J. D. C. A. Julianstown & District Community Association CLG Company number 481750 www. Julianstowncommunity.com Niamh Bn. Uí Loinsigh House Smithstown Julianstown County Meath BY Hand The Secretary An Bord PLeanála 64 Marlborough street Dublin 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 DROGHEDA. 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 1 Observations on PL17.247835 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 REGIONAL ROAD 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 NATIONAL ROADS AUTHORITY, 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 2 Observations on PL17.247835 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 3 Observations on PL17.247835 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).