J. D. C. A. & District Community Association CLG Company number 481750 www. Julianstowncommunity.com

Niamh Bn. Uí Loinsigh House Smithstown Julianstown BY Hand

The Secretary An Bord PLeanála 64 Marlborough street 1

RE: APPEAL AGAINST DECISION OF MEATH COUNTY CONCIL TO GRANT PLANNING PERMISSION FOR DEVELOPMENT AT STRAND ROAD, LAYTOWN, CO MEATH Planning Authority: Meath County Council Planning Authority File No: LB160330 An Bord Pleanála Case Ref.: PL17.247835

6 February 2017

Dear Sir

On behalf of Julianstown and District Community Association CLG (JDCA) I wish to lodge these observations in respect of the above planning application which was approved by Meath County Council on 8 December 2016.

Attached please find our full grounds of appeal and the reasons, considerations and arguments on which they are based. We confirm that all the relevant documents on the file, including previous submissions, have been inspected.

We enclose a cheque for €50 being the appropriate fee for this appeal.

Please direct all correspondence on this matter to Julianstown and District Community Association, Niamh Bn Uí Loinsigh House, Smithstown, Julianstown, Co Meath.

Yours sincerely

Julianstown and District Community Association CLG

Julianstown and District Community Association CLG, No. 481750 Directors: A Monahan, C Ó Domjnaill, J O’Shea, N UíLoinsigh, E Dolphin Observations on PL17.247835

1 INTRODUCTION

1.1 THE APPLICANT IS ALDI STORES (IRELAND) LIMITED, NEWBRIDGE ROAD, NAAS, CO KILDARE AND THE APPLICATION IS FOR THE DEVELOPMENT OF A DISCOUNT FOOD STORE AT STRAND ROAD, LAYTOWN, CO MEATH.

1.2 THE JDCA WISHES TO MAKE OBSERVATIONS ON THE APPEAL BASED ON THE FOLLOWING CONSIDERATIONS WHICH ARE SET OUT IN MORE DETAIL BELOW:

1. The development will lead to an unacceptable increase in the number of articulated HGVs travelling on Julianstown Main Street every morning. 2. The traffic impact assessment is inadequate because it does not: a. Consider the impact of the proposed development on the entire transport network b. Identify the catchment area served by the proposed development c. include 5 year and 15 year forecasts as required by guidelines d. take into account the cumulative impact of committed developments and vacant houses. 3. The impact of the proposed development on passenger car traffic in Julianstown has not been assessed due to the inadequacies in the traffic impact assessment. There is a likelihood that some visitors to the proposed development will drive by car via Julianstown and return on the same route. Since the traffic volumes using the Main Street in Julianstown are significantly greater than the capacity of the street, this increase is unacceptable and permission should be refused.

2 BACKGROUND AND CONTEXT

2.1 JULIANSTOWN IS A SMALL VILLAGE IN EAST MEATH. THE REGIONAL R132 ROAD WHICH WAS FORMERLY THE N1 MAIN DUBLIN-BELFAST ROAD BECOMES ITS MAIN STREET CONNECTING JUNCTION 7 OF THE M1 WITH . JULIANSTOWN SITS AT THE INTERSECTION WITH THE R150 LEADING TO LAYTOWN. WE HAVE ATTACHED A MAP IN SCHEDULE 1 SHOWING THE LOCATION OF JULIANSTOWN RELATIVE TO THE PROPOSED DEVELOPMENT. ALSO INCLUDED IN SCHEDULE 1 ARE PHOTOS SHOWING THE MAIN STREET IN JULIANSTOWN AND ITS HISTORIC BUILDINGS. THIS STREET IS CURRENTLY SUBJECT TO TRAFFIC VOLUMES IN EXCESS OF 20,000 AADT.

2.2 JULIANSTOWN HAD A POPULATION OF 616 IN 2011. IT IS A DESIGNATED ARCHITECTURAL CONSERVATION AREA. JULIANSTOWN HAS A RICH HISTORY AND THE BRIDGE IN THE VILLAGE WAS THE LOCATION FOR A DECISIVE BATTLE DURING THE IRISH REBELLION OF 16411. IT’S CHARACTERISTIC FEATURES INCLUDE A TERRACE OF SIX COTTAGES BUILT IN THE SWISS STYLE IN THE LATE 19TH CENTURY AS WELL AS THE FORMER RIC BARRACKS AND COURT HOUSE.

1 https://en.wikipedia.org/wiki/Battle_of_Julianstown

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2.3 JULIANSTOWN IS CLASSIFIED AS A “COMMUTER VILLAGE” IN THE MEATH COUNTY DEVELOPMENT PLAN 2013 TO 2019 (THE CDP). THE WRITTEN STATEMENT2 FOR JULIANSTOWN STATES THAT THE GOAL IS THAT:

“JULIANSTOWN WILL GROW INTO AN ATTRACTIVE, SAFE AND SUSTAINABLE VILLAGE. FOUNDED ON ITS RICH HISTORY AND ECOLOGY, IT WILL BE HOME TO A VIBRANT, CREATIVE AND ENTERPRISING COMMUNITY, WELCOMING TO ALL.”

