Submissions should be with an Bord Pleanala before 5.00pm tomorrow 30th August 2022 . ABP Reference No: 313892


You can call into the ABP offices at 64, Marlborough Street, Dublin 1, D01 V902 or you can submit online at https://www.pleanala.ie/en-ie/observations

If you have any queries please phone ABP at 01 858 8100 or Lo-call 1800275 175


An Bord Pleanala,                                                                                                                                                                               64, Marlborough Street,                                                                                                                                                             DUBLIN, 1.                                                                                                29th August, 2022.

Ref No. ABP 313892   Blanchardstown to City Core Bus Corridor.

Dear Sir/Madam,

The Navan Road Community Council (NRCC) was set up in 1968 to help bring together community groups and sporting groups so that they would have one voice when trying to get things done in the community.

We enclose our fee €50.00.  Please acknowledge receipt.  

We also request, on behalf of our members, and many people who attended our recent Public Meeting – that  an Oral Hearing be held.   We are informed by the Board that there is no fee for this in a Strategic Roads Infrastructure project. 

The NRCC supports the Core Bus Corridor Projects. Nevertheless, we do have concerns about the possible negative impacts of this project on our Navan Road Community.  

Our submission to An Bord Pleanala (ABP) is to highlight our objections to aspects of the planning application submitted by the National Transport Authority (NTA) for the Core Bus Corridor (CBC) along the Navan Road, specifically our area of interest between The Parkway Railway Station and the junction of the Old Cabra Road with the North Circular Road (NCR), and the local communities surrounding same.

The NRCC wishes to contribute pro-actively in developing this project to the benefit of our community as well as positively benefiting the wider population who access the city via the Navan Road for work and leisure purposes. We do not wish to see, nor will we tolerate a negative consequence arising because of this project.

When the idea of a CBC was mooted some three years ago we formed a sub-committee to interact with the NTA to outline our positivity to the project but to also get fuller details and to outline our concerns . This sub-committee met with the NTA on a number of occasions. Our meetings were informative and constructive, with the NTA showing genuine interest in our issues. A specific example would be where, in our first meeting, the NTA indicated that the roundabout at The Halfway House Pub would be removed for the CBC. We argued that this roundabout was an important visual sign for motorists that they were entering a built-up suburban area and should slow down. We explained that speeding was a regular 

occurrence on the dual carriageway leading to the roundabout and that a removal of same would lead to a continuance through our heavily populated area. The NTA took our concerns on board and, at our next meeting on 13th February 2020, they assured us that the roundabout was to be retained within a signalised junction. At that point we felt that we could work positively with the NTA to develop the CBC in the interest of commuters and the city at large, while also protecting our local communities as best possible.

Alas that was to be the last meeting with the NTA as Covid intervened. Covid also hugely impacted on the ability of our sub-committee to meet. In recent times when we attempted to re-engage with the NTA we found them unable or unwilling to facilitate us. It was with frustration and some anger therefore when we saw the plans for the CBC as submitted by the NTA to ABP. We noted that the roundabout at the Halfway House was again totally removed in the latest maps, in spite of the NTA in 2020 agreeing with us that it be kept. On further examination of the application it seems clear to us that we simply had to object to aspects of the proposals, which surely would have benefitted by further interactions with community representatives like ours, as outlined below.

While the NRCC supports the Core Bus Corridor Projects, we and many other communities want to have an enhanced, efficient, modern, and clean transport system.

We want this CBC project to be a catalyst to develop:

  •  A more efficient transport system to convey the commuter, our elderly and disabled community, and visitors,  into and out of the wider city areas in an efficient and comfortable manner.
  • A fair and attractively priced fare structure.
  •  Safe and enhanced Cycle lanes and pedestrian paths.
  •  A new vibrancy in our neighbourhood with initiatives arising from the CBC project. We want this project to be the starting point for the rejuvenation of our Navan Road area and indeed the wider Blanchardstown to City Centre Core Bus Corridor 5.
  • A reduction in vehicular traffic that is currently impacting on the Air Quality, Noise and Traffic Safety- which should be attained if  the proposed new bus routes and infrastructure is correctly put in place. 
  • A tree lined Navan Road from the Parkway Railway Station to the NCR.

However, our support is not at any price. There are many concerns with the possible negative impacts of this project on our community. We would like to engage with the NTA to resolve our concerns and to make this project a success.   Our concerns and our proposals to make this project work to the benefit of our community and our city.


As a community, Navan Road Community Council (NRCC) held a public meeting at very short notice in our School Hall, Tuesday 16th October, 8.00 pm. which was full to capacity, with people arriving from 5.30 onwards to view the plans, with before/after pictures, purchased from the ABP.  Many were very shocked at the ‘After’ pictures lacking trees.     Many were unaware of any details, as the entire ‘public’ consultation process took place on line only,  disenfranchising all people not on internet,  – Trinity Study 2019  ‘TILDA’ on the impact on people lacking internet connection, and the disenfranchisement of all.   We had appealed throughout,  at Zoom meetings etc. NOT to hold the statutory stage to the Board during summer  (subsequently done from end June to end August) when both the public were on holiday, as are our elected public reps.  –  confirmed at our meeting as all our T.D.’s were away,  as were several of our Councillors. We invited all.

