Month: August 2022

Some of the items here may be of assistance when compiling your submission to An Bord Pleanala

24^th March 2019.

Dear Sir/Madam,

We, the Navan Road Community Council wish to make the following submission on BusConnects Core Bus Corridor 5: Blanchardstown to City Centre.

The Navan Road Community Council is an umbrella organisation for resident’s associations, clubs and other groups in our area. The Navan Road Community Council, represents the residential areas between the Phoenix Park and the Royal Canal, and extending from Skreen Road to Ashtown Road, including both sides of Navan Road.

While we would be generally in favour of the plan to improve bus services there are real concerns about some aspects of Phase Two and the impact on our area. 

Overall, the proposed plan will have an adverse effect on our community and living environment: 

1. We object to the proposed reduction in footpath widths, removal of trees and grass margins, reduction in private gardens and increased number of traffic lanes i.e. an extra right turning lane into Baggot Road inbound. 

• Traffic entering the City will be channeled down the Cabra Road and through Phibsborough.  This would not be a viable route.  At present the Cabra Road and North Circular Road traffic comes to a complete standstill, with Phibsborough being the bottle neck.  This is at its worst during the morning and evening peak hours but also outside these times.

• Traffic leaving the City will again be channeled through Phibsborough and onto the Cabra Road.  It is proposed that traffic will also be diverted from Prussia Street onto Blackhorse Avenue, and then ‘directed’ onto the Navan Road via Nephin Road.  We feel that Nephin Road would not be able to contend with the amount of increased traffic.  This will result in extra traffic using Skreen Road, Croagh Patrick Road and Baggot Road as rat runs. The direct effect of this will be to seriously damage the quality of life of residents in the affected areas.  Noise, air pollution and safety would be detrimentally affected.

•  We would also question the ability of any of the above mentioned roads to handle such an increase in traffic. Skreen Road, Croaghpatrick Road and Nephin Road are    two lane thoroughfares with very poor road surfaces and on street parking.

• While there has been some up grading of Blackhorse Avenue in recent times, there are some obvious problems with the proposal to increase traffic.  Firstly, the road is liable to flooding in heaving rain conditions. In fact,  during severe rainfall, sections of the road can become impassable. Secondly, the section of Blackhorse Avenue from the Baggot Road junction outbound to past the Hole in the Wall pub is basically still a country lane and is in extremely poor condition. It includes a dangerous bend with traffic regularly forced across the centre of the road due to the poor condition of the surface. 

• The junction of Blackhorse Avenue,  Ashtown Gate and Castleknock Road is very hazardous and is particularly dangerous for pedestrians. Navan Road Community Council have been trying for at least twenty years to get Dublin City Council and Fingal County Council to talk to each other with a view to putting some infrastructure in place to make this area safer.

• From what we can ascertain on looking at the maps provided in the BusConnects brochure, it would appear that a considerable number of trees along the Navan Road in our area would be removed.  We were disappointed to see how little attention is given (Page 17, 3.2.4) to this issue. There is absolutely no explanation of how trees will be replaced.  Trees are the green lung of the city and are especially important where there is a lot of traffic.  The majority of the trees along our section of the Navan Road are there in excess of 40 years and we object to their removal. Where removal is absolutely necessary we demand that they would be replaced with mature trees and not saplings.  Consultation with the Navan Road Community Council and our residents on this matter before replanting would be essential.

• The Ashtown Roundabout denotes the entrance to Dublin City and is an important, distinctive feature of our area. We are totally opposed to its removal. We propose traffic and pedestrian signalling of the Ashtown Roundabout and retention of the trees.

• We object to the removal of the 122 bus service from Ashington to Drimnagh. This would significantly impact on those travelling to work, the infirm, the elderly and those travelling with young children.  It would also remove the only service which stops at the new Mater Hospital and would also remove access from this side of the City to Crumlin Children’s Hospital. 

1. To encourage commuters to move from car to public transport, it is imperative that proper, free park and ride facilities are provided for the commuter belt and that shuttle services are provided to link to the proposed improved bus network.

In conclusion, the proposal is detrimental to the needs of the residents of this area.  It will result in having a negative impact on the green environment and the overall quality of life for our residents.  This is too high a price to pay for an improved bus service.