2.4 STRATEGIC POLICY SP3 SEEKS:

“TO ADDRESS TRAFFIC PROBLEMS ON THE R132 THROUGH JULIANSTOWN”

2.5 STRATEGIC POLICY SP1 AIMS:

“TO PROMOTE THE FUTURE DEVELOPMENT OF THE VILLAGE AS A COMPACT SETTLEMENT WITH A PEDESTRIAN FRIENDLY ENVIRONMENT, A LEGIBLE AND COHERENT PHYSICAL FORM, AND A VARIETY OF LAND USES AND AMENITIES.” (EMPHASIS ADDED)

2.6 MA OBJ 1 REFERS TO TRAFFIC MANAGEMENT:

“TO INVESTIGATE THE EFFECTIVENESS OF, AND IF APPROPRIATE, PROGRESS THE IMPLEMENTATION OF, TRAFFIC MANAGEMENT AND TRAFFIC CALMING OPTIONS AND ENVIRONMENTAL MEASURES THROUGH JULIANSTOWN VILLAGE, IN CONJUNCTION WITH THE , DEPARTMENT OF TRANSPORT, SPORT AND TOURISM AND THE NATIONAL TRANSPORT AUTHORITY WITH A VIEW TO PROVIDING AN ENHANCED AND SAFER ENVIRONMENT FOR THE VILLAGE.”

2.7 ADDITIONALLY, JULIANSTOWN WAS THE NATIONAL PILOT PROJECT FOR VILLAGE DESIGN STATEMENTS AND JDCA WITH MEATH COUNTY COUNCIL3 DEVELOPED A VILLAGE DESIGN STATEMENT WHICH WAS ADOPTED IN 20104 THROUGH EXTENSIVE PUBLIC PARTICIPATION.

2.8 VDS POL AIMS TO:

“FACILITATE AND SUPPORT THE IMPLEMENTATION OF THE JULIANSTOWN VILLAGE DESIGN PLAN.”

3 TRAFFIC PROBLEMS IN JULIANSTOWN

3.1 DESPITE THE OPENING OF THE M1 MOTORWAY IN 2003, TRAFFIC VOLUMES PASSING THROUGH MAIN STREET REMAIN EXTREMELY HIGH WITH AVERAGE ANNUAL DAILY TRAFFIC (AADT)5 IN THE REGION OF 20,000 VEHICLES PER DAY. SINCE THE END OF THE FINANCIAL CRISIS THE VOLUMES HAVE STARTED TO GROW AGAIN AT A RATE OF APPROXIMATELY 2.5% PER YEAR. THE ACTUAL VOLUME IS LIKELY TO BE HIGHER SINCE THE TRAFFIC COUNTER EQUIPMENT IS INSTALLED TO THE SOUTH OF THE R150 JUNCTION AND DOES NOT COUNT VEHICLES COMING FROM THE WEST ON THE R150 AND TURNING LEFT TOWARDS DROGHEDA

2 CDP page 411 3 CDP section 7.1 4 http://www.meath.ie/CountyCouncil/Publications/HeritagePublications/File,44006,en.pdf 5 Data from https://www.nratrafficdata.ie

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AND TRAFFIC COMING FROM THE NORTH AND TURNING RIGHT ONTO THE R150 IN THE VILLAGE CENTRE.

3.2 IN TERMS OF HGVS ON AVERAGE AT LEAST 300 ARTICULATED LORRIES USE JULIANSTOWN MAIN STREET DAILY, WITH 55 PASSING BETWEEN 6AM AND 9AM. THERE ARE SIMILAR VOLUMES OF RIGID HGVS. PLEASE SEE THE SCHEDULE 2 WHICH CONTAINS AN EXTRACT FROM THE TII DATA DETAILING AVERAGE HOURLY TRAFFIC VOLUMES BY TYPE OF VEHICLE FOR 2016.

3.3 THIS TRAFFIC CAUSES NOISE, AIR POLLUTION, DAMAGE TO THE BUILT ENVIRONMENT AND CONSTRAINED MOBILITY (PARTICULARLY OR THE YOUNG, OLD AND INFIRM). THERE ARE VIRTUALLY NO COMFORTABLE PUBLIC AREAS IN THE VILLAGE. WALKING AND CYCLING ARE UNPLEASANT DUE TO THE NOISE AND THE HIGH NUMBER OF HGVS WHICH PASS THROUGH THE VILLAGE. IT IS IMPOSSIBLE TO HAVE A CONVERSATION OUTSIDE IN JULIANSTOWN WITHOUT SHOUTING.

