O' Regan voices concerns for North Inner City residents due to Dart Underground plans
Issued: Sunday 15 August, 2010

Councillor Claire O' Regan (Labour) has drafted a submission to An Bord Plenala setting out her concerns regarding the proposed Dart Underground plan, and its impact on residents of the North Inner City.

Please see submission below, which will be delivered to An Bord Pleanala tomorrow.

CONTACT
Claire O' Regan
087 2817555

Dart Underground Railway Order

The Secretary
An Bord Pleanala
64 Marlborough Street
Dublin 1

15th August 2010

Re: Case Reference 29S.NA0005

Applicant: Coras Iompar Eireann
Development Description: Construct, operate, improve and maintain DART Underground railway line between Inchicore and East Wall, Dublin

Dear Sir/Madam

Please find enclosed the €50 fee.

I request an oral hearing and that the following be considered when making your decision:

Urban Context
East Wall is physically cut off from the city and its amenities to the North, South and West. This is to a large extent due to various elements of the national transport infrastructure, including the Port Tunnel to the north and the elevated railway lines to the west and south, which form physical barriers to the environment. While we acknowledge the physical importance of this infrastructure, it brings no direct benefit to the community of East Wall but rather separates the neighbourhood from its urban context, as well as being a source of noise, air and visual pollution.

My main concern is that the Railway Order Application will worsen these effects – causing additional blockages to our already limited access routes during construction, and additional noise, air and visual pollution during construction and later during operation when traffic on the railway line will be significantly increased - with no benefit to the community of East Wall.

This is another example of how East Wall has been ignored by the agents of forward planning in the city, who have failed to realise the area’s potential despite its advantageous location (in terms of proximity to the city centre). It is a missed opportunity of major significance to the residents of East Wall.

I request that an Bord Pleanala ensure that access to the proposed improved DART network from East Wall is provided in one of two ways – either by provision of a station for East Wall/North Strand or by a pedestrian bridge from Church Road to link the neighbourhood to the proposed Spencer Dock station.

East Wall/North Stand Station
The average distance between DART stations in the inner city is approximately 900m. The distance between the existing Clontarf Road station and the proposed Docklands station is more than 1900m. East Wall lies half way between these stations, but neither station is a comfortable walking distance from the neighbourhood.

The Railway Order Application includes a proposal to build an Operation Control Centre (OCC) at the half way point between Clontarf Road and Docklands stations. It is my understanding of the drawings that platforms will be in situ for emergency evacuation at this location. I submit that since construction (of the OCC) will be taking place at this location, with significant impact (noise, air, visual) on the residents of East Wall during construction, it would be appropriate and of benefit to the East Wall community to also build a station at this location.

I request that an Bord Pleanala enquire of CIE whether providing a station to serve East Wall/North Strand was considered. If not, why not? If it was considered and rejected, what were the reasons? Should it be that the construction of a station is technically feasible, we request an Bord Pleanala make this a condition of award of the Railway Order. Our own examination of the site in question had indicated that a station and the OCC can be accommodated in the land between the two elevated railway lines, together with a new public open space connecting North Strand and East Wall (this is an objective of the Dublin City Council Draft Development Plan 2011-2017 Chapter 4.4.5 page 33 – Public Realm).

Pedestrian/Cycle Link
Should the provision of a DART station serving East Wall/North Strand not b feasible, I request that an Bord Pleanala ensure that a bridge for pedestrians and cyclists be provided from the southern end of Church Road in East Wall over the railway enclosing line to give access to the proposed Docklands station..

Such a bridge was envisaged in an Area Action Plan for East Wall prepared by Dublin City Council in 2004 and is also indicated in the Dublin Docklands Development Masterplan 2008. Figure 5.1 of the Masterplan, page 119, Pedestrian Network, shows Church Road as the main pedestrian route in East Wall, with a link south across the railway line towards the Spencer Dock area. The Docklands Masterplan was reviewed by the design team for the Railway Order Application. However there is no proposal for the provision of such a bridge in the application.

At a public information event held by CIE in East Wall Community Centre in 2009, the representative of CIE was asked whether the Railway Order would include a bridge/link from Church Road to Spencer Dock (and the proposed Docklands station). CIE answered that this was not their responsibility and therefore had not been and would not be considered. I submit that this is poor planning and neglectful of CIE’s responsibility to the residents of East Wall who are expected to tolerate significant noise, air and visual impacts as a result of CIE’s existing operations and proposed developments, without any benefit in return.

I request that even if it is true that CIE has no responsibility to provide such a bridge/link, an Bord Pleanala make it a condition of the Railway Order that CIE enter into a partnership with the appropriate authority and provide funding for such a bridge/link from Church Road to the proposed Docklands station. I request also that an Bord Pleanala ensure that no impediments to the provision of such a bridge be created by the proposed works (the subject of the Railway Oder Application) ie that the development be designed to accommodate such a bridge in the future .

Chapter 24.2.2.13 of the Environmental Impact Statement (EIS) refers to the new operational control centre and car parking as perceived as part of the industrial character of the area reinforced by adjoining mainline and DART alignments and ‘as such’ will have a slight neutral impact on the landscape character.

It does not refer to the old residential area on the other side of the railway line which is not of industrial character and should be considered in any planning.

Noise.
At Volume 2, Book Four of Four of the EIS, Chapter 25.2.5.2 (‘Tunnel Boring Machines’) it states that there will be significant adverse effects on residential property at Inchicore and at non residential property at Marconi House, Gaiety Theatre and Grand Canal Theatre and therefore there is an obligation for the contractor to implement a mitigation strategy to reduce or remove, insofar as it is reasonably practicable, the adverse airborne noise effect at night time for residential property and during critical operational times (eg during a performance) for non residential property. There is no mention of a mitigation strategy for the East Wall area from where it appears there are now to be two boring machines starting simultaneously and therefore a mitigation strategy, at least, is urgently required. I would also suggest that this proposed boring should not be granted permission.

Access and egress for construction traffic for the proposed OCC and West Road will be from West Road, with, at peak, 134 daily two way HGV movements. It is proposed that part of West Road be closed. This will cause significant noise and inconvenience.

It is also proposed that working hours be from 7am-11pm Monday to Friday and 7am-3pm Saturdays, Sundays and Bank Holidays. This is relentless and excessive. As it is, the movement of trains can be clearly heard in properties all the way to Church Road, at least, if not further. The additional noise created by traffic and works will be unbearable for families who wish to sleep, especially with a window open. Chapter24.3.2.13 of the EIS states that the results of operational airborne rail assessment have indicated that with a proposed acoustic barrier, noise levels can be reduced at all assessed properties along both sides of the track to within acceptable levels and the residual impact is neutral to slight. It is incomprehensible that this might mitigate against significant additional noise where the noise is already significant even before the proposed works start.

I also request that steel not be used in the construction of the new railway bridge at West Road, as this would be very noisy (as evidenced by the nearby bridge over the Tolka), and not desirable in a residential area.

Community Liaison.
I request that CIE provide a 24 hour telephone number for residents in case of infringements of planning permission (eg construction outside of permitted hours). The contact person should have authority to order work be stopped, especially incase of emergency (eg structural damage to nearby properties). CIE should provide a weekly update to residents including, but not limited to, work done, the next phase, noise and dust emissions.

Yours sincerely

Councillor Claire O’ Regan
66 Seaview Avenue
East Wall
Dublin 3