Before we deal with the specifics of the application lodged with ABP we wish to highlight the following very serious concerns,   which if not considered carefully, will lead to our Navan Road, being opened and re-opened over and over, for various utilities;  

UTILITY WORKS                  

The developer is unable to provide replacement trees in locations where established trees are to be removed due to the location of underground utility services, notably natural gas. These utilities were installed over 25 years ago and have limited life. They are nearing end of life and will need to be decommissioned in the coming few years. Natural gas networks are being decommissioned all across Europe in favour of district heating networks to meet stringent climate change commitments. By 2050 there will be no natural gas use by residential consumers in Ireland, so the gas network has a maximum remaining life of 27years. New trees will have a life of several hundred years, long after natural gas is no longer a fuel option in this area. It is therefore more important to get the trees in the right location, or keep them in their current locations,  and divert the utilities locally than to allow short-life utilities to restrict long term investment in green infrastructure. ABP should rule it inadmissible to use utilities as a reason to exclude tree planting, or remove existing trees,  and insist on local diversion of utilities to facilitate tree planting or retention of trees where a single utility is involved, especially where that is utility is limited life natural gas.

Furthermore, ABP should insist on the proposed district heating network be installed as part of the Bus Connects works,  to avoid doubling the inconvenience to residents and businesses by separate road opening events. This would facilitate the proper planning and development of the area by anticipating the inevitable switch from natural gas to low-carbon heat networks, which must be complete by 2035 (i.e in only 13 years time) in the Dublin area to meet our national carbon emissions targets. SEAI’s National Heat Study identifies the established residential communities along Navan Road as having a heating demand intensity which makes district heating cost optimal. The injection of hydrogen and biomethane (so-called ‘green gas’) into the natural gas network will not be financially or carbon-intensity viable until after significant surplus offshore wind generation capacity has been installed in Ireland, which will not be available before 2035 and will, therefore, arrive too late to justify retention of the natural gas network in Dublin. Redundant utilities should, therefore, not be allowed to determine where Ireland makes long-term investments in necessary green infrastructure. The developer should be required, by ABP CONDITION attaching to any grant of permission, to replace any trees removed with equivalent semi-mature trees of similar species in the nearest proximate location as a matter of planning policy and to relocate utilities, where necessary, to facilitate that planning.


The National Transport Authority (NTA) has proposed the removal of hundreds of street trees to facilitate this project. This is very evident from the Parkway Rail Station and along the Navan Road as far as the North Circular Road. We do not see an effort in the documentation to make our community one that has at its core the well-being of people and their economic lives.

We have identified at least 150 street trees to be removed to facilitate this project. There are also unquantified numbers of woodland trees to be removed.

CONDITION;   ONLY IF OUR STREET TREES ARE FORCIBLY REMOVED, against the wishes of the majority of our community; 

There is an opportunity to replant street trees in properly constructed tree pits that will still allow for the provision of cycle, public transport, and car lanes. The technology for this is available in other countries, e.g., Denmark, France, Germany, Britain and indeed in Ireland. These large tree pits (and they will have to be large) will be constructed to current European , and where it has been possible to plant trees in particularly challenging locations. There are a few examples in the Navan Road itself, of street trees that were previously planted into restricted tree pit sizes in pedestrian paths that have not grown properly as a result. What we demand is a recognized standard for tree pits to be used in the replanting of new street trees. This will include proper structural soil growing media for the tree roots, and protection for the hard surface above the root areas. 

PARK & RIDE FACILITIES – what the core bus corridor could do better.

Provide Park and Ride facilities at strategic locations with:-  Cheap or nominal fee, with regular bus service, and/or regular shuttle buses connecting to train stations and City bus services.  A comfortable enclosed shelter for the commuter waiting to make a bus connection, properly maintained and regularly serviced public toilets .  Clean, safe, and comfortable Café/Restaurant, with everything open at hours that will benefit the commuter.

What the Core Bus Corridor Proposes.

OLD CABRA ROAD  There is a proposal for a Bus Gate on this road.

Whilst this would seem to be a positive idea, the consequences of it may be to create new issues on at least four narrow roads in our area – Blackhorse Avenue, Baggot Road, Nephin Road, Skreen Road.    Motorists and other road users will use these roads to take short cuts (also known as “Rat Runs”) onto and from Blackhorse Avenue. This will result in congestion, danger to the young, the old, the disabled, pedestrians and cyclists and who must navigate narrow and busy road areas. 

We propose a CONDITION-   The Blackhorse Avenue Road is upgraded to make it fit for purpose for the commuter, the pedestrian, and the cyclist. 