3.4 THE BORD CAN EXPERIENCE WHAT IT IS LIKE IN JULIANSTOWN BY WATCHING THIS SHORT VIDEO: HTTPS://YOUTU.BE/KTPC3RNBAAQ

3.5 WHEN TRAFFIC IS BUSY AT THE AM AND PM PEAKS THERE ARE TAILBACKS OF SEVERAL KILOMETRES, AND WHEN TRAFFIC IS LIGHT AT NIGHT, CARS AND HGVS SPEED THROUGH THE VILLAGE WITHOUT OBSERVING THE 50KM/H SPEED LIMIT.

3.6 AS RECENTLY AS 1990 TRAFFIC VOLUMES IN JULIANSTOWN WERE ESTIMATED TO BE 8,000 VEHICLES PER DAY6 AND EVEN THEN, THIS VOLUME OF TRAFFIC WAS CONSIDERED TO BE EXCESSIVE FOR THE VILLAGE.

3.7 THE HUGE INCREASE IN POPULATION IN EAST MEATH SINCE 2000 HAS NOT BEEN ACCOMMODATED WITH ANY NEW ROAD INFRASTRUCTURE TO CONNECT WITH THE NATIONAL ROAD NETWORK. THE LARGE COMMUTER POPULATION IN THE AREA TRAVELS THROUGH THE MAIN STREET IN JULIANSTOWN TO ACCESSES THE M1 AT JUNCTION 7.

3.8 NEITHER THE EAST MEATH LOCAL AREA PLAN NOR THE ACCOMPANYING STRATEGIC ENVIRONMENTAL ASSESSMENT HAS ANY ASSESSMENT OF TRAFFIC IMPACTS AND ENVIRONMENTAL EFFECTS ARISING FROM THE RELEVANT PLANNING POLICIES DESPITE THE ENVIRONMENTAL HARM THAT IS BEING CAUSED IN JULIANSTOWN. WE CONSIDER THIS TO BE A SERIOUS OMISSION BY THE LOCAL AUTHORITY.

3.9 WE HAVE INCLUDED IN SCHEDULE 3 A COPY OF OUR BASELINE ASSESSMENT OF THE CURRENT ENVIRONMENTAL PROBLEMS IN JULIANSTOWN FOR CONSIDERATION BY THE BORD.

4 INCREASE IN ARTICULATED HGV TRAFFIC IN JULIANSTOWN

4.1 FROM THE INFORMATION ON THE FILE IT SEEMS THAT ALDI INTENDS TO SERVICE THE STORE FROM ITS NEWBRIDGE, KILDARE LOGISTICS CENTRE AND IT ANTICIPATES 1-2 ARTICULATED VEHICLE VISITS PER DAY7. THESE VISITS WILL BE COMPLETED BEFORE THE STORE OPENS8 (9AM SEVEN DAYS A WEEK). IN RESPONSE TO FURTHER INFORMATION ALDI STATED THAT THE HGVS WOULD ACCESS LAYTOWN VIA COLPE AND

6 “By-Pass ‘wll pose major problems for Julianstown’” Drogheda Independent 10 April 1992 7 Traffic Impact Assessment -March 2016 paragraph 8.4 8 Ibid paragraph 8.6

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BETTYSTOWN9.

4.2 THE SHORTEST ROUTE BETWEEN NEWBRIDGE AND THE SITE IS 100KM AND PASSES VIA JUNCTION 7 OF THE M1 AND THE R132 LEADING TO THE MAIN STREET IN JULIANSTOWN10 AND THEN ON TOWARDS COLPE. ASSUMING THAT EACH SERVICE VISIT RETURNS THROUGH JULIANSTOWN - AT A MINIMUM THE PROPOSED DEVELOPMENT WILL INCREASE DAILY ARTICULATED VEHICLE VOLUMES ON THE MAIN STREET IN JULIANSTOWN BY FOUR OR 1.3% AND BY APPROXIMATELY 8% BETWEEN 6AM AND 9AM.

4.3 IN OUR SUBMISSION THIS INCREASE IN ARTICULATED HGV TRAFFIC ON THE MAIN STREET IN JULIANSTOWN IS UNACCEPTABLE FROM A SUSTAINABLE PLANNING AND DEVELOPMENT POINT OF VIEW AND IS CONTRARY TO THE OBJECTIVES AND STRATEGIC POLICIES PERTAINING TO JULIANSTOWN AND THEREFORE PERMISSION SHOULD BE REFUSED.

4.4 IF THE BORD IS MINDED TO GRANT PERMISSION, WE SUBMIT THAT PERMISSION SHOULD ONLY BE GRANTED ON CONDITION THAT SERVICE VEHICLES DO NOT USE JUNCTION 7 OF THE M1.