Yours faithfully,

Patricia Dunleavy,

Chairperson,

Navan Road Community Council,

Apologies that is has taken longer than we thought to post our submission to An Bord Pleanala. Some of the points in this older submission are still relevant and may be of assistance to residents.

Dear NTA,

We the Navan Road Community Council wish to make the following submission on the proposed Bus Connects project.

The Navan Road Community Council is an umbrella organisation for resident’s associations, clubs and other groups in our area. We represents the residential areas between the Phoenix Park and the Royal Canal, and extending from Skreen Road to Ashtown Road, including both sides of Navan Road.

The main problem with trying to address the changes proposed under Bus Connects lies in the fact that the bus route changes are given in isolation with no information as to how the road infrastructure will be adapted and used to provide bus corridors where none exist at present.  Also there is no information about which roads will become “one way” or “buses only”. It is disingenuous to provide proposed bus route changes without the corresponding infrastructure changes that will be required too.

Many of our residents are dependent on a regular direct bus service. Many feel strongly that it is not new routes that are required but rather more buses to serve their needs.

Whilst there are some good points in Bus connects, sadly many are at the cost of current services that are operating well and responding well to current needs.  

We are pleased to note that Bus Connects would mean that many more of our residents would have access to local rail and luas stations.

Unfortunately, this good point would be mitigated against by the fact that trains on the Maynooth corridor are presently extremely and dangerously overcrowded long before they reach Ashtown and other stations nearer the city.  There is absolutely no use in getting passengers access to trains that are already full to overcapacity.  Investment in more rail and luas stock is imperative in conjunction with the roll out of any new bus services for Dublin. 

Too often our transport systems seem to be operating in limbo, for example the latest new train timetable in operation since  8^th September 2018 has resulted in trains arriving late at 

Ashtown Station, consequently then late arriving in the City resulting in passengers being late for work.  Efforts to get spaces on earlier trains has resulted in even more overcrowding.

Late train arrivals may also be due to Dart services being recently ‘improved’ to a 10 minute  peak service, causing ongoing  delays in the Maynooth line entering Connolly Station resulting in late trains.

Our different modes of public transport cannot continue to operate in isolation.  Joined up thinking and investment in relation of all modes is urgently required and long overdue.

There are several major concerns for residents of our area.

Under these proposals the 122 bus would be replaced by the 262 which is a circular route which does not operate to the City Centre and onwards as the current 122 does.   At present the 122 serves Crumlin Children’s Hospital. The proposals would result in people living in this area having to leave home perhaps up to 30 minutes earlier and arriving home up to 30 minutes later in evenings.  The frequency of the proposed 262 should be increased to 10/15 minutes during the morning and evening peak times. 

This new proposal would completely undo the new cross city  routes introduced only a few years for all our buses (apart from 122) Nos. 37, 38’s, 39 and 70 presently cross the City to Burlington Road, and the 39A to UCD . This has been of great benefit and comfort to our residents and many others from further away within Dublin 15.

The B routes would replace several bus routes and there is huge worry in our area that by the time buses reach us they will be full.  In fact we could envisage a scenario where the B buses would be full leaving the Blanchardstown Hub or soon thereafter.  With the 122 route gone this would leave our very large area with no direct bus link to the City Centre, especially during peak times.

Changes to what is currently the 120 bus combined with full trains at Ashtown could see more Pelletstown residents accessing the B routes on the Navan Road resulting in less capacity on these routes. There are a large number of homes currently under construction and more areas still to be developed in Pelletstown which will add to the commuter problems.

The removal of the 122 means that there is no service to the main entrance of the Mater Hospital. 

Removal of the 37 bus means that Blackhorse Avenue and Dunard Estate no longer have a bus service which terminates in the City Centre.  Skreen Road loses its service completely. 

The proposal to put a regional bus hub at Blanchardstown Centre would not make sense.  At present the roads into and out of the Centre are often gridlocked. The roads cannot cope with current bus and motor traffic on a daily basis.  This is much worse at peak shopping times i.e. Christmas, Bank Holidays, weekends etc.

Redirecting the 70 bus into Blanchardstown Shopping Centre deprives the Navan Road of a bus which will lead to more crowded or full buses by the time they reach our area.

