An Bord Pleanála deny climate impact of new Dublin dual carriageway

— Board disagrees with its inspector who called design of planned road “outdated and unreflective of sustainable movement and place-making”.
— Inspector highlighted council data which shows road will increase emissions.
— Provision for cycling includes mixing with both pedestrians and motorists.

An Bord Pleanála’s board has rejected its own inspectors findings that a new dual carriageway planned to service new residential areas around Carrickmines, just outside the M50 in Dublin, will increase climate emissions, cause severance and increase car use.'s reader-funded journalism won't survive without your help. With over 762,000 views so-far this year, it's not just "avid cyclists" who read this website, but, if you want it to keep going, more support is needed from readers like you. Now, back to the article...

The Glenamuck District Roads Scheme, a project which aims to open up lands for development, which mainly includes the Glenamuck District Distributor Road and the Glenamuck Link Distributor Road. The former of which is made up of 660 metres of two-lane single carriageway and 890 metres of four-lane dual carriageway, and the latter is 1.8km of predominantly two-lane single carriageway road.

An Bord Pleanála said that the proposed roads would “not have an adverse impact on climate associated with improved car journey times or increased car dependency” — this is despite Dún Laoghaire-Rathdown County Council, who are proposing the scheme, having said at the project’s oral hearing that the project will increase emissions by 2,560 tonnes of CO2 by 2035.

A recently released written An Bord Pleanála order approving the Glenamuck District Roads Scheme claims that a dual carriageway, planned as an access route to the new residential areas, will “have significant positive effects on Population and Human Health” because the road will, it claims, provide for “shorter journey times”.

In 2003, when nearby controversial work on the M50 at Carrickmines was being approved, the then director of transportation at Dún Laoghaire-Rathdown County Council, Eamonn O’Hare, was quoted by The Irish Times as stating: “In Dundrum, Ballinteer, Sandyford there will be continued traffic chaos until the motorway is completed as planned.”

Fast-forward 17 years, the motorway has been built and widened. However, in 2018 it was reported that “M50 operating with traffic levels that weren’t expected until the mid-2020s” and last month “M50 traffic between 6am and 7am increases by 86% in five years“. Now “traffic chaos” on the M50 is a regular headline.

The An Bord Pleanála order — which is signed by Paul Hyde, the deputy chairperson of An Bord Pleanála on behalf of the board members — said: “The proposed road development would have significant positive effects on Population and Human Health in terms of the increased benefits in terms of shorter journey times and a reduction in traffic hazard for pedestrians and cyclists and other road users.”

The An Bord Pleanála board differed from its planning inspector, Donal Donnelly, who claimed in his report that the project would have adverse impact on human health and climate, with “improved car journey times and increased car dependency discouraging the use of more sustainable transport modes and impacting on the health and well-being of the local population.”

The planning inspector, referencing national policy and the Design Manual For Urban Roads and Street, went into detail on how the planned road is not conducive to enabling an active community and sustainable transport.

The inspector said that an alternative local system of roads serving the local area “may have the dual benefit of encouraging local trips by sustainable modes whilst minimising traffic flows to nearby strategic roads”. He said that the council’s Environmental Impact Assessment Report “does not assess the impact of such an alternative scenario”.

But the board said that it “considered that the provision of the improved road network and accessibility to public transport modes actively support sustainable modes of transport and the development of high public quality transportation systems.”

In its only apparent defence of the board denying the climate impact of the road, the board claimed that “the proposed road would not have an adverse impact on climate associated with improved car journey times or increased car dependency as the use of more sustainable transport modes is actively encouraged and facilitated through the proposed road” — this is despite both the council’s own data on an increase in climate emissions and the details provided by the inspector on the design of the road.

The boards’ order and direction documents both refer to the road as a “plan-led” approach. This is in contrast to the Inspector’s report which stated that: “It is acknowledged elsewhere in the EIAR (an Environmental Impact Assessment Report drafted for the council) that the road is being delivered in isolation as an infrastructural project and that the designers have no control over the phasing, layout, frontage or future boundary treatments of surrounding private developments.”

He also said: “Severance associated with distributor road design and the creation of barriers to cross movement, the development of separate communities and traffic speeds creating safety concerns for local community.”