5 INADEQUATE TRAFFIC IMPACT ASSESSMENT

5.1 WE RESPECTFULLY SUBMIT THAT THE TRAFFIC IMPACT ASSESSMENT (TIA) IS MATERIALLY DEFICIENT AND DOES NOT MEET THE STANDARDS SET IN THE NRA “TRAFFIC AND TRANSPORT ASSESSMENT GUIDELINES” (MAY 2014). WE SUBMIT THAT THESE DEFICIENCIES SHOULD BE ADDRESSED BY WAY OF A REQUEST FOR FURTHER INFORMATION SO THAT THE BORD CAN MAKE ITS OWN ASSESSMENT OF TRAFFIC IMPACTS ON THE ENTIRE TRANSPORT NETWORK INCLUDING THE MAIN STREET IN JULIANSTOWN.

5.2 ACCORDING TO THE NRA GUIDELINES:

“IT IS GENERALLY ACCEPTED THAT TRAFFIC AND TRANSPORT ASSESSMENT NEED TO CONSIDER THE IMPACT OF THE DEVELOPMENT PROPOSALS ON THE ENTIRE TRANSPORT NETWORK”

5.3 HOWEVER, THE TIA PROVIDED BY ALDI CONSIDERS ONLY VEHICULAR TRAFFIC IN THE VICINITY OF THE DEVELOPMENT AND THE IMPACT ON THE LOCAL ROAD NETWORK11. THIS DEVIATION FROM “GENERALLY ACCEPTED” PRACTICE IS NOT EXPLAINED IN THE TIA.

5.4 THERE ARE OTHER DEFECTS IN THE TIA MEANING THAT TRAFFIC IMPACTS CANNOT BE ADEQUATELY ASSESSED:

No definition of the catchment area

5.5 THE APPLICANT DOES NOT ADDRESS THE CATCHMENT AREA INTENDED TO BE SERVED BY THE PROPOSED DEVELOPMENT CONTRARY TO GUIDELINES. IT IS HIGHLY LIKELY THAT AS A SOPHISTICATED OPERATOR ALDI (WHICH HAS MORE THAN 120 STORES IN IRELAND AND USES A STANDARD MODEL) HAS INFORMATION

9 Response by TPS Ltd to item 6(b) of request for further information (10 November 2016) 10 The route via junction 8 (Duleek) is 10km longer, on poorer quality roads and involves vehicles stopping at the M1 toll situated between junctions 7 and 8 (source Google Maps) 11 Traffic Impact Assessment -March 2016 paragraph 2.0

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ABOUT THE INTENDED CATCHMENT FOR THE PROPOSED DEVELOPMENT.

5.6 THIS SHOULD BE PROVIDED AS PART OF THE TIA.

5.7 IN OUR SUBMISSION, THE CATCHMENT AREA IS LIKELY TO EXTEND TO THE WEST AND SOUTH OF JULIANSTOWN DRAWING TRAFFIC FROM STAMULLEN AND ITS HINTERLAND12 THROUGH JULIANSTOWN FURTHER INCREASING TRAFFIC VOLUMES IN THE VILLAGE.

NO ASSESSMENT OF CUMULATIVE IMPACTS FROM COMMITTED DEVELOPMENT AND VACANT HOUSES

5.8 THE APPLICANT DOES NOT CONSIDER CUMULATIVE IMPACTS. THE ONLY TRAFFIC GROWTH FACTOR IDENTIFIED IN THE TIA IS AN INCREASE IN THE RATE OF CAR OWNERSHIP13. THIS ASSUMPTION IS GROSSLY WRONG AND MATERIALLY COMPROMISES THE TIA. THE LARGEST CONTRIBUTION TO GROWTH IN CAR TRIPS IN THE ROAD NETWORK IS THE CONTINUED HIGH GROWTH IN NEW HOUSING IN THE AREA. THESE FACTORS ARE QUANTIFIED IN THE EAST MEATH LOCAL AREA PLAN AND SHOULD HAVE BEEN CONSIDERED BY ALDI.

5.9 ACCORDING TO THE EAST MEATH LAP THERE ARE 1,41414 COMMITTED HOUSING UNITS YET TO BE COMPLETED OR OCCUPIED. IN ADDITION, THERE ARE 309 AND 464 VACANT DWELLINGS IN THE ST MARY’S (PART RURAL) AND JULIANSTOWN EDS15 RESPECTIVELY.

5.10 PER CENSUS 2016, THE CURRENT OCCUPANCY RATE IS 2.8 PER UNIT. THEREFORE COMMITTED UNITS WILL GENERATE A POPULATION INCREASE OF 3,959 WITH AN ADDITIONAL 2,164 FROM VACANT UNITS. THIS POPULATION GROWTH AND CONSEQUENT IMPACT ON THE TRANSPORT NETWORK SHOULD BE ASSESSED.

5.11 GIVEN THAT THE POPULATION WITHIN THE EAST MEATH LAP AREA IS LESS THAN 11,00016 THERE IS EVERY POSSIBILITY THAT THE POPULATION OF THE CATCHMENT AREA WILL GROW BY AS MUCH AS 60% IN THE MEDIUM TERM.