A large number of students from the 70 route attend schools within our area, such as St. Dominic’s College,  St. Declan’s College , Navan Road Primary Schools School and the Educate Together Primary School in Pelletstown to name but a few. This amazingly inhuman plan will require they change buses on the way to and from schools in hail, rain or snow, with heavy school bags scrambling for places morning and afternoon at the over-crowded Blanchardstown Centre Hub.

At present the No. 70 Bus –  on exiting Little Pace comes directly down Navan Road with no stops until it reaches the Travel Lodge/Auburn Avenue stop, in less than 5 minutes if no traffic delays.  Users of No. 70 bus will have to leave home at least half hour earlier in mornings, getting home half hour later in evenings.

Running the 262 and N2 Services via the one way Broombridge requires traversing a narrow and Listed Bridge. It is not clear how such an old, historic bridge (Sir William Rowan Hamilton- the algebra of quaternions) will withstand two way bus traffic.

For people with visual impairments it is essential that there is no change of colour of the bus livery. It would be especially problematic if the idea of changing bus stops to grey was followed through.

The danger for  disabled people – throughout the whole City of Dublin – will be getting on a first bus which requires a CHANGE OF BUS,  and  being  left behind at the second CHANGE STOP, in hail, rain or snow, if the second bus is full.

Those of us regular bus users are well aware of constant arguments with a parent not having the courtesy to fold a buggy on access to a bus, thereby taking up the entire and  only space for a wheel-chair, which is then refused entry to bus – leading to a double whammy for the unfortunate wheelchair user  – when they eventually get the first bus, the second  CHANGE BUS  may be full.

Service users of campuses such as St. Vincent’s Centre on the Navan Road may have spent many years learning to identify the bus number and route they require so that they can travel independently.  The proposed changes would have a very detrimental effect on these bus users and may well result in many losing this small measure of independence.

We would finally like to bring to your attention the fact that public transport is not only there to move people to and from work quickly and efficiently, although this is obviously important.  Public transport also fulfils a role in helping people socialise and avail of shopping and entertainment.  Some of the proposed changes would definitely lessen this aspect of public transport to the detriment of many residents of Dublin.

Yours sincerely,

Patricia Dunleavy,

Chairperson,

Navan Road Community Council,

10, Glendhu Park,

Navan Road,

Dublin 7, D07EA44.

Below are some talking points which may be of assistance when you are compiling your submission to An Bord Pleanala regarding the above scheme

1. Quality of Life

• Why has the NTA ignored the issue of Quality of Life in its plan for the Blanchardstown to City Centre Core Bus Corridor 5? The proposed removal of trees before and after the Ashtown Roundabout and the Compulsory Purchase of sections of front gardens, pedestrian path width reduction and redistribution of traffic from Old Cabra Road are some examples. 

• Trees

• The trees on the Navan Road from the M50 interchange as far as the Ashtown Roundabout will be almost entirely eliminated in the NTA proposal. The Street Trees on the Navan Road from the Ashtown Roundabout to Cabra Cross will be reduced by at least 150 in the NTA proposal proposals.  These trees are a major component of the Quality of Life of our area and community and they also contribute positively to the reduction of Climate Change impacts. 

• Can you explain how the NTA can propose to remove 150 Street trees and still find space for new trees to grow? 

• Where is the expert arboriculture and horticulture expertise to guide the NTA?

• Why has the NTA not considered other proposals for retaining the trees in tandem with considering alternative ideas for dealing with car traffic, public transport and cycling and walking?

• The NTA is proposing trees in the public footpaths.  Surely there will be a conflict here between the pedestrian and the trees? And remember pedestrians include the young, the old and the disabled.

• Park and Ride

• Why has the NTA not prepared a plan for Park and Ride centres in tandem with the Core Bus Corridor plan and that is expressly mentioned in the information document? We would propose that it make more sense to intercept car traffic commuters with Park and Ride facilities well in advance of the Dublin County Area.

• Cycling

Did the NTA consider the Greater Dublin Area Cycle Network Plan in their Blanchardstown Core Bus Corridor Plans?

• If yes, what were the outcomes and can we have a copy?
• If not, why?