The inspector said that to get to an “appropriate road design serving a sustainable community” that the project would “require extensive re-design and retrofitting of speed reducing features and crossing opportunities, together with a minimisation of junction capacity and the creation of more access points.” He said this “could not be accomplished unless the Board refuses permission or seeks substantive additional information in the form of an integrated land use and transportation masterplan setting out the basis for cross-movement throughout the scheme and LAP lands, with a clear prioritisation of sustainable modes under the Design Manual For Urban Roads and Streets movement hierarchy.”

Donnelly said: “Notwithstanding the desire of the applicant that the proposed distributor roads will be characterised as streets, I consider the proposed scheme before me suffers from ‘up-designing’ and an absence of ‘self-regulation’. I acknowledge that as the area develops and activity increases, there may be an opportunity for vibrant street environments to emerge. However, I consider that the proposed roads have been designed to standards in excess of their context and movement function.”

He quoted a section of the Design Manual for Urban Roads and Streets, which states: “…enabling greater capacity and vehicle flow based on excessive demand forecasts and/or the assumption that private vehicle usage will increase unabated.” The inspector said: “It is highlighted in Section 11.4 above that traffic modelling ensures that capacity is provided for traffic growth and the eventuality is more traffic congestion. It is also stated in Design Manual for Urban Roads and Streets that the continued assumption of growth in private vehicle usage is unsustainable and that a simpler, more integrated approach to road design can achieve advantages in terms of sustainability, place making and traffic movement.”

Donnelly said: “In my opinion, another evident effect of up-designing apparent with the Glenamuck District Roads Scheme is the overly prescriptive layout of junctions, which becomes necessary due to their size and capacity. The proposed junctions are of particular concern for cyclists. Most collisions involving cyclists occur at junctions and it is advised within the National Cycle Manual that cycling routes approaching, going through and exiting junctions should be obvious.”

He continued: “It would appear that cyclists approaching major junctions on the Glenamuck District Roads Scheme have the option of using on-road facilities or moving off-road to use ‘toucan’ crossing facilities. In my opinion, this may lead to some confusion for cyclists, motorists and pedestrians.”

“Notwithstanding the provision for pedestrians and cyclists at these junctions, they remain hostile and unsafe locations for these modes. Junctions are designed as major intersections, and this increases the risk of conflicts between pedestrians/cyclists and motorised traffic. Traffic can approach these major intersections with certainty and authority. This model of development in a neighbourhood context is outdated and unreflective of sustainable movement and place-making,” said Donnelly.

The inspector said that the road as planned will cut of the “potential for a direct link to the Ballyogan Luas Stop via The Park over a distance of approximately 830m”; that the roads, footpaths and cycleways are linear features devoid of cross movement opportunities which will create a barrier effect and reduce permeability; and that a number of pedestrian/ cyclist routes are indicated but there are no matching crossing points indicated.

On human health, Donnelly said: “The Environmental Impact Assessment Report makes the assumption that the proposed road infrastructure will not intensify the number of car journeys in the area in itself but will relieve congestion associated with the existing road network. This assumption may be accurate in the short-medium term; however, in the longer-term improved road infrastructure tends to result in traffic growth. Improved car journey times also has the effect of encouraging car usage, whilst discouraging more healthy, active and sustainable transport options. Thus, there may be adverse health effects associated with the approach of building more roads to address traffic congestion.”

On climate, he said, in the future, that increased motor traffic could be offset by low emission vehicles, but that “In the medium to longer term, however, I would be of the opinion that the proposed development will give rise to increase traffic and associated emissions that may have a nationally imperceptible but nonetheless cumulative impact on climate change.”

He said: “It was submitted on behalf of the applicant at the hearing that the proposed scheme will result in 4,855 tonnes of CO2 in the opening year of 2020 and 9,239 tonnes of CO2 in the design year of 2035. This represents a change of 701 tonnes and 2,560 tonnes of CO2 in 2020 and 2035 respectively compared with the ‘do nothing’ scenario with the existing road network.”

Donnelly said that he considers that the council’s Environmental Impact Assessment Report is “focused primarily on accommodating traffic growth and this in turn has informed the design of the proposed development”.



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