5.12 THE TIA SHOULD ASSESS IMPACTS ARISING FROM THE CONTINUED STRONG GROWTH OF POPULATION IN EAST MEATH INCLUDING MAKING 5 AND 15 YEAR PROJECTIONS AS RECOMMENDED IN THE NRA GUIDELINES.

6 PROPOSED DEVELOPMENT WILL INCREASE PASSENGER CAR TRIPS ON THE MAIN STREET IN JULIANSTOWN

6.1 NOTWITHSTANDING THE DEFICIENCIES IN THE TIA IDENTIFIED IN SECTION 5, IT IS LIKELY THAT THE CATCHMENT AREA OF THE PROPOSED DEVELOPMENT INCLUDES SHOPPERS LOCATED TO THE WEST AND SOUTH OF JULIANSTOWN WHO WILL DRIVE THROUGH JULIANSTOWN TO GO TO ALDI AND RETURN BY THE SAME ROUTE. IN PARTICULAR THE SMALL TOWN OF STAMULLEN AND ITS HINTERLAND HAS A POPULATION

12 Census 2016: Population of Stamullen ED is 5,001 13 Traffic Impact Assessment -March 2016 paragraph 5.16 14 East Meath Local Area Plan 2014 to 2020 Volume 1 – page 21 15 Census 2016 – www.cso.ie (note the EDs are not contiguous with the East Meath LAP area) 16 East Meath Local Area Plan 2014 to 2020 Volume 1 – Table 2.1

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OF 5,00117. DESPITE ITS SIZE IT DOES NOT HAVE A LARGE SUPERMARKET SO SHOPPERS MUST TRAVEL BY CAR FOR WEEKLY SHOPS.

6.2 CURRENTLY THE AADT AND HOURLY AVERAGE VOLUMES USING JULIANSTOWN MAIN STREET IS MANY TIMES THE ENVIRONMENTAL CAPACITY OF A VILLAGE STREET18. WE UNDERSTAND THAT TII RECOMMENDS THAT TRAFFIC VOLUMES GREATER THAN 20,000 AADT SHOULD BE ACCOMMODATED WITH TYPE 1 DUAL CARRIAGE WAYS19 YET PEOPLE LIVING IN JULIANSTOWN MUST ENDURE THIS VOLUME OF TRAFFIC ON THE MAIN STREET OF THEIR VILLAGE.

6.3 JULIANSTOWN CANNOT TAKE ANY FURTHER INCREASES IN TRAFFIC VOLUMES, THEREFORE THE BORD NEEDS TO ASSESS THE IMPACT OF OVERALL TRAFFIC VOLUMES IN JULIANSTOWN INCLUDING CUMULATIVE EFFECTS. WE CONSIDER THAT ANY INCREASE IN TRAFFIC IN JULIANSTOWN IS NOT POSSIBLE FOR CAPACITY REASONS AND PERMISSION SHOULD BE REFUSED.

7 CONCLUSION

7.1 WE SUBMIT THAT THE BORD SHOULD REQUIRE FURTHER INFORMATION SO THAT IT CAN CARRY OUT A TIA TO THE STANDARD OF THE NRA GUIDELINES.

7.2 WE FURTHER SUBMIT THAT THE DECISION OF MEATH COUNTY COUNCIL SHOULD BE OVERTURNED BECAUSE THE PROPOSED DEVELOPMENT WILL:

(a) lead to significant increase in articulated HGVs on Julianstown Main Street; and (b) lead to significant increases in passenger car journeys on Julianstown Main Street.

7.3 BOTH OF THESE EFFECTS FROM THE PROPOSED DEVELOPMENT INDIVIDUALLY AND CUMULATIVELY ARE INCONSISTENT WITH THE STRATEGIC POLICIES AND OBJECTIVES IDENTIFIED FOR JULIANSTOWN IN THE CDP AND ARE INCONSISTENT WITH PROPER PLANNING AND SUSTAINABLE DEVELOPMENT DUE TO THE ENVIRONMENTAL HARM THEY WILL CAUSE IN THE VILLAGE OF JULIANSTOWN.

Julianstown and District Community Association CLG Julianstown Co Meath

6 February 2017

17 Census 2016: Population of Stamullen ED 18 See “Traffic in Towns” (HMSO 1963) Appendix 1: Capacity of a village street should be less than 300/hr depending on width. 19 DMRB Volume 6 Section 1 – Part 1 NRA TD 9/12

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Schedule 1: Map and views of Main Street Julianstown