The existing path should be reconstructed and widened;   it may be that the road is to become a one car lane direction road only  –   as a result of the NTA proposal to create a  NO ENTRY to Blackhorse Avenue, from the direction of Castleknock Road,  with a NO RIGHT TURN into the Phoenix Park at the Ashtown Gate entrance.      However, this will result in all the traffic entering on to the Navan Road (N3)  at the proposed new signalised junction at Ashtown,  instead of the existing roundabout.   AND, all traffic travelling  Blackhorse Avenue, from a Western direction to homes & business, will have to travel down along Navan Road, and then ‘rat run’ through Baggot Road,  turning right to go back up to the Western ends of Blackhorse Avenue.

NEW CABRA ROAD.   It is proposed that all vehicular traffic use this route into and out of the City.     At present, many people in our area try to avoid the 38A Bus service from Ashtown onwards, as its route is along New Cabra Road, where on a daily basis it comes to a stop, sometimes as far back as Clarkes Bakery area, and moves along slowly till it is well past Phibsboro, with 3 traffic light systems in place at the tailback area.    Adding to this is a proposal to introduce a right turn at St. Peters Church unto NCR,   which will surely add to the long tailbacks.    

On the way back from the City, on a daily basis,  the 38A Bus -destination Tyrrellstown comes to a stop at the Berkeley Road junction with NCR, for a minimum of 3, sometimes 4 traffic light changes.   There is also a tail back along NCR down to Dorset Street.      No. 122 from Ashington, with our Navan Road area, also uses New Cabra Road, via Cabra, but does not come out of City via Berkeley Road.

Enhancing the Environment of our area;

The proposed works to create the new Core Bus Corridor and the enhanced cycle lanes are welcome. There are however, two potential negative outcomes arising from the Core Bus Corridor works.

1. There will be an inevitable reduction in tree numbers and in many locations, as already mentioned above.  There is a current deficit of street trees due to previous infrastructure works – we have dealt with this above, see  Utilities;    This then impacts on the health of the community as well as the environment of the area.

2. The works that will be necessary to undertake the construction of new cycle and pedestrian path infrastructure will, as outlined in the NTA proposed works, necessitate the undertaking of remedial work in front gardens. We understand that this work will necessitate the rebuilding of the boundary walls and railings.


As confirmed in the Media earlier this week,  residents abutting the new runway at Dublin Airport have been awarded a Grant of approximately €20,000 each ‘to facilitate the insulation of their homes against night noise from the airport’

CONDITION;   we request a condition in any permission granted that a similar grant be proposed for all the homes along Navan Road  (approximately 220) who will have to endure noise all day long,  as well as certain hours throughout the night with the new night  time bus service.


CONDITION;    should be contained in any permission granted, that our Government Statutes on the rights and legal obligations to represent people with disabilities is honoured,  e.g.  relating to bus stops/dangers from cycle lanes intruding on the stops/bicycle racks erected in a dangerous fashion to become a danger to people with sight deficiencies. 

Core Bus Corridor and  DART + Maynooth electrification/to close all level crossings from Ashtown to Maynooth  both under NTA.

It is unclear from our non professional perusal of the copious documentation in both these current proposals,  what liaison, if any,  is taking place between both applications, and their applicant,   on the effects on our area and the wider Dublin 15 area from both plans,    i.e., throughout D.15 there are road diversions, claimed by locals to lead to even more car traffic to reach a train station, as well as proposal to make Ashtown Road a cul de sac at the former level crossing, cutting off pedestrian communities on both sides, i.e,  Ashtown/Navan Road areas and new area of Pelletstown  – with only a large footbridge to cross over, whilst car traffic to be directed into a tunnel UNDER Royal Canal, and UNDER rail lines, coming out at Ashtown, directly unto the Navan Road at the current roundabout site?

Any comments on the Junctions – lights etc. 

Proposed Island Bus Stops along Navan Road from Parkway to NCR

This raises serious concerns for pedestrians, elderly people, people with disabilities, wheelchair users and the visually impaired who will have to pass through the cycle lane making it dangerous and harder to see an oncoming bike or scooter,  electric or manual.

The major Bus Stops which we have concerns are

  1. Parkway out from town. 1000 school children attend new Edmund Rice school
  2. Ashtown Grove/Daughters of Charity, in/out. Provide services to persons with intellectual disability using buses to bring clients on trips to Blanchardstown Centre
  3. Our Lady Help of Christians Church, in/out. 1700 school children attend surrounding schools
  4. Nephin Road. Declan’s College Cabra, in/out. 650 school children attend

Condition: detailed analysis required that design suitable for bus stop capacity

Proposed Bicycle Stands along Navan Road from Parkway to NCR

This raises concerns that the bicycle stands are to near the bus stops and areas where elderly, infirmed, wheelchair, blind and impaired people use the bus service

Condition: detailed analysis required that design suitable for bus stop