• Core Bus Corridor requirement

In view of the potential massive changes in workplace attendance and practices post-Covid, has the NTA reconsidered the design and scale of the Core Bus Corridor project and alternatives to reduce impact on local communities? 

• Environmental Impact Assessment

• The proposed Environmental Impact Assessment^[1] will be prepared for the Planning Application! You say that it will: 

• “identify the anticipated environmental effects of the scheme during both the construction and operational stages”.  Where is the identification of the effects of the plan itself on this community?  Surely, before the plan is agreed we as the residents should know what the long term effect on our community is likely to be?

• According to the project approach to Environmental Assessment^[2], “The assessment of traffic and transport impacts such as general traffic re-distribution away from the Proposed CBC on to surrounding roads and specific traffic turning movements at individual junctions.  It also requires an assessment of bus, pedestrian and cycle operations and bus reliability with a focus on the movement of people along the route.

Where are the results demonstrating the traffic re-distribution?  Particularly those impacted by the closure of Old Cabra Road to general through-traffic?

“The LAM has been used throughout the CBC Infrastructure Works to provide all road-based outputs to inform the TIA, EIA and junction design models”^[3].  However, there are key questions that challenge the integrity of the modelling.

 Section 5.4 Count Data suggests that “The busiest junction in the study area is the Navan Road/Kempton Avenue junction with 66568 daily movements”.  This cannot be correct as anyone familiar with the CBC corridor would know!

How can these results be accurate since the LAM modelling did not include the key ATC 5.5A and 5.5B on Old Cabra Road?

The diversion of traffic from Old Cabra Road will have significant negative impact on the quality of life of Navan Road residents, particularly those on Blackhorse Avenue, Skreen Road, Nephin Road, Baggot Road and Castleknock Road.  What information does the NTA have to support its contention that the only traffic that will use these roads is local traffic?

• Why has the NTA not examined the secondary consequences of its plans to divert traffic from Stoneybatter onto other roads – Infirmary Road/Conygham Road/Chapelizod, North Circular Road and Blackhorse Avenue for example?  Interestingly, the NTA does not expressly say that the car traffic will be diverted onto Blackhorse Avenue.  But it will be. Does the NTA not realise that doing this will diminish further the Quality of Life of these neighbourhoods?

• Pedestrian and cyclist flow

• There would appear to be future conflicts between the pedestrians attempting to get onto the bus and cyclists who are being directed between the bus and the pedestrian path?  How is this issue to be resolved?

• You are showing four way crossing points at junctions and which is to be welcomed, in particular for pedestrians.  How will cyclists and pedestrians be protected from conflicts with each other at these junctions including the Ashtown roundabout?

• What is the crossing time allowed for pedestrians at the four way junctions?

• What is the international design Best Practice for dealing with conflicts between cyclists, cars and pedestrians?  Is the NTA utilising this Best Practice?

• In the plan for Bus Gates and Signal Controlled Priority is there an emerging conflict here if pedestrians and/or cyclists are already on junctions and when buses may be approaching them?  If so, how is this conflict to be resolved? 

• Has the NTA given any consideration to the likely conflict between pedestrians, cyclists and eScooters? 

8.            Ongoing and Future management of the Bus Corridor

Recognising that adherence by motorists and cyclists to the new CBC traffic restrictions, bus lanes, signalised junctions and turn restrictions is fundamental to the success of the CBC, what controls and  Service Level Agreements (e.g. for policing and maintenance) are being or will be implemented to ensure success.

• Proposed Land Takes

• There are proposed land takes in a number of private and public land areas. For example, the land takes on public open space in shown in Map 20 Belleville, The Paddocks and Darling estate. How will this land take be undertaken and without affecting the existing trees as well as the amenity of these areas and the function of the public open spaces?  There is no indication in your document that trees will be directly lost. 

• Similarly, in a previous document there was an intention outlined by the NTA to plant trees in private land as mitigation for the removal of the existing Street Trees.  For example, the School for the Deaf on the Navan Road Map 26.  Why has this now been omitted from the plan but there is no reference to it in this current Third Round document?