Direct route to site for HGVs

Julianstown

Junction 7

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Schedule 2: Traffic Data - 2016 Peak Factor Peak Volume Peak pmPeak Factor Peak Volume Peak Peak am 00-24 06-24 06-22 07-19 23:00:00 22:00:00 21:00:00 20:00:00 19:00:00 18:00:00 17:00:00 16:00:00 15:00:00 14:00:00 13:00:00 12:00:00 11:00:00 10:00:00 09:00:00 08:00:00 07:00:00 06:00:00 05:00:00 04:00:00 03:00:00 02:00:00 01:00:00 00:00:00 data: Exclude Class TimePeriod Channel Setup Description Grid ID Site Name Site 2016-12-31 to 2016-01-01 000000201321 NRA DailyReport Volume 2016 None hour 1 directions All 201321 R132 Co.Meath Whitecross, Julianstown, of South R132 313813270049 000000201321 N 090.0 TMUR132 Average Daily Average Flow 17:00:00 08:00:00 19866 18900 18157 14869 0.983 0.942 1561 1278 1113 1446 1561 1436 1329 1314 1239 1129 1016 1047 1278 1146 295 448 600 818 928 757 300 152 102 125 197 88 12:00:00 07:00:00 MBIKE 46 44 43 37 1 4 1 4 0 1 1 2 3 3 4 3 3 3 3 3 3 3 3 3 3 1 0 0 0 0 0 0 0.20% 0.20% 0.20% 0.20% 0.10% 0.10% 0.20% 0.20% 0.30% 0.20% 0.20% 0.20% 0.20% 0.20% 0.20% 0.30% 0.30% 0.30% 0.20% 0.20% 0.30% 0.20% 0.10% 0.10% 0.20% 0.20% 0.10% 0.10% 17:00:00 08:00:00 17473 16644 15957 12963 0.985 0.939 1415 1112 1028 1334 1416 1271 1159 1148 1079 1111 CAR 268 419 557 760 969 855 771 877 973 650 256 126 110 177 84 75 88.00% 88.10% 87.90% 87.20% 91.10% 93.30% 92.70% 92.90% 92.40% 92.20% 90.70% 88.50% 87.20% 87.30% 87.10% 85.90% 84.20% 83.10% 83.70% 87.00% 84.90% 85.80% 85.50% 82.70% 82.40% 85.20% 87.60% 89.80% 16:00:00 07:00:00 0.875 1548 1456 1417 1206 112 119 108 111 106 100 100 101 118 18 21 31 43 61 82 98 98 94 90 76 29 19 11 11 12 LGV 1 9 10.30% 10.00% 12.20% 11.10% 10.10% 7.80% 7.70% 7.80% 8.10% 6.00% 4.60% 5.20% 5.30% 5.50% 5.70% 6.90% 7.80% 8.00% 7.60% 7.90% 8.70% 9.30% 9.70% 9.50% 7.90% 9.80% 9.20% 6.30% 14:00:00 07:00:00 0.563 BUS 0.75 105 102 99 83 9 9 2 1 3 3 4 6 7 8 8 8 5 6 5 5 7 8 9 5 2 0 0 0 0 1 0.50% 0.50% 0.50% 0.60% 0.50% 0.20% 0.40% 0.40% 0.40% 0.40% 0.40% 0.60% 0.60% 0.60% 0.40% 0.50% 0.50% 0.60% 0.70% 0.60% 0.80% 0.70% 0.60% 0.20% 0.10% 0.10% 0.20% 0.40% 14:00:00 09:00:00 0.906 0.938 HGV_RIG 332 316 311 287 29 30 12 22 27 28 26 27 30 29 30 28 19 10 2 3 3 4 7 8 5 4 3 1 2 2 1.70% 1.70% 1.70% 1.90% 0.60% 0.60% 0.60% 0.50% 0.60% 0.60% 0.80% 1.50% 2.00% 2.20% 2.10% 2.40% 2.90% 3.10% 2.90% 2.20% 1.70% 1.30% 1.80% 2.50% 2.50% 1.60% 1.30% 0.80% 13:00:00 09:00:00 0.929 HGV_ART 303 280 271 240 24 26 10 11 16 20 22 23 21 24 25 26 22 20 13 1 5 4 4 5 8 6 3 4 2 2 5 1.50% 1.50% 1.50% 1.60% 1.60% 1.00% 0.70% 0.60% 0.70% 0.70% 0.70% 1.10% 1.50% 1.70% 1.90% 1.90% 2.40% 2.70% 2.50% 1.70% 1.70% 1.80% 2.20% 2.00% 3.50% 2.70% 1.60% 2.50% 12:00:00 07:00:00 CARAVAN 59 57 57 51 1 4 1 4 0 1 1 1 2 3 4 4 4 5 4 5 5 5 5 5 3 1 0 0 0 0 0 0 0.30% 0.30% 0.30% 0.30% 0.10% 0.10% 0.10% 0.20% 0.20% 0.20% 0.20% 0.30% 0.30% 0.30% 0.40% 0.40% 0.50% 0.50% 0.50% 0.40% 0.30% 0.20% 0.10% 0.30% 0.20% 0.20% 0.10% 0.10% InvalidReading 1 1 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 0.00%

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Schedule 3: Environmental baseline in Julianstown

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JULIANSTOWN: ENVIRONMENTAL ISSUES

Fred Logue [email protected] 0871316023 INTRODUCTION

This report sets out some facts concerning environmental issues in Julianstown Co Meath. It is compiled from information that is publicly available from several sources together with information released in response to requests for access to environmental information.

