I have objected to the proposed Variation to the County Development Plan to bring a major new road through lands west of Malahide Road and from there parallel to the M50 motorway.  I also included a copy of my previous submission in 2006 which was ignored.

The Council management continue with a roads-first planning policy and are continuing to marginalise pedestrians, cyclists and public transport users.  The result of course, is more traffic, more congestion and more noise and pollution.

Particularly shocking is the fact that the Manager is claiming the power to put a proposed variation to the Development Plan on public display, without Council approval and indeed, despite the opposition of 6 out of the 7 local councillors.  Of course, we as Councillors do not have the resources to mount a legal challenge to this.

13th October 2008
Senior Executive Officer,
Planning Department,
Fingal County Council,
Main St.,
Swords,
Co. Dublin.

Re: SEA on Variation to Development Plan – Malahide Road/ East-West Distributor Road

A chara,

As you know, in September 2008, the Council approved the following recommendation from the Howth/Malahide Area Cttee.:

“That this Area Committee recommends that the Council direct the Manager to carry out a multi-modal transport study in relation to transport in the North Fringe/South Fringe area (Stapolin, Donaghmede, Balgriffin, Belcamp, Clonshaugh) with Dublin City Council’s co-operation if possible, to include consideration of the possibilities for a light rail link between the Dublin-Belfast railway line at Stapolin and the Metro in the vicinity of Ballymun/Dublin Airport and other possible rail links and to include consideration of roads, bus routes, cycling routes and walking routes in the area.”

This has not been done.

As you know, this proposed Variation has been put on display despite the opposition of the Howth Malahide Area Cttee.  The full Council were not notified of the proposed display.

As an elected representative I greatly resent being asked to make submissions in relation to a draft Variation which does not reflect the policy of the Council as agreed in 2006 and which is on display against the wishes of the local Area Cttte.

I attach below the submission I made to the last public consultation in relation to roads proposals in this area and which led me to proposing the above motion in relation to a multi-modal study.  Please also consider it to be part of this current submission.

In the time available and given other responsibilities, I have not had a chance to fully review the Environmental Report.  However, I have read through with an eye on two issues:

1.    Consideration of Alternatives
2.    Traffic and emissions impacts
3.    Piece-meal development

1.    Consideration of Alternatives.

No alternatives to car-oriented road design have been considered.  The alternatives such as a public transport only route which I brought forward for consideration in my 2006 submission (copy below) have been ignored.

2. Traffic and emissions impacts

Although traffic modelling and predictions have been carried out, they are not presented in the Environmental Report.  This is an unacceptable omission.

I was informed in the previous consultation that all traffic predictions in the area are based on a maximum 50% car share of modal split, something which no similar suburban area in Dublin achieves, even those with quality rail / light rail serving the entire area.  

The textual comments in the document appear to assume that traffic levels are independent of the provision of infrastructure.  This is not the case.  For a good overview please see Litman, T., Generated Traffic and Induced Travel, Victoria Transport Policy Institute, http://www.vtpi.org/gentraf.pdf

Similarly there are no emissions predictions in the Report.  It would appear that these haven’t been carried out.   It is quite straightforward to do outline emissions predictions based on traffic predictions.  This should have been done.  

I attach two reports from an EPA-funded research project by FEASTA, the Foundation for the Economics of Sustainability which cover aspects of SEA in the wider context of a Sustainability Assessment process, also at http://www.feasta.org/documents/epa_transport/ . Please see the sections on air and climate impacts in particular.

Induced traffic effects are of course of great consequence for emissions assessment.

3. Incoherent and piecemeal planning

The draft Variation shows part of a route which from previous discussions I know to be part of a planned Baldoyle to Blanchardstown Road which the Council’s Roads Department is proposing.  The Environmental Report shows the East-West Distributor Road leading to a minor road in the vicinity of the Airport. This is not what is intended and is fundamentally misleading.  The two sections of this road proposal should be considered and assessed together.

Is mise, le meas,

Cllr. David Healy