1. Submissions

10.1 In order for the Navan Road Community Council to make a coherent submission to the NTA, the proposals for Corridor 5 – and in particular for the sections that will impact most on our community – the Navan Road Community Council (NRCC) should have access to the full extent of plans, maps, timelines and other documentation. However, much of this detailed information is missing and we are informed that it will be available in the future –but after the submission date. For example:

• Environment Impact Assessment reports and details
• Traffic Impact Assessment

This is unfair to the NRCC and to the community of the Navan Road area. Without the fullest extent of the information being made available to our Committee we are literally making a submission in the dark. It is also unfair to the communities of the other 15 corridors.  Can you please provide the timelines for when we will can expect to have this information?

10.2 Our community and the other 15 Core Bus Corridor Communities have had a difficulty in organising community involvement due to the Covid19 pandemic. We have been unable to meet in groups to brief our community and Elected Members in person and in turn receive feedback.  We therefore, strongly suggest that the NTA consultation process should be rescheduled until the current pandemic is considered to be under control and that allows our community to discuss the issues in a proper, open and democratic manner.

---

^[1] Information on the Proposed Approach to Environmental Assessment November 2020, BCIDE-JAC-ENV_ZZ-0005_XX_00-RP-ES-0001

^[2]IBID, Section 5.1.1

^[3] Blanchardstown to City Centre CBC – Draft-WIP Transport Modelling Report v1 FINAL.docx 

Dear Resident,

Further to the hugely successful public meeting held on 16 August 2022 to discuss NTA proposals to An Bord Pleanala for the Blanchardstown Scheme, a reminder that the Closing Date for Submissions/Observations is 5.30pm Mon 30 August 2022.

Your Submission can be made by post or online,quoting the above reference number

By post to:  An Bord Pleanala, (Strategic  Infrastructure Division)  64 Marlborough Street, Dublin 1 , D01 V90, enclosing a cheque for €50.00.

Online to: https://www.pleanala.ie/en-ie/observations with a debit/credit card payment of €50.00

The Navan Road Community Council will be making a submission and draft versions of the submission will be available on the website in the next few days at www.navanroad.com.  

Please consult this to assist you with your own submission.

Other links to look at: Observation on a Strategic Infrastructure Development application online | An Bord Pleanála (pleanala.ie)

Click to access Making-an-observation-on-a-SID-application-EN.pdf

Click to access Newspaper-Notice-30th-June.pdf

https://blanchardstownscheme.ie

Navan Road Community Council

PUBLIC MEETING TUESDAY 16 AUGUST 2022

Core Bus Corridor 5 – Blanchardstown to City Centre

VENUE:  St. John Bosco Boys National School

The National Transport Authority (NTA) has prepared plans for the Core Bus Corridor 5 – Blanchardstown to City Centre. The proposal has recently been forwarded to An Bord Pleanála (ABP).

The Navan Road Community Council supports the Bus Connects project.  But not at any price!

From Parkway Railway Station to the North Circular Road our neighbourhood will change. But, it will change for the worse, if we do nothing!

Listen to the Brief/Comments/Views of our Core Bus Corridor Committee.  Let us hear your views. View Bus Connects submission to An Bord Pleanala at http://www.blanchardstownscheme.ie

Timeline for the Public Meeting Tuesday 16 August 2022

6.00 pm: View the plans. If you need help to understand the plans, we will do our best to help you.

7.50 pm: Information and Discussion Session

9.15 pm: Close of Public Meeting

Navan Road Community Council will hold a public meeting on Tuesday 16th August 2022 to discuss the proposed Core Bus Corridor 5 – Blanchardstown to City Centre submission to An Bord Pleanála by the NTA.

These proposals will have far reaching implications for our community starting with the proposal to remove approximately 150 street trees from Navan Road Parkway Station to Cabra Cross which will leave our area devoid of trees. There are also the proposals for compulsory purchase orders for some of our neighbours front gardens and the proposal to “borrow” parts of other gardens. Plus the removal of the roundabout at Ashtown. The plans are available online at http://www.blanchardstownscheme.ie

The meeting will take place in St. John Bosco Primary School Hall behind Our Lady Help of Christians Church on the Navan Road.

6.00pm – View the plans. If you need help to understand the plans, we will do our best to assist you.

7.50 pm – Information and Discussion Session

9.15pm – Close of public meeting

All residents are invited and urged to attend if at all possible.