Overall the picture is not good:

 With the financial crisis at an end, the population of East Meath has started to grow again over the last three years and the quantity of zoned land, existing planning permissions and vacant housing is enough to increase the population by approximately 16,000.  Having dipped during the financial crisis, traffic in Julianstown is now increasing by about 2.2% per year and if this trend continues the volumes will be at pre-M1 levels within 10 years.  Meath County Council has no information on projected traffic volumes and does not seem to have ever considered the effect of its zoning and planning policies on the traffic volumes or the environment generally in Julianstown.  The local authority has no information on air quality in Julianstown and says it has no responsibility for it.  It has conducted noise studies under EU law obligations and the studies indicate high noise levels but there is no effective measure in place to reduce these noise levels.  The local authority appears to be in some form of negotiation with the owners of the Old Mill site but refuses to disclose information about this. It seems to not want to fulfil its obligations under the Derelict Sites Act because it thinks this could harm the prospects of the site being restored.

TRAFFIC VOLUMES

The National Roads Authority (now called Transport Infrastructure Ireland) maintains a traffic counter which is located on the R132 in Julianstown just to the North of the school. It records hourly and daily traffic rates and distinguishes cars from HGVs. This traffic counter was installed in the mid-1990’s and there is generally good data coverage from 1997 to date. The more recent data is available at this link www.nratrafficdata.ie

Traffic volumes are measured as “Annual Average Daily Traffic” (AADT) and are detailed below.

AADT For Julianstown by year 26000

24000

22000

20000

18000

AADT (vehicles/day AADT 16000

14000

Year

Figure 1 AADT volumes in Julianstown 1997 to 2016 We can look in more detail at monthly increases which since the financial crisis has come to an end have started to grow again. The monthly figures shows that the AADT traffic in Julianstown has grown by approximately 465 extra vehicles per day since growth resumed in 2013. If this rate of increase continues then the traffic volumes will reach its pre-2013 peak of 24,666 within 10 years.

One point of optimism is that HGV volumes are proportionately lower than pre-M1 with the HGV volume at 3.5% of the overall volume.

Julianstown - Monthly y = 45.566x + 19135 22000 21500 21000 20500 20000 19500 y = 41.681x + 18232 19000 18500 18000 17500

17000

Jul Jul Jul Jul

Jan Jan Jan

Sep Sep Sep Sep

Nov Nov Nov Nov

Mar Mar Mar Mar

May May May May Average Traffic Volume (24 hours) (24 Volume Traffic Average 2013 2014 2015 2016 Year/Month

Weekday 7 Day Linear (Weekday) Linear (7 Day)

Figure 2 Monthly AADT for Julianstown Mar 2013 to Nov 2016

y = 490.7x + 19700 22000 September 21500 21000 20500 20000 y = 465.2x + 18667 19500 19000 18500 18000 17500 Weekday2013 7 Day2014 Linear (Weekday)2015 Linear (72016 Day)

Figure 3 September AADT 2013 to 2016 showing annual growth of approximately 465 - 491 vehicles per year

WHAT TYPE OF ROAD DOES TII SPECIFY FOR THIS LEVEL OF TRAFFIC?

Under an AIE request we asked TII to tell us what road specification they recommend for roads with volumes of 20,000 AADT. They referred us to the “Design Manual for Roads and Bridges” which recommends either a type 2 or type 1 dual carriageway. In other words, for traffic volumes in excess of 20,000 AADT a dual carriageway with wide hard shoulders with no right turns is specified. Clearly these types or roads are not intended to pass through villages.

See the below excerpt:

Figure 4 Excerpt from the TII Design Manual showing capacity of various design types

WHAT INFORMATION DOES MEATH COUNTY COUNCIL HOLD IN RELATION TO TRAFFIC VOLUMES IN JULIANSTOWN?

In response to an AIE request Meath Council informed us that it holds no information on the increase in traffic passing through Julianstown based on current planning policy and zoning in East Meath and that no such traffic studies have been provided to it pursuant to any planning permission or other submission.

It seems that Meath County Council has never considered the impact of its policies on traffic volumes in Julianstown.

WHAT IS THE POPULATION OF THE AREA?

The growth in population in East Meath depends on three main factors: capacity of zoned land for which planning permission has yet to be sought, number of outstanding planning permissions that have yet to be completed and number of vacant properties. Details of this information is contained in the Meath County Development Plan, the East Meath Local Area Plan and in the 2011 and 2016 census results.

