conclusion and recommendations 8.1 The proposed Osberstown Interchange and the proposed Sallins Bypass are infrastructure that will provide greatly improved access to an urban area identified for significant growth under the National Spatial Strategy, the Regional Planning Guidelines for the Greater Dublin Area, the Kildare County Development Plan 2011, the Naas Town Development Plan 2011 and the Sallins Local Area Plan 2009 and I therefore consider the proposed development to be acceptable in principle. 8.3 I have significant concerns regarding the design of the proposed Distributor Link Road and the proposed Sallins Link Road development vis-à-vis the requirements of the Design Manual for Roads and Streets (2013). In particular, I consider the junction of the Distributor Link Road with the Western Link Road will present a serious obstacle and a serious traffic hazard to pedestrian and cycle traffic travelling along the northern side of the Western Distributor Road due to the design of the junction (non-compliant with the required standards) and the level of vehicular traffic that will traverse this junction. An appropriately designed
n Bord Pleanála Page 2 of 5 signalised junction that takes account of pedestrian and cycle traffic in lieu of the existing roundabout junction would be appropriate in my opinion. 8.4 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 and development potential for the cumulative proposed development. These impacts have the potential to be significant, adverse and long term. However this concern relates primarily to the proposed upgrade of the M7 Naas-Newbridge Bypass rather than to the proposed Osberstown Interchange and Sallins Bypass infrastructure. 8.5 I am not satisfied that the traffic model used (an assignment model) was appropriate given the nature of the cumulative schemes, 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 wholly relied upon. However, again, this concern relates primarily to the proposed upgrade of the M7 Naas-Newbridge Bypass. 8.6 My concerns regarding the traffic model used are compounded by concerns regarding the baseline assumptions in the National Transport Model that prevents the Local Area Model from taking account of traffic impact arising from the change in development potential facilitated by the provision of access to the national motorway network. 8.7 Notwithstanding that the concerns outlined above relate primarily to the proposed upgrade of the M7 Naas-Newbridge Bypass and not to the proposed Osberstown Interchange and Sallins Bypass, the applicant has categorically stated (and submitted detailed evidence to support this position) in both this and the concurrent application that the Osberstown Interchange cannot be
n Bord Pleanála Page of 5 accommodated without the prior upgrade of the M7 Naas-Newbridge to three lanes. I would accept the applicant’s position. I would therefore advise the Senior Planning Officer that a favourable recommendation in respect of the Osberstown Interchange and Sallins Bypass Scheme would be appropriate subject to the condition that the construction and the commissioning of the Osberstown Interchange and Sallins Bypass does not precede the commencement and commissioning of the proposed M7 Naas-Newbridge Upgrade and Newhall Bypass. 8.8 In addition, I would highlight that the positive environmental effects purported to arise from the proposed scheme result from the combined Osberstown Interchange and Sallins Bypass infrastructure. The provision of the Osberstown Interchange without the Sallins Bypass will not result in the positive impacts on Sallins Main Street, will result in less positive impacts on Monread Road and other parts of the local road network, will not improve access to Sallins rail station or significantly improve the situation for public transport services. I would therefore advise that the Osberstown Interchange and Sallins Bypass Scheme be undertaken and commissioned as a single project. 8.9 Should the Senior Inspector be inclined to make a favourable recommendation on the proposed development, the following conditions may be appropriate having regard to the content of my assessment. 1 The design of the proposed Sallins Link Road shall be modified, in compliance with the requirements of the ‘ Design Manual for Urban Roads and Streets ’ (2013) to take account of the increased place context value of the adjacent lands from west to east, as determined by the land use zoning objectives applying thereto. In particular, the revised design should revisit the road width, and the nature of pedestrian and cyclist facilities (segregated versus integrated), the removal of proposed grass verges, having regard to the changing place context value along the full length of the proposed link road between the proposed R407 Sallins Bypass and Clane Road (existing R407). Reason: In order to comply with the requirements of the Design Manual for Urban Roads and Streets (2013), in the interest of pedestrian and cyclist safety and in the interest of proper planning and sustainable development
2 (a) Large street side tree planting shall be provided along the proposed Distributor Link road approaching the junction with the Western Distributor Road (between ch.0+100 and the junction), the nature and spacing of which shall be agreed with the Planning Authority and the planting undertaken prior to commissioning of the proposed Distributor Link Road.
n Bord Pleanála Page of 5 (b) The roundabout junction between the proposed Distributor Link Road and the Western Distributor Road: (i) shall be replaced either with a signal controlled replaced with a traffic controlled cross junction with provision for pedestrian and cycle facilities, or; (ii) the existing roundabout junction shall be retrofitted to be more compact and / or pedestrian and cycle friendly, in compliance with the requirements of the Design Manual for Urban Roads and Streets (2013). Reason: In order to comply with the requirements of the Design Manual for Urban Roads and Streets (2013), in the interest of pedestrian and cyclist safety and in the interest of proper planning and sustainable development.
3 Heavy construction vehicles along Clane Road / Sallins Main Street accessing/egressing Millbank Road shall be routed north:south to/from direction of the Millbank Road junction on a ratio of approximately 50:50 on any one working day. Reason: To balance the impact of heavy construction traffic on those settlements and residential areas situated between the construction site and the quarries / facilities serving the development.
______John Desmond Inspectorate 12/08/14
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