Previous points for Bus Connects Scheme Blanchardstown to City Centre

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.

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^[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