For the purpose of this study we consider East Meath to be the Julianstown and St Mary’s (Louth+Meath) electoral districts. We will also consider the Laurence’s Gate and West Gate Districts which are in the Southern part of Drogheda (see map below):

Figure 5 Map showing electoral districts in East Meath

Table 1 Population and housing statistics from the census

2011 2016 East Meath Population 26,639 28,802 Occupied Houses 9387 9965 Vacant Houses 1039 850 South Drogheda Population 10,046 10,359 Occupied Houses 3646 4034 Vacant Houses 316 271

In total between East Meath and South Drogheda the 2011 population of 36,984 has grown to 39,161. The ratio of population to houses gives an occupancy rate of approximately 2.8 persons per house. The population of East Meath is therefore approximately the same as Navan and considerably greater than Kilkenny, Tralee, Carlow or Sligo for example.

HOW MANY MORE HOUSES CAN BE BUILT IN EAST MEATH AND WHAT DOES THIS MEAN FOR POPULATION GROWTH?

The number of houses that can be built is defined by the area of land zoned in the County development plan and the number of planning permissions granted or that may be granted. This information is outlined in the East Meath local area plan 2014 to 2020 which sets out the zoning and policies around planning permission.

It should be noted that Julianstown is not included in the LAP but rather in the general County Development. The process to adopt a new County Development Plan due to be adopted in 2019 is now underway and a consultation will take place in early 2017.

According to the East Meath LAP the following is the capacity for housing in East Meath (Meath County area only)

Committed houses (i.e. planning granted): 1497 New planning limit 100 Vacant houses* 850

Excess zoning (110.3 ha @ 25/ha) 2765

Excess zoning (28 ha @ 20/ha) 560

Total capacity (houses) 5772

Total population (2.8 per unit) 16,147

There is capacity in terms of zoned land, committed planning permission and vacant housing to increase the population of East Meath by over 16,000 (equivalent approximately e.g. to the population of Killarney or Clonmel). This 54% increase would bring the population to a level similar to Waterford and the overall Drogheda/East Meath population close to that of Galway and its suburbs.

WHAT ABOUT AIR POLLUTION IN JULIANSTOWN?

Trafffic, especially vehicles with diesel engines, creates serious pollution primarily NOX and particulates which cause various illnesses in exposed populations. We asked Meath County Council for all information held concerning air quality in Julianstown. They responded to say that they do not hold any such information and that they have no responsibility for air quality

WHAT ABOUT NOISE POLLUTION?

Clearly traffic causes noise and the greater the volume the greater the noise. Meath has responsibility under an EU directive to monitor and plan around traffic noise in its administrative area and produces regular Noise Action Plan1. The R132 in Julianstown qualifies because the traffic volumes here exceed 3 million vehicles per year (actual volumes are 7.3 million per year growing at a rate of 2.2% per year. The noise levels are not measured but are calculated by TII.

The excerpts from the noise plan are hard to read and we have requested Meath County Council and TII to provide the raw data in each case.

Figure 6 24 hour average noise for R132 and M1

1 http://www.meath.ie/CountyCouncil/Publications/RoadsPublications/NoiseActionPlanforRoads/

Figure 7 Night time noise for R132 and M1

DERELICT OLD MILL SITE

We asked Meath County Council, through an AIE request to provide access to all relevant information concerning its handling of the Old Mill site. There is a surprising lack of information considering that public statements emanating from councillors and officials indicate that there are on-going discussions with developers about redevelopment on the site. There are two letters from February 2015 and February 2016 indicating that Meath County Council is reluctant to initiate registering the site on the register of derelict sites because they are fearful that this will prejudice the restoration of the site. This is quite strange since the Derelict Sites Act and the powers given to local authorities are designed to be used to prevent dereliction. It is rather unusual to say the least for a local authority to take the view that exercising its power in relation to dereliction would prolong the dereliction. The released information confirms that there has been correspondence with the owners in relation to the site and proposals for its development but Meath County Council has not identified the relevant information and has not released it.

We are pursuing further requests and an appeal to the Commissioner for Environmental Information on this issue.

WHAT CAN BE DONE?

Meath County Council has statutory obligations mainly through the development planning process to assess the environmental issues in its administrative region at the start of each development plan cycle. Following from that it has statutory obligations to include objectives for many things including: transport, conservation and protection of the environment, integration of planning and sustainable development with social, community and cultural requirements of the area and its people, protection of structure and the preservation of the character of architectural conservation areas and so on.

Unless specific objectives are included in the County Development Plan the local authority has no real legal obligation to take any measure to alleviate the traffic and the attendant noise and air pollution or to take any substantive steps to benefit Julianstown and the environment in Julianstown.

The County Development Plan is the only realistic way the community can influence the policy for the following six years and therefore there must a concerted effort to get specific objectives included with lead towards traffic reductions in the village.

SOURCES OF INFORMATION

TII traffic counters

East Meath Local Area Plan 2014 to 2020

Access to Information on the Environment Regulations 2007 to 2014

Meath Noise Action Plan 2013

Census 2011

Census 2016